Wrangell Island Project FEIS - 1

Appendix B – Response to Comments on the Wrangell 

Island Project Draft Environmental Impact Statement

Introduction

Appendix B is the Forest Service’s response to comments received on the Wrangell Island Project Draft 

Environmental Impact Statement (DEIS).

Regulatory Guidance on Use of Public Comment

An agency’s clear and complete response to public comments should influence the structure of any 

comment analysis process. Council on Environmental Quality (CEQ) regulations provide clear guidance 

on both the intent of soliciting public comment and how comment should be used. These regulations 

require agencies to “assess and consider comments both individually and collectively” (40 CFR 1503.4).

Analysis and Incorporation of Public Comment

Agencies, organizations, and individuals submitted written comments on the Wrangell Island Project 

DEIS; the interdisciplinary team (IDT) thoroughly read and objectively analyzed all of the comment 

letters received. Letters from individuals and organizations were considered both individually and 

collectively, as many of the letters had the same or similar concerns. The comments were annotated and 

sorted by topic. The IDT completed responses to the annotated comments. Comments fell into two broad 

categories:

1. Comments within the scope of the project. Most comments within the scope of this project have 

been incorporated into the final EIS (FEIS) or analysis for the FEIS to the extent practicable. 

Some comments ask for clarification or additional information in the FEIS. Other comments 

requested certain information be considered, requested modification to an alternative, or 

suggested a new alternative altogether.

2. Comments outside the scope of the project. Many comments are addressed through Forest Plan or 

other direction. Some comments disagreed with the Forest Plan and other regulations decided at a 

different level, which makes them beyond the scope of this document. Comments that involve 

issues beyond the analysis area or speculation that does not involve reasonably foreseeable 

projects are also beyond the scope of this document. 

In addition to these categories regarding scope, comments are determined to be substantive or not 

substantive. Substantive comments raise specific issues or concerns regarding the project or the IDT 

process, within the scope of the project. Comments that expressed general support or opposition to the 

project were captured in the coding process, however, they express an opinion only, and they are not 

considered to be substantive.

The Forest Service received comments during the 45-day comment period following the publication of 

the Wrangell Island Project DEIS, from the Federal and State agencies, organizations, and individuals 

listed in table 1. The text, in its entirety, from Federal, State and local agency comment letters is included 

within the response to comments table in this appendix (table 2). All original comment letters are in the 

project record. 

In addition to those individuals listed in table 1, one form letter was submitted via email by 69 

individuals. The text of the form letter can be found in table 2. There were also two online petitions-style 

documents submitted in response to the DEIS. The first of these was submitted via MoveOn.org and had 
BAppendix

Wrangell Island Project FEIS ♦ 2

40 signers at the close of the comment period. The second was hosted by the non-governmental 

organization Alaska Wilderness League and had collected 13,340 signatures and 32 additional substantive 

comments at the close of the comment period. These additional substantive comments were extracted and 

analyzed. The text of these additional substantive comments can be found in table 2.

Table 1. Agencies, organizations, and individuals who submitted unique, substantive comments on the 

Wrangell Island Project DEIS

Name/Agency/Organization City, State 

(Country)

Comment 

Letter 

Number

FEDERAL AGENCIES

US Department of the Interior Anchorage, AK 059-DOI

Environmental Protection Agency Seattle, WA 063-EPA

STATE AGENCIES

Alaska Department of Environmental Conservation Juneau, AK 003-DEC

Alaska Department of Fish and Game Douglas, AK 036-ADFG

Alaska Department of Natural Resources, Division of Forestry Anchorage, AK 050-ADNR

TRIBAL GOVERNMENT

Wrangell Cooperative Association Wrangell, AK 062-WCA

LOCAL GOVERNMENT

City and Borough of Wrangell Wrangell, AK 054-CBW

NON-GOVERNMENTAL ORGANIZATIONS

Alaska Forest Association Ketchikan, AK 024-AFA

Alaska Wilderness League Juneau, AK 064-DK

Defenders of Wildlife Anchorage, AK 056-DOW

Greater Southeast Alaska Conservation Community, Cascadia Wildlands, 

Greenpeace, The Boat Company, Peter Branson, Center for Biological 

Diversity (hereafter, “GSACC et al”)

Sitka, AK 061-GSACC

Resource Development Council Anchorage, AK 023-RDC

Southeast Alaska Conservation Council & Wrangell Resource Council Juneau, AK 051-

SEACCWRC

Southeast Alaska Conservation Council, Wrangell Resource Council, 

Alaska Wilderness League, Audubon Alaska, Defenders of Wildlife, 

EarthJustice, Natural Resources Defense Council, Sierra Club, Women’s 

Earth and Climate Action Network (hereafter “SEACC et al”)

Juneau, AK 058-SEACC

Society of American Foresters Ketchikan, AK 025-SAF

The Nature Conservancy Juneau, AK 044-TNC

Trout Unlimited & Sitka Conservation Society Anchorage, AK 048-TUSCS

FORM LETTER AND PETITIONS

Form Letter 1 – Submitted by 69 individuals 099-FL1

Petition 1 – Signed by 40 individuals 097-P1

Petition 2 – Signed by 13,307 individuals 098-P2

UNIQUE LETTERS AND SUBSTANTIVE COMMENTS

Allen, E A Not stated 039-EAA

Allen, Elise Not stated 098-EA

Artley, Dick Grangeville, ID 035-DA
Appendix B

Wrangell Island Project FEIS ♦ 3

Name/Agency/Organization City, State 

(Country)

Comment 

Letter 

Number

Bechmann, Elisabeth Austria 038-EB

Bellagh, Rick Juneau, AK 017-RB

Bingham, Charles Not stated 098-CB

Bisschop, Peter Not stated 098-PB

Bistline, Pat Hope, ID 034-PB

Branson, Peter Wrangell, AK 046-PB

Brown, Zachary Gustavus, AK 027-ZB

Brown, Zachary Palo Alto, CA 097-ZB

Burnett, Rob Not stated 014-RB

Buslot, Chantal Belgium 043-CB

Campbell, Bruce Not stated 098-BC

Church, Nancy Not stated 098-NC

Cornelius, Michele Not stated 028-MC

Crabtree, Patricia Not stated 016-PC

DeBusman, Richard Copperopolis, CA 097-RD

DeBusman, Richard and Nancy Wrangell, AK 053-RND

Demerjian, Bonnie and Haig Wrangell, AK 029-BHD

Dugan, Linda Not stated 041-LD

Edain, Marianne Not stated 098-ME

Ely, Thomas Not stated 098-TE

Ewell Not stated 037-E

Fairweather, Susan Not stated 040-SF

Gross, Darrel Wrangell, AK 057-DG

Hart, Matthew Not stated 098-MH

Hartmann, Thomas Skagway, AK 060-TH

Hudson, Patrick Not stated 018-PH

Jackson, Evan Corvallis, OR 033-EJ

James, Wilfred Not stated 020-MJ

Johnson, Robert Not stated 007-RJ

Kirsch, Katya Haines, AK 008-KK

Koester, David P Not stated 011-DK

Kussart, Janet Juneau, AK 030-JK

Lezenby, Kathryn Not stated 098-KL

Lindekugel, Buck Not stated 097-BL

Loh, Nicole Not stated 052-NL

Lund, Leslie Not stated 098-LL

MacIntyre, Jordana Not stated 098-JM

Mackovjak, James Not stated 098-JM

Manderscheid, B Not stated 098-BM
BAppendix

Wrangell Island Project FEIS ♦ 4

Name/Agency/Organization City, State 

(Country)

Comment 

Letter 

Number

Manning, Cindy

Isla Santa Cruz, 

Galapagos, 

Ecuador

019-CM

Marvin, Malena Not stated 097-MM

Mary and Jeff Not stated 020-MJ

Meeks, Mark Bailey, CO 009-MM

Meister, Odile Wrangell, AK 026-OM

Metzler, Peter Not stated 098-PM

Mitchell, Michelle Not stated 098-MM

Montgomery, James Not stated 097-JM

Moore, Maureen E Juneau, AK 005-MM

Murray, Tim Wrangell, AK 047-TM

Neall, George M, III Not stated 022-GN

O'Brien, Diane Wrangell, AK 065-DO

Rak, David Wrangell, AK 042-DR

Renggaard, Line Not stated 010-LR

Sarles, Dan Boston, MA 031-DS

Sau, Tsang Not stated 045-TS

Scott, Gabe Not stated 097-GS

Simmons, Andrea Not stated 098-AS

Smith, Bruce Wrangell, AK 006-BS

Smith, Winston Juneau, AK 055-WS

Sorenson, Lena Tenakee Springs, 

AK 021-LS

Steitz, Jim Not stated 098-JS

Stewart, Sarah and Family Gardiner, MT 012-SS

Tanner, Charlotte Ward Cove, AK 013-CT

Terry, Anne Not stated 098-AT

Todd, Stephen Not stated 049-ST

Wade, Bruce Not stated 098-BW

Weil, Jesse Not stated 098-JW

Wolferman, Sondra Not stated 098-SW

Woodbury, George Not stated 032-GW

Zurcher, Naomi Not stated 098-NZ

This table lists only those who submitted unique, substantive comments, and does not list the 42 names signed to the MoveOn.org 

petition or the 13,307 names signed to the Defenders of Wildlife petition where unique, substantive comments were not added. Both 

petitions and all a list of all the signers for each, as well as each of the 69 copies of the form letter are in the project record.
Appendix B

Wrangell Island Project FEIS ♦ 5

In order to address all commenters’ concerns, the complete text of all comment letters received are 

included in table 2. The table consists of three columns, from left to right: comment number, text of the 

comment letter, the IDT response to the portions of the letters identified as substantive comments. While 

careful effort was made to preserve the text of the letters as they were received by the Forest Service, 

edits have occasionally been made, such as removal of footnotes, tables of contents, or complex tables or 

figures, to increase clarity and readability. Notes have been inserted when applicable, to indicate a change 

in the content of the letter. In some cases, paragraph breaks have been added to improve clarity of 

responses.

Appendix B

Wrangell Island Project FEIS - 7

Table 2. Response to comments

Comment 

Number Comment Response

001-KM Dear Forest Supervisor ,

I am writing to submitted my comments to USFS on the proposed Timber 

sale for approximately 65 mmbf on the remaining commercial timber on 

Wrangell Island. 

001-KM-01 First, I urge you to withdraw this sale. I don’t think any of the alternatives 

offered in this DEIS are viable. It is difficult to understand what the 

motivation for preparing this sale is. The proposed cuts are scattered 

around the island and it is hard to imagine who will bid on these areas. 

The costs of this sale to the taxpayers of the United states are far too 

high. The miles of new roads proposed in the logging alternatives would 

fall on the backs of US taxpayers, who should not pay for road building 

to clear cuts. Clearcutting should not be allowed in the Tongass and are 

not allowed in any other national forest.

Comment noted.

001-KM-02 The DEIS says that most of the proposed logging is planned to occur in 

the mixed age stands of timber. The largest of these is nearest to the city 

of Wrangell. Can it be that the citizens of Wrangell do not care what 

happens to wildlife and fisheries habitats in their back yards. 

Wrangell Island has already been decimated and this will finish it off. 

Sincerely,

Kathrin McCarhty 

414 3rd St Juneau, AK

907-635-0051

Comment noted.

002-MW-01 Regarding the Wrangell Island Project, I object to the alternatives that 

call for logging old growth on Wrangell Island to support local mills. The 

future of Alaska and the Tongass lies in its ability to support our 

fisheries, our tourism industry and the health of the planet. 

Comment noted. The Forest Service considers the timber 

industry to be an important part of a diverse economy for 

Southeast Alaska.

002-MW-02 Old growth temperate rainforests, disappearing everywhere, including 

Alaska, are a vital resource to the planet as the world warms. The value 

of these refuges is hard to determine now, but, since we know that the 

crisis is coming, we should not do business as usual as if this were the 

19th century.

Climate change is addressed in chapter 3 of the EIS. 

The Forest Service recognizes the value of old growth temperate 

rainforests and is committed to not only maintaining Southeast 

Alaska’s natural resources in perpetuity but is equally committed 

to doing its part to ensure that communities within and adjacent 

to the Tongass National Forest are economically vibrant.
BAppendix

Wrangell Island Project FEIS ♦ 8

Comment 

Number Comment Response

002-MW-03 The Alaskan mills that exist because of the subsidy of the federal 

government ought to be let fade away and the millions which are spent 

to prop them up in the name of “local jobs” would be better directed to 

assisting workers to transition to other work.

My preferred alternative is to not provide a single acre of old growth 

forest and, instead, to leave these vital areas to continue to support our 

fisheries and tourism industries and the health of our planet.

Sincerely, Margo Waring

11380 N. Douglas Hwy. 

Juneau, AK 99891

907-586-3155

Your support for the no action alternative is noted.

003-DEC THE STATE of ALASKA

GOVERNOR BILL WALKER

Department of Environmental Conservation

DIVISION OF WATER

410 Willoughby Ave., Ste 303

P.O. Box 111800 Juneau, AK 99811-1800 

Main: 907.465.5180

FAX: 907.465.5177

dec.alaska.gov

The Department of Environmental Conservation has reviewed the Draft 

Environmental Impact Statement (DEIS) for the U.S. Forest Service's 

proposed Wrangell Island Project. Specifically, this project proposes to 

harvest between 42.8 and 65.1 MMBF of timber from approximately 

3,184 to 5,309 acres, and to construct up to 17.2 miles of new National 

Forest System (NFS) roads, up to 16.2 miles of temporary roads, and to 

recondition up to 5.8 miles of existing roads, depending on alternative. 

All temporary roads would be decommissioned and 5.8 to 12.5 miles of 

new NFS roads would be closed to motor vehicle traffic upon completion 

of project activities. Associated with this project is the use of the existing 

permitted log transfer facilities at Pats Creek and Earl West Cove.

The DEIS identified Alternative 2 as the Forest Service's preferred 

alternative for this project. This alternative proposes to harvest 

approximately 65.1 MMBF of timber from an estimated 5,309 acres, and 
Appendix B

Wrangell Island Project FEIS ♦ 9

Comment 

Number Comment Response

would involve the reconditioning of 5.8 miles of existing roads, and the 

construction of 17.2 miles of new NFS road and 14.9 miles of temporary 

road. It also proposes to close 6.1 miles of new NFS roads and 10.0 

miles of existing roads after project activities are complete.

003-DEC-01 We are pleased to see the relatively large amounts of uneven-aged 

management prescriptions and helicopter yarding that were incorporated 

into each action alternative, as such prescriptions should minimize the 

potential for detrimental effects to soil and aquatic resources.

Thank you for your comment. The uneven-aged management 

prescriptions and helicopter yarding are designed to maintain the 

stand’s structure characteristics for scenic values and minimize 

the potential for detrimental effects to soil and aquatic resources 

while harvesting a portion of the stand’s timber. These 

prescriptions were designed to meet scenery standards and 

guidelines and maintain wildlife habitats.

003-DEC-02 The Tongass National Forest uses an analytical threshold of concern for 

cumulative watershed effects of 20 percent of watershed basin area 

consisting of young growth less than 30 years old. Watersheds at or 

exceeding this threshold may be experiencing increased peak flows and 

attendant sediment recruitment from stream channel erosion and bed 

scour. According to the DEIS (Table 60, page 161), none of the 24 7th 

level HUC watersheds in the project area currently exceed this threshold, 

with Watershed 19010209010304 and the McCormack Creek Watershed 

having the highest existing cumulative harvests at 18 percent and 15.5 

percent, respectively, Implementation of the Wrangell Island Project 

would increase the cumulative harvesting percentages above the 

threshold within these two watersheds and three others, depending on 

alternative. These include the following:

Watershed

Alt 1 

Harvest 

Since 

1984 

(%)

Alt 2 

Basin 

Area 

Harve

st

Alt 3 

Basis 

Area 

Harve

st

Alt 4 

Basin 

Area 

Harvest

Alt 5 

Basin 

Area 

Harve

st

McCormack 

Creek 15.50% 27.35

%

26.80

% 28.49% 25.00

%

19010209010

102 7.00% 29.34

%

12.92

% 12.75% 12.10

%

Kunk CreekFrontal 12.50% 23.59

% 0.00% 19.82% 19.30

%

Zimovia 

Strait-E Kunk 

Creek-Frontal

12.90% 18.60

%

15.10

% 23.70% 26.90

%

Please refer to the Aquatics Resource Report for a complete 

discussion of aquatic resources. The “Aquatics” section in 

chapter 3 of the FEIS contains updated numbers.

The Wrangell Island Project does predict increases in peak flow. 

McCormack Creek is predicted to have the largest peak flow 

increases. A field evaluation of McCormack Creek (appended to 

the Aquatics Resource Report) indicates that the nature of the 

channel (primarily bedrock and with high containment) would 

have little sediment recruitment and would be relatively resilient 

to increased peak flows. Most of McCormack Creek peak flow 

increases are due to past activities.
BAppendix

Wrangell Island Project FEIS ♦ 10

Comment 

Number Comment Response

Zimovia 

Strait-C 

19010209010

304 

18.00% 20.83

%

19.80

% 22.75% 19.80%

In addition, according to Tables 68, 71, 74, and 77 (DEIS pages 171-

175), predicted peak flow increases as a result of the proposed timber

harvesting and road construction within these watersheds are also

significant, especially within the McCormack Creek Watershed, which

shows predicted peak flow increases of greater than 22 percent under all

the action alternatives.

003-DEC-03 Given the increased level of harvesting that is being considered within

these watersheds, particularly within the McCormack Creek watershed,

channel condition assessments should be completed, not only for

determining existing channel conditions relative to the amount of timber

harvesting and road construction proposed for the Wrangell Island

Project, but also to establish a baseline for future monitoring. 

The Aquatics Resource Report appendix includes a report on the 

McCormack Creek watershed. 

004-HW-01 I oppose the USFS preferred alternative, as it is neither ecologically nor 

economically sound.

Your opposition to Alternative 2 is noted.

004-HW-02 I ask that instead, USFS adopt the “Small Mill and Wildlife Alternative”, 

submitted by the Wrangell Resource Council and SEACC in 2011.

Howard Whitaker

2041 Campton Circle

Gold River, CA 95670-8301

Please see response to comment 058-SEACC-05. 

005-MM To Whom It May Concern,

005-MM-01 I am writing today to insist that you consider the alternative plan, the 

Small Mill &Wildlife Alternative, submitted by the Wrangell Resource 

Council & SEACC for SUSTAINABLE logging on Wrangell Island.

Please see response to comment 058-SEACC-05.

005-MM-02 By your own estimations, all the alternatives considered in your current 

plans are economically infeasible & would result in old growth timber 

being logged WITHOUT the benefit of any value-added processing AND 

all the yellow cedar could be sold overseas.

Have we not learned anything after all these years? These trees are 

irreplaceable & Americans will be PAYING to log them & send them 

overseas! Get a grip people!

Please see response to comment 051-SEACWRC-07.
Appendix B

Wrangell Island Project FEIS ♦ 11

Comment 

Number Comment Response

Take another look, with open eyes this time around.

Maureen E. Moore

3320 Douglas Hwy

Juneau, AK

006-BS I am commenting on the proposed road closures on Wrangell Island. I 

was unaware of the original discussions back in 2007 or 2009 when the 

last closures occurred. I found out about the issue after hunting season 

began and I headed out to my long used hunting areas and could no 

longer realistically access those hunting areas because the roads were 

destroyed. It was a very big disappointment then and this new 

information I just learned about is just as bad. I also don’t own an ATV so 

the ATV only proposed roads are not much use for me, although many 

others I know will be able to use them.

For a little background, I use the existing logging roads for access to 

subsistence hunting of deer and moose. I also hunt grouse in the spring 

time. I have two boys that are just turning into teenagers and finally old 

enough to start out hunting. Wild game is a large part of our diet. These 

roads give access to hunting grounds that otherwise could not be 

reached, especially with children. Hunting on Wrangell is difficult enough 

and removing access to these side valleys makes it much more difficult. I 

don’t just drive the roads looking for animals, I use these roads to get me 

to starting points where I can hike in. I am familiar with many other 

Wrangell hunters that do the same thing, using these roads for hunting 

access to areas away from the main high traffic roads.

After your last road destruction process I lost hunting grounds for moose 

hunting. When moose hunting it is not a simple pack out like it is with a 

deer. Moose packing requires about four packs with a small moose and 

probably a couple more packs with a large moose. If you have to walk a 

mile up a painfully steep and water barred road only to hike another mile 

into the woods, not once but six times with a heavy pack, you can see 

why these areas are no longer realistic for moose hunting.

I have reviewed your proposed alternative road maps of Wrangell Island 

and will focus on what I am told is the preferred Alternative 2 map. 
BAppendix

Wrangell Island Project FEIS ♦ 12

Comment 

Number Comment Response

006-BS-01 My biggest concern that personally affects me, and several others, is the 

closing of the lower section of the 50024 (Lower Basin) Road. This road 

has been in place and used as a local hunting area since the 1980s, 

giving access to the south side of the valley. This road in use with the 

northern upper road (6263) is a large part of my hunting strategy in this 

area. Any game taken from the upper steep sided road or at the head of 

the valley can be packed out to this lower easier accessing road. This 

area is also a great place for hunting with younger hunters as the second 

road acts as a safety net. This is the only place on the island like this and 

destruction of either road will take these features away. I can also 

personally state that this road is used by people picking berries in the 

summer, by hunters looking for bear in the spring, by hunters in the fall 

looking for deer and moose, and also by local people looking for their 

season’s firewood stock. This road is only a few miles from the paved 

highway which also makes it appealing for us low budget subsistence 

hunters because it does not take as much gas to travel.

Thank you for your comment. Road 50024 was identified by the 

IDT as a hunting area, however, it was also identified as 

receiving little known use. Once the proposed unit is harvested, 

there is no need for near term administrative access. For of 

these reasons, the IDT did not recommend a change to the 

current objective maintenance level (ML 1, or closed). The 

Responsible Official will determine the objective maintenance 

level in his decision.

006-BS-02 I would also like to comment on the 50009 road. This is a road that I 

used to hunt from before the road was destroyed. Although I still hunt it 

to some degree, I can no longer realistically reach the hunting grounds I 

used to from the end of the road just because of the new starting point. I 

see that you have plans to open the lower half of the road to allow 

access to a new logging unit. I would like to see you leave this lower part 

of the 50009 road open to vehicle use after it has been fixed and used. 

This would make hiking into and hunting the upper area realistic again 

for not just deer and moose in the fall but also grouse hunting with 

children in the spring. Just this half a road will make a difference.

Thank you for your comment. The IDT did not identify road 

50009 as a hunting area, but did identify the road as receiving 

little known use. Once the proposed unit is harvested, there is no 

need for near term administrative access. For these reasons, the 

IDT did not recommend a change to the current objective 

maintenance level (ML 1, or closed). The Responsible Official 

will determine the objective maintenance level in his decision.

006-BS-03 I don’t really approve of closing access roads in general but these two 

roads are of importance to me and I would like your consideration in 

keeping these roads open for access. My observation of the current No 

Action plan and the proposed Alternative 2 is that other than the main 

road system, there will be very few remaining vehicle roads that take you 

away from the high use areas. And unfortunately because of that fact, 

my existing hunting areas will receive much more hunting use and 

pressure.

Comment noted. Alternative 1 would have 73.7 miles of open 

road while Alternative 2 would have 86 miles of open roads and 

14.5 miles of motorized trails. The additional accessible miles of 

Alternative 2, in combination with the different modes of travel, 

would help to disperse use.
Appendix B

Wrangell Island Project FEIS ♦ 13

Comment 

Number Comment Response

006-BS-04 I would also like to mention that if you can find a way to advertise these 

issues and meetings in a way that everyone can see them, that would be 

helpful. Of the few people I have spoken to about this issue, none of 

them had any idea road closures were happening.

Thank you for the opportunity to comment and I hope you give honest 

consideration about how your decision will affect my livelihood as well as 

the livelihood of many other Wrangell outdoorsman. 

Bruce Smith

Wrangell, Alaska

Thank you for your comment. Access management was 

identified early in the project scoping and public meetings. We 

advertised the availability of the Wrangell Island Project DEIS 

and its comment period via newspapers in Wrangell and 

Ketchikan, local radio, posted flyers, the project website (which is 

linked to from other Tongass National Forest pages), and direct 

mail and email. The open house (meeting) was advertised on the 

local radio station and newspaper. We are open to suggestions 

on how to effectively communicate with the public. 

007-RJ I am disappointed with the volume of the proposed alternatives, except 

"no sale.

007-RJ-01 Instead of cutting the rest of the old growth that supports a whole variety 

of uses on Wrangell Island, the Forest Serve ought to look at ways of 

integrating restoration activities and supplying timber off the existing road 

system to the small mills in the area.

Southeast should no longer rely on the timber industry as an economic 

driver. Thanks to the major reduction of timber harvest, the driving 

economic forces in Southeast AK are now fishing, tourism, Federal 

agencies, and recreation as well as traditional uses - folks going out and 

hunting and fishing to meet our own needs.

Your agency spends millions of dollars trying to keep a couple crews of 

loggers and equipment operators employed, when just a few decades 

ago it would have taken hundreds of folks to do the same amount of 

work. The effect of the actions of these few crews have a huge negative 

result on others livelihoods, including many of my friends and neighbors.

Thank you for listening.

Robert Johnson

Your comment is noted. The Forest Service considers the timber 

industry to be an important part of a diverse economy for 

Southeast Alaska and not incompatible with other economic 

uses of the National Forest. 

Also see response to comment 058-SEACC-05.
BAppendix

Wrangell Island Project FEIS ♦ 14

Comment 

Number Comment Response

008-KK Dear Mr. Dalrymple,

008-KK-01 The Forest Service’s Preferred Alternative for the Wrangell Island Timber 

Sale is unsustainable and not economical for Wrangell residents or the 

region. Alternative 2 proposes logging 65 million board feet of old-growth 

from 5,309 acres and bulldozing 32 miles of new road. The new roads 

will cost nearly $5.5 million dollars. 

According to the Forest Service’s own data, all the action alternatives are 

economically infeasible. That means that under every scenario 

considered the American public would be paying companies to log the 

ancient trees on Wrangell Island.

Please see response to comment 050-ADNR-04.

008-KK-02 Worse still is that 100 percent of Alaska Yellow Cedar will likely be 

exported without local processing. If the Preferred Alternative is selected, 

more than 10 million board feet of Alaska Yellow Cedar and nearly 5 

million board feet of Western Red Cedar could be logged and sent out of 

state or overseas without local, value-added manufacturing. 

Please see response to comment 051-SEACCWRC-07.

008-KK-03 The Preferred Alternative will damage the largest remaining block of 

intact old-growth on Wrangell Island above Rainbow Falls and 

Shoemaker Bay. This will significantly reduce deer habitat below the 

existing Tongass Forest Plan guideline of 18 deer per square mile to 

maintain sustainable wolf populations and human deer hunting. 

The “Wildlife Habitat” section of chapter 3 of the EIS and the 

Wildlife Resource Report discuss the effects of each alternative 

on deer and wolves. 

See response to comment 036-ADFG-07.

008-KK-04 Thoms Creek (VCU 4790) is the most productive salmon stream on 

Wrangell Island, supporting an important sockeye fishery. Logging oldgrowth in Thoms Creek makes no sense since it would be off-limits to 

logging under the proposed Amendment to the Tongass Land 

Management Plan, which is under review now and slated for 

implementation later this year. 

Please see response to comment 048-TUSCS-02.

008-KK-05 The Forest Service should instead select the “Small Mill and Wildlife 

Alternative” submitted by the Wrangell Resource Council and SEACC in 

2011. The citizen’s alternative proposal wouldn't require new roads and 

2 MMBF per year of timber would supply local mills:

• Ensuring a consistent, long-term supply of economic timber to 

small mills in Wrangell from small sales along the existing road system 

over a 30-year period

• Maintaining Wrangell Island’s deer population

• Integrating wildlife and fish habitat restoration, recreation, and 

stewardship activities into the project based on the “Good for Services” 

model

Please see response to comment 058-SEACC-05.
Appendix B

Wrangell Island Project FEIS ♦ 15

Comment 

Number Comment Response

Please start planning for a future that make economical and 

environmental sense for Wrangell and Southeast Alaska.

Katya Kirsch 

PO Box 521

Haines, AK 99827

009-MM-01 I am writing in opposition to the proposal for logging on Wrangell Island. 

The preferred alternative means loss of natural forests critical for our age 

as never before. The losses include that of animal habitat with 

consequent diminishment of wildlife. There are far better alternatives 

now not being pursued which would allow sustainable forestry and 

preservation of environmental resources there. I urge a different 

approach entirely, one that will protect and preserve our natural heritage 

while enabling careful economic activity. I strongly urge an orientation 

that takes seriously climate change and works with the future of human 

life in view. 

Sincerely, 

Mark Meeks

399 Blackbird Drive

Bailey, Colorado 80421

mkenosha@aol.com

Your opposition to the action alternatives is noted. 

010-LR-01 Drop the proposed unsustainable, money-losing alternatives that 

sacrifice the remaining old growth on Wrangell to support an exportdriven timber program.

Your opposition to the action alternatives is noted. 

010-LR-02 The Forest Service’s Preferred Alternative – Alternative 2 – proposes 

logging 65 million board feet of old-growth from 5,309 acres and 

bulldozing 32 miles of new road. The new roads will cost nearly $5.5 

million dollars. High road development costs means more old growth 

habitat must be clearcut to pay for the new roads.

According to the Forest Service’s own data, all the action alternatives are 

economically infeasible. That means that under every scenario 

considered the American public would be paying companies to log the 

ancient trees on Wrangell Island.

Please see response to comment 050-ADNR-04.
BAppendix

Wrangell Island Project FEIS ♦ 16

Comment 

Number Comment Response

010-LR-03 What’s worse is that current export policies allow 100 percent of Alaska 

Yellow Cedar plus up to 50 percent of the hemlock and spruce to be 

exported without local processing. If the Preferred Alternative is selected, 

more than 10 million board feet of Alaska Yellow Cedar and nearly 5 

million board feet of Western Red Cedar could be logged and sent out of 

state or overseas without local, value-added manufacturing. (See DEIS, 

Table 12 at p.66.) 

Please see response to comment 051-SEACCWRC-07.

010-LR-04 Without explanation, the Forest Service failed to consider at the “Small 

Mill and Wildlife Alternative” submitted by the Wrangell Resource Council 

and SEACC in 2011. The citizen’s alternative proposal wouldn't require 

new roads and would meter out up to 2 MMBF per year of timber to 

supply local mills:

• Ensuring a consistent, long-term supply of economic timber to 

small mills in Wrangell from small sales along the existing road system 

over a 30-year period

• Maintaining Wrangell Island’s deer population

• Integrating wildlife and fish habitat restoration, recreation, and 

stewardship activities into the project based on the “Good for Services” 

model

Please see response to comment 058-SEACC-05.

010-LR-05 Loss of More Important Deer and Salmon Habitat

The Preferred Alternative hammers the largest remaining block of intact 

old-growth on Wrangell Island above Rainbow Falls and Shoemaker 

Bay. This means significant reductions in deer habitat - a figure that 

already falls far below the existing Tongass Forest Plan guideline of 18 

deer per square mile. This guideline reflects the habitat needed to 

maintain sustainable wolf populations and human deer hunting. Under 

the Preferred Alternative, deer habitat capability will drop to 11.7 deer 

per square mile on national forest land by 2042. Loss of this much deer 

habitat promises future reductions in season length and/or bag limits on 

Wrangell Island. If you count on filling your freezer with deer hunted on 

Wrangell Island you may need to look for new hunting grounds in the 

future.

Please see response to comment 008-KK-03.
Appendix B

Wrangell Island Project FEIS ♦ 17

Comment 

Number Comment Response

010-LR-06 Thoms Creek (VCU 4790) is the most productive salmon stream on 

Wrangell Island; it supports an important sockeye fishery. All the action 

alternatives call for logging productive old-growth in Thoms Creek VCU 

even though this area would be off-limits to logging under the proposed 

Amendment to the Tongass Land Management Plan, which is under 

review now and slated for implementation later this year. 

Sincerely,

Line Ringgaard

Please see response to comment 048-TUSCS-02.

011-DK Hello,

Thanks for considering my input for the Wrangle Island Project.

I am a commercial fisherman in South East Alaska and was born in 

Alaska.

011-DK-01 I would like to see an end to all old growth logging in South East Alaska. 

No new roads and sustainable yield second growth logging only.

It is my view is that South East Alaska presents a unique and priceless 

ecosystem that should be left intact out of respect for future generations. 

I ask you to think for a moment ..in fact place your fingers on the globe, 

where there is intact wilderness left on this planet. If you do this, and you 

care about preserving intact wilderness then I think you will understand 

how precious and rare wilderness is. Now think back only 100 to 200 

years and think about the change in intact wilderness. You opinion is 

critical. I hope this perspective influences you.

No more old growth logging. No new roads

Thanks

Dave

David P. Koester

541-914-1555

Comment noted. 
BAppendix

Wrangell Island Project FEIS ♦ 18

Comment 

Number Comment Response

012-SS We are writing to comment on the the Wrangell Island Project draft 

environmental impact statement (DEIS).

The Forest Service’s Preferred Alternative – Alternative 2 – proposes 

logging 65 million board feet of old-growth from 5,309 acres and 

bulldozing 32 miles of new road. The new roads will cost nearly $5.5 

million dollars. High road development costs means more old growth 

habitat must be clearcut to pay for the new roads.

This is a shocking waste of public money and a shocking destruction of 

public land and trees.

012-SS-01 However, according to the Forest Service’s own data, all the action 

alternatives are economically infeasible.That means that under every 

scenario considered the American public would be paying companies to 

log the ancient trees on Wrangell Island.

Please see response to comment 050-ADNR-04.

012-SS-02 Meanwhile, without explanation, the Forest Service has failed to consider 

at the “Small Mill and Wildlife Alternative” submitted by the Wrangell 

Resource Council and SEACC in 2011. The citizen’s alternative proposal 

wouldn't require new roads and would meter out up to 2 MMBF per year 

of timber to supply local mills:

• Ensuring a consistent, long-term supply of economic timber to 

small mills in Wrangell from small sales along the existing road system 

over a 30-year period

• Maintaining Wrangell Island’s deer population

• Integrating wildlife and fish habitat restoration, recreation, and 

stewardship activities into the project based on the “Good for Services” 

model

This “Small Mill and Wildlife Alternative” protects fish and wildlife and 

respects the local residents.

Please see response to comment 058-SEACC-05.

012-SS-03 The Thoms Creek (VCU 4790) is the most productive salmon stream on 

Wrangell Island; it supports an important sockeye fishery. 

All the action alternatives under current consideration call for logging 

productive old-growth in Thoms Creek VCU even though this area would 

be off-limits to logging under the proposed Amendment to the Tongass 

Land Management Plan, which is under review now and slated for 

implementation later this year. 

All the alternative plans, except the non considered “Small Mill and 

Wildlife Alternative”, for the Wrangell Island Timber Sale are 

unsustainable and not economical for Wrangell residents or the habitat 

and the wildlife and trees.

Please see responses to comments 048-TUSCS-02 and 058-

SEACC-05.
Appendix B

Wrangell Island Project FEIS ♦ 19

Comment 

Number Comment Response

Please do not consider any of the current alternatives. They are not 

good. 

Please bring your attention to “Small Mill and Wildlife Alternative” 

submitted by the Wrangell Resource Council and SEACC in 2011 and do 

a responsible job managing Wrangell Island.

Thank you for your careful attention to our comments.

Sincerely, 

The Stewart Family, 

1045 Highway 89 S, 

Gardiner, MT 59030

013-CT Dear Forest Service:

013-CT-01 The way the Tongass is being logged is not working. I've lived here for 

50 years and every year the forest gets sparser and sparser. What's 

wrong with you people?????

They are not growing back as you have projected, any fool can see that. 

The clear cuts are NOT TEMPORARY MEADOWS!

I just returned from Sweden, granted the Swedes are not so happy with 

the way things are in their "crop" trees, but as far as I'm concerned it 

works a lot better than our bombed off land. Their animals have a place 

to live and they are able to log all the time. They replant and actually 

manage their trees. Take a look at what they do and stop destroying 

what we have.

Charlotte Tanner, PO 886, Ward Cove, Alaska 99928

Your comment is noted. Please see the “Silviculture” section in 

chapter 3 of the EIS. 

014-RB Dear Robert Dalrymple, District Ranger,

014-RB-01 I am disappointed that the Wrangell Island Timber Sale plan fails to 

recognize the true value of alternatives to industrial scale timber harvest 

management of the Tongass National Forest. The plan is uneconomical 

when considering the costs to tourism and recreation, commercial and 

subsistence fishing, hunting, and support of small local mills. As a former 

resident of Alaska and frequent visitor to the Tongass, I hope you will 

consider the benefits of a longer term and more sustainable plan for the 

Wrangell Ranger District.

Sincerely,

Rob Burnett

Comment noted. The Forest Service considers the timber 

industry to be an important part of a diverse economy for 

Southeast Alaska and not incompatible with other economic 

uses of the National Forest.
BAppendix

Wrangell Island Project FEIS ♦ 20

Comment 

Number Comment Response

015-JL-01 LEAVE THE OLD GROWTH FOREST...ALONE !!!!!!!!!!!!!!! Comment noted.

016-PC Dear sirs:

016-PC-01 It would be very helpful if you would hold to your promises of the last few 

years and make small projects of timber cutting available for the people 

of Wrangell. And make sure that the people of Wrangell will be involved 

in the timber cutting and processing for the goodness of their town. 

You and the timber industry should be interested in helping out the local 

industry. Do not bypass the people of Wrangell when they need your 

help so badly at this time. After all the trees you are going to cut are on 

their island. This would be in the best interest of everyone. Thank you 

for taking this into your immediate consideration. 

Sincerely, 

Patricia Crabtree 

The Forest Service recognizes the needs of the timber industry 

in Southeast Alaska, including the small operators. This project 

would provide opportunities for small operators. The Forest 

Service would continue to work with the City and Borough of 

Wrangell and the public during the implementation phase of the 

project. 

017-RB Dear sirs,

017-RB-01 Even if it were hugely profitable to cut down our old growth forest, I 

would be writing you asking not to allow our oldest trees to be cut down. 

Knowing that it costs the taxpayers of our country millions upon millions 

of dollars to do so makes me lose hope in our species. For the love of 

good sense and good management of this public resource , please do 

not allow this unsustainable timer sale to proceed.

Rick Bellagh 

Juneau , AK

Thank you for your comment. Your opposition to the Wrangell 

Island Project is noted.

Please see response to comment 050-ADNR-04.

018-PH-01 Please do the right thing for the people of Ak. The harvest should theirs 

not some foreign national.

Pat Hudson

Comment noted.

019-CM-01 Not sustainable, not economical!

I work every summer in the area...please don't do it!

Cindy 

><((((,°> <°,))))))€ 

Cynthia M. Manning 

Casilla 20.01.47 Pto. Ayora, 

Isla Santa Cruz, Galapagos, Ecuador 

Comment noted.
Appendix B

Wrangell Island Project FEIS ♦ 21

Comment 

Number Comment Response

Tel:011-593-9-94202923 (Ecuador from outside);

0994202923(Ecuador from inside): 

(USA) 001-206-557-8813

020-MJ For the past six years, the Forest Service has promised folks in Wrangell 

a timber sale on the island that will sustain rural prosperity, preserve and 

maintain forests, and provide an economically viable supply timber for 

the long-term. Instead, the Wrangell Island Project draft environmental 

impact statement (DEIS) proposes unsustainable, money-losing 

alternatives that sacrifice the remaining old growth on Wrangell to 

support an export-driven timber program.

The Forest Service’s Preferred Alternative – Alternative 2 – proposes 

logging 65 million board feet of old-growth from 5,309 acres and 

bulldozing 32 miles of new road. The new roads will cost nearly $5.5 

million dollars. High road development costs means more old growth 

habitat must be clearcut to pay for the new roads.

020-MJ-01 According to the Forest Service’s own data, all the action alternatives are 

economically infeasible. That means that under every scenario 

considered the American public would be paying companies to log the 

ancient trees on Wrangell Island.

Please see response to comment 050-ADNR-04.

020-MJ-02 What’s worse is that current export policies allow 100 percent of Alaska 

Yellow Cedar plus up to 50 percent of the hemlock and spruce to be 

exported without local processing. If the Preferred Alternative is selected, 

more than 10 million board feet of Alaska Yellow Cedar and nearly 5 

million board feet of Western Red Cedar could be logged and sent out of 

state or overseas without local, value-added manufacturing. 

Please see response to comment 051-SEACCWRC-07.

020-MJ-03 Without explanation, the Forest Service failed to consider at the “Small 

Mill and Wildlife Alternative” submitted by the Wrangell Resource Council 

and SEACC in 2011. The citizen’s alternative proposal wouldn't require 

new roads and would meter out up to 2 MMBF per year of timber to 

supply local mills:

• Ensuring a consistent, long-term supply of economic 

timber to small mills in Wrangell from small sales along the existing road 

system over a 30-year period

• Maintaining Wrangell Island’s deer population

• Integrating wildlife and fish habitat restoration, 

recreation, and stewardship activities into the project based on the 

“Good for Services” model

Please see response to comment 058-SEACC-05.
BAppendix

Wrangell Island Project FEIS ♦ 22

Comment 

Number Comment Response

020-MJ-04 Loss of More Important Deer and Salmon Habitat

The Preferred Alternative hammers the largest remaining block of intact 

old-growth on Wrangell Island above Rainbow Falls and Shoemaker 

Bay. This means significant reductions in deer habitat - a figure that 

already falls far below the existing Tongass Forest Plan guideline of 18 

deer per square mile. This guideline reflects the habitat needed to 

maintain sustainable wolf populations and human deer hunting. Under 

the Preferred Alternative, deer habitat capability will drop to 11.7 deer 

per square mile on national forest land by 2042. Loss of this much deer 

habitat promises future reductions in season length and/or bag limits on 

Wrangell Island. 

Please see response to comment 008-KK-03.

020-MJ-05 Thoms Creek (VCU 4790) is the most productive salmon stream on

Wrangell Island; it supports an important sockeye fishery. All the action 

alternatives call for logging productive old-growth in Thoms Creek VCU 

even though this area would be off-limits to logging under the proposed 

Amendment to the Tongass Land Management Plan, which is under 

review now and slated for implementation later this year.

(Mary & Jeff)

Please see response to comment 048-TUSCS-02.

021-LS For the past six years, the Forest Service has promised folks in Wrangell 

a timber sale on the island that will sustain rural prosperity, preserve and 

maintain forests, and provide an economically viable supply timber for 

the long-term. Instead, the Wrangell Island Project draft environmental 

impact statement (DEIS) dropped in our laps earlier this month proposes 

unsustainable, money-losing alternatives that sacrifice the remaining old 

growth on Wrangell to support an export-driven timber program.

The Forest Service’s Preferred Alternative – Alternative 2 – proposes 

logging 65 million board feet of old-growth from 5,309 acres and 

bulldozing 32 miles of new road. The new roads will cost nearly $5.5 

million dollars. High road development costs means more old growth 

habitat must be clearcut to pay for the new roads.

021-LS-01 According to the Forest Service’s own data, all the action alternatives are 

economically infeasible. That means that under every scenario 

considered the American public would be paying companies to log the 

ancient trees on Wrangell Island.

Please see response to comment 050-ADNR-04.

021-LS-02 Without explanation, the Forest Service failed to consider at the “Small 

Mill and Wildlife Alternative” submitted by the Wrangell Resource Council 

and SEACC in 2011. The citizen’s alternative proposal wouldn't require 

Please see response to comment 058-SEACC-05.
Appendix B

Wrangell Island Project FEIS ♦ 23

Comment 

Number Comment Response

new roads and would meter out up to 2 MMBF per year of timber to 

supply local mills:

• Ensuring a consistent, long-term supply of economic timber to 

small mills in Wrangell from small sales along the existing road system 

over a 30-year period

• Maintaining Wrangell Island’s deer population

• Integrating wildlife and fish habitat restoration, recreation, and 

stewardship activities into the project based on the “Good for Services” 

model

021-LS-03 Loss of More Important Deer and Salmon Habitat

The Preferred Alternative hammers the largest remaining block of intact 

old-growth on Wrangell Island above Rainbow Falls and Shoemaker 

Bay. This means significant reductions in deer habitat - a figure that 

already falls far below the existing Tongass Forest Plan guideline of 18 

deer per square mile. This guideline reflects the habitat needed to 

maintain sustainable wolf populations and human deer hunting. Under 

the Preferred Alternative, deer habitat capability will drop to 11.7 deer 

per square mile on national forest land by 2042. Loss of this much deer 

habitat promises future reductions in season length and/or bag limits on 

Wrangell Island.

Please see response to comment 008-KK-03.

021-LS-04 If you count on filling your freezer with deer hunted on Wrangell Island 

you may need to look for new hunting grounds in the future.

Comment noted. The 2016 Forest Plan, pages 3-686 through 3-

688 shows the distribution of the Wrangell Community use area 

and harvest numbers of deer. These numbers show that many 

residents already hunt in other areas, notably Zarembo Island. 

While the availability of deer on Wrangell Island itself cannot be 

guaranteed due to predation by wolves and bears, disease or 

heavy snowfall, there is a high probability that Wrangell Island 

will continue to provide deer for those that use the area. 

021-LS-05 Thoms Creek (VCU 4790) is the most productive salmon stream on 

Wrangell Island; it supports an important sockeye fishery. All the action 

alternatives call for logging productive old-growth in Thoms Creek VCU 

even though this area would be off-limits to logging under the proposed 

Amendment to the Tongass Land Management Plan, which is under 

review now and slated for implementation later this year. 

Please see response to comment 048-TUSCS-02.

021-LS-06 I am writing to tell the Forest Service, its current plan for the Wrangell 

Island Timber Sale is unsustainable and not economical for Wrangell 

residents or the region.

Lena Sorenson 

Tenakee Springs, Ak

Your opposition to the Wrangell Island Project is noted.
BAppendix

Wrangell Island Project FEIS ♦ 24

Comment 

Number Comment Response

022-GN-01 I am contacting you regarding the USFS's proposed sale of timber from 

Wrangell Island (link). I urge the USFS to not approve this project. It 

appears to be a lose-lose proposition for the public, the environment, 

sportsmen, commercial fishermen and the tourist industry.

Your opposition to the Wrangell Island Project is noted. 

Alternative 1, the no action alternative, would not implement the 

project.

022-GN-02 The only “winner” of this proposal seems to be the timber industry, who 

is being subsidized to enhance their profits. I did not realize that was the 

purpose of the USFS. I thought the mission of the USFS was: 

"To sustain the health, diversity, and productivity of the Nation's forests 

and grasslands to meet the needs of present and future generations." Its 

motto is "Caring for the land and serving people."

It seems to me that your motto has become “Caring for corporations and 

serving corporate wishes."

There appears to be no logical justification for approving this project. 

Comments I have reviewed from a number of other sources mirror my 

own assessment that this is an ill-conceived project. Alaska contains 

some of the most scenic, unspoiled wilderness area in the world. Why 

does the USFS seem so eager to despoil this by allowing massive 

timbering and mining projects to take place?

Thank you for your comment. Please see the Purpose and Need 

of the project, in chapter 1 of the EIS.

I had hoped to review the EIS and the USFS’s reasoning for their 

support of this project, but was unable to do so. When I try to access the 

EIS using the link on the USFS website, I get the message “Invalid 

Project”. How disappointing! Perhaps when (if???) you respond to this 

email you can provide working links to the EIS and other relevant 

information the USFS has? 

George M. Neall III

Retired P.E./Mining Engineer

(The website issue Mr. Neall refers to was a USFS-wide internet 

issue, which was resolved on July 5, 2016. Mr. Neall was 

contacted on receipt of his email and was provided with an 

update and the information he was seeking.)

023-RDC Resource Development Council

Growing Alaska Through Responsible Resource Development

July 14, 2016

Robert Dalrymple

District Ranger

Wrangell Ranger District 

Box 51

Wrangell, AK 99929 
Appendix B

Wrangell Island Project FEIS ♦ 25

Comment 

Number Comment Response

Dear Mr. Dalrymple:

The Resource Development Council for Alaska (RDC) is writing to offer 

its perspective on the Wrangell Island Project Draft Environmental 

Impact Statement (DEIS).

RDC is a statewide, non-profit, membership-funded organization 

comprised of individuals and companies from Alaska’s oil and gas, 

mining, timber, tourism, and fisheries industries, as well as Alaska Native 

corporations, local communities, organized labor, and industry support 

firms. RDC’s purpose is to encourage a strong, diversified private sector 

economy in Alaska through the responsible development of our natural 

resources.

023-RDC-01 While RDC appreciates the work the Forest Service has put into the 

Wrangell Island Project, we urge the agency to increase the supply of 

old-growth timber to the forest products industry until young-growth 

timber is more fully mature. Further, more work needs to be done to 

improve the economics of the project. 

Thank you for your comment. Your support for an increase in the 

proposed harvest of old-growth timber is noted. 

Please see project background information in chapter 1 of the 

EIS, and the discussion of inventoried roadless areas in chapter

3 of the EIS.

023-RDC-02 Such action will enhance the economy of Southeast Alaska and create 

much-needed jobs for local residents. A more balanced project can be 

achieved while protecting the environment, wildlife, and fisheries of the 

region.

Please see the “Project Purpose and Need” and “Issues”

sections of chapter 1 of the EIS, and discussions on timber 

economics in the “Timber Economics and Availability” section in 

chapter 3 of the EIS. All action alternatives comply with the 

Forest Plan standards and guidelines to minimize environmental 

effects. 

023-RDC-03 The Wrangell Island Project was originally intended as one part of the 

Forest Service’s pledge to provide a series of four ten-year timber sales, 

each with an annual volume of 15 to 20 million board feet (mmbf), to help 

meet its ten-year timber sale commitment under the 2008 Tongass Land 

Management Plan. As currently configured, the project no longer meets 

that objective. The project now appraises in a deficit timber sale mode, 

requiring modifications to address economic shortcomings.

Please see the Purpose and Need (chapter 1). The project no 

longer meets the criteria for a 10-year timber sale of 150 to 200 

MMBF because of a reduced suitable old-growth timber land 

base as described in the current Forest Plan, appendix A.

023-RDC-04 Extensive partial harvesting prescriptions will result in much higher 

logging costs and remove only the higher value trees to compensate for 

the high costs. This will leave residual timber stands with insufficient 

value to support future logging. Moreover, new trees growing in the 

shadow of the residual trees will be dominated by shade tolerant 

hemlock trees, reducing future stand diversity and value. Given the high 

Partial harvest is used to meet the Forest Plan scenic integrity 

objective while also maintaining wildlife habitat and allowing for a 

portion of the stand to be harvested. Also see response to 

comment 061-GSACC-12.
BAppendix

Wrangell Island Project FEIS ♦ 26

Comment 

Number Comment Response

cost of partial cutting, combined with the negative economics and 

impacts on those stands, the partial cut prescription is unwarranted. 

Furthermore, with three-quarters of the land already set aside in the 

project area, the partial cutting prescription should be dropped.

While helicopter logging is the most expensive of logging 

methods used in Alaska, it has been proposed in locations where 

roading and cable yarding are not feasible. It is also used to 

conduct partial harvest in areas where it is important to avoid 

ground disturbance in order to protect other environmental 

resources. Trees harvested by helicopter have to meet a certain 

timber value criteria in order to be economical. 

The partial-harvest prescriptions are designed to provide 

economical timber sustainably. The single-tree selection method 

of uneven-aged management would remove up to one-third of 

the stand’s live basal area at each cutting cycle. Retained cedar 

and spruce would be a seed source for regenerating trees in 

openings created by selective harvesting. When several trees 

are harvested as groups, larger openings would be created. 

More light reaching the forest floor would improve conditions for 

the less shade-tolerant species. Hemlock is and would continue 

to be a dominant species but the diversity of species will not be 

lost. Canopy openings will promote species diversity. 

Prescriptions are designed to maintain and promote cedar and 

spruce so future timber value opportunity would not be 

diminished.

023-RDC-05 Other elements of the plan severely compromising the economics of the 

project include viewshed prescriptions, which are unnecessarily 

constraining in an area that has had extensive logging over the past 60 

years. 

The Forest Plan establishes the scenic integrity objective in the 

project area by land use designation (pages 4-56 to 4-63). The 

partial harvest is designed to meet those scenic integrity 

objective.

023-RDC-06 These constraints, as well as strict adherence to the Roadless Rule, 

leaves only a quarter of the land within the project area open to timber 

harvesting, reducing the planned timber sale volume to 65 mmbf –

roughly a third of the originally planned volume.

The 2001 Roadless Rule and the Forest Plan define areas which 

can be harvested. See figures 2 and 3 in the FEIS.

023-RDC-07 The potential negative fish and wildlife impacts of the Wrangell project 

are overstated and 

Comment noted. All resource impacts are presented in chapter 3 

of the EIS, and discussed in their respective resource reports. 

023-RDC-08 the benefits of the sale are not even acknowledged in the DEIS. The economic benefits of the Wrangell Island Project are 

described in the “Timber Economics and Availability” section of 

chapter 3 of the EIS, including the amount of timber and 

employment opportunities created. Also see table 8 (Project 

employment and income utilizing the current export policy) and 

table 9 (Project employment and income utilizing 100 percent 

domestic processing) in the FEIS.
Appendix B

Wrangell Island Project FEIS ♦ 27

Comment 

Number Comment Response

023-RDC-09 Meanwhile, the market demand analysis for the project is inadequate 

and inaccurate. The analysis does not address the cost of accessing and 

harvesting young growth stands, 

The market demand analysis is assessed for the Tongass 

National Forest overall, and not at the individual project level. 

The Forest Plan Amendment FEIS market demand analysis for 

the planning cycle assessed the cost and value for young-growth 

timber.

Because there is no commercially usable young growth on 

Wrangell Island the Wrangell Island Project proposes the harvest 

of only old-growth or “bridge” timber, as described in the EIS. 

023-RDC-10 nor does it address the value of the young growth in both the domestic 

and export markets. 

Please see response to comment 023-RDC-09

Current values for young growth can be found in the Official R10 

RV Update Bulletin March 24, 2017 (on public 

website http://www.fs.usda.gov/detail/r10/landmanagement/r

esourcemanagement/?cid=stelprdb5335939) and in the project 

record, however, these values were not used in the project 

analysis since no young-growth harvest is proposed. 

023-RDC-11 In addition, projected timber harvest levels are too small to support an 

adequate economy of scale to support a competitive industry. 

Please see the purpose and need. The Wrangell Island Project is 

only one component of the Tongass Timber Sale Program.

023-RDC-12 Moreover, the assumption that the mills will make investments to enable 

them to process small volumes of young growth timber is flawed.

Industry investments in young-growth timber processing are 

outside the scope of this project.

Please note that the Wrangell Island Project doesn’t propose to 

harvest any young growth, as all the young growth in the project 

area is not yet commercially viable. For more discussion on 

young growth, refer to the Forest Plan Amendment FEIS. 

023-RDC-13 Furthermore, the market demand analysis falsely assumes private timber 

will be available to local sawmills and the projected level of private timber 

harvest is overstated. These and other issues, including road 

construction costs and silviculture concerns, are discussed in detail in 

the July 2016 comments of the Alaska Forest Association (AFA), which 

RDC endorses.

Comments on the development of the Tongass National Forest 

timber demand analysis are outside the scope of this project 

analysis. The AFA comments were addressed in appendix I, pp 

152 to 167 of the 2016 Tongass Land and Management Plan 

Amendment FEIS. 
BAppendix

Wrangell Island Project FEIS ♦ 28

Comment 

Number Comment Response

023-RDC-14 Given false assumptions, errors and shortcomings, the revised 

demand analysis should not be used to assist the Forest Service in 

meeting the Tongass Timber Reform Act requirements for estimating 

planning cycle demand for timber from the forest. As AFA outlined in 

its July 2016 comments, the volume of timber under contract if far 

below the level the Forest Service asserts is necessary to comply 

with the law and also far below the level necessary to sustain what is 

left of the forest products industry in Southeast Alaska.

Comments on the level of Tongass National Forest market 

demand are beyond the scope of this project. A discussion of 

how this project fits into the Tongass timber program is in the 

Wrangell Island Project FEIS, appendix A.

In conclusion, RDC appreciates the effort the Forest Service has put into 

the Wrangell Island Project, however, more work remains to be done to 

improve the economics of the project, including an increase in the supply 

of old-growth timber to industry.

Sincerely,

Carl Portman 

Deputy Director

024-AFA Alaska Forest Association

111 Stedman Street

Ketchikan, AK 99901

Phone: 907-225-6114

Fax: 907-225-5920

July 5, 2016

Robert Dalrymple, District Ranger

Wrangell Ranger District

PO Box 51

Wrangell, Alaska 99929

Dear Bob,

AFA Wrangell Island timber sale comments

Summary

• This project was initiated more than five years ago as part of an 

effort to honor the 2008 10-year timber sale commitment. As currently 

configured, this project no longer meets that objective.
Appendix B

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Comment 

Number Comment Response

• The project currently appraises deficit and changes must be 

made to address the economic shortcomings; otherwise much of the 

project cannot be implemented.

• The extensive partial cutting prescriptions will result in much 

higher harvest costs and removing only the higher value trees to 

compensate for the high cost will leave the residual timber stands with 

insufficient value to support future logging. Further, the new trees that 

grow in the shadow of the residual trees will be dominated by shade 

tolerant hemlock trees, thereby reducing the future stand diversity and 

value.

• The viewshed prescriptions are unnecessarily constraining in 

an area that has had extensive logging over the last sixty years. These 

constraints contribute to the poor economics of this project.

• The potential negative fish and wildlife impacts of this project 

are grossly overstated and the beneficial impacts are not even 

mentioned.

• The impact of adherence to the administrative roadless rule 

reduces the planned timber sale volume to a third of the originally 

planned volume. This contributes to the poor economics of the project 

and contributes to an ongoing violation of ANILCA and TTRA.

• The Demand analysis for this project is grossly inadequate and 

inaccurate.

The Alaska Forest Association (AFA) is a non-profit business association 

that was formed in 1957 to represent the interests of the timber industry 

in Alaska. The AFA currently manages a pension program, a group 

health insurance program, a scholarship program for the timber industry 

and also sponsors the Sustainable Forestry Initiative program for Alaska. 

We appreciate the effort that the Forest Service has put into this project 

and we note that the project was originally intended to honor the 2008 

commitment the Forest Service made to prepare a series of four 10-year 

timber sales, each with a total volume of 150 to 200 million board feet 

(mmbf). We also note that the State of Alaska raised a concern in its 

2011 Scoping comments that the project had declined in size from 185 

mmbf to 91 mmbf. Now the preferred alternative is even smaller; at 65 

mmbf it is just a third of the original proposed volume. This project no 

longer meets the intent of honoring the 2008 Forest Service 

commitment.
BAppendix

Wrangell Island Project FEIS ♦ 30

Comment 

Number Comment Response

024-AFA-01 Wrangell Island Project Economics

With very few exceptions, the timber sale projects prepared subsequent 

to the 2008 TLMP have been disastrously uneconomic. The two primary 

exceptions were the Logjam project and the Big Thorne projects on 

Prince of Wales Island. This Wrangell project can also be a financial 

success if a few basic issues are addressed. Failure to address the 

economic issues prior to completing the EIS will at best, result in only a 

partial implementation of the project.

Helicopter logging is very costly and the helicopters harvest timber at a 

very high rate. The logistics of helicopter logging include a large crew of 

specialists. The helicopter companies typically have to provide their own 

bunkhouse, cookhouse, fuel supply, maintenance, etc. This results in a 

very large mobilization that requires a minimum volume to amortize. 

Typically it takes 25 to 30 mmbf of harvest volume to justify mobilizing a 

helicopter logging operation to Alaska each year. Once in Alaska the 

mobilizations between logging sites requires about 5 to 10 mmbf 

depending on housing availability and cost, fuel availability, crew 

transportation needs and other logistics.

While helicopter logging is the most expensive of logging 

methods used in Alaska, it has been proposed in locations where 

roading and cable yarding are not feasible. It is also used to 

conduct partial harvest in areas where it is important to avoid 

ground disturbance in order to protect other environmental 

resources.

A single small or mid-size sawmill alone cannot meet the high cash flow 

requirement for a helicopter logging operation, so a significant portion of 

the helicopter production must be sold into the log export markets where 

log prices are high enough to justify the helicopter logging costs.

The future timber market conditions at the time of the sale would 

influence the successful bidder’s processing decisions. 

Currently, the timber sale could only be offered if the expected 

advertised bid appraised positively as defined by the 

Consolidated Appropriations Act of 2017.

Further, only about 20% of the trees in a typical stand of timber in 

Southeast Alaska is of sufficient value to justify helicopter logging, so if a 

purchaser is required to cut and remove a third of each partial cut stand, 

then the project will generally not be profitable. Perhaps a third of the 

basal area could be cut but only about 20% removed on the average.

024-AFA-02 Road Construction Costs

The DEIS indicates that the planned specified roads in the project area 

will cost $50,000 per mile more to construct than the temporary roads. In 

addition to converting some of the partial cut harvest units to clear cuts 

with lower cost conventional logging, the Forest Service should consider 

constructing most of the necessary logging roads in order to reduce the 

cost of these roads that are planned for closure when the logging is 

completed. If the agency is concerned about the design and construction 

of a few bridges or large culverts, those structures can be individually 

designed by the roadbuilder and approved by the agency prior to 

construction.

Road costs presented in the EIS are estimates based on 

historical costs. In general, a National Forest System (NFS) 

Road is a road needed for the long-term management of NFS 

lands. The use of these roads can be regular or intermittent with 

closures in between uses. Temporary roads are not needed for 

long-term management. The Forest Service policy is to 

decommission temporary roads.

Roads were determined to be NFS roads if they accessed more 

than one unit, opportunities exist for additional road construction 

beyond the planned road, additional harvest opportunities exist 
Appendix B

Wrangell Island Project FEIS ♦ 31

Comment 

Number Comment Response

along or beyond the planned road, or if the planned road was 

over a previously decommissioned road (multiple entries 

showing its need for management of NFS lands). 

Road construction costs would be kept to a minimum wherever 

possible.

024-AFA-03 Silviculture Concerns

Partial cutting of old growth timber should be limited to higher elevation 

slopes where the timber can be accessed only by helicopter logging. In 

order to offset the high cost of partial cutting, only higher value timber 

can be removed and most or all of the hemlock trees will be left and 

consequently the residual stand will have less valuable timber on the 

average. Further, the understory that grows in the stand over time will 

also be heavily dominated by hemlock. The result will be a stand of 

timber that will have very low value and very little diversity. The 

increased browse from the initial partial cutting will not last nearly as long 

as the low value, hemlock dominated timber. This is not a good longterm outcome for the timber or the wildlife.

Partial harvest is proposed where other harvest methods are not 

practicable or to meet resource objectives. The partial cutting 

prescriptions would remove up to 33 percent of the existing live 

basal area. Trees eligible for removal would have to be a certain 

size to be considered economically viable in today’s market. 

Trees that are not large enough to be economically viable today 

but have potential timber value are crop trees for a future entry. 

Species diversity would be maintained and might be enhanced 

with increased light reaching the forest floor. Here is an excerpt 

from Robert Deal’s dissertation titled, The Effects of Partial 

Cutting on Stand Structure and Growth, and Forest Plant 

Communities of Western Hemlock-Sitka Spruce Stands in 

Southeast Alaska, “Sitka spruce was maintained over a wide 

range of cutting intensities, and conversion to hemlockdominated stands generally did not occur. It appears that 

silvicultural systems that use single-tree selection or small 

openings can be successful for timber management purposes in 

Southeast Alaska. Concerns about changing tree species 

composition, lack of spruce regeneration, greatly reduced stand 

growth and vigor, increased dwarf mistletoe infection in hemlock 

trees, and higher incidence of tree wounding, decay, and 

mortality with partial cuts were largely unsubstantiated. Stand 

structural diversity, species richness and understory plant 

abundance were all greater in partially cut stands than in younggrowth stands developing after clearcutting.” (Deal, 1999)

024-AFA-04 Visual Concerns

There are a number of partial cuts with 33% removal indicated along the 

west coast of Wrangell Island, presumably as a result of the viewshed 

prescriptions. Realistically, these partial cuts will end up either looking 

like mange or even worse if the result is a lot of blowdown. The high cost 

of partial cutting combined with the negative economics and negative 

impacts on those stands in the future should be adequate reason to drop 

The Forest Plan limits visual impacts resulting from timber 

harvest in sensitive scenic areas. The partial cutting prescription 

is designed to meet the scenery and wildlife habitat objectives 

while also providing some timber volume. 
BAppendix

Wrangell Island Project FEIS ♦ 32

Comment 

Number Comment Response

the partial cut prescription in those areas where conventional logging is 

possible.

The DEIS indicates that timber harvest is allowed on only a quarter of 

the land within the project area. With three-quarters of the land already 

set-aside it seems unnecessary to include partial cutting prescriptions, 

especially given that the DEIS indicates that the project is not fully 

economic when those costly prescriptions are included. The Forest 

Service provided the TetraTech economic analysis of the 2008 TLMP 

and that analysis indicated that only 3,351 acres within the project area 

would be economically viable given the TLMP constraints, and that was 

before re-imposing the administrative roadless rule on the Tongass. 

024-AFA-05 Fish and Wildlife Impacts

There are many references in the DEIS about past logging and impacts 

to fish and wildlife habitat, but realistically fish returns have increased 

dramatically since logging commenced on the Tongass and game levels 

remain high in most previously harvested areas. 

Comment noted. The analysis used the most recent available 

information.

024-AFA-06 The State of Alaska allows plenty of hunting opportunities on Wrangell 

Island including annual harvesting of two black bears, two deer, one elk, 

one moose, one wolverine and five wolves per person.

Comment noted.

024-AFA-07 Roadless Rule impacts

The DEIS states that the project does not include timber harvest within 

the 2001 Inventoried Roadless Areas even though the roadless rule is 

the primary reason that the project has been delayed for many years and 

is now planned at only a third of the original volume. We understand that 

the Forest Service must comply with the whims of the changing federal 

administrations, but at a minimum, the agency should acknowledge the 

cost impact of the reimposition of the roadless rule as well as the impact 

that re-imposition had on the dependent timber industry and local 

communities; both now and in the future (at least until the roadless rule 

is again rescinded and the timber supply restored).

Comment noted. The 2001 Roadless Rule is outside the scope 

of this project analysis, and the effects were analyzed for the 

Tongass National Forest prior to the decision on the Roadless 

Rule. 

024-AFA-08 Demand for Timber

The February 14, 2011 State comment letter for this project stated “The 

State of Alaska is concerned that the proposed Wrangell Island Project, 

combined with all other Tongass National Forest projects currently 

underway, will not meet the USFS’s obligations under the 2008 Tongass 

Land Management Plan (TLMP or Forest Plan) or the Tongass Timber 

Reform Act (TTRA) of 1990. Section 101 of the TTRA directs the USFS 

to seek to meet the annual and planning cycle demand for timber from 

the Tongass National Forest”.
Appendix B

Wrangell Island Project FEIS ♦ 33

Comment 

Number Comment Response

The Wrangell DEIS states “Timber harvest under the action alternatives 

would contribute to meeting projected market demand for timber in 

Southeast Alaska and support logging and sawmill or export jobs” and 

“Economic effects are analyzed in the 1997 Forest Plan FEIS, 2003 

Forest Plan SEIS, 2008 Forest Plan Amendment FEIS and most recently 

in the analysis for the 2015 Forest Plan Amendment DEIS.” 

However, neither the 2003 SEIS nor the 2008 FEIS anticipated the 

impacts of the re-imposition of the agencies roadless rule and the 2015 

DEIS attempts to justify another reduction in the demand level area 

mockery. The planning cycle section of the 2015 Transition DEIS states 

that an annual demand for the next five years will average 46 mmbf of 

which 22 mmbf will be old growth and 24 mmbf will be young growth, but 

the agencies own annual demand calculation states that the volume 

necessary to comply with the law (TTRA) is 146 mmbf and that volume is 

for the sawmills, which are currently dependent upon old growth timber 

only.

Comment noted. The timber market demand analysis is outside 

the scope of this project analysis.

Information on the 2017 annual timber demand has been 

disclosed in the Wrangell Island Project FEIS, appendix A. This 

annual demand is based on the planning cycle demand as 

discussed in Daniels, et al. used for the 2016 Forest Plan 

Amendment analysis.

024-AFA-09 We carefully reviewed the draft, revised PNW demand analysis that the 

Forest Service relied upon in the 2015 TLMP DEIS. The authors of this 

revised demand analysis state “The Pacific Northwest Research Station 

has been asked to assist planners in meeting the TTRA requirement for 

estimating planning cycle demand for timber from the Tongass.” 

Unfortunately, the November 2015 Transition DEIS makes a number of 

bad assumptions and erroneous conclusions, many of which refer back 

to this revised demand analysis as the source. Based on personal 

communication with lead author Jean Daniels, the AFA is not surprised 

by the flaws in the draft demand analysis on which the Forest Service 

rests so many of its conclusions. Inexplicably, the draft demand analysis 

was prepared without input from the State of Alaska or the timber 

industry in Southeast Alaska, even though the industry and the State are 

key participants in the market. Further, in a short-sighted effort to meet 

an arbitrary agency deadline rather than allow for a thorough and 

accurate analysis, the Forest Service required submission of the draft 

demand analysis before it was complete. Had the Forest Service truly 

been interested in a factually accurate demand analysis, it would have 

allowed its staff to complete their analyses, which might have rectified 

some of the following shortcomings which permeate the draft demand 

analysis and render it misleading at best.

Comments on the demand analysis are outside the scope of this 

project analysis. The comments on Daniels, et al. demand were 

addressed in the 2016 Forest Plan Amendment FEIS, appendix 

I, pages I-152 through I-167.

See the Wrangell Island Project FEIS, appendix A for the 2017 

annual market demand and how this project fits into the Tongass 

timber program.
BAppendix

Wrangell Island Project FEIS ♦ 34

Comment 

Number Comment Response

Here are some of the errors and shortcomings in the revised demand 

analysis:

024-AFA-10 1. The cost of accessing and harvesting the young growth stands is not 

assessed. Other than a few significant blocks of young growth, most of 

the young growth stands are small and widely scattered and just the 

mobilization into each of these stands will make the harvest economics 

difficult. In addition, the current and proposed TLMP standards and 

guidelines will result in further fragmenting the blocks into even smaller 

parcels and thus further increasing the cost of harvesting. No significant 

effort to adequately inventory the young growth and analyze these 

impacts has been made, but it is apparent to those of us who are familiar

with timber harvest logistics that most of the young growth proposed for 

early harvest will be uneconomic. Just the fact that the trees will be cut 

long before they reach maturity means that the volume of timber per acre 

will be reduced by more than half. Further, many of the road systems 

that initially accessed the stands have been closed and will require 

extensive, costly reconstruction.

Comment noted. No young-growth harvest is proposed in the 

Wrangell Island Project, therefore this comment is outside the 

scope of this project.

024-AFA-11 2. The value of the young growth on both the domestic and export 

markets is not addressed. Export values for logs fluctuate more than 

domestic lumber prices in part because they are impacted by foreign 

exchange rates and foreign trade policies. Domestic lumber values for 

the low grade products that can be produced from small logs vary 

primarily with the US housing market. Alaskan sawmills can only sell to 

the domestic lumber market profitably if they manufacture and transport 

their lumber to market for less than the value of the lumber. In order to 

compensate for the low value of construction lumber, new small log 

sawmills typically rely on extreme high production rates and a proximity 

to both their timber supply and their markets. The high production, small 

log mills that are currently being constructed in the US are in areas that 

have an abundance of young growth timber available and those mills are 

very close to their customers. A high production small log mill in SE 

Alaska would have to rely on an inadequate and uncertain timber supply 

from the current Forest Service timber sale program and the mill would 

be at a further competitive disadvantage to small log mills that are closer 

to their customer. In 1992, the Irland Report1 explained “In SEA, the 

economics of processing depends on the cost levels of harvesting wood 

on the level of the uncut volume under contract, on the security of new 

supplies, and on the ability to obtain enough wood to operate facilities at 

high operating rates during market peaks. At present, TNF can fulfill 

none of these requirements.” This is why the mills in Southeast Alaska 

have concentrated on higher value products from the mature, old growth 

Please see response to comments 024-AFA-09 and 10.
Appendix B

Wrangell Island Project FEIS ♦ 35

Comment 

Number Comment Response

timber. As one option to utilize a very small volume of small logs from 

commercial thinning operations, the Viking mill managers suggested that 

they might be able to ramp up to 8 or 10 million board feet of small logs 

over a period of years, but only if they could maintain full operations of 

their old growth sawmill and customer base. The old growth harvesting 

under that scenario would allow the Viking sawmill to subsidize the small 

log operation. Without the old growth timber the Viking mill could not 

afford to saw the small, 60-year old young growth trees.

024-AFA-12 3. The projected timber harvest levels are too small to support an 

adequate economy of scale to support a competitive industry. The timber 

industry in Southeast Alaska has lost its economy of scale and much of 

the infrastructure that once allowed it to be more competitive. We used 

to have many logging and sawmill operations, but now there are very few 

and as a result every aspect of the timber business is less efficient and 

more costly. For instance, the lack of a regional logging equipment 

dealer in Southeast Alaska was mentioned at one of the Forest Service 

Tongass Advisory Committee meetings. We spoke with Modern 

Machinery in Washington State and they explained that they would have 

to have about $1.25 million in business each month in order to have a 

successful dealership located in our region. Working with our loggers, we 

estimate that roughly 300 million board feet of logging and related road 

construction would be needed to generate the monthly business level 

that Modern Machinery says is the minimum necessary to sustain a 

regional equipment dealership. This is more than double the regional 

harvest level anticipated by this revised demand analysis.

In its 6/23/92 report Irland explained that “there is no market demand for 

Alaska timber or end products. There is a regional and world market for 

softwood logs of varying levels of quality, for chips, for lumber, and for 

dissolving pulp. Alaska’s share of these markets, even when viewed only 

in terms of hemlock and spruce, is small. So Alaska is a pricetaker on a 

huge market” and “There is a local demand for logs and for local 

processing. The future of that demand depends on the local processing 

industry’s competitive position in its end use markets. In turn, that 

competitive position is strongly affected by the conditions of wood 

supply.” Without a reliable supply of timber and an adequate economy of 

scale, the local mills are not able to compete with facilities in other 

regions that have those advantages and thus the private timber is 

economically unavailable to the local mills. To compensate for the 

decline in the economy of scale, the surviving mills have been able to 

remain competitive by manufacturing high value products, but these high 

Please see response to comments 024-AFA-09 and 10
BAppendix

Wrangell Island Project FEIS ♦ 36

Comment 

Number Comment Response

value products cannot be sawn from 60-year old hemlock and spruce 

trees.

024-AFA-13 4. The assumption that the mills will make investments to enable them to 

process small volumes of young growth timber is a faulty assumption. 

The document assumes that “existing mills will make any machinery 

upgrades necessary for the young growth transition, but rates of 

utilization may fluctuate”. This is a very poor assumption. A competitive 

small log sawmill will cost upwards of $100 million and will require more 

small logs to furnish it than can be sustained on the existing young 

growth acreage on the Tongass. For instance, a small log mill in 

Arkansas is currently being upgraded at a cost of about $190 million and 

will have an annual capacity of 387 million board feet. Another new mill 

being upgraded in Florida will cost about $130 million and will produce 

up to 700 million board feet. A similar small log sawmill is planned for 

Shelton, Washington. It is expected to employ 150 to 200 workers and 

will utilize about 200 million board feet of logs annually. 

However, the entire 462 thousand acres of Tongass young growth would 

sustain less than 150 million board feet annually if harvested at about 

age 60; and that ignores the impossible economics of such an endeavor. 

Yet, the Forest Service preferred alternative in the draft TLMP 

amendment proposes to manage only about 260 thousand acres of 

young growth and if harvested prematurely, as currently proposed, the 

agency estimates that the maximum young growth harvest will be only 9 

million board feet during the first ten years and then slowly ramping up to 

a maximum of 88 million board feet after 23 years! The upper limit of 88 

million board feet is less than the volume necessary to sustain even a 

single competitive small log sawmill and the high cost and low value of 

these small logs will reduce the amount of economically available young 

growth to a level far below 88 million board feet, making it impossible to 

ever amortize the investment necessary to construct a new small log 

sawmill. 

Please see response to comments 024-AFA-09 and 10

024-AFA-14 5. Private timber is incorrectly assumed to be available to the local 

sawmills and the projected level of private timber harvest is overstated. 

The revised demand report relies in part on an assumption that private 

timber harvests are currently about 61 million board feet annually and 

will increase to about 80 million board feet over the next 15 years. 

However, the only significant private timberland owner still harvesting 

timber in the region is Sealaska and they have explained that their 

maximum sustainable harvest rate is only about 45 million board feet per 

year for the next 25 years. Further, Sealaska has indicated they would 

like the opportunity to bid on an additional 20 million board feet of timber 

Please see response to comments 024-AFA-09 and 10.
Appendix B

Wrangell Island Project FEIS ♦ 37

Comment 

Number Comment Response

annually to improve their own economy of scale. In addition, page 3-267 

of the EIS indicates that the Forest Service is in the process of acquiring 

22,890 acres of private land at Cube Cove. This action will further reduce 

the amount of private timber available in the future. Since the two State 

Forests in Southeast are already selling timber at their maximum 

sustained yield, the only source of additional timber for Sealaska’s 

operations is the Forest Service. The future volumes of timber from 

private lands are greatly overstated and since the timber from these 

lands is not subject to export restrictions, that timber will not be 

economically available to the local mills anyway. Instead the private 

timber will most likely be sold to mills in regions that have economic 

advantages like proximity to customers, lower energy costs, larger pools 

of skilled workers and much larger economies of scale and 

infrastructure.

024-AFA-15 6. Wood-based energy products are unlikely to be economic and the 

utility log projections in scenario-2 are grossly in error. The document 

states that the efforts to promote biomass energy products invalidates 

the prior demand assumptions – “Scenario 2 builds upon Scenario 1 by 

adding markets for wood energy products based on the assumption that 

30 percent of existing heating fuel use in Southeast Alaska would be 

replaced by wood based fuel over time”. Actually, it is government 

subsidies that are driving the demand for biomass energy. Without the 

subsidies, the biomass businesses will likely not be profitable. Further, 

these subsidies will not affect the demand for wood products; this is 

another supply cost issue. “When the government provides a supply-side 

subsidy to the producers of a product, the supply curve shifts to the right 

and the demand curve remains the same”. 

A good example of the false economy associated with biomass energy 

subsidies is the collapse of the California biomass to energy industry. 

About half of the facilities that had been operating in California have 

closed since the ratepayer subsidies ended. Now the biomass industry is 

seeking a replacement subsidy from the California cap-and-trade 

program.

The economics of wood-based energy products in SE Alaska are 

marginal even with the extensive subsidies and incentives that are 

available from time to time. Planning a business or a regional economy 

that relies on continued subsidies and incentives is very risky decision. 

Wood-based energy in the interior Alaska makes more sense primarily 

because of the low moisture content of the timber in that region. The 

timber supply constraints in Southeast Alaska effectively limit woodbased energy to the sawmill residuals and most of those residuals are 

Please see response to comments 024-AFA-09 and 10.
BAppendix

Wrangell Island Project FEIS ♦ 38

Comment 

Number Comment Response

already being utilized. Also, the document states that higher (heating) 

fuel costs invalidate the prior demand assumptions, but fuel costs in 

Southeast Alaska have declined over the last year and a half. This 

assumption is invalid.

The projected utility log harvest for scenario-2 (Table-18) are grossly in 

error. Utility spruce and hemlock logs comprise only about 15% of the 

forests in Southeast and adding cedar utility logs might raise that total to 

17%, but even at 17% utility it would take a total harvest level of over 

500 million board feet to produce the Table-18 projected volume of utility 

logs. We had that level of harvest for many years and were able to utilize 

the utility logs and sawmill chips at our local pulp mills and we did so 

without any subsidy or incentives. A similar scenario based on real 

economics rather than federal subsidies would be more likely to 

succeed.

024-AFA-16 7. Artificial supply constraints do not lower the demand for timber or 

timber products. The document states that this revised demand analysis 

is needed because the Forest Service decided to restrict the supply of 

old growth timber. This artificial restriction does not reduce the demand, 

but rather limits the supply. A reduction in supply shifts the supply curve 

to the left. It is a shift in price that moves demand left or right along a 

supply curve. Although the restriction of timber supply has forced the 

closure of several mills, the revised demand analysis assumption that 

the demand for timber and timber products is less due to the restrictions 

on the timber supply are incorrect.

Prior to a Congressional deficit timber sale prohibition the agency 

regularly advertised timber sales that were grossly deficit and would 

have bankrupt any purchaser that made the mistake of purchasing such 

a timber sale. Consequently, many of those timber sales received no 

bids. The Earthjustice graph in Figure 1 of the revised demand analysis 

compares the various Forest Service demand estimates to the volume of 

timber harvested. This false allegation that the harvest level is declining 

due to a lack of demand is one of the primary reasons that Congress 

enacted the prohibition on advertising deficit timber sales.

As a friend once explained, there is a large demand for $5 

cheeseburgers, but not much demand for $20 cheeseburgers. The 

revised demand analysis already explains that environmental groups err 

when they try to equate timber harvest with timber demand. The revised 

demand analysis attributes the supply constraints to federal budgets and 

NEPA issues, but fails to acknowledge that Forest Service self-imposed 

standards and guidelines for its timber sale program have greatly 

increased the cost of harvesting timber sales. These high costs are the 

Please see response to comments 024-AFA-09 and 10.
Appendix B

Wrangell Island Project FEIS ♦ 39

Comment 

Number Comment Response

primary reason the agency has been unable to prepare economic timber 

sales.

As Irland explained, “the future position of the supply curve is far from 

certain, as it is subject to influence by the Forest Service, the courts, and 

the Congress. Indeed, the ASQ and the Standards and Guidelines, and 

the offering area schedule to be set in the TLMP Revision process, will 

determine the supply curve in many respects not only as to level but as 

to costs.” In 2007 for instance, the agency prepared an economic 

analysis of the pending TLMP revision. That analysis predicted that the 

agency would be able to prepare economic timber sales from only about 

20% of the so-called suitable, available timber in the revised plan. 

Inexplicably, the agency adopted the flawed plan anyway and the result 

has been the enormous reduction in timber sale volume that could be 

harvested and manufactured profitably. Until the agency makes changes 

to correct the economic shortcomings in its land management plan, the 

economic problem will persist. It has nothing to do with demand.

The revised demand analysis section entitled Changes to Alaska’s 

Forest Sector and Table 3 both point out that the surviving mills in 

Southeast Alaska are operating well below their capacity. The document 

does not explain that this is due to the constrained timber supply, not a 

lack of demand. For instance, Viking lumber managers, have repeatedly 

told the Forest Service that they would like to purchase more timber 

sales because their customers have additional capacity and Viking wants 

to more fully utilize their mill. By the way, the document mischaracterizes 

the Viking sawmill as a “large lumber mill”. The Viking mill is a mid-size 

mill. Large mills typically produce in excess of 100 million board feet of 

lumber annually.

This section of the revised demand analysis also includes a non sequitur 

remark about potential monopolistic influence of a single surviving 

sawmill. The Forest Service manages some 85% of the land in the 

Southeast region and thus has monopoly power of its own. A decision by 

the Forest Service to halt old growth timber sales before there is 

sufficient young growth timber to sustain a viable manufacturing industry 

demonstrates real monopoly power. The only other significant owners of 

old growth timber are the State and one private landowner. The best way 

to avoid these issues is for the Forest Service to provide sufficient timber 

supply to sustain a viable timber manufacturing industry. That was the 

intent of the TTRA market demand provision.

024-AFA-17 8. Log export versus local manufacture policies. The bulk of the federal 

timber program has long been dedicated to providing year around 

manufacturing jobs, but there will not be sufficient volume or value in the 

Please see response to comments 024-AFA-09 and 10.
BAppendix

Wrangell Island Project FEIS ♦ 40

Comment 

Number Comment Response

young growth stands to support small log manufacturing facilities until 

these young growth stands reach maturity at about age 90. Even the 

Nature Conservancy’ 2009 Transitioning to Young Growth report 

acknowledged that that the Forest Service would have to subsidize the 

logging in order to enable profitable harvesting of 60-year old trees in 

Southeast Alaska. While exporting some of the young stands to the 

Pacific Rim might be economic from time to time, that log export activity 

will not help the industry transition to young growth manufacturing and

will actually delay any economically viable transition to a young growth 

manufacturing industry because it will postpone the date at which young 

growth stands in Southeast Alaska start reaching maturity. Log export 

markets pay a higher price than the local mills can afford because of the 

federal supply constraints that increase harvest costs beyond what the 

manufacturer’s competitors pay for timber. The current, temporary policy 

of allowing up to 50% of the federal timber sale volumes to be exported 

helps compensate for the high logging costs and thus allows local 

manufacturers to operate profitably and continue to provide year around 

jobs.

024-AFA-18 9. National forest log exports from Alaska are not new and they do not 

lower demand for timber. The document states that the entry of Tongass 

sawlogs into international export markets invalidates prior demand 

assumptions. Actually, Tongass cedar sawlogs have been sold into 

international export markets for many decades and from time to time 

hemlock and spruce sawlogs from the Tongass have also gone into 

export markets. The more recent increase in hemlock and spruce log 

exports from the Tongass was intended to capture some higher values in 

order to compensate for the artificially high cost of harvesting Tongass 

timber and also to compensate for the loss of the mills that could 

profitably manufacture products from the small, rough, low-value 

sawlogs. The temporary log export policy does not lower the demand for 

timber from the Tongass.

Please see response to comments 024-AFA-09 and 10.

024-AFA-19 Given all these errors and shortcomings, this revised demand analysis 

should not be used to “assist planners in meeting the TTRA requirement 

for estimating planning cycle demand for timber from the Tongass”. We 

urge the Forest Service to make a greater effort to increase the supply of 

old-growth timber available to the industry. Currently the volume of 

timber under contract is far below the level the agency asserts is 

necessary to comply with the law and also far below the level necessary 

to sustain event the few surviving members of the timber industry in 

Southeast Alaska.

The amount of old-growth timber within the alternatives was 

constricted in part by the definition of suitable old-growth forest 

(Forest Plan, appendix A), Forest Plan LUD allocation, what was 

needed to meet the Forest Plan standards and guidelines, and to 

respond to the NEPA guidance for a range of alternatives.
Appendix B

Wrangell Island Project FEIS ♦ 41

Comment 

Number Comment Response

Thank you,

Owen Graham

Executive Director

Alaska Forest Association

025-SAF Dixon Entrance Chapter

Southern Southeast Alaska

June 28, 2016

Robert Dalrymple, District Ranger Wrangell Ranger District

P.O. Box 51 Wrangell, AK 99929

RE: Wrangell Island DEIS 

Dear Mr. Dalrymple;

The Dixon Entrance Chapter of the Society of American Foresters is 

providing the following comments on the Wrangell Island Draft EIS:

025-SAF-01 Considering the tight supply of readily available and positively appraised 

USFS timber in southeast Alaska, it is encouraging to see that the Forest 

Service has selected Alternative 2 as the "proposed action" for this EIS. 

It allows the commercial harvest of 65 million board feet of timber while 

adequately protecting other resources considered in the Forest Plan. 

However, we do have a couple of qualifying comments concerning the 

DEIS.

Thank you for your comment. Your support of Alternative 2 is 

noted. 

025-SAF-02 There is a very large portion of the prescribed acreage that is designated 

as uneven-aged management (partial harvest} that will no doubt be 

predominately helicopter logged. In fact, 66% of the total project acres 

are designated for this type of harvest. 

What is the long term management goals for areas designated by this 

logging prescription? As we know, partial cutting does not allow for the 

rapid regrowth of young trees that is typical of clearcuts in Southeast, 

while the Forest Service is beginning the initial phases of their 

"transitioning to young growth" program. These partial cut acres, then, 

cannot be counted on to help meet the future base acreage needed to 

help maintain a sustainable young growth harvest program. 

The long-term management goals for stands with uneven-aged 

silvicultural prescriptions are to maintain old-growth structure 

characteristics that benefit wildlife and maintain scenic integrity 

objectives while harvesting a portion of the stand’s timber on a 

sustainable basis. These stands are expected to be available for 

future harvest entries.

Is it the Forest Service's intent for these areas to eventually be removed 

from the commercial base? 

Stands located outside of the T77 watersheds and The Nature 

Conservancy/Audubon conservation priority areas priority 

watersheds (2016 Forest Plan ROD, p. 7) and within 

development LUDs remain classified as suitable and available 
BAppendix

Wrangell Island Project FEIS ♦ 42

Comment 

Number Comment Response

for old growth harvest and would be managed in accordance 

with the underlying LUD and the 2016 Forest Plan Amendment 

ROD.

Or perhaps put them on a 200 year rotation in order to allow sufficient 

regrowth to occur before re harvest? 

The uneven-aged silvicultural system does not have a rotation, 

but rather cutting cycles that are used to maintain a desired 

stocking level, as well as three or more age classes and multiple 

stories, i.e. old-growth structure characteristics. The unevenaged system is also a regeneration method, meaning it is used 

to regenerate trees. Small openings in the canopy would be 

created and new trees would regenerate in these openings. 

Trees that were not harvested this entry would then release –

adding sufficient regrowth in future years. These are the crop 

trees. 

It seems that perhaps the intent of providing a sufficient future supply of 

feasible young growth timber would be better met by allowing more 

clearcut acres now, and less partial cuts, into the final Wrangell Island 

timber sale program.

Partial harvest was proposed only where clearcutting was not 

economically practicable or would not meet other resource 

objectives. Alternative 2 would harvest 1,781 acres using the 

clearcutting, converting these acres to young growth available for 

future management. 

025-SAF-03 Secondly, the 65 million board feet designated in Alternative 2 will be 

meted out in both "large and small sale" over a 10-year span. At best, 

then, and even if ALL of the designated volume was sold under a large 

sale format, which equates to only 6.5 MMBF per year. That small 

amount of annual volume makes it very difficult, if not impossible, for an 

operator to economically mobilize men and equipment onto Wrangell 

Island for an amount of volume that can realistically be logged in a 

matter of 2-3 months, and then repeat this procedure for a number of 

consecutive years. Hopefully, the Forest Service has considered this and 

will make a large portion of the 65 MMBF available in one or two 

individual timber sale offerings so as to maximize the economy of scale 

for mobilization.

The Wrangell Island Project is considered a “bridge” timber 

project that would harvest old-growth timber to maintain the 

region’s timber industry as it transitions from an industry based 

on old-growth timber to an industry based on young-growth 

timber.

The Tongass timber program strives to offer a variety of sale 

sizes to support the various capabilities of timber purchasers in 

the region. The Wrangell Island Project would provide 

opportunities for a variety of different size timber operations.

025-SAF-04 Finally, to help make ANY sizable timber sale offering from the Wrangell 

Island appraise positive, and especially since it's well removed from the 

most likely successful bidder, Viking Lumber on Prince of Wales Island, 

there needs to be due consideration given to a suitable proportion of 

exportable timber from the sale area as well. Although this amount does 

not have to be the majority of the volume, it should be appropriate to 

help cover the high cost of transporting the logs to Prince of Wales for 

manufacturing.

Thank you for the opportunity to comment on your proposed project.

Comment noted. The Wrangell Island Project used the current 

export policy in its analysis, as described in the “Timber 

Economics and Availability” section of chapter 3 of the EIS. 

Timber from the Wrangell Island Project would be offered under 

the export policy in place at the time of the sale. Also see the 

Timber Economics Resource Report.
Appendix B

Wrangell Island Project FEIS ♦ 43

Comment 

Number Comment Response

Sincerely,

Stan McCoy

Chapter Chair

026-OM Dear Robert Dalrymple, 

026-OM-01 I am disappointed that the Forest Service is not proposing an alternative

that is similar to the “Small Mill and Wildlife Alternative” submitted by the 

Wrangell Resource Council and SEACC in 2011. Such an alternative 

would be more beneficial to the local community as it would provide a 

smaller but steady source of timber over the next 30 years for our local 

mills.

Please see response to comment 058-SEACC-05.

026-OM-02 It also would use the existing road system and would be less likely to 

disrupt Wrangell Island’s deer population and other wildlife. So many 

people here in Wrangell depend on being able to hunt deer locally and 

don’t always have the resources to hunt on other islands. 

I firmly believe that any proposal needs to be of benefit to the local 

community. Please strongly consider providing an alternative that 

supports Wrangell’s economy and protects its wildlife.

Odile Meister

Stikine Strings

P.O. Box 2247

Wrangell, Alaska 99929

907-305-0479

Effects on wildlife habitat and subsistence harvest is discussed 

in chapter 3 of the EIS.

027-ZB Hello,

My name is Zachary Brown, and I am a resident of Gustavus, Alaska. 

027-ZB-01 I am writing to voice my strong objection to the current plan for the 

Wrangell Island Timber Sale. This sale is a continuation of the 

antiquated mentality of "getting the cut out" without any regard for 

community, subsistence, fisheries, or tourism values, the new economy 

of the Tongass.

Your comment is noted. 

027-ZB-02 It is far beyond time to stop the large-scale clear-cutting of old-growth 

forest for export in the round. This is not only ecologically devastating --

it is economically infeasible, with the American taxpayer PAYING to cut 

the ancient trees of Wrangell Island. This is simply indefensible. There is 

Comment noted. 
BAppendix

Wrangell Island Project FEIS ♦ 44

Comment 

Number Comment Response

NOTHING for the citizens of Alaska in this sale -- only profit for timber 

companies. 

Who does the US Forest Service serve? The public of the United 

States, or private corporations?

Thank you for your consideration,

Zachary Brown

Gustavus, AK

028-MC-01 As a Southeast Alaskan resident who cares about protecting the 

environment, the Wrangell Island Project plan is very disappointing. The 

Small Mill and Wildlife Allternate should be considered over Alternative 

2.

Please see response to comment 058-SEACC-05.

028-MC-02 Alternative 2 makes no sense. There is no excuse to log old-growth 

forest that should be protected, and putting in so much new road is 

devastating to the environment and would cost so much that it doesn’t 

make sense even from a purely profit motive. The American public would 

be paying companies to log ancient trees! Also, the wood would be 

exported instead of being processed locally. This would be harmful to the 

deer, to the fish, and would not benefit the local businesses in any way.

I visit this part of Southeast Alaska by boat, and would hate to see it 

ruined by bad decisions.

Sincerely, 

Michele Cornelius

Your opposition to Alternative 2 is noted. The purpose and need 

in chapter 1 of the EIS explains the reasons for the project.

029-BHD July 11, 2016

Dear Sirs:

029-BHD-01 We are writing to express our dismay at your preference of Alternate 2 

for the Wrangell Island Project. This is despite the Forest Service’s 

declaration that industrial-scale old-growth logging will be decreased in 

the Tongass.

Your opposition to Alternative 2 is noted. Please see the purpose 

and need in chapter 1 of the EIS.

029-BHD-02 This, instead, appears to perpetuate an unsustainable and economically 

unfeasible practice that has long been discredited. 

Please see response to comment 050-ADNR-04.

029-BHD-03 It has been years since logging has served as the foundation of our 

region’s economy. Fishing, tourism and outdoor recreation are now 

Please see chapter 3 of the EIS for discussions on anticipated 

effects to these resources.
Appendix B

Wrangell Island Project FEIS ♦ 45

Comment 

Number Comment Response

major drivers. How will tourists react to the “mass wasting”, clearcut and 

roadbuilding described in your factsheet? 

029-BHD-04 How do the practices outlined in Alternative 2 benefit local, small-scale 

timber companies? How will timber cutting above the Institute impact a 

proposed boarding school and house sites being discussed for that 

valuable property and 

Supplying a reliable economic supply of timber to large and small 

mills in Southeast Alaska is part of the goal of the Wrangell 

Island Project. The Wrangell Island Project would provide 

opportunities to different size operators.

The small sales program on Wrangell Island typically focuses on 

offerings with less-expensive conventional yarding methods and 

little to no road construction. Therefore, the extent of small sale 

opportunities correlates to the total harvest volume and more 

specifically to the volume proposed for harvest along existing 

roads using conventional logging systems. Construction of new 

roads in larger sales can also benefit small timber sale operators 

by increasing access to additional roadside timber volume. 

The Wrangell Island Project does not propose any harvest that 

would affect the Institute property.

029-BHD-05 how will the destruction of important deer habitat help Wrangell families? The effects on deer habitat are presented in chapter 3 of the EIS. 

Timber harvest would increase deer foraging habitat over the 

short-term in summer and low-snow winters, but could also 

reduce overall the amount of habitat. 

029-BHD-06 How, particularly in the present economic era, can the Forest Service 

justify building road and selling off timber at a near-loss?

It seems to us that the Wrangell Island Project is an attempt by the 

Forest Service to appease strident large-scale timber companies, and 

perhaps our Congressional delegation, instead of truly addressing the 

needs of the people of Southeast Alaska, its wildlife and environment.

We support Alternative 1 and ask that you reconsider your selection.

Bonnie and Haig Demerjian

Box 1762

Wrangell, AK 99929

Roads are part of the necessary infrastructure not just for 

present day management activities, but are also needed for longterm management. This infrastructure also plays a key role in 

tourism, outdoor recreation, subsistence use, and other National 

Forest activities. 

030-JK-01 Hello Forest Service, Comment noted. 
BAppendix

Wrangell Island Project FEIS ♦ 46

Comment 

Number Comment Response

The Wrangell Island Timber Sale is unsustainable and not economical 

for Wrangell residents or the region. Therefore, I am writing you to 

rethink this proposal as Alaska does not need to be wasting it money on 

a boondoggle that will not be sustainable or economical. 

030-JK-02 We all know that we don't like looking at clear cuts and we don't like our 

'old growth' forest decimated and the tourist industry relies on our being 

pristine and a state worth looking at, not one that slashes it's forest for 

no reason but to destroy and cut with no forethought of the outcome. 

Please reconsider your plan so that all may enjoy the beauty of our trees 

and our forest. The Tongass National Forest is for everyone; NOT to be 

wasted for the trees that will take hundreds of years to grow back. 

Sincerely,

Janet Kussart

425 Kennedy St.

Juneau, AK 99801

Comment noted. 

The Wrangell Island Project proposes partial harvest in highvalue scenic areas. Please see chapter 3 of the EIS for a 

discussion of anticipated effects on forest resources.

031-DS-01 District Ranger Dalrymple,

I visited SE Alaska and the Tongass in early June and met with a 

number of different people - timber mill operations, native corporation 

heads, native town mayors, conservation groups and so on - and in 

doing so discussed challenges of old-growth logging in the area. I came 

to believe that a number of approaches to logging in SE Alaska are 

based upon "the good old days" of the 1970s and 1980s when 500 

million board feet of lumber were logged.

Those days are not returning, no matter how many rose colored glasses 

are used to look at the current timber industry. Timber is no longer the 

dominant industry in the region: salmon and other fisheries (both 

commercial and subsistence), tourism and even arts have risen to 

prominence in locations like Sitka, Ketchikan and Prince of Wales. 

Irresponsible timber harvesting is not only a danger to the environment 

but, perhaps more critically, threatens the larger, more sustainable 

sectors that undergird the 2016 SE Alaska economy.

The Forest Service’s Preferred Alternative – Alternative 2 – proposes 

logging 65 million board feet of old-growth from 5,309 acres and 

bulldozing 32 miles of new road. The new roads will cost nearly $5.5 

Comment noted.
Appendix B

Wrangell Island Project FEIS ♦ 47

Comment 

Number Comment Response

million dollars. High road development costs means more old growth 

habitat must be clearcut to pay for the new roads.

031-DS-02 According to the Forest Service’s own data, all the action alternatives are 

economically infeasible. That means that under every scenario 

considered the American public would be paying companies to log the 

ancient trees on Wrangell Island.

Please see response to comment 050-ADNR-04. 

031-DS-03 Current export policies allow 100 percent of Alaska Yellow Cedar plus up 

to 50 percent of the hemlock and spruce to be exported without local 

processing, further denting the local economy. If the Preferred 

Alternative is selected, more than 10 million board feet of Alaska Yellow 

Cedar and nearly 5 million board feet of Western Red Cedar could be 

logged and sent out of state or overseas without local, value-added 

manufacturing.

Please see response to comment 051-SEACCWRC-07.

031-DS-04 Without explanation, the Forest Service failed to consider at the “Small 

Mill and Wildlife Alternative” submitted by the Wrangell Resource Council 

and SEACC in 2011. The citizen’s alternative proposal wouldn't require 

new roads and would meter out up to 2 MMBF per year of timber to 

supply local mills:

• Ensuring a consistent, long-term supply of economic timber to 

small mills in Wrangell from small sales along the existing road system 

over a 30-year period

• Maintaining Wrangell Island’s deer population

• Integrating wildlife and fish habitat restoration, recreation, and 

stewardship activities into the project based on the “Good for Services” 

model

Please see response to comment 058-SEACC-05.

031-DS-05 Loss of More Important Deer and Salmon Habitat

The Preferred Alternative hammers the largest remaining block of intact 

old-growth on Wrangell Island above Rainbow Falls and Shoemaker 

Bay. This means significant reductions in deer habitat - a figure that 

already falls far below the existing Tongass Forest Plan guideline of 18 

deer per square mile. This guideline reflects the habitat needed to 

maintain sustainable wolf populations and human deer hunting. Under 

the Preferred Alternative, deer habitat capability will drop to 11.7 deer 

per square mile on national forest land by 2042. Loss of this much deer 

habitat promises future reductions in season length and/or bag limits on 

Wrangell Island; local hunters will be punished by this plan.

Please see response to comment 008-KK-03.

031-DS-06 Thoms Creek (VCU 4790) is the most productive salmon stream on 

Wrangell Island; it supports an important sockeye fishery. All the action 

alternatives call for logging productive old-growth in Thoms Creek VCU 

Please see response to comment 048-TUSCS-02.
BAppendix

Wrangell Island Project FEIS ♦ 48

Comment 

Number Comment Response

even though this area would be off-limits to logging under the proposed 

Amendment to the Tongass Land Management Plan, which is under 

review now and slated for implementation later this year. 

Please reconsider other alternatives that are more in line with 21st 

century priorities and that seek to balance environmental and economic 

concerns and work with the local economy rather than against it. Thank 

you for your time and consideration.

-Dan Sarles, Boston, MA, regular Alaska visitor

032-GW June 20 2016

Robert Dalrymple 

District ranger

PO BOX 51 

WRANGELL, AK 99929 

This is to comment on the Draft EIS for the Wrangell 10-year timber sale. 

The comments are directed at Alternative 2 of the Draft. 

032-GW-01 None of the the proposed alternatives are economic. In order for the 

Forest Service to fulfill its obligation to meet demand there must be 

alternatives in the draft that are economic. The following comments 

provide ideas for modifying alternative 2 so that it will not be deficit.

Thank you for your suggestions. Please see the “Timber 

Economics and Availability” section in chapter 3 of the EIS and 

the Timber Economics Resource Report. The current R10 FASTR economic model was used to provide a general economic 

comparison of each alternative as a whole. FAST-R is based on 

historical timber values and costs and does not indicate future 

market conditions at the time each sale is put up for competitive 

bid. Sales cannot be offered unless they can meet a positive 

advertised rate.

032-GW-02 The changes proposed address road cost by building System roads to a 

linear grading standard. The linear grading standard for system roads 

was established several years ago but has not been used recently. This 

change can reduce cost by at least $600,000. 

Linear grading construction costs were used in the road cost 

estimates. Refer to the Transportation Resource Report for more 

details.

032-GW-03 The helicopter logging is all under the single tree selection prescription, a 

minimum average selling value of $850/MBF will provide flexibility for 

meeting the STS prescription while maintaining enough value to keep 

the sale out of deficit. The same approach used for helicopter logging is 

applied to Shovel logging under the STS prescription, the minimum 

selling value is $700/MBF.

Thank you for your suggestions for improving the economics of 

the Wrangell Island Project. These would be taken into 

consideration during the implementation and development of 

timber harvest contracts.

Road 50058 is proposed to access timber from this project and 

future young-growth management. The existing 50060 
Appendix B

Wrangell Island Project FEIS ♦ 49

Comment 

Number Comment Response

There will be a camp cost as the Wrangell logging work force is gone 

because of the lack of logging jobs with the reduced timber sale 

program. The same is true for the long shore work force which will result 

in the need to move the export logs to an active export area. This would 

likely be Klawock or perhaps Tolstoi or Ketchikan. The 50058 road has 

been dropped as it is not necessary for logging the timber. If this road is 

built it should not be funded by the timber sale. The Spruce and Red 

Cedar will be barged to Klawock. The fifty percent export is all hemlock.

The appraisal data used to develop the above is Base Year 2013 

updated to the 2nd quarter of 2015. A summary of the results of the 

above changes is attached

SINCERELY, 

GEORGE WOODBURY

switchback road has adverse haul and high maintenance costs 

due to its location. Log truck use of this road is a safety concern, 

especially with other traffic using the road. Road 50058 would 

provide safer, more economical access to Middle Ridge. This 

alternative road would reduce the cost of hauling timber for this 

project, as well as for any future timber project, would require 

less maintenance than the existing road 50060, and would be a 

safer route.

033-EJ Forest Supervisor Stewart,

Dear Forest Supervisor Stewart:

033-EJ-01 I am writing to express my opposition to the proposed Wrangell Island 

Timber Sale. 

Your opposition to the project is noted.

033-EJ-02 While I was encouraged by the recent forest plan amendment that 

proposed new protections for the Tongass 77 and other conservation 

priority areas, the Wrangell Island Sale runs counter to this. The sale 

units in Thoms Lake and in important deer winter habitat are particularly 

troubling and should be removed from the sale. 

The Wrangell Island Project proposes no timber harvest in the 

Thoms Lake area. The land surrounding Thoms Lake is owned 

and managed by the State of Alaska. Deer winter habitat is 

discussed in the “Wildlife Habitat” section of chapter 3 of the 

Wrangell Island Project EIS. 

Please see the “Relationship to the Forest Plan” section of 

chapter 1 of the Wrangell Island Project FEIS.

033-EJ-03 In addition, ecosystem functioning will be harmed by continued oldgrowth timber harvest. As an ecologist with much experience in oldgrowth Pacific Northwest forests, harvesting virgin timber is harmful and 

unnecessary, both for wildlife and the fact that how the forest functions is 

altered for hundreds of years.

Please refer to the “Wildlife Habitat” and “Silviculture” sections in

chapter 3 of the EIS for discussions on the effects to wildlife and 

timber.

033-EJ-04 In addition, I am concerned that by the Forest Service’s own estimate the 

project will not be economically viable and will cost taxpayers money. I 

encourage you to halt planning this project and redirect the Forest 

Service’s limited resources toward more productive projects that better 

suit the needs of Southeast Alaska. 

Evan Jackson

Please see response to comment 050-ADNR-04.
BAppendix

Wrangell Island Project FEIS ♦ 50

Comment 

Number Comment Response

33823 SE Twin Maple Ln Apt. C

Corvallis, OR 97333

034-PB Forest Supervisor Stewart,

Dear Forest Supervisor Stewart:

034-PB-01 Bad idea. I have first hand seen the damage done to adjoining areas. 

The small monetary return is not worth the long term damage to the fish, 

animals and the whole eco-system. The damage is there for years to 

follow. Thank you.

S. Pat Bistline

Your comment is noted.

034-PB-02 I am writing to express my opposition to the proposed Wrangell Island 

Timber Sale. 

Your opposition to the project is noted.

034-PB-03 While I was encouraged by the recent forest plan amendment that 

proposed new protections for the Tongass 77 and other conservation 

priority areas, the Wrangell Island Sale runs counter to this. The sale 

units in Thoms Lake and in important deer winter habitat are particularly 

troubling and should be removed from the sale.

Please see response to comment 048-TUSCS-02.

034-PB-04 In addition, I am concerned that by the Forest Service’s own estimate the 

project will not be economically viable and will cost taxpayers money. I 

encourage you to halt planning this project and redirect the Forest 

Service’s limited resources toward more productive projects that better 

suit the needs of Southeast Alaska.

pat bistline

652 Lookout Blvd

Hope, ID 83836

Please see response to comment 050-ADNR-04.

035-DA NOTE: Due to the length of the following letter, much of which consists 

of quoted material, the portions containing substantive comments have 

been excerpted below. The letter can be found in its entirety, in the 

planning record.

July 14, 2016

Dear Supervisor Stewart, Regional Forester Pendleton and selected IDT 

members

Please read and consider my comments on the DEIS for the proposed 

Wrangell Island timber sale below. I ask you to remember these wise 

words as you read my comments:
Appendix B

Wrangell Island Project FEIS ♦ 51

Comment 

Number Comment Response

“God has cared for these trees, saved them from drought, disease, 

avalanches, and a thousand tempests and floods. But he cannot save 

them from fools.

John Muir

“The Eyes of the Future are looking back at us and they are praying for 

us to see beyond our own time.”

Terry Tempest Williams

Supervisor Stewart, you hold a unique, precious crown jewel in your 

palm of your hand. You have the power to destroy it and the 

responsibility to protect it for the people of the world today but most 

importantly for future generations. The old-growth on Wrangell Island is 

not a renewable resource.

Competent professionals don’t do something tragic just because they 

can. Who are these corporate captivated IDT members who assist you? 

I remember when USFS specialists actually cared.

035-DA-01 There are many businesses in SE Alaska that depend on the tourists 

drawn by the rain forests.

Here’s what TravelAlaska Inc. says on their website:

“Tongass' vast coastal terrain is the world’s largest temperate rain 

forest, and its canopy consists of towering hemlock, spruce and red and 

yellow cedar. Beneath the massive conifers are young evergreens and 

shrubs such as devil's club, blueberry and huckleberry. Moss and ferns 

cover the ground, and lichens drape many trees.”

Link:https://www.travelalaska.com/Destinations/Parks%20and%20Public

%20Lands/Tongass%20National%20Forest.aspx

As I will show below, many other businesses in your area depend on an 

intact Wrangell Island rainforest ecosystem yet your Purpose and Need 

says:

“This project would contribute to the orderly flow of timber to large and 

small timber purchasers, mill operators, and value-added wood product 

industries in Southeast Alaska and benefit the local and regional 

economies of Wrangell and Southeast Alaska reliable, long-term 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.” (page 4)

Your Purpose and Need doesn’t even mention tourism or the revenue it 

generates in your local area. You favor the timber industry and ignore 

the people who depend on the tourist dollars. You overlook and reject 

the needs of “ma & pa” outfitters and guides, restaurant owners, motel 

owners and other businesses that depend on the tourist dollar. This 

Comment noted. Multiple organizations and agencies consider 

the timber industry to be an important part of a diverse economy 

for Southeast Alaska. The purpose and need for this project 

includes the Forest Plan goals and objectives of providing a 

diversity of opportunities for resource use, including timber 

harvest. 
BAppendix

Wrangell Island Project FEIS ♦ 52

Comment 

Number Comment Response

wasn’t a mistake. Issue #3 at page 13 that you failed to address in this 

DEIS states:

“Concerns were raised regarding potential effects of proposed timber 

harvest to Visual Priority Travel Routes, and areas of high scenic 

integrity. Comments were expressed regarding visual evidence of 

logging on the island and advocated for protection of the viewshed along 

the back channel from the water, which is important to the Wrangell 

tourism industry.”

You again mention the importance of tourism at page 55:

“Wrangell’s economy was previously based on mining, timber 

harvesting, manufacturing, fishing, and seafood processing. However, 

tourism is now playing a larger role in Wrangell’s economy, and the City 

and Borough of Wrangell are actively seeking diversification and 

economic growth.”

You cannot satisfy the timber industry and the many businesses that 

depend on out-of-state visitors simultaneously. No action alternative that 

logs Wrangell Island at any level (emphasis added) will protect the “City 

and Borough of Wrangell are actively seeking diversification and 

economic growth.”

A Caterpillar D-6 skidder weighs 18 tons. A John Deere 440 skidder with 

winch line weighs 17,600 pounds. It’s physically impossible for industrial 

equipment of this size to traverse the fragile forest floor with spinning 

wheels and tracks to “restore” the resources you are responsible for 

protecting.

I saw many of these plundered landscapes myself. Sadly, I watched 

other resource specialists join the timber employees as they hooted with 

joy when viewing logged-over, plundered areas in the field exclaiming 

they looked good and were exactly what they prescribed.

Will people spend their money to see this?

Simply eliminating clearcutting is not enough. The public visiting the 

rainforest do not want to see stumps, landings, skid trails or roads.

Competent specialists are not afraid to disagree with the Responsible 

Official and insist the timber sale be modified to protect the natural 

resources in and downstream from the sale area.

I ask the Mr. Delabrue, Ms. de Montigny, Ms. Galla, Ms. Slusser, Ms. 

Smith, Mr. Turner, Ms. Burch, Mr. Klimek, Ms. Miller, Mr. Primaky, Ms. 

Thompson, and Ms. Whitacre to consider the following questions. Your 

answers will reveal a lot about yourself.
Appendix B

Wrangell Island Project FEIS ♦ 53

Comment 

Number Comment Response

• Have you ever had the courage to admit that your mind has been 

manipulated by the USFS since your first day at work?

• Have you ever had the courage to ask yourself why the USFS 

teaches you things about your resource that contradict what you learned 

in college?

• Have you ever wondered why the USFS teaches you that 

Americans who don’t want their national forest developed are rabid 

“enviros” to be disliked or hated?

• The last time you helped to plan and design a project that you 

knew would devastate your resource, did you look the other way and 

believe everything was fine because your Ranger or Supervisor said so?

• Why does your Ranger or Supervisor hide the fact that their real 

priority is volume and not properly functioning natural resources?

• Are you comfortable working for an agency with a timber agenda 

and culture?

• Do your Chapter 3 effects disclosures tell the public that No Action 

will harm your resource? Do you really believe logging and roading the 

area benefits your resource more than maintaining the status quo?

• If you would have written the Purpose & Need yourself and were 

certain nobody would know the author, would it have been similar to the 

P&N for this sale?

• Do you really believe logging and road construction will satisfy the 

P&N goals? 

035-DA-02 Comment: It’s clear that Supervisor Stewart did not learn from the 

Agriculture Department's inspector general’s findings based on a 1999 

audit of the USFS timber program. The first sentence of the NYT article 

describing the audit findings says this:

“Federal auditors have found that the Forest Service frequently fails to

assess, prevent or correct environmental damage from logging on the 

national forests.”

This DEIS smoothes-over and minimizes the “environmental damage 

from logging” that will be caused by the Wrangell Island timber sale.” A 

few IDT members know this but their position pays to well to jeopardize it 

by doing the right thing for future generations of Americans. 

Comment noted. The Forest Service performed a 

comprehensive analysis of the effects of the project alternatives. 

These are presented in the FEIS, resource reports and project 

record. The analysis was performed in compliance with 

applicable law, regulations and policy.

Retired Deputy Chief Jim Furnish reflects on his USFS employment. He 

believed logging must always result in a healthy, unharmed ecosystem 

... with health measured using methods developed by independent 

scientists not associated with the USDA in any way.
BAppendix

Wrangell Island Project FEIS ♦ 54

Comment 

Number Comment Response

Please consider retired Deputy Chief Furnish’s observations in light of 

the proposed Wrangell Island timber sale.

035-DA-03 Comment: Based on the content of the draft EIS Retired Deputy Chief 

Furnish would consider your Wrangell Island timber sale one that:

• uses agency dogma to further the “agency’s timber-first priority”

• will create a “landscape of cookie cutter homogeneity”

• will “take from the forest at the expense of future generations”

• ignores emerging “societal values inviting the agency to change”

Comment noted. The Forest Service uses current guidance and 

applicable scientific knowledge to manage timber harvest on 

NFS lands. 

035-DA-04 Request for changes to be made to the final NEPA document: Include 

applicable science literature in the References section. Each research 

conclusion quote contained in the Opposing Views Attachments contains 

links to the source literature for the quote. I will expect to see the source 

literature in the References section and cited in the body of the final EIS.

Comment noted. We acknowledge the extensive list of sources 

you submitted. Sources that were determined to be relevant to 

the project by the IDT have been added to the FEIS. A response 

to your submitted references can be found in the project record 

(PR# 634_1274). 

035-DA-05 Request for changes to be made to the final NEPA document: Either:

1) remove the statement from the P&N:

“Local and Regional Economy—Goals and Objectives (USDA Forest 

Service 2008a, p. 2-5): 

• Goal: Provide a diversity of opportunities for resource uses that 

contribute to the local and regional economies of Southeast Alaska. 

• Objective: Support a wide range of natural resource employment 

opportunities within Southeast Alaska communities.”

The trees owned by 221 million Americans must never be removed to 

provide corporate profit.

OR

2) offer the sale as an SBA sale and say so in the final NEPA document,

OR

3) include the text or links to the text of the following papers (referenced 

above) in an Appendix to the NEPA document. Line-officers must not 

withhold such important information from the public. Congress 

promulgated laws to prevent zealous federal officials from behaving in 

such a manner to feather their nest.

“The Economic Impact of Trails-Forest Recreation’s Growing Inpact”

“Seeing Forests for their Green: Economic Benefits of Forest Protection, 

Recreation, and Restoration”,

Comment noted. The purpose of the project is to respond to 

these goals and objectives of the Forest Plan. The materials 

provided by the commenter have been placed in the project 

record.
Appendix B

Wrangell Island Project FEIS ♦ 55

Comment 

Number Comment Response

“The Economic Impact of Preserving Washington’s Roadless National 

Forests”

A 1998 presentation to the National Trails Training Partnership by U.S. 

Undersecretary of Agriculture Jim Lyons

Failure to do so will violate 40 CFR 1500.1(b) because environmental 

information is not available to citizens before decisions are made.

035-DA-06 RF Pendleton, you stand back and watch Supervisor Steward backhand 

and ignore the 321 million owners of the Tongass NF. Chief Tidwell led 

them to believe they might influence how the agency treats their land

Supervisor Steward and his IDT rejected all suggestions for new 

alternatives submitted by the public. Pages 23 and 24 contain 

reasonable citizen-generated alternatives that were rejected by 

Supervisor Stewart. You wouldn’t want those pesky members of the 

public to interfere with USFS business would you?

Competent Forest Supervisors consider citizen-generated alternatives as 

opportunities.

The IDT’s reasons for rejecting these alternatives are comical. The 

plaintiffs will certainly use this.

The Wrangell Island Project analysis was based on input we 

received through public scoping. This input helped define the 

issues, which were then used to develop the alternatives. We 

received public comment both in support and in opposition to 

various components of the project. The Responsible Official 

considers the public comment in making the Decision for this 

project.

Sincerely,

Dick Artley

Dick Artley [retired forest planner from the Nez Perce National Forest, 

Idaho, duties were 1) NEPA legal compliance reviewer, 2) forest NEPA 

coordinator, and 3) forest appeals/litigation coordinator. Education: BS 

in forestry from the University of Washington and MS in logging 

engineering from Oregon State University 1980

415 NE 2nd Street

Grangeville, Idaho 83530

da99333@gmail.com

036-ADFG THE STATE OF ALASKA

GOVERNOR BILL WALKER

Department of Fish and Game
BAppendix

Wrangell Island Project FEIS ♦ 56

Comment 

Number Comment Response

DIVISION OF HABITAT

Southeast Region Office

802 3rd Street Douglas, AK 99824-5412

PO Box 110024

Juneau, Alaska 99811-0024

Main: 907.465.4105

Fax: 907.465.4759

July 15, 2016

Andrea Slusser NEPA Planner

US Forest Service, Wrangell Ranger District PO Box 51

Wrangell, AK 99929 

Dear Ms, Slusser:

Biologists from the Alaska Department of Fish and Game (ADF&G) 

Habitat, Wildlife Conservation, and Sport Fish Divisions reviewed the 

Draft Environmental Impact Statement (DEIS) and Aquatic and Wildlife 

Resources Reports (ARR; WRR) for the Wrangell Island Timber Sale. 

We acknowledge your effort to address ADF&G concerns raised during 

scoping and present alternatives that limit clearcut harvest to 50j-01

or less of the total harvest area offered. ADF&G appreciates 

participating in the nearly decade long development of this sale. Please 

consider the following when selecting an alternative for implementation.

036-ADFG-01 Wildlife Corridors and Old Growth Reserves (OGRs)

Alternatives 2 and 5 mostly avoid placing clearcut units in wildlife travel 

corridors identified in Figure 13 of the WRR. After reviewing GIS imagery 

and discussing with US Forest Service Wildlife Biologist Joe DelaBrue, 

slight adjustment of the remaining clearcut units positioned in corridors 

could result in uninhibited wildlife migration.

Thank you for your comment. Figure 13 of the Wildlife Resource 

Report depicts existing conditions. 

036-ADFG-02 Project documents acknowledge that Thom's and Fools Medium OGRs 

do not meet Forest Plan criteria for minimum acreages and that 

conveyance of the selected parcel within Thom's Medium OGR to the 

state would further reduce its size. 

Please adopt the recommendations of the Interagency OGR Review 

Team (2013 Addendum interagency biologist review of the old-growth 

The status of the potential State land selection near Thoms Lake 

is identified in table 4 of the EIS. 

The Thoms and Fools medium OGR boundaries are designated 

in the Forest Plan. The establishment of most medium and large 

OGRs was finalized in the 1997 Forest Plan decision based on 

the criteria of previous work by the VPOP committee and others 
Appendix B

Wrangell Island Project FEIS ♦ 57

Comment 

Number Comment Response

reserves in the Wrangell Island timber sale project area, unpublished 

document) into the FEIS. 

If this is not feasible, consider removing the areas highlighted by the 

team for inclusion in the OGR network from the selected alternative, so 

they may be incorporated in the future along with acreage to make up for 

the conveyance, should it occur.

(2008 Forest Plan Amendment FEIS Volume 1 p. 3-253). The 

basis for the location of these OGRs was the number, size, 

spacing and habitat composition. Sometimes, to achieve these 

objectives, the size and habitat composition of a reserve did not 

meet the suggested criteria. 

Reconfiguring these medium OGRs would require amending the 

Forest Plan. This was considered during the analysis, both to 1) 

enlarge these medium OGRs to meet the size criteria and 2) 

reconfigure them to be entirely within the inventoried roadless 

areas. These were eliminated from detailed study as explained in 

chapter 2 of the Wrangell Island Project EIS. The conservation 

strategy was also reviewed and documented in 2016 Forest Plan 

appendix D (pages D-2 to D-9). No modifications to these two 

medium OGRs were made in the 2016 Forest Plan.

036-ADFG-03 Harvest of Productive Old Growth Forest (POG)

The DEIS considers how POG harvest may affect deer, wolves, 

goshawks, and martens, and that there is no abundance data for these 

species on Wrangell Island. Proposed harvest of remaining high value 

POG in a given VCU ranges from 0-26% under the action alternatives. 

Focusing harvest on high value POG will continue to isolate and diminish 

ecological communities. 

Comment noted. The removal of POG was analyzed for all of the 

species mentioned in the Wildlife Resource Report.

036-ADFG-04 Wrangell Island populations of martens and other less vagile species 

cannot be augmented by immigration. Since the marten habitat resource 

surveys recommended during scoping were not carried out, we 

recommend limiting the clearcut harvest of POG until the status of the 

marten population is better understood.

We did analyze all marten habitat on Wrangell Island, but 

surveys were not completed. Please refer to the Wildlife 

Resource Report.

036-ADFG-05 Marten

ADF&G telemetry and harvest data from Chichagof Island and data 

gathered by the US Forest Service on Mitkof Island (G. DeGayner and J. 

Doerr, 1995, US Forest Service, Tongass National Forest, unpublished 

data) demonstrated that martens with home ranges intersecting roads 

are vulnerable to trapping. In a 2007 letter to US Forest Service staff, 

Wildlife Biologist Rich Lowell highlighted GIS-based analysis shows 

marten habitat more than a mile2 from a road on Wrangell Island 

comprises only enough area to support about a dozen animals. ADF&G 

prefers maintaining unroaded marten habitat capable of producing a 

harvestable surplus over the management options suggested on page 

66 of the WRR. We recommend removing this list of management 

options since closing the season by emergency order is the only option 

Thank you for your comment. The suggested changes have 

been made to the Wildlife Resource Report and the 

management options have been removed.
BAppendix

Wrangell Island Project FEIS ♦ 58

Comment 

Number Comment Response

ADF&G can enact. Since marten are easily captured in traps set for 

other species, a marten closure would also require a closure for other 

furbearers.

036-ADFG-06 Road Construction and Access Management

The alternatives presented seek to limit density of open roads on 

National Forest lands to 0.7-1.0 linear miles per square mile with the 

goal of maintaining wolf and marten harvest at sustainable levels. Prince 

of Wales Island Landscape Level Assessment field observations indicate 

many roads marked as closed in the Forest Service database are not 

functionally closed, allowing human access and harvest (T. Schumacher, 

Wildlife Conservation Biologist, ADF&G, Juneau, personal 

communication). To ensure current and predicted densities of open 

roads are accurate, we recommend a ground-based assessment to 

determine functional status. 

Please refer to the Wildlife Resource Report for information on 

road densities concerning marten and wolves. The road data on 

Wrangell Island is considered to be accurate.

036-ADFG-07 Deer Abundance and Habitat Capability

The DEIS acknowledges Wrangell Island deer habitat capability is below 

the Forest Plan Guideline of 18 deer per square mile and that 

recommended by Person ( 1997) for areas where deer are the primary 

prey of wolves. The DEIS also acknowledges that continued harvest of 

POG will further reduce deer habitat capability. Please consider that the 

public, through the Board of Game process, has expressed a desire for a 

level of deer harvest, 900 deer from GMU 3, that has not been met since 

2004. The highest level of harvest since 2010 was 533 deer.

Wrangell Island makes up a small portion of GMU 3. An annual 

average of 69 deer have been harvested over a 17-year period 

(1997-2013) on GMU 3. Wrangell Island itself has been above 

this average for 4 out of 5 of those years, with a high of 92 deer 

harvested in 2009 and a low of 62 harvested in 2010.

036-ADFG-08 Young-Growth Management

Alternatives range from 936 to 1,781 acres of even-aged management 

with 1,250 acres of thinning planned in the next 10 years. The 

information contained in the DEIS could be strengthened by discussing 

where, when, and how thinning will occur and how research suggests 

Wrangell Island management indicator species will be affected.

The benefits of timber thinning are described in the Silviculture 

Resource Report. These benefits relate to increased species 

diversity, increased forage and overall habitat enhancement by 

avoiding prolonged stem exclusion. 

036-ADFG-09 Wolves

The WRR suggests immigration will help maintain the Wrangell Island 

wolf population. Though wolves are capable of swimming to Wrangell 

Island, ADF&G advocates for maintaining a harvestable population by 

providing habitat sufficient to support a prey base for at least one 

resident pack and some transient wolves. Please update the WRR and 

DEIS to include recent information for wolves and deer in the attached 

Species Status Assessment for the Alexander Archipelago Wolf 

(USFWS 2015) and the ADF &G report on estimating wolf abundance in 

GMU 2 (Roffler et al. 2016).

Thank you for your comment. The suggested changes have

been made to the Wildlife Resource Report.
Appendix B

Wrangell Island Project FEIS ♦ 59

Comment 

Number Comment Response

036-ADFG-10 Consideration for Sensitive Streams

During scoping, ADF&G raised concern for the risk of sedimentation in 

Thom's, Fools, and Salamander Creeks, which stand out as drainages 

with a high proportion of low gradient flood plain channel types. This 

concern was not addressed in the DEIS. Please ensure the provisions in 

the Forest Plan and Forest Service Handbook 2509.22, and other 

reasonable site specific measures to reduce ground disturbance when 

logging in the headwaters of these streams, are outlined in the Final EIS 

and unit cards.

Sedimentation was addressed in the analysis, please refer to the 

“Aquatics” and “Soils” sections of chapter 3 of the FEIS. The 

effects of sedimentation would be minimized through the 

application of standards and guidelines, BMPs and Forest 

Service Handbook direction. These are discussed in the EIS. All 

fish bearing stream crossings constructed with this project would 

follow handbook guidance for aquatic organism passage design.

All units are designed to avoid RMA areas. Only Class IV 

streams (intermittent) are within harvest units. 

036-ADFG-11 Fish Passage

The ARR lists 39 red and 3 gray culverts in Table 29. The table on page 

98 of the appendix ranks these crossings by remediation score, but the 

road and milepost numbers do not align with Table 29, the stream and 

culvert classes are not listed, and only 40 crossings are shown. Please 

reconcile these two tables. Red culverts need to be replaced as a 

component of the Wrangell Island timber sale. Where available upstream 

habitat does not warrant culvert replacement, the district biologist can 

work with ADF&G Habitat Division to obtain concurrence to not provide 

fish passage and eliminate red culvert status.

Thank you for the opportunity to review and provide comments on the 

proposed action. Please contact Habitat Biologist Greg Albrecht at (907) 

465-6384 or greg.albrecht@alaska.gov with any questions you may 

have.

Sincerely,

Jackie Timothy

Southeast Regional Supervisor

Thank you for your comment. Please see response to 061-

GSACC-75. 

The Aquatics Resource Report tables have been revised to 

clarify the information in the tables. Each “red” culvert is 

assessed against other “red” culverts and road maintenance 

issues affecting water quality across the Forest to determine the 

priority for remediation. Stewardship projects will be considered 

as separate projects with related NEPA and planning. The Forest 

Service would obtain all appropriate permits, and/or 

concurrences, including Title 16, from ADF&G, on projects 

addressing or affecting fish habitat.

037-E -- This e-mail contained no text, and therefore no substantive 

comment.

038-EB-01 The time has come for Southeast Alaska to no longer rely on the timber 

industry as an economic driver. The Forest Service should manage the 

National Forests in Southeast Alaska for a host of public values that 

support the tourism and fishing economy of today; the driving economic 

forces are and continue to be tourism and recreation.

Comment noted. Other individuals, organizations and agencies 

consider the timber industry to be an important part of a diverse 

economy for Southeast Alaska. 

038-EB-02 17 miles of new national forest roads! Wolf mortality concerns have not been identified on Wrangell 

Island and intensive predator control is not occurring on Wrangell 

Island at this time. Bag limits are set by ADF&G with input from 

the Board of Game.
BAppendix

Wrangell Island Project FEIS ♦ 60

Comment 

Number Comment Response

Already wolf hunting is rife on Wrangell Island with "bag limits" of 5 

wolves and portions of the island are subject to Alaska’s infamous 

"intensive predator management program" encouraging even further 

reduction of the wolf population. As we have seen on Prince of Wales 

logging and roads initiate many harmful effects, including the 

"overharvest", ie. poaching of wolves.

Dr. Elisabeth Bechmann 

Austria

039-EAA To Whom This May Concern,

039-EAA-01 The Tongass offers the country’s largest remaining swath of ancient 

forest, as well as an estimated one third of the world’s remaining 

temperate rainforest. It is far past time for an end to old-growth logging 

and destruction of habitat essential for endemic species found only in 

this biologically rich region. I support Alternative 1, the “no-action” 

alternative because in this alternative, none of the proposed logging 

activities would occur.

Thank you for your time and consideration of this extremely important 

matter, 

E.A. Allen

Your support for the no action alternative is noted.

040-SF-01 I am writing to express my strong support for Alternative 1 which would 

allow approved forest management activities unrelated to the proposed 

sale to continue. It would also maintain the existing road access plan for 

the island.

The continuance of old-growth logging and construction of roads would 

have severely detrimental impacts on wildlife habitat and the local 

environment. Our remaining temperate rainforest must be preserved.

Susan Fairweather.

Your support for the no action alternative is noted.

041-LD-01 I oppose no cutting of timber on this island/area in Alaska and am in 

favor of Alternative #1. We need to protect these natural wildlife habitats 

and end Any and all plans to cut these forests and woodlands

Your support for the no action alternative is noted.

042-DR July 17, 2016
Appendix B

Wrangell Island Project FEIS ♦ 61

Comment 

Number Comment Response

To: Bob Dalrymple, District Ranger

Wrangell Ranger District

P.O. Box 51

525 Bennett Street

Wrangell, AK 99929

Re: Written Comments on the Wrangell Island Project DEIS

My name is David Rak. I have lived in Wrangell and worked for the 

Forest Service here since 1980. In his letter I represent myself as a 

Wrangell resident and subsistence hunter. No Forest Service equipment, 

supplies or time were used in the preparation of these comments or this 

document. My participation is as a private citizen interested in proper 

management of National Forest System lands on Wrangell Island near 

my home.

042-DR-01 Comment 1 – Subsistence Deer Harvest. 

My wife and I harvest almost all the meat we eat, and I prefer Sitka Black 

Tail Deer. The Forest Service Wrangell Island Project will harm my 

opportunity to harvest deer on Wrangell Island. At the public meeting I 

attended for the Wrangell Island Project, Forest Service officials stated 

that the “project purpose was to get the timber out”. The Alaska National 

Interest Conservation Act requires a subsistence priority for resources on 

federal lands. The Forest Service preferred alternative in the Wrangell 

Island Project fails to provide that subsistence priority. The FEIS needs 

to address the priority for subsistence deer harvest on Wrangell Island.

When I arrived on Wrangell Island, the McCormack Creek road 6265 had 

just been extended past Basin Creek. I have witnessed firsthand the 

road building and timber harvests over most of Wrangell Island. Through 

a significant period of that time there has been an overall decline in the 

availability of deer to harvest. Deer populations on Wrangell Islands have 

declined, and the DEIS explains they are thought to be well-below 

carrying capacity.

The Forest Service preferred alternative for the Wrangell Island Project 

would harvest trees on approximately 5,300 acres over the projected life 

of the project. In comparison, from 1954 to the present trees have been 

harvested on approximately 7,200 acres of National Forest on Wrangell 

Island. The Wrangell Island Project preferred alternative would harvest 

The purpose and need for the project’s timber harvest is 

presented in chapter 1 of the EIS. The project alternatives effects 

to deer are presented in the “Wildlife Habitat” and “Subsistence”

sections of chapter 3 of the EIS, and analysis is presented in the 

Wildlife and Subsistence Resource Reports.

The Wrangell Island Project complies with ANILCA and followed 

the ANILCA Section 810 Evaluation process outlined in FSH 

2090.23 to determine the effects on subsistence use. Because 

the project could have an effect on subsistence resources, two 

public subsistence hearings were held.

Treatments proposed under Alternative 2 would result in the 

reduction of deep snow deer habitat by 58 acres and reduce 

deer habitat capability by 5 percent from current condition. At 

stem exclusion, deer habitat capability would be further reduced 

by 9 percent of existing condition. Alternative 2 would also have 

an immediate reduction in deer density by 0.6 deer per square 

mile post project completion and further reduce by 1.2 deer per 

square mile at stem exclusion The construction of approximately 

32.1 miles of proposed new road and 5.8 miles of reconditioning 

of closed roads would effects how deer are accessed on the 

Island. Upon project completion, the total amount of open 

National Forest System roads accessible by motorized traffic 
BAppendix

Wrangell Island Project FEIS ♦ 62

Comment 

Number Comment Response

timber on almost as many acres in the expected tenure of the project as 

have been have been harvested in the 62 previous years. (The expected 

tenure for the Wrangell Island Project would be 3 to 5, but no longer than 

10 years.) At a public meeting for the Wrangell Island Project I was told 

that every alternative will reduce the number of deer. The loss of that 

much deer habitat promises future reductions in season length and/or 

bag limits on Wrangell Island. The level of impact to habitat in the DEIS 

is too great and would harm my access to subsistence deer harvest. The 

FEIS must be more forthcoming about the realistic consequences on 

subsistence deer hunting.

would be approximately 100.6 miles, which includes motorized 

trails. Therefore, Alternative 2 would have a beneficial impact on 

subsistence users trying to access deer on Wrangell Island. 

Roads can affect subsistence users by providing access, 

dispersing hunting pressure, or creating the potential for 

increased competition through road closures. Alternative 2 would 

increase the amount of open roads across the Island. Therefore, 

Alternative 2 is not expected to increase competition for 

subsistence resources on Wrangell Island. Any improved 

motorized access from temporary roads would be of short 

duration because all temporary roads would be decommissioned

at project completion. (Subsistence Resource Report).

Hunter harvest data from 1996-2013 was used to assess hunter 

demand and deer habitat capability was used to estimate the 

theoretical number of deer available. On Wrangell Island (WAA 

1903), the average hunter harvest is 69 deer per year. 

Therefore, under Alternative 2 hunter harvest of deer on 

Wrangell Island represent approximately 3.1 percent of the 

modeled deer habitat capability. Therefore, habitat capability in 

WAAs 1903 would continue to be adequate to sustain the current 

levels of deer harvest. Furthermore, with increased miles of open 

road should alleviate the competition for subsistence resources 

across the Island (Subsistence Resource Report).

042-DR-02 Comment 2- Consistent, long-term supply of economic timber to 

Wrangell small mills from small sales over a 30-year time frame. 

Ensuring a consistent, long-term supply of economic timber to small mills 

in Wrangell from small sales over a 30-year transition time frame was 

one of the desired outcomes of the Wrangell Island Project. An 

alternative needs to be developed to better achieve this need. All 

National Forest System lands on Wrangell Island that are available for 

harvest are impacted in the DEIS preferred alternative 2. No areas are 

held for future timber harvest actions under current OGR and Roadless 

regulations. 

Sixty-six percent (3,528 acres) of the timber harvest in the preferred 

alternative would be single tree selection. At public meetings for the 

Wrangell Island Project, Forest Service officials explained that helicopter 

logging is the expected harvest system for acres with the single tree 

selection prescription, and that helicopter logging requires a large 

Please see response to comment 058-SEACC-05.

Alternative 2 does not harvest all suitable available lands on 

Wrangell Island.

While helicopter logging is the most expensive of logging 

methods used in Alaska, it has been proposed in locations where 

roading and cable yarding are not feasible. It is also used to 

conduct partial harvest in areas where it is important to avoid 

ground disturbance in order to protect other environmental 

resources.

A 30-year timeframe alternative was considered, but not carried 

forward for detailed analysis. See the Alternatives Considered 

but Eliminated from Detailed Study in chapter 2 of the FEIS. 
Appendix B

Wrangell Island Project FEIS ♦ 63

Comment 

Number Comment Response

amount of timber volume to be economically feasible. The expected 

tenure for the Wrangell Island Project would be 3 to 5, but no longer than 

10 years. The outcome of the Wrangell Island Project would be a short 

term, large volume, pulse of timber from National Forest lands on 

Wrangell Island. The Forest Service officials explained economic 

security for the community of Wrangell is not embedded into any of the 

alternatives. The FEIS needs to include an alternative that ensures a 

consistent, long-term supply of economic timber to small mills in 

Wrangell from small sales over a 30-year time frame. 

These comments are submitted subject to a Pre-Decisional 

Administrative Review Process (36 CFR 218) to maintain eligibility to file 

an objection to the associated draft decision notice. 

Thank you.

David Rak

Wrangell Resident

043-CB Andrea Slusser

Wrangell Ranger District

525 Bennett Street P.O. Box 51, Wrangell, AK, 99929-0051

Dear Madam,

043-CB-01 Please Support Alternative 1 – which is the “no-action” alternative, no 

more logging. 

Sincerely,

Chantal Buslot 

Belgium

Thank you for your comment. Your support for the no action 

alternative is noted.

044-TNC The Nature Conservancy in Alaska

416 Harris Street, Suite 301

Juneau, Alaska 99801

tel [907] 523-8157

fax [907] 586-8622

nature.org

District Ranger Bob Dalrymple 
BAppendix

Wrangell Island Project FEIS ♦ 64

Comment 

Number Comment Response

Wrangell Ranger District

PO Box 51

Wrangell, AK 99929-0051

July 18, 2016

The Nature Conservancy would like to take this opportunity to comment 

on the proposed Wrangell Island Project. 

044-TNC-01 The project has the potential to play a role in supplying the 'bridge 

timber' called for under the Tongass Advisory Committee's 

recommendations, but it is worth noting that much of the timber in the 

sale area is of marginal value and volume, as is evidenced by the fact 

that the preliminary appraisal for each alternative is negative. 

The analysis used the Regional FAST-R economic model to 

compare the alternatives as a whole rather than as an appraisal. 

The FAST-R model is most useful in comparing alternatives. 

This model uses historical logging costs and values which may 

not reflect market conditions at the time of the timber sale 

advertisement. Timber sales from the Wrangell Island Project 

would be offered through competitive bid. A sale appraisal would 

be conducted and only sales with a positive bid value can be 

advertised. For more information, please see the Timber 

Economics Resource Report.

044-TNC-02 We are pleased that the majority of the sale area in the Preferred 

Alternative (3,500 acres) would have a silvicultural treatment that will 

minimize negative impacts to wildlife habitat and aesthetics.

Comment noted. The harvest unit boundaries and partial harvest 

with at least 67 percent basal area retention were designed 

specifically to minimize negative impacts to the scenic and 

wildlife resources.

The Conservancy recommends that the following be considered for 

inclusion in the final plan: 

044-TNC-03 It is important that the local community be involved in the scheduling of 

individual sales within the project area. A collaborative process should 

be established on Wrangell Island in the interests of giving local 

residents a say in how the project is implemented. 

Project implementation will be addressed in the Record of 

Decision. The Forest Service will continue to work with the City 

and Borough of Wrangell and others during the implementation 

of this project.

044-TNC-04 Specific focus should be placed on scheduling and designing those units 

most easily accessible to a smaller operator (limited initial infrastructure 

investment needed, shovel logging, etc.) to be useful to local mills. There 

are 40 units totaling 396 acres within 400 ft. of an existing road that are 

shovel-operable in the preferred alternative; the scheduling and size of 

these sale units in particular should be designed to benefit local 

operators.

Comment noted.

Supplying a reliable economic supply of timber to large and small 

mills in Southeast Alaska is part of the goal of the Wrangell 

Island Project. Generally, alternatives with a higher volume of 

timber harvest yield more options to create opportunities for a 

variety of purchasers. The harvest units from Wrangell Island 

Project can be offered in a variety of timber sale and/or 

stewardship contract sizes, and would be determined on a yearly 

basis. 

The small sales program on Wrangell Island typically focuses on 

offerings with less-expensive conventional yarding methods and 
Appendix B

Wrangell Island Project FEIS ♦ 65

Comment 

Number Comment Response

little to no road construction. Therefore, the extent of small sale 

opportunities correlates to the total harvest volume and more 

specifically to the volume proposed for harvest along existing 

roads using conventional logging systems. Construction of new 

roads in larger sales can also benefit small timber sale operators 

by increasing access to additional roadside timber volume. 

044-TNC-05 Approximately 530 acres of the sale are located within the Thoms Creek 

TNC/Audubon Conservation Priority Area and TU77 watershed, 

including 3 70 acres designated to be clearcut. According to the planned 

TLMP Amendment Record of Decision due to be signed in December, 

these areas will not be suitable for harvest. In expectation of this 

impending change, and in the interests of maintaining the habitat value 

of this landscape, we recommend removing these units from the 

preferred alternative.

We share the interests of many in southeast Alaska in seeing the 

maintenance of a viable timber industry. Involving local communities in 

land management planning, and scheduling harvests at a scale that the 

landscape can support, is key to the sustainability of local industry, and 

we hope that the Wrangell Island Project meet both these criteria in its 

final form. 

Thank you for your time, we look forward to working with you in the 

future.

Conor Reynolds, Conservation Forester

The action alternatives no longer include the harvest units within 

the T77 watershed and The Nature Conservancy/Audubon 

conservation priority area VCU 4790, and are consistent with the 

2016 Forest Plan.

Please see response to comment 048-TUSCS-02.

045-TS Dear Sir,

045-TS-01 Please leave the geat Tongass as it is right now and stop the idea of 

opening it up for logging or any human development for the sake of the 

wild salmon and those whose lives depend on the fish like the grizzzles.

thank u for your time,

tsang

Comment noted.

046-PB Peter Branson

PO Box 1259

Wrangell, AK

99929

Thoms Place
BAppendix

Wrangell Island Project FEIS ♦ 66

Comment 

Number Comment Response

Attn: Ranger Robert Dalrymple,

Wrangell Ranger District

PO Box 51

Wrangell, AK 99929

Thanks for the opportunity to comment on the Wrangell Island Timber 

Sale DEIS. 

046-PB-01 Of all the offered alternatives, I’ll have to strongly support Alternative 1, 

the no action alternative. All the action alternatives harvest far too much 

timber, are unsustainable on both economic and ecological levels, and 

would cost the taxpayers up to and beyond $15 million.

Your support for the no action alternative is noted.

046-PB-02 I work as a local hiking guide and have observed a rising demand from 

the growing tourism industry for hiking and other recreational activities, 

while at the same time cabins are closed, our few trails fall into disrepair 

and recreation budgets are slashed. Imagine the world class trails and 

other recreation infrastructure we could build in the island on even half 

the money you plan to spend to cut the last of the big trees.

Comment noted. 

046-PB-03 No one really knows the status of the wolf population on the island, and 

building more road access will only increase the already considerable 

hunting and trapping pressure on this vulnerable animal.

Please see the wolf discussion in the “Wildlife Habitat” section of 

chapter 3 of the EIS. No statistically reliable population estimates 

for wolves are available for Wrangell Island or Game Unit 3 

(GMU 3), but an estimated 125 to 385 wolves are thought to 

occur in GMU 3 in approximately 23 packs (Lowell 2012). GMU 3 

includes Kuiu, Kupreanof, Mitkof and Zarembo Islands, several 

smaller islands as well as Wrangell Island. With the relatively 

short distance between islands in GMU 3 and the mainland, 

Lowell (2009) states that population exchange between GMU 3 

islands and GMU 1B mainland probably occurs on a regular 

basis. Wolf harvest in GMU 3 fluctuates on a yearly basis; 

between 1998 -2007 annual wolf harvest was 47 and from 2008 

– 2010 it slightly increased to 50, which is above their 10-year 

mean annual harvest (Lowell 2012). For most wolf harvest, 

trapping is the primary means of taking wolves, however in three 

of the last ten years firearms has exceeded those taken by 

conventional methods (Lowell 2012). Reported wolf harvest on 

Wrangell Island harvest has averaged 2.7 wolves per year 

(range 0-6) over the last 24 years (Lowell, personal 

communication 2015) (Wildlife Report p.55).
Appendix B

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Comment 

Number Comment Response

Wolf mortality concerns have not been identified on Wrangell 

Island. The existing road density on Wrangell Island (NFS lands) 

below 1,200 feet is at 0.98 mi/mi2 and under Alternatives 2 

through 4, the density would increase to 1.3 mi/mi2 resulting in 

an increased road density by 0.32 mi/mi2 on NFS land on 

Wrangell Island (Wildlife Resource Report).

046-PB-04 In conversations with Alaska DNR officials over 20 years ago they told 

me the watersheds on the island were already logged beyond Best 

Management Practices. We need more than the minimal buffers State 

and Federal law require. Stay out of drainages, especially Thoms Creek.

30 years ago, newly arrived as a Thoms Place homesteader, I was 

greeted to Thoms Place Marine Park with the sounds of yarders, 

chainsaws, and heavy equipment as they created the huge clearcut on 

the hill above the bay. 30 years later I had hoped we we’ve moved to a 

more diversified, sustainable economy of tourism, marine service, fishing 

and other sectors not so reliant on extraction of raw resources. Instead I 

learn you want to make the scare in our land bigger, and look backwards 

rather the forward.

Sincerely,

Peter Branson

Comment noted. 

No harvest is proposed in the Thoms Creek Watershed. See 

response to comment 048-TUSCS-02 for more on this 

watershed. 

The Forest Plan requires additional riparian management areas 

that are larger than the 100 foot buffers required by the TTRA. 

The economy of Southeast Alaska has become more diversified, 

however the timber industry is still part of the economy. It should 

be noted that the Wrangell Island Project proposes a substantial 

amount of partial harvest for the purpose of not being visually 

apparent and thereby protecting the scenery. 

047-TM July 5, 2016

Comment on the Wrangell Island Project

047-TM-01 1. Wrangell Island covers 210 square miles. According to the Forest 

Service, 58% is forest and 43% of that is non-productive. That works out 

to be 70 square miles of productive forest on Wrangell Island. From what 

I can learn only about 24 % of the old growth exists on Wrangell and 

Etolin Islands. If that is accurate, that leaves 16.8 square miles of old 

growth forest. The Project's Alternative 2 is 5,309

acres or 8.3 square miles.

This plan proposes to cut almost exactly half of the sparse old growth 

forest that remains on the Island - the best of what is left.

Comment noted. In response to your comment and others like it, 

some graphics have been added to the FEIS to better illustrate 

the harvestable land on Wrangell Island. Please see figures 2 

and 3.

047-TM-02 2. Before the Silver Bay Mill packed up, they cut all the old growth guard 

trees down the beach to the mill. They cut the old growth around what is 

the new clinic, they clearcut the Mental Health Lands from 5 mile to Pat's 

Creek at 10 mile. While these lands are not controlled by the Forest 

Timber harvest on National Forest lands is regulated to protect 

resources. Regarding scenery specifically, the cumulative effects 

analysis on scenery incorporated adjacent non-National Forest 

lands for all alternatives. The harvested areas you describe are 
BAppendix

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Comment 

Number Comment Response

Service, I think the point should be made that the industry has few 

standards when it comes to protecting natural beauty or heritage forest.

The logging industry has been like a bad tenant that leaves your house a 

mess and your favorite things broken or missing. It has taken away some 

of the most beautiful scenery on the island.

the reason why partial harvest—which has a smaller impact on 

scenery—on adjacent National Forest lands is being proposed 

for the Wrangell Island Project.

047-TM-03 3. The scale of this project at 65 million board feet, invites big industry 

back. It will compete for manpower with the local industries that have 

fought hard to get established here in the wake of the logging exodus. In 

the late 1990's, Wrangell was awarded 40 million dollars in economic 

development money to help it survive the failure of the logging industry 

as a result of the Roadless Initiative. The environmental impacts of this 

project run contrary to the interests of the new industries that have grown 

up in the aftermath of logging - fisheries, tourism, and Alaska Crossings, 

a program that immerses at-risk youth in the natural environment.

The economy of Wrangell is no longer dependent on the logging 

industry. I think everyone agrees that the very small local operations 

should be encouraged but most people that I have talked to are revolted 

by the idea of becoming a logging town again. To reopen this wound by 

reintroducing logging on a large scale is an insult to those who have 

worked to develop alternatives. It is an insult to the lawmakers and tax 

payers that awarded Wrangell the development money. It is quite 

possible that the small mills that currently operate here would be put out 

of business.

Summary,

1. Wrangell Island has been host to some of the most depredatory 

logging practices for well over a century. There is little untouched old 

growth left on the island.

2. The industry has not had a good record as stewards of the land or 

good neighbors.

3. Wrangell has become dependent on industries that would suffer if 

large scale logging were to be reintroduced. The boom and bust nature 

of logging is harmful to the growth and maturation of the community.

Tim Murray

522 Zimovia Ave.

Wrangell, AK 99929

Please see response to comment 054-CBW-04.
Appendix B

Wrangell Island Project FEIS ♦ 69

Comment 

Number Comment Response

Captco@aol.com

048-TUSCS Trout Unlimited

Sitka Conservation Society

July 18, 2016

Robert Dalrymple, 

District Ranger, Wrangell Ranger District 

PO Box 51, 

Wrangell, AK 99929 

comments-alaska-tongass-wrangell@fs.fed.us 

Attn: Wrangell Island Project 

Dear Mr. Dalrymple, 

Please accept these comments on the Wrangell Island Project Draft 

Environmental Impact Statement (DEIS) submitted on behalf of Trout 

Unlimited (TU) and the Sitka Conservation Society (SCS). We appreciate 

the opportunity to provide input in this process. TU has a long history of 

working collaboratively with the U.S. Forest Service (USFS) throughout 

the National Forest System, and both TU and SCS have enjoyed a 

lengthy and fruitful partnership with the USFS on the Tongass National 

Forest (Tongass). Both organizations are committed, through the 

investment of significant staff and financial resources, to protecting and 

restoring important fish, wildlife and water resources on the Tongass, 

and to ensuring the region’s unique wild salmon resources continue to 

serve as the economic, cultural and spiritual backbone of Southeast 

Alaska. 

TU is the nation’s largest sportsman’s organization dedicated to 

coldwater conservation with more than 1,000 members, and tens-ofthousands of additional supporters, in Alaska that are passionate 

anglers, lodge owners, fishing and hunting guides, and commercial 

fishermen, among other various other occupations. In addition to 

members in more remote parts of the state, TU has active chapters in 

Fairbanks, Anchorage and the Mat-Su, on the Kenai Peninsula, and in 

Juneau. TU members regularly hunt and fish on the Tongass for sport, 

commercial and subsistence purposes. Many of our members make their 

living from the forest’s fish, wildlife and water resources.
BAppendix

Wrangell Island Project FEIS ♦ 70

Comment 

Number Comment Response

SCS has been working to protect Southeast Alaska’s quality of life and 

the Tongass National Forest since 1967. Based in Sitka, Alaska, SCS 

has more than 1,000 local members that use and depend on the natural 

resources the Tongass provides, and SCS is investing significant 

resources to ensure the Tongass is managed so these important 

resources continue to be available for future generations. SCS is 

committed to the conservation of wilderness areas and to the sustainable 

development of Southeast Alaska’s natural resources. SCS’ Executive 

Director, Andrew Thoms, served on the Tongass Advisory Committee 

(TAC). 

The Wrangell Island Project has undergone numerous iterations in 

recent years. As currently envisioned in the DEIS preferred alternative, 

this project risks significant deleterious impacts to important fish and 

wildlife habitat, threatens to undermine the collaboratively-developed 

TAC recommendations and the on-going forest plan amendment, would 

further erode the public’s trust in the USFS to make good on its promise 

for a meaningful transition, and comes at the expense of the region’s 

economic base: the fishing and tourism industries. In particular, TU and 

SCS have the following concerns with the project and DEIS: 

The collaboratively developed TAC recommendations included 

support for “bridge” timber for industry during the transition to 

young growth. This project would contribute to that supply of 

“bridge” timber.

048-TUSCS01I. Logging or Road Building Activities Should not Occur within HighValue Habitat. 

The Tongass is the nation’s top salmon-producing forest. Sport, 

commercial and subsistence fishing of Tongass salmon contributes $1 

billion annually to the regional economy and accounts for 10% of 

Southeast Alaska’s employment. In addition to this, more than a million 

out-of-state visitors flock to the Tongass each year, contributing another 

$1 billion annually and accounting for another 15% of regional 

employment. Both of these industries, which are far and away the 

region’s top sources of earnings and employment, rely entirely on in-tact 

fish and wildlife habitat, beautiful scenery, and untouched landscapes. 

While stream buffers and other standards and guides provide some 

assurances against the most severe impacts to important fish, wildlife 

and water resources, they are inadequate to fully protect sensitive 

watersheds from serious and long-term impacts. As we have seen time 

and time again, development activities that appear relatively minor when 

considered in isolation can combine to have catastrophic impacts on 

local fisheries and fish-producing waters. Wrangell Island, in particular, 

See response to comment 048-TUSCS-04, 061-GSACC-06 and 

the Aquatics Resource Report.

Fish habitat and the watershed resource, including the T77 

watersheds, in the Wrangell Island Project, were analyzed for the 

project. At the Forest-level, the T77 watersheds are addressed in 

the 2016 Forest Plan. The action alternatives no longer include 

the harvest units within the T77 watershed and The Nature 

Conservancy/Audubon conservation priority area VCU 4790, and 

are consistent with the 2016 Forest Plan.

Please see the “Relationship to the Forest Plan” section of 

chapter 1 of the Wrangell Island Project FEIS.

The application of BMPs and Forest Plan standards and 

guidelines including stream buffers have been found to be 

effective in protecting fish, water and wildlife resources. It is 

anticipated that the fish resources in the project area would not 

be measurably affected. Watershed effects within the project 

area are presented in the “Aquatics” section of chapter 3 of the 
Appendix B

Wrangell Island Project FEIS ♦ 71

Comment 

Number Comment Response

has been the site of significant past logging and road building. With 

newly-proposed timber harvest and road building activities planned on 

top of and between past harvest units, impacts to important fish and 

wildlife resources will compound.

As was unanimously recognized by the TAC and various other 

organizations, certain watersheds are too important for their fish and 

wildlife values, are too vulnerable to impacts from development, and 

should be entirely off-limits to old-growth logging. These high-value 

areas include the Tongass 77 watersheds, conservation priority areas 

from the Audubon/TNC Ecoregional Assessment, Inventoried Roadless 

Areas, and Phase 2 and 3 areas from the 2008 Tongass Land and 

Resource Management Plan. Old-growth logging within these areas is 

incompatible with the intended use and desired conditions of the area, 

and therefore the USFS should take extra care to ensure no logging or 

road building activities are planned within these important and sensitive 

areas. 

EIS and in the “Environmental Consequences” section of the 

Aquatics Resource Report. 

Please see response to comment 048-TUSCS-02

048-TUSCS02a. Logging and Road Building Should be Prohibited Within the Thoms 

Lake VCU. 

In particular, no old-growth logging or road building activities should be 

planned within the Thoms Lake VCU (4790). This VCU contains two 

major and six minor anadromous fish-bearing streams, all of which are 

important to local fisheries. Thoms Creek is the most productive salmon 

stream on Wrangell Island, providing a diversity of lake, stream and 

estuary habitats, and supporting an important subsistence sockeye 

fishery. It also supports chum, coho and pink salmon, as well as 

steelhead, cutthroat trout and Dolly Varden. In addition to Thoms Creek, 

Skip, April, Bearing, Cinnamon, Haux, and another unnamed creek, all 

within the Thoms Lake VCU, also contribute significantly to the fishery. 

Beyond these fisheries values, the Thoms Lake VCU also contains 

significant wildlife values and hosts important winter deer habitat.

All alternatives evaluated by the DEIS include timber units and road 

building within the Thoms Lake VCU. As currently envisioned, the 

preferred alternative proposes numerous units within the Thoms Lake 

VCU, including but not limited to units 624, 701, 704, 705, 710, 711, 720-

22, 724, 725, 728, 731, 733, and 736. Additional units may exist within 

Thoms Lake that we could not identify due to the limited maps made 

available in the DEIS. According to the unit cards, these units account for 

roughly 5.4 mmbf from 442 acres in the preferred alternative, which is a 

Comment noted. The condition and effects of the alternatives on 

watersheds and fisheries are presented in the “Aquatics” section 

of chapter 3 of the EIS. VCU 4790, which includes the Thoms 

Creek watershed, is also addressed in the Aquatics Resource 

Report.

The action alternatives no longer include the harvest units within 

the T77 watershed and The Nature Conservancy/Audubon 

conservation priority area VCU 4790, and are consistent with the 

2016 Forest Plan.
BAppendix

Wrangell Island Project FEIS ♦ 72

Comment 

Number Comment Response

small fraction of the 65 mmbf contemplated in the preferred alternative. 

Yet, harvesting old-growth timber from these units poses serious risks to 

nearby streams and important fish and wildlife habitat, and directly 

conflicts with the recommendations of the TAC and the proposed forest 

plan amendment.

Because of the important fish and wildlife values of the Thoms Lake 

VCU, the great importance of the fishing and tourism industries that 

depend on these resources, and the broad recognition by the TAC and 

others of the need to protect fish and wildlife resources in high-value 

habitat, the USFS should adopt an alternative that maximizes protections 

for fish and wildlife while eliminating altogether logging and road building 

activities from high-value areas such as the Thoms Lake VCU. 

Protecting Thoms Lake from logging and road building activities of the 

Wrangell Island Project will help ensure the project does not come at the 

expense of our most important fish and wildlife habitat.

048-TUSCS03b. Logging and Road Building Should be Prohibited Within Roadless 

Areas. 

Roadless Areas are hugely important for their fish and wildlife values, 

and for providing opportunities for solitude and remote primitive and wild 

recreation. Due to these important and widely-recognized values, the 

Roadless Rule generally prohibits road construction or logging in 

Inventoried Roadless Areas (IRAs). Consistent with this, the TAC 

recommended that no old-growth bridge timber should be sourced from 

IRAs and at various times the Secretary of Agriculture has reserved 

decision-making authority over timber sale activities in IRAs on the 

Tongass. 

The DEIS states that “all timber harvest and road building activities 

would be located outside any existing 2001 Inventoried Roadless Areas.” 

However, the 2001 inventory by itself is an incomplete inventory and the 

USFS must also take into account the 2003 Supplemental Environmental 

Impact Statement that expanded the Tongass roadless area inventory 

from 9.4 million acres to 9.6 million acres. The DEIS identifies the North 

Wrangell IRA as encompassing only the northern-portion of the block of 

Forest Service land north of the 6259 Road. However, nearly the entire 

block of USFS land north of the 6250 Road is Roadless and should be 

off-limits to logging and road construction. While all the action 

alternatives considered by the DEIS improperly contemplate logging 

within the North Wrangell IRA, the preferred alternative is especially 

There are no development activities proposed within the 2001 

inventoried roadless areas as part of the Wrangell Island Project. 

The Ninth Circuit Court of Appeals upheld the reinstatement of 

the 2001 Roadless Rule on the Tongass National Forest in 2011. 

Consequently, the 2001 Roadless Rule remains in effect in 

Alaska and the Forest Service continues to apply the Rule to the 

Tongass National Forest. The North Wrangell Island IRA 

boundary is defined in the 2001 Roadless Rule. 

The inventoried roadless area is defined in the 2001 Roadless 

Rule at 36 CFR 294.11 and is defined as: “Areas identified in a 

set of inventoried roadless maps, contained in Forest Service 

Roadless Conservation, Final Environmental Impact Statement, 

Volume 2, dated November 2000, which are held at National 

headquarters office of the Forest Service, or any subsequent 

update or revision of those maps.”
Appendix B

Wrangell Island Project FEIS ♦ 73

Comment 

Number Comment Response

egregious with Units 524 and 955-70 all occurring within the North 

Wrangell IRA. All of these units, and any others, that are sited within an 

IRA should be omitted from consideration so the final project can be 

brought into compliance with the Roadless Rule.

II. Timber Planning must be done at an Appropriate Scale. 

The DEIS provides various statements about the purpose and need for 

the project, including: (1) “to support the local and regional economies of 

Southeast Alaska;” (2) “to seek to provide a supply of timber . . . that 

meets market demand;” (3) “to restore and improve forest resources to a 

condition where they provide increased benefits to society;” and (4) to 

“help provide a reliable, long-term 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.”13 

However, various issues chronic to timber planning on the Tongass 

undermine the USFS’ ability to satisfy these purposes and needs with 

the Wrangell Island Project. 

048-TUSCS04a. The Wrangell Timber Sale Undermines the Local Economy. 

Timber planning too often comes at the expense of the region’s 

economic base of fisheries and tourism, and the Wrangell Island timber 

sale is no different. Once-productive salmon streams no longer support 

abundant salmon runs and ample wildlife populations when clearcut 

logging disrupts the recruitment of large-woody debris, erosion 

overburdens nearby streambeds, or road-stream crossings cut off 

important spawning or rearing habitat. Tourists and recreationists don’t 

travel to the Tongass to see and hike through large swaths of clearcut 

lands; they come to take in its scenic beauty and in-tact landscapes. The 

Forest Service has identified roughly 65 watersheds in need of 

significant restoration as a result of past logging and road-building 

activities and estimates it will cost $100 million to address the backlog of 

unmet watershed restoration needs. As currently envisioned, the 

Wrangell Island timber sale will create new restoration needs and further 

harm the region’s base in fisheries and tourism. 

As discussed above, fishing and tourism are the mainstays of Southeast 

Alaska’s economy. These industries—which have their foundation in 

healthy watersheds, in-tact fish and wildlife habitat, natural scenic beauty 

and untouched landscapes—depend heavily on the Tongass National 

There are no watersheds on Wrangell Island considered 

“impaired” on National Forest System lands. Restoration needs 

in Tongass National Forest watersheds are a legacy of logging 

practices used prior to 1980, such as harvest of riparian stands 

adjacent to sensitive fish streams. Current practices which 

prohibit old growth harvest of riparian forests are unlikely to 

create new restoration needs. Chapter 3 of the EIS and unit and 

road cards describe the protection measures that would be used 

for this project. Aside from improving fish passage at 

road/stream crossings, no major restoration needs have been 

identified on the National Forest System lands of Wrangell 

Island.

The record number of visitors to Southeast Alaska and the 

record level of salmon returns in recent years do not support the 

assertion that timber harvest causes economic harm to 

commercial fishing or tourism. In fact, the timber industry, 

although small, contributes to the overall economy of Southeast 

Alaska. The TAC and others recognize the importance of a 

timber industry in Southeast Alaska. The industry sectors are not 

necessarily exclusive of each other.
BAppendix

Wrangell Island Project FEIS ♦ 74

Comment 

Number Comment Response

Forest, which accounts for roughly 80% of the region’s land base and 

produces 79% of the regional salmon catch.

Fishing and tourism far outpace other private-sector sources of 

employment and earnings, and provide a steady and reliable source of 

employment and earnings for many Southeast Alaska communities. 

Despite decreases in Southeast Alaska’s timber industry, Southeast 

Alaska’s population increased 7 percent from 2000 to 2012 and personal 

income increased by 17 percent over the same period. Per capita 

income for Southeast Alaskans outpaces statewide and national 

averages while unemployment rates remain lower than statewide or 

national averages.17 Southeast Alaska’s economy remains strong, and 

is buoyed by its healthy fish and wildlife habitat, productive salmon 

streams and scenic beauty. Managing the Tongass with fish, wildlife and 

visitor services at the forefront is the key to ensuring local communities 

and economies are strong and stable. 

Please see the Biological Evaluation in the project record for 

more on effects to fish.

The Forest Service recognizes the importance of wild salmon 

and successfully protects them by protecting streams and water 

quality with the use of BMPs, buffers and Forest Plan standards 

and guidelines. The ongoing good condition of the fisheries from 

the Tongass National Forest reflects that management focus.

See response to comment 058-SEACC-02.

In order to support Southeast Alaska’s rural communities and be 

responsive to the needs of the region, the Forest Service should seek 

ways to improve protections for important fish and wildlife habitat and 

enhance visitor services. At the same time, instead of continuing to offer 

large old-growth timber sales that undermine the region’s job-producing 

industries, causes unnecessary and irreparable harm to important fish 

and wildlife habitat, and is a legacy program that would not exist if not for 

massive taxpayer subsidy, the Wrangell Island Project should be 

redesigned with the fishing and tourism industries at the forefront and to 

in every way possible avoid and minimize impacts to fish and wildlife 

habitat. Instead of designing the project as a large sale for export 

markets, the project should be scaled back and reconfigured to meet the 

needs of local small mills with domestic processing and manufacturing. 

When evaluating the benefits from forest lands to society, the USFS 

places far too much emphasis on traditional extractive resources that too 

often are export based while largely ignoring benefits from fish, wildlife 

and water resources. As discussed above, by far the most valuable 

activity occurring on the Tongass is derived from intact fish and wildlife 

habitat. This is true throughout the country, but is especially relevant in 

Southeast Alaska and on Wrangell Island where the Tongass comprises 

such a majority of the land base. Southeast Alaska’s timber industry 

pales in comparison to the region’s fishing and tourism industries. 

Maximizing the benefits from the Tongass to the public requires the 

The Wrangell Island Project was designed to minimize impacts 

to fish and wildlife and scenic resources. The Forest Plan 

resource protection requirements, in conjunction with the 

alternative designs in this project, would limit adverse impacts to 

other regional economic interests. Please also see response to 

comment 058-SEACC-03.

The project would contribute to a timber supply for both small 

and larger operators while minimizing impacts to fish and wildlife 

habitat. See response to comment 048-TUSCS-06.
Appendix B

Wrangell Island Project FEIS ♦ 75

Comment 

Number Comment Response

USFS to manage the Tongass in a way that keeps fish and wildlife at the 

forefront. 

048-TUSCS05b. The USFS Overestimates Market Demand for Tongass Timber while 

Neglecting Small Mills and Local Processing. 

The USFS consistently and artificially overestimates market demand for 

Tongass timber while failing to design timber sales that accommodate 

local mills and local processing. Too often, mill capacity is confused for 

market demand without accounting for the massive subsidies and longterm contracts that built up the Southeast Alaska timber industry, the ongoing subsidy required for its maintenance today, or other economic and 

social factors that have led to the Tongass timber industry’s steady 

decline in recent decades. This overestimation of market demand 

causes the USFS to consistently and inappropriately overinflate the size 

of its timber sales in an effort to maintain a massive shelf volume of 

timber.

At the same time, motivated by a desire to satisfy inflated demand 

estimates, the USFS designs projects that rely on export markets without 

providing a reliable and consistent supply for small mills that employ 

local processing and manufacturing. Properly scaled and appropriately 

placed timber sales will continue to evade the USFS on the Tongass so 

long as it continues to promote export over local processing and futilely 

chase artificially inflated market demand estimates that cannot be met. 

A true estimate of market demand must be expressed as a function of 

price, not as a fixed value. As price increases or decreases, demand will 

move in the inverse direction. As has been well documented, the 

Tongass timber program operates at tremendous financial loss to the 

Forest Service and federal taxpayers. Over a five year period from 2009 

to 2013, the Forest Service experienced a net loss of $713 for every 

thousand board-feet of Tongass timber sold and more than $20 million 

annually. However, timber demand estimates fail to account for this 

massive subsidy, which if passed on to the timber purchaser would 

certainly result in less demand for Tongass timber. Other forest users, 

including tour businesses, outfitters and guides, often are required by the 

Forest Service to cover costs of NEPA, trail maintenance, or other 

related staff costs—costs not borne by the Southeast Alaska timber 

industry and not fully accounted for in USFS market demand estimates. 

Comments on the methods used to determine the Tongass 

timber market demand are outside the scope of the Wrangell 

Island Project EIS.

Please see response to comments 058-SEACC-02, -09, and -10.

The Wrangell Island Project is designed to contribute an orderly 

flow of timber to both small and larger timber operators. 

Appendix A describes how the Wrangell Island Project fits into 

the Timber Program. 

The comment confuses the market demand of the industry with 

the land management costs of the Forest Service.
BAppendix

Wrangell Island Project FEIS ♦ 76

Comment 

Number Comment Response

In order to better serve the needs of Southeast Alaskans and the 

American public, the Forest Service must bring management of the 

Tongass more in-line with what is socially and ecologically acceptable. 

Rapidly ending the planning and sale of large-scale old-growth timber 

sales on the Tongass will reduce conflict and litigation, protect important 

fish and wildlife habitat, and help promote stable and strong local 

economy and communities. Designing reasonably scaled timber sales 

that cater to local processers and local demand will help stabilize timber 

industry employment while also conserving valuable old-growth forest. 

The Forest Service should publish a true market demand analysis that 

expresses demand for Tongass timber as a function of price, end the 

outdated practice of heavily subsidizing large-scale old-growth timber 

sales, and seek to meet the demand that exists when purchasers are 

required to bear the full costs of timber sale planning and administration, 

environmental review, and restoration. 

048-TUSCS06c. The Wrangell Sale Undermines a Meaningful Transition. 

In many regards, Southeast Alaska has already transitioned. Logging 

and milling of Tongass timber supports very few private sector jobs. 

Even when timber from private and state lands is included, the timber 

industry in Southeast Alaska still accounts for just a few hundred jobs. It 

is time for the Forest Service to catch up with the rest of the region and 

shift its Tongass timber program to one that plans and implements 

appropriately-scaled timber sales that support the region’s small mills 

and encourage local manufacturing of young-growth forest products. 

The past 60 years of industrial logging has targeted the rarest and most 

productive stands of large-tree old-growth forest on the Tongass, thus 

reducing the highest-volume contiguous old growth by 66 percent forestwide. This large-tree old-growth forest, which historically covers less 

than five percent of the Tongass, is among the most valuable habitat for 

fish and wildlife. The overwhelming weight of the scientific community 

recognizes the extraordinary value of the remaining big-tree old-growth 

and has repeatedly called on the Forest Service to speed up the 

transition and end its old-growth timber sale program.

While the forest products industry plays an important role in Southeast 

Alaska, recent old-growth timber sales have undercut the Tongass 

transition, eroded public confidence and trust in the USFS, and served 

as unnecessary obstacles to the creation of a sustainable timber industry 

with local manufacturing in the Tongass. Old-growth sales going back to 

Timber harvest continues to be a viable component of the local 

and regional economy of Southeast Alaska although it has 

diminished from previous decades. The project would contribute 

to the orderly flow of timber to large and small timber businesses 

and benefit the local and regional economies of Southeast 

Alaska. The project would also provide a supply of “bridge” 

timber that would support local jobs and facilitate the timber 

industry transition to a sustainable wood product industry based 

on young growth. The project would also provide a reliable longterm supply of “bridge” timber that would support local jobs and 

facilitate the timber industry transition to a sustainable wood 

product industry based on young growth.

The needs of small local mill operators are included in all of the 

action alternatives as part of the timber made available to 

industry. See Chapter 1 - Purpose and Need for Action. 

The TAC members supported supply of “bridge” timber as part of 

the transition to young growth.

While the Wrangell Island Project provides opportunities for local 

operators on Wrangell Island, the Forest Service also must 

consider the timber industry’s needs at a regional level. 
Appendix B

Wrangell Island Project FEIS ♦ 77

Comment 

Number Comment Response

the Log Jam timber sale, if not before, have been sold to the public as 

bridge timber and as a way to encourage the industry to transition. 

However, instead of offering a limited supply of old-growth timber in a 

way that prudently meters it out over time, the USFS appears to be trying 

to maximize the volume of old-growth timber it offers in each sale while 

continually developing new sales to offer out in the future. Rather than 

encouraging investment in transition technologies and entrepreneurship 

within the Tongass timber industry, this scheme encourages the timber 

industry to dig in its heels against the tides of change and to cut as much 

as possible as fast as possible with the assurance that future timber sale 

planning will provide new, highly-subsidized old-growth timber volume. 

The Wrangell Island timber sale is no different. It eschews opportunities 

with local mills and local timber processers in favor of a large, exportbased timber sale that caters to off-island purchasers. It also, curiously, 

fails to consider any alternative with a positive advertising rate and is 

inconsistent with the on-going forest plan amendment, both of which 

make it impossible to know what the project may look like once it’s 

implemented and more difficult to provide meaningful comment. 

Presumably, the USFS will cherry pick the most valuable timber units for 

sale from whatever alternative is chosen, excluding the remaining lowvalue units, but based on the information available in the DEIS it is 

impossible to tell what the final project will look like upon implementation. 

The Tongass is unique among our national forests because of its 

abundant and healthy wild salmon populations. These populations of 

wild salmon are the basis of the region’s most valuable industries, 

support communities within the region both big and small, and attract 

visitors from all over the world. Thank you for the opportunity to 

participate in this planning process and for your careful consideration of 

these comments. 

Sincerely, 

Austin Williams 

Alaska Director of Law and Policy 

Trout Unlimited 

3105 Lake Shore Dr. Suite 102B 

Anchorage, AK 99517 

(907) 227-1590 
BAppendix

Wrangell Island Project FEIS ♦ 78

Comment 

Number Comment Response

awilliams@tu.org 

Andrew Thoms

Executive Director

Sitka Conservation Society 

PO Box 6533

Sitka, AK 99835

(907) 747-7509

andrew@sitkawild.org

049-ST July 18th, 2016

Robert Dalrymple

District Ranger, Wrangell Ranger District,

PO Box 51

Wrangell, AK 99929

comments-alaska-tongasswrangell@fs.fed.us

Dear Mr. Dalrymple,

After reviewing the Wrangell Island Project DEIS, my view is that the 

alternatives offered would be very poor stewardship of the accessible old 

growth forest that remains on Wrangell Island by the US Forest Service. 

This project, as proposed, is extremely shortsighted in that it cuts a high 

volume of timber in a short amount of time. All of the alternatives in the 

DEIS will diminish deer habitat, and will harm subsistence deer hunters 

abilities to hunt in areas that they have traditionally used. The proposals 

in the DEIS will prevent small, local mills or aspiring specialty wood 

businesses from having a sustainable, long-term supply of accessible old 

growth timber in the form of small sale offerings or microsales.

049-ST-01 Comment 1 - The WIP FEIS must offer alternatives that do not harm 

deer populations, as well as do not harm subsistence deer hunters ability 

to hunt in areas that they have traditionally used. I deer hunt on Wrangell 

Island and depend on healthy populations of deer here. The WIP will 

harvest trees on approximately 5,300 acres of old growth habitat. While 

some of the acres are in helicopter units, many of these acres are 

proposed clear-cuts, which are of particular concern, as the wintering 

habitat for deer in these units will be lost. This could result in diminished 

deer populations, which in turn will affect deer hunters by reduced bag 

limits and shortened hunting seasons. 

Wildlife, including deer, are a key issue in the analysis, please 

see the “Key Issues” section in chapter 1 of the EIS. Alternatives 

were developed to address the key issues. Alternative 1 

proposes no action, and would not change the existing 

conditions with regard to timber harvest. Alternative 5 was 

developed to minimize the effects of timber harvest on deer and 

other species while meeting the purpose and need of the project. 

The effects of each alternative are presented in chapter 3 

“Wildlife” and “Subsistence” sections as well as in the Wildlife 

and Subsistence Resource Reports. 
Appendix B

Wrangell Island Project FEIS ♦ 79

Comment 

Number Comment Response

Some of the areas that are proposed to be clear-cut in the preferred 

alternative that I hunt in are units: 552, 553, 551, 557 and 610 in the 

Middle Ridge area, as well as units 682, 666, and 665 in the High Bush 

Lake area. All of these proposed clear-cuts are in areas that I depend on 

to provide habitat for the deer that I hunt. These units are also in areas 

that I traverse during deer season to access hunting. These stands of 

trees being clear-cut will greatly reduce my ability to walk and hunt in the 

places that I have come to depend on. In the preferred alternative the 

Forest Service is proposing clear-cuts, and logs that will mostly leave the 

island unprocessed, in exchange for diminished deer populations and 

habitat. 

Comment noted. Whether to harvest these units will be made at 

the time of decision.

049-ST-02 Comment 2 - The WIP FEIS must offer alternatives that focus on the 

needs of small mills and specialty wood businesses in the form of longterm, small timber sales and microsales. The Forest Service failed to 

offer any viable alternatives in the WIP DEIS that focused on local, small 

mills or stewardship contracts. Over the past 12 years, I have bought 

lumber from small, local mills when I could, and depend on these 

products as I upgrade and remodel my home on Wrangell Island. The 

expected timber development in the WIP will take place in 3 to 5 years 

and appears to cut the majority of the existing accessible old growth on 

and near the road system. Small mills that create local jobs, would be 

much better served by an alternative that has small offerings and 

microsales over the course of 3o years or more. Stewardship contracts 

should be included in this alternative. An alternative in the DEIS that 

focuses solely on small mills over a long period of time would be a much 

more sustainable approach to this project, and would foster longevity in 

some of these businesses, as well as attract more specialty wood 

businesses to this area. Cutting approximately 65 mmbf of timber in a 

few years and having most it leave this island unprocessed, while 

creating few long-term jobs is an abysmal attempt at managing our 

public lands and old growth forest resources. 

Please see responses to comments 051-SEACCWRC-07 and 

058-SEACC-05. 

Supplying a reliable economic supply of timber to large and small 

mills in Southeast Alaska is part of the goal of the Wrangell 

Island Project. Generally, alternatives with a higher volume of 

timber harvest yield more options to create opportunities for a 

variety of purchasers including small sale opportunities. The 

harvest units proposed in each of the Wrangell Island Project 

alternatives can be offered in a variety of timber sale and/or 

stewardship contract sizes, and would be determined on a yearly 

basis. 

The small sales program on Wrangell Island typically focuses on 

offerings with less-expensive conventional yarding methods and 

little to no road construction. Therefore, the extent of small sale 

opportunities correlates to the total harvest volume and more 

specifically to the volume proposed for harvest along existing 

roads using conventional logging systems. Construction of new 

roads in larger sales can also benefit small timber sale operators 

by increasing access to additional roadside timber volume. 

049-ST-03 As a resident that chose to make Wrangell Island my home over 17 

years ago, I am deeply disappointed in the alternatives in WIP DEIS. The 

Wrangell Island Project would sacrifice the remaining, accessible old 

growth on the island that local deer hunters and businesses will rely on 

for generations to come, in exchange for an export-driven project that is 

unsustainable. This project, as proposed, will harm the long-term viability 

of the community of Wrangell both environmentally and economically. 

Comment noted. Please see figures 2 and 3 of the FEIS.
BAppendix

Wrangell Island Project FEIS ♦ 80

Comment 

Number Comment Response

For these reasons, please consider and respond to the comments 

above.

Sincerely, 

Stephen Todd

050-ADNR THE STATE of ALASKA

GOVERNOR BILL WALKER

Department of Natural Resources

DIVISION OF FORESTRY CENTRAL OFFICE

550 W. Seventh Avenue, Suite 1450

Anchorage, AK 99501-3566 

Main: 907.269.8463

Fax: 907.269.8931

July 18, 2016

Robert Dalrymple, District Ranger

Tongass National Forest, Wrangell Ranger District

P.O. Box 51 Wrangell, AK 99929

RE: Wrangell Island Project Draft Environmental Impact Statement 

Dear Mr. Dalrymple:

The Alaska Department of Natural Resources welcomes the opportunity 

to review and comment on the U.S. Forest Service's (USFS) Draft 

Environmental Impact Statement for the proposed Wrangell Island 

Project. Previously the State of Alaska was a Cooperating Agency for 

implementation of the 2008 Tongass Land Management Plan and 

associated project level work during the Scoping phase for this DEIS in 

2011, and we submitted consolidated scoping comments on February 

14, 2011. That input took place under at least three Memoranda of 

Understanding (MOU) (08MU-11100500-109; 08MU-11100500-110; and 

09MU-11100500 -030). Subsequently, these earlier MOUs were 

replaced with 14-MU-11100500-022. The purpose of this 2014 MOU is 

"to maintain an established framework of cooperation between the U.S. 
Appendix B

Wrangell Island Project FEIS ♦ 81

Comment 

Number Comment Response

Forest Service and the State of Alaska related to implementing and 

monitoring the Tongass Land and Resource Management Plan." 

050-ADNR-01 The Forest Service requests the State of Alaska to act as a cooperating 

agency; however, the State of Alaska will accept such requests on a 

case-by-case basis. To date, the State has chosen not to accept any 

requests to be a cooperating agency.

Nonetheless, the Alaska Department of Natural Resources supports 

continued close cooperation with the U.S. Forest Service and the 

Wrangell District on timber management issues of mutual concern. 

The Forest Service has worked cooperatively with the State of 

Alaska in preparing the Wrangell Island Project EIS under the 

MOU prior to 2014. Alaska Department of Natural Resources 

and Alaska Department of Fish and Game employees worked 

with the IDT to develop alternatives and review maps and 

documents. Those employees brought valuable input from the 

State perspective into the process. 

One example of this cooperation is the 'Wrangell Island Road Use 

Agreement' between the Alaska Department of Natural Resources and 

the Forest Service's Regional Forester. This forest road right-of-way 

construction and use agreement was entered into by both parties on 

September 15, 1998. We request the Forest Service acknowledge this 

agreement in the Final EIS.

The State of Alaska remains committed to maintaining a Southeast 

Alaska timber industry. In 2011, the Alaska Legislature expanded the 

new Southeast State Forest to nearly 50,000 acres. The Commissioner

of the Alaska Department of Natural Resources adopted the Southeast 

State Forest Management Plan on February 29, 2016. While relatively 

modest in size, the Southeast State Forest is managed as a 'working 

forest' and it plays an important role is helping support the region's 

timber industry with key timber sales.

The road use agreement has been included in the Transportation 

Resource Report. The intent of road use agreement exemplifies 

the cooperative relationship the Forest Service has with the 

State of Alaska.

Comment noted. The Southeast State Forest Management Plan 

was included in the cumulative effects analysis and is included in 

the project record.

050-ADNR-02 The Division of Forestry prefers Alternative 2 of the Wrangell Island 

Project DEIS because it is best suited to provide a reliable, long-term 

supply of "bridge" timber that would support local jobs and the timber 

industry during the transition to a sustainable wood product industry 

based on future young growth management on the Tongass National 

Forest. 

Your support for Alternative 2 is noted.

050-ADNR-03 In addition, the Division of Forestry prefers Alternative 2 because it 

provides for more new, improved, and long-term forest road access to 

the industry and public than do the other alternatives. It is also critically 

important that Alternative 2 is designed to provide for both large and 

small timber sales, as the continued well-being of Alaska's timber 

industry needs both. We note that Alternative 2 calls for 66 percent of the 

harvested area to be cut using "single tree selection." This results in less 

impact on scenic values.

Your support of Alternative 2 for infrastructure development, 

improvement, and access management is noted.
BAppendix

Wrangell Island Project FEIS ♦ 82

Comment 

Number Comment Response

050-ADNR-04 A major concern we shared in our scoping comments of February 14, 

2011, remains, that "by not offering sufficient volume of timber -

consistent with the Tongass Timber Reform Act – while finalizing the 

Transition Framework, the USFS ensures it will not meet its stated goals 

of sustaining the remaining timber industry to allow for a transition to a 

young-growth dominated industry." This shortcoming is emphasized 

when comparing the Gate 1 Committee's recommendation in 2009 for a 

proposed action with 185 MMBF of timber harvest over 11 ,040 acres 

within Wrangell Island's Phase 1 land base with Alternative 2's proposed 

harvest of only 65.1 MMBF on 5,309 acres. A related concern is whether 

the overall economics of the proposed sale, considering low wood quality 

and current market conditions, will be positive or not. 

Alternatives 2 through 5 call for the harvesting of old growth timber using 

a mix of harvest types. There will be no harvest of second or younggrowth timber during the planning period because no commercially 

viable young-growth timber is available. It is important to consider key 

issues, such as scenic values, within the overall larger landscape context 

for these harvest alternatives. For example, there is an Old-Growth 

Reserve network on Wrangell Island, along with riparian management 

areas and beach buffers, plus additional areas affected by the Roadless 

Rule. All of these special areas are closed to timber harvesting.

The reduction in acres is a result of the application of the 2001 

Roadless Rule. Please see figure 3 in the FEIS, which displays 

the areas within the analysis area that are not available for 

timber harvest. The earlier volume estimates were based on the 

“Tongass exemption” from the 2001 Roadless Rule, which is no 

longer in effect. This exemption was published in the Federal 

Register on December 30, 2003 (Volume 68, Number 249). See 

response to comment 048-TUSCS-03.

While financial efficiency analysis using the FAST-R tool 

indicates deficit values for the alternatives as a whole based on 

historical costs and values, each sale from the Wrangell Island 

Project would need to have a positive advertised rate in order to 

advertise the sale for bid. The market conditions at the time of 

the offer would determine the economic feasibility. 

Please also see response to comment 058-SEACC-06.

050-ADNR-05 We support in principle a number of the potential stewardship-related 

opportunities described in the DEIS. While we recognize these 

stewardship opportunities are not covered by this DEIS, and will require 

going through their own NEPA-DEIS/FEIS process, they are dependent 

to a large degree on timber revenues produced by sales resulting from 

the Wrangell Island Project. Among these, the Pats Lake area 

restoration, improvements to the Pats Lake road and Forest Service 

right-of-ways, and the completion of the north Wrangell loop road are 

viewed as being beneficial to the Wrangell Island community as well as 

timber operators. Recognizing that the State of Alaska resources are 

limited, there may be indirect ways for the State to support these future 

stewardship opportunities.

The Alaska Department of Natural Resources recommends that the U.S. 

Forest Service ensure that the final Wrangell Island Project contributes 

to sustaining the remaining timber industry during the transition to a 

young-growth dominated industry. We prefer Alternative 2, since it is the 

alternative that comes closest to sustaining the timber industry, even 

though it still falls short of meeting demand.

The Forest Service looks forward to working with the State and 

other land owners within the analysis area on future stewardship 

projects.
Appendix B

Wrangell Island Project FEIS ♦ 83

Comment 

Number Comment Response

Sincerely,

Tim Dabney

Regional Forester

051-

SEACCWRC

Southeast Alaska Conservation Council

224 Gold Street

Juneau, AK 99801 

www.seacc.org 

907 586-6942

Sent via email July 18, 2016

M. Earl Stewart, Forest Supervisor Tongass National Forest

648 Mission Street

Ketchikan, AK 99901

comments-alaska-tongass-wrangell@fs.fed.us

Dear Forest Supervisor Stewart:

The Southeast Alaska Conservation Council and Wrangell Resource 

Council submit these comments on the 2016 Draft Environmental Impact 

Statement (DEIS) for the Wrangell Island Project (WIP). These 

comments supplement the more comprehensive comments submitted 

July 18, 2016 by Earthjustice on behalf of several groups, including 

SEACC and WRC.

For over four decades, SEACC has actively participated in Tongass 

management at all levels. Inspired by the land, wildlife, cultures, and 

communities of Southeast Alaska, SEACC’s mission is to protect the 

special places of the world’s largest temperate rainforest, promote 

conservation, and advocate for sustainable human use of natural 

resources. The residents of Wrangell Island who make up WRC support 

maintenance of a viable, livable community that uses all of the island’s 

natural renewable forest resources sustainably. Their livelihoods range 

from commercial fishing and small timber mill operations to local 

business and health care.
BAppendix

Wrangell Island Project FEIS ♦ 84

Comment 

Number Comment Response

Since January 2011, SEACC and WRC have worked in good faith with 

the Borough of Wrangell, local small mill owners, and others to design a 

collaborative and sustainable logging program on Wrangell Island. 

051-

SEACCWRC01

The Forest Service promised a timber sale on Wrangell Island that 

sustains rural prosperity, preserves and maintains forests, and provides 

an economically viable supply timber for the long-term. Instead, the WIP 

DEIS proposes nothing but wasteful, money-losing alternatives that 

sacrifice essential old growth deer habitat on Wrangell Island to support 

an export-driven timber program while the island’s recreation and 

tourism infrastructure (cabins, trails, and campsites) crumble because of 

budget cuts and reduced staffing. After years of efforts by WRC, 

SEACC, the Borough of Wrangell and others to promote a collaborate 

approach to this project, the Forest Service remains stuck pursuing an 

unrealistic and unsustainable approach to forest management that 

sacrifices the long-term economic, social, and ecological values of 

Wrangell Island.

The DEIS identifies Alternative 2 at the agency’s preferred alternative. 

This alternative calls for logging 65 mmbf of old-growth forest from 

approximately 5,309 acre and bulldozing 17.2 miles of new road and 

14.9 miles of temporary roads along with reconditioning 5.8 miles of 

existing roads. The new roads will cost nearly $5.5 million dollars. High 

road development costs mean more old growth habitat must be clearcut 

to pay for the new roads. 

The purpose and need for the project are presented in chapter 1. 

All action alternatives meet the purpose and need. The Forest 

Service worked collaboratively with the City and Borough of 

Wrangell, the State of Alaska and the US Fish and Wildlife 

Service in the development of the alternatives.

051-

SEACCWRC02

At this stage, all the action alternatives appear economically infeasible 

and appraise negatively, even with the current Region 10 export policy in 

place.

While the financial efficiency analysis using the approved FASTR tool indicates deficit values for the alternatives as a whole, 

based on historical costs and values, each sale from the 

Wrangell Island Project would need to have a positive advertised 

rate in order to advertise the sale for bid. The market conditions 

fluctuate dramatically and the market conditions at the time of 

the offer would determine the economic feasibility of each sale.

Please see the Timber Economics Resource Report and FASTR financial efficiency analysis for information on the economic 

modelling, including caveats and assumptions. Please note that 

the results from the FAST-R economic model are not equivalent 

to an appraisal and are only meant to be a tool to compare 

alternatives. 
Appendix B

Wrangell Island Project FEIS ♦ 85

Comment 

Number Comment Response

051-

SEACCWRC03

Without explanation, the Forest Service failed to consider the “Small Mill 

and Wildlife Alternative” submitted by the Wrangell Resource Council & 

SEACC in 2011. This is surprising given District Ranger Dalrymple’s 

instructions in the Wrangell Island EIS Project Initiation Letter:

The [Interdisciplinary Team] should develop a range of alternatives 

including the No Action Alternative, the Proposed Action Alternative, and 

additional action alternatives that respond to the purpose and need and 

key issues. These should include an alternative (s) to address public 

comments from the public [and] SEACC.

Unlike the action alternatives disclosed in the DEIS, our alternative 

focused on:

• Ensuring a consistent, long-term supply of economic timber to 

small mills in Wrangell from small sales along the existing road system 

over a 30-year transition timeframe. 

• Maintaining Wrangell Island’s deer population. 

• Integrating wildlife and fish habitat restoration, recreation, and 

stewardship activities into the project based on the “Good for Services” 

model.

As developed, this Small Mill and Wildlife Alternative recognized the 

importance of customary and traditional hunting, fishing, and gathering 

on Wrangell Island and the recreation and tourism economy that relies 

on intact watersheds and landscapes. Unlike the action alternatives in 

the DEIS, our alternative provided the greatest direct economic benefit to 

the community of Wrangell while maintaining a healthy forest ecosystem 

on Wrangell Island. Failing to take a hard look at our alternative violates 

NEPA. Had the Forest Service considered it, perhaps they would not 

have offered such economically infeasible alternatives as it did. The 

agency’s own “timber economics report” notes important factors for the 

economic impracticability for the action alternatives, including use of the 

Viking Mill in Klawock, over 130 miles away, for calculating tow costs, 

and high-cost helicopter yarding. The Small Mill and Wildlife Alternative 

would have supplied local mills with reasonable supply of old growth for 

decades from the existing road base. 

Regarding the Small Mill and Wildlife alternative, please see 

response to comment 058-SEACC-05.

Regarding the range of alternatives, please see response to 

comment 061-GSACC-10.

By ignoring this proffered alternative, the agency missed an important 

collaborative opportunity to work with local residents on a communityforest project that makes long-term sense for the entire community 

The Forest Service worked collaboratively with the City and 

Borough of Wrangell in the development of the alternatives. The 

Forest Service hosted numerous public meetings and worked 
BAppendix

Wrangell Island Project FEIS ♦ 86

Comment 

Number Comment Response

economy. The agency must scrap this DEIS and issue a revised draft 

EIS that includes this reasonable alternative; the DEIS is so inadequate 

as to preclude meaningful analysis. See 40 C.F.R. § 1502.9(a), (c).

I. The Agency Violated the Tongass Timber Reform Act, National Forest 

Management Act, and NEPA by Failing to Disclose and Consider an 

Annual Market Demand Calculation for 2016.

The agency identifies the underlying need for the WIP coming from “from 

the Forest Service’s obligation, subject to applicable law, to seek to 

provide a supply of timber from the Tongass National Forest that meets 

market demand annually and for the planning cycle . . . .” WIP DEIS at 4. 

The agency begins its analysis regarding Issue 1: Timber Economics 

and Availability with the explanation:

In order to meet this objective, the project is designed to include 

sufficient units and volume to allow the Forest Service to adjust future 

timber sale offerings from the project area to meet fluctuating market 

conditions.

DEIS at 62. Its cumulative effects analysis on this issue notes: “Timber 

harvest under the action alternatives would contribute to meeting 

projected market demand for timber in Southeast Alaska and support 

logging and sawmill or export jobs.” DEIS at 65.

In explaining the reasons for conducting environmental analysis of the 

WIP, the DEIS explains how the agency develops forecasts for market 

demand. See DEIS, Appendix A at 278-282. Inexplicably, the DEIS only 

provides information identifying “the goal for volume of timber to be 

offered” for FY 2014 but not FY 2016. Id. at 282.

regularly with the Wrangell Economic Development Committee 

and the Wrangell Cooperative Association. 

The Wrangell Island Project Analysis has been prepared in 

compliance with the Tongass Timber Reform Act and other 

applicable laws, including NFMA and ANILCA. The resource 

impact analysis is conducted and documented in the resource 

reports (located in the project record), and the EIS is, for many 

resources, a summary of those reports.

The 2017 annual timber demand is described in Appendix A -

Rationale for Scheduling the Environmental Analysis for the 

Wrangell Island Project and has been updated to reflect the 

Daniels et al. 2016 demand analysis.

051-

SEACCWRC04

A. Failure to Prepare and Consider a Current Annual Market Demand 

Projection for FY 2016 Violates the Tongass Timber Reform Act.

In findings related to the TTRA in the ROD for the 1997 Revised 

Tongass Plan, Regional Forester Janik stated:

Legal advice to the Forest Service indicates that annual timber sale 

offerings from the Tongass National Forest will be limited to an amount 

of timber for which there is demand, as referred to in (sic) TTRA. The 

Forest Service will develop procedures to ensure that annual timber sale 

offerings are consistent with market demand.

1997 TLMP Revision ROD at 37 (emphasis added). As directed, the 

Forest Service prepared and adopted these procedures in 2000, named 

the “Morse methodology” after their author. Subsequently, as explained 

in the 2008 TLMP Amendment ROD:

The Wrangell Island Project was conducted in compliance with 

NEPA and TTRA. Appendix A of the EIS describes market 

demand for timber.
Appendix B

Wrangell Island Project FEIS ♦ 87

Comment 

Number Comment Response

The Forest Service adopted the Morse methodology as the means by 

which the agency complies year-by-year with the annual demand portion 

of the TTRA “seek to meet” requirement. Similarly, the agency intended 

to comply with the requirement to seek to meet demand “for each 

planning cycle” through a series of annual applications of the Morse 

methodology.

2008 TLMP Amendment ROD at 30 (emphasis added). The TTRA limits 

the timber that the Forest Service can offer on the Tongass to timber "for 

which there is demand” and the Forest Service complies with the TTRA, 

by conducting the Morse methodology annually. The failure to do so in 

2016 violates the TTRA’s “seek to meet” prerequisite.

051-

SEACCWRC05

B. Failing to Apply Applicable Procedures for Calculating Annual Market 

Demand in FY 2016 Violates NFMA.

The NFMA requires that ‘‘resource plans and permits, contracts and 

other instruments for the use and occupancy of National Forest System 

lands shall be consistent with the land management plan.” 16 U.S.C. § 

1604(i). The 2008 TLMP Amendment ROD established the annual 

average volume of timber that could be offered over the life of the plan; it 

also directed the agency to comply with the annual year demand portion 

of the TTRA “through a series of annual applications of the Morse 

methodology.” See 2008 TLMP Amendment ROD at 30. Failing to follow 

direction for complying with the TTRA, as provided for in the 2008 TLMP, 

violates the National Forest Management Act.

For the record, the recently released draft Record of Decision for the 

2016 TLMP Amendment reaffirms existing plan direction:

The Forest Service adopted the Morse methodology as the means by 

which the agency complies year-by-year with the annual demand portion 

of the TTRA “seek to meet” requirement. Similarly, the agency intended 

to comply with the requirement to seek to meet demand “for each 

planning cycle” through a series of annual applications of the Morse 

methodology.

Draft ROD at 25.

The Wrangell Island Project Analysis has been prepared in 

compliance with NFMA. There is no requirement in NFMA to 

provide an annual demand calculation. 

051-

SEACCWRC06

C. The Agency’s Failure to Make and Disclose a FY 2016 Annual Market 

Demand Calculation in the DEIS Violates NEPA.

The agency claims it uses the annual market demand forecast “to set the 

short-term goals or the Tongass Timber Program – volume the Forest 

plans to offer in the current year, pending sufficient funding and sufficient 

NEPA-cleared volume.” DEIS at 281. Absent from the DEIS and 

planning record, however, is of the detailed, comprehensive monitoring 

The Wrangell Island Project Analysis has been prepared in 

compliance with NEPA and other applicable laws and 

regulations. Comments on regional annual market demand 

calculations are outside the scope of this project analysis.

The Wrangell Island Project DEIS used the most current annual 

timber demand analysis available. At that time, the timber 
BAppendix

Wrangell Island Project FEIS ♦ 88

Comment 

Number Comment Response

information the Forest Service claims is required by the Morse 

methodology. Id. Failing to make and disclose the annual market 

demand calculation and accompanying monitoring data for Tongass 

timber in the WIP DEIS violates NEPA because it fails to fully inform the 

public how the agency is complying with the annual demand portion of 

the TTRA “seek to meet” direction.

We recommend the agency withdraw this DEIS and issue a revised draft 

EIS because the lack of this critical information precludes meaningful 

analysis. See 40 C.F.R. § 1502.9(a), (c).

Appendix H at H-6 Project-level NEPA documents also describe how 

each specific timber sale meets the TTRA requirement to seek to meet 

market demand for Tongass timber while also providing for the multiple 

use and sustained yield management of the Forest’s renewable 

resources.

demand was being assessed through a Forest Plan Amendment. 

The 2017 annual demand has now been calculated and 

disclosed in the Wrangell Island Project FEIS, appendix A.

051-

SEACCWRC07

Agency Fails to Take a Hard Look at the Effect of the Current Export 

Policy Affects Local and Regional Economies.

According to the analysis in the Final Environmental Impact Statement 

(FEIS) for the 2016 TLMP Amendment:

NEPA analysis of the effects of the Limited Export Policy has been 

conducted at both at the programmatic and site-specific levels since its 

adoption. While analysis at the forest plan level assists the agency in 

selecting among management alternatives, the forest plan itself also 

does not authorize the harvest of timber without further, site-specific 

NEPA review. Project-level NEPA analyses evaluate the effects of timber 

sales in light of the policy including potential effects on in-state 

employment and the financial efficiency of project alternatives.

2016 TLMP FEIS, Appendix H at H-6. Unfortunately, the WIP DEIS lacks 

any such analysis.

Although our initial scoping comments identified our interest in design of 

a sustainable timber program for “local, value-added wood 

manufacturers,” the DEIS totally fails to evaluate the effects of the 

proposed sale on these local businesses. The DEIS offers only a general 

statement that the “[c]urrent export policy allows 100 percent Alaska 

yellow-cedar export plus hemlock/spruce export equal to 50 percent total 

sale net sawlog volume” DEIS at 66. The DEIS does not try to explain 

the environmental and economic effects of this policy. Inexplicably, the 

Forest Service does not even identify the export policy as one of the 

effects analysis indicators for Issue 1, Timber Economics and 

Availability. DEIS at 63.

See chapter 3 of the EIS, Timber Economics and the Timber 

Economics Resource Report.

The analysis includes consideration of current export policy in 

the financial efficiency analysis used to compare the alternatives.

The effect of the current export policy on employment is shown 

in the Wrangell Island Project FEIS (see Table 10. Alternative 

comparison of the measures and potential effects of project 

activities on timber supply and timber sale economics) in the 

“Timber Economics and Availability” section of chapter 3. It was 

inadvertently left off table 12 in the DEIS. The number of 

annualized jobs was listed as one of the indicators in the “Timber 

Economics and Availability” section of chapter 3 of the DEIS, and 

in the FEIS has been clarified to explain that this compares the 

number of jobs supported by 100 percent domestic processing 

(with the exception of yellow-cedar which is considered surplus 

to Alaska markets) to the jobs supported if the current export 

policy was used to the fullest extent. However, this is only an 

estimate since it is up to the purchaser to decide if the material 

that can be exported is sawn at a local mill, including yellowcedar. There is no requirement to export. 

A more detailed explanation on how the export policy benefits 

purchasers in the 2016 Forest Plan, appendix H. Briefly, it 

provides another market for low-grade material that may not be 
Appendix B

Wrangell Island Project FEIS ♦ 89

Comment 

Number Comment Response

In recommending the new export policy to the Regional Forester, the 

Director of Forest Management advised the new policy “would increase 

the utilization of small diameter and low grade timber . . ., level the 

playing field with industry in the lower 48 . . ., [and] also increase returns 

to the Government from the sale of timber from the Tongass. See Memo 

from Forest Management Director Castillo to Regional Forester Bschor 

(Mar. 13, 2007). Missing from the WIP DEIS is any evaluation of how 

effective the new policy has been in achieving these objectives. Without 

disclosing and evaluating real data, neither the public nor 

decisionmakers can meaningfully evaluate the benefits or costs of the 

policy.

One of the stated forest-wide multiple use goals for this timber project is 

the management of Tongass timber “for production of saw timber.” DEIS 

at 4. No explanation is given for how allowing the export (in the round) of 

up to 50 percent of the project’s timber assists the Forest Service’s 

achievement of this goal.

Appendix A states “[d]emand for Tongass National Forest timber 

currently depends on markets for sawn wood and exports of softwood 

logs.” DEIS at 281. Missing from the DEIS is any data or analysis 

supporting this assumption. Neither can the Forest Service rely on the 

programmatic effects analysis, such as it is, in the 2008 or 2016 TLMP. 

Given the deficit appraisals projected for all the action alternatives with 

and without export, what basis does the Forest Service have for a 

conclusion that export increases utilization of Tongass timber, improves 

sales economics, or results in increases the appraised value of project 

timber?

efficiently and profitably utilized at the local mill. It also allows 

Alaskan purchasers to be more competitive with their 

competitors. Thirdly, it allows some sales to appraise positively,

which has been a requirement for most of the Appropriations 

Bills. Other regions can offer deficit sales if there is sufficient 

interest. Often, a purchaser can be more cost-effective than the 

appraisal program allows. 

051-

SEACCWRC08

III. Forest Service Fails to Follow Internal Agency Direction for 

Computing Financial Efficiency Analysis as Required in the Forest 

Service Handbook.

FSH 2409.18_32.2 directs agency planners how to compute financial 

efficiency of project alternatives at the Gate 2 stage. This analysis should 

compare estimated Forest Service direct expenditures with estimated 

financial revenues. According to the Handbook, planners are to “[u]se 3-

year average historical costs to estimate the costs of implementing future 

timber sale projects.” FSH 2409.18_32.22. Although R-10 Supplement 

2409.18-2013-1 approves use of the Financial Analysis Spreadsheet 

Tool – Residual Value (“FAST-R”), it does not specifically delete, amend, 

or modify National FSH direction regarding disclosure and analysis of 

historical cost data.

See response to comment 061-GSACC-25. The financial 

information can be found in the Timber Economics Resource 

Report. The analysis followed the FSH 2409.18-32.2 direction. 

Please refer to the Timber Supply and Economics Resource 

Report.
BAppendix

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Comment 

Number Comment Response

Why didn’t agency planners disclose 3-year average historical costs from 

2012-2015? Failing to do so violates the agency internal directives and 

NEPA. The FAST-R outputs are meaningless without disclosing all the 

data they rely on. This information is important because economic 

efficiency is goal of TLMP and this project and a comparison between 

direct expenditures and projected financial revenues provides a strong 

basis for comparison of the action alternatives.

051-

SEACCWRC09

IV. DEIS Ignores No Mention Made of the Direction in Executive Order 

13653 for the Forest Service to Manage Its Lands and Waters for 

Climate Preparedness and Resilience.

Missing from the DEIS is a reference to the November 1, 2013 Executive 

Order 13653. Neither does the DEIS support the required risk-informed 

decision making or explain what steps the agency proposes to take with 

this proposed project to improve climate preparedness and resilience, 

the President’s Climate Action Plan, or the Secretary’s explicit 

recognition of the Tongass’ global significance as a carbon-rich reserve. 

The supplemental DEIS should identify how the Forest Service’s 

management proposals for the natural infrastructure on Wrangell Island 

follow and promote the dual goals of improved climate resilience and 

carbon sequestration.

Climate change is addressed in the “Air Quality and Climate 

Change” section of chapter 3 of the FEIS. In the intervening time, 

Executive Order 13653 has been rescinded by EO 13783 and is 

no longer applicable to the Wrangell Island Project. The issues 

identified by the commenter are addressed in both chapter 3.1 

and appendix I of the 2016 Forest Plan FEIS.

051-

SEACCWRC10

V. Proposed WIP Violates TLMP By Failing to Apply TLMP Standards.

The 2008 Amended Forest Plan describes desired landscape attributes 

on the Tongass as including maintenance of viable wildlife populations 

and the maintenance and improvement of fish and wildlife habitat “to 

ensure sustainable fish and wildlife and their uses.”6 To achieve these 

desired attributes, the Forest Service must manage the Tongass is such 

a way as to “[m]aintain the abundance and distribution of habitats, 

especially old-growth forests, to sustain viable populations in the 

planning area” and “[m]aintain habitat capability sufficient to produce 

wildlife populations that support the use of wildlife resources for sport, 

subsistence, and recreational activities.”

Incredibly, without explanation, the DEIS evaluates effects on various 

bird and wildlife populations in terms of whether the population will 

“persist.” The DEIS fails to disclose and evaluate whether the WIP will 

comply with the 2008 TLMP and maintain sufficient wildlife habitat to 

support sustainable wildlife populations on the Tongass, particularly deer 

and wolves. Not only does the DEIS violate NFMA by failing to assure 

compliance with TLMP requirements, it fails to demonstrate the project 

follows the agency’s obligations to provide for the multiple use and 

The Wrangell Island Project Analysis has been prepared in 

compliance with the Forest Plan and NFMA. The effects of the 

alternatives on fish and wildlife habitats are presented in chapter

3 of the EIS and the associated resource reports, located in the 

planning record. The findings are documented in the Biological 

Evaluations and Biological Analyses.

Viability is addressed at the Forest Plan level, not at the project 

level. The Forest Plan conservation strategy ensures viability 

and sufficient habitat to support wildlife populations on the 

Forest. The Wrangell Island Project analysis complies with the 

Forest Plan.

The language in the EIS has been clarified to explain that all 

effects are based on habitat. The remaining habitat would be 

sufficient to maintain populations on Wrangell Island.

Your support for the no action alternative is noted.
Appendix B

Wrangell Island Project FEIS ♦ 91

Comment 

Number Comment Response

sustained yield of all renewable forest resources under the Tongass 

Timber Reform Act.

For all the above reasons, we find the WIP DEIS so flawed at to preclude 

meaningful analysis. As proposed, the project is both economically and 

ecologically unsustainable. We support selection of the no action 

alternative.

Best Regards. 

Buck Lindekugel 

Grassroots Attorney 

Stephen Todd 

WRC Board President

052-NL To whom it may concern,

052-NL-01 Support Alternative 1 – which is the “no-action” alternative, no more 

logging. 

Thank you,

Nicole.L

Thank you for your comment. Your support for the no action 

alternative is noted.

053-RND 7/16/16

Wrangell Ranger District

Wrangell, Alaska

Dear Forest Managers:

In regards to plans to clearcutting of old growth in the Tongass Nat’l 

Forest, we would like to object to the idea on the following points:

053-RND-01 1.) Tourism is a higher & better use of this area & clearcuts are not 

what tourist come here to see.

2.) Developing trails in scenic locations would attract more tourism 

dollars & not have the high cost to taxpayers that is associated with 

subsidized logging.

Comment noted. 

Opportunities for future opportunities including recreation are

described in the “Stewardship Opportunities” section of chapter 1 

of the EIS. These proposals will require additional work before 

they can undergo a separate NEPA analysis.
BAppendix

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3.) Tourism has greater long term, lower impact on the forest, the 

community & the environment.

053-RND-02 4.) We come to Thoms Place each year to enjoy peace, quiet, 

fishing, great scenery & a clean environment. Logging is not what we are 

looking for.

No logging has been proposed in the viewshed of Thoms Place.

053-RND-03 We respectfully request that the Forest Service take no more action in 

pursuing the idea of clearcut logging in the Tongass Forest.

Regards,

Richard DeBusman

Nancy DeBusman

PO Box 2362

#2 Thoms Place

Wrangell, AK 99929

RN.DEB@Hotmail.com

Thank you for your comment. Your support for the no action 

alternative is noted.

054-CBW CITY AND BOROUGH OF WRANGELL

P.O. BOX 531

Wrangell, AK 99929 

(907)-874-2381

FAX (907)-874-3952

www.wrangell.com

July 15, 2016

Robert Dalrymple

District Ranger, Wrangell Ranger District 

Box 51

Wrangell, AK 99929

Re: City and Borough of Wrangell comments on the Wrangell Island 

Project Draft EIS

Dear Mr. Dalrymple:
Appendix B

Wrangell Island Project FEIS ♦ 93

Comment 

Number Comment Response

The Assembly recognizes the difficulties of putting a timber sale together 

in the political climate of today addressing all of the complex 

environmental and multi-use issues. We have reviewed the draft EIS for 

the Wrangell Island Timber Sale Project and provide comments below. 

We do have one concern about the timing of the release of this 

document. After so many delays, it is very unfortunate that the draft EIS 

is finally released during our busiest economic time when so many 

Wrangellites, those most directly affected by the implementation of this 

plan, are out of town and working and will likely not have access to the 

online document to review and comment. There is local interest not only 

regarding units to be harvested, but for the road management issue for 

recreation, tourism and subsistence is of utmost importance. 

054-CBW-01 The Borough supports the Proposed Alternative 2 in order to NEPA 

approve the maximum timber available. We hope that this will provide 

opportunities in the future for local business opportunities and job 

creation that can be sustained over a longer period of time. It appears 

that there is considerable helicopter logging of areas that might be more 

easily accessible and more economical if a road and even age 

management were utilized. The extensive partial cut units requiring 

helicopter logging are resulting in much higher harvest costs. In addition, 

it appears that only the higher value trees in these areas will be 

removed, to compensate for the high removal cost, thus leaving the 

residual timber stands with insufficient value to support an additional 

entry for future timber harvest. A single small or mid-size timber 

operation alone cannot meet the high cash flow requirement for an 

expensive helicopter logging operation, so a significant portion of the 

helicopter production must be sold into the log export markets where log 

prices are high enough to justify the helicopter logging costs. That 

reduces the incentive for local smaller timber mills and value added 

operations to initiate or grow a business opportunity. The Borough 

encourages some flexibility in sale design from uneven age management 

to even age management options. 

Your support for Alternative 2, to provide the most timber 

volume, is noted.

While helicopter logging is the most expensive of logging 

methods used in Alaska, it has been proposed in locations where 

roading and cable yarding are not feasible. It is also used to 

conduct partial harvest in areas where it is important to avoid 

ground disturbance in order to protect other environmental 

resources.

Please see response to comment 054-CBW-04.

054-CBW-02 a) The Forest Service should allow flexibility wherever possible in their 

harvest units such that visual prescriptions are met, but the health of the 

Forest and the potential to make a second entry is planned for to provide 

longer term supply. Certain areas are of visual concern to Wrangellites, 

such as Long Lake and the mill basin area, but there are other areas 

where helicopter logging is being utilized that could be managed as even 

age. We would like to see more flexibility or a different management 

scheme in some of these areas (for example units 534, 557,558, 531, 

Both scenic resources and timber economics were identified as 

issues and were addressed in the analysis. Alternative 4 

emphasized visual protections while Alternative 2 emphasized 

timber volume production. Units were designed for partial 

harvest only where required to meet scenic integrity objectives or 

where roaded conventional cable logging was not feasible. All 

the units mentioned are not accessible by economical road 

construction, with the exception of Unit 528. Unit 528 requires 
BAppendix

Wrangell Island Project FEIS ♦ 94

Comment 

Number Comment Response

530, 972, 527 and 528) to allow even age management methods be 

utilized, increase openings, to improve sale economics.

roading that would exceed the value of the timber. Therefore 

these units were proposed for partial yarding with helicopter. The 

high cost of helicopter yarding per tree precludes using this 

logging method for clearcutting. 

Uneven-aged management is used in conjunction with helicopter 

logging to improve timber economics since helicopter logging 

smaller or extremely large trees may be more costly than the 

value of the wood harvested. Extremely large tress sometimes 

need to be split laterally or cut to a shorter log length because of 

helicopter weight limits. 

054-CBW-03 b) What is the economics and potential of reopening the road accessing 

units 527,972 and 528 in order to harvest the timber using even age 

management? That road is through recently selected Borough lands and 

could provide a dual purpose – provide the USFS with easy access to 

timber and a long term road to access Borough land without the long 

term maintenance requirements of the USFS. The Borough had 

previously commented on this road and supported its use. This potential 

access and alternative unit management should be included in the EIS.

Thank you for your comment. Units 528, 972, and the majority of 

unit 527 are not accessible from the road off of 6255. Unit 972 

was partially harvested, previously, and would not likely support 

the cost of any road construction, reconditioning, or 

reconstruction.

054-CBW-04 The Borough wants to emphasize that not only does it support small and 

large sales where possible in order to support economic sustainability of 

local business opportunities, but also supports the continuation of the 

micro sale program and efforts to ensure growth of the music wood 

industry. We believe and want confirmation, that this proposed 

alternative will provide NEPA approved timber that can continue to be 

utilized and accessed by this industry as well. 

Your comment is noted. The Tongass timber program offers a 

variety of sale sizes to support the various capabilities of timber 

purchasers in the region. The Wrangell Island Project would 

result in a variety of sale sizes offered to the timber industry. The 

timber sale offerings would depend on market conditions at the 

time of offer. Sales would be offered by competitive bid. The 

microsale program would continue across the Wrangell Ranger 

District.

054-CBW-05 The Borough is requesting that the USFS include the map in the final 

EIS that was presented to the Wrangell Borough Assembly on June 28, 

2016 showing the specific areas on Wrangell Island that can actually be 

harvested. The maps in the DEIS are misleading – for example the LUD 

map Figure 2, shows timber LUDS but does not define the roadless 

areas and the acreage that cannot be harvested. The Roadless maps do 

not show the Old Growth reserves and other areas that are removed 

from being harvested. The map presented to the Assembly was very 

informative as to what areas on Wrangell Island can even be considered 

for timber harvesting, prior to having to meet all of the design 

prescriptions such as views, wildlife etc.

Figure 3 has been included at your request. This map illustrates 

the areas which are not available for timber harvest within the 

analysis area. It does not include all the stream buffers, nest 

buffers, and other small scale protections that would prohibit 

timber harvest. 

054-CBW-06 In our response to the Notice of Intent last year, the Borough commented 

regarding concerns for the interpretation of the TU77 watersheds and 

The 2016 Forest Plan classified T77 watersheds VCUs as 

unsuitable for commercial old-growth timber harvest. The action 
Appendix B

Wrangell Island Project FEIS ♦ 95

Comment 

Number Comment Response

VCU’s as they apply to young growth in the recently adopted Plan 

Amendment. The Borough’s understanding is that this Draft EIS is being 

reviewed under the 2008 Forest Plan. Implementation of the new Forest 

Plan Amendment as it applies to the TU77 watersheds, applies to Young 

Growth and not to this Wrangell Island Sale as this sale is a “bridge” sale 

until young growth is available to transition to and does not include 

young growth.

alternatives no longer include the harvest units within the T77 

watershed and The Nature Conservancy/Audubon conservation 

priority area VCU 4790, and are consistent with the 2016 Forest 

Plan.

054-CBW-07 Road Management issues: The Borough supports Alternative 2 Road 

Access Management Plan and is encouraged that some of the roads, 

rather than being closed can be converted to ATV access. This will 

continue to provide recreational, hunting and subsistence opportunities 

for residents. 

Your support of Alternative 2 for access management is noted.

054-CBW-08 Borough supports the proposed long term management plan for USFS 

Roads 6270 and 6299 in the Thoms Creek area and requests that these 

roads remain open. The road provides access to an important 

recreational and subsistence area along Thoms Creek. The Borough 

recently selected lands from the Thoms Place Subdivision in this area 

and the road traverses through a corner of the property providing much 

needed multi-use access and opportunity in this area. 

Your support of road 6299 remaining open for recreation and 

subsistence use as well as providing access to Borough selected 

lands is noted.

Road 6270 is not proposed for closure in any alternative.

054-CBW-09 The Borough supports the development of the alternative access road to 

access Middle Ridge Cabin and surrounding areas in concept. The 

existing road, can be a safety hazard, but does provide access to 

additional harvest areas, hunting and subsistence and other view and 

recreational areas on 50054 and 50060. 

Your support of the new 50058 road accessing Middle Ridge is 

noted. This road would be needed to access timber from this 

project and future young growth in a safe and efficient manner. It 

would also provide safer access to the Middle Ridge cabin area 

for the public.

054-CBW-10 The proposed alternative road, however does not access very much 

timber and the Borough questions if the cost of the road is justified in this 

sale under the timber program? Would the economics of the Wrangell 

Island Project improve without this road? The Borough recommends that 

the road be constructed from other funds, ie. recreation (because the 

road can provide a great short recreational loop drive), stewardship 

funds or other source or at a minimum cost shared with another 

program. There are some spectacular viewing and picnic sites at the top 

of the existing road that should remain open for their views towards Pat 

Lake and valley.

Your comment is noted. Road 50058 is proposed to access 

timber from this project and future young-growth management. 

The existing 50060 switchback road has adverse haul and high 

maintenance costs due to its location. Log truck use of this road 

is a safety concern, especially with other traffic using the road. 

Proposed road 50058 would provide safe, more economical 

access to Middle Ridge. This alternative road would reduce the 

cost of hauling timber for this project, as well as for any future 

timber project, would require less maintenance than the existing 

road 50060 and, would be a safer route. Road 50060 would 

continue to be open for public motorized access. 

054-CBW-11 The Borough supports keeping FS Road 50051 open as well, it provides 

a back channel access, but most importantly it provides easy access to 

the Tyee Transmission Lines for maintenance purposes.

Your support of road 50051 remaining open is noted.
BAppendix

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Comment 

Number Comment Response

054-CBW-12 The Borough would like to see FS Road 50034 maintained for use for 

ATV vehicles rather than closed. 

Comment noted. Road 50034 is not needed for proposed timber 

harvest in any of the alternatives. Road 50034 is within a 2001 

inventoried roadless area, drainage structures have been 

removed, and it crosses several fish streams.

054-CBW-13 Also, the USFS on page 6 states that the City and Borough of Wrangell 

became a cooperating agency. This statement by itself is true, but the 

following sentence needs to be added to that paragraph:

“ Due to a breakdown in and lack of communication from the USFS to 

the Borough regarding the preparation of the Draft EIS, controversial 

issues causing delays and project status, the City and Borough of 

Wrangell withdrew as cooperating agency after believing the USFS did 

not uphold its responsibilities.”

Comment noted. The section has been revised.

054-CBW-14 How this sale is actually packaged and sold is very important to the City 

and Borough of Wrangell. The community wants to maximize the long 

term economic benefits for local business opportunities as well as 

creation of local and sustainable jobs. The City and Borough of Wrangell 

requests that the Borough be included in the sale implementation design 

phase and that the Tongass Forest Supervisor Earl Stewart commit to 

that cooperative effort in the final record of decision for the Wrangell 

Island Sale.

Thank you for the opportunity to comment. The Borough looks forward to 

building our relationship and communication with the USFS in order to 

create a Wrangell Island Sale that can support economic growth and 

development of jobs in timber and other industries that utilize the 

Tongass resources on Wrangell Island. 

Attached for your reference, please find Wrangell’s version of the USDA 

funded regional Cluster Plan Initiative from 2012 and a Timber Plan 

developed by the Economic Development Committee with acceptance 

by the Assembly in 2013.

Sincerely,

David Jack

Mayor, City and Borough of Wrangell

Your comment is noted. The Forest Service will continue its 

cooperative relationship with the City and Borough of Wrangell 

during the implementation of this project.

055-WS Comments on the Wrangell Island Timber Sale Project (July 2016)

Winston Paul Smith, Ph.D.
Appendix B

Wrangell Island Project FEIS ♦ 97

Comment 

Number Comment Response

Principal Research Scientist, University of Alaska – Fairbanks

As a member of the team of Pacific Northwest Research Station 

scientists assigned to review and analyze all information used to address 

wildlife viability issues for the 1997 Tongass Land Management Plan, I 

contributed directly to the initial conceptual framework and subsequent 

species-specific elements that became the 1997 TLMP Conservation 

Strategy and is now reflected in the 2008 Amended Tongass Land 

Management Plan (the 2008 Amended Forest Plan). Since that time, I 

have designed and implemented experimental research testing 

fundamental, underlying assumptions of the TLMP Conservation 

Strategy and other conservation measures specific to endemic small 

mammals. The findings of this research were presented at scientific 

conferences and published in numerous articles in national and 

international peer- reviewed journals. I submit that the following 

comments represent a unique understanding and perspective reflecting 

both my direct knowledge and experience gained through developing the 

TLMP Conservation Strategy and my extensive, comprehensive, credible 

science experience and knowledge gained through studying endemic 

small mammals. Accompanying this document is my Curriculum Vitae, 

which details my relevant experience and scientific publications.

The Southern Red-backed vole (Myodes gapperi wrangeli) is one of four 

recognized subspecies in the Tongass National Forest. It is an endemic, 

old-growth-dependent species.

This subspecies only inhabits Wrangell and Sergief islands. Sergief 

Island is only three miles long. Wrangell Island, in contrast, is 30 miles 

long, up to 14 miles wide, and roughly 54,000 hectares (134,000 acres). 

The map accompanying these comments compares the relative size of 

the two islands. By virtue of its overwhelming size difference, Wrangell 

Island is home to virtually the entire population of this subspecies in the 

Tongass. Moreover, the apparent isolation of these two islands for an 

extended period raises questions about the likely interruption of gene 

flow and whether voles on Sergief represent a genetically distinct 

population or taxon.

As part of my work at the Pacific Northwest Research Station, I studied 

Southern Red- backed voles on Wrangell Island. Based on this work, I 

recently co-authored a paper entitled Habitat selection, interspecific 

interactions, and coexistence between a generalist (Peromyscus keeni) 
BAppendix

Wrangell Island Project FEIS ♦ 98

Comment 

Number Comment Response

and a specialist (Myodes gapperi) in rainforest of Southeast Alaska that 

explains how vole habitat selection allows potentially competing species 

to coexist. This paper, which is attached, has been through peer review 

and is awaiting publication. Our research recognized that small mammal 

species respond to specific components of their environment on a scale 

of resolution much finer than gross habitat differences.

055-WS-01 There is no current population estimate for the Southern Red-backed 

vole. The only study of vole population dynamics demonstrated that 

populations can decline precipitously in managed landscapes; Smith et 

al. 2005 demonstrated that in 2000 the overall vole population was about 

20% of the population in 1998. 

Despite this, the Wrangell Island Project Draft Environmental Impact 

Statement (DEIS) concludes: “Although there would be effects on 

Southern red-backed vole habitat, they should continue to exist on 

Wrangell Island at current levels.” DEIS at 110. The agency fails to 

explain why it concluded the vole population will continue to exist at 

current levels after the Wrangell Island timber sale despite the fact that 

the agency does not know the current population level.

In my opinion, the Forest Service needs more information regarding the 

status of the Southern Red-backed vole population on Wrangell to 

understand the project level effects of the proposed 65 million board feet 

old-growth timber sale project. 

In general, southern red-backed voles (Myodes gapperi) are 

globally secure (NatureServe 2015) and occur across much of 

northern North America and are a common resident of later 

successional, moist forest habitats (Runck and Cook 2005). 

According to NatureServe 2015 the Wrangell red-backed vole 

(Myodes gapperi wrangeli) have global and State heritage status 

rank as vulnerable because of restricted distribution, unknown 

population size and trends, and unknown impacts of ongoing 

logging operations on species status. Smith reported in 2005 that 

the global population of Wrangell red-backed voles in the year 

2000 was only 20 percent of what it was in 1998. There are still 

essential question regarding the influence of annual population 

fluctuations on habitat distribution and population demography. 

The highest densities and highest reproductive rates are often 

found in old-growth forest (Smith 2005), but also concluded that 

the southern red-backed vole are not as sensitive to canopy 

removal as has been indicated elsewhere. 

In consideration of the limited population information available, 

the agency’s conclusions on the Wrangell red-backed vole are 

based on effects to habitat (Wildlife Resource Report). Because 

vole densities and reproductive rates were highest in productive 

old-growth forest and questions remain on young growth, only 

old growth was selected for the measurement criteria for 

southern red-backed voles. The Wrangell Island Project could 

potentially affect 5 to 9 percent of the old-growth habitat on NFS 

land. On all lands, regardless of ownership, there would be 

approximately 78 to 81 percent of 1954 (historic) old-growth 

habitat remaining after harvest. 

These voles occur on Wrangell Island and Sergief Island in both 

old- and young-growth forest and in 2011 the Wrangell southern 

red-backed vole was found in alpine habitat on Etolin Island. 
Appendix B

Wrangell Island Project FEIS ♦ 99

Comment 

Number Comment Response

Smith (2005) concluded that the southern red-backed vole are 

not as sensitive to canopy removal as has been indicated in

previous research. The partial-harvest units may have enough 

diversity with the remaining canopy and understory vegetation 

plus the addition of woody debris, e.g. tree tops and other slash, 

to benefit the vole populations and may even increase them. 

Smith (2005) stated that risk of extirpation of endemic 

populations of southern red-backed voles which were thought to 

use only old-growth forests may be less than presumed during 

the 1997 Forest Plan Revision analysis because they may be 

able to exist in young-growth stands and have been found in 

alpine areas. 

In 2011 the Alaska Department of Fish and Game documented 

red-backed voles in the alpine (at approximately 2,400 to 2,700 

feet elevation) on Etolin Island, an area with no forest canopy. 

The Wrangell red-backed vole has also been known to occur on 

Sergief Island.

The viability analysis for endemic mammals was conducted 

during the 1997 Forest Plan revision for the Tongass through the 

use of two panels (1997 Forest Plan revision FEIS, appendix N). 

These panels arrived at a moderate level of concern for endemic 

mammals and recommended to provide surveys for endemic 

populations. These occurred on Wrangell by live trapping from 

1998 through 2000 with a subsequent survey in 2009. 

The decision on the 2016 Forest Plan is focused on a faster 

transition than originally envisioned in the 1997 Revision; this 

should also have a positive effect on the amount of the oldgrowth available for habitat.

Another factor that reduces the risk of not maintaining viability for 

the southern red-backed vole was the removal of the exemption 

from the 2001 Roadless Rule. This effectively maintains an 

additional 22,736 acres of old-growth forest as habitat for voles 

and other old-growth associated species. 
BAppendix

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Comment 

Number Comment Response

As the commenter noted, there is limited scientific study on the 

Wrangell red-backed vole. The language in the EIS has been 

clarified to explain that all effects and persistence determinations 

for voles are based on habitat. The remaining habitat would be 

sufficient to maintain populations on Wrangell Island.

055-WS-02 The 2008 Amended Forest Plan directs the agency to “[u]se existing 

information on the distribution of endemic mammals to assess projectlevel effects. If existing information is lacking, surveys for endemic 

mammals may be necessary prior to any project that proposes to 

substantially alter vegetative cover (e.g., road construction, timber 

harvest, etc.).” 2008 Amended Forest Plan at 4-97. It also explains the 

agency must “[a]ssess the impacts of the proposed project relative to the 

distinctiveness of the taxa, population status, degree of isolation, island 

size, and habitat associations relative to the proposed management 

activity.” Id. The lack of existing information in combination with these 

factors leads me to conclude the agency should conduct a rigorous

multi-year population survey to assess the project-level effects before it 

moves ahead with the Wrangell Island Project. Given the significant 

threats facing this endemic species and the lack of a habitat model or 

proxy, it is impossible to assess whether this project adversely (or even 

irretrievably) affects these voles if one does not have a benchmark 

population estimate before the project is implemented.

I am also concerned that the DEIS not only fails to address the fact that 

the Forest Service’s proposed Forest Plan Amendment would change 

important components of the Conservation Strategy, but it also does not 

examine the consequences of those changes on the Southern Redbacked vole. I incorporate my comments (and the supporting materials) 

on the proposed forest plan amendment herein (Conservation Strategy, 

Northern Flying Squirrel, Goshawks). As the Final Environmental Impact 

Statement for the 2008 Amended Forest Plan (2008 FEIS) 

acknowledged, “[t]he 1,000- foot beach buffer, riparian corridors, and the 

[old-growth] reserve system are also features of the [2008 Amended] 

Forest Plan that provide functional habitat for species with relatively 

small home ranges.” 2008 FEIS at 3-289. I explained in my previous 

comments:

Further disturbance or changes in the size, composition, or spatial 

arrangement of the [old-growth reserve] network (including other oldgrowth set asides) and conservation measures will almost certainly 

increase the risk to viability of northern flying squirrels, and possibly 

other endemic small mammal species (e.g., Wrangell Island red-backed 

Based on the analysis, we determine that the threat to this 

endemic species was not significant, therefore the cited Forest 

Plan standards and guidelines do not apply in this case. Surveys 

had been conducted previously, and the information from those 

surveys was used in the analysis.

Comments on the Forest Plan are beyond the scope of this 

project analysis. The 2016 Forest Plan Amendment FEIS is 

included in the Wrangell Island Project EIS project record.
Appendix B

Wrangell Island Project FEIS ♦ 101

Comment 

Number Comment Response

vole). In particular, further loss of old-growth forests and active 

management of second-growth stands, especially in existing riparian 

buffers or other conservation elements, will increase the risk to viability 

of northern flying squirrels and other endemic small mammals. . . . 

Therefore, any forest plan amendment or revision that proposes to 

continue the harvest of old-growth forest or impose canopy removal 

(e.g., clearcuts) in buffers (especially openings greater than 200 m) or 

other conservation elements without including a comprehensive analysis 

of the Wildlife Conservation Strategy is imprudent and irresponsible as it 

ignores the best available credible science.

W. Smith, Proposed Forest Plan Amendment Further Compromises 

Established Conservation Measures to Sustain Viable Populations of 

Endemic Small Mammals at 9 (Feb. 2016). The recent release of the 

Forest Service’s proposed record of decision for the amended forest plan 

and the accompanying final environment impact statement demonstrates 

the agency ignored my concerns and is ready to adopt a forest plan that 

compromises the basic tenets of the Conservation Strategy I helped the 

agency develop in 1997. In deciding whether to pursue the Wrangell 

Island timber sale and evaluating the adverse impacts of that project on 

the Southern Red-backed vole, the FEIS must account for these 

fundamental changes.

055-WS-03 Finally, given the extremely small geographic footprint that these voles 

inhabit, the lack of any population information, the substantial amount of 

old-growth habitat on Wrangell that has already been logged, and the 

additional loss of old-growth from the proposed Wrangell Island timber 

sale, I conclude the Wrangell Island Project raises significant viability 

concerns regarding the future of this endemic vole on the Tongass. The 

DEIS never explains whether the Forest Service has concluded that the 

Southern Redbacked vole currently is viable on the Tongass and 

whether and why it will remain so after the proposed Wrangell timber 

sale. To the contrary, the DEIS, in describing all endemics, states “[t]he 

long-term viability of these endemic populations is unknown, but of 

increasing concern.” DEIS at 83 (emphasis added). Notably, the agency 

also never conducted this analysis during its review of the 2008 

Amended Forest Plan. The 2008 FEIS simply collapsed 14 endemic 

species and subspecies into one category when characterizing its 

viability conclusions. To the best of my knowledge, the agency has never 

conducted a viability analysis for the Southern Red-backed vole and, as 

a result, has not identified a habitat threshold (amount and distribution) 

Please see response to comments 055-WS-01 and 055-WS-02.

The extent to which cumulative disturbance from forest 

management poses a threat to the persistence of endemic 

southern red-backed vole populations in southeastern Alaska 

remains unclear but evidence from numerous studies conducted 

elsewhere in its geographic range is varied with implications of 

risk to local extirpation ranging from low to moderate (Smith and 

Nichols 2004). Smith (2005) found that recent ecological studies 

of endemic populations of southern red-backed voles (reputed 

old-growth associates) suggest that risk of extirpation in 

managed landscapes is likely less than was presumed during 

recent land management planning in the region because redbacked vole populations may be able to exist in managed younggrowth stands that originated from clear-cut logging. In addition, 

there is no estimate of probability of detection or standardized 

protocol for surveying voles that allows statistical inference about 

absence.
BAppendix

Wrangell Island Project FEIS ♦ 102

Comment 

Number Comment Response

that explains how much of Wrangell’s old-growth forest must remain to 

ensure its viability. 

I strongly encourage the agency to conduct this analysis before it 

proceeds with the Wrangell Island timber sale because to do otherwise 

jeopardizes the vole’s future viability on the Tongass.

Viability analysis is conducted at the Forest level.

056-DOW Defenders of Wildlife

441 West 5th Avenue, Suite 302

Anchorage Alaska 99501 

tel 907.276.9453 

fax 907.276.9454

www.defenders.org

Andrea Slusser

Wrangell Ranger District

525 Bennett Street P.O. Box 51

Wrangell, AK, 99929-0051

andreamslusser@fs.fed.us

July 18, 2016

VIA ELECTRONIC MAIL

Dear Ms. Slusser,

Defenders of Wildlife appreciates this opportunity to comment on the 

Wrangell Island Project Draft Environmental Impact Statement (DEIS). 

Established in 1947, Defenders is a national, science-based non-profit 

conservation organization. With more than one million members and 

supporters nationwide, Defenders is focused on conserving and 

restoring native species and habitat throughout the country, including on 

national forests such as the Tongass. 

Our comments focus on wildlife issues discussed in the DEIS and other 

documents in the planning record. In addition to these comments, 

Defenders has joined the broader comments submitted by Earthjustice 

and other groups.

Summary
Appendix B

Wrangell Island Project FEIS ♦ 103

Comment 

Number Comment Response

We appreciate the discussion of current conditions and likely impacts to 

wildlife and habitat from project alternatives presented in the DEIS. 

Broadly, it appears that prior habitat loss and fragmentation from timber 

harvest and road building activities has left Wrangell Island in a 

precarious position in terms of its ability to provide the habitat needed to 

ensure the continued viability of some wildlife species, especially those 

dependent on productive old-growth (POG) and high-volume POG 

habitats such as deer, wolves and marten. That unfortunate history plus 

current market demand and economic realities make it challenging to 

design a sensible, responsible timber sale on Wrangell Island that can 

effectuate both timber production and wildlife protection goals. 

The conservation strategy described in Appendix D of the Tongass Land 

and Resource Management Plan (Forest Plan) is not currently 

implemented properly on Wrangell Island because some designated old 

growth reserves (OGRs) contain less than minimum acreages of 

different habitat types. This project provides an opportunity to modify and 

refine OGR boundaries to implement the conservation strategy and the 

project interagency (IA) team recommended just that, but the alternatives 

presented in the DEIS ignore these recommendations, leaving the OGRs 

inadequate to accomplish their intended purpose. Also, a priority 

watershed that would be protected from logging by the proposed Forest 

Plan amendment awaiting finalization in just a few months is slated for 

harvest and should be removed from the project area.

The DEIS evaluates numerous Management Indicator Species (MIS) to 

estimate overall wildlife impacts from the proposed project, and several 

of these evaluations raise concerns about wildlife viability. Sitka Blacktailed deer habitat on the island, for example, falls well short of levels 

considered sufficient to support populations that can meet the needs of 

humans and predators. The DEIS also does not appear to define critical 

winter deer habitat, a key factor limiting deer populations, with sufficient 

precision to support conclusions regarding its adequacy.

The DEIS evaluates impacts to wolves in terms of road density and deer 

habitat. Current road density is beyond the recommended level to protect 

wolves, and the proposed action would increase road density 

significantly. Current and projected road density estimates may also be 

understated somewhat in the DEIS and we propose refining those 

estimates in the Final EIS. The combination of high road density and 

insufficient deer habitat creates a viability concern for wolves on 
BAppendix

Wrangell Island Project FEIS ♦ 104

Comment 

Number Comment Response

Wrangell Island. This concern was identified in agency scoping 

comments over five years ago, which should have triggered 

management actions pursuant to the standards and guidelines for 

wolves in the current Forest Plan. The Forest Service and agency 

partners should implement those management actions and present the 

results in the FEIS.

In some places, the units of measure employed in the DEIS to evaluate 

impacts do not correspond well with underlying factual information 

regarding a species or its use of habitat; in these cases we suggest ways 

that the FEIS can present a clearer picture of likely impacts by modifying 

the units of measure to better correspond with known information. 

Unfortunately, it appears likely that this clearer picture will only make the 

outlook more bleak for old-growth-dependent wildlife. 

We thus urge the Forest Service to 1) implement the conservation 

strategy by modifying OGR boundaries to meet or exceed minimum 

Forest Plan requirements, and incorporate the interagency team 

recommendations regarding OGRs into an FEIS alternative; 2) remove 

the Thom's Lake watershed area from the harvest plan; 3) implement the 

management actions for wolves described in the Forest Plan standards 

and guidelines, and add the information generated from those efforts to 

the FEIS to better inform the analysis of impacts to wolves; and 4) revise 

some of the DEIS analyses and units of measure to more accurately 

estimate impacts to specific wildlife species, as detailed below.

056-DOW-01 I. Existing Wildlife Habitat and the Conservation Strategy

The DEIS discussion of wildlife habitat buries the lede by ignoring the IA 

team's extensive evaluation of OGRs in the Wildlife Resource Report 

and instead solely presenting portions of the analyses for specific wildlife 

species. In so doing, the DEIS misses the best opportunity available to 

improve wildlife habitat characteristics on Wrangell Island by modifying 

OGR size and composition to meet minimum conservation strategy 

requirements while improving connectivity. The Forest Plan requires that 

the biologically preferred alternative for OGRs appear as an alternative 

in the NEPA analysis; the FEIS must cure this defect. The DEIS also 

fails to align the timber base for this sale with prescriptions from the 

forthcoming amendment to the Forest Plan, and should remove areas 

from Value Comparison Unit (VCU) 4790 that will soon be prohibited 

from harvest by the Forest Plan.

A biologically preferred design for changing OGRs boundaries 

was developed during the analysis as documented in the 

interagency report. It was not analyzed in detail because no 

project-specific Forest Plan amendments were no longer being 

proposed in the project (October 27, 2015, Corrected Notice of 

Intent, Federal Register, Volume 80, Number 207). The OGR 

boundaries as defined by the Forest Plan were used for all 

alternatives. The referenced items are available in the project 

record.

The action alternatives no longer include the harvest units within 

the T77 watershed and The Nature Conservancy/Audubon 

conservation priority area VCU 4790, and are consistent with the 

2016 Forest Plan.
Appendix B

Wrangell Island Project FEIS ♦ 105

Comment 

Number Comment Response

056-DOW-02 A. Expanding OGRs to Meet Minimum High POG, POG, and Overall 

Acreage Requirements.

Pursuant to the conservation strategy, there are five old growth reserves 

(OGRs) on Wrangell Island: the Fools Inlet and Thom's Creek "medium" 

OGRs, and three small OGRs. The intent of the reserve system on the 

forest is to help ensure the maintenance of well-distributed populations 

of all old-growth associated wildlife populations on the Tongass, with a

focus on species most sensitive to habitat loss and fragmentation.

The two OGRs designated as "medium" on Wrangell Island, the Thom's 

and Fools Inlet OGRs, do not actually meet the definition of medium 

OGRs under the 2008 Forest Plan (Appendix D). Medium OGRs should 

be contiguous landscapes of approximately 10,000 acres including at 

least 5,000 acres of productive old growth (POG) and at least 2,500 

acres of high-volume stratum POG. Both lack sufficient POG and highvolume POG acreage, and the Fools Inlet OGR also falls short in total 

acreage. An interagency (IA) team with members from the Forest 

Service, U.S. Fish and Wildlife Service (USFWS), and Alaska 

Department of Fish and Game (ADF&G) was tasked with, among other 

things, "augmenting the existing medium OGRs on Wrangell Island so 

that they would meet the minimum Forest Plan size."

The IA Team did so, recommending additions of high-POG acres to both 

medium OGRs to bring them up to minimum acreage criteria. For 

Thom's OGR, the biologically preferred option is to "add acres of highvolume POG south and east of road 6299 adjacent to the existing 

Thom's Medium OGR." Also, the existing Fools Medium OGR fails to 

meet minimum acreages for medium OGRs by 756 total acres and 418 

high-POG acres; the IA team's recommended addition would be to 

"connect the Fools Medium OGR and the Earl West Small OGR along 

Fools Creek, which would enhance the overall north-south connectivity 

on Wrangell Island. This addition would add low elevation, high-volume 

POG habitat along Fools Creek." Additionally, the IA team evaluated the 

five small OGRs on Wrangell Island and recommended an important 

change to Earl West OGR as well as a previously recommended 

biologically preferable OGR in VCU 5050. Specifically: 

The Earl West OGR was originally designed to provide a "stepping 

stone" along a key landscape travel corridor from the Fools Medium 

OGR to the north and to the mainland. The roaded portion of the OGR 

contains high-POG, low elevation deep snow deer winter habitat. The 

majority of the deep snow winter habitat within this VCU is in the Timber 

Please see response to comment 036-ADFG-02. 
BAppendix

Wrangell Island Project FEIS ♦ 106

Comment 

Number Comment Response

Management [Land Use Designation] and either has already been 

affected by past timber harvest or will be affected by proposed harvest. 

The biologically preferred OGR identified by the 2008 Forest Plan 

Interagency Review Team was not adopted for this VCU. Rather it was 

modified under the 2008 Forest Plan to exclude potential LSTA roads 

and units north of the 6273 road to maintain future management 

opportunities. The IA team recommends that the 2008 biologically 

preferred OGR be adopted under the Wrangell Project.

Additionally, the IA team noted that the Blake Small OGR had not been 

designated as part of the 2008 Plan amendment, and recommended 

doing so now: 

This small OGR was not designated by the Forest Supervisor in the 

2008 Forest Plan Amendment. The Forest Plan Interagency Review 

Team recommended a Project Level Review because the small OGR 

was important to maintain habitat on the west side of a VCU 5050, which 

is also split by a salt water channel and because the Fools Medium OGR 

does not currently meet Appendix D minimum acreage criteria in the 

Forest Plan. The small OGR was originally placed to promote 

connectivity and dispersal to the mainland. The suggested location of the 

Blake Small OGR would be located within 2001 Roadless. The 2011 

Wrangell IA Team recommended that the Blake Channel small be 

adopted for the Wrangell Island Project.

Contrary to Forest Plan direction, however, none of the project 

alternatives presented in the DEIS implement these recommendations. 

An alternative that would have modified the OGRs was eliminated from 

consideration because, according to the DEIS, this would have required 

a Forest Plan amendment and the uncertain outcome of the alreadyinitiated Forest Plan amendment process warranted dismissing this 

alternative. This rationale is unpersuasive. 

Modifications to OGRs are addressed in Appendix K of the 2008 Forest 

Plan. Appendix K fully anticipates that "project level reviews will ensure 

that OGRs meet Forest Plan OGR criteria while addressing forest-wide 

multiple use goals and objectives." After an IA team review of OGRs in 

each impacted VCU, line officers are directed to incorporate the IA 

team's recommendations into the NEPA review, considering the 

biologically preferred option among other considerations. Line officers 

must attempt to develop a viable project that avoids conflict with the 

biologically preferred OGR, and at a minimum the biologically preferred 

OGR will be considered in an alternative in the NEPA document. Any 

The Forest Plan does not require modification of OGRs as 

suggested by the comment. Per direction in the Forest Plan 

appendix K, changes to OGR boundaries were considered and a 

preliminary evaluation was conducted. As mentioned previously, 

the Wrangell Island Project does not propose any Forest Plan 

amendments, including modifying the existing OGRs. 

Regarding habitat protection, it should be noted that a significant 

portion of Wrangell Island is now managed under the 2001 

Roadless Rule, which prohibits timber harvest and road 

construction. This means that 22,736 acres of old-growth is 

protected in the project area by OGRs, the Forest Plan 

conservation strategy and 2001 inventoried roadless areas.
Appendix B

Wrangell Island Project FEIS ♦ 107

Comment 

Number Comment Response

resulting OGR changes are "generally a non-significant Forest Plan 

amendment.” There is no mention of an intent to abandon Appendix K 

modifications based on project level reviews simply because there is a 

Forest Plan amendment or revision process underway. 

The current Forest Plan amendment is limited in scope and includes no 

forest-wide nor Wrangell Island-specific assessment of OGRs. Projects 

and their accompanying reviews are proceeding apace notwithstanding 

the Forest Plan amendment process, and it is disingenuous to claim that 

only the OGR modification portion of the review process for the Wrangell 

Island Project must be dismissed because of uncertainty regarding the 

outcome of that amendment process. Both the Wrangell Island Project 

and a non-significant plan amendment to modify the OGRs on Wrangell 

Island to meet minimum OGR criteria can proceed despite the pendency 

of the Forest Plan amendment currently underway.

The Forest Plan established the OGR system and a means of assessing 

and potentially modifying specific OGRs via project level reviews. The 

Forest Plan amendment process provides no reason to dismiss the 

biologically preferred OGR modifications, or to not present them in an 

alternative in the EIS as required by Appendix K of the Forest Plan. The 

FEIS should include an alternative, perhaps a modified Alternative 5, that 

brings both medium OGRs on Wrangell Island up to minimum Forest 

Plan amounts of POG, high POG, and total acreage, and expands the 

small OGRs as recommended by the IA team.

The Wrangell Island Project does not propose any Forest Plan 

amendments.

The Tongass Old-growth conservation strategy needs to be 

assessed with both components instead of being limited to the 

reserves only. It was developed as a forest-wide strategy and not 

expected to function on an island scale alone. The 2016 Forest 

Plan Amendment FEIS, appendix D contains an evaluation of the 

Tongass Old-growth conservation strategy. This includes a 

forest-wide assessment of the old-growth habitat reserves, as 

well as the matrix components. The OGRs on Wrangell Island 

were considered in this review.

056-DOW-03 B. Aligning the Proposed Harvest Areas with the 2016 Proposed Plan 

Amendment

Although the 2016 Forest Plan amendment is not yet finalized, the 

Forest Service has issued a proposed Record of Decision that would 

remove the lands from VCU 4 790 from the timber base. Some of those 

lands are proposed for timber harvest as part of the Wrangell Island 

project. If the amendment is finalized before the Wrangell Island project 

decision, then this area would need to be removed from the sale. But 

even if the Wrangell Island project decision precedes the final 

amendment, the Forest Service should remove the lands in question in 

order to preserve the intent of the amendment and the significant 

planning effort undertaken to date. This effort is to facilitate a transition 

away from old growth logging by, among other things, removing some 

old growth areas from the suitable timber base on the forest. The Forest 

Service shouldn't simultaneously seek to log those very areas in the 

weeks or months preceding the finalization of the amendment.

The action alternatives no longer include the harvest units within 

the T77 watershed and The Nature Conservancy/Audubon 

conservation priority area VCU 4790, and are consistent with the 

2016 Forest Plan.
BAppendix

Wrangell Island Project FEIS ♦ 108

Comment 

Number Comment Response

II. Impacts to Specific Wildlife Species

Below are comments for deer and wolves in addition to the comments 

submitted on our behalf by Earthjustice. In general, we request that the 

FEIS present both road density and winter deer habitat with elevation 

and other characteristics more closely tied to characteristics already 

known to be important for deer and wolves. Also, even the information as 

presented in the DEIS demonstrates concern for the continued viability 

of wolves on Wrangell Island. Accordingly, the Forest Plan should 

implement all applicable Forest Plan standards and guidelines for 

wolves. Finally, the marten analysis presents several considerations 

similar to wolves, and the FEUS should address whether there is a 

mortality concern for marten on Wrangell Island as well.

Responses to species-specific comments are listed below. 

056-DOW-04 A. Sitka Black-Tailed Deer

This deer was chosen as a Management Indicator Species because it 

receives the highest hunting and subsistence use of all terrestrial 

species in Southeast Alaska, and represents those species that use 

lower elevation POG habitat (below 800 feet) during the winter period. 

The DEIS acknowledges that the habitat capability on Wrangell Island is 

significantly less than 18 deer per square mile, the level generally 

required to provide viable deer populations considering human and other 

predation. It further acknowledges that deer habitat will be decreased as 

a result of any of the alternatives under consideration. Winter habitat and 

deer condition going into winter are the most important limiting factors for 

deer in Southeast Alaska.

Given the critical importance of winter habitat to deer survival, the DEIS 

does not appear to contain the most helpful analyses available to 

measure winter habitat and gauge the impact of the various alternatives 

on that critical metric. Low-elevation, high-volume old growth stands with 

southern aspects in low snowfall areas provide the very best winter deer 

habitat available. It would thus be logical and very helpful for the DEIS to 

consider the alternatives in light of impacts to this specific type of habitat 

- with "low" elevation defined as below 800'.

The DEIS provides the current and historical conditions for "deep snow" 

deer habitat (high-volume POG on south facing slopes), but without 

reference to elevation. It also displays "average snow" habitat, which 

includes all POG at or below 1500' elevation. It fails to show habitat 

information for either high-volume or all POG at or below 800' elevation. 

From the standards and guidelines on wolves, WILD1.XIV.A.2 

ensures consideration and evaluation of deer habitat needs 

during project planning, not a bare minimum deer density 

requirement for all agency actions. Use of the words “where 

possible” and “generally considered” convey that this is not an 

absolute requirement: “Provide, where possible, sufficient deer 

habitat capability to first maintain sustainable wolf populations, 

and then to consider meeting estimated harvest demand. This is 

generally considered to equate to the habitat capability to 

support 18 deer per square mile (using the habitat capability 

model outputs) in biogeographic provinces where deer are the 

primary prey of wolves.” In addition, it goes on to say the 

biologist should consider additional local factors rather than 

relying solely on model outputs. This standard and guideline, 

while important, is only one part of a comprehensive strategy for 

maintaining population viability.

On table 36 of the WL section of the DEIS it shows acres and 

percent reduction from existing condition of deep snow habitat by 

alternative and table 38 shows cumulative effects to deep snow 

habitat by alternative within WAA 1903. What the footnote to 

those tables failed to mention is that high-volume POG (SD 5S, 

5N, and 6/7) on south-facing slopes is only that POG below 800ft 

elevation. The Wildlife Resource Report and FEIS section have 

been revised to clarify this information.

The deep snow habitat is high POG below 800ft. The omission 

has been corrected, as described above. The analysis of effects 

to black-tailed deer uses the Interagency deer model, which 
Appendix B

Wrangell Island Project FEIS ♦ 109

Comment 

Number Comment Response

It also fails to show all POG in terms of south-facing aspect, and does 

not identify typically low, medium or high snowfall areas. 

The FEIS should show the historic, current and proposed remaining low 

elevation (below 800') high-volume old growth habitat on south-facing 

slopes, as well as all POG below 800' and 1500' on south or non-north 

facing slopes, to provide a much clearer picture of the impacts to critical 

winter deer habitat by alternative. 

Deer density on NFS lands is currently modeled at 12.9 deer/square 

mile, down from a historic level of 15.3. That figure would drop to 11.7-

12.0 deer/square mile, depending on the alternative chosen. On all 

lands, deer density drops to 9.9-10.2 deer/square mile depending on the 

alternative.

And although historically five out of six provinces in the Etolin Complex 

Biogeographic Province met the 18 deer/ square mile standard, today 

only one Wildlife Analysis Area (WAA) does so (Zarembo Island). The 

record thus demonstrates that deer habitat on Wrangell Island is well 

below that considered necessary to support viable populations of deer 

and predators. 

The WRR also discusses the Interagency Deer Model, which was 

developed to evaluate potential winter habitat capability and was 

updated during both the 1997 Forest Plan revision and the 2008 

Amendment. The model is appropriate at the W AA scale (and thus 

appropriate for this project), and calculates a Habitat Suitability Index 

(HSI) based on vegetation, elevation, aspect, and typical snowfall for an

average winter. Generated HSI values range from 0.0 in areas that have 

no winter habitat value to 1.0 in optimal habitat. This sounds promising 

as a useful tool to display a range of habitat suitability that would add 

considerable detail and spatial understanding not conveyed in the DEIS 

charts showing overall amounts of "deep snow" or "average snow" 

acreage available on Wrangell Island. Unfortunately, the tool is never 

applied and HSI values do not appear to have been generated, or at 

least are not presented in the DEIS or WRR. 

The FEIS should display the historic, current and projected HSI values 

for the Wrangell Island WAA by alternative.

takes into account snow depth (indicative of typical, moderate 

winter severity), elevation, aspect, and vegetation type and is 

currently used in Tongass Forest planning to provide an index of 

habitat capability (referred to as the TLMP deer model, 

DeGayner 1997) (2008 FEIS V1 p. 3-231).

The FEIS describes historic, current, percent remaining from 

current condition by alternative and percent remaining from 

historic by alternative for high-volume POG (deep snow below 

800 ft.) and all POG (average snow below 1500 ft.). The deer 

model is used as a relative comparison tool between 

alternatives, which was how the model was designed to be used.

Figure 14 of the Wildlife Resources Report displays all POG 

habitat on Wrangell Island which includes “deep snow” deer 

habitat. The effects from the proposed project on deep snow 

habitat can be found on table 43 and 44 (Wildlife Resources 

Report pages 105 and 106). The proposed project could harvest 

between 24-58 acres of deep snow habitat depending on which 

alternative is selected. This could result in a 1-3 percent decline 

from existing condition on National Forest System lands only.

As indicated in the Wildlife Resource Report, the Wrangell Island 

Project analysis used the 2011 Direction for Project-level deer, 

wolf, and subsistence analysis for running the deer model.

The deer model was used to generate Deer Habitat Capability 

for current, historic and by alternative on table 35 and 36 of 

DEIS. The HSI values within the deer model were used to 

generate a value for each GIS polygon as described in the 2011 

direction and the raw data is located in the project record. 

In a meeting on August 23, 2011, Tongass National Forest and 

Alaska Department of Fish personnel met to ensure consistent 

use of the deer model and assessment of deer habitat for 

project-level analysis. “The primary purpose of the deer HSI 

model is to provide a measure to estimate and compare the 

relative effects of proposed actions/alternatives on deer winter 

habitat. Deer habitat capability expressed in terms of percent of 

1954 values can be used to identify the amount of habitat 
BAppendix

Wrangell Island Project FEIS ♦ 110

Comment 

Number Comment Response

change over time. Habitat capability values resulting from the 

model should only be used to estimate changes that result from 

proposed projects and do not reflect actual known deer numbers. 

The deer model has shortcomings that were considered and 

disclosed during the Forest Planning process for the 2008 Forest 

Plan Amendment FEIS, p. 3-231. 

Wolves were analyzed as part of this project (see Wildlife 

Resource Report), the analyses included prey abundance and 

road density and provided estimated impacts on wolves. 

Contrary to the comment, we applied the relevant standards and 

guidelines. Wolf viability is addressed at the Forest Plan level. 

It is important to note that wolf mortality concerns have not been 

identified on Wrangell Island. Therefore, the standards and 

guidelines for an interagency cooperation wolf habitat 

management program is not necessary.

Furthermore, wolves were selected as an MIS because of 

population viability concerns in some areas of the Tongass. 

However, the datasets available for monitoring wolves are 

insufficient for detecting all but very large changes in the wolf 

population and are not designed to track trends in the population 

resulting from changes in their habitat. Additionally although 

recent efforts have been made to improve information on wolves 

in the form of multi-year research projects undertaken by ADF&G 

and the Forest Service, it is difficult to determine the link, if any, 

between habitat change on the Tongass and changes in the wolf 

population, especially given confounding factors such as 

weather-dependent fluctuations in prey abundance or spatially 

differential hunting pressure (USDA Forest Service 2004i) (2008 

FEIS V1 p3-238).

See response to comment 046-PB-03

Hunter harvest data from 1996-2013 was used to assess hunter 

demand and deer habitat capability was used to estimate the 

theoretical number of deer available. On Wrangell Island (WAA 

1903), the average hunter harvest is 69 deer per year. 

Therefore, under Alternative 2 hunter harvest of deer on 
Appendix B

Wrangell Island Project FEIS ♦ 111

Comment 

Number Comment Response

Wrangell Island represent approximately 3.1 percent of the 

modeled deer habitat capability.

On Wrangell Island wolf mortality concerns have not been 

identified. Based on information from USFWS 2016 wolf mortality 

was not considered a concern for GMU 3 because deer were not 

the only ungulates to be found.

Note that the 0.7-1.0 miles per square mile road density 

guideline does not need to be considered until a determination 

has been made and that consideration of wolf hunting and 

trapping harvest is also considered. In addition, local knowledge 

of habitat conditions, spatial location of roads, and other factors 

was considered by the biologist rather than solely relying upon 

road densities (2008 Forest Plan FEIS, appendix H, p. 173).

There are no known wolf dens on Wrangell Island. We have not 

conducted formal surveys for wolves but have not encountered 

any probable dens sites through other field reconnaissance. 

Standard and guidelines regarding wolf dens would be followed 

during project implementation. 

B. Alexander Archipelago Wolf

The AA wolf was chosen as a MIS due to population concerns in some 

parts of the Tongass. The AA wolf inhabits the mainland and the islands 

south of Frederick Sound, including Wrangell Island. They use a wide 

variety of habitats but spend most of their time in old growth forests at 

low elevations, below 270 feet. The Forest Plan contains standards and 

guidelines to ensure the longterm sustainability of wolves on the 

Tongass.

Prey abundance (deer) and road densities were used to analyze the 

effects of the project on wolves? As detailed below, consideration of 

these factors clearly indicates concern for the continued viability of 

wolves on Wrangell Island. This concern, in turn, triggers additional wolfspecific standards and guidelines in the Forest Plan, also described 

below. The DEIS fails to express the viability concern for wolves 

indicated by the facts regarding prey abundance and road density on 

Wrangell Island, and the Forest Service has not applied the relevant 

standards and guidelines. The FEIS must correct these deficiencies.

Wolves were analyzed as part of this project (see Wildlife 

Resource Report), the analyses included prey abundance and 

road density and provided estimated impacts on wolves. 

Contrary to the comment, we applied the relevant standards and 

guidelines. Wolf viability is addressed at the Forest Plan level. 

It is important to note that wolf mortality concerns have not been 

identified on Wrangell Island. Therefore, the standards and 

guidelines for an interagency cooperation wolf habitat 

management program is not necessary.

Furthermore, wolves were selected as an MIS because of 

population viability concerns in some areas of the Tongass. 

However, the datasets available for monitoring wolves are 

insufficient for detecting all but very large changes in the wolf 

population and are not designed to track trends in the population 

resulting from changes in their habitat. Additionally although 

recent efforts have been made to improve information on wolves 

in the form of multi-year research projects undertaken by ADF&G 
BAppendix

Wrangell Island Project FEIS ♦ 112

Comment 

Number Comment Response

1. The Forest Service Has Not Implemented the Forest Plan Standards 

and Guidelines for Wolves.

The standards and guidelines for wolves are as follows:

A. Implement a Forest-wide program, in cooperation with ADF&G and 

USFWS, to assist in maintaining long-term sustainable wolf populations.

1. Where wolf mortality concerns have been identified, develop and 

implement a Wolf Habitat Management Program in conjunction with 

ADF&G. To assist in managing legal and illegal wolf mortality rates to 

within sustainable levels, integrate the Wolf Habitat Management 

Program (including road access management) with season and harvest 

limit proposals submitted to federal and state boards.

a) Participate in interagency monitoring of wolf populations on the 

Forest.

b) Where wolf population data suggest that mortality exceeds 

sustainable levels, work with ADF&G and USFWS to identify probable 

sources of mortality. Examine the relationship among wolf mortality, 

human access, and hunter/trapper harvest. Conduct analyses for smaller 

islands (e.g., Mitkof lsland), portions of larger islands, or among multiple 

wildlife analysis areas (WAAs). 

c) Where road access and associated human-caused mortality has been 

determined, through an interagency analysis, to be a significant 

contributing factor to locally unsustainable wolf mortality, incorporate this 

information into Travel Management planning and hunting/ trapping 

regulatory planning. The objective is to reduce mortality risk and a range 

of options to reduce this risk should be considered. In these landscapes, 

both open and total road density should be considered. Total road 

densities of 0. 7 to 1.0 mile per square mile or less may be necessary. 

Options shall likely include a combination of Travel Management 

regulations, establishing road closures, and promulgating hunting and 

trapping regulations to ensure locally viable wolf populations. Local 

knowledge of habitat conditions, spatial locations of roads, and other 

factors need to be considered by the interagency analysis rather than 

solely relying upon road densities. Road management objectives would 

be developed and implemented through an interdisciplinary Access and 

Travel Management or comparable process. (See Transportation Forestwide Standards and Guidelines.) Suggested wolf hunting and trapping 

and the Forest Service, it is difficult to determine the link, if any, 

between habitat change on the Tongass and changes in the wolf 

population, especially given confounding factors such as 

weather-dependent fluctuations in prey abundance or spatially 

differential hunting pressure (USDA Forest Service 2004i) (2008 

FEIS V1 p3-238).

Please see response to comment 046-PB-03.

Hunter harvest data from 1996-2013 was used to assess hunter 

demand and deer habitat capability was used to estimate the 

theoretical number of deer available. On Wrangell Island (WAA 

1903), the average hunter harvest is 69 deer per year. 

Therefore, under Alternative 2 hunter harvest of deer on 

Wrangell Island represent approximately 3.1 percent of the 

modeled deer habitat capability.

Wolf mortality concerns have not been identified on Wrangell 

Island.

Note that the 0.7-1.0 miles per square mile road density 

guideline does not need to be considered until a determination 

has been made and that consideration of wolf hunting and 

trapping harvest is also considered. In addition, local knowledge 

of habitat conditions, spatial location of roads, and other factors 

were considered by the biologist rather than solely relying upon 

road densities (2008 Forest Plan FEIS, appendix H, p. 173).
Appendix B

Wrangell Island Project FEIS ♦ 113

Comment 

Number Comment Response

changes would be developed and forwarded to the Federal Subsistence 

Board and the Alaska Board of Game.

2. Provide, where possible, sufficient deer habitat capability to first 

maintain sustainable wolf populations, and then to consider meeting 

estimated human deer harvest demands. This is generally considered to 

equate to the habitat capability to support 18 deer per square mile (using

habitat capability model outputs) in biogeographic provinces where deer 

are the primary prey of wolves. Use the most recent version of the 

interagency deer habitat capability model and field validation of local 

deer habitat conditions to assess deer habitat, unless alternate analysis 

tools are developed. Local knowledge of habitat conditions, spatial 

location of habitat, and other factors need to be considered by the 

biologist rather than solely relying upon model outputs.

3. Design management activities to avoid abandonment of wolf dens. a) 

Maintain a 1,200-foot forested buffer, where available, around known 

active wolf dens. Road construction within the buffer is discouraged and 

alternative routes should be identified where feasible. No road 

construction is permitted within 600 feet of a den unless site-specific 

analysis indicates that local landform or other factors will alleviate 

potential adverse disturbance. b) If a den is monitored for 2 consecutive 

years and found to be inactive, buffers described in a), above, are no 

longer required.

However, in the spring, prior to implementing on-the-ground 

management activities (timber harvest or road construction), check each 

known inactive den site to see if it has become active.

There are no known wolf dens on Wrangell Island. We have not 

conducted formal surveys for wolves but have not encountered 

any probable dens sites through other field reconnaissance. 

Standard and guidelines regarding wolf dens would be followed 

during project implementation. 

056-DOW-05 The DEIS contains no indication that the Forest Service is implementing 

these standards and guidelines in any way relevant to the Wrangell 

Island project. There is no mention of cooperation with ADF&G or 

USFWS to assist in maintaining long-term sustainable wolf populations, 

or efforts to provide the habitat capable of supporting 18 deer per square 

mile as required in paragraph A.2 above. Indeed, the DEIS does not 

appear to consider the provision of deer habitat equating to 18 deer per 

square mile to be a specific desired condition, or to even be of particular 

importance, before or after implementation of the Wrangell Island 

project.

As indicated in the EIS, the project complies with Forest Plan 

standards and guidelines, there is regular cooperation with 

ADF&G, and deer habitat was considered. Although the Tongass 

and the ADF&G conduct limited deer pellet surveys to estimate 

deer population trends, robust deer density estimates are not 

available for the Tongass because surveys are conducted in a 

very limited number of areas (they focus on areas with heavy 

hunting pressure) and are inconsistently conducted from year to 

year. Given these limitations, impacts to actual deer density 

cannot be quantified per se; however, some generalizations can 

be made about the effects of changes in habitat capability on 

deer numbers if information about current population trends is 

known (FEIS, p. 3-282). The wolf guideline is intended to apply 

to biogeographic provinces where deer are the primary prey of 
BAppendix

Wrangell Island Project FEIS ♦ 114

Comment 

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wolves (FEIS, p. 3-283). Deer density on Wrangell Island 

historically (1954) supported 15.3 deer/mi2 and is currently at 

12.9 deer/mi2 (Wildlife Resource Report, p. 59).

The 2016 Forest Plan FEIS, pages 3-283 and 3-284 

acknowledges that certain areas as displayed by percent number 

of WAAs in certain biogeographic provinces may not have the 

long-term ability to support 18 deer per square mile. 

056-DOW-06 The DEIS also contains no discussion of management activities 

designed to avoid abandonment of wolf dens as part of this project as 

required in paragraph A.3, instead simply stating that there are no known 

wolf dens in the project area. There is no indication of any effort to locate 

any dens. The DEIS, however, characterizes with reasonable specificity 

the preferred denning sites of nearby wolves. At minimum, the FEIS 

should apply this knowledge to the project area and seek to identify likely 

wolf den locations. This could facilitate the potential identification of dens 

prior to project activities, or the creation of protective buffers around 

likely areas in the absence of confirming den sites. If this approach is 

unworkable for any reason, then the FEIS should explain why, so that 

the public can see that the Forest Service is at least trying to implement 

the Forest Plan standards and guidelines designed to protect wolves, 

which is a critical component of the conservation strategy.

There are no known wolf dens on Wrangell Island. We have not 

conducted formal surveys for wolves but have not encountered 

any probable dens sites through other field reconnaissance. 

Standard and guidelines regarding wolf dens would be followed 

during project implementation. 

056-DOW-07 Significantly, the DEIS does not state whether the Wrangell Island WAA 

is an area of wolf mortality concern, which would trigger the Wolf Habitat 

Management Program provision noted above. It discusses no such 

Habitat Management Program or any of the efforts required by section 

A.1 (a)-(c) listed above. In sum, the DEIS fails to implement at the 

project level the Forest Plan standards and guidelines designed to 

protect AA wolves on the Tongass. The FEIS should remedy this as 

follows.

2. The Forest Service Should Acknowledge Wolf Mortality Concerns on 

Wrangell Island and Implement the Standards and Guidelines for 

Wolves.

For a detailed, project-level analysis, the DEIS does not say much about 

wolves on Wrangell Island, so there is presumably a scarcity of reliable 

data. 

It is this somewhat limited knowledge base that the Forest Service must 

use to determine project effects on these wolves, to select appropriate 

The FEIS and Wildlife Resource Report have been revised to 

clarify this information. The Wrangell Island Project analysis 

indicates there is a not wolf mortality concern on Wrangell Island. 

Therefore, the standards and guidelines for an interagency 

cooperation wolf habitat management program is not necessary.

Please see response to comment 046-PB-03.
Appendix B

Wrangell Island Project FEIS ♦ 115

Comment 

Number Comment Response

conservation efforts to minimize adverse impacts, and ultimately to 

ensure their continued viability. The available site-specific information, 

together with information about other southeast Alaska wolves 

considered in light of relevant metrics including road density and deer 

habitat, all point to the conclusion that wolf mortality is a concern on 

Wrangell Island.

056-DOW-08 i. Road Density is a Concern for Wrangell Island Wolves

One of the primary concerns to the long-term viability of wolf populations 

in a given area is road density, which can increase hunting and trapping 

mortality through improved human access. Wolf harvest has doubled 

when total road density below 1200' elevation exceeded 0.7 

miles/square mile, and both open and closed roads can increase harvest 

levels. When calculating road densities, open and closed roads should 

be included and consideration should be given to excluding high 

elevations from the analysis.

Existing road density on Wrangell Island as 0.98 miles/square mile on 

Forest Service land, and 1.3 miles/square mile on all lands as measured 

in the DEIS. This is already above the Forest Plan standard and 

guideline of 0.7-1.0 miles/ square mile, and all action alternatives will 

exacerbate this problem for wolves, increasing the total density to 

between 1.42-1.5 miles/square mile, depending on the alternative.

Moreover, the DEIS figures appear likely to understate the problem of 

road density for wolves on Wrangell Island. As noted, southeast Alaska 

wolves spend most of their time at low elevations, below 270 feet, den at 

low elevations, and are rarely ever found above 924 feet of elevation. 

Instead of using an elevation more meaningful in light of wolf behavior, 

such as 500' or 800', the DEIS uses a 1200' elevation to determine road 

density. The FEIS should present road density at lower elevations to 

better understand the practical increased hunting pressure on wolves, 

which are far less likely to be vulnerable to increased hunting pressure 

due to roads above 800'. That is, the FEIS should exclude high 

elevations from the analysis, as the DEIS notes should happen but does 

not actually do.

The wolf standards and guidelines for road density was based on 

the analysis described in Person et al. 1996.

This included a calculation of the road density below 1,200 feet. 

Also, open road densities above or below the referenced road 

density may be appropriate to effectively manage road-access 

related wolf mortality which was the approach taken by the 

Forest Plan Revision. This was based on the conclusion that 

“Establishing a rigid road density level, and arbitrarily closing 

roads to meet this density, provides no management assurance 

that wolf conservation objectives would be achieved, and may 

unnecessarily limit overall public use of an established road 

system that may otherwise have no specific adverse impact on 

wolf mortality” (1997 Tongass Forest Plan FEIS, appendix N).

056-DOW-09 ii. Deer Habitat is a Concern for Wrangell Island Wolves

As noted above, deer density on all Wrangell Island lands is currently 

estimated based on available habitat at 10.9 deer/square mile and is 

expected to drop to 9.9-10.2 deer, depending on the action alternative 

chosen. This is well below the 18 deer/square mile standard for 
BAppendix

Wrangell Island Project FEIS ♦ 116

Comment 

Number Comment Response

supporting viable wolf populations, where deer are the wolves' primary 

prey. The DEIS does not appear to regard this as a problem for deer or 

wolves, and simply concludes that wolves will continue to persist on 

Wrangell Island if the proposed project proceeds, despite the low deer 

density. 

As also noted above, critical winter deer habitat is not well-characterized 

in the DEIS because key factors like appropriate elevation, aspect, 

vegetation (high volume old growth) and typical snowfall are not all 

reflected in the information presented. When critical winter deer habitat is 

accurately characterized in the FEIS, it is likely that estimated "deep 

snow" habitat and perhaps the expected deer densities will decrease for 

all action alternatives, making the situation worse for wolves on Wrangell 

Island.

Since the two key units of measure - deer habitat and road density -

already fall well short of desired conditions, a proposed timber sale that 

will further reduce deer habitat and increase road density points to 

mortality concerns for wolves. In fact, the USFWS already specifically 

stated that "Long term viability of wolves on Wrangell Island is a 

concern," citing the combination of timber harvest and road construction 

impacts on deer, as well as road density and hunting pressure on 

wolves. There is nothing in the record to suggest that wolves are thriving 

despite the seemingly adverse conditions, or that there is something 

about Wrangell Island wolves that render these concerns less applicable

to them than other wolf populations. As such, the Forest Service should 

acknowledge on these facts that there are wolf mortality concerns on 

Wrangell Island.

We followed the 2011 Direction for Project-level Deer, Wolf, and 

Subsistence Analysis for evaluating deer habitat to run the 

interagency deer model. This model uses the four factors 

mentioned in this comment to rate each stand with a value 

known as Habitat Suitability Index (HSI). These HSI values are 

then assigned to each GIS polygon. In addition, a separate 

analysis was conducted for deep snow habitat and average 

snow habitat for deer using vegetation, elevation and aspect. 

See tables 35 through 38 in the EIS.

Wolf mortality concerns caused by road access and associated 

human-causes have not been identified on Wrangell Island. We 

could not verify the UWFWS quote provided. However, the 

USFWS 12 month finding for the proposed listing of the 

Alexander Archipelago wolf states: “After review of the best 

available scientific and commercial information, we find that 

listing the Alexander Archipelago wolf is not warranted at this 

time throughout all or a significant portion of its range, including 

POW.” Wrangell Island is not mentioned in the discussion of this 

finding.

056-DOW-10 3. The Forest Service Should Implement the Wolf Habitat Management 

Program Described in the Standards and Guidelines.

Upon recognizing those concerns, the Forest Service should activate the 

process described in the standards and guidelines quoted above, 

including working with ADF&G and USFWS on population estimates, 

identifying sources of mortality, and considering whether Travel 

Management options or hunting/ trapping regulatory planning is 

appropriate. The guidelines state "Conduct analyses for smaller islands" 

to "examine the relationship among wolf mortality, human access, and 

hunter/ trapper harvest;" the NEPA assessment of this project makes an 

ideal time to conduct an analysis for Wrangell Island.

Our understanding is that a Wolf Habitat Management Team has now 

been initiated on Prince of Wales island. A significant wolf population 

As mentioned previously, wolf mortality has not been identified

as a concern on Wrangell Island.
Appendix B

Wrangell Island Project FEIS ♦ 117

Comment 

Number Comment Response

decline on Prince of Wales has already been documented, but evidence 

of such a decline is not and should not be a prerequisite to establishing a 

wolf habitat management team on Wrangell Island. The standards and 

guidelines seek no such evidence, and requiring it would ensure that 

wolf management efforts are not undertaken until significant harm to 

wolves has already occurred.

Wrangell Island contains many of the same issues that have led to the 

wolf population declines on Prince of Wales, such as road density, deer 

density, and reported and unreported wolf trapping and mortality. There 

is potentially even more concern on Wrangell Island in terms of hunting 

pressure on wolves because the human population is almost 60% of that 

on Prince of Wales, while the Wrangell Island land base is only 8% of 

Prince of Wales. 

Conditions on Wrangell Island regarding wolves are not 

comparable to those on Prince of Wales Island. A report about 

the wolves on Prince of Wales Island and habitat 

recommendations has been placed on the Tongass public 

website

- https://www.fs.usda.gov/land/tongass/landmanagement. 

056-DOW-11 With regard to Travel Management, it appears that instead of working 

with ADF&G and USFWS to develop options driven by wolf viability 

concerns, as prescribed in the wolf standards and guidelines, the 

interdisciplinary team pursued a process with the Borough of Wrangell 

that "identified the roads associated with the (proposed) alternative that 

are the most important to the community for subsistence and recreation 

access." The proposed Alternative 2 has the greatest amount of timber 

harvest and road building among the alternatives. While community 

desires for road access for subsistence and recreation are valid 

considerations, the FEIS should include a Travel Management 

component driven by wolf viability concerns and reflecting the required 

cooperation of ADF&G and USFWS.

The Forest Plan standards and guidelines for the Alexander 

Archipelago Wolf states “Where wolf mortality concerns have 

been identified, develop and implement a Wolf Habitat 

Management Program in conjunction with ADF&G.” It continues 

to state “Where road access and associated human-caused 

mortality has been determined, through an interagency analysis, 

to be a significant contributing factor to locally unsustainable wolf 

mortality, incorporate this information into Travel Management 

planning and hunting/trapping regulatory planning.” (Forest Plan, 

4-95).

On Wrangell Island, wolf mortality concerns have not been 

identified, therefore these standards and guidelines for 

interagency cooperation in a wolf habitat management program 

do not apply. The Forest Service and the City and Borough of 

Wrangell work cooperatively with the ADF&G, USFWS and the 

City and Borough of Wrangell on wildlife concerns, including 

wolves, regarding the Wrangell Island Project. This resulted in 

the travel management proposed in each alternative.

056-DOW-12 The standards and guidelines are intended to ensure the continued 

viability of the wolf, and as such need to be applied in a proactive 

manner, not in a post-mortem context to understand how wolf 

populations significantly declined or were rendered non-viable. Here, the 

key indicators of deer habitat and road density are below thresholds 

important for wolf survival and thus clearly indicate a threat to long-term 

wolf viability, even before consideration of project impacts. The USFWS 

has voiced this wolf mortality concern. The Forest Service should 

Wildlife viability is addressed at the Forest Plan level.

No wolf dens have been discovered on Wrangell Island. Please 

see the Wildlife and Transportation Resource Reports for deer 

winter habitat, wolves and travel management.
BAppendix

Wrangell Island Project FEIS ♦ 118

Comment 

Number Comment Response

implement the standards and guidelines, and the FEIS should display 

the results of those efforts, including stronger population estimates; 

better identification of and buffers for wolf dens, critical deer winter 

habitat, and road density; consideration of Travel Management and 

hunting/trapping components to benefit wolf populations; and the general 

cooperation and engagement of ADF&G and USFWS as part of the 

required Forest-wide program to maintain long-term sustainable wolf 

populations.

056-DOW-13 C. Marten

The Wrangell Island project is within the Etolin Island Biogeographic 

Province, which is considered a high-risk province for marten habitat. 

During severe deep snow winters, high-volume POG habitat may be the 

most crucial element to marten survival. Harvests of 60 and 69 marten 

on Wrangell Island in 2011 and 2012, respectively, far exceeded the 

annual average since 1992 of 16 marten per year. Increased road 

densities associated with timber harvest activities have improved 

trappers' access to furbearers' habitat, reducing their refugia and making 

them vulnerable to overharvest. Thus, the marten presents concerns 

related to high-POG winter habitat and road density similar to the deer 

and wolf.

Marten were evaluated for the Wrangell Island Project. Please 

see the Wildlife Resource Report and Wildlife section of chapter

3 of the EIS.

056-DOW-14 Additionally, selective logging that preserves at least 70% of the basal 

area minimizes impacts to marten habitat carrying capacity. The FEIS 

should provide the more precise mapping of "deep snow" habitat and 

lower elevation road density as already discussed, and the final project 

should protect key deep snow habitat with selective logging in any areas 

where logging is allowed. Fragmentation is also a significant concern for 

marten. Gaps consisting of one vacant marten territory every one to 

three square miles can reduce habitat capability to the point that 

reproductively successful marten populations may no longer exist. Gaps 

will reduce gene flow, so the greater the size and number of gaps, the 

higher the risk of reducing gene flow. Thus the need "to provide for a 

continuous recruitment of old, large-diameter trees for denning and 

resting sites and prey habitat through the affected area."

Comment noted. 

The wildlife analysis addressed effects on marten. Figure 14 of 

the Wildlife Resource Report displays all POG habitat on 

Wrangell Island which includes “deep snow” habitat. The effects 

from the proposed project on deep snow habitat can be found in 

tables 43 and 44 (Wildlife Resources Report pp 105-6). The 

project could harvest 24 to 58 acres of deep snow habitat 

depending on which alternative is selected. This could result in a 

1 to 3 percent decline from existing condition on NFS lands only. 

Marten habitat would be maintained on Wrangell Island through 

the conservation strategy. Other areas such as 2001 inventoried 

Roadless Areas are not available for commercial timber harvest. 

See figure 3 in the FEIS.

056-DOW-15 These considerations for marten strongly support the IA team 

recommendations for modifying OGRs to increase size, POG and highvolume POG acreage, and improve connectivity - which will all tend to 

minimize the number and size of habitat gaps that threaten marten 

survival. These considerations also counsel in favor of the road closures 

Comment noted in favor of the road closures approved in the 

Wrangell Island ATM. The closures in the decision for the ATM 

are part of Alternative 1 and Alternative 5.
Appendix B

Wrangell Island Project FEIS ♦ 119

Comment 

Number Comment Response

already selected in the Wrangell District ATM but deferred until this 

project decision, since hunting pressure has increased significantly on 

marten due to additional roads.

Please see response to comment 056-DOW-01 and -02.

056-DOW-16 Finally, the Forest Plan standards and guidelines for marten are similar 

to those for the wolf, in that the Forest Service is supposed to implement 

a Forest-wide program with ADF&G to conserve marten habitat to assist 

in maintaining long-term sustainable marten populations.st Also, when 

there are marten mortality concerns in an area, management activities 

including access to Forest Service lands and consideration of ADF&G 

hunting/trapping regulations should occur. The DEIS mentions no 

Forest-wide program involving Forest Service and ADF&G cooperation 

to conserve marten habitat. At a minimum, the two agencies should 

closely monitor marten habitat and harvest levels on Wrangell Island to 

actively seek to maintain long-term sustainable populations, as required 

by the standards and guidelines. The FEIS should explicitly address 

whether there is a concern for marten mortality on Wrangell Island.

Please see response to comment 036-ADFG-03

ADF&G manages marten harvest on Wrangell Island and 

monitors the number of animals harvested. ADF&G has not 

identified any marten mortality concerns. The Forest Service 

monitors the effects to old-growth habitat through the Forestwide monitoring program. See 2016 Forest Plan, chapter 6.

Conclusion

There are clear challenges in proposing further old growth logging and 

clearcutting in an area carrying such significant successional debt from 

prior timber harvesting and road building activities that have substantially 

reduced important wildlife habitat, especially high-volume POG. One key 

step in attempting to do so responsibly is to prepare thorough analyses 

to support all appropriate management actions to safeguard wildlife and 

habitat in light of the proposed action. The Forest Service has 

undertaken a number of helpful analyses, but there are management 

actions and decisions left outstanding that need to be completed before 

an adequate FEIS and Record of Decision can be prepared.

Those actions include modifying the OGRs so that they meet minimum 

Forest Plan criteria and can thus serve their intended purpose; building a 

project alternative that reflects the biologically preferred OGR 

configurations identified by the IA team; actively implementing all 

applicable standards and guidelines for wildlife, particularly wolves and 

marten; and more carefully defining and presenting key units of 

measurement bearing on road density and critical winter deer habitat. 

We look forward to seeing these adjustments as the FEIS is developed. 

Sincerely,

Patrick Lavin

Alaska Representative
BAppendix

Wrangell Island Project FEIS ♦ 120

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Number Comment Response

057-DG-01 I am against any logging on the island, especially by [Alaska Mental 

Health Trust], who doesn’t give the residents of Wrangell Island any say 

in it. 

We have to live here. The tourists have to look at it. 

I’m against all of it. 

Bald eagles are being killed, porcupines have nowhere to go, birds and 

squirrels are living on telephone poles and being killed because they 

have nowhere to live. 

It’s totally wrong. 

We’re trying to bringing up our kids to [spend time outdoors]. 

It seems like nobody cares. 

City hall doesn’t care and won’t stand up to [Alaska Mental Health Trust] 

Forest service should trade the [Alaska Mental Health Trust] lands. 

Should not be able to log in the towns, including the Institute property. 

Our kids have no future, all the trees are knocked down. What happened 

to all the trees and animals? 

Just greed and money, it’s not right at all. 

When we were kids, we were brought up to camp and hunt. Now it’s 

destruction everywhere. 

I worked for both timber mills all my life, it’s greed and money. 

They can select different areas away from town to log. 

I want city hall to represent the people [against the Alaska Mental Health 

Trust]. 

Mental health doesn’t need to be logging on the islands we live on. 

Darrel Gross 

PO Box 754 

Wrangell, AK 99929

Comment noted. Please note that Activities on Alaska Mental 

Health Trust lands are outside the jurisdiction of the Forest 

Service. Alternative 1 does not propose any timber harvest. 

058-SEACC SOUTHEAST ALASKA CONSERVATION COUNCIL

WRANGELL RESOURCE COUNCIL

ALASKA WILDERNESS LEAGUE

AUDUBON ALASKA

DEFENDERS OF WILDLIFE

EARTHJUSTICE

NATURAL RESOURCES DEFENSE COUNCIL

SIERRA CLUB 
Appendix B

Wrangell Island Project FEIS ♦ 121

Comment 

Number Comment Response

WOMEN’S EARTH AND CLIMATE ACTION NETWORK (WECAN) 

July 18, 2016

VIA ELECTRONIC MAIL AND U.S. MAIL

Robert Dalrymple

District Ranger

Wrangell Ranger District

P.O. Box 51

Wrangell, AK 99929

E: comments-alaska-tongass-wrangell@fs.fed.us 

Re: Wrangell Island Project

Dear Mr. Dalrymple:

The undersigned organizations submit these comments on the Wrangell 

Island Project Draft Environmental Impact Statement (DEIS). These 

comments are in addition to separate comments these groups may 

submit. These groups have long-standing interest in the social and 

ecological values of the Tongass National Forest and any developments 

that may affect those values. For the reasons described below, the 

Forest Service should not pursue the Wrangell Island Project.

Southeast Alaska’s tourism, recreation, and fishing industries long ago 

supplanted industrial-scale logging as the region’s main economic

drivers. The tourism industry, for example, accounts for 28 percent of the 

employment and generates an annual $1 billion economic benefit. The 

salmon fishing industry contributes another $1 billion annually to the 

regional economy and accounts for 12 percent of Southeast Alaska’s 

employment. In contrast, the arts sector alone is nearly twice the size of 

the regional timber industry. Sustainable industries are Alaska’s future, 

but they depend on healthy watersheds, abundant fish and wildlife 

habitat, and scenic landscapes that the Wrangell Island Project will 

destroy.
BAppendix

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Number Comment Response

The Wrangell Island Project raises significant and pervasive 

environmental concerns in large part because it proposes such a 

massive old-growth logging project in a portion of the Tongass that has 

already suffered some of the worst impacts from logging. In fact, the 

Forest Service is unable to conclude that fish and wildlife populations will 

be sustainable after this timber sale project, explaining instead that the 

agency believes these populations should continue to “persist.” 

Elsewhere the DEIS acknowledges that the long-term viability of 

endemic species, even without the Wrangell Island Project, “is unknown, 

but of increasing concern.” For example, virtually the entire population of 

a subspecies of the southern red-backed vole on the Tongass National 

Forest lives on Wrangell Island, but the agency has no idea how many 

remain or whether the population will remain viable after the proposed 

logging. The Alaska Department of Fish and Game (ADF&G) has raised 

repeated and consistent concerns regarding the loss of old-growth 

habitat for bears, but the Forest Service ignores those concerns entirely. 

And, with regard to Sitka black-tailed deer and Alexander Archipelago 

wolf, the agency admits the amount of old-growth habitat remaining 

today is already below the level the agency generally considers sufficient 

to support a sustainable relationship between wolves, deer, and deer 

hunters. Again the agency is unable to say that this relationship will 

remain stable after the Wrangell Island Project. As a result, deer hunters 

on Wrangell, especially those who hunt from the road system, will 

experience negative, long-term effects from this sale due to loss of oldgrowth habitat and the resulting decline in deer.

In addition to the environmental damage the Wrangell Island Project will 

cause, the project is the latest illustration that the Tongass timber 

program has operated at massive economic losses to United States 

taxpayers. According to the U.S. Government Accounting Office, “[t]he 

Forest Service reported an average of $12.5 million annually in timberrelated expenditures for the Tongass from fiscal years 2005 to 2014. 

During that period, it reported receiving an average of $1.1 million in 

revenues associated with timber harvested from the Tongass.” 

Additionally, every alternative presented in the DEIS reflects a significant 

economic loss based on the indicated advertised rate. The Forest 

Service, however, never addresses the consequences of that economic 

reality. It is a remarkable critique of the Tongass timber program that the 

Forest Service has proposed a timber sale project that as whole could 

not be profitable based on today’s circumstances. 
Appendix B

Wrangell Island Project FEIS ♦ 123

Comment 

Number Comment Response

For all of these reasons, the Wrangell Island Project fails to advance the 

Department of Agriculture’s visionary goal of “transitioning quickly away 

from timber harvesting in . . . old-growth forests.” The Wrangell Island 

Project would entrench and prolong the existing unsustainable oldgrowth industry. It would provide 65 million board-feet (MMBF) of timber, 

100 percent of which is old-growth. Despite this, the DEIS does not 

identify even one economically viable action alternative under prevailing 

market conditions. As a result, if the Wrangell Island Project encourages 

any investment at all, it would be only in more industrial-scale old-growth 

logging that is not environmentally or economically sustainable. 

Sustaining and encouraging long-term investment in the existing, 

subsidy and export dependent old-growth industry is the opposite of 

transitioning quickly out of it. Instead the Forest Service should redirect 

its efforts to fostering investment in sustainable economic enterprises 

and a rapid reduction in old-growth logging, consistent with the 

Department of Agriculture’s transition goal. 

[Table of contents removed for space considerations]

PURPOSE AND NEED

058-SEACC01The DEIS defines the Wrangell Island Project purpose and need too 

narrowly, because it focuses too much on large-scale old-growth logging 

objectives. According to the DEIS, “[t]he purpose of the Wrangell Island 

Project is to respond to the goals and objectives identified by the 2008 

Tongass Land and Resource Management Plan . . . to guide timber 

management to support the local and regional economies of Southeast 

Alaska, while moving the Wrangell Island Project area towards the 

desired future condition for all resources.” The DEIS further contends 

that “[t]his project would contribute to the orderly flow of timber to large 

and small timber purchasers, mill operators, and value-added wood 

product industries in Southeast Alaska and benefit the local and regional 

economies of Wrangell and Southeast Alaska while also improving forest 

resource conditions.”

Comment noted. The purpose and need for the project is 

described in chapter 1 of the EIS. The purpose is to respond to 

the goals and objectives in the Forest Plan to guide timber 

management to support the local and regional economies of 

Southeast Alaska while moving the project area towards the 

desired condition for all resources. The purpose and need for the 

Wrangell Island Project is appropriate, as it meets goal and 

objective direction in the Forest Plan and responds to the 

requirements in the Tongass Timber Reform Act.

058-SEACC02The purpose and need statement identifies two goals and three 

objectives that relate solely to timber industry needs. The local and 

regional economy goal and objective purportedly relate to 

diverse resource uses and employment, but in reality the Forest Service 

seems to treat it as solely timber-driven. As the planning record makes 

clear, the Forest Service appears to have predetermined its mission as 

providing maximum old-growth volume.

Timber harvest continues to be an important component of the 

local and regional economy of Southeast Alaska to maintain a 

diverse economy although it has diminished from previous 

decades. Economic sectors such as commercial fishing, 

recreation, and tourism are continuing to grow alongside the 

continuation of timber harvesting occurring under the resource 
BAppendix

Wrangell Island Project FEIS ♦ 124

Comment 

Number Comment Response

protection measures of the Forest Plan. These industries are not 

necessarily exclusive of each other as indicated in the comment. 

Please see response to comment 035-DA-01.

058-SEACC03The purpose and need statement also does not reflect the reality of 

Southeast Alaska’s economy or the goal of transitioning away from the 

controversy and conflict of old-growth logging. As explained above, the 

region has moved beyond massive old-growth logging as the primary 

economic driver. By applying the purpose and need statement for this 

project so narrowly, the agency actually works against the economic 

interests of Southeast Alaskans. The economic drivers of the Southeast 

economy depend upon intact, old-growth forests: fishing, tourism, and 

recreation. The agency should be developing projects that support those 

industries and, in so doing, facilitate the transition away from 

environmentally and economically unsustainable industrial-scale oldgrowth logging. The final environmental impact statement for the 

Wrangell Island Project (FEIS) should adjust the purpose and need to 

reflect appropriately the agency’s multiple use obligations.

The Forest Plan standards and guidelines, in conjunction with 

the alternative designs in this project would limit adverse impacts 

to other regional economic interests. 

Please see response to comment 058-SEACC-02.

058-SEACC04RANGE OF ALTERNATIVES

Under the National Environmental Policy Act (NEPA), the agency is 

required to develop alternatives that would “inform decisionmakers and 

the public of the reasonable alternatives which would avoid or minimize 

adverse impacts or enhance the quality of the human environment.” The 

DEIS does not comply with NEPA’s directive to “[r]igorously explore and 

objectively evaluate all reasonable alternatives.” The courts have made 

it clear: “The agency must look at every reasonable alternative within 

the range dictated by the nature and scope of the proposal. The 

existence of reasonable but unexamined alternatives renders an EIS 

inadequate.” 

During the scoping process, groups requested that the Forest Service 

significantly downsize the timber sale volume of the Wrangell Island 

Project or cancel the timber component altogether, explaining that the 

proposed volume was excessive, did not reflect a reasonable 

assessment of demand for timber, and would result in negatively 

appraised projects. Instead, they encouraged the Forest Service to 

review small-volume alternatives that addressed the needs of smallscale timber operators. 

The EIS was prepared in compliance with NEPA (chapter 1 -

Introduction). The EIS proposes an adequate range of 

alternatives which address the key issues developed from public 

scoping responses while meeting the purpose and need for the 

project. The no action alternative addresses the request to drop 

the timber sale. The amount of volume proposed in the 

alternatives is greatly reduced from the original proposal for 150 

plus MMBF. The needs of small scale operators are included in 

the purpose and need for the project and the market demand 

assessment. Please also see response to comment 061-

GSACC-10.

058-SEACC05Southeast Alaska Conservation Council (SEACC), for example, 

proposed a “Small Mill & Wildlife Alternative” that contemplated 2 MMBF 

per year over ten years. In its letter, SEACC also questioned the 

A letter from SEACC, dated July 25, 2011, was received and 

was considered in the analysis. This letter suggested an 

alternative that would limit timber offerings to a series of sales, 
Appendix B

Wrangell Island Project FEIS ♦ 125

Comment 

Number Comment Response

economic viability of the Wrangell Island Project given the sole focus on 

large-volume alternatives:

The 2009 [Map Committee] analysis found that the original Wrangell 

Island sale volume of 150-200 MMBF appraised at negative fifty-nine 

dollars per thousand board feet (-$59/MBF), and only 30 MMBF 

appraised positive. 

. . .

Proposing large volume sales with small amounts of economical timber 

will not provide long-term support to small mill operators on Wrangell 

Island. Over the past decade, 50% of timber sales on the Tongass were 

not bid on at all, and of the timber that did sell, 40% was either defaulted 

on by the operator or mutually cancelled.

Similarly, other groups asked the Forest Service to downsize significantly 

the timber component of the project:

We also request that you consider either fundamentally downsizing the 

timber sale volume or cancel planning on the timber sale component of 

this project. With regard to site specific and island-wide concerns, we 

think that the proposed volume is excessive and does not reflect a 

reasonable assessment of current and potential demand for timber from 

the project area. We would prefer to review a program that proposes to 

address the needs of potential small-scale timber processors. Instead, 

this project continues the costly program of producing big sales 

dependent on raw log exports. It is appropriate to substantially limit oldgrowth removals from Wrangell Island because of damage from past 

logging and road construction.

Other groups also questioned the Forest Service’s decision to proceed 

with large-volume alternatives given the negative appraisals:

Preliminary agency planning on this project using 2007 data showed that 

this project would be a deficit sale with values ranging from -$37.04 to -

$80.16 per MBF. 2007 appraisal rates declined considerably from 2005 

to 2007. Yet planning on this sale seems to assume that the current 

market will improve and yield positive appraisals. In a 2009 letter from 

Clarence Clark of the Alaska Department of Forestry to Tongass Forest 

Supervisor Forrest Cole, Clark pointed out that it would require a 

substantial and unlikely market upswing to change these values. Is there 

any indication of an improving market at this time? Please provide 

detailed information about current appraisal rates, and provide charts 

each 2 MMBF per year for 10 years, over 30 years, targeted to 

small local mill operators. This alternative included no new road 

construction. 

Efforts have been made to increase the values of the sales to the 

operator through the R10 Limited Export policy. This allows the 

operator for alternate markets for lower quality wood.

This “Small Mill and Wildlife Alternative” was inadvertently 

omitted from the DEIS chapter 2 section “Alternatives 

Considered But Eliminated from Detailed Study.” It has been 

included in the FEIS. The proposal was eliminated from detailed 

study because an adequate supply of timber is needed to 

maintain the industry during the transition to young growth. This 

small amount of timber volume would not satisfactorily contribute 

to a supply of timber that meets the annual or planning cycle 

demand for the Forest. Access to most of the suitable and 

available timber on Wrangell Island requires additional road

construction or helicopter yarding which are typically beyond the 

financial capabilities of a small mill operator. A 2 MMBF timber 

sale would usually not have sufficient timber volume to provide 

the economy of scale to cover these additional costs.

Furthermore, the Forest Service cannot designate contracts for 

certain operators, such as only those on Wrangell Island; timber 

harvest contracts must be open to competitive bidding (FSH 

2409.18 section 58.1).

However, the needs of small local mill operators were included in 

all of the action alternatives as part of the timber made available 

to industry. The project would contribute to the orderly flow of 

timber to large and small mills. See the Project Purpose and 

Need section of chapter 1 of the EIS.
BAppendix

Wrangell Island Project FEIS ♦ 126

Comment 

Number Comment Response

that demonstrate fluctuations in appraisal rates over the past decade. If 

this project is contingent on a market upswing, please explain why the 

Forest Service disagrees with Clark’s assessment.

The DEIS, however, fails to acknowledge these requests and concerns. 

It also fails to explain why the agency refused to consider such 

alternatives. As the planning record makes clear, the agency should 

have addressed these requests. In the Wrangell Island EIS Project 

Initiation Letter, you specifically instructed: “The [Interdisciplinary Team] 

should develop a range of alternatives including the No Action 

Alternative, the Proposed Action Alternative, and additional action 

alternatives that respond to the purpose and need and key issues. These 

should include an alternative (s) to address public comments from the 

public [and] SEACC.” Instead, the DEIS includes only large volume 

action alternatives that range from 42.8 to 65 million board feet (MMBF).

The Forest Service’s failure to examine smaller volume sales is even 

more confounding because, as predicted more than seven years ago, all 

of the action alternatives analyzed in the DEIS result in substantially 

negative appraisals. The action alternatives result in indicated advertised 

rates for domestic processing ranging from negative $215.62 to negative 

$253.21. Even when the agency relies on the Region 10 export policy, 

the expectations still result in negative indicated advertised rates across 

the board, ranging from negative $54.21 to negative $91.90. 

In sum, all of the action alternatives entail intensive, old-growth logging 

in a portion of the Tongass that has already experienced excessive 

logging and, as a result, fail to address other legal obligations to maintain 

sufficient habitat for old-growth dependent species and to manage the 

forest for multiple uses. The agency acted unlawfully when it failed to 

evaluate how small sale alternatives would meet the economic timber 

goals and objectives, and support diverse natural resource employment 

opportunities while minimizing adverse environmental and wildlife 

impacts. The FEIS must include multiple small sale alternatives or, at a 

minimum, explain why these alternatives were excluded from 

consideration despite their positive economic opportunities, reduced 

habitat impacts, and support for domestic operations rather than serving 

export markets. 

058-SEACC06ROADLESS RULE

The Wrangell Island Project does not protect roadless areas adequately 

or consistently with Department of Agriculture policy. It protects 2001 

Inventoried Roadless Areas (IRAs) as required by the Roadless Rule. 

The Ninth Circuit Court of Appeals upheld the reinstatement of 

the 2001 Roadless Rule on the Tongass National Forest in 2011. 

Consequently, the 2001 Roadless Rule remains in effect in 

Alaska and the Forest Service continues to apply the Rule to the 
Appendix B

Wrangell Island Project FEIS ♦ 127

Comment 

Number Comment Response

However, in connection with the 2003 forest plan amendment, the Forest 

Service updated and corrected errors in the 2001 inventory, and uses 

the updated inventory in connection with the currently applicable forest 

plan. By relying exclusively on the older, flawed inventory, the Wrangell 

Island Project, as proposed in the DEIS, would allow logging to proceed 

in places that are actually roadless. This is unacceptable.

Since at least 2010, it has been agency policy to protect Tongass 

roadless areas from logging. The area immediately south of the North 

Wrangell IRA is actually roadless, as can be seen on the map in the 

DEIS. The current roadless area inventory recognizes that area as part 

of IRA 227 (North Wrangell). Three of the alternatives—2, 4, and 5—

propose logging in that IRA. To do so would be disingenuous and 

inconsistent with the agency’s stated purpose of protecting roadless 

areas from logging.

The fact that the Roadless Rule does not prohibit logging there, due to 

erroneous maps, is a technicality that does not excuse the agency from 

protecting areas it knows to be actually roadless. The Roadless Rule 

does not require the Forest Service to log in this area and does not 

prevent the agency from protecting areas that are actually roadless but 

misrepresented in the maps. The point of the Rule and of agency policy 

is to protect roadless area values, not outdated maps. 

Further, it would be a simple matter, though not required to protect actual 

roadless areas in the Wrangell Project, to update the Roadless Rule 

maps for the Tongass with a short notice-and-comment rulemaking. 

Presumably, the agency will get around to this housekeeping matter 

eventually. In the meantime, it is important not to log in areas known to 

be roadless but mistakenly omitted from the old inventory. To do so 

would knowingly destroy roadless area values contrary to the purposes 

of the rule and preclude future protection of these areas.

The refusal to consider alternatives that protect known roadless areas in 

the current inventory violates NEPA. The DEIS misses the point when it 

refuses to consider such alternatives, stating, “[e]xcluding timber harvest 

from both types of roadless areas would not provide sufficient timber 

volume to meet the purpose and need of this project.” As an initial 

matter, this statement is untrue. As discussed in the following section 

addressing market demand, the DEIS greatly exaggerates the actual 

market demand. It would be possible to meet the purpose and need of 

Tongass National Forest using the inventory of roadless lands 

defined by the rule. Furthermore, the 2016 Forest Plan Record of 

Decision does not allow old-growth or young-growth timber 

harvest in inventoried roadless areas.

With the publication of the Roadless Rule FEIS, USDA defined 

IRAs as those areas identified in the set of maps contained in 

Volume 2 of the FEIS [66 Fed. Reg. 3250 (Jan. 12, 2001)]. 

Technical corrections (“clerical, typographical or other technical 

error”) can be made to these maps; however, the 2000 definition 

of IRAs, which relies on this set of maps, does not apply to future 

areas that may be inventoried for wilderness consideration or 

other purposes [Id.]. The Roadless Rule identifies no other 

mechanism for revision of the IRA maps, and any land area 

additions or subtractions would require further rulemaking. Since 

the roadless area evaluation prepared in 2002-2003 was 

conducted for wilderness consideration purposes rather than as 

a regulatory proposal concerning modification of roadless area 

boundaries, modification of the mapped boundaries of the IRAs 

cannot be undertaken as a ministerial act and would require 

agency rulemaking. 

The comment suggests that the Forest Service maps are 

inaccurate and that the area between the North Wrangell IRA 

and Road 6259 has been granted protection from timber harvest 

and road construction. The maps correctly display inventoried 

roadless area boundaries as defined by the 2001 Roadless Rule. 

Although there are forested areas without roads on the Tongass 

National Forest, without the IRA designation, these areas are 

available for timber harvest and road construction. The Wrangell 

Island Project does not propose logging in any 2001 inventoried 

roadless area. 

See the Alternatives Considered but Eliminated from Detailed

Study section of chapter 1 of the FEIS, as well as response to 

comment 048-TUSCS-03.
BAppendix

Wrangell Island Project FEIS ♦ 128

Comment 

Number Comment Response

the project with much lower timber volumes. Even if it were true, 

however, that protection of roadless areas in both inventories left 

insufficient timber to meet the purpose and need for the Wrangell Island 

Project, the appropriate response would be to change the purpose and 

need to bring it in line with agency policy. 

058-SEACC07I. EXAGGERATING MARKET DEMAND FOR TIMBER 

INAPPROPRIATELY DEVALUES COMPETING FOREST RESOURCES 

IN THE DECISION-MAKING PROCESS.

The Forest Service’s aim to satisfy market demand for Tongass timber 

motivates the Wrangell Island Project’s proposed logging components. 

The statutes under which the Forest Service operates require the agency 

to balance timber objectives with other forest values such as wildlife, 

recreation, and subsistence. Therefore, if the Forest Service relies on 

estimates of demand that are greatly exaggerated, it may seek too large 

a sale, giving logging goals “precedence over the competing 

environmental and recreational goals without justification sufficient to 

support the agency’s balancing of these goals.” Because demand 

influenced the proposed location of the Wrangell Island Project that too 

may be unsupportable if the Forest Service uses inaccurate demand 

projections.

The market demand for timber has not been exaggerated for the 

Wrangell Island Project, and other resource have not been 

devalued as a result. The balance of multiple uses among 

resources is obtained at the scale of the Tongass National 

Forest as a whole, not on a project-by-project or acre-by-acre 

level. To achieve this balance, the Forest Plan applies land use 

designations, each with different goals and objectives. See 

chapter 1 of the EIS. The 2016 Forest Plan, chapters 2 and 3, 

also address this.

Within the development LUDs, consideration was given and an 

analysis of effects was conducted for other resources. An 

analysis of effects for all resources was conducted and 

summarized in chapter 3 of the EIS.

058-SEACC08II. REAL-WORLD CONDITIONS AND THE FOREST SERVICE’S 

OWN UPDATED RESEARCH SHOW ACTUAL MARKET DEMAND IS 

DRAMATICALLY LESS THAN DEPICTED IN THE DEIS.

In planning the Wrangell Island Project, the Forest Service relies on 

outdated projections of market demand which anticipate approximately 

three times the demand that updated Forest Service research and recent 

history suggest will occur. In particular, the Forest Service relies on a 

ten-year-old study that was published by its Pacific Northwest Research 

Station before the Great Recession and associated housing collapse 

gutted demand for Tongass timber (Brackley Report). Of the three 

scenarios for which the Brackley Report projects demand, the DEIS 

states that Scenario 2, “Expanded Lumber,” is most similar to the current 

market trajectory. 

In April 2016, and prior to the release of the DEIS, the Pacific Northwest 

Research Station published updated timber demand projections for 

years 2015-2030 (Daniels Report). The DEIS mentions but does not 

incorporate or rely on the new projections. According to the Daniels 

Report, a new analysis was not just desirable but required because 

changing conditions have rendered “many” of the Brackley Report’s 

assumptions invalid. Although the Daniels Report is flawed and likely still 

With the decision on the 2016 Forest Plan, the demand analysis 

from the Daniels, et al. report has been used. Appendix A has 

been updated to reflect this latest information. 

A supply of old-growth “bridge” timber is necessary to transition 

to a young-growth management program as explained in the 

2016 Forest Plan FEIS, pages 3-512 through 3-516. This project 

helps to supply that timber during the transition period.
Appendix B

Wrangell Island Project FEIS ♦ 129

Comment 

Number Comment Response

overestimates demand, its projections are dramatically lower than those 

in the pre-recession Brackley Report, especially when compared to the 

Expanded Lumber scenario the DEIS relies on. The 2006 Brackley 

Report’s Expanded Lumber scenario projects approximately three times 

the demand that the 2016 Daniels Report forecasts in any scenario.

Projected Logging (MMBF) in Daniels and Brackley Reports

Year

Daniels Report (2016)

Range, all scenarios

Brackley Report (2006)

Scenario 1, Expanded 

Lumber

2016

2017

2018

2019

2020

2025

2030

41.6 – 41.6

42.3 – 43.4

43.1 – 46.3

43.8 – 49.2

44.5 – 52.1

44 – 63

46.4 – 76.4

122.2

131.3

140.3

150.1

163

230.9

N/A

058-SEACC09III. ANY EXAGGERATION OF DEMAND IS AMPLIFIED 

FURTHER IN THE FOREST SERVICE’S DECISION-MAKING 

PROCESS. 

Projected demand is only the starting point from which the Forest 

Service calculates the two timber program goals that guide its decisionmaking. Those goals each incorporate a substantial buffer or margin of 

error to reduce the chance that in any given year, actual demand will 

exceed available timber. Thus, if the market demand projections used in 

these calculations are already two to three times larger than is realistic, 

those grossly inflated figures will be further padded and then multiplied 

so that the final goals for the timber program vastly overstate the need 

for timber. 

The market demand projection the Forest Service chooses to credit is 

first padded using a formula that is part of what is called the Morse 

methodology. The purpose of the Morse methodology is to set a goal for 

the amount of timber to be offered in a given year based on the projected 

demand and adjusted to account for a large set of variables that affect 

whether supply will ultimately be sufficient to meet demand—in other 

words, to account for uncertainty. In fiscal year 2014, for example, the 

Comments on the different methods of market demand 

projection are outside the scope of this project, since market 

demand is analyzed at the Forest planning level. Please refer to 

the 2016 Forest Plan Amendment FEIS, appendix G for a 

discussion on the Daniels, et al. demand and the method of 

analysis used.

The timber volume from this project will help to ‘seek to meet’ the 

timber market demand. There is no precedence for timber on a 

forest-wide basis. Protection measures are in place to ensure 

that fish and wildlife resources are maintained. 

See also response to 061-GSACC-19.
BAppendix

Wrangell Island Project FEIS ♦ 130

Comment 

Number Comment Response

Brackley Report Expanded Lumber demand projection was for 105.6 

MMBF. The resulting volume offered goal was 142 MMBF. 

As a next step in the Morse methodology, the volume offered goal is 

tripled to obtain a goal for the total volume of timer under contract 

(“volume under contract” goal). The purpose of aiming to place a threeyear supply of volume under contract, rather than just seeking to meet 

demand year-to-year, is to allow the industry flexibility to adapt to further 

uncertainties such as market fluctuations and weather conditions. For 

fiscal year 2014, for example, the volume under contract goal was 426 

MMBF. In fact, only 39.1 MMBF were logged that year, less than onetenth of the volume under contract goal. The example demonstrates how 

the initial overestimate of demand (105.6 MMBF) was further amplified 

through the Morse methodology so that the timber program goals were 

grossly disproportionate to actual demand.

The Wrangell Island Project has been planned as a means of meeting 

the volume under contract goal that was calculated using the market 

demand projections from the outdated Brackley Report’s Expanded 

Lumber scenario. Because the Morse methodology and volume under 

contract approach are designed to ensure that available timber does not 

fall short of demand, using as its starting point these demand projections

that the Forest Service’s own research shows are overstated by a factor 

of three undeniably gives timber “precedence over the competing 

environmental and recreational goals without justification sufficient to 

support the agency’s balancing of these goals.” 

058-SEACC10IV. THE FOREST SERVICE CANNOT IGNORE REAL-WORLD 

CONDITIONS OR ITS OWN UPDATED RESEARCH.

The DEIS offers only two reasons for relying on the Brackley Report 

rather than the updated Daniels Report projections or some other, more 

realistic estimate. First, the DEIS states that “[p]lanning for the Wrangell 

Island Project occurred under the 2008 Forest Plan and uses [the 

Brackley Report] demand assumptions.” Second, the DEIS states that 

“all data and analysis [in the Daniels Report] remains in draft form until 

the manuscript is published.” Neither is a valid reason to persist in using 

the Brackley Report’s invalid projections.

It is no answer that the Wrangell Island Project was planned using the 

2008 Amended Forest Plan for which the Brackley Report was created. 

The 2008 Plan neither requires reliance on the Brackley Report nor 

Please see appendix G of the 2016 Forest Plan Amendment 

FEIS, which discusses the methods used in the analysis for what 

the commenter refers to as the Daniels Report, but which is in 

fact the “Tongass National Forest Timber Demand: Projections 

for 2015 to 2030”. Appendix A of the Wrangell Island Project 

FEIS has been revised to reflect the 2016 Forest Plan.

See response to comment 058-SEACC-08 and -09.
Appendix B

Wrangell Island Project FEIS ♦ 131

Comment 

Number Comment Response

prohibits the Forest Service from using its most up-to-date projections. 

To the contrary, the FEIS for the 2008 Plan explicitly recognizes the 

dynamic nature of the timber market and the need to reassess timber 

program goals over time. “Since the method was initially developed by 

Morse (2000), inputs to the model have been adjusted to reflect new

understandings and information, such as share of raw material provided 

by the Tongass National Forest to local processors, the amount of time 

between purchase and harvest of a timber sale, and mill capacity. In this 

way, the approach has allowed for adaptations to current situations.” 

The 2008 Amended Forest Plan makes no mention of the Brackley 

Report, but states, “Estimates of annual timber demand are based on a 

number of factors, including Pacific Northwest projections, installed mill 

capacity, utilization rates and market trends.” Since the Pacific 

Northwest Research Station has now updated its projections with the 

Daniels Report, the Plan requires the Forest Service to take that factor 

into account. That the Daniels Report was prepared in connection with 

the 2015 Forest Plan amendment is not relevant. Whatever motivated 

the report originally, it is now the Forest Service’s most up-to-date 

prediction of market demand, and it contradicts the Brackley Report. 

The fact that the Daniels Report was in draft form during part of the 

Forest Service’s preparation of the DEIS does not excuse its omission. It 

was published in final form before the DEIS was released. Even if it had 

not yet been published, agencies are free to use—but not free to 

ignore—draft studies in NEPA analyses. The DEIS offers no reason to 

doubt the validity of the “draft form” data and analysis. Indeed, the 

demand projections in the draft Daniels Report that is in the planning 

record remain unchanged in the final version that was published in April 

2016.

Finally, if the DEIS aims to evade the Daniels Report by using only the 

market demand projections for fiscal year 2014, a prior year not covered 

by the Daniels Report, the attempt must fail. The Forest Service is 

required to seek to meet current market demand, not demand for past 

years. The DEIS offers no reason that the demand projection for the year 

2014, which is already proven a gross exaggeration as a matter of 

historical fact, is likely to be accurate in the coming years. That the 

Daniels Report offers no competing projection (because it was published 

in 2016) does not make the Brackley Report projection for 2014 reliable 

or appropriate.
BAppendix

Wrangell Island Project FEIS ♦ 132

Comment 

Number Comment Response

058-SEACC11V. TO PERSIST IN RELYING ON THE BRACKLEY REPORT 

DEMAND PROJECTIONS IN THE FEIS WOULD VIOLATE NEPA AND 

THE APA.

If the Forest Service continues to rely on the Brackley projections in the 

FEIS as it has in the DEIS, the agency will run afoul of NEPA in four 

ways. First, the choice will represent a failure to use the requisite “high 

quality” information in its analysis, especially on an issue as central to 

the Wrangell Island Project as market demand. Second, by failing to 

acknowledge that the Brackley Report projections are unrealistically high 

because they are based on invalidated assumptions, the analysis will 

present a highly misleading picture of timber needs and the resulting 

trade-offs with wildlife. “Presenting accurate market demand information 

[i]s necessary to ensure a well-informed and reasoned decision, both of 

which are procedural requirements under NEPA.” Third, setting 

artificially high timber program goals will have constrained the range of 

alternatives considered, and in particular preclude the analysis of much 

smaller volume sales that would still satisfy realistic estimates of 

demand. Fourth, if, like the DEIS, the FEIS fails to provide a nonarbitrary reason to prefer the Brackley Report projections over the 

Daniels Report, the Forest Service will have failed to respond to a 

responsible opposing point of view on market demand—in this case, the 

agency’s own contemporary, published viewpoint.

Continuing to rely on the Brackley Report projections in the FEIS without 

a better explanation will also violate the APA. The substantial gap 

between the Brackley Report logging projections and both real-world 

experience and the subsequent Daniels Report projections is a “relevant 

factor” and “an important aspect of the problem,” rendering the agency’s 

failure to explain it arbitrary. 

In sum, the DEIS offers no non-arbitrary reason to persist in using the 

Brackley Report’s invalid market demand assumptions to plan the 

Wrangell Island Project when the Forest Service has already prepared 

higher quality projections that track recent logging more realistically. 

Continuing to use these invalid projections to justify the Wrangell Island 

Project will violate the statutes that require the Forest Service to balance 

timber objectives with other forest values. Doing so without offering any 

rational explanation and allowing these projections to constrain its 

analysis will violate NEPA and the APA. The FEIS must adopt more 

realistic projections of market demand. 

The Wrangell Island Project FEIS, appendix A has been updated 

to discuss the most current demand, Daniels, et al. 2016. This 

project is considered to be needed at this time since it provides 

old-growth timber volume to maintain industry through the

transition to young-growth management. Currently, industry has 

less than 3 years of timber under contract which is one of the 

objectives of the Forest Plan (p. 2-5).

See responses to comments 058-SEACC-08, -09 and -10.

058-SEACC12TIMBER ECONOMICS Please see response to comment 051-SEACCWRC-08 and 061-

GSACC-25.
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I. THE DEIS FAILS TO PROVIDE A CLEAR ASSESSMENT OF 

THE COSTS AND BENEFITS OF THE WRANGELL ISLAND PROJECT.

The DEIS fails to provide a Forest Service Financial Efficiency Analysis 

as required by FSH 2409.18, which compares Forest Service direct 

expenditures with estimated financial revenues. The DEIS omits this 

entire discussion. Instead the DEIS relegates the discussion—including 

all indications of what the project will cost taxpayers—to a draft 

document in the planning record. Even that document fails to reveal the 

Wrangell Island Project’s substantial negative net value, but more 

importantly to discuss the significance of the project’s economic 

inefficiency to the decision-making process. Failing to disclose this 

analysis in the DEIS is misleading and impermissible. The Forest 

Service justifies the Wrangell Island Project (and the entire Tongass 

timber sale program) exclusively on the grounds of purported economic 

benefits, but the Forest Service fails to disclose to the public and the 

decision-maker the true cost of its timber sale program.

The required Financial Efficiency Analysis would compare the revenue 

from the project with Forest Service expenditures (i.e., costs to the 

taxpayer) expected to result. In this analysis, FSH 2409.18_32.22 directs 

the Forest Service to “[i]nclude all costs that are anticipated as a result of 

the project,” such as but not limited to “direct costs associated with . . . 

[h]arvest administration . . . [s]ale preparation . . . [and] [r]oad design and 

engineering.” The Big Thorne FEIS, for example, disclosed that 

Alternative 3 will cost taxpayers $6 million plus undisclosed NEPA costs. 

The Big Thorne FEIS also reported that NEPA costs are estimated at 

$48/MBF, resulting in an estimated NEPA cost of $7.1 million for the 

selected alternative (148,900 MBF multiplied by $48/MBF). Thus, making 

calculations from the numbers reported in the Big Thorne FEIS, it would 

appear that the total estimated cost of the Big Thorne project to 

taxpayers would be $13.1 million.

Here, the DEIS itself discloses only revenues, and not even as the total 

revenue for each alternative but only as an abstract “per MBF” figure. It 

omits any mention of the Forest Service’s expenditures resulting from 

each alternative, including the costs of sale administration, sale 

preparation, and road design and engineering that the Forest Service 

Handbook requires. These expenditures appear only in a document in 

the planning record called the Timber Economics Draft Resource Report, 

which contains calculations of both total revenue and total Forest Service 

costs for each alternative. From the Timber Economics Draft Resource 
BAppendix

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Report, it is possible to replicate the type of net value calculation 

disclosed in the Big Thorne FEIS. The results show that by the Forest 

Service’s own estimate the proposed alternative’s cost to taxpayers, net 

of revenues, is $6.5 million (indicated advertised value of -$3.3 million 

minus $3.2 million total project costs), plus undisclosed NEPA costs. 

Also by the Forest Service’s estimate, NEPA costs of $48/MBF would 

amount to an additional $3.1 million (65,000 MBF multiplied by 

$48/MBF), for a total of $9.6 million in costs to taxpayers for the Wrangell 

Island Project. None of those estimates of net value are disclosed in the 

DEIS; not even to the extent they were disclosed in the Big Thorne FEIS. 

As a result, the DEIS presents a highly one-sided, misleading picture of 

the alternatives’ economic efficiency.

In truth, even total taxpayer costs of $13.1 million (Big Thorne) and $9.6 

million (Wrangell Island Project) are likely gross underestimates for these 

sales. They are derived from a Forest Service calculation done by 

Robert Vermillion in December 2012 that the cost of preparing timber on 

the Tongass is $104/MBF including NEPA costs. The Forest Service has

never disclosed the data underlying the Vermillion calculation. Nor does 

the record here explain why the four-year-old estimate is still relevant or 

reliable. Even for 2012, it is not at all clear that the Vermillion calculation 

incorporates all of the costs that FSH 2409.18_32.22 explicitly instructs 

the Forest Service to include. There is no indication that the Vermillion 

calculation includes costs of brush disposal, road maintenance, 

reforestation, or regenerated stand management, such as silvicultural 

exams, stand improvement, and timber and transportation planning. 

Aside from the opaque Vermillion calculation, the only available evidence 

in these administrative records suggests that the actual cost of Tongass 

timber sales is at least ten times that high. The actual cost of the timber 

sale program has been derived from publicly available Forest Service 

financial documents by Joe Mehrkens, the former Regional Economist 

for the Alaska Region of the Forest Service. Mehkens has determined 

that, during fiscal years 2010 through 2012 (the same time period used 

by the Forest Service for its calculation), the Forest Service spent from 

$34.2 million to $47.7 million annually on the timber sale program, with 

an average expenditure of $42.5 million per year. See Table 1. During 

the same period of time, an average of 29,600 MBF was cut annually 

from the Tongass, resulting in an average cost of $1,435/MBF to 

produce timber. See id. 
Appendix B

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Thus, the actual cost of producing timber appears to be more than 13 

times higher than the $104 asserted by the Forest Service for the same 

three fiscal years. 

In short, while the Forest Service fails to disclose any of its costs in a 

Financial Efficiency Analysis in the DEIS, and fails to disclose the data 

underlying the cost estimates in the planning record, Mehrkens has 

provided a detailed, fully supported accounting, upheld in court as a 

reliable source. To respond only that Mehrkens was over-inclusive in 

estimating the costs of the timber program would be inadequate so long 

as the Forest Service refuses to disclose the data underlying its own cost 

estimate—the Vermillion calculation—and fails to explain why the total 

timber sale program costs are so much higher than implied by the 

Vermillion calculation. 

The Forest Service itself has said “[f]inancial efficiency . . . [is] one tool 

decision-makers can use to gain information about resources, 

alternatives, and trade-offs between costs and benefits.” The agency 

must conduct this analysis for the Wrangell Island Project to comply with 

NFMA and must disclose it in the FEIS to comply with NEPA. The 
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economic analysis associated with the Wrangell Island Project is 

fundamental to the Forest Supervisor’s decision. The entire purpose and 

need for the project is economic: The timber sale is justified solely on 

the ground that it will ostensibly produce economic opportunity for 

Southeast Alaska residents. Thus, the public costs are critical to the 

agency’s analysis. The underlying policy question is whether the jobs 

created by the project are worth both the high cost to taxpayers and the 

extreme ecosystem risks the project poses. Failing to provide accurate 

information on costs and benefits skews this analysis. Additionally, the 

Forest Service’s NFMA obligations require the agency to consider these 

costs and benefits in deciding whether and how to proceed with this 

project given the adverse impacts to old-growth ecosystems, wildlife, 

fisheries, subsistence, and forest-dependent industries, such as fishing, 

tourism, and recreation. 

058-SEACC13II. THE DEIS FAILS TO ACCOUNT FOR HIGHGRADING THE 

MOST VALUABLE AND LARGEST TREES.

One possible, if not likely, outcome of the dire economic reality of the 

Wrangell Island Project is that the Forest Service will offer timber sales 

that highgrade the available volume to meet requirements for positive 

economic appraisals. The DEIS fails to address this damaging practice. 

High grading refers to the practice of logging only those trees that will 

give the highest immediate economic return, resulting in a decline in 

long-term forest health and productivity. Experts have explained:

It can also occur at a larger spatial scale, in which the most productive 

stands of trees are clear-cut, and nearby stands of low productivity are 

retained, or conserved. While high-grading maximizes profit, the 

selective removal of certain forest types threatens ecological functioning 

over large areas (Albert and Schoen 2007, Albert and Schoen in review, 

Lertzman and McKinnon in press, DellaSala et al. 2011b). The effects of 

high-grading are especially severe for wildlife species with specialized 

habitat requirements associated with these preferred stand types, or 

those that rely on the mix of different forest types, including highly 

productive stands, to meet their annual life history requirements (e.g., 

Schoen et al. 1988, Schoen and Kirchhoff 1990).

For example, Sitka black-tailed deer rely on the “rare large-tree stands 

during severe winters to escape deep snow,” and “heavy mortality could 

be expected” if those stands are logged. Similarly, “[t]he crevices in the 

bark of especially large (>100 cm diameter) old trees provide[] important 

habitat for arthropods, making large-tree old growth important habitat for 

The Wrangell Island Project does not include “highgrading”. 

The single-tree selection (STS) method for uneven-aged 

prescriptions will economically harvest a portion of the stand 

while retaining at least 67 percent of the stand’s basal area to 

maintain the visual quality. This level of retention will meet 

scenery objectives to be undetectable to casual observers. This 

will also result in retained wildlife habitat structure and 

elevational corridors. The stand retention will consist of trees that 

contribute to scenic integrity, trees with high wildlife habitat 

value, or trees that have future timber value. This is not a 

prescription for high grading, as the residual stand composition 

will include a mix of species and trees in good condition. New 

trees will regenerate in harvest openings perpetuating multiple 

age and size classes, promoting species diversity, productivity 

and forest health. Most trees will be harvested singly scattered 

across the stand. Harvest openings will be small, less than two 

acres in size. The resulting stand will maintain and promote 

variable densities of trees of different ages and crown classes, 

inter-mixed with large, older trees, intermediate trees and young 

trees.

Please see the Silviculture section of chapter 3 of the EIS and 

the Silviculture Resource Report, which describes the 

silvicultural prescriptions and effects to forest health and 

productivity. The effects of timber harvest on wildlife are 

presented in the wildlife section. 
Appendix B

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Comment 

Number Comment Response

birds like Brown Creeper (Certhia americana) (Kissling 2008, USFWS 

2010).”

Despite these concerns, the DEIS fails to even mention the concept. 

Removing the most valuable trees and leaving areas with poor quality 

trees results in differential impacts that the agency has not address. The 

FEIS must address the adverse impacts associated with highgrading, 

especially given the dire economic reality of the Wrangell Island Project.

Please see responses to comments 061-GSACC-26 and 044-

TNC-02.

058-SEACC14III. THE DEIS FAILS TO ADDRESS THE IMPLICATIONS OF THE 

EXPORT POLICY.

Since 2007, the Regional Forester has annually re-adopted a Limited 

Export Policy, allowing 50 percent of spruce and hemlock sawlog volume 

to be shipped out of Southeast Alaska as round logs with no local 

processing. The Forest Service’s decision to adopt this policy has direct 

environment effects because it increases the volume of logging on the 

Tongass, thereby increasing adverse environmental impacts, while 

decreasing the number of jobs created per unit of timber cut. The Limited 

Export Policy has, however, never been subject to NEPA review or 

public notice, review and comment pursuant to the Administrative 

Procedure Act (APA). 

In March 2016, groups wrote Regional Forester Beth Pendleton to ask 

that the Forest Service prepare an environmental impact statement (EIS) 

and provide public notice and opportunity for comment before adopting a 

Tongass Limited Export Policy for 2016 or beyond. Since then, the 

agency released the DEIS for the Wrangell Island Project, which 

references the “Current Export Policy,” but it does not appear the Forest 

Service has adopted any export policy for 2016. The annual review for 

2015 is included in the planning record. 

As explained below, the DEIS fails to disclose and analyze the Limited 

Export Policy’s significant environmental and economic impacts in 

application to the Wrangell Island Project. If the agency has adopted the 

Limited Export Policy and plans to apply it to this project, then the FEIS 

must correct these deficiencies. The agency’s decision to adopt the 

Limited Export Policy and apply it to the Wrangell Island Project also 

raises serious concerns under NFMA and the other statutes under which 

the Forest Service operates when it approves a timber sale project, as 

the decision directly influences the agency’s ability to balance competing 

objectives in favor of large-scale old-growth logging. These statutes 

Comments on the regional export policy itself are outside the 

scope of this project analysis. 

The economic impacts for the Wrangell Island Project were 

analyzed for all action alternatives with the financial efficiency 

tool (FAST-R) to provide an estimate of total jobs, direct income, 

and indicated advertised values for both 100 percent domestic 

processing and under the current export policy scenario. These 

are in Wrangell Island Project EIS, chapter 2, the Timber 

Economics Resource Report and the individual FAST-R runs in 

the project record. 

The other environmental effects from the proposed harvest 

under each alternative are presented in chapter 3 and do not 

vary between the two export scenarios.

The export policy on the Tongass is explained in the 2016 Forest 

Plan Amendment FEIS, appendix H, pages H-1 through H-5 and 

in the responses to comments of the same document. The 

language that restricts timber offered to positively appraised 

sales has been included annually in various Appropriations Bills 

with the exception of 2009. 

Application of the export policy is not an alternative in and of 

itself, rather the results are displayed with and without export to 

illustrate its impact.

The goal of the Limited Export Policy was to help make the sales 

appraise positively by allowing them to sell to an available 

market for lower grade material and therefore they could be 

offered to the timber industry for bid. However, the policy is not 
BAppendix

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require the Forest Service to balance multiple competing interests when 

managing the national forests.

Additionally, for the reasons described below, we continue to urge the 

Forest Service to discontinue the Limited Export Policy. If the Forest 

Service does adopt the policy, then it must comply with NEPA, the APA, 

and its NFMA obligations.

A. The DEIS Fails to Address the Impacts of, and the Reasonable 

Alternatives to, the Limited Export Policy With Regard to the Wrangell 

Island Project.

Applicable law restricted the export of unprocessed timber cut on the 

Tongass, and simultaneously limited the advertisement of timber sales to 

those that would appraise positively. Under Federal statute, timber cut 

from National Forest land “may be exported from the State or Territory 

where grown if, in the judgment of the Secretary of the department 

administering the national forests, or the public lands in Alaska, the 

supply of timber for local use will not be endangered thereby.” The 

statute authorizes agencies to promulgate regulations to this effect. 

Under Forest Service regulations, “[u]nprocessed timber from National 

Forest System lands in Alaska may not be exported from the United 

States or shipped to other States without prior approval of the Regional 

Forester.” The rationale for this regulation is that a restriction on extraAlaskan export is necessary to provide a volume of timber to sustain 

“adequate wood processing capacity in Alaska” such that timber from the 

National Forests in Alaska can be sustained. In 2003, Congress passed 

a Consolidated Appropriations Resolution providing in relevant part that 

“[n]o timber sale in Region 10 shall be advertised if the indicated rate is 

deficit when appraised using a residual value approach.” This provision 

has remained in Congress’s subsequent appropriations legislation.

In March 2007, in response to the falling number of Tongass timber 

sales, Regional Forester Dennis Bschor partially authorized the export of 

unprocessed Tongass logs through the Limited Export Policy. 

Specifically, the Regional Forester authorized export of 50 per cent of 

Sitka spruce and western hemlock sawlogs under 15-inches in diameter 

at the small end of a 40-foot log and grade 3 or 4 logs of any diameter. In 

so authorizing, the Regional Forester incorporated the findings of Randy 

Coleman, Group Leader of Policy Analysis and Economics, and Dan 

Castillo, Director of Forest Management, that “Forest Service appraisals 

of proposed Tongass timber sales would rise if they assumed that a 

designed to enforce the purchaser to export the maximum 

volume available. Purchasers have elected to do less exporting 

instead of the maximum allowed and more domestic processing 

for certain contracts depending on their markets, quality of wood 

and/or mixture of species.

Please see response to comment 050-ADNR-04 and appendix A 

of the EIS.

The Forest Service has recognized that distinct circumstances 

exist in Alaska such that limited export allowance of forest 

products from the Tongass works to maintain local industry. 

Accordingly, the Forest Service allows, but appropriately limits, 

the export of unprocessed timber from National Forests in Alaska 

under the general authority of the Organic Administration Act of 

June 4, 1897, NFMA, and 36 CFR § 223.201. The regulation at 

36 CFR § 223.201 was appropriately noticed, commented upon, 

and adopted in 1974, and gave the Regional Forester sole 

responsibility and authority to approve shipment of unprocessed 

timber from NFS lands in Alaska via export from the United 

States or shipment to other states, provided certain specific 

considerations were met. The establishment of the limited export 

policy in 2007, updated in 2009, enables the Forest Service to 

appraise timber sales for export for the purpose of offering 

enough positive-value timber sale volume to enable the 

struggling forest products industry to remain possible. The export 

policy is more fully explained in the 2016 Forest Plan 

Amendment FEIS, appendix H.

The export policy was developed to allow purchasers more 

opportunities for the use of the lower grade material. This did 

indirectly encourage the purchase of National Forest timber by 

providing more sale opportunities which may have resulted in 

more harvest than without the sales offered and awarded. 

Although sawmilling jobs may decrease with export, other jobs in 

the export industry such as stevedoring have been supported. 

Plus the policy promotes sawmills to stay in business to 

manufacture the higher value material and employ local workers. 

Timber currently has been offered and sold that, without the 

export policy to help attain a positive appraisal, could not have 
Appendix B

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Comment 

Number Comment Response

portion of the unprocessed spruce and hemlock logs were shipped to 

lower 48 markets.” 

The Limited Export Policy is reviewed annually by the Regional Forester 

and has evolved over time. In each year since 2007, citing conditions in 

the domestic timber market, as well as the transitional status of Alaskan 

timber processors, the Regional Forester has reviewed and approved a 

continuation of the Limited Export Policy. 

The DEIS fails to explain whether the Forest Service has adopted the 

Limited Export Policy for 2016, but it suggests the “Current Region 10 

Export Policy” has a significant, if not the most important, impact on the 

likelihood that various alternatives could be sold and, therefore, on the 

environmental impacts of the Wrangell Island Project. As explained 

above, the DEIS provides the differences between the “Current Region 

10 Export Policy” and “Domestic Processing” for the “Indicated 

Advertised Rate.” Although all of the action alternatives appraise 

negatively, the Current Region 10 Export Policy results in anticipated 

bids that are significantly less negative than their domestic counterparts, 

thereby increasing the likelihood that they would be pursued. It also has 

a direct effect on the amount and location of logging that is likely to 

place, which would result in varying environmental impacts and 

economic impacts for Southeast Alaska. As a result, the FEIS must 

disclose and evaluate those impacts. 

The DEIS also errs in failing to consider alternatives in which the Limited 

Export Policy is not adopted and/or applied to the Wrangell Island 

Project. Variations on the Limited Export Policy are not even included 

among the “Alternatives Considered But Eliminated From Detailed 

Review.” The DEIS offers no explanation why the agency did not 

consider these variations and the resulting differential environmental 

impacts. The failure to consider such alternatives violates NEPA. 

been sold and no jobs, sawmilling or otherwise, would have been 

supported.

The export policy results in more positive appraisals by allowing 

the lower grade western hemlock and Sitka spruce material to be 

exported. That is one of the goals of the export policy – to allow 

for positive sales. In the past this material was utilized in the pulp 

mills and currently there is not a large market for it in Southeast 

Alaska. This is exactly the purpose of the export policy; to 

sustain the timber industry in Southeast Alaska by allowing them 

to utilize an existing market. This could change in the future with 

an increase in biomass energy or as facilities are able to utilize 

and develop other markets for smaller logs. 

The history of export on the Tongass is explained in the 2016 

Forest Plan Amendment FEIS, appendix H, pages H-1 through 

H-5. The language that restricts timber offered to positively 

appraised sales has been annually included in various 

Appropriations Bills with the exception of 2009. 

Please see response to comment 050-ADNR-04.

By excluding variations on the Limited Export Policy, the DEIS excludes 

reasonable alternatives that fall within the project’s “purpose and need,” 

in violation of NEPA. The DEIS describes the Wrangell Island Project as 

having five purposes: to provide for the continuation of timber resources 

by the timber industry and Alaska residents, to manage timber resources 

for saw timber “in an economically efficient manner[,]” to seek to provide 

an economic timber supply to meet annual market demand and the 

market demand for the planning cycle, to provide 2 to 3 years of volume 

under contract to local mills and then establish shelf volume, and to 

The EIS presents reasonable alternatives (chapter 2) to meet the 

purpose and need of the project (chapter 1).
BAppendix

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review the timber sale program and implement changes that keep an 

“economic timber” perspective throughout the process. Yet, the DEIS 

fails to explain why domestic alternatives with smaller volumes could not 

fulfill these purposes. 

Comparing alternatives that do and do not apply the Limited Export 

Policy to Wrangell Island Project would highlight important tradeoffs in 

impacts that are currently obscured by the agency’s analysis in the 

DEIS. Allowing more export increases the likelihood that timber is sold 

from the Wrangell Island Project and the volume of timber sold, which 

both have corresponding adverse environmental effects and high 

financial costs to the public of a timber sale program that results in a loss 

to the treasury. Reasonable alternatives would address a range of 

possibilities. At one end, with no export, there would be less logging but 

more jobs per unit of timber logged and greater protection of wildlife, 

biological diversity, carbon stores, carbon sequestration, the public fisc, 

subsistence uses, and the recreation, tourism, and fishing sectors of the 

economy. At the other end is the “Current Region 10 Export Policy,” 

which, if it is similar to its predecessors, emphasizes timber production 

with relatively few jobs and relatively high adverse impacts and costs on 

all other values. Intermediate options could also be considered. The 

agency must analyze these alternatives in the FEIS; to do otherwise 

would violate NEPA. It would also violate NFMA and the other statutes 

under which the Forest Service operates when it approves a timber sale 

given the inherent tradeoffs and balancing the agency must make in 

deciding how to pursue competing objectives. 

058-SEACC15B. The Forest Service’s Decision to Adopt the Limited Export 

Policy is Itself a Major Federal Action Requiring NEPA Review and APA 

Public Notice and Comment.

As groups made clear in the March 2016 letter and their comments on 

the DEIS for the Tongass Land Management Plan Amendment, the 

Regional Forester’s implementation of the Region 10 Export Policy is a 

major federal action, because it entailed the “[a]doption of formal plans . . 

. upon which future agency actions will be based.” By the agency’s own 

description, the adoption of the Limited Export Policy and its continued 

application via annual reviews are a “major development.” The Forest 

Service expects the Limited Export Policy “to boost appraised timber 

values,” and, by its own account, but for this change in policy, far fewer 

timber sales “would appraise as positive.” A major increase in the 

number of sales appraising as positive—leading ultimately to more 

logging—was the Policy’s raison d’etre. As the adoption of a formal 

Comments on whether the export policy itself required NEPA 

review are outside the scope of this project analysis since the 

Regional Forester has already been given sole responsibility and 

authority to determine the export policy under 36 CFR 223.201.

The comment misrepresents the intent of the policy. No more 

logging would occur than that already analyzed under NEPA. 

Other benefits realized by the policy have involved maintaining 

support for logging and transportation jobs and increasing 

support for jobs involved in export – stevedoring, sort yard 

workers, extra personnel involved with transportation.
Appendix B

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policy on which agency action would occur, the Limited Export Policy is a 

major federal action.

058-SEACC16It is unclear whether the Forest Service has adopted a Limited Export 

Policy that is currently applicable and, if it has, what it provides. The 

application of that policy to the Wrangell Island Project requires analysis 

of the resulting adverse impacts in the FEIS. The agency must provide a 

“full and fair discussion of significant environmental impacts” of the 

decision to allow exports in the FEIS, including but not limited to 

resultant increases in logging and the impacts on ecosystems that will 

follow from the resultant logging. The FEIS must include alternatives that 

do not involve continuation of the Limited Export Policy to reflect the 

requisite NEPA analysis. Additionally, as a major federal action, the 

Regional Forester’s adoption of the Limited Export Policy requires NEPA 

analysis. Additionally, the agency’s decision both to adopt a Limited 

Export Policy and to apply it to the Wrangell Island Project raises 

significant concerns under NFMA and the other statutes under which the 

Forest Service operates, because allowing exports dramatically affects 

the size and likelihood of any logging effort and, as a result, the agency’s 

balancing of timber objectives with other forest values such as wildlife, 

recreation, and subsistence. 

Any timber sales from the Wrangell Island Project would comply 

with the export policy in place at the time of the sale 

advertisement. The current export policy is described in a letter 

from the Regional Forester, dated 4/21/2015, which maintained 

the previous policy with no changes. Individual sales are 

reviewed for export prior to being offered. 

At any time, the Regional Forester can decided to modify the 

policy, to advertise a sale that does not include the policy or 

allow more volume to be exported based on the current 

circumstances at the time the timber harvest contract is 

completed for offer. 

Table 12 of the Timber Economics Resource Report shows 

estimated jobs and values of both scenarios of 100 percent 

domestic processing and using the R10 limited export policy. If 

the amount of export is changed, further analysis may be 

conducted.

See response to comment 058-SEACC-14

058-SEACC17SUBSISTENCE

Of all the terrestrial species in Southeast Alaska, deer support the 

highest hunting and subsistence use. The DEIS acknowledges that 

“[t]here are no reliable population estimates for deer populations in 

[Game Management Unit] 3, which includes Wrangell Island.” It also 

explains that “[d]eer populations on most islands in [Game Management 

Unit] 3 have declined since 2004 and are thought to be well-below 

carrying capacity.” Despite these concerns, the DEIS blandly concludes 

that “deer would continue to persist at current levels” after the Wrangell 

Island Project.

Yet, in describing the impacts on subsistence resources, the DEIS states 

that: “It is assumed that a deer population at carrying capacity should be 

able to support a sustainable hunter harvest (demand) of approximately 

10 percent of the habitat capability while also providing a reasonably 

high level of hunter success in the WAA (USDA Forest Service 1997a, p. 

3-674).” Given that the DEIS acknowledges that this population is well 

The Wrangell Island Project analysis complies with ANILCA and 

followed the process to determine the alternative’s effects on 

subsistence use. Because the project could have an effect on 

subsistence resources, public subsistence hearings were held. 

The subsistence analysis is documented in the Subsistence 

section of chapter 3 of the EIS, and in the Subsistence and 

Wildlife Resource Reports.

Please see response to comment 061-SEACC-35 and -36.
BAppendix

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below carrying capacity, it must analyze the consequences on 

subsistence hunter harvest given that reality.

The Forest Service recognizes that the “possibility of a restriction may 

already exist for deer in the long-term, and for all the alternatives.” The 

DEIS also identifies the residents of Wrangell and Thom’s Place as 

those facing the most significant changes to their subsistence resources. 

With regard to residents of Wrangell, the DEIS explains:

ADF&G reports that in WAA 1903 (Wrangell Island), from 1996 to 2013, 

an average of 69 deer were harvested with the lowest number harvested 

in 2002 (29 deer) and highest in 2006 (105 deer). The proposed project 

area is located within WAA 1903, which accounted for approximately 10 

percent of the annual harvest of deer for Wrangell residents between 

1996 and 2001.

Given the fact that deer populations are in continuing decline, the 

population is already below carrying capacity, and the deer habitat 

capability is already below the 18 deer per square mile generally 

considered necessary to support a sustainable relationship between 

wolves, deer, and human deer hunters, the FEIS must be more 

forthcoming about the realistic consequences on subsistence deer 

hunting. 

058-SEACC18CLIMATE CHANGE, CARBON STORAGE & SOCIAL COST OF 

CARBON

In the DEIS, the Forest Service’s consideration of climate-change related 

environmental impacts are inadequate on several grounds. First, the 

DEIS fails to situate analysis of the alternatives within the context of the 

U.S. Government’s overall commitment to prioritizing forest protection as 

a tool for mitigating global climate change. Second, in its assessment of 

climate change impacts associated with each alternative, the DEIS 

inexplicably excludes carbon releases that follow indirectly from the 

harvest of forest stands, restricting its analysis to the immediate fossilfuel combustion emissions associated with construction and harvesting. 

Third, the DEIS attempts to evaluate the carbon impacts of alternatives 

quantitatively by comparing project-related emissions to the total size of 

forest stores—a comparison in itself misguided, but here rendered 

nonsensical by the Forest Service’s refusal to estimate net emissions 

associated with each alternative. Fourth, the DEIS fails to account for 

changes in rates of sequestration and carbon storage that will result from 

climate change, even while it acknowledges that such changes can be 

The Wrangell Island Project climate change analysis tiers to the 

2016 Forest Plan Amendment FEIS climate change analysis 

(USDA Forest Service 2016d, p. 3-11) with available projectlevel analysis of the effects on climate change in chapter 3 of the 

EIS. 

The Council on Environmental Quality (CEQ) issued final 

guidance (August 1, 2016) to assist Federal agencies in their 

consideration of the effects of greenhouse gas emissions and 

climate change when evaluating proposed Federal actions in 

accordance with NEPA and the CEQ Regulations Implementing 

the Procedural Provisions of NEPA (CEQ Regulations), however,

this guidance was rescinded by EO 13783 on March 28, 2017.

The climate change section in the FEIS has been updated to 

include additional discussion related to changes in rates of 

carbon sequestration and storage resulting from the Wrangell 

Island project.
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expected. Finally, the DEIS fails to define the timescale over which it is 

analyzing climate-change related impacts.

I. THE FOREST SERVICE FAILS TO CONTEXTUALIZE ITS 

DECISION AS AN INSTANTIATION OF THE U.S. GOVERNMENT’S 

INTERNATIONAL COMMITMENT TO MITIGATE GLOBAL CLIMATE 

CHANGE.

The Federal Government in general and the Forest Service in particular 

are keenly aware of the climate-change effects of logging old-growth 

stands in the Tongass. As the DEIS states, “[f]orest ecosystems 

represent the largest terrestrial carbon sink on Earth.” In the United 

States, “public forests . . . represent approximately 20 percent of the U.S. 

timberland area.” Forests sequester carbon as their trees grow, and 

they store this carbon within live trees and within soils. Specifically, the 

Administration has highlighted the importance of “[c]onservation and 

sustainable management . . . to ensure our forests continue to remove 

carbon from the atmosphere while also improving soil and water quality, 

reducing wildfire risk, and otherwise managing forests to be more 

resilient in the face of climate change.” In general, rainforests are 

crucially important to the carbon cycle, but among global rainforests, 

northern temperate rainforests play a predominant role in rainforest 

carbon sequestration: “Because the tropical gross deforestation 

emission is mostly compensated by the [carbon] uptakes in both tropical 

intact and regrowth forests, the net global forest [carbon] sink [of roughly 

1.1 billion metric tons of carbon per year] resides mainly in the temperate 

and boreal forests.” Northern coastal temperate rainforest biomes are 

“disproportionately important in regional carbon cycling.” Forests of the 

Pacific Northwest and Southeast Alaska store “exceptional levels” of 

carbon, and “are among the most [carbon] dense ecosystems in the 

world. Moreover, “[t]he national forests of the Pacific Northwest Region . 

. . have a higher proportion of forests in old age classes (>100 years) 

than other ownerships,” and “Southeast Alaska . . . boasts nearly a third 

of the world’s old-growth temperate rainforest.” For these reasons, in 

other contexts the Federal Government has recognized forest policy’s 

importance in its leadership role in global efforts to mitigate climate 

change. 

The DEIS correctly points out that the Tongass is important to the U.S. 

Government’s policies addressing the detrimental effects of 

anthropogenic climate change. In fact, the Tongass is America’s most 

important carbon forest. It is the largest single forest-carbon sink in the 

The analysis does not present a quantitative analysis of carbon 

emissions at the alternative level because we currently lack 

accurate tools, methods, and appropriate data for all elements of 

carbon flux as a consequence of the proposed project-level 

activities. Instead, we provide a qualitative analysis of carbon 

emissions over time by alternative. For example, there is 

considerable uncertainty with respect to post-harvest carbon 

releases over time. The estimation of carbon release over time at 

the alternative level would be a questionable practice with high 

levels of uncertainty. We acknowledge that carbon sequestration 

rates are likely to change over time as a result of climate change, 

however such changes are not understood well enough at this 

point to provide meaningful project-level quantitative analysis.

Additional discussion and citations regarding the differential 

ability of forested land to sequester carbon dioxide and store 

carbon as well as a more explicit discussion about carbon loss 

and relevant timescale can be found in chapter 3 of the 2016 

Forest Plan. In summary, harvesting old growth creates a net 

release of CO2 into the atmosphere – particularly in short- and 

mid-term. There is uncertainty regarding long-term CO2 release 

of harvested stands particularly because of the importance of 

how the wood is used (durable or nondurable products), the 

regrowth of young forests, and market dynamics related to 

substitution. The revised chapter 3 also more clearly discloses 

uncertainty of GHGs contributions in the short- and long-term 

that result from timber harvest. Given the level of uncertainty in 

parameters related to the net contribution of GHGs, an attempt 

to quantify the evaluation would not provide clarity but instead 

result in a false sense of certainty. The qualitative analysis 

provides the necessary level of information to evaluate the 

relative differences in carbon losses and gains for each 

alternative, thus providing the information for the deciding official 

on the relative contribution of GHGs from the proposed actions 

(USDA Forest Service 2009).

Alternative 1 addresses the commenter’s request for no harvest.
BAppendix

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United States storing over a billion tons of carbon. The DEIS estimates 

that the Tongass stores around 1.2 billion tons of carbon. However, 

documents in the record suggests that the DEIS’s estimate 

underestimates the Tongass’s carbon storage by 1.6 billion tons. 

According to one study, “[t]he Tongass National Forest stores 

substantially more forest carbon than any other national forest in the 

United States.” The Tongass annually removes about 2,787 pounds of 

atmospheric CO2 per acre per year through growth and recruitment. A 

2005 study found that aboveground carbon constitutes around 30 

percent of total carbon stored in the Tongass, with a conservative 

estimate that 66 per cent of the total was found in soils and 4 per cent in 

roots, a distribution consistent with carbon inventories in other 

ecosystems. The Tongass, and specifically its old growth stands should 

take a specially protected place within the Federal Government’s efforts 

to address climate change.

The DEIS contemplates alternatives that would destroy old-growth forest 

in the Tongass, but fails contextualize decisions within a policy context in 

which action alternatives would contradict the commitments that the U.S. 

Government has made to forest protection on the international stage. In 

the FEIS, the Forest Service should evaluate alternatives in light of the 

Tongass’s relative global importance as a forest carbon sink and store. It 

must discuss how action alternatives would release carbon stores within 

some of the Earth’s most carbon-concentrating forest stands. The FEIS 

must also consider and discuss how the logging proposed in this project 

and its anticipated climate effects fails to match the U.S. Government’s 

commitment to climate-change mitigation, a commitment that it has 

which it has repeatedly voiced, most recently in the Paris Agreement 

under the United Nations Framework Convention on Climate Change. If 

there were a keystone forest that signals the commitment of the United 

States to climate action, the Tongass is that forest. The FEIS must 

grapple with the strong negative signal action like this would have on the 

United States’s role as a global climate leader. Without this context the 

true impact of the alternatives cannot be evaluated.

058-SEACC19II. THE DEIS IGNORES NON-COMBUSTION RELATED 

EMISSIONS OF GREEN-HOUSE GASES.

It is widely recognized, including by the DEIS itself, that foreclosed 

carbon sequestration and release of forest carbon stores are reasonably 

foreseeable impacts when an old-growth forest is logged. A forest 

sequesters carbon as its trees grow, including for centuries after they 

have become old-growth. Studies have found that primary forest in the 

Please refer to response to comment 058-SEACC-18.

Although an estimate of carbon emissions can be calculated, the 

uncertainty in any estimate must be disclosed and the relative 

merit in considering that estimate evaluated based on the degree 

of uncertainty. As described earlier, the estimation of carbon 

emissions, particularly over the mid- and long-term, is 
Appendix B

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boreal and temperate regions of the northern hemisphere “alone 

sequester about 1.3 +/- 0.5 gigatonnes of carbon per year.” Pacific 

Northwestern forests were found to increase in biomass even at 300 and 

600 years of age. These results demonstrate that, although a tree’s rate 

of carbon absorption might decline beyond 80 years of age, “old-growth 

forests can continue to accumulate carbon.” Old-growth stores entail not 

only carbon stored in the larger mass of trees, but also carbon in forest 

soils, which “will move back to the atmosphere if these forests are 

disturbed.” As a whole, old-growth forests store far more carbon than 

young forests.

Logging’s impact to a forest’s carbon flux involves sequestration 

opportunity costs (that is, foregone carbon sequestration that would have 

occurred but for logging), as well as heightened release of CO2 via 

decomposition of materials that had been under the forest floor (and 

would have remained there but for logging). Logging an old-growth forest 

thus results in a net carbon release; this is true notwithstanding the 

effects of limited carbon storage in wood products and growth of young 

forest in its place. As a result of disturbing old-growth forest, forest 

carbon storage is reduced “for at least 250 years.” Although young 

forests grow relatively quickly, “the creation of new forests (whether 

naturally or by humans) frequently follows disturbance to soil and the 

previous vegetation, resulting in a decomposition rate of coarse woody 

debris, litter, and soil organic matter (measured as heterotrophic 

respiration) that exceeds the [net primary productivity] of the regrowth.” 

In other words, when old-growth forest is logged and replaced by young 

forest, the young trees’ capture of CO2 in aboveground carbon stores is 

offset by the more rapid and voluminous release of carbon associated 

with decomposition above and below ground. The Forest Service 

recognizes in documents in the record that “the Tongass National Forest 

would generate a net loss of carbon to the atmosphere if active harvest 

of old growth is pursued (i.e., harvesting old growth would reduce the 

carbon sequestering ability of forests).” It also recognizes that a full 

analysis of the greenhouse gas emissions, and specifically CO2 

emissions, associated with the alternatives must account not only for 

“carbon that is released to the system due to the burning of fossil fuels 

(gas) by harvesting equipment,” but also for releases from numerous 

other sources, including:

. . . the initial increased rate of carbon release resulting from the 

increased temperatures of soils and water (due to increase solar 

accompanied by high levels of uncertainty and that uncertainty 

far exceeds the potential differences in carbon storage among 

the five alternatives. Therefore, we have not provided a rigorous 

evaluation of the differences among alternatives in the social 

costs that may result from carbon emissions and resulting shortmedium- or long-term contributions to GHGs. Given the high 

uncertainty in carbon emissions, and particularly the relatively

small differences among alternatives in carbon emissions, an 

evaluation of social costs would be highly speculative.
BAppendix

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radiation reaching the newly cleared areas), the ultimate use of the 

harvested materials (e.g., biomass fuels, pulp, paper, or lumber), the rate 

of natural decay and carbon release in the system, the rate of tree 

growth following harvesting, the age of the trees harvested, and the 

length of time until the next harvest rotation (likely to be about 100 years 

or more).

Notwithstanding the scientific consensus and the Forest Service’s own 

recognition that carbon flux associated with the project includes 

sequestration opportunity costs and post-harvest releases of forest 

carbon stores, the DEIS’s discussion of greenhouse gas emission 

inexplicably restricts its analysis to emissions from fossil-fuel combustion 

associated with construction and harvesting activities. In discussing 

“greenhouse gases” the DEIS limits its focus to “GHGs directly emitted 

by humans.” It states: “[t]he primary sources of GHG emissions in the 

Wrangell Island Project area are from transportation emissions (from 

seaplane flights, ferry/cruise ship activity, and vehicle travel) and 

emissions from fuel combustion associated with the community of 

Wrangell.” In discussing “[e]ffects common to all action alternatives,” the 

DEIS focuses exclusively on emissions from “road construction activities, 

timber harvest operations, and administration of all operations by use of 

service vehicles throughout the life of the project,” all of which involve the 

combustion of fossil fuels. Under these restricted considerations, the 

DEIS concludes that “it is uncertain whether the rate of carbon 

sequestration would be higher or lower under no action compared with 

the action alternatives.”

By restricting its analysis to fossil-fuel combustion emissions, the DEIS 

fails to account for each action alternative’s reasonably foreseeable 

impact of foreclosed carbon sequestration and releases of carbon stores 

released when old-growth stands are logged. In the FEIS, the Forest 

Service must reconsider the carbon flux rate associated with each of the 

alternative, taking into account the carbon sequestration foregone by 

destroying old-growth stands, as well as the releases of stored carbon 

after such harvests.

058-SEACC20III. THE DEIS’S QUANTITIATIVE ASSESSMENT OF 

ALTERNATIVES’ CLIMATE-CHANGE IMPACTS IS BOTH 

INCOMPLETE AND MISGUIDED.

In the context of evaluating impacts associated with climate-change, the 

Council on Environmental Quality (CEQ) has cautioned against agencies 

using comparisons of emissions from a government action to global 

carbon flux. According to the CEQ’s Draft Guidance for Greenhouse Gas 

Please refer to response to comments 058-SEACC-18 and -19.
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Emissions and Climate Change Impacts, “these comparisons are not an 

appropriate method for characterizing the potential impacts associated 

with a proposed action . . . [because t]his approach does not reveal 

anything beyond the nature of the climate change challenge itself: the 

fact that diverse individual sources of emissions each make relatively 

small additions to global atmospheric GHG concentrations that 

collectively have huge impact.”

Despite professing its adherence to the very CEQ guidance document 

discussed above, the DEIS’s climate change analysis entails a 

comparison of greenhouse gas emissions expected from each of the 

alternatives with the total carbon stores of global forests. Setting the 

comparing the carbon stock of the Tongass (out of which any project 

effects would draw) against the total stock of the Earth’s forests, the 

DEIS concludes that “[o]verall, the effects of this project on climate 

change and air quality would be negligible”:

Although important on a global scale, it is estimated that the forests of 

the Tongass represent approximately only one-quarter of one percent of 

the stored carbon in forests worldwide (USDA Forest Service 2008b, p. 

3-19). Therefore, it is reasonable to conclude that small, if even 

measurable, changes in carbon sequestration, greenhouse gasses, and 

yellow-cedar decline under any of the action alternatives would not be a 

relevant factor for choosing among alternatives. . . . the task of 

understanding all the factors that influence climate change contains 

substantial uncertainty and for these reasons is not essential to a 

reasoned choice among alternatives.

As stated in CEQ’s guidance, the DEIS’s quantitative evaluation of the 

differences between alternatives is misleading and “does not reveal 

anything beyond the nature of the climate change challenge itself.” 

Making this analysis not only misguided but also incomplete, the DEIS 

purports to make a quantitative comparison, but does so without positing 

any quantities. Notwithstanding its statement in its scoping report that 

“the level of carbon emissions will be disclosed for all action 

alternatives,” in the DEIS the agency “do[es] not attempt to calculate 

quantifiable impact values,” though conceding acknowledges that “the 

magnitude of effects would differ somewhat by alterative.” Documents in 

the record indicate that the Forest Service was capable of estimating the 

stores of carbon in the areas subject to its alternatives and thus the 

carbon flux associated with each alternative. For example, a Draft Soils 

Resource Report in the record estimates a carbon storage rate of 184.4 

As explained in response to comment 058-SEACC-18, there is 

considerable uncertainty with respect to post-harvest carbon 

releases over time as well as forest product carbon retention 

over time. Carbon sequestration rates are also likely to change 

over time as a result of climate change, however such changes 

are not understood well enough to provide meaningful projectlevel quantitative analysis. Therefore, estimation of carbon 

release over time at the alternative level would be a questionable 

practice with high levels of uncertainty.
BAppendix

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tons per acre, with 70 tons per acre in the forest’s soils. At no point in the 

DEIS does the Forest Service estimate the greenhouse gas emissions 

associated with any of the alternatives.

At most, the DEIS characterizes the net climate-change impacts of 

action alternatives as “slight.” However, even this characterization is 

ambiguous, since it does not indicate whether the “slight” impact is in the 

direction of mitigating or exacerbating climate change.

In the FEIS, the Forest Service should quantify estimated carbon 

impacts from each of the alternatives. At the same time the Forest 

Service should quantify and address the social costs of the carbon 

dioxide released into the atmosphere as a result of each alternative. 

Federal agencies including USDA and the Forest Service have, in other 

settings, calculated the social costs of carbon from federal land 

management actions. Once it has estimated net carbon fluxes and 

attendant social costs of carbon associated with each alternative, the 

FEIS should not use these estimates to draw comparisons between the 

discrete climate-change contributions of each alternative and an global 

figure—like the total global forest carbon stores, as in the DEIS—but 

rather should be used to evaluate and compare each of the alternatives 

to each other.

058-SEACC21IV. THE DEIS FAILS TO ACCOUNT FOR CHANGES TO THE 

PROJECT AREA’S RESILIENCE AS A RESULT OF CLIMATE 

CHANGE.

As recognized in the DEIS, the record, as well as in the scientific 

literature, it is reasonably foreseeable that climate change will affect the 

project area’s ability to sequester and store carbon. Southeast Alaska 

has already experienced warming temperatures, and “[p]rojections of 

future changes anticipate even more dramatic effects.” In Alaska, 

“[f]orest ecosystems are expected to undergo various changes as a 

result of climate change.” The warming of average temperatures is likely 

to reduce forests’ abilities to store carbon and regenerate following 

disturbance, relative to their abilities before climate change. “Rising 

temperatures . . . may lead to forests becoming a weaker sink or a net 

carbon source before the end of the century.” In other words, as the 

Forest Service states in the record: “climate change may also affect 

carbon sequestration in Southeast Alaska.” The Forest Service has 

previously concluded that due to the threats of climate change impacts 

upon forests, “the best course of action today is continued management 

of the Tongass for resiliency in the face of uncertain but anticipated 

Climate resilience of the temperate coastal rainforest in 

Southeast Alaska is primarily maintained through the system of 

reserves and other non-development LUDs and therefore the 

broad region of Southeast Alaska would continue to serve a 

strong role as a climate change refugia. Furthermore, there is no 

direct evidence to suggest that that regenerating rainforest on 

the Tongass would be less resilient and therefore, that it will 

have reduced capacity for carbon storage under future climate 

conditions than it displays currently. Please see response to 

comments (appendix I) of the 2016 Forest Plan Amendment. 

In the long term, sustainable forest management strategy aimed 

at maintaining or increasing forest carbon stocks, while 

producing an annual yield of timber, fiber, or energy from the 

forest will generate the largest stained mitigation benefit.” (IPCC 

2007, p 543)
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change . . . . primarily by management of the Tongass as a mostly intact 

ecosystem.”

In the face of these changes, “[p]rimary forests tend to be more resilient 

to climate change and other human-induced environmental changes 

than secondary forests and plantations.” Studies have found that North 

America’s Pacific Coastal Rainforests, especially the Tongass, may be 

particularly resilient to climate change. The forests that action 

alternatives propose to log are those which, relative to other forests 

worldwide, would otherwise be uniquely suited to function as a carbon 

store. Despite recognizing that climate change will have effects upon the 

Tongass and forests worldwide, the DEIS fails to describe how these 

effects bear upon the alternatives’ environmental impacts.

The FEIS should take these studies into account, and, given their 

findings, evaluate how the alternatives’ varying preservation of oldgrowth stands bears on overall forest resilience, and, inter alia, the 

Tongass’s resulting future net carbon flux. The differential ability of oldgrowth forest stands to withstands the effects of climate changes and 

continue to function as a carbon store must be considered, because it 

bears upon, inter alia, the extent to which the Tongass’s carbon flux will 

persist depending on the alternatives’ differing preservations of oldgrowth stands.

058-SEACC22V. THE DEIS’S ANALYSIS OF ALTERNATIVES IS INADEQUATE 

BECAUSE IT FAILS TO DEFINE THE TIMESCALE OVER WHICH 

CLIMATE CHANGE IMPACTS ARE BEING EVALUATED.

The scientific literature explicitly states that the relevant timescale for 

evaluating the effects of climate change is under 100 years. The 

Intergovernmental Panel on Climate Change’s analysis indicates that in 

order to avoid a global average surface temperature increase (relative to 

pre-industrial levels) of 2°C, the atmospheric concentration of CO2 in the 

year 2100 will have to be around 450 ppm. Such a concentration can 

only be achieved, according to the IPCC, if “substantial cuts in 

anthropogenic GHG emissions” occur “by mid-century through largescale changes in energy systems and potentially land use.” With regard 

to the timing of these necessary “large-scale changes,” the IPCC found 

that “[d]elaying mitigation efforts . . . through 2030 is estimated to 

substantially increase the difficulty of the transition to low longer-term 

emissions levels and narrow the range of options consistent with 

maintaining temperature change below 2°C relative to pre-industrial 

levels.” The IPCC’s projections are known to be conservative with 

Please refer to response to comment 058-SEACC-18.
BAppendix

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respect to the estimated pace of global warming, so that it would be 

reasonable to believe that necessary large-scale changes would in fact 

be needed well before 2030 in order for mitigation to succeed. The 

relevant timescale of climate-change mitigation measures is thus the 

next 10 to 15 years.

Though the DEIS purports to evaluate the effects of alternatives on 

climate change, it defines no timescale for its analysis. In the FEIS, the 

Forest Service must correct the DEIS’s mistake of treating timescale as 

an undefined variable. In doing so, the FEIS must consider the timescale 

over which the fossil-fuel combustion emissions that it already considers 

as well as the foreclosed sequestration and carbon stores release that it 

has not (but must in the FEIS) will occur. In so doing it must map the 

timescale of the climate change impacts associated with each 

alternatives onto the timescale relevant to the mitigation of climate 

change, that is, the 10 to 15 year period over which “large-scale 

changes” in land use must occur. In the absence of such a 

understanding of climate effects across the relevant time scale, the 

Forest Service’s analysis is will deficient in evaluating environmental 

impacts.

FISH & WILDLIFE IMPACTS

NFMA requires that the Forest Service provide for the diversity of plants 

and animals, based on the suitability and capability of each National 

Forest, as part of meeting overall multiple-use objectives. The Forest 

Service recognized that the statute “directs the Forest [Service] to 

manage wildlife habitat to maintain viable and well distributed 

populations to ensure continued existence in the planning area.” The 

agency in turn adopted regulations that provide: “Fish and wildlife 

habitat shall be managed to maintain viable populations of existing 

native and desired non-native vertebrate species in the planning area.” 

The agency characterizes a viable population, for planning purposes, “as 

one which has the estimated numbers and distribution of reproductive 

individuals to insure its continued existence is well distributed in the 

planning area.” This means, with regard to a forest plan, to “insure that 

viable populations will be maintained, habitat must be provided to 

support, at least, a minimum number of reproductive individuals and that 

habitat must be well distributed so that those individuals can interact with 

others in the planning area.” 
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In the 2008 Amended Forest Plan explicitly adopted these obligations. It 

requires the Forest Service to manage the Tongass is such a way as to 

“[m]aintain the abundance and distribution of habitats, especially oldgrowth forests, to sustain viable populations in the planning area” and 

“[m]aintain habitat capability sufficient to produce wildlife populations that 

support the use of wildlife resources for sport, subsistence, and 

recreational activities.” The 2008 Amended Forest Plan also identifies 

specific objectives with regard to biodiversity, including the need to 

“[p]rovide sufficient habitat to preclude the need for listing species under 

the Endangered Species Act, or from being listed as Sensitive due to 

National Forest habitat conditions.” 

Under the NFMA, the Forest Service must demonstrate that a sitespecific project, like the Wrangell Island Project, will be consistent with 

the 2008 Amended Forest Plan and it statutory obligations to protect 

wildlife populations. As explained below, the Forest Service consistently 

fails to explain or, in many cases, even offer conclusions regarding the 

Wrangell Island Project’s compliance with the 2008 Amended Forest 

Plan and its NFMA obligations, including, most notably, whether the 

project is consistent with the substantive obligation to ensure the viability 

of species on the Tongass. 

058-SEACC23I. THE DEIS FAILS TO ASSESS CUMMULATIVE IMPACTS 

GIVEN THE REASONABLY FORESEEABLE CONSEQUENCES OF 

THE AGENCY’S ANTICIPATED FOREST PLAN AMENDMENT. 

The Forest Service is on the verge of amending the 2008 Amended 

Forest Plan in such a manner that would fundamentally alter the 

decades-long conservation strategy by allowing second-growth logging, 

including clear-cuts of up to 10-acres, in old-growth reserves, riparian 

management areas, and beach fringe buffers. These areas comprise 

some of the most productive lands on the Tongass and their protection 

from logging has been an essential component of the agency’s 

conservation strategy. Allowing logging on these protected lands 

compromises the conservation strategy and risks the viability of many of 

the Tongass’s most at-risk wildlife species. The DEIS, however, entirely 

fails to analyze the myriad of potential cumulative effects of the Wrangell 

Island Project given this imminent and fundamental change in Tongass 

management. 

The Forest Service’s cumulative impacts analysis requires “some 

quantified or detailed information; . . . [g]eneral statements about 

‘possible’ effects and ‘some risk’ do not constitute a ‘hard look’ absent a 

The Wrangell Island Project complies with NFMA and the 

decision will be consistent with the 2016 Forest Plan. Comments 

on the effects to the Forest’s conservation strategy are beyond 

the scope of this project analysis. The Conservation Strategy 

addressed in appendix K of the 2016 Forest Plan and in 

appendix D of the Forest Plan FEIS. Management of young 

growth within the beach buffer, riparian management areas 

outside the TTRA buffers and within the Old-growth habitat 

which are components of the conservation strategy. There is no 

proposed harvest of young growth in this project or in the 

reasonably foreseeable future due to the young age of the 

stands. The young growth on Wrangell Island will generally not 

to be merchantable for another 30 years. Therefore, these 

components of the conservation strategy would not be affected 

and were not included in direct or cumulative effects for this 

project. 

The analysis addressed cumulative effects for each resource, as 

documented in the resource reports and summarized in chapter

3 of the EIS.
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justification regarding why more definitive information could not be 

provided.” In addition, the “cumulative impact analysis must be timely,” 

meaning the Forest Service cannot “defer consideration of cumulative 

impacts to a future date when meaningful consideration can be given 

now.” As explained below, the Forest Service itself is creating the 

adverse impacts on ecosystems and wildlife when it decided to change 

the conservation strategy without any scientific support and, as a result, 

it must analyze the resulting cumulative impacts when it considers site 

specific decisions. 

For decades, the Tongass conservation strategy relied on a system of 

old-growth reserves, along with various protections for lands outside of 

the reserves, including areas set aside as wildlife corridors to connect 

the reserves. Riparian management areas and beach fringe buffers 

provide essential connectivity between old-growth reserves for a wide 

variety of Tongass species. Although this system has not been proven 

sufficient to protect old-growth-dependent wildlife in the Tongass, it 

provides a protective floor that should not be compromised. As the 

Pacific Northwest Research Station cautioned after its independent 

scientific peer review of the Forest Service’s conservation strategy:

Because of the unusually long time needed for succession to achieve 

climax in these temperate rain forests, a rotating block design for timber 

harvesting is not appropriate. Therefore, sufficient biodiversity reserves 

must be established, and these must be permanently unavailable for 

timber harvest. Otherwise blocks must be allowed to serve as source 

areas for many years beyond the age at rotation.

According to the Forest Service itself, “beach fringe was a very key 

feature of the overall Tongass conservation strategy.” Beach and 

riparian buffers are essential to maintaining viable populations of flying 

squirrels and other small mammals, eagles, goshawks, deer, marten, 

otters, bears, shorebirds, waterfowl, bald eagles and other marineassociated species. They also provide essential protections for salmon. 

The 2008 Amended Forest Plan FEIS explained:

Beach and estuary fringe, and riparian habitats, have special importance 

as components of old-growth forests, serving as wildlife travel corridors, 

providing unique wildlife habitats, and providing a forest interface with 

marine or riverine influences that may distinguish them as separate 

ecosystems within the larger old-growth forest ecosystem . . . . In 

conjunction with riparian areas, which provide connectivity within 

watersheds, the beach fringe is thought to be a component of the major 
Appendix B

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travel corridor system used by many resident wildlife species . . . . 

Accordingly, the Forest Plan establishes a Beach and Estuary Fringe 

Forest-wide Standard and Guideline that prevents timber harvest within 

1,000 feet inland from mean high tide...Together, the beach and riparian 

habitat management features and the mapping of small reserves 

represented a substantial response to the landscape linkage element of 

conservation planning and significantly contributed to management of 

the overall matrix among habitat reserves.

The newly amended forest plan the agency plans to adopt would allow 

clear-cutting of second-growth on up to 10-acre blocks in these areas, 

which are protected by the 2008 Amended Forest Plan. There is, 

however, no science showing that these protected areas can be logged 

in economically viable ways without compromising the conservation 

values of the areas. To the contrary, scientists reviewing the Tongass 

Advisory Committee recommendations were highly critical of this 

strategy. For example, a group of ten independent scientists with 

significant Tongass experience stated that “we find no empirical data to 

support the contention that one can log 60-80 year old young-growth in 

ways that are economically viable and achieve desired wildlife benefits.” 

The scientists’ letter reviews the current science on second-growth 

logging and concludes, “[b]ased on the current science, the prospects of 

achieving old-growth forest characteristics by placing small clearcuts in 

mature young-growth stands is extremely low. We anticipate these 

ecologically important areas will be deferred from logging until that 

science changes.” Similarly, in his comments on the Tongass Advisory 

Committee recommendations, Matthew Kirchhoff was highly critical of 

the assertion that the Forest Service could allow 10-acre cuts in 

protected areas and still maintain their conservation value:

What you are recognizing is we made a mistake when we clear-cut such 

ecologically valuable areas in the first place. What you are doing now is 

sentencing them to an infinite cycle of more logging—out of the 

misguided notion that calling it restoration makes it good. More logging 

will create more clearcuts, which will demand more logging of inevitable 

second-growth. How and when will these stands be allowed to become 

old-growth—real old-growth that doesn’t need our constant tree-cutting 

intervention to minimally function?

Mr. Kirchhoff concluded that the Forest Service “should take beach 

fringe and [old-growth reserve]s off the table, except possibly, in very 

limited research-oriented applications.”
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Number Comment Response

In the DEIS, the Forest Service fails to acknowledge the ecological 

consequences that result from the agency’s decision to relax protections 

for all these areas nor does it account for the cumulative impacts of the 

Wrangell Island Project on all of the affected species given these 

changes. Given that the Forest Service and independent scientists have 

concluded that old-growth reserves, beach fringe buffers, and riparian 

management areas are essential to maintaining the viability of a wide 

array of wildlife species on the Tongass, the Forest Service must 

evaluate what cumulative effects stem from the fact that the agency now 

wants to allow commercial logging in these areas. The DEIS’s failure to 

examine those impacts, including the conflicting expert opinions, must be 

rectified in the FEIS. 

058-SEACC24II. THE FOREST SERVICE MUST EXPLAIN THE IMPACTS ON 

WILDLIFE POPULATIONS IN A MANNER CONSISTENT WITH NFMA, 

THE FOREST PLAN AND NEPA’S REQUIREMENTS.

Throughout the DEIS, the Forest Service repeatedly concludes that 

wildlife populations will continue to persist after the Wrangell Island 

Project. The agency’s decision to offer such a paltry characterization is a 

marked and disappointing departure from the agency’s previous 

conclusions and explanations in earlier timber sale EISs. It is also 

arbitrary and unlawful under NMFA and inconsistent with the thresholds 

established in the 2008 Amended Forest Plan.

On balance, the DEIS offers a confused and frequently inconsistent 

description of wildlife impacts. In some cases, the DEIS explains the 

agency concludes that a bird or wildlife population with merely “persist” 

after the Wrangell Island Project. Even more curious, the agency 

repeatedly concludes a population will persist “at current levels,” but 

admits it does not know the current population level and fails to describe 

its basis for these predictions, making it impossible to know whether the 

population will persist at that level. For example, the DEIS admits that 

the agency lacks a current population estimate for the Queen Charlotte 

goshawk either on the Tongass as a whole or on Wrangell Island. The 

DEIS, however, concludes “Wrangell Island would continue to provide 

suitable habitat and the Queen Charlotte goshawk would continue to 

persist at current levels.” With regard to wolves, the DEIS simply states 

wolves “occur on Wrangell Island.” It never explains whether the agency 

considers the wolf population sustainable. Instead, it states: “There 

could be cumulative effects on wolves or their prey when past, present 

and reasonable foreseeable future projects are combined with the 

implementation of the Wrangell Island Project; however, wolves would 

The Wrangell Island Project analysis appropriately analyzed the 

effects of the alternatives on wildlife with consideration for the 

requirements of NFMA, the Forest Plan, and NEPA and is in full 

compliance. All standards and guidelines were followed. These 

effects are presented in the wildlife section of chapter 3, and in 

the Wildlife Resource Report.

For more information on the species analyzed please see the 

Wildlife Resource Report and chapter 3, Wildlife, of the FEIS. All 

the effects on the species analyzed are based on percent 

reduction of habitat from existing condition (National Forest 

System lands only), and percent reduction of habitat from historic 

condition (all lands within the analysis area). Populations are not 

accurately known, therefore they were not used to estimate 

effects.
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continue to persist on Wrangell Island.” With regard to deer, the DEIS 

explains “[t]here are no reliable population estimates for deer populations 

in [Game Management Unit] 3, which includes Wrangell Island,” but then 

concludes goes “deer would continue to persist at current levels.” 

Simply put, the DEIS provides one of the weakest assessment of wildlife 

impacts that the undersigned groups have ever seen the agency 

produce. The FEIS must provide a clear, consistent assessment of the 

impacts on the ability of Wrangell Island to support sustainable wildlife 

populations after this timber sale, while explaining why the project is 

consistent with the agency’s obligations to ensure wildlife viability on the 

Tongass. Suggesting that bird and wildlife species might simply “persist” 

is insufficient. If the agency has concluded these populations are not 

sustainable or not able to contribute to overall viability, then it must 

acknowledge these facts and the resulting biological consequences in 

the FEIS. 

NFMA and the other statutes under which the Forest Service operates 

require the agency to balance timber objectives with other forest values 

such as wildlife, recreation, and subsistence. Additionally, the agency 

must demonstrate that a site-specific project is consistent with the 

governing forest plan. This requires the agency to explain why it believes 

the Wrangell Island Project is consistent with the 2008 Amended Forest 

Plan, including the standards and guidelines governing wildlife. In the 

DEIS, the agency fails to conduct that analysis in almost every instance. 

Instead, the agency speaks in terms of populations continuing to 

“persist” after the Wrangell Island Project. As an initial matter, the 

agency never explains what it means to persist. More importantly, 

however, persistence is not the threshold established in the standards 

and guidelines of the 2008 Amended Forest Plan. Ultimately, of course, 

the agency must demonstrate why it can pursue the Wrangell Island 

Project and still ensure the continued viability of wildlife species. The 

agency must correct these pervasive problems and conduct the required 

wildlife analyses, because do otherwise the agency would act contrary to 

its statutory obligations and 2008 Amended Forest Plan. 

058-SEACC25III. THE DEIS RELIES ON LIMITED AND OUT-DATED SCIENCE.

The DEIS relies on very limited science for marten, squirrels and 

endemics, bears, deer, and wolves. Additionally, much of the science 

that is included is outdated.

The analysis used the best available science concerning each 

species including several applicable documents provided as part 

of this comment letter. The FEIS has been updated to reflect 

this. In some cases, older studies are still considered valid. 
BAppendix

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• Marten: There are ten studies on marten in the planning record 

index. The majority (6) were published in the 2000s. The remaining four 

are from the 1990s, and there are no current (i.e., from the 2010s) listed 

on the index. The most current study is from 2008.

• Squirrels and Endemics: There are thirteen studies on squirrels 

and endemic species, again with the majority (9) published in the 2000s. 

There are no studies listed on the index from the 2010s. The remaining 

four were published in 1978, 1986, and 1988. The most current studies 

are from 2007.

• Bears: The planning record incudes ten studies on bears. The 

majority (5) were published in the 2000s. Three survey and inventory 

reports from 2011 and 2012 are also included as well as one study from 

1976 and one from 1982.

• Wolves: The planning record includes 11 studies on wolves. 

The slight majority (6) were published in the 2000s. Three were 

published in 1987, 1996 (the conservation assessment), and 1999. The 

remaining two were published by ADF&G in 2012.

• Deer: There are 23 deer studies, with the majority published in 

the 1980s (10) and 1990s (7). The remaining six studies from the 2000s 

(4) and the 2010s (2).

In preparing the FEIS, the Forest Service needs to provide additional 

contemporary scientific publications to meet the obligation to base its 

decision on complete, accurate, and up to date information. 

IV. SITKA BLACK-TAILED DEER

The Wrangell Island Project highlights one of the great travesties of the 

Tongass timber program. The timber industry and the Forest Service 

have targeted portions of the Tongass for repeated, intensive, and 

devastating logging practices that leave the affected areas with 

irretrievable environmental damage. Even without the current proposed 

logging, it will take hundreds of years for Wrangell Island to recover from 

the adverse effects of historical logging. Instead of allowing that process 

to proceed, the Forest Service proposes to subject one of the hardest hit 

areas with another massive sale. Simply put, these are the last places on 

the Tongass the Forest Service should be logging. The problems 

The 2016 US Fish and Wildlife Service 12 month finding on wolf 

petition was added to the project record (Federal Register Vol 81 

No 3, Wednesday January 6, 2016, “endangered and threatened 

wildlife and plants 12 month finding on a petition to list the 

alexander archipelago wolf as an endangered or threatened 

species”). 
Appendix B

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confronting the deer population on Wrangell illustrates this very problem 

with vivid clarity.

058-SEACC26Sitka black-tailed deer occupy most islands in Game Management Unit 

3. The DEIS acknowledges there are no reliable population estimates for 

deer in the unit and that populations in the area have exhibited extreme 

historical fluctuations. 

ADF&G summarizes the general trends in Game Management Unit 3 for 

deer as follows: 

Deer populations . . . were high during the 1950s and 1960s after 

extensive wolf control, but have remained at relatively low levels in most 

of the Unit since a series of severe winters in the early 1970s. By the late 

1990s, deer had recovered to moderate levels in some portions of the 

Unit but again declined to low levels throughout the Unit following the 

severe winters of 2006-2009.

ADF&G also explains that: “Pellet-group trends suggest [populations] 

are at a much lower level than 15,000 [deer], while [ADF&G] harvest 

estimates have remained well below the 900 deer threshold established 

by the [Alaska Board of Game] in 2000 each year since 2005.” 

The Wrangell Island Project included a thorough analysis on the 

effects from the alternatives on Sitka black-tailed deer. These 

are presented in chapter 3 of the EIS and the Wildlife Biological 

Evaluation. 

Comments noted. The deer analysis was conducted at the GMU 

and WAA scale. 

According to the Forest Service, deer populations on most islands in the 

Unit “have declined since 2004 and are thought to be well-below carrying 

capacity.” As detailed below, these population declines have resulted in 

corresponding declines in deer harvests. 

The Wrangell Island Project DEIS, p. 79 stated that there are “no 

reliable population estimates in GMU 3, which includes Wrangell 

Island” but all stated that deer populations in this area have had 

extreme fluctuations. These fluctuations are mostly due to 

severe winters but it should be noted that wolf predation is also a 

factor in deer population recovery. This statement was based on 

deer harvest data collected by ADF&G. 

A. The DEIS Downplays the Impacts on Game Management Unit 

3’s Deer Population.

The DEIS offers little more than a handful of paragraphs to discuss the 

adverse impacts on deer. The DEIS’s paltry suggestion that there is 

some risk that the deer population might decline does not satisfy the 

agency’s NEPA obligations and the agency’s lack of meaningful analysis 

about the deer population runs contrary to its NFMA obligations. 

The primary factors for the great swings in deer numbers and harvests in 

Game Management Unit 3 are contributed to (1) clear-cut logging that 

reduces winter carrying capacity; (2) severe winter weather; (3) 

predation by wolves and bears; and (4) illegal hunting. Specific to 

Deer populations in Southeast Alaska have historically fluctuated 

with high and low extremes; some reasons for decline have 

resulted from logging, predation by wolves and bears and illegal 

hunting (Lowell 2015). 

Specifically, as stated by Lowell (2013), “[GMU] 3 deer 

populations and estimated harvest steadily declined from RY04 

to RY08 [RY refers to the Regulatory Year]. In RY05, the 

estimated unit-wide harvest began to decline annually before 

reaching a low of 333 deer in RY08. Although the unit-wide deer 

harvest rebounded to 547 in RY09 and 673 in RY10, it declined 

to 514 in RY11. With the possible exception of a few smaller 

islands, Unit 3 deer exist largely at levels well below carrying 

capacity.” 
BAppendix

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Wrangell Island, the Forest Service also suggests that hunting pressure 

in general may have contributed to low deer densities on the island, as 

well as the combination of all factors. 

The degree to which each of the factors have driven, or currently drive, 

poor population and harvest numbers varies. According to some, 

“[s]evere winter weather causes most population declines.” For 

example, significant population declines were associated with severe 

winters in the 1960s and 1970s, resulting in hunting restrictions in 1973 

and complete closure of the unit in 1975-1979. 2006-2009 were also 

heavy snow years. In 2012, Petersburg area biologist Rich Lowell 

contributed the low deer numbers in the Unit to “‘die-offs associated with 

record snowfall in 2006, followed by three consecutive winters with 

above average snowfall. On top of those hard winters, there’s predation 

by wolves and black bears.’” Game Management Unit 3 is thought to be 

“the only area in Southeast Alaska where deer harvest was actually 

lower in the severe winter of 2006.”

According to ADF&G, even though severe winter weather can contribute 

toward “dramatic population swings,” the greater concern is that “habitat 

capability and deer numbers are expected to decline in some areas as 

large tracts of previously logged areas reach the closed canopy stem 

exclusion stage and become extremely poor deer habitat.” Elsewhere 

ADF&G explains that “[c]lear-cut logging has and will continue to reduce 

winter carrying capacity for deer in some areas [of Game Management 

Unit 3].” Further, the “extensive habitat alterations due to clear-cut 

logging [in the Unit] can exacerbate the effects of severe winters . . . [by] 

remov[ing] productive old growth stands that are important winter habitat 

for survival of deer.” ADF&G further concludes that “continued 

reductions in deer habitat capability associated with past, present, and 

future timber harvests will continue to reduce the unit’s ability to support 

high deer numbers over the long term (several decades).”

The Wrangell Island Project included a comprehensive analysis 

on the effects of the alternatives on deer which is summarized in 

chapter 3 with a detailed analysis, documented in the Wildlife 

Resource Report.

In 1998, the Forest Service admitted:

There is no high value deer winter range habitat on Wrangell Island 

based on the most recent Deer Habitat Model. Much of the moderate 

value deer winter habitat has been logged or severely fragmented by 

past timber harvest. A few small blocks of moderate value habitat remain 

near the City Reservoir, at Fools Inlet and within the Thorns Old Growth 

Reserve. 

The 1998 Wrangell Island Analysis (R10-MB-371) on page 16 

states “No high value deer winter habitat exist in the North 

Wrangell Landscape Unit”, page 28 “there was no high value 

deer winter range in this unit (Salamander Landscape Unit), and 

on page 33 “based on the latest model, there is no high value 

deer winter range within this landscape unit (Earl West 

Landscape Unit). However these descriptions were limited to 

parts of the island and not intended to describe all of Wrangell 

Island. We have since updated our GIS data and how the high-
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The agency estimated the carrying capacity of Wrangell Island at 2,824 

deer, but even then admitted “current deer densities are believed to be 

much lower than that based on pellet counts.” It appears that only two 

pellet group surveys have been done on the island, both in VCU 4800 in 

the southeast end of the island in the Fool’s area, which is part of the 

Wrangell Island Project. The mean pellet groups per plot in that area 

were 0.54 and .61 in 1994 and 2000, respectively. The Forest Service 

concluded that this area contains some moderate value deer winter 

habitat and one of the “only high volume stands remaining on Wrangell 

Island.” The DEIS completely ignores of these issues.

The Forest Service does not explain how far below carrying capacity the 

deer population has fallen or whether the population is stable. It does not 

describe to what degree the current carrying capacity of the area is 

already below the habitat capability generally recognized as necessary 

to maintain a sustainable population of deer (such that it supports human 

hunting and wolf predation). Stated more directly, the agency must 

explain the relationship between the carrying capacity, the habitat 

capability, and the deer population (both current and future). It fails to 

describe the habitat level that must remain to keep the deer population at 

its current population. 

Instead of conducting the required analysis, the Forest Service blandly 

asserts that the reduction in habitat capability “could lead to a decline in 

the deer population.” Similarly, the agency explains “[d]eclines in the 

deer population resulting from reduced habitat capability may decrease 

the availability of deer to wolves and hunters.” The agency misleads the 

public when it suggests that a deer population decline is nothing more 

than a possibility. In fact, it asserts the deer populations “would continue 

to persist at current levels.” This assertion is unsupported by any 

explanation or analysis, making it arbitrary and misleading. 

The FEIS must correct these deficiencies and provide the public a clear 

and accurate assessment of the impacts of the agency’s unrelenting 

pressure on Wrangell’s remaining old-growth habitat. With regard to 

NFMA, the agency must conduct the analysis necessary to demonstrate 

that it is properly balancing the competing interests of deer, wolves, deer 

hunter, and logging, and justify its proposal to further reduce habitat to 

levels well below that required to support sustainable wolf and deer 

populations.

value winter habitat – which is now called “deep snow winter 

habitat” – is calculated. 

For a current comprehensive analysis of deer habitat for the 

entire Wrangell Island (WAA 1903), please see table 11 of the 

Wildlife Resource Report. 
BAppendix

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058-SEACC27B. The DEIS Also Minimizes the Impacts on Deer Harvest Trends.

In the 1980s, estimated deer harvests in Game Management Unit 3 were 

very low, hovering at or below 200 animals. Throughout most of the 

1990s, trend was positive, with harvests peaking in 1998 at around 1,000 

deer. Throughout most of the 2000s, harvest again trended down, 

dipping to 377 deer in 2008, the lowest since 1990.

In 2000, the Alaska Board of Game set deer population and harvest 

objectives for Unit 3 at 15,000 and 900 animals, respectively. The 

population objective of 15,000 deer “was developed by assessing the 

deer habitat carrying capacity within the unit and the local Area 

Biologist’s subjective assessment of where the unit’s deer population 

stood relative to carrying capacity.”

The following table provides harvest data for 1997-2014. It shows that 

during this period, the deer harvests in Game Management Unit 3 

averaged 685 deer. During the same time period, the number of hunters 

averaged 897, fluctuating between the high of 1,186 (1999 & 2000) and 

low of 617 (2008 & 2009). 

The Wildlife Resource Report and DEIS wildlife section have 

been revised to discuss the deer harvest trends in GMU 3.

Deer populations in Southeast Alaska have historically fluctuated 

with high and low extremes; some reasons for decline have 

resulted from logging, predation by wolves and bears and illegal 

hunting (Lowell 2015). The management goal for GMU 3 is to 

achieve and maintain a population of 15,000 deer while 

maintaining an annual harvest of 900 deer. This goal has not 

been reached since the year 2000 and as a result, ADF&G

prepared an operational plan for the intensive management (IM) 

of Sitka black-tailed deer in a portion of GMU 3 (ADF&G 2013). 

Part of the IM plan is to reduce the number of predators (wolves) 

on Mitkof Island. Wrangell Island is classified as an intermediate 

and deep snow area based upon long-term yearly averages. 

According to ADF&G hunting statistics from years 1997-2014, 

GMU 3 has had fewer hunters which has resulted in decreased 

harvest but average deer per hunter has remained stable 

(ADF&G website).
Appendix B

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The DEIS fails to address the consequences that deer hunting is on a 

demonstrable decline. The FEIS must correct this failing. To comply with 

NFMA, the agency must explain its rationale for concluding that the 

Wrangell Island Project reflects the proper balance of the agency’s 

multiple use obligations given the precipitous decline in deer hunting on 

Wrangell Island.

058-SEACC28V. WOLVES 

A. The Forest Service’s Conclusions Regarding Wolves is 

Inconsistent With the Agency’s Goals in the 2008 Amended Forest Plan 

and its Obligations Under NFMA.

The Forest Service explains in the DEIS that: “Current deer habitat 

capability on Wrangell Island (WAA 1903) is below the Forest Plan 

guideline of 18 deer/mi2, which suggests that the project could result 

insufficient numbers of deer to sustain wolves and human hunting.” In 

characterizing the cumulative effects, the DEIS provides: “However, 

wolves are highly mobile within their territories and adjacent islands with 

higher deer densities would continue to support wolves on the Wrangell 

Ranger District.” The Forest Service is unable to conclude that a 

sustainable wolf population would remain after the Wrangell Island 

Project. Instead, the agency explains “wolves would continue to persist 

on Wrangell Island.”

This 2008 Amended Forest Plan directs the Forest Service to “assist in 

maintaining long-term sustainable wolf populations.” It makes clear that 

the agency should try to provide “sufficient deer habitat capability to first 

maintain sustainable wolf populations, and then to consider meeting 

estimated human deer harvest demands.” The DEIS makes clear that 

the Forest Service has concluded that the wolf population would not be 

sustainable after the Wrangell Island Project and instead the population 

should continue to persist at some undefined level. This is unacceptable; 

the agency should not proceed with a project that continues to lower that 

density. At a minimum, the agency must admit that it will not meet the 

“sustainable” objective and the FEIS must disclose this conclusion in a 

clear and forthright fashion, and the agency must justify its choice to 

meet this important goal of the forest plan. Moreover, the agency must 

explain how it can proceed with this project in the face of the obligation 

to protect viable and well distributed populations of wolves on the 

Tongass. 

The Wrangell Island Project included a thorough analysis on the 

effects from the alternatives on wolves. These are presented in 

chapter 3 of the EIS and the Wildlife Biological Evaluation. 

The Wrangell Island Project will be consistent with the Forest 

Plan and it complies with NFMA. The analysis on wolves is 

presented in chapter 3 and the Wildlife Resource Report. 

Please see response to comment 058-SEACC-29.
BAppendix

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058-SEACC29B. The Forest Service Must Disclose in the FEIS the Full Impacts 

of Increased Road Density Resulting From the Wrangell Island Project 

and Justify Its Compliance With NFMA.

Like virtually every project before it, the Wrangell Island Project will drive 

road density above the limits generally recognized to ensure wolf 

populations do not suffer unsustainable rates of mortality. The DEIS 

explains that “[t]he Forest Plan states that a road density of 0.7 to 1.0 

mi/mi2 or less may be necessary to reduce harvest-related mortality risk 

where locally unsustainable wolf mortality has been identified.” The 

DEIS reports that:

Existing total road densities in WAA 1903 are at the upper end of the 

Forest Plan recommendation of 0.7 to 1.0 where road access and 

associated human-caused wolf mortality is a concern. Harvest rates may 

increase under alternatives that increase the total road density on 

Wrangell Island (open and closed roads). Therefore, all action 

alternatives would have a direct and indirect effect to wolf individuals and 

their habitat.

It goes onto to conclude that “[a]ll action alternatives would put Wrangell 

Island above the 1.0 mi/mi2 road density which could lead to an increase 

in human caused wolf mortality.”

Ultimately the agency must disclose the consequence of the increased 

road density on the agency’s ability to maintain sustainable wolf 

populations in the project area, as well as the ability to ensure wolf 

populations remain well-distributed and viability. This analysis is 

particularly important given the DEIS fails to disclose that the 

“interagency analysis” that is supposed to trigger the road density 

measures in the 2008 Amended Forest Plan is irretrievably broken. The 

U.S. Fish and Wildlife has repeatedly reached conclusions regarding 

unsustainable rates of mortality, but the Alaska Department of Fish and 

Game refuses to do so and, as a result, road building and mortality go on 

unchecked. The DEIS must disclose this infirmity and explain the 

resulting consequences. 

ADF&G believes that, while there may be vulnerabilities for 

wolves in select parts of GMU 2 (Person et al. 1996, Person 

2001, Person and Russell 2008, Person and Logan 2012), 

wolves are viable (i.e., not threatened with extinction) across 

their overall historic range in Southeast Alaska, which includes 

Wrangell Island (ADF&G 2012b).

In 2016, the USFWS estimated that the rangewide population of 

the Alexander Archipelago wolf to be approximately 850-2,700 

wolves with the majority (approximately 62 percent) occurring in 

coastal British Columbia where populations have been stable 

since 2000. Based on anecdotal information wolf populations in 

GMU 3 are thought to be at higher densities than the early 

1990’s because of increased moose and Sitka black-tailed deer 

number (USFWS 2016). Using the most recent and best 

available wolf population estimates in southeastern Alaska and 

coastal British Columbia, USFWS estimated that GMU 3 

contains approximately 14 percent (136 to 373 wolves) of total 

rangewide population (USFWS 2016). 

Road densities would increase on National Forest System land 

by 0.12 to 0.32 mi/mi2 depending on which action alternative is 

selected (Wildlife Resource Report). The OGR configuration 

would remain as it is.

The USFWS has not reached same conclusions about wolf 

mortality in GMU 3. ADF&G has not commented on wolf 

mortality in GMU 3.

Please see response to comments 038-EB-02 and 058-SEACC28 and 056-DOW-04, -07 through -12.

C. The Wrangell Island Project and the DEIS Suffer From the 

Same Infirmities Addressed in In Re: Big Thorne Project and 2008 

Tongass Forest Plan, No. 15-35244 (9th Circuit). 

The 2008 Amended Forest Plan’s critical mechanism for meeting the 

Forest Service’s obligation to ensure the wolf remains viable in the 

Tongass is, the agency concedes, discretionary and non-binding and, as 

Comments on the Forest Plan are outside the scope of this 

project.

Wolf habitat concerns on Wrangell Island (GMU 3) are not the 

same as on Prince of Wales Island (GMU 2). For instance, 

Wrangell Island’s wolf population does not receive the same 
Appendix B

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a result, the plan does not require the agency to maintain the necessary 

old-growth habitat to “insure [the wolf’s] continued existence.” The 

Wrangell Island Project is being pursued pursuant to that forest plan. 

Pursuant to the NFMA regulations, “wildlife habitat shall be managed to 

maintain viable populations of existing native and desired non-native 

vertebrate species in the planning area.” “[T]o insure that viable 

populations will be maintained,” a forest plan must manage habitat in 

such a way as “to support, at least, a minimum number of reproductive 

individuals and that habitat must be well distributed so that those 

individuals can interact with others in the planning area.” As described 

above, the 2008 Amended Forest Plan explicitly incorporates these 

obligations.

In adopting the 2008 Amended Forest Plan, the Forest Service 

concluded that if the agency managed habitat in such a way that 

maintained sustainable wolf populations, it would by necessity maintain 

viable wolf populations. According to the Forest Service, the Wolf 

Conservation Assessment provided the best available information 

regarding wolf viability and it concluded that it was not scientifically 

defensible to identify what minimum wolf population would insure the 

wolf’s continued existence. As a result, the Forest Service accepted its 

experts’ recommendation that the agency meet its viability obligations by 

minimizing the risk of dropping below that unidentified viability floor by 

maintaining sufficient old-growth habitat to support the higher level of 

sustainable wolf populations (which accounts for deer hunting and wolf 

hunting and trapping). The Forest Service, however, concedes the 2008 

Amended Forest Plan does not require the agency to maintain sufficient 

habitat to support sustainable wolf populations. 

In short, the Wrangell Island Project demonstrates the infirmity of the 

2008 Amended Forest Plan. The Forest Service is not obligated to 

manage habitat in such as to ensure the viability of the wolf, which 

allows damaging projects like this one to proceed. 

level of hunting and trapping pressure as do the wolves on 

Prince of Wales Island, which also features substantially higher 

road density. 

058-SEACC30VI. ENDEMICS AND SMALL MAMMALS

In addition to the general wildlife directives discussed above, the 2008 

Amended Forest Plan establishes as one of its objectives “to maintain 

habitat to support viable populations and improve knowledge of habitat 

relationships of rare or endemic terrestrial mammals that may represent 
BAppendix

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unique populations with restricted ranges.” The Forest Plan directs the 

agency to: 

Use existing information on the distribution of endemic mammals to 

assess project level effects. If existing information is lacking, surveys for 

endemic mammals may be necessary prior to any project that proposes 

to substantially alter vegetative cover (e.g., road construction, timber 

harvest, etc.). Surveys are necessary only where information is not 

adequate to assess project-level effects.

The DEIS makes clear that “[e] ndemic species are distinct, unique 

species with a restricted area or range.” It goes on to explain:

There are roughly 24 mammal species or subspecies considered 

endemic to Southeast Alaska (Smith et al. 2005). Mammal surveys on 

the Tongass have resulted in the documentation of new distributions, 

new species. However, there continue to be gaps in knowledge about 

the natural history and ecology of wildlife subspecies indigenous to 

Southeast Alaska (Hanley et al. 2005). Within Southeast Alaska, roughly 

20 percent of known mammal species and subspecies have been 

described as endemic to the region. The long-term viability of these 

endemic populations is unknown, but of increasing concern since island 

endemics are extremely susceptible to extinction because of restricted 

ranges, specific habitat requirements, and sensitivity to human activities 

such as species introductions (http://msb.unm.edu/isles/). 

The DEIS acknowledges there are “increasing” viability concerns for 

endemic populations, but fails to explain those concerns. Given those 

concerns, it is all the more important that the Forest Service comply with 

the Forest Plan’s requirements to use contemporary information 

regarding those endemic populations to understand the potential effects 

of the Wrangell Island Project. The agency must explain whether and 

why it concluded it did not need additional information regarding these 

populations. The lack of analysis makes it impossible for the agency to 

conclude that it can approve the Wrangell Island Project as consistent 

with the 2008 Amended Forest Plan and its substantive obligations to 

ensure the continued viability of these endemic populations. 

Under NFMA, the Forest Service cannot blitely state that it does not 

know whether it can provide for the long-term viability of endemic 

populations. As explained above, the Forest Service has a mandatory 

Please see response to 055-WS-01.

The Wildlife section of chapter 3 of the FEIS and the Wildlife 

Resource Report have been updated to clarify the effects to 

endemic mammals. Habitat, rather than population estimates, 

was used to estimate effects to the endemic mammals. 

Additional population surveys are not necessary to estimate 

effects. 
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and substantive obligation to ensure the viability of these populations. To 

do otherwise, the agency would violate NFMA. 

058-SEACC31A. Southern Red-Backed Vole

The southern red-backed vole occurs as four endemic subspecies on the 

Tongass; Wrangell Island is home to one of those subspecies (Myodes 

gapperi wrangeli). As explained below, the DEIS fails to analyze the 

impacts of logging on these voles in any meaningful way. The agency 

also fails to explain whether or why it concluded it could approve the 

Wrangell Island Project and still ensure the viability of this endemic 

subspecies or the species as a whole. For these reasons, the concerns 

discussed below raise both NEPA and NFMA infirmities. 

As Winston Smith, Ph.D.’s comments to the Forest Service demonstrate, 

the Wrangell Island Project raises serious questions regarding the 

project-level impacts, as well as the agency’s ability to ensure the 

viability of this subspecies of southern red-backed vole. According to the 

DEIS, “[t]he southern red-backed vole (Myodes gapperi wrangeli) is the 

only endemic small mammal identified on Wrangell Island,” noting it also 

occurs on nearby Sergief Island. 

The Forest Service, however, does not disclose that “Wrangell Island is 

home to virtually the entire population of this subspecies in the Tongass.”

The DEIS also fails to explain there is no current population estimate for 

these voles. Even more troubling, it does not acknowledge that the last 

population estimate demonstrated a precipitous decline, as the 2000 

population was only 20% of the 1998 population. Indeed, the DEIS 

makes clear that the research the Forest Service relies on is already 

more than 10 years old, making the agency’s analysis significantly 

outdated. The DEIS explains, for example, that “[i]nformation about 

Wrangell Island red-backed voles comes from Smith and Nichols (2004) 

and the related Smith et al. (2005) on Wrangell Island.” This research 

“tested the association with old-growth specifically for the Wrangell 

Island red-backed vole,” and concluded that the voles, and particularly 

breeding populations demonstrated a significant preference for oldgrowth habitat. 

In describing the direct and indirect effects of the Wrangell Island logging 

on this endemic species, the DEIS offers only two paragraphs. The DEIS 

begins by acknowledging “[t]imber harvest would directly affect the 

The Wrangell Island Project is in full compliance with NEPA and 

NFMA.

The Wrangell Island analysis addressed the effects to the 

Wrangell Island southern red-backed vole. This is documented in 

the wildlife section of chapter 3 of the EIS and in the Wildlife 

Resource Report.

Please see response to comments 055-WS-01, -02, and -03.

The analysis documents the occurrence of the Wrangell Island 

red-backed vole on Wrangell Island, Sergief and Etolin Islands. 

The populations on each of the islands is not known. For more 

information see Wildlife Resource Report. The Wildlife Resource 

Report and the Wildlife section of chapter 3 of the FEIS have 

been updated to clarify this information. The analysis used the 

best information available. 
BAppendix

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southern red-backed vole through habitat loss (all [productive oldgrowth], and by altering the distribution of habitats across the 

landscape.” The DEIS continues by explaining that the “[a]lternatives 

that harvest the most [productive old-growth] . . . would be expected to 

have the greatest effect to the southern red-backed vole.” Alternative 2, 

the preferred alternative, would eliminate approximately nine percent of 

the existing productive old-growth habitat on National Forest Service 

lands. The DEIS, without explanation, concludes by stating “all action 

alternatives . . . would have minimal effect on red-backed voles which 

would lead to population declines and reduced genetic interchange 

because of habitat fragmentation.”

In the two paragraphs describing the cumulative effects of the Wrangell 

Island Project, the Forest Service offers even less. In acknowledging the 

logging on 6,800 acres of National Forest Service lands as well as 

logging and habitat loss from a variety of other sources, the DEIS makes 

the nonsensical suggestion that “[o]ne possible benefit is the [Alaska 

Mental Health Trust] land exchange where the Forest Service would gain 

approximately 1,105 acre[s], but the majority of this land has already 

been harvest and of little value to this [productive old-growth] associated 

species.” In the end, the DEIS concludes:

Therefore, implementation of the proposed action alternatives will 

increase habitat fragmentation, human disturbance, and cause a loss of 

habitat, when combined with past, present, and reasonably foreseeable 

future projects. Although there would be effects on Southern red-backed 

vole habitat, they should continue to exist on Wrangell Island at current 

levels.

In stark contrast, Dr. Smith raises serious concerns regarding the 

adequacy of the Forest Service’s analysis and its unfounded conclusions 

regarding voles. He concludes that “the Forest Service needs more 

information regarding the status of the southern red-backed vole 

population on Wrangell to understand the project level effects of the 

proposed 65 million board feet old-growth timber sale project.” He 

explains:

Given the significant threats facing this endemic species and the lack of 

a habitat model or proxy, it is impossible to assess whether a project 

adversely (or even irretrievably) affects these voles if one does not have 

a benchmark population estimate before the project is implemented.
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The Forest Service has relied on Dr. Smith’s expertise regarding 

endemics since the forest plan’s inception. The agency must respond to 

his concerns in the FEIS. The agency must conduct a population survey 

or, at minimum, justify its decision to proceed with the Wrangell Island 

Project despite lacking essential information regarding these voles. As it 

stands, the agency’s assessment of project-level effects raises both 

NEPA and NFMA infirmities. 

The Wrangell Island Project also raises significant concerns regarding 

the Forest Service’s ability to ensure the viability of the southern redbacked vole, and the Wrangell Island subspecies, on the Tongass. As an 

initial matter, the DEIS does not explain whether the agency has 

concluded it can approve the Wrangell Island Project and still ensure the 

viability of this vole on the Tongass, including the Wrangell Island 

subspecies. The DEIS only concludes that the agency believes these 

voles should continue to exist at the current, albeit unknown, level. 

Dr. Smith expresses specific concerns regarding the agency’s ability to 

ensure the viability of these voles:

[G]iven the extremely small geographic footprint that these voles inhabit, 

the lack of any population information, the substantial amount of oldgrowth habitat on Wrangell that has already been logged, and the 

additional loss of old-growth from the proposed Wrangell Island timber 

sale, I conclude the Wrangell Island Project raises significant viability 

concerns regarding the future of this endemic vole on the Tongass.

Notably, the FEIS for the 2008 Amended Forest Plan affords no 

guidance on this issue. It simply collapsed all endemic species together 

into one massive category and offered no explanation of the agency’s 

viability conclusions with regard to any particular species. It explained 

that the Forest Service concluded endemics faced the lowest overall 

likelihood of all species-specific effects. The agency, however, never 

analyzed whether losing these voles on Wrangell or even threatening to 

lose them on Wrangell raises a viability concerns. 

Given the agency’s admission in the DEIS that “long-term viability of 

these endemic populations is unknown, but of increasing concern” and 

the agency’s paltry conclusion that the southern red-backed vole “should 

continue to exist” (albeit at unknown levels), the Wrangell Island Project 

fails to meet the mandates of NEPA or NFMA. 
BAppendix

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058-SEACC32B. Marten

The DEIS explains that “[t]he Wrangell Island Project is within the 

Wrangell/Etolin Island Bio-geographic Province, which is considered a 

high-risk province for marten habitat.” It also acknowledges that 

“ADF&G does not have population data for marten on Wrangell Island or 

within [Game Management Unit] 3.” The agency, however 

acknowledges “the past nine decades of population decline in [Game 

Management Unit] 3.”

The DEIS, however, fails to disclose that Richard Lowell (ADF&G area 

wildlife management biologist for Game Management Unit 3), expressed 

specific concerns regarding the status of marten on Wrangell:

After reviewing the [Wrangell Ranger District] road density information 

provided by Melissa Cady, and following subsequent GIS analysis, the 

department has identified two islands within the [Wrangell Ranger 

District] where existing road conditions (no action alternative) give rise to 

concerns about the potential for excessive marten mortality. These 

include Wrangell Island and Zarembo Island.

. . . 

In the case of Wrangell Island our concerns center in large part on the 

fact that approximately 61 percent of the island’s overall land area 

(including portions of some nondevelopmental LUDs) remain accessible 

within 0.9 miles of existing roads. Based on extensive marten research 

conducted in similar habitat on Chichagof Island, the limited amount of 

refugia on the south and east sides of Wrangell Island is likely to support 

at most a dozen or so marten home ranges. The combination of high 

road density, limited amounts of roadless refugia, and the potential for 

high trapping pressure give rise to concerns about the potential for 

overharvest of marten. While the marten population on Wrangell Island 

may not go extinct in the short term there is potential for the island’s 

marten population to become severely depressed. Systematic surveys 

would be extremely valuable for better evaluating population status and 

monitoring mortality rates of marten on Wrangell Island. 

Lowell made it clear that although “the concerns expressed here center 

in large part on relatively high road densities and limited amounts of 

roadless refugia for martens, reductions in carrying capacity associated 

with the loss of old growth habitat also represent a contributing factor.”

The Wrangell Island Project included a thorough analysis on the 

effects from the alternatives on marten. These are presented in

chapter 3 of the EIS and the Wildlife Biological Evaluation. 

The Wrangell Island Project is in full compliance with FEPA and 

NFMA. 

Effects to marten are presented in the wildlife section of chapter

3 of the EIS and in the Wildlife Resource Report, including input 

from ADF&G. 

Richard Lowell, ADF&G biologist stated the following regarding 

marten in GMU 3: the only regulatory mechanisms that ADF&G 

can enact is closing the season by emergency order. For that 

reason maintaining unroaded refugia for martens is very 

important. In GMU 3, there has been one closure do date. In the 

fall of 2008 the Board of Game closed the trapping of the Kuiu 

marten because of low numbers. The remainder of GMU 3 

furbearer populations appear to be abundant or common and 

remain stable in suitable habitat (Lowell 2014). Although trapping 

effort tends to be high near those communities with established 

road systems, GMU-wide, trapping effort is moderate. Harvest is 

likely below sustained yield potentials in much of the GMU. 

Large areas of noncoastal habitat in unroaded portions of the 

GMU 3 islands remain untrapped, and provide refugia for 

furbearer populations (Lowell 2014). 

The letter referenced here is from Lowell, ADF&G in 2007. 

Marten was evaluated as part of Wrangell Island Project (Wildlife 

Resource Report), however comments on marten viability across 

the Forest are outside the scope of this project analysis. It should 

be noted that there has never been a recommendation to close 

the marten trapping on Wrangell Island. 

All action alternatives would have moderate direct and indirect 

effects to marten individuals and/or habitat because of the 

removal of potential habitat and increased motorized access. 

Two primary activities have been identified as affecting marten 

habitat: timber harvest below 1,500 feet (especially in highvolume POG forest) and increases in open motorized access. 
Appendix B

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The DEIS fails to disclose the opinions of this expert, including his 

concerns regarding the possibility of extinction of marten on Wrangell 

Island. The DEIS also ignores the fact that he recommends a population 

survey to determine the marten population and mortality rates. The 2008 

Amended Forest Plan directs that: “If existing information is lacking, 

surveys for endemic mammals may be necessary prior to any project 

that proposes to substantially alter vegetative cover (e.g., road 

construction, timber harvest, etc.). Surveys are necessary only where 

information is not adequate to assess project-level effects.” Here, the 

ADF&G area wildlife management biologist for Game Management Unit 

3 has called for such a survey, but the Forest Service ignores that 

recommendation without explanation. The agency must respond to these 

concerns and conduct the necessary survey work to understand the 

adverse impacts the Wrangell Island Project would have on marten. To 

do otherwise, the agency would act contrary to NFMA, the 2008 

Amended Forest Plan, and NEPA. 

The Wrangell Island Project raises additional NFMA infirmities. It fails to 

comply with the 2008 Amended Forest Plan, which directs the agency “to 

provide and conserve habitat to assist in maintaining long-term 

sustainable marten populations.”

The agency fails to explain whether the marten population is, and will be, 

sustainable after the Wrangell Island Project. Instead, the agency simply 

offers the unsupported conclusion: “Although there are effects to martins 

[sic], they would still continue to persist on Wrangell Island.” Persistence 

is not the threshold established in the 2008 Amended Forest Plan. 

Additionally, the Forest Service fails to explain how it is ensuring the 

viability of the marten in light of the various subspecies and their 

differential distribution across the Tongass. 

For all of these reasons, the Wrangell Island Project raises serious 

NEPA and NFMA concerns regarding the project’s adverse impacts on 

marten. 

Alternatives that result in the greatest reduction in POG and 

High-Volume POG habitat would be expected to have the 

greatest effects to marten. 

Marten individuals would be directly affected through disturbance 

from harvest activities, which could result in habitat loss, 

displacement or adversely affecting young. In some regions the 

American marten is considered to be one of the most sensitive 

species to disturbances induced by timber harvesting (Cheveau 

et al. 2013). Through the removal of forest cover and old-growth 

ecosystem features such as decadent live trees and snags 

(POG), timber harvest would reduce the vertical and horizontal 

structural complexity important to marten in relation to prey 

access, denning and resting sites, escape from predation, and 

thermoregulation (Flynn and Schumacher 2001; See table 28 for 

a patch analysis by alternative). Forest fragmentation resulting 

from timber harvest may also alter patterns of occupancy, and 

movement by marten (Chapin et al 1998, Cushman et al. 2011). 

Habitat loss and fragmentation could increase individual 

movement costs, because of constrained movements, increased 

predation risk and decrease foraging efficiency (Cheveau et al. 

2013). Alternative two is expected to have the greatest impact on 

marten habitat and potentially be reduced by 4,553 acres of 

POG, 2,275 acres of HPOG at all elevation; below 1500ft. be 

reduced by 3,969 acres of POG, 2,025 acres of HPOG; below 

800ft. be reduced by 1,624 acres of POG and 797 acres of 

HPOG habitat. 

Partial cutting may have less effect on marten habitat because 

approximately 67 percent or more of the stands pre-treatment 

basal area would be retained and be utilized by martens. 

Thompson and Harestad (1994) theorized that selective logging 

that removed less than 30 percent of the basal area every 100 

years in temperate rain forests would not reduce habitat carrying 

capacity.

The project area has an extensive road system and new roads 

associated with all action alternatives as well as other forest 

management projects that would contribute to potential issues 

associated with human access and over-exploitation of marten 

along the road system. However, implementation of the Wrangell 
BAppendix

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Ranger District ATM would close or store roads in Alternatives 2 

& 5, which could mitigate some trapping effects. Project total 

road densities would not exceed 0.52 miles per square miles for 

all land and all elevation WAA 1903 (NFS lands only). There is 

no road density threshold for marten under the Forest Plan but is 

important when examining roadless refugia (Flynn et al. 2004). 

Roads are expected to have minor impact to marten individuals 

because the existing roadless refugia (roadless areas, unroaded 

OGR’s and other matrix lands) within the project area would be 

maintained under all action alternatives.

Therefore, there would be direct/indirect effects to marten 

individuals and there habitat as a result of implementing any of 

the action alternatives because of potential habitat removal. 

Alternative two is expected to have the greatest impact because 

it removes the most amount of habitat and increased road 

densities. Although, there could be moderate effects to marten 

individuals and/or habitat, Wrangell Island would still maintain 

approximately 91-96 percent of POG and 88-91 percent of 

HIGH-VOLUME POG; below 1500ft. there would be 90-93 

percent of POG and 88-92 percent of HIGH-VOLUME POG; and 

below 800 feet there would be 93 to 96 percent of POG and 91 

to 96 percent of HIGH-VOLUME POG.

Cumulatively on all land ownerships there is approximately 78 

percent of the original (historic 1954) POG habitat remaining at 

all elevation within the project area WAA. Critical winter (deep 

snow) marten habitat (HIGH-VOLUME POG below 800 feet

elevation) there is currently 17,734 acres which is 60 percent of 

the original 1954 historic acres. All action alternatives would 

further reduce the amount of habitat available for martens. The 

greatest impact is from Alternative 2 which would decrease 

critical winter habitat by an additional 4 percent. Therefore 

implementation of the action alternatives would contribute to 

cumulative effects, through the loss of travel corridors, denning 

and hunting sites, and decrease their ability to avoid predators. 

Although, there could be effects to marten individuals and/or 

habitat, Wrangell Island would still maintain approximately 78-81 

percent of historic POG and 60-63 percent of historic HighVolume POG; below 1500ft. there would be 75-77 percent of 

POG and 59-61 percent of High-Volume POG; and below 800ft 
Appendix B

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there would be 73-75 percent of POG and 56-58 percent of HighVolume POG.

Therefore, implementation of all action alternatives would have 

cumulative effects to martens or their habitat when combined 

with past, present and reasonably foreseeable projects with the 

implementation of the Wrangell Island TS. Despite cumulative 

effects, Wrangell Island would continue to provide available 

habitat and martens would continue to persist. Furthermore, the 

American marten is now recognized to use a wide variety of 

forest habitats, contrary to previous views that the marten was a 

strict specialist of old coniferous forest. Martens have been found 

to use partial cuts in Maine, second-growth forests in Ontario, 

and plantations in New Brunswick, such patterns of habitat 

selection that vary across regions clearly show that habitat loss 

caused by timber harvesting may lead to different space use 

strategies following forest management (Cheveau et al. 2013).

The Wrangell Island Project is in full compliance with NEPA and 

NFMA. Comments on marten viability across the Forest are 

outside the scope of this project analysis.

058-SEACC33VII. BEARS 

The DEIS fails to adequately evaluate impacts from the Wrangell Island 

Project on black bears given the adverse impacts of logging and road 

construction. The DEIS also ignores the fact that ADF&G has expressed 

repeated and significant concern regarding the loss of old-growth habitat 

in Game Management Unit 3. For example in 2014, ADF&G biologists 

explained:

We remain concerned about the extensive habitat changes occurring 

throughout the unit due to logging. [ADF&G] has estimated that of the 

3,000 mi2 of terrestrial habitat in Unit 3, about 1,500 mi2 is forested. 

More than 129,000 acres of forested habitat in Unit 3 have been logged 

to date. As a result, timber harvest poses the most serious threat to 

black bear habitat in the unit over the long term. Black bears are able to 

exploit increases in forage in early-successional plant communities 

immediately after logging and may temporarily benefit from clear-cutting. 

However, this food source is lost approximately 20-25 years postlogging 

with canopy closure, and second-growth forests provide little bear 

habitat. Precommercial thinning and pruning of and second-growth 

The Wrangell Island Project included a thorough analysis on the 

effects from the alternatives on bears in GMU 3. These are 

presented in chapter 3 of the EIS and the Wildlife Biological 

Evaluation and Wildlife Resource Report. The best available and 

scientific information was used in the analysis. Road density 

effects were calculated at the WAA scale using all elevations.

The Wrangell Island Project will be consistent with the Forest 

Plan. 

The concerns identified by ADFG in the 2011 “Interagency 

Biologist Review of the Old-Growth Reserve in the Wrangell 

Island Timber Sale Project Area” were considered in the 

analysis. That report and its 2013 addendum can be found in the 

Wrangell Island Project Record. It should be noted that the 

concerns described are specific to other islands. ADF&G has not 

identified any concerns specific to Wrangell Island.
BAppendix

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stands can extend the short-term benefits to bears, but the long-term 

effects of logging will be detrimental. Large clearcuts on Mitkof, 

Wrangell, and Kupreanof Islands will diminish in value as bear habitat 

over the next few decades (Suring et al. 1988). The proliferation of roads 

associated with logging is also of concern as roads increase human 

access and make bears increasingly vulnerable to harvest. 

ADF&G’s experts pointed to the decline in bear harvest, as a troubling 

indicator of the bear population in Game Management Unit 3: 

Unit 3 hunter harvests ranged from 177 to 185 bears annually during this 

report period. The average annual harvest of 181 bears annually during 

this report period was well below the preceding 10-year average (RY00–

RY09) of 229 bears annually. The 177 bears killed by hunters in RY10 

represent the second lowest annual harvest since the 1992–1993 

season.

ADF&G’s concerns, however, go beyond the decline in the total numbers 

of bears being killed. For example, the bears are smaller: “During this 

report period, the average male skull size ranged from 17.8 inches to 

18.1 inches, well below the management objective of 18.5 inches (Table 

3).” Further, “[t]he average age of harvested males . . . was below the 

preceding 5-year average.” The male to female ratio of over 4:1 was 

above the management objective of 3:1.

These concerns led ADF&G to conclude: 

Timber harvest continues to pose the most serious threat to black bear 

habitat in the unit. Clearcut logging reduces habitat diversity associated 

with old growth forests and eliminates denning trees. Although 

postlogging increases in berry production, primarily Vaccinium sp., may 

contribute to short-term bear population growth, this forage source will 

be lost as second growth stands regenerate and the canopy closes. 

Roads associated with logging increase human access and can make 

bears increasingly vulnerable to harvest. The long-term effects of logging 

will be detrimental to black bears. Roads associated with logging 

increase human access and can make bears increasingly vulnerable to 

harvest.

ADF&G identified the need for more research to better understand the 

impacts of logging on the black bear population: 

[T]o ensure that the bear population is managed on a sustained yield 

basis, additional research is needed to estimate the black bear 
Appendix B

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population in the unit, particularly on Kuiu and Kupreanof Islands. . . . . A 

better understanding of the short- and long-term impacts of clearcut 

logging on black bear populations is needed.

. . . 

In light of a declining harvest trend and growing concern about a 

potential population decline, ensuring that black bear populations are 

managed within sustainable harvest limits will remain a formidable 

challenge for wildlife managers.

The DEIS fails to acknowledge any of ADF&G’s concerns. 

The Forest Service also failed to conduct additional research to 

understand the adverse consequences of the historical and continued 

logging on Wrangell Island. Indeed, the DEIS section on impact on bears 

only cites two scientific studies and one of them is from 1976. 

Simply put, the DEIS’s analysis of the impacts on bears is unacceptable. 

Finally, the DEIS explains that “[p] referred habitats by bears, which 

include coastal, estuarine, and riparian areas, are protected by the 

Forest Plan conservation strategy. These areas support salmon which 

are an important component to a bear’s diet.” The DEIS, however, does 

not disclose that the Forest Service’s proposed amendment to the 2008 

Amended Forest Plan will eliminate many of those key conservation 

measures. The Forest Service must conduct this analysis and describe 

the resulting impacts on bears in the FEIS. 

With regard to NFMA, the Forest Service must update its analysis and 

conduct the necessary research that ADF&G recommended before it 

approves logging even more old-growth habitat. To do otherwise, the 

agency would violate NFMA and the other statutes governing the agency 

obligation to balance wildlife protection with logging objectives. 

058-SEACC34VIII. QUEEN CHAROLETTE GOSHAWKS

The DEIS wholly fails to disclose or examine the serious risks to 

goshawks on the Tongass, either the pre-existing risks or the ways in 

which the various alternatives would aggravate them, in any fashion that 

would alert the public or decision-makers to them. In fact, the DEIS 

offers only two paragraphs to describe the goshawks’ biological and 

ecological needs. As explained below, it also fails to reference most of 

The Wrangell Island Project included a thorough analysis on the 

effects from the alternatives on goshawks. These are presented 

in chapter 3 of the EIS, the Wildlife Resource Report and the 

Biological Evaluation. 

The effects are estimated based on nesting, fledging, and 

foraging habitats.
BAppendix

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the scientific literature discussed in this section of the comment letter. 

The FEIS must correct these deficiencies. 

A. Goshawks Depend On Old-Growth Forest Habitat.

Goshawks are associated with, and well-adapted to, specific forest 

environments, and the prey that inhabit them. They “have broad short 

wings and a long tail, which enable rapid acceleration and agile 

maneuverability . . . .” They “hunt by alternating short flights with a 

period of watching from a perch. Once prey is spotted, an attack is 

launched from the perch . . . . This method of hunting relies on cover to 

conceal the predator’s approach, perches from which to observe and 

attack, adequate visibility for spotting prey, and adequate space between 

trees to allow for flying between perches and attacking prey.” Canopy 

cover also protects goshawks and their nestlings from avian predators 

such as great horned and barred owls, and bald eagles. 

Importantly, in Southeast Alaska, goshawks are associated with a very 

particular forest type: “very highly to moderately productive old-growth 

forest” (250 years old or older). Nests are “typically located in tall trees, 

within high-volume forest stands with relatively high canopy cover.” 

They spend significantly less time in low productivity forest 

(approximately nine percent) and actively avoid clear-cuts, nonforested 

areas, and mature sawtimber (approximately 75- to 150-year old stands). 

“The amount and distribution of productive old-growth forest (especially 

the moderate to very high volume components), mature sawtimber, and 

riparian and beach zones are likely to set a limit on goshawk distribution 

and abundance.”

More specifically, as noted goshawk expert, Dr. Smith explained in his 

comments on the Draft Amended Forest Plan, “three critical spatial 

components of the nesting home range have been characterized: nest 

area, post-fledging family area (PFA), and foraging area.” Goshawk 

pairs have multiple nest areas (two to eight) and use nest areas for more 

than a year, but they can be used intermittently for decades. Experts 

recommended the breeding home range of each goshawk pair have at 

least three nest areas, as well as three replacement nest areas. Postfledging family areas are portions of the breeding home ranges used by 

adults and juveniles after young birds leave the nest. These areas must 

afford young birds protection from predators and sufficient prey to 

sustain them as they develop. These areas “should have overstories with 

at least 50 percent canopy cover and well-developed herb and shrub 

Impacts to goshawks are assessed in terms of the reduction in 

total POG, which provides general habitat requirements 

especially foraging POG (all SD classes) habitat and High POG 

(SD 5N, 5S & 6/7) which represents optimal nesting habitat due 

to the presence of large-trees and snags. Reductions in forest 

cover, and the subsequent progression of forest succession of 

young-growth stands, also have the potential to affect the 

abundance and availability of prey. This may cause goshawks to 

increase their breeding home range size in order to gather 

sufficient prey to raise young (McClaren 2004). Additionally, if 

timber harvest reduces the proportion of the landbase consisting 

of POG and mature young-growth forest to below 50 percent, 

this could result in portions of the landscape becoming marginal 

or unsuitable for goshawks. Therefore, alternatives that harvest 

the most POG and reduce the proportion of the landscape 

consisting of mature high POG, would be expected to have the 

greatest effect on goshawks. All action alternatives would 

maintain at least 91 percent of the existing total POG within FS 

lands in WAA 1903 and maintain a minimum of 88 percent high 

POG (tables 10 & 11). At the VCU scale the most impacted is 

VCU 4750 maintaining a minimum of 82 percent of foraging 

habitat and 74 percent of optimal nesting habitat.

All of the action alternatives propose a high level of uneven-aged 

management prescriptions, up to 2/3 of the acres proposed for 

harvest. This will maintain the uneven-aged stand structure and 

may even enhance the foraging area by allowing more openings 

for flight and slash for small prey.
Appendix B

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understories, as well as key habitat features essential to the life histories 

of the goshawk prey species.” Goshawks’ foraging habitat must support 

a variety of prey species, requiring “an uneven-aged silvicultural system, 

which produces a mosaic of different-aged stands . . . rather than 

regeneration harvest, such as clear-cuts, that remove the entire canopy 

and result in a single, uniform and dense canopy for decades following 

harvest.” Goshawks foraging areas reflects the majority of breeding 

home range. Each of these three types of habitat “need[s] to be 

considered simultaneously in land-use planning or mitigation.”

The DEIS fails to address any of these considerations. The FEIS must 

correct these failings. 

058-SEACC35B. A Multitude of Factors Threatens the Viability of Goshawks 

Throughout Southeast Alaska.

As explained below, goshawks in Southeast Alaska are at risk from both 

natural and anthropogenic factors, described below, that have resulted in 

extremely large territories, presumed increased risk factors, and low 

goshawk numbers.

1. Goshawks have come to depend upon large territories in the 

region.

In Southeast Alaska, a combination of factors, including low prey 

abundance, natural fragmentation (by ice fields, muskeg bogs, steep 

terrain, and scattered islands), and past “highgrading” (disproportionately 

logging of higher volume forest stands) has forced goshawks into larger 

foraging territories than anywhere else in North America. Breedingseason home ranges average 4,500 hectares (11,120 acres) for 

females, and 5,900 hectares (48,200 acres) for males. One male 

breeding season use area was radio-tracked nearly 19,500 hectares 

(47,000 acres). By contrast, in the rest of North America, breedingseason ranges average between 570 and 3,500 hectares. Year-round 

use areas in Southeast Alaska are vast, averaging nearly than 16,000 

hectares (up to 67,000 hectares) for males, and more than 50,000 

hectares (up to 180,000 hectares) for females. 

As the U.S. Fish and Wildlife Service (USFWS) has noted, the energy 

expenditure associated with having to seek prey over such enormous 

areas poses a serious threat to goshawks in Southeast Alaska:

The Wrangell Island Project included a thorough analysis on the 

effects from the alternatives on goshawks. These are presented 

in chapter 3 of the EIS, the Wildlife Resource report and the 

Wildlife Biological Evaluation. 

The viability of goshawks is a Forest Plan issue and is outside of 

the scope of this project analysis. A viability assessment of 

goshawks was conducted for the Tongass National Forest Plan 

revision in 1997. This was subsequently reviewed in 2008 and 

2016 Forest Plan Amendment. In order to strengthen the 

protection for goshawk habitat, specific standards and guidelines 

were added or modified to all three versions of the Forest Plan.

Our analysis appropriately addressed spatial considerations 

through nest and POG protection immediately around known 

territories.

Effects to goshawks are assessed in terms of the reduction in 

total POG, which provides general habitat requirements 

especially foraging POG habitat (all SD classes) and High POG 

(SD 5N, 5S & 6/7) which represents optimal nesting habitat due 

to the presence of large trees and snags. Reductions in forest 

cover, and the subsequent progression of forest succession of 

young-growth stands, also have the potential to affect the 

abundance and availability of prey. This may cause goshawks to 

increase their breeding home range size in order to gather 

sufficient prey to raise young (McClaren 2004). Additionally, if 

timber harvest reduces the proportion of the landbase consisting 
BAppendix

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Comment 

Number Comment Response

Physiologically, foraging is a trade-off between the energy expended to 

acquire food and energy derived from its acquisition. The energetic 

demands of foraging increase with distance traveled. The thresholds for 

individual survival and for supplying food to nestlings and a brooding 

mate in this energy balance are unknown, but habitat alteration that 

decreases foraging efficiency will push individuals and broods toward 

that threshold.

As foraging ranges increase during the breeding season, the likelihood 

of reproductive success is adversely affected. “Longer travel distances 

during foraging increase . . . the probability that adults may abandon 

nests.” A Forest Service report concluded more than 15 years ago that 

“The very large areas used by goshawks in southeast Alaska may lead 

to high energy expenditure during daily movements. . . . [P]opulations of 

individuals requiring large ranges may be energetically stressed, have 

lower reproductive success, and be less resilient to further stress . . . .” 

Outside of the breeding season, range expansion is associated with 

increased risk of death. “Mortality of both male and female adult 

goshawks in Southeast Alaska was highest in late winter, when food 

availability is lowest” and ranges tend to be at their largest. 

Again, the DEIS fails to address these spatial considerations. The FEIS 

must correct this failing. 

2. Tongass Goshawks are a small, isolated, and declining 

population. 

A second major threat to goshawks in Southeast Alaska, partially related 

to the phenomena discussed above, is the fact that they comprise a 

small, potentially genetically isolated, and almost certainly declining 

population. As USFWS has noted, Queen Charlotte goshawks exist in an 

inherently precarious status, highly vulnerable to any further stresses. 

“Given the small populations, low survival or reproductive rates could not 

be sustained long before viability of the subspecies would be at risk.” 

USFWS has estimated that there are only approximately 300 to 400 

pairs of goshawks remaining in the region (about the same number as in 

British Columbia, which USFWS determined to be a distinct population 

segment and threatened within the meaning of the Endangered Species 

Act). USFWS has also determined that the Southeast Alaska population 

is largely isolated, because it appears to be cut off from both the Queen 

Charlotte Islands to the south (by open ocean), and the British Columbia 

mainland to the east (by the Coast Range mountains). 

of POG and mature young-growth forest to below 50 percent, 

this could result in portions of the landscape becoming marginal 

or unsuitable for goshawks. Therefore, alternatives that harvest 

the most POG and reduce the proportion of the landscape 

consisting of mature high POG, would be expected to have the 

greatest effect on goshawks. All action alternatives would 

maintain at least 91 percent of the existing total POG within FS 

lands in WAA 1903 and maintain a minimum of 88 percent high 

POG (tables 10 & 11). At the VCU scale the most impacted is 

VCU 4750 maintaining a minimum of 82 percent of foraging 

habitat and 74 percent of optimal nesting habitat (Wildlife BE/BA 

p34).
Appendix B

Wrangell Island Project FEIS ♦ 177

Comment 

Number Comment Response

In fact, the USFWS figure likely overstates the number of reproductive 

pairs in Southeast Alaska, putting local birds in an even worse position 

than the agency reports. USFWS based its population estimate on 

studies done by Schempf and Woods (2000) and Flatten et al. (2001). 

Schempf and Woods estimated that the Tongass National Forest 

contained between 580 and 747 nesting territories. Flatten et al. (2001) 

used broadcast and telemetry surveys to determine that, on average, 

approximately 45 percent of nesting territories are occupied in any given 

year. Applying Flatten’s territory occupancy rate to Schempf and Woods’ 

total territories, the USFWS estimated that, as of 2000, there were 

approximately 261 to 336 breeding pairs in the Tongass National Forest. 

Though it did not explain its methodology, the USFWS then extrapolated 

this range to estimate that approximately 300 to 400 pairs of goshawks 

occupied Southeast Alaska. 

However, much of the area that Schempf and Woods categorized as 

goshawk habitat, very likely would not support breeding birds. They 

considered hypothetical territories with as little as 20 percent of the land 

area in old-growth forest as “suitable.” In contrast, both the Goshawk 

Conservation Assessment and Doyle concluded that, to be suitable, at 

least half of a bird’s territory probably needed to be covered in oldgrowth forest. The Forest Service appears to accept these conclusions in 

principle. 

Thus, applying a more realistic habitat parameter would necessarily have 

led Schempf and Woods to a much lower estimate of the theoretical 

maximum number of suitable territories, and the USFWS to a much 

lower estimate of actual breeding pairs. A lower number would also be 

more consistent with a recent USFWS estimate for breeding pairs in 

Canada. In discussing its decision to list Queen Charlotte goshawks in 

British Columbia as threatened, USFWS estimated that, as of 2008, 

there were about 352 to 374 pairs of goshawks throughout the British 

Columbia (B.C.) distinct population segment (DPS). However, the B.C. 

DPS inhabits twice as much productive old-growth forest (5.7 million ha) 

as the Southeast Alaska DPS (2.2 million ha). It is not biologically 

plausible that half as much suitable habitat, in Southeast Alaska, would 

support as many pairs of the same subspecies as are found in 

neighboring and ecologically similar B.C. A substantially lower 

reproductive population would also be more consistent with Crocker-
BAppendix

Wrangell Island Project FEIS ♦ 178

Comment 

Number Comment Response

Bedford’s 1994 estimate that there were at the time 100-200 breeding 

pairs of goshawks in all of Southeast Alaska. 

Further, due to continued logging of old-growth, it is highly probable that 

the Southeast Alaska population is getting smaller. The Tongass 

National Forest reported having logged 6,996 acres between fiscal years 

2007 and 2012. And in addition to federal logging, habitat liquidation on 

other holdings has been considerable. Compounding this problem, even 

if all old-growth logging in all of Southeast Alaska stopped today, the 

goshawk population would probably still continue to decline given lag 

times in population responses, particularly if a viability threshold has 

been crossed. As USFWS has explained, “goshawk populations may 

continue to decline for several years after logging of old growth forests 

has ceased and timber harvest is restricted to second-growth stands 

because it is likely to take several generations for the populations to 

equilibrate with their modified environments.” 

The DEIS fails to evaluate the consequences of the Wrangell Island 

Project on the population of goshawks on Wrangell Island in any credible 

way. It asserts:

Cumulative reductions in nesting and foraging habitat on Wrangell Island 

could result in the local expansion of individual goshawk home ranges, 

potentially leading to a reduction in breeding density. Effects would be 

greatest under Alternative 2. However, given that goshawks are highly 

mobile and that breeding density is currently low on the Tongass 

National Forest, the effects of the Wrangell Island Project in combination 

with past, present, and foreseeable activities would result in effects to 

goshawks on Wrangell Island. Wrangell Island would continue to provide 

suitable habitat and the Queen Charlotte goshawk would continue to 

persist at current levels.

The Forest Service’s suggestion that “the effects of the Wrangell Island 

Project in combination with past, present, and foreseeable activities 

would result in effects to goshawks on Wrangell Island” is remarkable for 

its failure to provide any useful information or conclusion. It is also 

completely unsubstantiated to implicitly admit the agency does not know 

the current population of goshawks on Wrangell Island, but then claim 

that unknown population should continue to persist. The FEIS must 

correct these fundamental failings. 

058-SEACC36C. The DEIS Does Not Disclose the Cumulative Impacts on 

Goshawks Given the Agency’s Plan to Amend the Forest Plan.

The Wrangell Island Project included a thorough analysis on the 

effects from the alternatives on goshawks. These are presented 
Appendix B

Wrangell Island Project FEIS ♦ 179

Comment 

Number Comment Response

In assessing cumulative impacts, the DEIS fails to consider the impacts 

caused by the significant changes proposed in the newly released 

Amended Forest Plan.

The 2008 Amended Forest Plan classifies areas within the beach and 

estuary fringe “as unsuitable for timber harvest.” It establishes several 

important objectives regarding these areas: 

4. To maintain an approximate 1,000-foot-wide beach fringe of 

mostly unmodified forest to provide important habitats, corridors, and 

connectivity of habitat for eagles, goshawks, deer, marten, otter, bear, 

and other wildlife species associated with the maritime-influenced 

habitat. Old-growth forests are managed for near-natural habitat 

conditions (including natural disturbances) with little evidence of humaninduced influence on the ecosystem. 

5. To maintain an approximate 1,000-foot-wide estuary fringe of 

mostly undisturbed forest that contributes to maintenance of the

ecological integrity of the biologically rich tidal and intertidal estuary 

zone. Habitats for shorebirds, waterfowl, bald eagles, goshawks, and 

other marine-associated species are emphasized. Old-growth conifer 

stands, grasslands, wetlands, and other natural habitats associated with 

estuary areas above the mean high tide line are managed for nearnatural habitat conditions with little evidence of human-induced 

disturbance. 

The Forest Service concluded that the “beach fringe was a very key 

feature of the overall Tongass conservation strategy,” particularly with 

regard to goshawks. As Chris Iverson, the author of Appendix N to the 

1997 FEIS, explained:

The most compelling argument for this extended beach fringe is that this 

zone of 1000 feet from the shoreline is a landscape region significantly 

selected by goshawks, for foraging we presumed, during our habitat 

selection analysis (see Goshawk [Conservation] Assessment, Figure 9, 

pages 52-53). When the leadership (Forest Supervisors, RF, IDT 

Leader) were presented with this graph and statistic -the decision was 

made to extend the beach fringe to 1000' to provide additional risk 

reduction and confidence in goshawk conservation to contribute to a not 

warranted decision by the FWS for the listing petition that they were 

considering at the time.

in chapter 3 of the EIS, the Wildlife Resource Report and the 

Wildlife Biological Evaluation. 

The cumulative effects analysis was conducted at the WAA scale 

(WAA 1903, specifically), and the timeframe was established as 

15 years, which is the generally accepted lifespan of a forest 

plan and would reasonably encompass foreseeable projects. 

This has been clarified in the FEIS and Wildlife Resource Report.

Please see response to comment 058-SEACC-35.
BAppendix

Wrangell Island Project FEIS ♦ 180

Comment 

Number Comment Response

The agency’s new Amended Forest Plan deletes the portions of the 

standards and guidelines that prevented logging in the beach (and 

estuary) fringe. In their place, the agency proposes a Forest-wide 

standard that prevents most old-growth logging in these areas (with 

several exceptions that do not count towards the projected timber sale 

quantity), but now allows second-growth logging. The DEIS, however, 

fails to examine the impacts of this change on the underlying conclusions 

regarding cumulative effects on goshawks. 

The DEIS also never examines the cumulative impacts on the “three 

critical spatial components of the nesting home range:” nest area, postfledging family area, and foraging area. As Dr. Smith made clear: 

First, spatially explicit analyses of contributions to northern goshawk 

breeding-season habitat revealed that conservation measures of the 

Tongass Land and Resource Management Plan contribute about half the 

secure habitat recommended for post-fledging areas of breeding pairs in 

the southern portion of this species range (Reynolds et al. 1992) and 

was less than half the relative amount of habitat documented in nest 

areas in Southeast Alaska. A similar conclusion was obtained for the 

broader landscape (21 km2) that surrounded each nest. This is because 

much of the habitat across the landscape has been clear-cut-logged and 

half the remaining choice habitat is in the Development land-use 

designation available for timber harvest.

. . .

Secondly, guidelines developed for northern goshawk populations in the 

southwestern United States may underestimate habitat needed by 

breeding pairs in Southeast Alaska. 

. . .

In Southeast Alaska, the predominant (frequency and biomass) prey 

items during the breeding season (Lewis et al. 2006) are bird and 

mammal species that are most abundant, or occur exclusively, in 

productive old-growth forests (Iverson et al. 1996,Smith et al. 2001, 

2004, 2005). Consider further that the mammal fauna of Southeast 

Alaska is depauperate (Smith 2005); few mammal species exclusively 

occur in low-volume or managed forests of Southeast Alaska (Smith et 

al. 2001, Smith and Nichols 2004); and the structure of dense secondgrowth stands effectively renders prey unavailable to foraging goshawks 

(Reynolds et al 1992, 2006). Avian communities in managed forests 

include few, if any, additional prey for northern goshawks (Smith et al. 

2001). Thus, breeding pairs in managed landscapes of Southeast Alaska 
Appendix B

Wrangell Island Project FEIS ♦ 181

Comment 

Number Comment Response

likely rely almost entirely on productive old-growth forests as foraging 

and nesting habitat. That breeding pairs in managed landscapes of 

Southeast Alaska depend on productive old-growth forests to meet lifehistory needs was reflected in the findings of compositional analyses and 

radio-telemetry studies, both of which determined that northern 

goshawks strongly selected medium- and high-volume old-growth 

forests, and avoided recently managed or non-forested habitats 

[Goshawk Conservation Assessment].

These challenges are exacerbated by the Forest Service’s choices for 

second-growth management that are reflected in the agency’s newly 

released 2016 Amended Tongass Land Management Plan. “The 

potential for second-growth stands to become useable habitat over the 

Tongass planning horizon is limited because unmanaged second-growth 

typically requires at least 300 years following disturbance to develop oldforest features (Nowacki and Kramer 1998).” Rather than manage 

second-growth in a way that returns it to old-growth characteristics, the 

Forest Service is targeting second-growth for commercial purposes in 

critical old-growth reserves, Beach-Estuary Fringe, and Riparian 

Management Areas. As explained above, these areas were set aside as 

reserves, in part, because they represented important habitat and they 

were considered critical to the long-term viability of goshawks. 

The FEIS cannot ignore the fact that the Forest Service is poised to 

compromise fundamental elements of the goshawk conservation 

strategy. The agency must analyze those changes and the resulting 

adverse impacts

* * *

For the reasons stated above, the Wrangell Island Project accomplishes 

nothing more than miring Southeast Alaska in the destructive and 

controversial practices of industrial-scale old-growth logging. As this 

project demonstrates with vivid clarity, the Tongass timber program is 

economically and environmentally unsustainable and, as a result, the 

Forest Service should adopt the no action alternative. If the agency 

moves ahead despite the overwhelming adverse impacts, it must correct 

the deficiencies described above. 

Respectfully, 

Buck Lindekugel 
BAppendix

Wrangell Island Project FEIS ♦ 182

Comment 

Number Comment Response

Grassroots Attorney

SOUTHEAST ALASKA CONSERVATION COUNCIL

Stephen Todd

Board President

WRANGELL RESOURCE COUNCIL

Kristen Miller

Conservation Director

ALASKA WILDERNESS LEAGUE

Susan Culliney

Policy Associate

AUDUBON ALASKA

Patrick Lavin

Alaska Representative

DEFENDERS OF WILDLIFE

Holly Harris

Staff Attorney

EARTHJUSTICE

Niel Lawrence

Alaska Director

NATURAL RESOURCES DEFENSE COUNCIL

Alli Harvey

Our Wild America Alaska Campaign Rep

SIERRA CLUB

Osprey Orielle Lake

Executive Director

WOMEN’S EARTH AND CLIMATE ACTION NETWORK (WECAN)
Appendix B

Wrangell Island Project FEIS ♦ 183

Comment 

Number Comment Response

[List of documents cited removed for space considerations]

059-DOI United States Department of the Interior

OFFICE OF THE SECRETARY

Office of Environmental Policy and Compliance 1689 C Street, Suite 119

Anchorage, Alaska 99501-5126

VIA ELECTRONIC MAIL, NO HARD COPY TO FOLLOW

9043.1 July 18, 2016

ER16/0323 PEP/ANC

Andrea Slusser

Wrangell Ranger District 525 Bennett Street

P.O. Box 51

Wrangell, Alaska 99929

Subject: Notice of Availability of the Draft Environmental Impact 

Statement for the Wrangell Island Project, Tongass National Forest, 

Alaska

Dear Ms. Slusser:

The U.S. Department of the Interior (Department) has reviewed the 

subject Draft Environmental Impact Statement (EIS) for the proposed 

Wrangell Island Project, located in the Tongass National Forest in 

Southeast Alaska. We provide the following comments and 

recommendations in accordance with our authorities under the National 

Environmental Policy Act and the Fish and Wildlife Coordination Act for 

your use in developing a Final EIS and Record of Decision.

The purpose of the project is to provide timber and economic 

opportunities for the local and regional economies of Southeast Alaska. 

The Department has reviewed the various alternatives, which differ 

primarily by location of harvest units, how individual units are harvested 

(clearcut vs. partial harvest), and how specific roads would be managed 

following harvest. Below, the Department provides additional information 

and recommendations on the Draft EIS.
BAppendix

Wrangell Island Project FEIS ♦ 184

Comment 

Number Comment Response

059-DOI-10

(out of 

sequence in 

the letter)

General Comments

In scoping comments provided March 3, 2011, the Department’s U.S. 

Fish and Wildlife Service (USFWS) requested that the U.S. Forest 

Service (USFS) modify two Medium Old Growth Reserves (OGR) as part 

of the timber sale project to better comply with Tongass National Forest 

Land and Resource Management Plan standards. The USFWS also

requested that the USFS evaluate and minimize impacts to subsistence 

harvesting, wetlands, fisheries, and habitat for several wildlife species. 

The scoping comments described potential timber harvest methods and 

road management strategies to help reduce impacts of existing and 

future timber harvest.

On September 12, 2013, the USFWS responded to a second scoping 

notice for a modified version of the Wrangell Island Project. The 2013 

letter provided additional recommendations on minimizing impacts to 

deer and wolves. The USFWS also worked with the USFS and the 

Alaska Department of Fish and Game to review OGRs in the project 

area to identify alternative locations for OGRs that could provide for 

additional timber harvest while providing additional protection for forest 

habitat within Inventoried Roadless Areas. Timber harvest is currently 

not allowed in these roadless areas.

The Draft EIS generally addresses each of the topics discussed in the 

previously submitted USFWS scoping comments. In the enclosure, we 

provide additional information and recommendations to strengthen the 

Final EIS and reduce impacts to terrestrial and aquatic resources. Staff 

with the USFWS are available to discuss these recommendations and to 

assist the USFS with planning for this important project. Contact 

information is provided below.

In addition, the Department’s U.S. Geological Survey (USGS) Alaska 

Science Center has conducted additional studies on marbled murrelets 

and yellow-billed loons. We recommend that the Final EIS include 

information on these species provided in the Specific Comments (below) 

to make the EIS more complete and accurate.

Comment noted. The Wrangell Island Project does not propose 

any Forest Plan amendments, including modification of OGRs. 

Please see the Alternatives Considered but Eliminated from 

Detailed Study in chapter 2 of the EIS.

059-DOI-01 Specific Comments

The yellow-billed loon is listed as one of the USFS sensitive species in 

the Draft EIS. Chapter 3: Affected Environment and Environmental 

The reference material provided has been added to discussions 

of the yellow-billed loon in the Wildlife Resource Report. The 

cited paper has been added to the project record.
Appendix B

Wrangell Island Project FEIS ♦ 185

Comment 

Number Comment Response

Consequences, Issue 2 – Wildlife Habitat, includes a section on yellowbilled loons on page 74. The following citation could be added at the end 

of the last paragraph regarding anthropogenic disturbances, as the 

research specifically tested the influence of observer visits on nests.

Uher-Koch, B.D., J.A. Schmutz, and K.G. Wright. 2015. Nest visits and 

capture events affect breeding success of Yellow-billed and Pacific 

Loons. Condor 117(1):121-129.

Doi:10.1650/CONDOR-14-102.1.

059-DOI-02 The marbled murrelet is included on a list of species of interest in the 

Draft EIS. Chapter 3: Affected Environment and Environmental 

Consequences, Issue 2 – Wildlife Habitat, includes a section on marbled 

murrelets on page 83. The citation listed below could be added to the 

sentence: “Marbled murrelets spend most of their lives in the coastal 

marine environment in sheltered bays, fjords, leeward sides of islands, 

and island passes (Arimitsu et al. 2010, Kuletz 2005, Piatt and Nashlund 

1995), but come onshore for nesting (Hobson 1990).”

Arimitsu, M.L., J.F. Jiatt, M.D. Romano, E.N. Madison, and J.S. 

Conaway. 2010. Kittlitz’s and Marbled Murrelets in Kenai Fjords National 

Park, south-central Alaska: At- sea distribution, abundance, and foraging 

habitat, 2006-08. USGS Open-File Report 2010-1181, 68p.

The reference material provided has been added to discussions 

of the marbled murrelet in the Wildlife Resource Report and 

Wildlife section of the FEIS. The cited paper has been added to 

the project record.

Thank you for the opportunity to comment on this Draft EIS. For further 

information regarding the attached recommendations, please contact 

Steve Brockmann, Southeast Alaska Coordinator for the USFWS, at 

(907) 780-1181 or steve_brockmann@fws.gov. If you have any 

questions regarding marbled murrelets or yellow-billed loons, please 

contact John Pearce, Supervisory Wildlife Biologist for the USGS, at 

jpearce@usgs.gov or 907-786-7094.

Sincerely,

Philip Johnson

Regional Environmental Officer – Alaska

Enclosure

Enclosure: U.S. Fish and Wildlife Service Recommendations for the 

Draft Environmental Impact Statement for the Wrangell Island Project
BAppendix

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Comment 

Number Comment Response

059-DOI-03 I. Alexander Archipelago Wolf and Sitka Black-tailed Deer

Work on nearby Prince of Wales Island has demonstrated that wolf 

mortality from trapping and hunting can reach unsustainable levels 

(leading to wolf population declines) where road densities are high. 

Person et al. (1996), for example, documented a two-fold increase in 

reported wolf harvests where road densities exceeded 0.7 miles per 

square mile below 1,200 feet elevation.

Road density below 1,200 feet on Wrangell Island is currently 0.98 miles 

per square mile on U.S. Forest Service (USFS) managed lands and 1.3 

miles per square mile across all ownerships (Draft Environmental Impact 

Statement (EIS), pp. 92-93), exceeding the Tongass National Forest 

Land and Resource Management Plan (Forest Plan) guideline of 0.7 to 

1.0 miles per square mile for areas where wolf mortality concerns have 

been identified.

The U.S. Fish and Wildlife Service (USFWS) recommends that additional 

road closures be considered to maintain road densities below the Forest 

Plan guideline of 0.7 to 1.0 miles per square mile, at least on Forest 

System lands. Among the action alternatives considered, only Alternative 

5 would result in road densities lower than 1.3 miles per square mile. As 

currently configured, even Alternative 5 would exceed the guideline, 

resulting in 1.1 miles per square mile.

Deer habitat capability (a theoretical carrying capacity for deer, based on 

GIS modeling) on Wrangell Island also falls short of the 18 deer per 

square mile guideline specified in the Forest Plan for areas where deer 

are prey for both wolves and human hunters (Draft EIS, pp. 91-92). The 

USFWS notes that many of the scoping letters submitted for the project 

requested that deer habitat be protected or improved to provide for 

subsistence hunting.

Comments on recommending additional road closures and 

removing harvest units are noted. These modifications will be 

considered at the time of decision.

Please see the Wildlife section of the EIS and the Wildlife 

Resource Report for a detailed analysis of these species.

Past management has reduced deer habitat capability on Wrangell 

Island across all ownerships from 12.9 deer per mile in the year 1954 

(when industrial-scale logging began on the Tongass) to 10.9 deer per 

square mile in 2015, highlighting the need for proactive management to 

sustain and improve deer habitat for wolves and human hunters. Instead, 

the alternatives evaluated in the Draft EIS would reduce habitat 

capability further. The proposed alternative would result in habitat 

capability of 10.4 deer per square mile immediately following 
Appendix B

Wrangell Island Project FEIS ♦ 187

Comment 

Number Comment Response

implementation, with further declines as second growth forest eliminates 

deer forage produced in new timber harvest units. Ultimately, the Draft 

EIS predicts that deer habitat capability would decline to 9.9 deer per 

square mile by 2042. Other action alternatives would result in habitat 

capability ranging from 10.1 to 10.2 deer per square mile in 2042 (Draft 

EIS, p. 93).

The USFWS recommends the USFS minimize impacts to deer habitat 

capability by avoiding harvest of forest stands that are the most critical to 

deer during deep snow winters. High-volume forest stands on lowelevation, south-facing slopes are widely understood to provide the best 

combination of accessible forage and protection from deep snow and 

prolonged cold. The USFWS recommends the alternative selected 

exclude the following units from timber harvest because they include 

deep snow winter habitat: 579, 638, 666, 711, 713, 811, 814, 816, 818, 

854, 855, 866, 879, 955, and 958. These exclusions will minimize impact 

on the very limited amount of deep snow winter habitat that remains on 

Wrangell Island. If harvest in these stands is deemed necessary, the 

USFWS recommends very light selection cuts of individual trees or small 

patches of trees to create small openings that replicate natural 

regeneration of these old growth stands. The USFWS also recommends 

that other forest stands known or believed to support wintering deer, but 

that are not identified as deep snow habitat, should also be protected 

from timber harvest or treated with very light selection cuts to help 

maintain the local deer populations relying on these stands.

059-DOI-04 II. Aquatic Resources

Emergent wetlands, ponds, sloughs, watercourses, and riparian areas 

are high value habitat types where disturbance should be avoided or 

minimized. To avoid and minimize impacts to these aquatic and riparian 

habitats, the USFWS recommends that stream crossings span the full 

floodplain where possible. This approach provides long-term dynamic 

channel stability, retention of existing spawning habitats, maintenance of 

food (benthic invertebrate) production, and reduced risk of structural 

failure. To accommodate fish passage and to maintain the existing 

hydrology, culverts should be sized and installed to allow for 

establishment of pre-existing substrate, grade, and channel width. 

Alternatives may include bottomless arch culverts or embedded round or 

oval pipes.

All crossing designs should be based on site specific information, such 

as estimate of peak discharge, flow velocities and patterns, channel 

Activities within these high-value habitat types were avoided to 

the extent practicable when designing road locations. All harvest 

and road construction would comply with BMPs, Forest Plan 

standards and guidelines, and directives. All new fish bearing 

stream crossings constructed with this project in all action 

alternatives would follow handbook guidance for aquatic 

organism passage design and be completed in conformance with 

Forest Plan standards and guidelines and BMPs. 
BAppendix

Wrangell Island Project FEIS ♦ 188

Comment 

Number Comment Response

stability, suspended sediment and bedload transport, flooding regime 

(50-year to 100-year flood frequency and magnitude), cross-section 

profiles of channel morphology, and surface water elevations.

059-DOI-05 The USFWS recommends that all new construction, maintenance, or 

decommissioning of roads associated with this timber sale be performed 

utilizing techniques and best management practices that lower the risk of 

erosion and reduce the amount of materials entering streams, that 

reduce or eliminate disturbance to stream channel morphology, and that 

minimize or eliminate changes or alterations to slope drainage and runoff 

patterns.

All road construction, maintenance and road decommissioning 

would comply with BMPs and directives.

059-DOI-06 The USFWS also recommends identifying opportunities to restore 

degraded streams to productive capacity. Practices to restore degraded 

streams may include recreating the geomorphic structure and sedimentstorage capacities through various methods and techniques, including

instream placement of wood (e.g., creating natural jams), augmenting off 

channel habitats, and restoring riparian vegetation.

A few opportunities for stream restoration or enhancement have 

been identified in chapter 1. These efforts could be included in 

stewardship projects and considered in a future NEPA analysis.

059-DOI-07 III. Old Growth Reserves

A previous version of this Draft EIS included action alternatives that 

would have increased timber availability or improved wildlife habitat 

protection through modification of Old Growth Reserves (OGRs). Such 

alternatives have been eliminated from detailed study in this Draft EIS 

because modifying OGR boundaries would require a minor Forest Plan 

amendment, and the Forest Plan is currently being amended to 

accelerate transition to primarily second growth harvest. An amended 

Forest Plan (USFS 2016a) and draft Record of Decision (USFS 2016b) 

are currently available for public review. The amendment is narrowly 

focused and does not consider modifications to OGR boundaries 

(although it does propose to modify how second growth stands within 

OGRs may be harvested).

Comment noted. 

The analysis considered potential modifications to boundaries 

and locations. This included the biologically preferred option 

developed by the interagency team, as well as an option to 

maximize the amount of the OGRs in inventoried roadless areas 

to allow for more timber harvest; however, these were not carried 

forward in the alternatives. See the Alternatives Considered but 

Eliminated from Detailed Analysis in the FEIS.

Also see appendix K of the 2016 Forest Plan and appendix D of 

the 2016 Forest Plan FEIS.

Many timber sale decisions since 1997 have modified OGR boundaries 

to improve compliance with Forest Plan guidance. As part of the 

environmental analysis for the Wrangell Island Project, an interagency 

team of biologists from the USFS, Alaska Department of Fish and Game, 

and USFWS reviewed OGRs in the project area and identified potential 

modifications to two Medium OGRs to bring them into compliance with 

Forest Plan standards for size and composition.

Based on this interagency review, the USFWS recommends that the 

Final EIS evaluate modification of the Thom’s Medium OGR in Value 

The only modifications to OGRs that were considered in the 

2016 Forest Plan Amendment analysis were those affected by 

the Sealaska land transfer (2016 Forest Plan Amendment FEIS, 

appendix E). Also, the conservation strategy as a whole was 

reviewed and documented in the 2016 Forest Plan Amendment 

FEIS, appendix D. The old-growth modification process remains 

the same as stated in the 2016 Forest Plan, appendix K.

The modifications of small OGRs after the 1997 Forest Plan 

revision decision was expected since they did not receive a 
Appendix B

Wrangell Island Project FEIS ♦ 189

Comment 

Number Comment Response

Comparison Units 4780 and 4790, as described in the wildlife resource 

report for the Wrangell Island Project (USFS 2016c). This reserve is 

currently deficient in size, lacking approximately 700 acres of the 

required 2,500 acres of high-volume old growth (USFS 2016c, Table 15, 

p. 40). The recommended modification would add the necessary acres of 

high-volume forest south and east of road 6299 adjacent to the existing 

OGR.

thorough review before the decision. This was done with a series 

of modification through project-level analyses. These 

modifications were incorporated into the 2008 Forest Plan 

Amendment Decision. Also during the analysis for the 2008 

Forest Plan amendment, the entire network of small OGRs was 

reviewed and reconfiguring based on an interagency review to 

increase habitat protection. The Sealaska land transfer affected 

several old-growth reserves identified in the 2008 Plan. These 

were analyzed and modified following the Forest Plan, appendix 

K and disclosed in the 2016 Forest Plan Amendment, appendix 

E and on the LUD map.

It should also be noted that about 61 percent of the National 

Forest on Wrangell Island is now within IRAs or OGRs, neither of 

which generally allow old-growth timber harvest. 

059-DOI-08 The USFWS also recommends that the Fool’s Medium OGR be modified 

to correct deficiencies in both productive old growth acreage (1,086 

acres short) and high-volume old growth (572 acres short) (USFS 2016c, 

Table 15, P. 40). The USFWS concurs with interagency team 

recommendations for this OGR, which would connect the Fool’s Medium 

OGR to the Earl West Small OGR along Fool’s Creek. This modification 

would preserve existing habitat connectivity and low-elevation, deep 

snow deer habitat (Draft EIS, Figure 14, p. 81).

Comment noted. Please see response to comment 059-DOI-07.

059-DOI-09 The USFWS recommends that the selected alternative include both of 

these Medium OGR modifications to help protect remaining habitat for 

deer and other species on Wrangell Island, portions of which have been 

previously logged.

Comment noted. Please see response to comments 059-DOI-01 

and -07.

060-TH-01 With regards to the Wrangell Island Project EIS I am supporting the No 

Action alternative.

A small island such as the Wrangell Island does not need additional 

forest roads. It is my understanding that old growth will be cut by the 

proposed timber sale. I am vehemently opposing that option. Cutting oldgrowth is a destructive process with long-term impact, especially on 

islands. In the big picture of economy, timber sale from this island is 

irrelevant. The impact on fauna and flora of an old-growth cut in such a 

confined and isolated space is disproportional.

Please opt for the No Action alternative.

Your support of the no action alternative is noted.
BAppendix

Wrangell Island Project FEIS ♦ 190

Comment 

Number Comment Response

Thank you, Thomas Hartmann

resident of Skagway, AK

061-GSACC Greater Southeast Alaska Conservation Community (GSACC)

Cascadia Wildlands

Greenpeace

The Boat Company

Peter Branson

Center for Biological Diversity

July 18, 2016

Dave Beebe

Greater Southeast Alaska Conservation Community

P.O. Box 6064 Sitka, AK 99835

community@gsacc.net

Gabe Scott Cascadia Wildlands

P.O. Box 853 Cordova, AK 99574 

cascadia@alaska.com

Larry Edwards Greenpeace

P.O. Box 6484 Sitka, AK 99835 

(907)747-7557

ledwards@greenpeace.org

Hunter McIntosh The Boat Company

1200 18th St. NW, Ste. 900

Washington, D.C. 20036 

hunter@theboatcompany.com

Peter Branson

P.O. Box 1259 Wrangell, AK. 99929 

wrangelloid@yahoo.com
Appendix B

Wrangell Island Project FEIS ♦ 191

Comment 

Number Comment Response

Miyoko Sakashita

Center for Biological Diversity 

2804 W. Northern Lights Blvd. Anchorage, AK 99517 

miyoko@biologicaldiversity.org

Robert Dalrymple, District Ranger Wrangell Ranger District

525 Bennett St., Wrangell, AK 99929 

comments-alaska-tongass-wrangell@fs.fed.us

Re: Wrangell Island Project EIS, comments

Mr. Dalrymple:

We submit these comments on behalf of Greenpeace, Cascadia 

Wildlands (“Cascadia”), the Greater Southeast Alaska Conservation 

Community (GSACC), Center for Biological Diversity (the “Center”) and 

The Boat Company regarding the Wrangell Island Project DEIS. The 

proposed action would remove 65 million board feet (MMBF) of timber 

from an island ecosystem that the Forest Service had previously 

concluded was sufficiently degraded that it could not withstand another 

round of intensive timber removals without substantial risk to other island 

resources. The undersigned organizations have members who use the 

Tongass National Forest, including the project area, for recreation, 

commercial fisheries, subsistence, wildlife viewing and other activities. 

Greenpeace and the Center submitted scoping comments in response to 

the initial scoping period in January 2011, Greenpeace, Cascadia, the 

Center and GSACC submitted comments on September 16, 2013, and 

Greenpeace, Cascadia, the Center and GSACC submitted scoping 

comments during a third scoping period on November 27, 2015. We 

have consistently urged the Forest Service to cease planning on a 

project of this scale and reiterate that you should rescind planning on this 

project.

Concerning past and present exhibits:

During each of those three scoping periods we submitted exhibits with 

our comments. To avoid confusion with the earlier exhibit numbers, the 

exhibits provided with our comments on the DEIS are numbered in the 
BAppendix

Wrangell Island Project FEIS ♦ 192

Comment 

Number Comment Response

form of D-nn, with D meaning related to DEIS comments and nn being 

the exhibit number. A list of the exhibits we are submitting with these 

comments is provided in Appendix B.

Exhibits submitted with the 2013 and 2015 comments were different, 

even though both numbering sequences began with a “1”. The 2011 

exhibits were not numbered. In Appendix D we provide a table with one 

column for each of those three set of exhibits, briefly indentifying each 

document and showing its exhibit number (or for the originally 

unnumbered 2011 set, a proforma sequence number). The table uses 

blue text for some added notes and bold text to identifies exhibits we 

submitted for the first scoping, but which are absent from the project 

record. These documents are missing despite them having been sent 

twice! The circumstances are:

1) The 2011 scoping comments were sent on 1/26/11, and the 

accompanying DVD of exhibits was mailed on 1/31/11. [Packing list in 

Exh. D-02].

2) On October 30, 2012 the WIP project IDT leader contacted 

Greenpeace to request that the exhibits be submitted a second time, 

because the first submission was lost when the contract for the WIP 

NEPA work was terminated. [Exh. D-64 (Piazza corresp.)].

3) The replacement exhibits were mailed the same day and was 

received in good condition. [Id.].

4) The submitted documents listed in the 2011 column of the table 

in Appendix D , are not in the planning record index we received during 

the present DEIS review period.

5) Also, the October 2012 mailing included additional DVDs with 

more videos than had been provided previously of the 2006 Tongass 

Conservation Strategy Review Workshop science panels, and the 

Powerpoint presentations. These are identified in a list in Appendix D.

We ask the planning record be made whole with respect to the materials 

we have submitted, by including all of them that we have submitted 

previously and currently and listing each individually in the record index. 

Some of the missing exhibits are cited again below, and have been 

assigned D-series exhibit numbers. The remainder of the missing 

exhibits are in a zip archive being submitted as Exh. D-01, and a list of 

those resubmissions are listed in Appendix C.

061-GSACC01Concerning our 2015 scoping comments, missing in the planning record The project record is a “living document” until the project has 

been finalized. The 2015 scoping comments were considered 

and are now in the formal indexed project record.
Appendix B

Wrangell Island Project FEIS ♦ 193

Comment 

Number Comment Response

We timely submitted comments for the project’s fourth scoping period on 

November 27, 2015 by email to you, and followed-up on November 30 

by submitting to you by email an errata both as a complete replacement 

document and as a single corrective page. [Exhs. D-14 through D-17]. 

Despite an exhaustive search of the planning record index we are unable 

to locate any of these documents, even though the email address we 

used is correct. Oddly, all of the exhibits we submitted on a postal-mailed 

DVD to accompany those comments are in the planning record. [See 3rd 

column of the table in Appendix D]. It is a shame that our 2015 

comments are not in the record, have not been available to other parties 

who may have reviewed the record in preparing comments on the DEIS, 

and we suppose were not considered during preparation of the DEIS.

The absence of our comments in the record is deeply troubling, 

especially in view of the fact that many of the exhbits that we submitted 

for the record – twice, in 2011 and 2012 – are also missing from the 

record, as discussed above. In a 2005 Forest Service briefing for an IDT, 

the final slide of the segment concerning planning records ended said 

simply: “Final Word -- If it’s not in the planning record, it didn’t happen.” 

[Exh. D-80 (USFS 2005)]. We hope the Forest Service is not trying to 

use that fact here, to the advantage of advancing its proposed action.

061-GSACC02A planning record typographic error

We note that our 2015 Exhibit 15 is hyperlinked to the wrong file 

(634_0834) in column C of the record index, although column G of this 

record is correct (linking to 634_0833). Note that the similar record for 

our Exhibit 14 is correct.

[Table of contents removed for space considerations]

I. Introduction

As noted in a 1998 Wrangell Island Analysis Report (R10-MB-371) for 

future timber development, by the end of the 1990s, “much of the ‘easy’ 

ground has already been harvested.” This means that remaining timber 

areas on the island occur near scenically sensitive travel routes, highly 

sensitive watersheds, wildlife travel corridors and other habitat, and 

potential OGR additions needed to address shortcomings in existing 

OGRs. [634_0767 at 49].5 In the 1998 analysis, Forest Service 

personnel planned the extraction of up to 25–30 MMBF of timber from 

Wrangell Island, mostly through small sales and one large sale of 15 

MMBF, with an increased emphasis on reducing the amount of clearcuts. 

Thank you, the typographic error has been corrected.

The 1998 Wrangell Island Landscape Assessment was 

completed 18 years ago. It provided historical background 

information which was considered in the beginning of the 

Wrangell Island Project analysis. The existing condition 

described in the Wrangell Island Project EIS represents the 

current situation and includes those projects that were identified 

in the 1998 Landscape Assessment and have since been 

implemented.

The Wrangell Island Project would provide timber volume to both 

large and small operators including those located on Wrangell 

Island.
BAppendix

Wrangell Island Project FEIS ♦ 194

Comment 

Number Comment Response

[Id.] Planners believed that this was the maximum amount of timber 

extraction that could occur without further impacting the most sensitive 

watersheds, high quality old growth habitats and wildlife corridors on the 

island. [Id.] Even so, planners recognized that it would be impossible to 

fully mitigate wildlife concerns given the condition of the landscape. [Id.]. 

In several of the affected areas, nearly half of the amount of harvestable 

old-growth on National Forest land had already been cut, and road 

densities typically exceeded 1 mi/mi2. [See id. at 15-30 (raising concerns 

about additional harvest in VCUs in the north and central parts of the 

island due to cumulative effects on wildlife habitat and fisheries)]. The 

analysis found that there was little or no high-value winter deer range 

habitat remaining, and that moderate value deer winter habitat had 

already been logged or fragmented by past logging. [Id. at 61]. And now, 

in 2016, much of the logging planned in 1998 has been completed.

Nevertheless, the Tongass National Forest’s current Proposed Action is 

planning to remove another 65 MMBF from 5,309 acres of public land, 

and construct an additional 32 miles of temporary and National Forest 

System road. [DEIS at 4-5]. The proposed action and other action 

alternatives would all take more than 40 MMBF, and are therefore 

unreasonable. We thus request that at a minimum you consider 

fundamentally downsizing the timber sale volume or preferably cancel

any further planning on the timber sale component of this project. Most 

of the projects contemplated in 1998 have been implemented, leaving 

even less to work with, and creating unacceptable environmental risks. 

Further, the proposed volume does not reflect a reasonable assessment 

of current and potential demand for timber from the project area. We 

would prefer to review a micro-sale or small sale project that responds to 

the needs of the one-and-only small-scale processor in the area. 

Instead, this project continues the Obama administration’s increasing 

trend of managing the Tongass National Forest as a subsidized timber 

colony for Pacific Rim wood processors far outside the region.

061-GSACC03A. The Timber Volume Purpose and Need is overly narrow and 

based on poor quality or missing socio-economic analysis

The project’s purpose and need statement aims primarily at timber 

industry goals and objectives, and also cites local and regional 

objectives aimed at providing for resource uses that contribute to the 

local and regional economies including a wide range of natural resourcebased employment opportunities. [DEIS at 4]. The purpose and need for 

the Wrangell Island Project reflect an overly narrow focus on perceived 

timber industry needs without any analysis of the existing status of the 

industry, particularly in Wrangell and adjacent communities. In general, 

Please see response to comments 050-ADNR-04, 058-SEACC02 and -03, and appendix A of the EIS. Appendix A and the 2016 

Forest Plan address the entire industry, including local small 

timber operators, as well as the most recent assessments of the 

timber industry. 

The commenter misinterprets the purpose and need. This 

project’s purpose and need statement focuses on providing a 

supply of timber to meet timber industry goals and objectives in 

an area identified for timber harvest in the Forest Plan. It is an 
Appendix B

Wrangell Island Project FEIS ♦ 195

Comment 

Number Comment Response

the Forest Service’s large timber sale program aims exclusively and 

narrowly at supplying two timber operators that export most of their 

timber as unprocessed logs. Two timber sale purchasers in southeast 

Alaska – Alcan Forest Service Products LLP in Ketchikan (Alcan) and 

Viking Lumber Company (Viking) in Craig – are the primary purchasers 

of federal timber. [2015 LRMP DEIS at 3-454]. Alcan is a timber broker 

and does not harvest or process federal timber in southeast Alaska. [Id.; 

Exh. D-24 at 2 (D. Alaska 2013)]. Both entities, particularly Viking 

Lumber, may cease operations in the near future, raising serious 

questions about further planning on a project of this scale. [Exh. D- 73 

(SitNews 2016);6 D-47__ (KRBD 2016)]. Further, given the extremely 

poor quality of the remaining timber on the island from an economic 

perspective, this project will not provide a life raft to Viking’s mill 

operation at a projected domestic processing value of negative $218.66 

per MBF, amounting to a project-level loss of $1.4 million for a company 

already on the verge of shutting its doors. [DEIS at 66, Table 12].

Even if the government could somehow preserve Viking’s mill through 

this project, the Forest Service cannot allow the needs of private entities 

to narrowly define the scope of a proposed project. [National Parks 

Conservation Ass’n v. Bureau of Land Management, 606 F.3d 1058, 

1070 (9th Cir. 2010)]. Instead, federal agencies must look to other 

relevant factors, including the views of Congress as expressed in the 

agency’s statutory authority and other congressional objectives. [Id. 

citing Citizens Against Burlington, Inc. v. Busey, 938 F.2d 190, 196 (D.C. 

Cir. 1991)]. In enacting NFMA, Congress indicated that timber production 

was not to be a sole objective of management planning. [S. Rep. 94-893, 

reprinted in 1976 U.S.C.C.A.N. 6662, 6671]. NFMA thus requires that 

forest plans provide for multiple uses, including recreation, watershed, 

wildlife and fish. [16 U.S.C. § 1604(e)]. Similarly, in enacting ANILCA, 

Congress intended to “provide the opportunity for rural residents 

engaged in a subsistence way of life to continue to do so.” [16 U.S.C. § 

3101(c)]. Finally, with reference to at-risk populations of wolves and 

goshawks, Congress determined that depleted fish and wildlife species 

“are of esthetic, ecological, educational, historical, recreational and 

scientific value to the Nation and its people.” [16 U.S.C. § 1531(a)(3)].

The timber industry in southeast Alaska is very small. There have been 

no new sawmills established since 2000 and the overall number of 

sawmills declined by half, to ten active operations since 2000. [2015 

LRMP DEIS at 3-451]. Nine of the ten sawmills essentially comprise a 

very small cottage industry and processed a total of 2.6 MMBF in 2013. 

[Id., Table 3.22-6]. The largest sawmill, Viking Lumber Company, 

processed 11.5 MMBF of federal timber in 2013. [Id.; 2015 LRMP DEIS 

appropriate purpose and need for this project. An analysis of the 

exiting industry as explained above is done on a Tongass-wide 

level and not the project level.

The timber from this project is not intended for any specific 

company. Timber volume is offered by the Forest Service 

through a competitive bidding process. It is unknown at this time 

which company would be successful in obtaining the timber 

sales or where they operate from. They could be companies 

already operating in the region or companies new to the region.

The comment confuses the two different levels of planning; the 

Forest Plan and the project plan.

The Wrangell Island Project Analysis has been prepared in 

compliance with NFMA, ANILCA, and other applicable laws 

including the Tongass Timber Reform Act. 

The timber industry is smaller than it has been in the past and 

overall harvest levels on the Tongass reflect that, however, a 

reliable supply of timber is still an essential component for timber 

operators. The Wrangell Island Project would contribute to that 

supply. The project is also an important part of the Tongass 

transition to young growth as it serves as “bridge” timber to 

industry as they transition their operations to handle younggrowth timber.

Because of the ever-widening economy in Southeast Alaska 

which is becoming more global annually, the analysis considered 

the economic and socioeconomics at the regional scale rather 

than at a project scale. 
BAppendix

Wrangell Island Project FEIS ♦ 196

Comment 

Number Comment Response

PR 769_05_000336 at 6, 8 (Parrent 2014)]. Viking marginally processed 

over twenty percent of its timber. [Id. (3.5 MMBF sawn into cants)]. 

Viking employs a mere 34 mill workers. [Id. at 4 ].

Viking Lumber Company and the one other major purchaser of federal 

timber, Alcan, rely primarily on raw log exports. In 2007, the Regional 

Forester developed a limited interstate shipment policy that it expanded 

in 2009 to allow timber sale purchasers to export 50 percent of total Sitka 

spruce and western hemlock sawlog volume. [DEIS at 3-453-454]. Thus, 

the stated purpose and need for the project – timber volume for these 

two entities – primarily benefits corporations outside the region rather 

than the southeast Alaska economy, while residents of the region are left 

with very consequential resource damage and environmental impacts. It 

is unreasonable and arbitrary to focus the Wrangell Island Project 

purpose and need on satisfying the perceived needs of two distant 

timber exporters, and the expense of social, economic and ecological 

sustainability.

061-GSACC041. The DEIS does not show how the timber sale program will meet 

regional employment goals

The DEIS does not adequately show how the emphasis on maintaining 

Viking’s and Alcan’s access to federal timber is related to the goal of 

providing jobs for southeast Alaska residents. First, the export policy 

further reduces the return to the local economy from the public spending 

on the timber program by diminishing local utilization of timber and local 

manufacturing employment. The 2015 LRMP Amendment DEIS makes 

clear that the Forest Service intends to authorize the export of roughly 

two-thirds of the timber removed from federal forests as unprocessed 

logs. [2015 LRMP DEIS at 3-456-457, Tables 3.22-8, 3.22-9]. In general, 

Alcan and Viking have exported nearly all the cedar and half the hemlock 

and spruce sawlogs as unprocessed raw logs since the Alaska Region 

developed and subsequently liberalized its export policy. Indeed, 

between 2008 and 2009 the ratio of federally supported mill jobs per 

MMBF of federal timber dropped to nearly one-half. [See id. at 3-449-3-

450, Tables 3.22-4, 3.22-5, 3.22-6]. Overall, the 2015 LRMP DEIS 

shows a clear decline in actual “industry”/mill employment relative to 

federal timber removals over time, with pre-export policy federal timber 

(2002 – 2007) supporting 2.2 processing jobs per MMBF, and postliberalized export policy federal timber (2009 – 2014) supporting 1.5 

processing jobs per MMBF. [Id.]. The job transfer to foreign timber 

processors may be worse under this project, but the DEIS never 

considers this issue – which should be critical to ascertaining to what 

degree the Wrangell Island Project would meet even the very narrow 

The Forest Plan provides a goal of providing a diversity of 

opportunities for resources uses that contribute to the local and 

regional economies of Southeast Alaska. It does have an 

objective to support a wide range of natural resource 

employment opportunities, including timber, within Southeast 

Alaska communities. This project would generate economic 

opportunities and employment at the local and regional level. 

Projected annual employment is provided in chapter 2, table 9 

for each alternative.

The Alaska Region does not have employment goals for any 

particular economic sector. The analysis presents potential 

employment results from the project. All alternatives through 

FAST-R show estimates of total jobs supported, direct income, 

and indicated advertised values for both the 100 percent 

domestic processing and current export policy scenarios and can 

be found in both the Timber Economics Resource Report and 

the individual FAST-R runs contained in the project record. 

Employment data is collected as the regional level, and local 

employment is included in the regional data. Timber from the 

Wrangell Island Project can also support smaller operators both 

on and off Wrangell Island. These supported jobs are then 

combined to support the timber industry in Southeast Alaska and 

indirectly support other businesses through the use of related 
Appendix B

Wrangell Island Project FEIS ♦ 197

Comment 

Number Comment Response

need it declares, of supplying a forest products industry that provides 

jobs for southeast Alaska residents.

Also, the DEIS never evaluates the levels of local employment in 

logging, which raises further questions about whether the Wrangell 

Island Project would meaningfully support jobs for southeast Alaska 

residents. The Forest Service acknowledges that non-resident 

employment accounts for a significant amount of jobs in southeast 

Alaska’s resource- dependent sectors. [2015 LRMP DEIS at 3-447]. The 

number of actual timber workers is so small that reports by the Alaska 

Department of Labor lump logging jobs with other natural resourcebased job categories, such as fishing, mining and agriculture. [2015 

LRMP DEIS PR 769_05_000344; -000314; -000318; - 000319]. The 

LRMP Amendment planning record shows that overall, workers from 

areas other than southeast Alaska comprise a significant proportion of 

the natural resource-based work force, and nearly half of the timber 

related jobs in southeast Alaska are held by non-residents. [PR 

769_05_000329 at 16-18, 22 ( ADOL 2015)].Since the 2008 TLMP 

Amendment, federal timber has supported 110 jobs per year. [DEIS at 3-

449, Table 3.22-4]. Are half of those jobs then actually held by reality TV 

show “Axe Men” from Oregon? The Wrangell Island Project DEIS never 

considers or answers these questions, making it impossible to evaluate 

whether the project’s timber volume goals align in any way with its 

regional employment rationale.

goods and services and amenities. There is a direct correlation 

between timber volume and the employment it generates.

Regional economic reports included in the analysis are prepared 

by others and the most recent information is in the 2016 Forest 

Plan Amendment FEIS. These are located in the planning 

record. 

The estimated employment generated by the project is displayed 

in chapter 3, Issue 1. Employment projections are provided for 

export and domestic processing scenarios. The status of the 

industry is indicated in these reports and in appendix A of the 

FEIS.

See response to comment 061-GSACC-03.

061-GSACC052. The DEIS does not show how the agency’s timber volume goals 

relate to the significant changes in the local and regional economy

The DEIS restates 2008 TLMP timber goals and objectives as the 

primary purpose and need for the project, and then, without any analysis 

of the local and regional economy, adds one local and regional economic 

goal and one local and regional economic objective from the 2008 

TLMP. [DEIS at 4]. Nowhere in the analysis is there any explanation of 

how these goals and objectives pertain to Wrangell Island or adjacent 

islands, where there is no large timber exporter, no active logging 

company, and one small mill that could operate for centuries with the 

volume authorized under action alternatives. In other words, after 

eliminating the vague goals and objectives from the 2008 TLMP, the 

entire reason for the Wrangell Island Project boils down to providing a 

large volume of timber to distant timber exporters. This actual purpose is 

overly narrow.

The Forest Service needs to reconcile this inconsistency and then 

develop and re-scope a revised purpose and need statement that more 

broadly addresses the region’s socio-economic needs. Congress 

The timber supply and economics are included as significant 

issues in the analysis and are described in the Timber 

Economics Resource Report and in Issue 1 of chapter 3 of the 

EIS. Estimates of total jobs, direct income, and indicated 

advertised values for both the 100 percent domestic processing 

and current export policy scenarios can be found in both the 

Timber Economics Resource Report and the individual FAST-R 

runs contained in the project record for each alternative.

The purpose and need for the project is defined in chapter 1 –

The Project Purpose and Need. The purpose is to respond to the 

goals and objectives in the Forest Plan to guide timber 

management to support the local and regional economies of 

Southeast Alaska while moving the project area towards the 

desired condition for all resources. The goals of the Forest Plan 

are integral to the purpose and need and cannot be eliminated 

from consideration. Timber harvest continues to be a viable 

component of the local and regional economy of Southeast 
BAppendix

Wrangell Island Project FEIS ♦ 198

Comment 

Number Comment Response

enacted NFMA in part to respond to “widespread public distress and 

scientific concern over the Forest Service’s post-World War II shift to 

massive, heavily subsidized timber production in the National Forests.” 

[Sierra Club v. Peterson, 185 F.3d 349, 353-54 (5th Cir. 

1999)(superseded on other grounds, 228 F.3d 559 (5th Cir. 2000)]. The 

goal was to ensure that timber production would not be the “sole 

objective” of the Forest Service and to direct forest managers to protect 

other resources such as fish and wildlife habitats. [S. Rep. 94-893, 

reprinted in 1976 U.S.C.C.A.N. 6662, 6671]. NFMA thus requires that 

forest plans provide for multiple uses, including recreation, watersheds, 

wildlife and fish. [16 U.S.C. § 1604(e)]. TLMP goals and objectives 

implementing this mandate thus seek to “[p]rovide a diversity of 

opportunities for resource uses that contribute to the local and regional 

economies of Southeast Alaska” and “[s]upport a wide range of natural 

resource employment opportunities within Southeast Alaska’s 

communities.” [LRMP at 2-3].

The DEIS fails to consider how the purpose and need for the Wrangell 

Island Project aim solely at supporting a marginal component of the 

regional economy. It instead treats various and significantly different 

economic sectors as equal, and asserts that communities of Southeast 

Alaska depend on the Tongass National Forest in various ways “to 

provide natural resources associated with fishing, timber, mining and 

tourism for employment.” [DEIS at 63].

First, the timber industry is a marginal component of the regional 

economy. Over the past decade, timber employment has decreased by 

nearly 90%, and the industry is smaller than it was over a century ago. 

[2015 LRMP DEIS PR 769_05_000340 at 10 (Southeast Conference 

2014)]. Timber removals in southeast Alaska overall at best provide 1% 

of total regional employment and 3% of total resource-based 

employment in the region. [2015 LRMP DEIS at 3-445, Table 3.22-3]. 

Timber worker earnings are less than 1% of total employment related 

earnings in the region. [2015 LRMP DEIS PR 769_05_000340 at 3 

(Southeast Conference 2014)]. The significance of these jobs relative to 

the overall economy is even smaller because employment data do not 

include the thousands of workers who are self- employed in the 

commercial fishing industry. [Id. at 4, 6]. In reality, federal timber is now 

responsible for a small fraction of a percent of regional employment, and 

even the industry’s employment from timber on all lands is only 0.7% of 

regional employment. [Exh. D-70 at 6 (SE Conference 2016)].

Conversely, economic activity associated with ecosystem values, 

particularly values associated with wildlife, have a substantial positive 

impact on the regional economy. Wildlife are much more important to the 

Alaska although it has diminished from previous decades. The 

project would contribute to the orderly flow of timber to large and 

small timber businesses and benefit the local and regional 

economies of Southeast Alaska. The project would also provide 

a reliable supply of “bridge” timber that would support local jobs 

and facilitate the timber industry transition to a sustainable wood 

product industry based on young growth. The Forest Plan 

resource protection requirements in conjunction with the 

alternative designs in this project would limit adverse impacts to 

other regional economic interests. 

The City and Borough of Wrangell and others have expressed 

strong support for timber harvest on the island and the economic 

and social benefits it brings. Please see response to comment 

054-CBW-04.

Appendix A – Rationale for Scheduling the Wrangell Island 

Project describes how the project fits into the Tongass timber 

program. The Wrangell Island Project is one component of the 

Forest’s timber sale program. Also see response to comment 

058-SEACC-09. 

The Forest Plan does provide for multiple uses and goals and 

objectives across the Forest. However, this project is specific to 

timber harvest within this analysis area of Wrangell Island. Other 

projects on Wrangell Island addressed other resources

Economic sectors such as commercial fishing, recreation, and 

tourism are continuing to grow alongside the continuation of 

timber harvesting occurring under the resource protection 

measures of the Forest Plan. The industries are not necessarily 

exclusive of each other as indicated in the comment. 
Appendix 

B

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Comment 

Number Comment Response

economy than Alcan and Viking’s clearcuts. In 2011, wildlife hunting and 

viewing generated 2,463 jobs in southeast Alaska, $138 million in labor 

income and $360 million in total economic output. [Exh. D-27 at 24 

(EcoNorthwest 2014)]. In contrast to the failed timber program, federal 

programs that support recreation can make positive contributions toward 

enhancing the visitor economy. According to a recent peer- reviewed 

analysis, the National Park Service returns $10 in direct visitor spending 

for every $1 invested. [Exh. D-79 (Thomas et al. 2014)]. This return is 

2000 times as high as the 1⁄2¢ per dollar return from the timber sale 

program. Alaska ranks third in the nation in spending and job support, 

with visitors to national parks spending $1.06 billion and supporting 

16,181 jobs. [Id.]. The program supports 400 private businesses. [Id.]. 

Further, the record shows that overall, the visitor industry impact in 

southeast Alaska is massive and dwarfs the timber industry by an order 

of magnitude, with average visitor industry spending in excess of $1 

billion per year, providing between 10,200 and 10,900 jobs, with labor 

income impacts ranging from $370 million to $407 million. [2015 LRMP

DEIS PR 765_05_000334 at 8 (McDowell Group 2015].

The other major private sector employer, commercial fishing, generated 

$219 million in ex-vessel value alone (meaning direct fishing revenue 

exclusive of processing jobs and other economic outputs) in 2013. Lands 

managed by the Forest Service provide slightly more than half of 

southeast Alaska’s salmon catch. [Exh. D-01 at 11 (Alexander 2011)]. 

Salmon hatcheries provide an additional 22 percent of the statewide 

salmon value, and are the largest agricultural industry in Alaska, 

providing hundreds of jobs. [Id. at 13]. Thus, the record shows that 

commercial fishing, the visitor industry and the maritime sector are the 

“bright points in our economy.” [2015 LRMP DEIS PR 769_05_000340 at 

1 (Southeast Conference 2014)]. These sectors have contributed to an 

overall growth in employment, population and wages following a market-

based recovery from past dependence on the timber industry. [Id. at 2-3]. 

Overall, both employment and income have increased in the region since 

2000. [2015 LRMP DEIS at 3-442].

Even areas formerly dependent on timber, like the Prince of Wales 

Island area or Wrangell, have recovered from their historical dependence 

on federal timber. Over the past decade, the Prince of Wales Island area 

has redefined its economy around small proprietorships in specialty 

wood mills, fishing and seafood and hospitality businesses. [Exh. D-72 

(SitNews 2012;9 634_0835 (Economic Trends 2012)]. Population levels 

have rebounded over the past five years. (Id.) Nature-based 

tourism generated more than $30 million in gross revenues to Prince of 

Wales Island in 2007 – mostly from sport fishing. [Exh. D-82 (Big Thorne 
BAppendix

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FEIS at 3-454)]. There were population increases throughout the region 

including in Ketchikan and Wrangell and nearly all Prince of Wales Island 

communities from 2010 – 2013. [LRMP DEIS PR 769_05_000340 at 5 

(Southeast Conference 2014)]. Wrangell also has experienced a 

market-based transition that includes increased participation in fisheries 

and the development of a maritime service sector that is an economic 

development model in the region. [634_0799 (SitNews 2013); Exh. D-71 

(Sitka Sentinel 2013);10 634_0825 (UFA 2014)].

Given these changes, many of them subsequent to the 2008 

Amendment, the perceived need to develop this project around the 

perceived needs of two timber operators was clearly overly narrow, and 

requires a re-assessment of the need for the project to account for 

changed conditions and circumstances.

061-GSACC063. The purpose and need is too narrow and precludes measures 

to improve the local and regional economy by ameliorating past damage 

to watersheds and recreation enhancement projects

The scoping process had previously indicated that the Forest Service 

would consider some level of road maintenance and improvements, 

invasive species treatments, erosion control and fish passage 

improvements as part of this project. [80 Fed. Reg. at 65691]. We would 

like to see the Forest Service implement a project that emphasizes 

fisheries habitat remediation projects on Wrangell Island with an 

emphasis on repair or removal of barrier culverts and/or road 

decommissioning. But efforts to ameliorate degraded habitat conditions 

will be undermined if they occur in conjunction with a proposed action 

that would take 65 million board feet of timber (MMBF). The proposed 

action compounds the negative environmental impacts from further 

timber removals by authorizing the construction or reconstruction of 

another 32 miles of road. [Id.]. Thus, our November 2015 scoping 

comments, requested that you consider fisheries impacts a significant 

issue in light of Wrangell’s market-based transition toward a fisheries 

economy and the significant risks to fisheries resources implicated by 

this project. 

The purpose and need for the project is clearly described in 

chapter 1 of the EIS. Watershed restoration and enhancement is 

outside the scope of this project. Fish culverts are managed 

through the Forest culvert program. Road management is 

described in each alternative. 

See responses to 061-GSACC-03, -04 and -05. Also refer to the 

“Stewardship Opportunities” section in chapter 1 of the EIS.

The fisheries resource is important but it was not identified as a 

significant issue in the analysis because the effects to fisheries 

are minimal, due to the application of buffers, BMPs, and Forest 

Plan standards and guidelines. The effect on fisheries are 

included in the analysis and are documented in the “Aquatics”

section of chapter 3 and Aquatics Resource Report. 

The watershed conditions and fish passage are presented in the 

“Issue 4: Access Management” and “Aquatics” sections of 

chapter 3 of the EIS. The effects from the alternatives on 

watershed and fisheries are presented in the Aquatics section. 

The application of Forest Plan standards and guidelines, Best 

Management Practices and the design of the alternatives would 

minimize adverse impacts to aquatic resources.

Also see responses to comments 058-SEACC-01, -02, and -03.
Appendix B

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Number Comment Response

An alternative or mitigation measure should be developed that 

addresses fish passage concerns. But the DEIS arbitrarily determined 

that cleaning up the mess left by the timber industry on public lands was 

“beyond the scope of the project.” [DEIS at 6]. It thus arbitrarily 

dismisses any efforts to improve habitat in ways that would actually 

realize socio-economic benefits such as red pipe replacements and 

recreational enhancement projects. These projects would better meet 

local and regional economic objectives, and any further planning on this 

project must include a purpose and need broad enough to benefit the 

larger region rather than two private corporations.

Watershed restoration and fish habitat enhancement are 

described in the “Stewardship Opportunities” section of chapter 1 

of the EIS. 

061-GSACC074. The proposed action fails to meet the identified, timber-industryintensive purpose and need

The record is clear from the timber industry and local government that, in 

order to fil the perceived need for a long-term sale, the volume offered 

would need to be no less than 150 mmbf of economical timber. [See e.g. 

June 20, 2012 IDT notes; 2011 AFA comments; Wrangell Borough 

comments]. The rationale for that large offering of timber volume was 

that it might entice investors to build a new mill on Wrangell Island. [See 

e.g. DEIS at 9 (noting “interest” in converting old mill site for a new mill)]. 

Comments were clear and consistent from timber industry boosters that 

a sale smaller than 150 mmbf would be worse than a waste of time. In 

light of that, there is no identified need for a 50 mmbf sale on Wrangell 

Island. [See 2011 AFA comments (“...piecemeal approach will not 

provide the incentive for operators to invest in Alaska...”). Furthermore, 

offering a sale of this size and volume would fail to meet the purpose and 

need of spurring timber industry investment to support the local 

economy. In reality the proposed action seems to represent the worst of 

all worlds, degrading wildlife and wildland values treasured by members 

of our environmental organizations, burdening the agency with work that 

it cannot afford to do, and stringing the dying old- growth industry along 

as an export-driven operation that does nothing for local economic 

opportunity or stability.

The prospect of new investment in a mill on Wrangell is not reasonably 

foreseeable, so it is a mistake to design a sale to seek to meet that 

imagined (future) market demand for timber. The approach taken in the 

DEIS fails to take a hard look at the actual economic condition of the 

industry and mills on Wrangell because of this erroneous assumption. 

The DEIS does disclose that there have been no proposals for such 

development. Under ordinary NEPA principles such a vague hope 

without even a proposal is not reasonably foreseeable, and it is not wise 

to plan this project as though it were.

Comment noted. Please see the Timber Economics Resource 

Report for a discussion on alternative size and 2001 inventoried 

roadless areas.

Job estimates for both export and 100 percent domestic 

processing scenarios are found in the Timber Economics 

Resource Report and chapter 3 of the EIS. Please see response 

to comment 029-BHD-04 and 049-ST-02 for discussion on sale 

sizes that could result from alternatives analyzed under the 

Wrangell Island Project EIS. 

The size of the project has changed over time. There is still 

support from industry for a sale larger than that proposed by the 

Wrangell Island Project. 

Elimination of the Tongass exemption to the 2001 Roadless Rule 

greatly diminished the available harvest area on Wrangell Island 

and rendered the originally planned 150 MMBF project 

impossible. The 2001 Roadless Rule even prohibits timber 

harvest on some roaded parts of Wrangell Island. See figure 3 of 

the FEIS. 

The purpose of this project is to provide a supply of timber to the 

regional industry.

All of the action alternatives, including the proposed action meet 

the Purpose and Need for the project. The Proposed Action is to 

make an estimated 65 MMBF of timber available to industry. The 

timber demand is described in Appendix A - Rationale for 

Scheduling the Wrangell Island Project. The purpose and need 
BAppendix

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Number Comment Response

a. Small Mills Alternative should have been considered

Please take a hard look at a small mills and wildlife alternative. It is 

particularly disappointing that the DEIS did not analyze a small mill & 

wildlife alternative, as was developed and urged by the SEACC. [See 

SEACC 7/25/2011 comment letter with attachments]. Under SEACC’s 

analysis there is a need for a combined 2 mmbf/ year of economical 

timber along the road system to feed the two small mills on Wrangell. 

The DEIS fails entirely to consider this reasonable alternative. The 

proposed action does not even entertain the possibility of offering the 

proposed volume in a series of smaller sales directed at local mills.

Similarly, the DEIS fails to analyze the impacts of the proposed action on 

opportunities for such a “small mills” alternative in the future. A 2009 

collaborative effort found about 30 mmbf of economical timber left on the 

island. The proposed action would log essentially all of that, leaving 

nothing for small operators in future decades. It remains an open 

question to us whether even 2 mmbf/year is appropriate or sustainable 

on Wrangell Island without the proposed large sale. After the proposed 

action, the opportunity will surely be gone.

for the project is defined in Chapter 1 - Purpose and Need for 

Action. The purpose is to respond to the goals and objectives in 

the Forest Plan to guide timber management to support the local 

and regional economies of Southeast Alaska while moving the 

project area towards the desired condition for all resources.

As indicated in chapter I, table 4, the Borough of Wrangell 

continues to express interest in pursuing ownership and 

development of the Silver Bay mill site for industrial purposes 

which could include a timber processing facility. The regional 

market demand assessment (EIS, appendix A) does not include 

a potential future mill at this site, nor is it considered a 

reasonably foreseeable action in the analysis.

The “Decisions to be Made” section in chapter 1 of the EIS 

describes the decisions to be made in the Record of Decision. 

The decision will include any timber volume to be made available 

by the project, as well as the location, design, and scheduling of 

any timber sales. The needs of small local mill operators are 

included in all of the action alternatives as part of the timber 

made available to industry. The project would contribute to the 

orderly flow of timber to large and small mills. See “The Project 

Purpose and Need” in chapter 1 of the EIS. Also see response to 

comment 058-SEACC-05. 

061-GSACC085. The Project’s purpose and need is erroneously supported by a 

“transition” that has not started.

A primary justification for the Wrangell Island Project, as indicated by the 

purpose and need section, is to help facilitate a transition to a younggrowth-based timber program over the next 10 to 15 years. The DEIS 

repeatedly, in the purpose and need section and throughout the 

document, refers to the project as a “bridge timber project.” See, e.g., 

DEIS at 2 (“Therefore, an underlying need exists for a reliable economic 

supply of sawtimber for Southeast Alaska mills to help support the timber 

industry and employment through the transition years until the industry 

can switch to a stable supply of young growth.”); id. at 65 (“This project 

contains a supply of old-growth ‘bridge’ timber that could support local 

jobs and facilitate the industry transition to a sustainable wood product 

industry based on young- growth management on the Forest and 

throughout Southeast Alaska.”). The EIS however does not explain how 

this proposal might achieve that. We have not seen any evidence 

suggesting that additional old-growth logging will cause an acceleration 

The transition to young growth is occurring now with limited 

amount of young-growth timber being offered and awarded for 

harvest. The transition was formally initiated in 2013 with the 

Secretary of Agriculture’s Memorandum 1044-009 dated July 12, 

2013. This included direction to the Forest Service to supply 

“bridge” timber to industry to facilitate the transition over time. 

The Wrangell Island Project is a component of the transition 

direction. See the sections “Why Is This Project Important?” and 

“The Project Purpose and Need” in chapter 1. 

The transition to young-growth harvest is described in the 2016 

Forest Plan Amendment, FEIS and Record of Decision. The 

Wrangell Island Project adopts the Tongass Advisory Committee 

recommendations which include bridge timber as part of the 

transition process. Please see appendix B of the 2016 Forest 

Plan.
Appendix B

Wrangell Island Project FEIS ♦ 203

Comment 

Number Comment Response

of second-growth logging, or an end to old-growth logging. The DEIS 

makes stated and un-stated assumptions related to the transition. It is 

assumed that mills will re-tool to process small diameter logs, that 

sustaining old-growth logging in the interim will speed that process 

along. [see DEIS at 2–3]. Public statements by the one remaining midsized mill operator in Southeast, Viking lumber, suggest that they have 

no intention of re-tooling into a second-growth operation. Our recent 

reconnaissance of the Big Thorne sale on Prince of Wales Island, for 

example, found them targeting old-growth stands and cedar, not the 

commercial thinning units that are also included in that sale.

An important thing the purpose and need section fails to disclose is that 

the “transition” has not yet begun. It has not been approved, has not 

been reduced to a final plan, and has not been shown to be 

implementable. Outside of a few vague sentences, the DEIS does not 

describe any details about the “transition” or how the Wrangell Island 

Project specifically helps facilitate the transition. The “need” for the 

Wrangell Island Project to support a nebulous “transition” is therefore 

arbitrary.

The purpose and need section of the FEIS must omit any reference to a 

Tongass “transition.” It is illogical to support this current project by 

reference a future strategy; the Wrangell Island Project cannot be “part” 

of a transition strategy that does not presently exist. To the extent that 

the purpose and need for the Wrangell Island Project is tied to the need 

to supply bridge timber for a “transition,” the FEIS must present detail 

about the contours of the “transition,” and articulate how the Wrangell 

Island Project specifically fits within the transition framework.

The current 5-year sale plan includes young-growth sales.

061-GSACC096. Last-minute changes to the project confound the systematic, 

inter-disciplinary process

The project record discloses that the original project plan was scrapped 

in early 2015 at the direction of the Forest Supervisor. [See AR 

634_0091_2015_05_06... (May 6, 2015 IDT notes)]. Please provide an 

explanation for this change, including a clear identification of where that 

decision was made, and on what rationale it was based. The sole reason 

seems to have been that the agency had failed to do the required 

analysis to warrant the Forest Plan modifications, and so is seeking to 

avoid losing a lawsuit. The approach chosen by the Supervisor thus 

prioritizes legal compliance as though that were an end in and of itself, 

and does so at the expense of doing the hard work necessary to analyze 

and design projects that work for both industry and conservation. The

last-minute changes seem to have thrown the analysis in chaos, 

Changes during an analysis are normal and appropriate as 

situations change or new information becomes available. In this 

case, the Wrangell Island Project was well underway and 

included a variety of project-specific Forest Plan Amendment 

proposals when the new Forest Plan Amendment was initiated. 

Because the Forest Plan itself was in the formal amendment 

process, the Forest Supervisor made the decision to drop the 

project-specific Forest Plan amendments from the Wrangell 

Island Project. This is described in Alternatives Considered But 

Eliminated From Detailed Study in chapter 2 of the Wrangell 

Island Project EIS.
BAppendix

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Comment 

Number Comment Response

breeding confusion in the IDT and introducing huge potential for analysis 

error. The May 20, 2015 Briefing Paper for example discloses some 

disturbing aspects of the change. Alternative 5, the closest thing to a 

‘conservation’ alternative, somehow gained 300 acres. The team, 

sensibly, wondered what the point of Alternative 3 was, absent the 

Forest Plan changes. The June 20, 2012 IDT notes reflect that the team 

was then exploring a sale that included all available timber volume on 

the island, made available at a certain rate over time. The aquatics 

resource report references apparently old versions of the alternatives 

(e.g. Alt 2 is 73 mmbf). With different experts making radically different 

assumptions at different periods of time the inter-disciplinary process 

loses its systematic character. Rather than being directed to do their jobs 

within their areas of expertise, the IDT members are transformed into 

pawns whose analysis is used after-the-fact to justify whatever decision 

the higher-up officials make.

The decision to be made includes an unusual provision related to a fiveyear review of the project and possible supplemental analysis. [See 

DEIS at 5, citing FSH 1909.15 Ch.18]. Please explain this process and 

the choice to be made. It is a basic tenet of NEPA that environmental 

analysis is an ongoing process, and applicable law in this area obviously 

requires supplemental environmental analysis whenever there are 

significant changed circumstances or new information.

Please explain the rationale for refusing to consider stewardship projects 

as part of the proposed action. The public process for this project 

uncovered a need for a wide variety of specific stewardship projects, 

from recreation improvements to road maintenance. It is very 

disappointed to see that those projects were considered “beyond the 

scope” of this project. Stewardship projects were within the scope of the 

scoping notice. It appears that the decision was made to limit this project 

to logging and road expansions in spite of the input of public and agency 

resource experts. It is unclear on review of the project record how or why 

this decision was made.

7. Conclusion

For the above reasons, we request that you develop a new purpose and 

need statement that is consistent with the agency’s multiple use 

mandate and a realistic analysis of regional socio-economic realities. 

The failure to address changed socio-economic conditions in a DEIS that 

The reference to FSH 1909.15 chapter 18 was only informational 

and not associated with the decision to be made. It has been 

removed from the FEIS to eliminate confusion.

Stewardship opportunities were identified by the public during 

the scoping process. These are presented in the “Stewardship 

Opportunities” section of chapter 1 of the EIS. Stewardship

projects were ultimately not included in the proposed action. 

These projects, such as “red” pipes, are already included in other 

Forest-wide programs or will need additional work to develop 

them into proposals which would then undergo a separate NEPA 

analysis. Please see response to comment 061-GSACC-03 and 

-75.
Appendix B

Wrangell Island Project FEIS ♦ 205

Comment 

Number Comment Response

authorizes a continuation of failed federal economic policy for the region 

is a major flaw.

061-GSACC10B. Range of Alternatives

The Forest Service designed five action alternatives. The proposed 

action provides the largest supply of timber volume for the industry – 65 

MMBF from 5,309 acres with 1,781 acres of clearcuts, 3,528 acres of 

“partial cuts” (by which 33% of the basal area of trees in a unit would be 

cut), and 32.1 miles of road. [DEIS at 18]. Alternative 3 would remove 

48.8 MMBF of old growth with 1,483 acres of 33% clearcuts and 1,701 

acres of clearcuts and adds 29.9 miles of road. [DEIS at 19]. Alternative 

4 would remove 51 MMBF of old growth through 1.738 acres of 33% 

clearcuts and 1,793 acres of clearcuts. [DEIS at 19]. Alternative 5 

purports to respond to wildlife habitat concerns, yet it would remove 42.8 

MMBF of old growth with 2,868 acres of 33% clearcuts and 936 acres of 

clearcuts and add 21.6 miles of road. [DEIS at 20].

The Wrangell Island Project’s limited purpose and need, aimed at timber 

industry objectives, resulted in a failure to meet the NEPA obligation to 

“[r]igorously explore and objectively evaluate all reasonable alternatives.” 

[40 C.F.R. § 1502.14(a); see also Barnes v. U.S. Dep’t. of Transp., 655 

F.3d 1124, 1131 (9th Cir. 2011)(“Congress created NEPA to protect the 

environment by requiring that federal agencies carefully weigh 

environmental considerations and consider potential alternatives to the 

proposed action before the government launches any major federal 

action”)]. This failure is highlighted by the contrary conclusions the 

Forest Service reached in its 1998 Wrangell Area Analysis (634_0767), 

as discussed in an earlier section of these comments.

A “reasonable” range of alternatives includes alternatives “that are 

practical or feasible” and not just those alternatives preferred by the 

agency. [Council on Environmental Quality (CEQ), Forty Most Asked 

Questions, Questions 2A and 2B; 40 C.F.R. §§ 1502.14, 1506.2(d). 

NEPA requires a discussion of the alternatives “in comparative form, 

thus sharply defining the issues and providing a clear basis for choice 

among options by the decision maker and the public.” [40 C.F.R. §§ 

1502.14]. The key criterion for determining whether a range of 

alternatives is reasonable “is whether an EIS’s selection and discussion 

of alternatives fosters informed decisionmaking and informed public 

participation.” [Westlands Water Dist. V. U.S. Dep’t of Interior, 376 F.3d 

The EIS was prepared in compliance with NEPA. Key issues 

were identified from public scoping input, from which a range of 

alternatives that meet the purpose and need were developed. 

The range of alternatives includes the No Action alternative and 

four action alternatives. These alternatives were designed to 

address the key issues and result in a range of quantifiable 

effects to those issues (resources). The alternatives include a 

range in the amount of timber harvest, the location of the harvest 

units, as well as the type of logging system to be used. Together, 

the analysis of these provide a meaningful comparison of effects.

All of the action alternatives meet the Purpose and Need for the 

project which is to contribute a supply of timber to meet the 

needs of industry. The industry needs are described in the timber 

demand analysis in appendix A of the EIS. 

Timber volume is offered by the Forest Service through a 

competitive bidding process. It is unknown which companies 

would be successful in obtaining the timber sales at this time.

Also see responses to comments 058-SEACC-04 and 058-

SEACC-05 and 061-GSACC-07. 

The key issues derived from scoping are defined in the “Issues”

section of chapter 1. The key issues are timber supply and 

economics, which directly addresses the local and regional 

economic values and timber demand and economics; scenery; 

wildlife habitat and subsistence; and access management. The 

alternatives were designed to respond to these issues and the 

analysis that each would have different quantifiable effects on 

the environment. A comparison of the effects between the 

alternatives is presented in table 2 of the FEIS.
BAppendix

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Comment 

Number Comment Response

853, 872 (9th Cir. 2004)(citations omitted). While an EIS need not 

include every conceivable alternative, [Vermont Yankee Nuclear Power 

Corp. v. NRDC, 435 U.S. 519, 551 (1978)], “[t]he existence of a viable 

but unexamined alternative renders an environmental impact statement 

inadequate.” [Westlands Water Dist., 376 F.3d at 868]. The exploration 

of alternatives to an agency’s preferred course of action is critical, 

because “[w]ithout substantive, comparative environmental impact 

information regarding other possible courses of action, the ability of an 

EIS to inform agency deliberation and facilitate public involvement would 

be greatly degraded.” [New Mexico ex rel. Richardson, 565 F.3d 683, 

708 (10th Cir. 2009)(citations omitted)].

The range of alternatives in the DEIS fails these standards. The four 

action alternatives all drive at the same result – excessive timber 

volumes with some variation in how and where the timber industry would 

perform the extractions. The alternatives provide no clear basis for 

choice and no means for the public to compare and provide comments 

on alternatives that would accelerate the end of old-growth logging and 

reduce the overall volume of total forest removals relative to the status 

quo. Thus, the alternatives are not sufficiently distinctive to sharply 

define the issues and allow for informed decisionmaking.

The DEIS contemplates only four action alternatives. All alternatives 

involve taking at least 42 MMBF of timber over the next decade primarily 

from some of the most highly degraded watersheds on the island. [DEIS 

at 35-41]. The preferred alternative would degrade 5,309 acres of oldgrowth habitat through clearcuts and 33% clearcuts and emphasizes 

maximizing timber volume for distant timber exporters. [Id. at 18]. 

Alternatives 4 and 5 seek to address scenic integrity and wildlife habitat, 

respectively. [DEIS at 19-20], but both propose excessive volumes of 51 

and 43 MMBF, meaning that the distinction between the two is only how 

much scenic value is lost compared to wildlife habitat, or vice versa – a 

poor choice. Alternative 3 purports to address multiple resource 

issues, but still would take 48.8 MMBF of timber. [Id. at 18-19]. The 

critical problem is that the alternatives all entail excessive removals of 

old-growth forest without any consideration for local or regional socioeconomic values, and without any assessment or description of potential 

markets or purchasers for the timber. There is no justification provided 

for a sale of this size, particularly given the agency’s prior findings about 

the poor condition of the island’s landscape. In sum, the DEIS analyzes 

only alternatives which do have substantially similar consequences, and 

then improperly excludes alternatives which would generate different 

results and allow for a more meaningful comparison between different 

courses of action.

Your opposition to the amount of timber proposed for harvest is 

noted.
Appendix B

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Comment 

Number Comment Response

1. A range of alternatives should have meaningful, quantitative 

distinctions and not be similar and aimed at one end result

The CEQ’s “Forty Questions” explains that a range of alternatives should 

include quantitative differences in how an agency analyzes a proposal:

For some proposals there may exist a very large or even infinite number 

of possible reasonable alternatives. For example, a proposal to 

designate wilderness areas within a National Forest could be said to 

involve an infinite number of alternatives from 0 to 100 percent of the 

forest. When there are potentially a very large number of alternatives, 

only a reasonable number of examples, covering the full spectrum of 

alternatives, must be analyzed and compared in the EIS. An appropriate 

series of alternatives might include dedication of 0, 10, 30, 50, 70, 90 or 

100 percent of the Forest to wilderness. What constitutes a reasonable 

range of alternatives depends on the nature of the proposal and the facts 

in each case. [CEQ 40 Most Asked Questions, Question 1b].

The Ninth Circuit case law mirrors this statement in identifying a need for 

alternatives that provide for meaningful quantitative distinctions. In State 

of Cal. v. Block, the Forest Service prepared a programmatic EIS for 

designating roadless areas and analyzed 8 action alternatives that would 

allocate roadless acreage between wilderness and non-wilderness 

designation. [State of Cal. v. Block, 690 F.2d 753, 766 (9th Cir. 1982)]. 

The court concluded that the range of alternatives was unreasonable in 

large part because the Forest Service limited its consideration of the 

amount of acreage available for Wilderness designation to no more than 

33% of the roadless acreage. [Id. at 766-768]. The court explained that:

... without any explanation, the Final EIS seriously considered only those 

alternatives that allocate more acreage to Nonwilderness than to 

Wilderness. Moreover, with the sole exception of Alternative I, 

Nonwilderness acreage allocations exceed Wilderness allocations by a 

substantial margin, ranging from five-to-two for Alternative D, to 

nineteen-to-one for Alternative E. See Table # 1, supra. While nothing in 

NEPA prohibits the Forest Service from ultimately implementing a 

proposal that allocates more acreage to Nonwilderness than to 

Wilderness, it is troubling that the Forest Service saw fit to consider from 

the outset only those alternatives leading to that end result. [Id. at 768].

Similarly, in Center for Biological Diversity v. Nat. Highway Traffic Safety 

Admin., the 9th Circuit reviewed a range of alternatives that would 

regulate vehicle emissions through fuel economy standards. [Center for 

Biological Diversity v. Nat. Highway Traffic Safety Admin., 538 F.3d 

1172, 1218 (9th Cir. 2008)]. The court characterized the alternatives as 

“hardly different” from the agency’s selected alternative and noted that 

The analysis provides quantifiable distinctions between the 

alternatives. These differences are identified in table 9 of the 

FEIS.
BAppendix

Wrangell Island Project FEIS ♦ 208

Comment 

Number Comment Response

none of the alternatives would achieve anything more than a small 

decrease (1.8 to 2.6%) from baseline emission levels. [Id.]. The court 

explained that the agency considered “a very narrow range of 

alternatives” with a minimal range of impacts. [Id. at 1218-1219].

All of the alternatives derived from a single study - NHTSA’s 

cost-benefit analysis. [Id. at 1218]. The court concluded that NHTSA’s 

excuses for failing to consider more stringent standards that would allow 

for increased conservation benefits were flawed. [Id. at 1219].

Finally, in an analogous Tenth Circuit case, New Mexico ex rel. 

Richardson, the state of New Mexico and a coalition of environmental 

organization challenged a BLM land management plan amendment that 

would determine which public lands in the planning area would be open 

to oil and gas leasing. [New Mexico ex rel. Richardson, 565 F.3d 683, 

688-689 (10th Cir. 2009). The BLM eliminated alternatives that would 

have heightened environmental protections relative to the existing plan 

and considered only two alternatives despite extensive public comment 

requesting alternatives that would protect environmentally sensitive 

areas. [Id. at 709]. The court noted that there were “powerful” 

environmental values associated with eliminated alternatives that 

provided for more significant reductions in lands open to development, 

and concluded that multiple-use principles required the BLM to include a 

conservation-oriented alternative in its NEPA process. [Id. at 710-11; see 

also Muckleshoot Indian Tribe v. U.S. Forest Service, 177 F.3d 800, 812-

813 (9th Cir. 1999)(ruling that the Forest Service “failed to consider an 

adequate range of alternatives [where t]he EIS considered only a no 

action alternative along with two virtually identical alternatives”)].

Taken together, New Mexico ex rel. Richardson, Center for Biological 

Diversity, and State of Cal. all demonstrate that a reasonable range of 

alternatives must include alternatives that provide for meaningful 

comparison of courses of action that will generate conservation benefits 

– particularly when there are significant environmental values that 

counter the agency’s development interests. Here, the Forest Service 

has only considered a group of similar alternatives that will lead to a 

single result – at least 42 MMBF of timber for Alcan or Viking – all based 

on a single analysis without consideration of alternatives that would 

increase and enhance conservation of multiple use resources.

This comment accurately reflect the Wrangell Island Project 

analysis, which provides quantifiable distinctions between the 

alternatives. 

061-GSACC112. Dismissal of lower timber volume alternatives was improper 

based on the substantive direction provided by NFMA

The DEIS arbitrarily rejected four alternative design options that would 

reduce the adverse impacts of this project on important resource values: 

(1) improvements to the OGRs to address wildlife habitat needs; (2) 

The Wrangell Island Project Analysis has been prepared in 

compliance with NFMA and other applicable laws including the 

Tongass Timber Reform Act. The analysis also complies with the 

Forest Plan. 
Appendix B

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Number Comment Response

avoiding timber harvest in low-elevation old-growth areas; (3) avoiding 

timber harvest in heavily degraded watersheds and (4) avoiding no new 

road construction. [DEIS at 23-24].

The excuses for failing to include these measures were arbitrary. First, 

the agency insisted that OGR modifications should not occur during the 

TLMP amendment process without explaining whether or what 

improvements could or may be made (if any) through that process or 

acknowledging that the agency can and does routinely modify OGRs as 

part of project level planning. Second, the DEIS asserts that Alternative 

addresses low-elevation deer habitat but never proves it – the map of 

elevational contours does not display the Alternative 5 units, and it 

seems clear that, at a minimum, many of the 33% removal units are 

within or adjacent to areas identified as deep snow habitat. [Cf. DEIS at 

43, 81]. Moreover, it is unreasonable to characterize the removal of 42 

MMBF as mitigating wildlife habitat concerns even if it would result in 

somewhat less impact relative to the proposed action -- this volume is 

plainly too high given the impacts of past logging. Finally, it is evident 

that the purpose and need arbitrarily favors the timber industry by overemphasis on timber volume, while blocking alternatives that would avoid 

impacts of logging and road construction in the most heavily degraded 

areas of the island. This ignores the agency’s substantive mandates 

under NFMA.

An agency’s NEPA analysis must be informed by the laws driving the 

action being reviewed. See Or. Nat. Des. Ass’n v. U.S. BLM, 625 F.3d 

1092, 1109 (9th Cir. 2010). Here, NFMA and its implementing 

regulations provide the substantive duties with which the agency must 

comply in amending the Forest Plan. As described above, NFMA 

requires that forest plans provide for multiple uses, including recreation, 

watersheds, wildlife, and fish. [16 U.S.C. § 1604(e)]. NFMA also sets a 

hard floor with respect to managing flora and fauna populations: the 

agency must provide for the “diversity of plant and animal communities.” 

Id. § 1604(g)(3)(B).

Regulations in place at the time the 1997 TLMP was adopted, and when 

it was amended in 2008, provided that the Forest Service must provide 

sufficient habitat to support “at least a minimum number of reproductive 

individuals and that habitat must be well-distributed so that those 

individuals can interact with others in the planning area.” 36 C.F.R. § 

219.19. Regulations adopted in 2012 require the agency to determine 

whether plan components “provide the ecological conditions necessary 

to contribute to the recovery of federally listed threatened and 

endangered species, conserve proposed and candidate species, and 

The rationale for eliminating alternatives from detailed study, 

including those mentioned by the commenter, is provided in the 

“Alternatives Considered But Eliminated From Detailed Study”

section of chapter 2 of the EIS. Portions of this section have 

been revised to provide more clarity.

The purpose and need for the project is provided in “The Project 

Purpose and Need” section of chapter 1 of the EIS. Additional 

information is presented in the section “Why Is This Project 

Important?” in chapter 1 of the EIS. Appendix A of the EIS 

provides information supporting the project’s purpose and need 

and proposed action.

The project does not propose any amendments to the Forest 

Plan.

The project provides a range of alternatives to address the 

issues while meeting the purpose and need of the project. Also 

see response to comment 058-SEACC-04 and 061-GSACC-03 

and 061-GSACC-10.

Plant and wildlife viability is addressed at the Forest Plan level. 

Wildlife habitat, fisheries and scenery are addressed in chapter

3. Low elevation and deep snow habitat are included in the 

analysis.

The commenter mixes resource management requirements at 

the Forest Plan and project levels. The Wrangell Island Project 

analysis is a project-level analysis with a purpose to provide a 

timber supply from an area which the Forest Plan has identified 

as available for harvest, specifically, the Timber Production, 

Scenic Viewshed and Modified Landscape Land Use 

Designations.
BAppendix

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maintain a viable population of each species of conservation concern 

within the plan area.” 36 C.F.R. § 219.19 (2012).

The Forest Service ignored its substantive duties under NFMA with 

respect to wildlife and plant populations in developing its narrow set of 

alternatives. The alternatives proposed by the Forest Service are entirely 

driven by the selection of timber industry goals set forth in the 

Secretary’s Memorandum, which expresses not the intent of Congress, 

but the desires of the executive branch. It is the former that carries more 

weight for the purposes of the NEPA analysis. See Or. Nat. Des. Ass’n, 

625 F.3d at 1109 (explaining that the considerations made relevant by 

the substantive statute driving the proposed action must be addressed in 

the NEPA analysis).

Plainly, plant and wildlife viability are a central purpose of NFMA and its 

implementing regulations. This should have been a driving feature 

behind the development of alternatives. [Cf. id.] Lower volume 

alternatives would elevate substantive viability considerations. And it 

would give the agency the opportunity to effectuate NFMA’s mandate to 

meet multiple use objectives—not just intensive timber harvest. The 

agency’s dismissal of lower volume alternatives on grounds that it did not 

facilitate the narrow commercial timber harvest goals failed to reconcile 

the agency’s substantive obligations. See id. (explaining that the 

“statutory objectives underlying the agency’s action work significantly to 

define its analytic obligations”); cf. id. at 1124 (where BLM in amending 

management plan considered no alternative that proposed closing more 

than a fraction of the planning area to ORV use, agency violated NEPA 

because it "uncriticall[y] privilege[d] one form of use over another”).

3. Conclusion: The Forest Service needs to issue a revised DEIS 

with downscaled alternatives that address wildlife habitat, fisheries and 

scenery

Ultimately, the failure to include lower volume alternatives was 

necessary to meet NEPA’s requirement to “foster informed decisionmaking and informed public participation.” [California v. Block, 690 F.2d 

at 767]. Only by studying a reasonable range of alternatives can the 

agency adequately compare the environmental impact of its proposed 

action, and allow the public to weigh in on alternative courses of action. 

[See 42 U.S.C. § 4332]. The alternatives requirement is critical to serving 

NEPA’s primary purposes of ensuring fully informed decisions and 

providing for meaningful public participation in environmental analyses. 

[See 40 C.F.R. § 1500.1(b), (c)]. By examining both the environmental 

impacts of the desired path and the impacts of other reasonable 

alternatives, NEPA enables an agency, and the public it serves, to 
Appendix B

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Comment 

Number Comment Response

evaluate whether the government has other options it could take that 

might be less damaging to the natural environment. [Headwaters, Inc. v. 

Bureau of Land Mgmt., 914 F.2d 1174, 1180 (9th Cir. 1990); California v. 

Block, 690 F.2d at 767]. Here, the agency’s selection of only high volume 

alternatives deprived the public and the decisionmaker this fundamental 

exercise required by NEPA. [California v. Block, 690 F.2d at 768 (“While 

nothing in NEPA prohibits the Forest Service from ultimately 

implementing a proposal that allocates more acreage to Nonwilderness 

than to Wilderness, it is troubling that the Forest Service saw fit to 

consider from the outset only those alternatives leading to that end 

result.”)].

061-GSACC12C. The DEIS fails to disclose the impacts from partial cutting, 

content on the topic notwithstanding

The Forest Service relies on a large amount of partial cutting for the WIP 

[DEIS at 66], in an attempt to show mitigation of impacts to scenery 

[DEIS at 42] and to wildlife and hunters [e.g., DEIS at 104]. Also, the 

economics of the project are sure to be highly sensitive to the overall 

timber volume obtained from partial cut units generally, and particularly 

to the volumes obtained from each species tree. As noted above, the 

major portion of the logging from the proposed alternative would, on an 

acreage basis, be accomplished with partial cut logging. This 

alternative’s 3,528 acres of partial cut units are 66% of 5,309 acres of 

units. In Alternatives 3 through 5, 47% to 75% of the units are partial cut.

By the term “partial cuts” we refer to logging units in which a substantial 

portion of the timber in a unit will be retained (not cut). In the case of the 

Wrangell Island Project, the amount of retention in partial cut units will be 

67 percent. [See e.g., DEIS at 21, 95, 222, 224 and 234]. However, the 

DEIS provides four differing, incompatible descriptions of the nature of 

this retention and how it is measured. According to one view, “one-third 

of the stand would be removed,” or secondly and somewhat equivalently 

that “66 percent of the old-growth stand structure” would be retained. 

[DEIS at 21 (Ch. 2 Wildlife section); and 234 (Ch. 3 Soil section)]. 

Another view is that the retention would “maintain 67 percent of the 

stand volume.” [DEIS at 95 (Ch. 3 Wildlife section)]. The authoritative 

word is in the Ch. 3 Silviculture section, which says in the partial cut 

prescription “approximately 67 percent of the stand’s pre-treatment basal 

area would be retained ... this treatment would remove approximately, 

but no more than 33 percent of the basal area.” [DEIS at 220-221 and 

222]. The DEIS analyses for various wildlife species assume that the 

impact of partial cutting on their habitats is exactly equal to the 

prescription’s percentage of removal (e.g., the deer modeling assumes 

The estimated effects of the partial harvest on each resource are 

provided in chapter 3 of the EIS and in the individual resource 

reports. The effects analysis was appropriately conducted for 

each resource based on the best available information. Each 

resource analysis uses units of measure applicable to that 

specific resource to estimate effects; in order to provide 

meaningful results. Many resources use area or percent of area 

affected or area remaining to describe effects. Basal area is a 

unit measure used in the silviculture effects analysis and has 

limited use in describing effects on other resources. 

The Wrangell Island Project proposes partial harvest rather than 

clear cut harvest in some units in order to meet Forest Plan 

scenic integrity objectives. The partial harvest or uneven-aged 

management will retain at least 67% of the stand’s basal area. 

This level of retention would meet scenery objectives and the 

harvested areas would be minimally detectable to casual 

observers. The remaining trees would also provide wildlife 

habitat with old-growth structure and elevational corridors. 

Trees would be harvested across the stand individually or in 

small groups creating openings less than two acres in size 

similar to the natural gap dynamics found in old growth forests. 

Helicopter yarding would be used when stands could not be 

economically accessed by roads. The types of trees selected for 

retention would be those trees that provide visual cover or 

texture from a distance, trees with high wildlife habitat value, and 

trees with future timber value. Trees with low economic value 

would also be left to provide old growth structure and wildlife 

habitat. 
BAppendix

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that 33% removal equates to clearcutting one-third of the unit). 

[634_1102 at 99 (WIP wildlife report)].

The problem here is that the proportion of basal area removal (or in the 

converse, the proportion retained) is not equivalent to a like proportion of 

the overall timber volume, nor is it representative of the impact on the 

unit’s overall “stand structure” (for which a unit of measure does not 

exist). Therefore, important analyses in the DEIS are based on 

fundamental misunderstandings of one of the major features of the 

project  the high proportion of the unit a cre a ges tha t a re pa rtia l cut.

To reach an understanding of how the Forest Service grappled with the 

basal area versus timber dilemma, Greenpeace staffer Larry Edwards 

met with the Wrangell District Ranger and the WIP IDT leader in 

Wrangell on July 11, and had a follow-up phone calls with them and the 

project’s IDT timber specialist on July 15 and 18. [Exh. D-28 (Edwards 

notes)]. What he learned concerning partial cut units is that:

1) The planning team does not yet known, for any unit, whether 

the tree removal by the single tree selection method will be by taking a 

distribution of individual trees across the unit or by taking clusters of 

trees.

2) It is not yet known, for any unit, what percentage each tree 

species will comprise the unit’s total number of cut trees or total removed 

timber volume. Edwards pointed out that the representation of this in 

DEIS Table 12 shows identical percentages by species for each 

alternative (when calculated). The reply was that the data in the table 

represent the average species composition on Wrangell Island, not 

individual alternatives. Species composition of each unit and each 

alternative will be determined later.

3) The above particulars for application of partial cutting are not 

known because at this point the basal areas of trees in the units are not 

yet known, nor is how the one-third basal area to be removed would be 

allocated across a unit. Further complicating this, some portions of units 

that would be helicopter-yarded may have no timber removal.

4) Because the basal area information does not yet exist for the 

project's units, the estimated timber volume yield for each one was 

assumed to be one-third of the unit's total volume, as calculated from its 

stand exam. A stand exam has been done for each unit.

a. Note: This puts information in the DEIS in conflict with the 

partial cut prescription, because the actual volume yield will be 

determined on how basal-area-related decisions will lay on the land, not 

the arbitrary assumption that partial cut yield can be determined directly 

from the stand exam. On this point the district ranger volunteered as an 

New trees would naturally regenerate in the created openings; 

perpetuating multiple age and size classes and promoting 

species diversity, forest productivity, and forest health. The 

resulting stand would maintain and promote variable densities of 

trees of different ages and crown classes with inter-mixed large 

older trees, intermediate trees and young trees. This would 

maintain or improve the pre-harvest diversity of the stand. All of 

the timber species present in the original stand would continue to 

be present in the new stand. 

It is unnecessary and impractical to identify the spatial location, 

size, and species of each tree to be harvested in the stand in 

order to determine effects, as implied in the comment. The 

Wrangell Island Project analysis used a standard practice, where 

the volume estimates are based on coarse scale stand mapping 

and stand exam plots with an intensity level of one plot per ten 

acres. This is cost-effective and is sufficient to estimate volumes 

and conduct an analysis of the environmental effects to other 

resources. The volume and species information would be refined 

during the implementation phase of the project. The specific 

trees to be cut in each unit would be determined during 

implementation using marking guidelines developed from the 

silvicultural prescriptions (located in the project record) and data 

from more intensive stand exams. 

The methods used to estimate the effects to wildlife, including 

deer, are used appropriately. The deer model used in the 

analysis was developed in the early 1990s when clearcutting 

was the primary silvicultural prescription. There are no other 

accepted deer models available which analyze for partial 

harvest. Since the coefficients of the deer model are fixed for 

clearcutting, all harvest units, including the partial-harvest units, 

are treated as though they had the same effects on deer winter 

habitat as a clearcut. This approach likely over-estimates the 

effects on deer habitat. The actual effects would be less than 

presented because the remaining trees in the stand would 

continue to provide deer habitat. 

The timber volume estimates in the EIS were derived from data 

obtained from stand exams, field observations, and aerial photo 
Appendix B

Wrangell Island Project FEIS ♦ 213

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explanation that the DEIS is based on "coarse data" and that "it is a 

paper plan of crudest form." The DEIS fails to disclose that it has these 

serious shortcomings or that the described conflict exists.

5) Copies of the stand exams were requested at the July 11 

meeting because they are not in the planning record. The request was 

denied because the stand exams are a work in progress and therefore 

are not available to the public.

6) The DEIS erroneously says that the deer modeling assumed 

that one-third of the partial cut units would be logged. GIS specialist 

Gene Primaky said on a phone call the modeling actually those entire 

units would be clearcut.

The upshot of this investigative work is that throughout its content the 

DEIS makes baseless representations on the amount and value of 

timber the project will produce and the impacts on other resources. The 

representations are presented as fact, with no indication that 

foundational data concerning the forest components that would be 

removed (or retained) is incomplete or based on sketchy assumptions. 

Instead, the actual outcomes of the project are likely to be quite different 

than what the DEIS claims.

Further, the partial cutting prescription  a s a pplie d s o fa r in the WIP 

project  is a black box which le a ve s to the pos t-NEPA implementation 

phase of the project all the consequential decisions that are necessary 

for determining the economic, scenery and wildlife impacts of the project. 

This, in combination with the marginal-at-best economics of the project 

and the agency’s drive to make the project economical and sellable, 

leaves the outcome of project open to presently undisclosable highgrading of important wildlife habitat or on a tree species basis. The 

problem here is that the DEIS is premature, in being issued now instead 

of after the partial cut unit layouts have been made, which would make 

the necessary information for an adequate NEPA analysis available. The 

project’s NEPA process schedule, in relation to the unit layout schedule, 

may be suitable for a clearcut project, but it precludes adequate NEPA 

analysis for a project that has a substantial amount of partial cutting. 

What the Forest Service is doing here is authorizing logging on over 

3,000 acres without preparing an adequate environmental analysis under 

the assumption it can defer such analysis pending further site-specific 

review. This is impermissible under NEPA, which requires evaluation of 

environmental impacts prior to the point of commitment.

We discuss the ramifications of those problems in detail in our sections 

on economics and wildlife, and the present section should be read in 

concert with each of them.

interpretation which were processed through the FSVeg model. 

The stand exam reports have been added to the project record. 

Timber volumes from partial-harvest units were estimated by 

using stand exam data and assuming that one-third of the 

volume of the harvest unit would be removed. This is an 

appropriate method for estimating volumes for comparison of the 

alternatives in the EIS. The timber volumes estimates would be 

refined during implementation with data from a more intensive 

timber cruise.

Timber value estimates were based on the stand exam data and 

averages processed through the FAST-R economic model. 

Timber values would be refined during implementation with data 

from a more intensive timber cruise.

The Forest Service regrets any misunderstanding that resulted 

from the variety of separate verbal conversations with the 

commenter. 

Terms and descriptions related to partial harvest have been 

clarified in the FEIS and resource reports.

More detailed information is provided in the “Silviculture” and 

“Wildlife Habitat” sections in chapter 3 of the EIS and in the 

Silviculture and Wildlife Resource Reports. 

Also see response to comment 061-GSACC-34.
BAppendix

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061-GSACC13D. The DEIS lacks sufficient information to evaluate the project 

concerning many important issues

IDT meeting notes from 2014 state that the "EIS will be simplified to

make sure we are clearly communicating with the public." [634_0087 

(3/21/14)]. We believe this has been taken to an extreme in the DEIS, to 

the point that some sections are so thin that the impacts of the project 

cannot be reasonably evaluated. This is notable in comparison to NEPA 

documents of other recent projects. If simplified communications are 

necessary, that should be done through a separate summary document. 

The purpose of an EIS is to provide necessary disclosures of 

environmental impacts, and a full and fair analysis of them, and 

simplification in this case has conflicted with that.

The Wrangell Island Project EIS was written in compliance with 

the Plain Writing Act of 2010 which requires public documents to 

be written in a “clear, concise and well-organized” manner and is 

“appropriate to the subject or field and intended audience”. 

The DEIS provides a summary of the information in the resource 

reports and other additional analysis as required by the National 

Environmental Policy Act itself (40 CFR 1500.4). Comparison to 

previous EISs notwithstanding, 40 CFR 1500.4 states that 

“Agencies shall reduce excessive paperwork by...preparing 

analytic, rather than encyclopedic [EISs and]...[emphasize] the 

portions of the environmental impact statement that are useful to 

decisionmakers and the public...and reducing emphasis on 

background material.” Such background material and in-depth 

resource analysis is conducted and discussed in the resource 

reports, and is further supported by information in the planning 

record. 

061-GSACC14II. Significant Issue One: Comments on Timber Supply and 

Economics

A. The Timber Supply and Demand section of the DEIS is 

incomplete, triggering the need to prepare a revised DEIS

The DEIS asserts that timber supply from public lands on Wrangell 

Island is necessary to contribute to local and regional economies. [DEIS 

at 10]. The Forest Service believes there is a need 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.” [Id. at 4]. The DEIS asserts that the project would meet the stated 

purpose and need by providing an “orderly flow of timber to large and 

small timber purchasers, mill operators, and value-added wood product 

industries in southeast Alaska and benefit the local and regional 

economies of Wrangell and Southeast Alaska while also improving 

resource conditions.” [Id.].

The DEIS fails to show how the project would meet these goals. It 

provides a five page discussion of timber economics and availability that 

ignores important factors such as what timber operators are likely to be 

active in the project area, market trends, alternative sources of timber, 

and whether possible employment opportunities arising from the sale 

would actually benefit southeast Alaskans. [Id. at 62 – 67]. Indeed, the 

analysis specifically avoids considering market trends, [Id. at 62], the role 

The analysis demonstrates that the project would meet the 

purpose and need to provide an orderly flow of timber to 

industry. This is described in the “Timber Economics and 

Availability” section of chapter 3 of the EIS, appendix A of the 

EIS, and the Timber Economics Resource Report. The current 

operators are identified. The cumulative effects address 

reasonably foreseeable timber from other land owners. Market 

trends are speculative. The markets have been extremely 

volatile and it is not known what the market conditions might be 

at the time of a sale offer. The timber from this project would be 

offered by competitive bid and it is unknown who the successful 

bidder would be. The project would supply timber for both large 

and small operators.

Please refer to the Timber Economics Resource Report for 

discussion on timber operators and alternative sources of timber. 

Market trends are highly volatile and difficult to predict, and 

future market trends are unknown.

The Tongass is obligated by law to seek to meet market demand 

while taking into account all forest resources. TTRA Section 101 

states “...the Secretary shall, to the extent consistent with 

providing for the multiple use and sustained yield of all 
Appendix B

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of the timber industry in the regional economy, [Id. at 63], and whether 

the no-action alternative would still adequately provide adequate 

volumes of timber for large operators given the availability of state, 

private and other federal timber. [Id. at 65].

renewable forest resources, seek to provide a supply of timber 

from the Tongass National Forest which (1) meets the annual 

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

market demand from such forest for each planning cycle.”

There is NEPA-cleared volume that is not already slated for 

small timber sales either through the decision by the 

Responsible Official or through informal appeal resolutions. See 

the Wrangell Island Project FEIS, appendix A.

See response to comment 061-GSACC-04 for discussion of the 

numbers FAST-R produced to compare the alternatives. The 

results of all FAST-R runs are in the project record. Regional 

economic reports are provided in the project record.

061-GSACC151. The DEIS failed to identify regional timber operators or consider 

the availability of other timber sources

The DEIS implies that there are a large number of potential bidders for 

Forest Service timber sale projects. [DEIS at 63]. This suggestion is 

false. As noted in Section I of these comments, there is no realistic 

domestic processing scenario for Viking given the extremely negative 

value of the remaining old-growth on Wrangell Island. The size and 

location of this project thus make clear that the Forest Service is 

designing this project for Alcan, which has been the only purchaser of 

large timber sales from the Wrangell Ranger District over the past 

decade. We question whether timber supply for Alcan in the project area 

is a significant issue given the availability of state, other federal, and 

private land timber – or even Canadian timber given Alcan’s status as an 

international timber broker. [Exh. D-08 (Alcan on TransPac Group 

website); D-06 (Ak Jrnl of Commerce 2006); D-56 (Nichols 2014)]. Our 

scoping comments requested that the DEIS evaluate the availability of 

other sources of timber for Alcan and consider timber supply and 

demand in light of Alcan’s logging history in the Wrangell Ranger District.

Alcan’s utilization of federal timber does not support the development of 

a project of this scale. Alcan entered into a contract for timber from the 

Skipping Cow project on November 1, 2005 and had cut 12.7 MMBF as 

of 2014, or slightly over 1 MMBF per year. [Id.] Alcan took over five years 

to cut timber from the 3.8 MMBF Backline sale. [Id.] It has cut slightly 

more than 1 MMBF per year from the Frenchie Stewardship project and 

also has a contract for the Zarkof Salvage project, even though both 

sales are likely to be 90 – 100% exported. [DEIS at 63; 634_0775; 

_0796; _0797]. There is also 13.1 MMBF available from 1,252 acres on 

The number of potential bidders may vary on each contract 

depending on the size of the sale. While it is true there are few 

larger operators, the most current volume under contract can be 

found in appendix A of the Wrangell Island Project FEIS. It

shows that there are over 40 operators with contracts. Over 100 

purchasers have had contracts over the last 15 years at one time 

or another. 

As noted in the Timber Economics resource report, in the 

economic modelling the timber was appraised to the Viking Mill 

in Klawock, Alaska and includes water tow costs because that 

mill already exists. It is not known where the Wrangell Island 

Project timber would be processed which would be a business 

decision for the successful bidder. The sales would only be 

offered if they have positive indicated rates. It is important to 

note that timber from the project would be offered in a 

competitive process that is open to all qualified bidders. It is not 

known who the successful bidder would be or where the timber 

would be processed. Those are determined through individual 

business decisions. 

A discussion about the number of operators, including those on 

Wrangell Island, is provided in chapter 3 of the EIS and in the 

2016 Forest Plan Amendment FEIS pages 3-485 through 3-490.
BAppendix

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nearby Etolin Island. [Exh. D-83 at R-1 (Navy project 2015 ROD)]. Thus, 

given Alcan’s recent utilization of timber from the Wrangell Ranger 

District, it appears that there is no demand for the volume of federal 

timber proposed for this project (and particularly, no demand in 

southeast Alaska).

Alcan has timber available from an Alaska Mental Health Trust Sale on 

Wrangell Island and a state of Alaska timber sale on Zarembo, all of 

which are 100% exportable. [634_0775]. Additionally, the Southeast 

Alaska state forest system now includes 5,519 acres in the Wrangell 

Island project area alone, with large units in the Pat’s Creek watershed 

and along Eastern Passage and Earl West Cove. [634_0831]. The DEIS 

failed to assess the amount of acreage that would be made available 

through non-federal timber sales and discuss how much of that acreage 

could be sold per year pursuant to Alaska’s sustained yield management 

or provide appraisal and any other economic data that would be useful 

for purposes of comparing the economic efficiency of state of Alaska 

cutting units versus TNF cutting units. Further NEPA analysis 

should consider these and all other pending state and private timber 

sales on Mitkof, Wrangell Island and surrounding smaller islands prior to 

determining whether there is actually any demand for federal timber from 

Wrangell Island at the scale of the proposed action. The DEIS failed to 

adequately consider outside timber sources, and the analysis is 

incomplete. The Forest Service needs to produce a revised DEIS that 

includes a detailed analysis of regional timber operators, their historical 

utilization of timber from the project area and adjacent islands, and 

respond with downscaled action alternatives.

Your views on the business operations of Alcan and Viking 

lumber companies are noted.

Other potential sources of timber from other land owners are 

addressed under “Cumulative Effects” in the “Timber Economics 

and Availability” section of the EIS. Aspects of the State of 

Alaska’s timber sale program are beyond the scope of this 

project. The cumulative effects are defined by the analysis area 

of Wrangell Island. The timber market demand is determined at 

the regional level and is outside the scope of this project 

analysis. 

See response to comment 061-GSACC-14.

061-GSACC16a2. The DEIS failed to evaluate Alcan’s utilization of National Forest 

Timber or provide information about local employment

Given that there is ample supply and little local demand, our scoping 

comments requested that the most significant issue in the timber 

economics section of the DEIS should be local utilization. The Forest 

Service should have included a downscaled, local utilization alternative 

given the project's local and regional economy objectives. Previous 

Forest Service objectives for Wrangell Island aimed primarily at jobs on 

the island, and a wood products supply for local industry. [634_0767 at 9 

(1998 WIA)]. But the DEIS arbitrarily omitted an assessment of the 

number of jobs and the amount of revenue the project will generate for 

the community of Wrangell. It also failed to provide a realistic 

assessment of the timber volume by species and grade that is likely to 

be transshipped or exported.

The timber from this project would be offered in a variety of sales 

including small sales. The timber would be offered by 

competitive bid. 

Your assertion that there is ample supply and little local demand 

is noted but not supported by timber industry representatives. 

Litigation has an effect on reliable supply of timber to industry. 

The timber economics and employment are addressed at the 

regional level, which includes information from Wrangell Island. 

The DEIS inadvertently left out the employment information from 

chapter 3, Issue 1 but it was in the comparison of alternatives 

table in DEIS, chapter 2. The estimated employment supported 
Appendix B

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Comment 

Number Comment Response

is provided in the “Timber Economics and Availability” section of 

chapter 3, Issue 1 of the FEIS, and summarized in the alternative 

comparison table in chapter 2. It is not known whether these jobs 

would be provided to Wrangell residents at this time, but local 

businesses usually gain revenue since the project is connected 

by road system to the community of Wrangell.

The amount of timber by species that would be exported is not 

known and would depend on the export policy in place at the 

time of award and the successful bidder’s business decisions. 

See response to 58-SEACC-14. 

061-GSACC16bThe analysis provided a range of potential local employment impacts 

under the assumption that there could be local sawmill utilization of 

cedar. That practice is misleading and we request that a revised DEIS 

provide employment and income tables that reflect the reality of raw log 

export and transshipment. This information is critical so that the public 

can evaluate the extent to which this project generates local wood 

processing employment.

Also, nearly half the value of Tongass timber projects derives from 

cedar. The DEIS failed to provide information regarding the respective 

values of tree species utilized locally versus those exported or 

transshipped without primary processing. This information is also 

important so that the public can assess how much of the public 

investment in this project will be returned to the regional economy. If 

Alcan brings in non-local loggers, and then ships the logs to China, 

Wrangell loses fish habitat, tourism opportunities and wildlife and gets 

nothing in return.

See response to comment 061-GSACC-16a. 

Please note that the Wrangell Island Project EIS states that 

yellow-cedar is assumed to be 100 percent exported because it 

was surplus to Alaska’s needs by the Secretaries of Agriculture 

and Interior in 1969.

The analysis included assessments for both export and domestic 

processing. The amount and species permitted for export is not 

known at this time. The amounts and species that would be 

exported would be determined by the export policy in place at 

the time of the sale award and the business decisions of the 

successful bidder. See the Timber Economics Resource Report 

for a discussion on the export policy.

061-GSACC16cAlcan’s operational history suggests that this project will not meet project 

objectives related to local economies. By 2014, Alcan had exported 

7,477 MMBF of Sitka spruce and western hemlock, and 2,081 MMBF of 

Alaska yellow cedar out of the 12.7 MMBF cut from the Skipping Cow 

project – or over three-quarters of the total volume. [Scoping exhibits 

634_0778; 0781; and _0790 through 0793].28 The Forest Service has 

made clear that timber purchasers may increase exports of hemlock and 

spruce in excess of limits established under the 50% export/domestic 

processing policy and authorized Alcan to export more than 50% of the 

volume from Zarembo Island. [634_0775]. Indeed, Alcan has only one 

buyer of any significance for domestic logs – Viking Lumber – and is not 

able to sell large amounts of timber to Viking. This results in Alcan’s 

exportation of logs in exceeding the Alaska Region’s export policy. 

See response to 061-GSACC-16a and -16b, above. The Region 

10 export policy is evaluated on a case-by-case basis at the 

request of the successful bidder. The export policy is reevaluated annually by the Regional Forester. Timber from the 

Wrangell Island Project would comply with the export policy in 

place at the time of the sale award. The current export policy 

was used in the analysis. It would be speculative to analyze for 

other export scenarios. 

In the case of Skipping Cow Timber Sale, which is outside the 

scope of the Wrangell Island Project and currently under 

contract, the Regional Forester reviewed and approved 
BAppendix

Wrangell Island Project FEIS ♦ 218

Comment 

Number Comment Response

[634_0830 (Nichols 2013, Alcan request for export limit waiver)]. Thus, 

although the Alaska Region admits that its practice of waiving the policy 

is “inconsistent” with policy, it readily grants waivers so that the 50% outof-region processing policy is a floor rather than a ceiling. [634_0775; 

_0778; _0781; and _0790 through _0794]. Thus, the analysis should 

contemplate exports and interstate shipments in excess of the Alaska 

Region’s policy.

additional export. This is in line with the current policy and 36 

CFR 223.201 which states “Unprocessed timber from National 

Forest System lands in Alaska may not be exported from the 

United States or shipped to other States without prior approval of 

the Regional Forester.” The rationale for allowing this additional 

export is outlined in the 4/8/2014 letter. 

061-GSACC173. The DEIS arbitrarily fails to consider timber demand market 

trends

The DEIS failed to make an effort to consider local timber demand 

separately from the Tongass National Forest’s export program. It fails to 

consider market trends in any meaningful way and simply states that 

“this analysis is limited to a snapshot in time based on available 

information and does not speculate on timber market fluctuations” and 

suggests that “the value of timber or costs may increase or decrease.” 

[DEIS at 62]. This assertion is arbitrary; the analysis does not consider 

available information on market trends.

Other federal timber remaining from Wrangell Ranger District sales “is of 

quality that will be difficult to process domestically and therefore meet 

the 50% domestic processing requirement.” Further, current market 

trends reflect a “substantial” decline in U.S. lumber prices. [634_0835 at 

4-5]. Given the low quality of remaining timber in the project area, and 

long-term domestic lumber market trends, the DEIS should have 

factored local demand into its economic analysis.

Also, the DEIS needed to reconsider Forest Service timber demand 

scenarios that reflect the assumption that export markets justify 

increased timber extraction in the region. The economic scenarios need 

updating in order to consider the substantial weakening of export 

markets and the competitive disadvantage of Alaska and Pacific 

Northwest raw log exporters. China is the primary consumer of west 

coast timber exporters; overall, nearly two-thirds of U.S. log exports are 

sent to China. [634_0833, 0834, 0836 at 6]. Recent Pacific Northwest 

Research Station press releases indicate that both the value and volume 

of log exports from Alaska and the West Coast are declining and at a 

much greater rate than other timber exporting regions. [Id.]. These data 

are consistent with industry projections finding that that Alaska and other 

Pacific Northwest log exporters are losing their market share, and are at 

an even greater competitive disadvantage relative to Canadian and 

southern U.S. timber operators. [634_0836 at 11].

In sum, there is little demand and poor markets for locally produced 

sawtimber for a project of this scale. Additionally, regional timber 

See response to comment 061-GSACC-14, -16a and -16b. 

Timber market trends are part of the market demand calculations 

and analysis done periodically by the Pacific Northwest 

Research Station for the entire Tongass timber program and not 

for project-level analysis since these trends are reflective of the 

regional program. A discussion of local operators is located in 

the Timber Economics Resource Report. 

Your assessment of timber demand and markets is noted.
Appendix B

Wrangell Island Project FEIS ♦ 219

Comment 

Number Comment Response

exporters face weakening foreign markets and the historical competitive 

disadvantage relative to other timber exporters appears to be increasing. 

Both economic issues warranted detailed analysis in the DEIS. A revised 

DEIS needs to consider actual market trends.

061-GSACC18a. The DEIS fails to take a hard look at known & reasonably 

foreseeable market trends & fluctuations

The DEIS [at 62] claims on the one hand that the economic analysis 

does not speculate on economic fluctuations, yet on the other hand the 

purpose of the project is to manipulate fluctuating conditions (to 

transform the old-growth industry into a second-growth one, which 

contributes to a sustainable regional economy). Economic planning and 

market manipulation is at the very core of the project. It is therefore 

disingenuous to pretend market fluctuations are unknowable or not 

relevant.

The DEIS claims that survival of the timber industry depends on a 

predictable and adequate supply of timber. [DEIS at 63]. Please provide 

objective data in support of this contention. We fundamentally disagree 

that lack of federal timber supply is the primary, or even a very important, 

factor in the collapse of the timber industry. A massive loss of timber and 

mill jobs in Alaska and the Pacific Northwest in the 1980s and 1990s was 

driven primarily by automation and the increasingly globalized 

marketplace. Additional timber volume doesn’t change anything about 

those underlying economics.

The Forest Service is making an even more controversial claim here, 

which is that by manipulating an increase in timber volume this will result 

in a directly corresponding increase in the economic contribution of the 

timber industry. It could be, however, that rather than creating a new 

local job, increasing available Forest Service volume would simply cause 

people to temporarily shift effort there rather than on timber from another 

landowner. The Forest Service approach to economics also relies on the 

unwarranted assumption that by increasing the overall volume of the 

sale we are increasing positive economic impact, even though an 

operator could certainly make more profit by dropping non-economic 

units. A 20- acre unit that profits $100 is better, economically, than a 30-

acre unit that profits $10. The obvious result of that flawed approach is 

that a great many of the proposed units are grossly uneconomical. 

Because the sale has been designed to provide maximum volume, the 

most profitable units are joined up with as many of the money-losing 

units as can be made to fit and remain economic. The volumemaximizing approach to sale design (in all alternatives) entirely neglects 

this critical factor. Please consider it.

See response to comment 061-GSACC-14, 16a, -16b, and -17, 

and the 2016 Forest Plan Amendment FEIS for discussion on 

market trends.

Market trends and fluctuations need to be analyzed for the entire 

Tongass timber program and not on a project-by project basis. 

Therefore, the Tongass timber program is discussed in the 

Wrangell Island Project FEIS, appendix A. 

Market conditions are relevant but aren’t easily predicted for the 

future. The timber industry relies on and needs a predictable and 

adequate supply of timber. A predictable and adequate supply of 

timber is necessary for purchasers to obtain the capital needed 

and experienced employees to successfully operate. 

The financial efficiency analysis discussed in the DEIS and 

Timber Economics Resource Report follows the direction in FSH 

2409.18 and Supplement R-10 2409.18-2013-1.

The timber quantity and quality vary within the harvest units of 

the project area. The alternative unit pool provides flexibility in 

responding to varying market conditions at the time of the sale 

offer. However, at the time of a proposed offering, if there are 

more units available there is the opportunity for greater flexibility 

to respond to varying market conditions. 

The analysis during the NEPA process is conducted at the 

project level rather than by individual harvest unit. The financial 

efficiency analysis is completed using the FAST-R model and the 

results are used as a relative comparison of the alternatives. The 

actual economic conditions of any resulting sales could not be 

known until the time of the sale award. 

Harvest units, including those that have had previous microsales, 

would be cruised to statistical standards during implementation.
BAppendix

Wrangell Island Project FEIS ♦ 220

Comment 

Number Comment Response

The economic analysis in the EIS needs to include a good deal more 

specificity. Table 12, for example, ought to include more site-specific 

breakdown. Each unit should be analyzed particularly as to its 

profitability, and that information should be front and center in the text of 

the EIS. This is a point of agreement between all interest groups. 

Operators gain nothing when they lose money logging un-economic 

units. If the Forest Service wants to boost the local economy by paying 

people do lose money, then surely it could find a more productive thing 

for them to do than mow down old-growth forests. The unprofitable units 

should in all likelihood be dropped from preferred alternative.

Past actions relevant to economics should be considered on a sitespecific basis. The June 20, 2012 IDT meeting notes for example 

indicate that some of the units proposed for this project were previously 

included in timber sales, but were dropped by the contractor due to poor 

economics on the site. This sort of information should be included and 

analyzed in the EIS.

Similarly, the helicopter and partial cut units should be examined 

specifically and the relevant economic factors disclosed. The helicopter 

units that are proposed don’t seem to offer a very economic option. It 

also needs to be considered that helicopter sales are unsuitable for 

small, local mills, as they require an economy of scale to justify the huge 

up- front cost.

The issue of fall-down in timber volume post-decision should be 

addressed up-front. The May 20, 2015 briefing paper internally advises 

that “actual volumes would likely be substantially lower” than the 

estimates. Representatives of Greenpeace and Cascadia visited many of 

the proposed logging units last week (July 18-20) and were struck at the 

poor economic prospects of most of the units. The low productivity of

most of the sites is obvious, but reliable timber cruises should be 

incorporated in to the EIS process to consider the factor objectively. 

Several units that are proposed here have already been partially logged, 

presumably as part of road-side microsales or free use programs. In 

those locations it was apparent that the best, biggest trees that were 

closest to the road were targeted. It is concerning that this logging does 

not appear in the EIS or on any of the maps. The economics of most of 

these units are so challenged to begin with, that when the five or six best 

trees have already been removed from a given unit the impact on 

volume and economics is going to be appreciable.

Also see response to comment 061-GSACC-12.

061-GSACC194. The DEIS failed to evaluate market-based local and regional 

economic transitions

The regional economy benefits from a diverse economy that 

consists of mining, recreation, fishing, maritime services, 

aquaculture and timber harvest. Timber harvest directly supports 
Appendix B

Wrangell Island Project FEIS ♦ 221

Comment 

Number Comment Response

Where economic opportunities are a key component of a decision, the 

Forest Service needs to ensure that there is a rational basis to assume 

that a project will provide promised benefits in terms of employment and 

economic activity. Our November 2015 scoping comments requested 

that the DEIS consider the declining role of federal timber in terms of 

providing meaningful economic impacts to Wrangell and the regional 

economy. This project will entail considerable expenditures of natural 

capital and taxpayer subsidies based on the assumption that the Forest 

Service has the ability to facilitate a wood products industry through 

large-scale timber removals from public lands.

The DEIS needed to evaluate the extent to which the Forest Service can 

provide a greater benefit to local economies and to rural stability through 

investments in meaningful fisheries habitat remediation projects and 

recreation projects that may yield business opportunities and quality of 

life improvements for rural residents. For example, the Wrangell Ranger 

District has previously noted a general public interest in more trails, 

including for winter recreation, and more cabins, shelters and campsites 

for local use, and outfitter guide use by a growing marine recreation 

industry. [634_0767 at 5 (1998 WIA)].

We thus requested that the DEIS provide a detailed discussion that 

describes the market- based, natural transition of the Wrangell economy 

toward tourism, fishing and maritime services. These changes are highly 

relevant to the purpose and need and balance of the environmental 

costs and benefits of the project. In particular, the DEIS needed to 

consider the economic trade-offs, including the effects of timber harvests 

and related activities on commercial fishing and recreation in the project 

area. But remarkably, the DEIS does not address the meaningful socioeconomic changes in Wrangell and other communities that have 

transitioned away from partial dependence on the federal timber program 

in any way. Significantly, the DEIS does not even include a section on 

socioeconomics. [Cf. DEIS at xiii; Saddle Lakes Timber Sale FEIS at 324 

– 336]. Many non-timber aspects of the regional and local economy, 

notably tourism and commercial fishing, are doing much better than the 

old- growth timber industry. See 634_0250 (Wrangell Visitor Economy 

By The Numbers, by Rain Coast Data). These economic factors and 

trends are directly relevant to the cumulative impacts of the proposed 

action as it relates to local economic impact and the purpose and need.

It is impossible for the Forest Service to conclude that this project would 

contribute to local or regional economies without considering the larger 

socio-economic context – yet the DEIS arbitrarily does just that.

jobs in logging and processing. It also provides a demand for 

fuel, supplies and services from local and regional businesses. 

The timber industry will probably never be as large in scale as it 

was during the 50-year contracts but still plays an important role 

in many of the smaller communities of Southeast Alaska. Timber 

may play a larger role as the supply of commercial young growth

increases (2016 Forest Plan Amendment FEIS, pages 3-512 

through 3-516). 

The comment appears to assume that there are economic 

tradeoffs between timber harvest and commercial fishing and 

recreation. There is no evidence of that as both fishing and 

recreation industries are growing and thriving even as timber 

harvest has been ongoing. Socioeconomic analysis is best 

conducted at a broader scale, which was recently done in the 

2016 Forest Plan Amendment FEIS. Information on commercial 

fishing is found on pages 3-105, 3-112 through 3-113, 3-3-501 

through 3-503 and 3-521 and for recreation and tourism 

industries on 3-364 through 3-372, 3-380 through 3-383, 3-499 

through 3-501 and 3-522.

Socioeconomic considerations are included in the analysis as 

they relate to the project, and are provided in chapter 3 by 

resource.
BAppendix

Wrangell Island Project FEIS ♦ 222

Comment 

Number Comment Response

The scoping notice asserted that the purpose and need for the project is 

to “contribute to the local and regional economies of Southeast Alaska” 

and specifically Wrangell. [80 Fed. Reg. at 65691]. Prior planning on this 

project dates back to 2008 and anticipated that a Wrangell-based 

sawmill would purchase and process the timber. [634_0832 at 9, 15]. In 

2009, the Forest Service had identified the timber industry as a 

“cornerstone” and “economic foundation” of the Wrangell economy along 

with fishing and fish processing. [Exh. D- at 3- 8, 3-9 (Navy FEIS 2009)]. 

This assumption reflected outdated data from 2005, when there were 29 

mill jobs. [Id. at 3-8]. Indeed, the adjacent Navy Timber Project reflected 

an intent “to promote a more stable economy for Wrangell” and cited 

wood products industry jobs as representing 9% of the community’s 

employment – in 1999. [Id., Appx. A at A-4].

Now there are at most, a few micro-sized mills, meaning that the number 

of mill jobs in the community has dropped considerably since the above 

2005 data. [634_0799 (SitNews 2013)]. Since 2009, Wrangell’s efforts to 

diversify its economy have resulted in substantial growth in its fishing, 

seafood processing and maritime industries – indeed, city employees 

report that the “maritime sector is booming” as Wrangell has become a 

regional center for vessel repair. [Id.; 634_0825 (UFA 2014)]. These 

efforts have resulted in a five-fold increase in raw fish taxes over the past 

two decades, a much larger number of fishing vessels, and a maritime 

services sector that supports local businesses and provides new jobs. 

[634_0799 (SitNews 2013)]. As reported in SitNews, “it’s clear from the 

investments that the city, state and private sector have made that the 

future is being built largely around fish with a secondary focus on 

tourism.” [Id.]. Indeed, for the three year period relevant to the recent 

Navy FEIS (2007–2009), salmon harvests delivered to Wrangell 

averaged 5 million pounds per year. Deliveries have doubled over the 

past three years, averaging nearly 10 million pounds per year. According 

to United Fishermen of Alaska (UFA), Wrangellites own 384 fishing 

permits, 210 fishing vessels, and the industry employs 362 Wrangell 

residents directly in commercial fishing, or 14.7% of the local population, 

and 372 seafood processing jobs. [634_0825 (UFA 2014). In sum, it is 

clear that a market-based transition has occurred, meaning that the 

timber industry is no longer a cornerstone of the local economy, and the 

DEIS failed to consider how this project can meet local economy goals in 

light of the Forest Service’s transition to a timber sale program that 

emphasizes raw log exports and Wrangell’s transition away from timber 

dependence and toward fishing and tourism.

Indeed, recent comments on the state of Alaska’s Southern Southeast 

State Forest Management Plan (SESFMP) show that Wrangell residents 
Appendix B

Wrangell Island Project FEIS ♦ 223

Comment 

Number Comment Response

have significant concerns about the impacts of large-scale timber 

projects for non-local use (i.e. for Wrangell’s one active mill, Mike Allen 

Enterprizes). Four Wrangell residents commented in 2015 on the plan. 

[634_0826, _00827, _0828, 0829]. All supported small sales for Mike 

Allen Enterprizes, but opposed large sales for non-Wrangell timber 

operators and for export, and explained that there is no local capacity for 

large timber sales. Additionally, each Wrangell resident expressed 

concern about how large timber sales would harm Wrangell’s ongoing 

economic transition – specifically impacts to local recreation and tourism 

and adverse impacts of LTFs and timber sales on water quality and 

fisheries. [Id.] In other words:

● while Forest Service planning on this project reflects the 

mistaken assumption that the project area is important for local timber 

use,

● the actual market-based changes to the local economy suggest 

that fishing and tourism opportunities have become much more 

significant contributors which would be harmed by the large-scale 

clearcuts created to support Alcan’s foreign and out-of-state markets for 

unprocessed logs!

In contrast to that plain economic reality, the DEIS flagrantly lies about 

the value of the timber industry to the local and regional economy:

Alaska timber mills contribute to local and regional economies by 

providing forest products and employment. 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 sawtimber in the region and on Wrangell Island. 

[DEIS at 2].

In sum, a revised DEIS must include a socio-economic resource section 

that provides a realistic assessment of changed economic conditions on 

the island and region, and acknowledge that the Forest Service is 

making an effort to thwart a natural, free-market based transition that has 

resulted in a more optimal allocation of capital and labor by degrading 

fish, wildlife and recreational habitat through an antiquated and 

socialized timber- first economic policy.

Comment noted. 

061-GSACC205. The project cannot proceed under the Forest Service’s Illegal 

Export Policy

The DEIS makes clear that the Forest Service has designed this project 

primarily to supply timber volume for foreign processors under the 

Region 10 Export Policy. [DEIS at 27]. All alternatives appraise negative; 

however, under the domestic processing alternatives, the indicated bid 

See response to comment 051-SEACCWRC-07. 

The export policy is not ‘illegal’ as the commenter alleges. The 

Regional Forester has the authority as stated in 36 CFR 223.201 

to approve such a policy and has done so after careful 
BAppendix

Wrangell Island Project FEIS ♦ 224

Comment 

Number Comment Response

rate ranges from -$218.66 to -$253.21. [Id.]. Conversely, the bid rates 

under the export policy range from -$54.21 to -$91.80. [Id.]. This means 

that estimated local jobs will be fewer under the export policy by nearly 

20 percent. [Id. (showing job losses of up to 50 jobs per alternative under 

the export policy.)]. It also means that this project depends entirely on 

the Forest Service’s 2016 export policy. The timber economics section 

does not mention the policy at all, except for a footnote to Table 12. 

[DEIS at 66]. Appendix A makes clear, however, that the export policy is 

the main reason for the Forest Service’s timber demand guesstimates 

that lead to the large volume goals for this project. [Id. at 282].

In a March 21, 2016 letter to Regional Forester Pendleton submitted by 

EarthJustice from the undersigned organizations and others, we 

explained that the development of the 2016 export policy was a major 

federal action under NEPA, requiring public notice, an analysis of the 

policy, and opportunities for public comment. [Exh. D-11 (AWL et al. 

2016)]. Similarly, the development of the policy is also subject to the 

Administrative Procedure Act. In the absence of procedures necessary 

to comply with the two statutes, the policy is clearly illegal. The failure of 

the DEIS to address this inconsistency and the effort to move forward 

with an export project absent statutory or regulatory authority to do so is 

arbitrary.

consideration of the analysis done prior to the adoption of the 

policy in 2007.

The comment misconstrues the purpose and need of this project. 

The analysis displays the potential economic and employment 

effects from the alternatives with both the current export policy 

and with domestic processing. Any timber sales that result from 

the project would be offered under competitive bid under the 

export policy in place at the time of the offer. It is not known what 

the export policy might be or what business decisions a 

successful bidder might make for processing. The export policy 

itself is beyond the scope of this project.

The export policy provides support to the domestic processing by 

giving purchasers a more lucrative market for domestically 

underutilized material namely that material that is too difficult to 

process domestically due to size, quality or species. By doing 

this, it allows the purchaser to be able to purchase more timber 

for the domestic market knowing that there is a more secure 

market for the possible underutilized material such as the lower 

quality sawtimber.

The comparison table in chapter 2, p. 27 of the Wrangell Island 

Project DEIS only attempts to show the difference in value if the 

export policy were to be used to its fullest capacity. These values 

are based on a snapshot in time and may fluctuate in the 

future. It does not indicate that most of the timber will go to 

foreign processors. That is up to the purchasers and will depend 

on market fluctuations at the time. 

061-GSACC21B. Comments on Appendix A

The economic analysis for this project relies on a methodology that 

greatly exaggerates demand for federal timber based on errors and 

faulty assumptions that undermine the entire stated purpose and need 

for the Wrangell Island Project. Further NEPA analysis is necessary to 

evaluate the failure of the methodology, whose highly optimistic market 

demand projections have consistently proven to have greatly overestimated the actual later demand. In particular, the selection of the 

“expanded lumber scenario” was unreasonable. [DEIS at 282]. In our 

administrative appeal of the 2008 TLMP amendment, we requested a 

correction of the economic studies and scenarios regarding timber 

See response to 061-GSACC-24

Discussion regarding the Brackley scenarios is no longer 

relevant since that demand study has been replaced with 

Daniels et al. 2016. The 2016 demand study focuses more on a 

transition to young-growth management. 
Appendix B

Wrangell Island Project FEIS ♦ 225

Comment 

Number Comment Response

production and demand for federal timber. The errors and flawed 

assumptions in Appendix A are significant enough that the Forest 

Service needs to re-evaluate the purpose of the project and timber 

volume provided-for in project’s alternatives. The continued use of these 

scenarios violates NEPA by failing to ensure the professional and 

scientific integrity of the government’s methods for assessing timber 

demand. [40 C.F.R. § 1052.24].

061-GSACC221. The market demand scenarios rely on flawed assumptions and 

have been repeatedly inaccurate

The Forest Service’s is attempting to guess at market demand by relying 

on scenarios developed through harvest projections developed in 

Brackley et al. 2006 (634_0489). [DEIS at 282]. Brackley’s scenarios 

reflect unreasonably optimistic timber demand scenarios and rely on an 

outdated demand study proven to be inaccurate relative to actual market 

conditions. It is unreasonable to continue to rely on the four demand 

scenarios, all of which increase over time -- even the “limited lumber” 

scenario reflects a demand rising from 52.8 MMBF in 2010 to 58.9 in 

2015. [Id. at 279]. Actual logging was considerably lower, with an 

average annual take of 33 MMBF from 2010 - 2014. [Id. at 277]. With the 

exception of 2012, the Forest Service has considered the industry to be 

in an “expanded lumber” scenario, which anticipated harvests rising from 

61.9 MMBF in 2007 to 105.6 for 2014. [Id. at 279]. The reliance on these 

scenarios is unreasonable, and should not be used to justify the timber 

volumes proposed for action alternatives.

Despite the low cut and sold volumes and the known constricted market 

conditions, the Tongass National Forest’s demand projections 

nonetheless continue to assume that supply is the critical problem and 

that southeast Alaska timber operators will be competitive and maintain 

historic market shares. However, supply is just one minor issue – the 

real problem is the industry’s inability to compete in lower value 

commodity markets as a result of the region’s high operational costs 

relative to the Pacific Northwest and other global suppliers. Therefore, 

the Wrangell Island Project DEIS tiers to and utilizes a methodology that 

is an ongoing programmatic failure -- a failure to provide a realistic 

assessment of timber markets and the demand for timber from the 

Tongass National Forest.

The most recent projections – being based on the four hypothetical 

demand scenarios developed by Brackley et al. (2006) – imagine a 

competitive Tongass timber industry that can retain past market shares, 

but the Forest Service has never tested such projections against explicit 

demand determinants such real price and cost data. All scenarios 

See response to comments 024-AFA-01 through -18, 058-

SEACC-08, 061-GSACC-24 and 061-GSACC-21. 

The comment addresses the Tongass timber demand which are 

beyond the scope of this project.
BAppendix

Wrangell Island Project FEIS ♦ 226

Comment 

Number Comment Response

anticipate increasing demand over time. The expanded lumber scenario, 

in use since 2012, anticipated demand of 90.5, 98.1 and 105.6 MMBF 

from 2012-2014. [DEIS at 279]. Actual harvests were 20.8, 36.3 and 39 

MMBF, respectively. [Id. at Figure 32]. Notably, actual harvests are 

below the lowest range of expected purchases by roughly 40% even 

under the limited lumber scenario [DEIS at 279, 282 (showing a limited 

lumber scenario harvest of 273 MMBF under the limited lumber scenario, 

and actual harvest of 164.7 MMBF)]. The Brackley scenarios and any 

projections developed from them thus reflect outdated, unsupported 

assumptions, and the choice of the expanded lumber scenario worsens 

this error.

Indeed, as part of the pending TLMP Amendment process, the Forest 

Service has issued a new demand study (Daniels 2015) that explicitly 

explains that a new analysis is necessary because of changed 

conditions that have rendered invalid many of the assumptions that 

informed the 2008 Forest Plan. The DEIS violated NEPA and the APA by 

failing to disclose the agency’s own opposing viewpoint, and by failing to 

take into account significant new information.

In sum, Appendix A fails to provide a reasonable explanation for the 

projections. The DEIS failed to disclose the flaws with the TNF’s market 

demand models including the long- term inaccuracy of the projections, 

the reliance on untested assumptions and the exclusion of relevant 

factors such as global market prices. The NEPA analyses have also 

failed to explain the specific factors considered in setting the projected 

offering levels, the data relied on to justify those different elements of the 

methodology, or information on whether it had followed agency guidance 

for updating information found in the methodology.

061-GSACC232. The DEIS arbitrarily selected the expanded lumber scenario

The DEIS assumes that market demand has attained Brackley’s 

“expanded lumber scenario” which estimates a demand of nearly 105 

MMBF for 2014 and increasing by 9-10 MMBF per year until 2020. [DEIS 

at 282]. The DEIS selected the “expanded lumber” scenario based on 

the export policy and good overseas markets. [Id.]. The DEIS projects 

that the timber industry is in an “expanded lumber scenario” such that 

perceived demand for FY 2016 is 122.2 MMBF, or roughly the same 

amount of timber that the industry took over the past three years. [Id at 

276, 279]. The DEIS thus explicitly relies on Brackley’s projected longterm harvest increases as one of the primary reasons for inflating timber 

demand in arriving at the “expanded lumber” scenario.

The Forest Service identified a “limited lumber” scenario in 2011, and the 

export policy has not changed since 2009, raising questions about 

Comments on the use of Brackley’s scenarios are no longer 

relevant since Daniels et al. demand analysis (2016) is now 

being used. 

The 2016 Forest Plan FEIS, appendix H also provides a 

comprehensive overview of the history for timber export in 

Alaska pages H-1 through H-3 and the current limited export 

policy pages H-3 through H-6.
Appendix B

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Comment 

Number Comment Response

whether the export policy or export markets justify the scenario change. 

The expanded lumber scenario anticipates “some form of demand 

stimulus.” [DEIS at 278]. There is no explanation anywhere in the 

analysis for these claims that there are good overseas markets. Had the 

Forest Service fulfilled its analytical requirement under NEPA, it would 

have found that current market trends reflect a “substantial” decline in 

U.S. lumber prices and particularly for West Coast raw log exports. 

[634_0835 at 4-5; _0833; _0834]. Absent identification of some specific 

demand stimuli that would trigger the “expanded lumber” scenario, we 

think it is unreasonable to proceed on the basis of a scenario that 

envisions a demand that is three times as high as actual harvest.

The Forest Service does have the capacity to track export markets, yet 

the DEIS does not discuss export market information compiled by the 

Pacific Northwest Research Station. The Forest Service needs to 

consider long-term trends based on that data, and revisit its selection of 

the “expanded lumber scenario” in order to consider the substantial 

weakening of export markets and the competitive disadvantage of 

Alaska and Pacific Northwest raw log exporters. China is the primary 

consumer of west coast timber exporters; overall, nearly two- thirds of 

U.S. log exports are sent to China. [634_0833; 46 _0834; and Exhs. D89 (Zhou-2013); D-90 (Zhou-2015); and D-92 (Zhou-2016(b))]. Those 

references by the Forest Service’s Pacific Northwest Research Station 

show that both the value and volume of log exports from Alaska and the 

West Coast are declining, moreover at a much greater rate than other 

timber exporting regions. In 2015 and 2016, the Station reported the 

following trends:

● The U.S. log export market is declining.

o The volume of log exports declined more than 5% from 2013 to 

2014.

● The primary log export market for West Coast logs – China – is 

declining.

o “China decreased its West Coast log and lumber imports in 

2015 as a result of its domestic economic and national restructuring 

adjustment.”

o 64% of West Coast log exports went to China in 2014, and 59% 

in 2015, a 5% decline.

o In the first quarter of 2016, 49% of log exports went to China.

o The Station’s May 26, 2016 press release noted that Asia-wide 

the export volume declined, as well as to China specifically.

● The West Coast’s share of total U.S. log exports is declining.

The Forest Service does track export annually and this 

information posted annually on the Alaska Region public website 

at http://www.fs.usda.gov/detail/r10/landmanagement/resourcem

anagement/?cid=fsbdev2_038785. This information is specific to 

the Tongass unlike the publications complied by the Pacific 

Northwest (PNW) Research Station. PNW information was 

considered during the analysis for the Daniels et al. 2016 

demand report. 

The export of timber can fluctuate over time. This due to many 

factors and not always because less wood is desired by the 

importers. Sometimes there is more domestic demand and more 

wood is processed locally by the purchasers than is allowed to 

be exported. The export policy is designed to provide options to 

the purchasers and not to be a requirement. 
BAppendix

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o Its share declined 4% from 2013 to 2014 (from 59% to 55%).

● The volume of West Coast log exports is declining.

o The volume decline was 13% from 2013 to 2014.

▪ This included a decline in Alaska log exports.

o There was a further 27% decline from 2014 to 2015.

o Comparing the first quarters of 2015 and 2016, there was a 

6.6% decline. Indicating continuing decline in the market.

● The value of West Coast log exports is declining.

o The value declined 7% from 2013 to 2014.

o The value declined 33% from 2014 to 2015.

o Comparing the first quarters of 2015 and 2016, there was a 

3.7% decline in value, indicating continuing decline in the market.

● Similar trends exist for exports of West Coast processed 

lumber, although with differences.

[Exhs. D-90 (Zhou 2015); D-91 (Zhou 2016(a)); D-92 (Zhou s2016(b))]. 

One stand-out here is the continuing but worsening drop in export 

volume from 2014 to 2015 by nearly a third, with further deep decline

continuing into 2016.

These data are consistent with industry projections finding that that 

Alaska and other Pacific Northwest log exporters are losing their market 

share, and are at an even greater competitive disadvantage relative to 

Canadian and southern U.S. timber operators. [634_0835 at 11 (Glass 

2015)]. In sum, there is little demand and markets are poor for locally 

produced sawtimber or raw log exports from southeast Alaska. 

Additionally, regional timber exporters face weakening foreign markets, 

and the their historical competitive disadvantage relative to other timber 

exporters appears to be increasing. The failure of the Forest Service to 

monitor actual market trends in its annual determination of the applicable 

market scenario is a serious flaw.

061-GSACC243. Appendix A uses an arbitrary formula to calculate timber 

pipeline goals

Notably, even if the “expanded lumber scenario” were applicable, 

Appendix A artificially inflates the timber volume goals by using an even 

more flawed methodology, the Morse methodology. [DEIS at 281-282]. 

The “expanded lumber scenario” (Brackley 2006) is just an input into that 

methodology. [Id.]. The Morse methodology relies on several 

unsupported assumptions, including a difficulty in estimating demand for 

Tongass timber, the volatility of forest products markets and rapidly 

Comments on the Tongass timber demand are outside the scope 

of this analysis. While there has been much discussion over the 

years over the Morse methods and varying opinions; the Forest 

Service has used this method to estimate annual demand since 

it allows for fluctuations in market demands. The assumptions 

that are mentioned are supported by those who calculate timber 

demand since as with any product, demand can change with the 

markets, materials can come from other sources. 
Appendix B

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Comment 

Number Comment Response

changing market conditions. None of these assumptions are correct 

given long-term, consistent timber harvest levels, a long-term decline in 

domestic lumber markets, and a long-term competitive disadvantage 

experienced by Tongass timber exporters relative to national and global 

competition. The Morse methodology sets an arbitrary timber offering 

goal of 142 MMBF that is not justified by the DEIS. [Id.].

4. Conclusion

The two methodologies used to determine the perceived need for a 

project of this scale have consistently overinflated market demand to a 

significant degree and violate NEPA by relying on misleading economic 

assumptions, as well as an academic failure to research actual market 

trends and input those trends into the agency’s conclusions. The Forest 

Service needs to produce a revised DEIS that incorporates and analyzes

actual market trend data, rather than relying on a flawed methodology 

designed to support a massive federal timber sale program for 

uncompetitive operators in competitive global marketplace.

Since the Morse method was initially developed, inputs to the 

model have been adjusted to reflect new understandings and 

information, such as share of raw material provided by the 

Tongass National Forest to local processors, amount of time 

between purchase and harvest of a timber sale, and mill 

capacity. The Morse method allows for adaptations to current 

situations.

As indicated in the model, planning the annual timber program 

requires more than just pure economic factors. To account for 

delays in timber sale preparation, administrative appeals, and/or 

litigation, sufficient contingency volume must be included in the 

annual timber sale program to account for realistic fall-downs. 

Budget and organizational constraints limit the extent to which 

the Forest Service can respond to economic cycles and the 

associated fluctuations in timber demand. All of these factors 

must be considered in evaluating the annual market demand for 

timber and setting annual timber offerings. 

The Wrangell Island Project EIS is a project-level analysis, and 

the project is just one component of the total Tongass timber 

program. The timber supply and demand issues tier to the Forest 

Plan, which the Wrangell Island Project EIS follows. The 

interaction between planning cycle demand and annual demand 

calculations is described in appendix G to the 2016 Forest Plan 

EIS. The demand analyses underlying this project-level EIS are 

based on the best science available at that time, and have been 

extensively peer reviewed. Since it is a Forest Plan level 

analysis, it was not necessary to conduct a revised analysis at 

the project-level.

061-GSACC25C. Further NEPA analysis is must include a financial efficiency 

analysis

A major shortcoming of the DEIS was that it failed to provide a financial 

efficiency analysis that compares taxpayer expenditures on the agency’s 

timber sale program with estimated revenues. [FSH 2409.18]. Thus the 

Forest Service failed to disclose the costs of sale administration, sale 

preparation, design and engineering of roads, agency overhead costs, 

and the costs association with efforts to ameliorate habitat degradation 

caused by logging and associated road construction. The DEIS thus 

violated NEPA by presenting a misleading characterization of the 

project’s economic costs and benefits. It is well known that agency 

A financial efficiency analysis was conducted following the 

Alaska Regional supplement and the approved financial 

efficiency analysis program (FAST-R) was used. FAST-R 

includes the costs of sale administration, sale preparation, 

design and engineering of roads and uses the same average 

cost for each alternative. The analysis of these values are 

discussed in Vermillion 2012, are in the project record and are 

embedded in the FAST-R program.
BAppendix

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expenditures exceed revenues substantially. The GAO estimates an 

annual cost-revenue ratio of 12.5:1. [Exh. D-33 (GAO 2016)]. Other 

estimates, which use the Forest Service’s own data, project even higher 

losses that exceed $20 million annually – or more. [Exh. D-41 

(Headwaters 2014); 634_0154 (Mehrkens 2013); Exhs. D-52 & -53 

(Merkens 2012 paper & accompanying spreadsheet)]. We thus add that 

the DEIS should provide a realistic estimate of the public expenditures 

needed to support Alcan and Viking’s timber brokerages.

The agency overhead costs if they are relevant to each of these 

costs were included in the calculations. The general SO program 

management or the costs associated with the entire Tongass 

program such as facilities maintenance which is used by all 

programs including recreation, archaeology, wildlife and 

hydrology. Other program costs not associated with the Wrangell 

Island Project (such as restoration) are not included.

FAST-R analysis displays project costs and projected revenues 

for each alternative. These are shown in the alternatives 

comparison table in chapter 2 of the EIS, and in the discussion of 

Issue 1 in chapter 3 of the EIS.

The cost-benefit analysis of the project was to provide a 

comparison of the alternatives.

The Forest Service analysis (Vermillion 2012) of public 

investment costs excluded costs associated with other activities 

that cannot be directly attributed to timber sale planning. These 

would include many other activities, such as wildlife habitat 

improvement through forest management activities, such as 

forest planning, silviculture and monitoring, which cannot be 

attributed to a specific timber sale project. Vermillion (2012) 

costs do not include other costs such as brush disposal and 

reforestation, which do not apply to Southeast Alaska. 

Silvicultural exams, timber and transportation planning as well as 

wildlife and stream survey costs are covered in part by the NEPA 

costs and in part by sale implementation costs and have been 

included if done solely for the project and were not previously 

funded by other projects. Stand improvement funds come from 

separate accounting codes, some derived from the sale of timber 

but have no bearing on the preparation of timber harvest 

contracts. Another cost that is not accounted for in Vermillion 

(2012) is the cost of litigation. 

061-GSACC26D. The DEIS failed to disclose the effect of partial-cut units on 

project economics

( See also other discussions of partial cutting in Section I.C of our 

introduction and Section III._ concerning wildlife. )

The DEIS section on the Significant Issue 1, “Timber Economics and 

Availability,” is only 41⁄2 pages long and does not discuss the economic 

The analysis addressed partial harvest as part of the economic 

modelling. This modelling included the following components and 

assumptions. The partial-harvest prescriptions are designed to 

harvest a portion of the trees that meet a certain timber value 

criteria and retain trees that either have not grown into the size 

class considered economical at this time, or are trees that are 

more valuable aesthetically and as wildlife habitat. Partial 
Appendix B

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Comment 

Number Comment Response

effect of partial cutting in any depth, even though the large proportion of 

partial cutting is sure to have a profound effect on project economics, 

including the appraised value per million board feet.

The total timber yield of each alternative will be composed of volume 

from both even-aged (clearcut) and uneven-aged (partial-cut) logging 

systems. However, the DEIS fails to disclose the amount of timber 

volume provided by each system and the monetary contribution of each 

system to the economics of the alternatives. The missing information is 

important because the project includes a large area in partial cut units --

between 1,483 and 3,528 acres comprising 47% to 75% of the total unit 

acreage, among the alternatives. The economic aspects of this should 

have been reported in Table 9 (the comparison of alternatives in Chapter 

2) and should have been discussed in Chapter 3.

How the undisclosed partial cut timber volumes were determined is a key 

issue because the DEIS shows that the project has poor economics. The 

fundamental feature of the partial cut prescription is an allowed 

percentage reduction (33%) of the total basal area of trees in a unit. 

However, basal area does not equate directly to timber volume, because 

tree height is a co-determinant for volume. Therefore, the timber volume 

yield from a unit will not be known until it has been determined how the 

33% criterion will be applied across the unit and volumes of the 

individual trees are estimated. The DEIS is vague mention about 

whether at present there are firm prescriptions for each partial cut unit or 

when, if in the future, those will be prepared. The unit cards contain no 

information about unit species composition, whether removals will be 

distributed across the unit (and if so, how) or in groups, and whether 

particular trees or groups have already been targeted and on what basis. 

Accordingly, Larry Edwards of Greenpeace quizzed the district ranger 

and project staff on July 11, 15 and 18 [Exh. D-28 (Edwards notes, pers. 

comms. with IDT)], as discussed in our Section I.C. We learned, as also 

discussed there, that timber yield from partial cut units were estimated 

from stand exams, which is inconsistent with the basal area criterion for 

partial cuts, and that decisions on distributed or clustered removals or 

actual tree selections are yet to be made. Consequently, the timber 

volume yield and the species composition of the yield from any unit is not 

yet known.

These are important considerations because the DEIS says the objective 

of the project’s partial cutting is to “achiev[e] an economic harvest of 

timber” [DEIS at 220], which likely means an objective of trying to 

maximize (to extent possible) the volume or species-related timber value 

obtained through the partial cutting. As discussed in detail in our other 

partial cutting section in our wildlife section (at III.A), the project has 

harvest units are yarded by helicopter. The cost of helicopter 

yarding is higher than conventional yarding and logs yarded by 

helicopter have to meet a certain value criteria to be considered 

economical. However, there would be an economic criteria range 

as some logs are more valuable than others, based on size, 

quality and species. The Wrangell Island Project analysis does 

not work down to the scale of individual trees or logs.

The estimated timber volumes used in the DEIS to compare 

alternatives are based on stand exams collected at an intensity 

of one plot per 10 acres. An average defect by species was 

applied to the gross volume to determine the net volume per 

acre estimate for each harvest unit. Each unit net volume 

estimate was compiled to get the total net volume estimate for 

each alternative. For the partial-harvest units the volume is 33 

percent of the estimated net volume per acre multiplied by the 

total unit acres. The logging system costs, by alternative and 

type, were used in the FAST-R economic modelling.

See responses to comments 061-GSACC-12 and -27.
BAppendix

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conflicting objectives for applying the partial cut prescription. The missing 

information is therefore fundamental to understanding the economics 

and feasibility of the project. By lacking this information and using 

unreliable or incorrect information in its place, the DEIS violates NEPA 

and is arbitrary.

061-GSACC27E. The DEIS failed to accurately disclose the effect of tree species 

composition on project economics

In partial cut units, the basal area removal by species will not be 

determined until implementation. [DEIS at 221; Exh. D-28 (Edwards 

notes, pers. comms. with IDT)]. The DEIS fails to disclose what role will 

be played by the ability to choose among tree species during 

implementation, and how this will affect project economics or the tradeoffs between economics and other resources (e.g., wildlife and scenery). 

One hint is in IDT meeting notes, saying that partial cutting will “leave[] 

67% basal area; not more than 50% cedar and spruce.” In other words, 

the intention is to cut from 50 to 100% of the cedar and spruce in these 

units, provided that the required 67% retention of the unit’s basal area is 

also met. This poses the likelihood or at least the potential for egregious 

high-grading by species, whereas timber sales otherwise are commonly 

understood to net a high percentage of hemlock on the Tongass. 

Because partial cutting depends on selecting particular trees or groups 

of trees, hemlock can be largely avoided. This has the potential for 

profound effect on the economics of the project, on the proportion of the 

timber volume that can be expected to be exported (since cedar export is 

unlimited), on the amount of employment the project will provide locally 

or in the region, and on ecosystem function including wildlife. The DEIS 

has not disclosed sufficient information to disclose the related impacts 

and for the public to understand these aspects of the project. The DEIS 

therefore violates NEPA.

See response to comment 061-GSACC-12 and 061-GSACC-29.

In partial cut units, the actual basal area removal by species 

would be determined during implementation, following the 

general marking guidelines developed with the individual unit 

prescription (located in the project record) and a more intensive 

inventory of existing basal area by species.

The IDT notes mentioned a deliberative discussion on species 

retention, which was not carried forward. The proposed partial 

harvest would retain the species that currently exist in the partialharvest unit.

III. Comments on “Significant Issue 2: Wildlife habitat impacts”

Previous scoping comments filed by the undersigned organizations 

requested that the Forest Service do and document surveys for wildlife 

species present in the project area and discuss their locations and 

preferred habitat uses in the DEIS. This analysis should entail more than 

a quantitative approach to measuring productive old growth losses at 

various scales. Instead, there needs to be consideration of specific 

habitat features that are essential to wildlife viability and abundance, 

particularly in light of the high degree of fragmentation in the project 

area. However, the DEIS only catalogued large scale changes without 

any reference to specific habitat needs or risks to wildlife viability arising 
Appendix B

Wrangell Island Project FEIS ♦ 233

Comment 

Number Comment Response

from further habitat loss and the substantial proposed increase in project 

area road density. [DEIS at 28-29]. Overall, the analysis in the DEIS 

failed to take a hard look at adverse impacts to wildlife as required by 

NEPA, and failed to demonstrate how the Forest Service can implement 

this project while meeting its NFMA obligation to preserve wildlife 

viability.

In this section we begin with a discussion of impacts to Sitka black-tailed 

deer, Alexander Archipelago wolves and Queen Charlotte goshawks with 

an emphasis on information and issues that are of heightened 

importance relative to the timing of prior scoping periods. We believe 

impacts to the three aforementioned species merit treatment as 

significant issues given the importance of deer for hunting in the 

community and the precarious population status of wolves and Queen 

Charlotte Goshawks. We then discuss impacts to other wildlife 

management indicators species (MIS).

There has been substantially more logging on Wrangell Island than 

commonly acknowledged in the DEIS, which generally shows about 

6,800 acres logged. In the project’s wildlife resource report, however, 

Table 12 (on page 18) shows that 10,836 acres have been logged on the 

island.

061-GSACC28A. Problems with the use of partial cut logging prescriptions in 

wildlife analysis ( See also other discussions of partial cutting in Section 

I.C of our introduction and Section II.D concerning economics. )

The Forest Service relies on a large amount of partial cutting for the WIP 

project [DEIS at 66], in an attempt to show mitigation of wildlife related 

impacts, including to deer and wolves and to hunters [e.g., DEIS at 104]. 

As already discussed in Section I.C of our introduction, partial cutting 

units comprise 47% to 75% of the acreage of all cutting units in the 

project, depending on the alternative. As we also discussed there in 

detail, the estimates in the DEIS for the timber volume yields of the 

alternatives and their yields by tree species are misleading, because in 

the partial cut units trees or clusters of trees have not yet been selected 

and it is yet be determined how the selections will be made in any of the 

units. This is a tremendous problem regarding not only determining the 

overall statistics for the project, but also for determining the impacts of 

the project’s alternatives on wildlife. The changes to forest structure and 

the related habitat function must be known before impacts can be 

reasonably predicted.

Partial harvest methods would cause fewer impacts to wildlife 

habitat than clearcutting. Effects to wildlife from partial cut 

prescriptions were analyzed based on the objectives and harvest 

guidelines defined for the uneven-aged prescriptions in the EIS 

in conjunction with other wildlife-specific assumptions described 

in the “Wildlife Habitat” section of chapter 3 of the FEIS and the 

Wildlife Resource Report. 

See responses to comments 061-GSACC-12, -26, and -27.

061-GSACC291. Basal area change is not, by itself, an indicator of impact to 

wildlife habitat

Please see response to comments 061-GSACC-12 and -28.

We agree that basal area change is not a good indicator of 

impact to wildlife habitat. That is why the wildlife effects analysis 
BAppendix

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Comment 

Number Comment Response

The metric of percent loss of the total tree basal area in a unit that is the 

criterion for the partial cut prescription (in this project, 33% removal) 

considers only that single element of tree size, and does not consider 

stand structure at all. Yet, it is stand structure and the juxtaposition of 

areas of differing stand structure that are important for wildlife. For 

example, the basal area metric does not take tree height into account, 

and therefore it cannot not predict the timber volume that would be 

removed (or retained) in a unit, or how the unit’s habitat structure would 

be affected. As a further example, selecting larger diameter or taller 

trees for the removal component would have a greater effect on wildlife 

species of concern (and scenery) than selecting average trees or making 

a random selection. The upshot is that impacts to wildlife habitat (and 

scenery) are likely to be underestimated by the analysis method used in 

the DEIS, which really assumes that the proportion of timber basal area 

removed directly represents the impact to other resources. The DEIS 

and planning record do not document any such correlation, nor do we 

believe that one exists. The situation is worsened by the fact that the 

project puts off the selection of the trees that will be cut to the 

implementation phase of the project. [DEIS at 221; Exh. D-28 (Edwards 

notes of IDT contacts]. For these reasons, the DEIS has failed to 

disclose the impacts of the partial cut component of the project to wildlife 

and wildlife habitat, and has provided misleading analysis based on a 

metric (basal area) that is arbitrary for wildlife impacts analysis. 

Consequently, the DEIS violates NEPA and NFMA. The remedy would 

have been to prepare the DEIS after the partial cut unit layouts are 

completed, which would have allowed the impacts on wildlife and other 

resources to be reasonably estimated. Now, a Revised DEIS is needed 

for that purpose.

A further problem is that the WIP IDT has not had a uniform 

understanding of what the partial cut prescription means on-the-ground. 

We repeat our statement from Section I.C:

The DEIS provides four differing, incompatible descriptions of the nature 

of partial cut retention and how it is measured. According to one view, 

“one-third of the stand would be removed,” or secondly and somewhat 

equivalently that “66 percent of the old-growth stand structure” would be 

retained. [DEIS at 21 (Ch. 2 Wildlife section); and 234 (Ch. 3 Soil 

section)]. Another view is that the retention would “maintain 67 percent of 

the stand volume.” [DEIS at 95 (Ch. 3 Wildlife section)]. The authoritative 

word is in the Ch. 3 Silviculture section, which says in the partial cut 

prescription “approximately 67 percent of the stand’s pre-treatment basal 

area would be retained ... this treatment would remove approximately, 

but no more than 33 percent of the basal area.” [DEIS at 220-221 and 

is based on the percentage of habitat area affected and 

remaining.
Appendix B

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222]. The DEIS analyses for various wildlife species assume that the 

impact of partial cutting on their habitats is exactly equal to the 

prescription’s percentage of removal (e.g., the deer modeling assumes 

that 33% removal equates to clearcutting one-third of the unit). 

[634_1102 at 99 (WIP wildlife report)].

The DEIS in essence relies upon the unfounded assumption that with 

partial harvest, impacts will be mitigated in exact proportion to the basal 

are percentage of the trees left standing. [634_1102 at 99 (WIP wildlife 

report);58 WIP DEIS at 20-21]. What this assumption amounts to is that 

the partial harvest prescription has no impact on the winter habitat value 

of the stand beyond the precise footprint of the trees that are removed, 

and making matters worse the resource specialists misunderstood that a 

different impact mechanism (i.e., the amount of unit timber volume 

retained, or amount of stand structure retained) instead of actually the 

amount of unit basal area retained is involved in the partial cutting 

scheme. Further, this really isn’t mitigation60 because: (1) the additional 

timber volume that an alternative needs is obtained in some other unit(s), 

in effectively a substitution for more volume that could have been logged 

from the first unit; and (2) there is no assurance that remaining habitat in 

partial cut units will have any habitat value of significance [DEIS at 20-21 

(Mitigation)].

Of importance in assessing impacts to wildlife is the Size Density Model 

(SDM) vegetative dataset. Timber volume classes are part of the core of 

the SDM dataset. [2008 TLMP FEIS at 3-139 to 140]. The timber volume 

classes are based, through aerial photo-interpretation, on tree height, 

crown size and stand texture. [603_0136 (Caouette et al. 2000)]. The 

metric in the DEIS of percentage removal of a unit’s basal area bears no 

relationship to these factors, which SDM relies upon. Even if this were 

not the case there would still be a tremendous analytical fault because 

how the basal area metric will actually be applied on-the-ground in the 

WIP project is presently indeterminate. It is indeterminate because the 

trees that will be removed have not yet been identified, and also there 

are no clear criteria for their selection because the Forest Service has 

proffered several conflicting objectives for the selection process. Those 

objectives are stated in the Silviculture section of the DEIS [at 220-221]:

● “maintain or create a stand with trees of three or more distinct 

age classes, either intimately mixed or in small groups”;

● “maintain visual quality and provide wildlife habitat”;

● “maintain[ ] [ ] multi-storied stand structure”;

● “achiev[e] economic harvest of timber”;
BAppendix

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● “economically harvest a portion of the stand while retaining 

trees that would be economical to harvest in the next entry, while 

mitigating other resource concerns.”

Fours things stands out here. First, economic timber production is 

predominant among the objectives (mentioned twice), and this can be 

expected to strongly influence the unit layout, which will be done later. 

Second, to boost the economic prospect for selling timber, a coobjective is to merely “mitigat[e]” impacts on the other resources. Third, 

for wildlife the intent for the future layout and cutting of these partial cut 

units is to only “provide” wildlife habitat – a very minimal standard – while 

in contrast values for other resources are intended to be “maintain[ed].” 

Fourth, regarding forest composition the focus is on silvicultural structure 

within the unit, not maintaining the existing habitat structure of the unit. 

The results are that the partial cut units are likely to be high-graded, to 

the detriment of wildlife habitat, and that the habitat function of the 

retained portion of the unit may be impaired to a greater extent than 

simply the proportion of the unit’s tree basal area that will be removed.

In sharp contrast to the above, the wildlife analyses for wildlife species 

implicitly assume that: (1) each of these partial cut units is uniform 

throughout; (2) the forest to be removed from the unit has that same 

uniformity; and (3) how the one-third removal is accomplished through 

the actual selection of trees or groups of trees (or which species of trees) 

does not matter. That is, the analysis assumes that the removal will be 

exactly representative of the existing stand structure from a habitat 

function perspective, and that it will not impair other parts of the unit. The 

reality of what would happen under this project is actually quite different, 

and the wildlife analyses are therefore arbitrary and misleading, and they 

fail to disclose the impacts the project is likely to cause to wildlife and 

wildlife habitat.

Economic timber harvest and timber supply is a key issue in the 

analysis. The harvest is occurring in areas designated for 

harvest in the Forest Plan, recognizing that there would be 

impacts to other forest resources in these specific areas. These 

impacts would be minimized where possible. 

Other areas of the forest have non-development designations 

where the focus is on these other forest resources. 

Highgrading is defined as removal of the most commercially 

valuable trees (high grade trees), leaving a residual stand 

composed of trees of poor condition or species composition 

(Helms1998). The harvest prescriptions proposed in the 

Wrangell Island Project cannot be categorized as highgrading. 

The objectives and harvest guidelines described for the unevenaged prescriptions have been clarified in the FEIS. These define 

how trees would be selected for harvest to ensure that 

highgrading does not occur and that a healthy, productive stand 

with species diversity remains.

061-GSACC30B. The DEIS claims mitigation of impacts to wildlife, but offers no 

assurance it will occur

The narrative of the DEIS relies on vague statements about past and 

future thinning and partial cutting prescriptions to try to show mitigation 

of the project’s impacts to deer and other wildlife. For example:

Project Design Features and Mitigation Measures for Action Alternatives. 

To reduce or avoid the overall impacts of this project, design features 

have been incorporated into the design of the harvest units for all action 

alternatives based on the application of the Forest Plan Standards and 

Guidelines and management prescriptions. The intent of these standards 

and guidelines are to help avoid, minimize, or mitigate possible adverse 

Please see response to comments 061-GSACC-12, -28, -29. 

Forest Service timber sale administration ensures that partial 

harvest requirements in the timber sale contract are enforced. 

The design features are expected to be effective in reducing the 

impacts of timber harvest on other resources, as stated in the 

EIS. These are standard practices used in timber management 

across the forest.
Appendix B

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Comment 

Number Comment Response

impacts due to project activities. Where applicable, these site-specific 

project design features are identified the unit and road cards. ...

Silviculture: Where specified, uneven-aged management (partial harvest) 

would harvest a maximum of one-third of the stand leaving a minimum of 

two-thirds to provide for visual, wildlife, and other resource values. ... 

Wildlife: In units designated for uneven-aged management (partial 

harvest), a maximum of one-third of the stand would be removed leaving 

a minimum of two-thirds to provide for wildlife values. The remaining 

stand would provide cavity-nesting habitat and other habitat values. 

[DEIS at 20-21, underline added to section headings].

Activities that have improved habitat for the primary prey (deer) include 

pre- commercial thinning which has improved the forage on 

approximately 4,000 acres since the 1970s with an additional 1,250 

acres planned over the next 10 years. [DEIS at 93].

Uneven-aged harvest prescriptions would lessen reductions in habitat 

capabilities as both some cover and forage would be maintained in 

harvested stands. [DEIS at 104].

In those places in the DEIS or elsewhere in its content, the DEIS 

provides no information to quantify these supposed mitigations or to 

demonstrate that they are anything more than wishful thinking that would 

have more than negligible benefits.

Thinning of the second growth in clearcuts is well known to have only 

transitory benefits, since it only delays stem exclusion and the resulting 

total loss of carrying capacity for deer.

While partial cutting is a “design feature” of many of the project’s units, it 

has not yet – at the time of this DEIS – been “incorporated into the 

design of harvest units.”64 The design of partial cut units has not

progressed beyond the mere drawing of the units’ boundaries. Thus, 

there is no assurance at all that meaningful mitigation will be achieved, 

especially since (as discussed previously) the several objectives for 

applying the partial cut prescription conflict with one another and are 

ineffective at protecting the forest structure65 deer depend upon in 

winter. The actual design of the partial cut units – meaning the selection 

of the individual trees or clumps of trees for cutting – is of critical 

importance for knowing the impact on deer habitat and carrying capacity. 

Factors affected by the actual selections (and conversely the quality of 

the retention) include tree heights, tree species, canopy structure, and 

the juxtaposition of the selections and retentions to habitat patches 

inside or outside the unit.

Concerning tree species that will be logged in partial cut units, the DEIS 

does not disclose by species the basal area or timber volume by species 

The partial harvest is a design feature in all action alternatives 

with specific objectives and harvest guidelines which have been 

clarified in the FEIS. It should be noted that the analysis used a 

very conservative approach in modelling the effects to deer from 

partial harvest by assuming the remaining stand would have no 

value to deer (using the same values as though the stand were 

clearcut). 

The effects to deer are presented in the “Wildlife Habitat” section 

of chapter 3 of the EIS and in the Wildlife Resource Report. The 

analysis found no concerns for maintaining viable deer 

populations in the analysis area.

See response to comment 061-GSACC-10.
BAppendix

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that will be removed in individual units or overall by the project, DEIS 

Table 12 being absolutely deceptive. This, and particularly the volume, 

cannot be known until later: “[a]ctual stand-specific basal area removal 

amounts by species will be set in the stand prescription.” [DEIS at 221]. 

However, IDT meeting notes reveal that although the total basal area 

removal for a unit may not exceed 33%, the removal of cedar and spruce 

will be not less that 50%, and could be a great as 100%. [634_0258 at 

3]. Thus, high-grading of the three least common tree species (spruce 

and both cedars) of the four predominant species is accommodated and 

very likely intended. The DEIS has failed to disclose this or to discuss 

the implications for deer or other wildlife species. It is a matter both of 

the actual impacts and whether partial cutting will provide effective 

mitigation.

C. Concerning analyses in the DEIS of impacts to deer

Our scoping comments identified significant concerns about the lack of 

high value winter deer range on Wrangell Island and consequently the 

impacts of this project on remaining deer habitat. In the DEIS the Forest 

Service failed to consider measures in the action alternatives that would 

meet its obligations under NFMA to provide for viable deer populations, 

and failed to take a hard look under NEPA at options that would reduce 

adverse impacts to deer and another resource (wolves) and use 

(subsistence) that depend on deer. Also, the range of alternatives is 

inadequate for evaluation of the issues that concern deer. These are 

critical matters because of the island’s low deer population. The island’s 

originally low and then further impaired carrying capacity for deer are 

well recognized. [1998 Wrangell Island Assessment; Shady EA/FONSI; 

WIP DEIS Table 21].

061-GSACC311. The DEIS failed to adequately protect low elevation deer winter 

habitat

The agency refused to consider in detail an alternative adjusting OGR 

boundaries in a way that would provide additional protections for deer 

based on the ongoing Forest Plan Amendment process. [DEIS at 23]. 

This rationale was arbitrary; the TLMP authorizes the Forest Service 

adjust OGRs as part of project level planning, [TLMP at 3-62]. Indeed, 

the Forest Service has proposed to modify OGRs at the project level 

during the Amendment process in order to provide timber volume. [See, 

e.g. September 2015 Saddle Lakes Timber Sale FEIS at 2-31 – 2-32]. 

The Forest Service also eliminated an alternative that would preclude 

removals of old-growth forest in low elevation areas, basing that decision 

on the assumption that Alternative 5 would reduce effects to wildlife 

habitat. [DEIS at 24].

See response to comment 036-ADFG-02 and 061-GSACC-11. 

The effects to low-elevation winter deer habitat are presented in 

the “Wildlife Habitat” section of chapter 3 of the EIS and in the 

Wildlife Resource Report. 
Appendix B

Wrangell Island Project FEIS ♦ 239

Comment 

Number Comment Response

The DEIS indicates that there has already been a loss of more than onethird of deer winter habitat below 800 feet in elevation. [DEIS at 28]. 

Previous Forest Service analyses indicated that deer numbers are lower 

on Wrangell Island than on surrounding islands based on browse 

indications, pellet density data and hunter harvest information. 

[634_0842 at 3- 17 (Shady EA/FONSI)]. These low population numbers 

may reflect the significant loss of winter deer habitat in many Wrangell 

Island landscape units. [634_0767 at 16, 21, 22, 27, 37 (1998 Wrangell 

Island Analysis)]. It appears that state timber projects have had or will 

have an additional significant impact on whatever high value winter deer 

range remains on the island. [Id.]. Indeed, in 2004 the Shady project EA 

noted that “any additional loss of important deer habitat could reduce the 

ability of an already depressed population to recover.” [634_0842 at 3-

19]. Given the cumulative loss and the existing scarcity of high value 

winter deer range on the island, we believe that the DEIS failed to 

adequately consider preserving remaining moderate and lower value 

deer habitat, and include impacts to those habitats as a metric for project 

impacts.

Many of the WIP cutting units abut previous harvests where canopy 

closures are now or will soon be occurring. [DEIS at 37]. The proposed 

action would also further fragment or directly remove much of the little 

remaining winter deer habitat. [DEIS at 37 (Alt-2 map), and at 81 (deep 

snow deer habitat map)]. Much of the project area and surrounding lands 

are already heavily fragmented and contain large portions of what is 

currently, or soon to be, unsuitable deer habitat due to canopy closure in 

the extensive created openings and second- growth stands.

The alternatives also remove or impair numerous elevational corridors to 

low elevation winter habitat. Not only does this reduce winter 

accessibility to such habitat for deer, it increases the efficiency of 

predation on deer because deer are left fewer, often narrower corridors 

and that elevates risks.

Note that the EIS indicates a 33 percent reduction of the deep 

snow winter habitat in all land ownerships since 1954.

Comment noted.

061-GSACC322. The DEIS analysis of cumulative impacts to deer is arbitrary

In discussing cumulative impacts to deer, on page 106 the DEIS claims 

that although the project would impact deer, “deer would continue to 

persist at current levels.” The claim is based on statements that:

● of the historical deer winter habitat, 67% of the deep-snow and 

82% of the average- snow habitat would still remain;

● 96% of the non-winter habitat would still remain; and

The cumulative effects analysis presented in the FEIS is 

appropriate for effects on deer. The commenter’s disagreement 

with the assumptions and conclusions are noted.

The analysis was conducted according to the direction provided 

by the interagency wildlife biologists and our conclusions are 

based on that analysis. 
BAppendix

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Comment 

Number Comment Response

● 77% of the island’s carrying capacity for deer would be 

maintained.

[DEIS text at 105-106,71 and Table 38]. The implication the DEIS makes 

is that there are large remnants of important habitat, so the population 

would not diminish. That implication and the conclusion that the current 

population level would be maintained are unsupported by any facts or 

analysis, and rely simply and arbitrarily on retention percentages that 

superficially appear to be large and satisfying.

An important perspective that is lacking in the analysis is a look at the 

project’s impacts on deer habitat in comparison to those that have 

already occurred since the 1950s. We provide such a comparison here, 

using calculations on data in the DEIS:

Table 1.

(all lands)

Additional loss, as a percentage of loss-to-date

(or loss already committed-to at stem exclusion)

Alt. 1 Alt. 2 Alt. 3 Alt. 4 Alt. 5

Carrying 

Capacity

Stem exclusion

0 30% 17% 22% 22%

Deep-snow 

habitat 0 5% 4% 5% 2%

Average snow 

habitat 0 40% 25% 28% 28%

Past logging on Wrangell Island is recognized as having had a high 

impact on habitat [634_0767; _0842], and this table shows that the 

action alternatives would cause a substantial cumulative addition to 

those impacts. It also shows that although the additional percentage 

reductions of deep-snow habitat are small numbers, the additional loss 

of carrying capacity is nonetheless substantial, at 17 to 30%. The table 

suggests that this is because of the quite large (25-40%) additional 

reduction of average-snow winter habitat. The DEIS failed to disclose the 

substantial magnitude of the further reduction of deer winter habitat.

See response to comment 056-DOW-04.

The comparison provided in the comment is not correct. 

Information has been clarified in Table 35 and Table 36 of the 

FEIS. 

The cumulative impacts section on deer includes Table 37, which shows 

impacts to carrying capacity, with capacity expressed in units of 

maximum number of deer. However, the table and its accompanying 

discussion fail to address the issue of what impact the alternatives may 

have on deer in the system in which they exist on Wrangell Island. The 

Comment noted.
Appendix B

Wrangell Island Project FEIS ♦ 241

Comment 

Number Comment Response

system includes predation by wolves and bears, and the Forest Service 

acknowledges the deer population to be chronically low. The DEIS does 

not attempt to explain how the numbers in Table 37 have any use in 

judging the impact of the project on this deer system, including the size 

of the deer population. In fact, we believe the numbers in Table 37 have 

little if any value for that purpose, and that they are misleading 

information.

Table 37 should instead have shown deer model results in units of deer 

per square mile (deer/mi2) -- i.e. those in Table 21 -- which are directly 

comparable to the 18 deer/mi2 threshold in Forest Plan standard and 

guideline XIV.A.2. The project’s impact on the Wrangell Island deer 

population should have been analyzed and discussed in consideration of 

the results of making that comparison, and in consideration of the fact 

that deer in some other parts of the game management unit that includes 

Wrangell Island (GMU3) have been in a “predator pit” at very low 

numbers for several decades. Standard and guideline XIV.A.2 was 

developed on the basis of scientific knowledge of the foundations and 

dynamics of the wolf/deer (predator/prey) community in the region. 

[634_0579 (Wolf scientists’ letter to Pendleton, 1997); _0615 (Person 

2001; _0575 (Person et al. 1996, wolf conservation assessment)]. We 

find the following facts:

1) the Wrangell Island deer population is known to be chronically 

low [634_0842; _0767];

2) the modeled carrying capacity of Wrangell Island for deer is 

now far below the Forest Plan’s threshold of 18 deer/mi2 [DEIS Table 

21], even without considering predation;77

3) the project would cause a substantial loss of deer winter habitat 

and carrying capacity on the island in comparison to losses from the past 

six decades of logging [see our table above];

4) creation of a predator pit for Wrangell Island deer or even 

functional extirpation of deer from the island are possible78 [Exh. D-34 

(Gillingham 1997, peer review of the deer model];79 and

5) the DEIS has not taken these factors into account in its 

cumulative impacts analysis for deer.

For those reasons, the DEIS has failed to take the “hard look” at impacts 

to deer that is required by NEPA, and its conclusions are arbitrary.

Please see response to comments 056-DOW-05 and 058-

SEACC-28.

061-GSACC333. Already substandard carrying capacity for deer in WAA 1903 is 

worsened by the project

Carrying capacity for deer was analyzed and presented in the 

EIS. These estimates are not actual deer densities, only 

theoretical estimates of habitat capability and are most useful in 
BAppendix

Wrangell Island Project FEIS ♦ 242

Comment 

Number Comment Response

A sufficient habitat carrying capacity for deer is necessary to support 

subsistence use of deer while sustaining populations of Alexander 

Archipelago wolves, and accordingly TLMP requires providing a carrying 

capacity of 18 deer/mi2 where possible. [TLMP at 4-95 (standard and 

guideline XIV.A.2)]. Wrangell Island (wildlife analysis area (WAA) 1903 ) 

is already below this carrying capacity; however, that fact does not 

relieve the Forest Service of its obligations to: under NFMA to protect 

viability of the wolf; under ANILCA maintain subsistence use of deer; and 

under the intent of the standard and guideline to manage its actions to 

those ends. In addition, as discussed above, the viability of the deer 

population on Wrangell Island may be at risk of a predator pit or 

extirpation because of the combination of low carrying capacity, 

predator/prey dynamics, chronic low population and other factors. Nondegradation of the already substandard carrying capacity and the 

island’s deer winter habitat would avoid increasing those risks.

comparing the alternatives. Other factors were considered during 

the analysis for the Forest Plan when determining whether viable 

populations of wolves would be maintained. Even with these 

lower estimates of habitat capability, The Forest Service 

determined that there was sufficient habitat to maintain viable 

and well distributed wolf populations on the Tongass for 100 

years of application of the Forest Plan (2016 Forest Plan 

Amendment FEIS p. 3-284). 

Comment noted.

061-GSACC344. The deer model results are not reliable, and the model was not 

run as stated in the DEIS

The DEIS provides only vague information on exactly how the deer 

model was run and was utilized. This is a sharply in contrast to other 

Tongass timber project EISs, which have provided details on that, 

sometimes leading to errors or oversights being discovered. 

Consequently, it is not possible for us to determine whether this project 

has used the model correctly, and that is a serious flaw in the DEIS. The 

project materials state merely that "[a]ll analysis is consistent with the 

2011 Direction ..." [634_1102 (wildlife report)], and "[m]odel methods are 

based on recent direction provided by the Forest Service and include: " 

only two points concerning elevation and when all lands or NFS-only 

lands were modeled. [DEIS at 91]. The information given is incomplete 

and inadequate.

Further, we challenge the 2011 deer model direction, and provide as an 

exhibit a critique by Greenpeace of the 2011 direction. [Exh. D-35 

(Greenpeace letter to Cole, 2012)]. The model should be used differently 

than directed.

a. The deer model was not run as stated in the project record 

concerning partial cut units

The DEIS failed to disclose how deer modeling was performed on partial 

cut units. The project’s wildlife report states the way it was done is that 

“these units were assigned old- growth habitat scores to the retained 

portion of the stand.” [634_1102 at 99 (WIP Wildlife Report)]. The 

prescription is for partial cut units to be two-thirds retained and one-third 

cut (on the basis of tree basal area). So, in other words what the 

The deer model was run under the 2011 direction. Information 

was added to the FEIS to explain that all timber harvest units 

were treated as clearcuts and that non-NFS lands were given a 

zero value.

Comments on the 2011 deer model direction are outside the 

scope of the Wrangell Island Project EIS. This direction was 

accomplished with interagency cooperation between the US 

Forest Service and the State of Alaska Department of Fish and 

Game to ensure that the model to be used in the same way as 

was for the analysis in the Forest Plan revision and subsequent 

amendments.

Please see response to comment 061-GSACC-12 and -30. 
Appendix B

Wrangell Island Project FEIS ♦ 243

Comment 

Number Comment Response

statement means is that the modeling assumed that one-third of such 

units will be clearcut and two-thirds will remain old-growth.

Because we were suspicious of how this modeling methodology could 

actually be applied, since the units layouts have not yet been done (i.e. 

with individual trees or clumps of trees not yet selected), Larry Edwards 

of Greenpeace met with IDT officials on July 11 and had two subsequent 

phone calls with them, to resolve that issue.

The outcome of the final call, today, is the modeling actually was not 

done by the method stated in the project’s documentation. As project 

GIS specialist Gene Primaky explained, way he ran the model assumed 

that the units would be entirely clearcut. [Exh. D-28 (Edwards’ notes)].

What is troubling here is, first, that the DEIS is devoid of details on how

the model was run. Secondly, the wildlife report in the project record 

contained misinformation. Third, at Edwards’ July 11 meeting with the 

district ranger (who will be the decisionmaker and attended many of the 

IDT meetings) and the IDT leader had no idea how the modeling had 

been done [Id.], despite deer modeling being a critical issue. Further, it 

appears that the project biologist may not have known how the modeling 

was actually done and whether it met his requirements and expectations. 

Finally, these observations are troubling as an indicator that there may 

possibly be other problems in the project DEIS, if oversight was 

insufficient.

b. Non-federal lands were not properly accounted for regarding 

cumulative impacts to deer

On a July 18 phone call that included the project’s GIS specialist he 

revealed in answer to a question that for the original 1954 condition for 

deer carrying capacity on Wrangell Island, the model runs assumed the 

carrying capacity of non-federal lands on the island was zero. [Exh. D-28 

(Edwards’ notes)]. This was not disclosed in the DEIS. Making this 

assumption gives a completely unrealistic view of the condition at that 

time and of the relative change to the present time and in comparison to 

the action alternatives. Other projects have been able to make a credible 

estimate of the all-lands forest condition at that time for purposes of 

modeling. It seems that should have been done here. If it is not possible 

to do for this project, the DEIS should have candidly disclosed that and 

should have foregone all cumulative impact comparisons to 1954 for 

deer carrying capacity. As it has been done, the analysis is 

misrepresentative because the reported 1954 carrying capacity can bear 

no relationship to the deer populations and amount of annual deer 

harvest in that era. Going ahead, every effort should be made to make a 

The Forest Service regrets any misunderstanding that resulted 

from a variety of separate verbal conversations with the 

commenter.
BAppendix

Wrangell Island Project FEIS ♦ 244

Comment 

Number Comment Response

reasonable estimate of the 1954 carrying capacity, based on inclusion of 

the likely forest composition across all lands at that time.

We point out further that the comparison of the present carrying capacity 

to 1954 as having been reduced by only 15% [Wildlife Report Table 17] 

is erroneous for an additional reason. It is a cumulative impact analysis 

(i.e. spanning several decades), but it considers only “NFS-only” lands, 

not all lands.

061-GSACC355. Subsistence uses of Deer

The Wrangell Island Project violates the Forest Plan and NFMA because 

Wrangell Island (WAA 1903) has far less carrying capacity for deer than 

the 18 deer/mi2 threshold in Forest Plan standard and guideline XIV.A.2. 

[See the carrying capacity discussions in ¶¶2. & 3. above]. The function 

of the standard and guideline is to both protect the sustainability of wolf 

populations and provide habitat to support an adequate population of 

deer for hunters, because wolf sustainability and the ability to acquire 

deer are interlinked. If there is a shortage of deer, some hunters will kill 

wolves to try to make more deer available, and this can threaten the 

sustainability of wolf populations and the viability of the Alexander 

Archipelago wolf. Carrying capacity on Wrangell Island is far below the 

threshold needed to ensure an adequate supply of deer for hunters, so 

the scale of the project is inappropriate, and the project should be 

terminated.

Our scoping comments requested an assessment of the impacts on 

subsistence from increased access for sport hunting and fishing due to 

more roads. Given the numerous proposals for timber-related road 

construction in the project area, it is necessary to do project level 

analysis of road closures and road management objectives now rather 

than to defer the analysis to the District Access Travel Management 

process.

The commenter has overstated the 18 deer/mi2 guideline and 

Forest Plan and NFMA requirements. Carrying capacity for deer 

was part of the analysis as well as its relationship to wolf and 

human predation. Also, please see response to comment 056-

DOW-09.

See the “Subsistence” section of chapter 3 of the EIS. Public 

access to NFS lands was part of the subsistence analysis. 

Please note that Wrangell is designated as a subsistence 

community. Access management analysis was conducted for 

each road and is a component of the Decision. 

061-GSACC36C. Impacts to Alexander Archipelago Wolves: consider abundance 

and significance of GMU 3 populations

We have significant concerns about the impacts of continued intensive 

logging and road construction in GMU 3 including Wrangell Island, and 

request that you consider impacts to wolves on Wrangell Island as a 

significant issue for the Wrangell Island Project. The DEIS is deficient in 

considering impacts to wolves in a mere three pages which only briefly 

mention increased risks the project would cause to the population due to 

reduced deer habitat capability and road density. The discussion fails, for 

example, to analyze these risks in sufficient detail or to include any sitespecific analysis of project area wolf population status or critical issues 

such as the extent to which the project could increase human-caused 

Wildlife – including wolves – is identified as a key issue in the 

analysis. The analysis is included in the “Wildlife Habitat” section 

of chapter 3 of the EIS and the in Wildlife Resource Report. Deer 

carrying capacity, road density, wolf populations and human 

predation are included in the analysis. For more analysis on 

wolves, please refer to the Wildlife Resource Report.
Appendix B

Wrangell Island Project FEIS ♦ 245

Comment 

Number Comment Response

mortality. [DEIS at 91-93]. The DEIS assumes that wolves would persist 

on the island despite acknowledging that localized depletions would 

occur, but without providing meaningful analysis to support its 

conclusion. It suggests that “wolves are highly mobile” and can move to 

adjacent islands with higher deer densities to meet their ecological 

needs – without discussing whether, or the degree to which, this is 

relevant. [Id. at 93].

061-GSACC371. The DEIS failed to analyze risks to GMU 3 wolf populations

Our November 2015 scoping comments requested that the DEIS 

consider and disclose a reasonable population estimate for Wrangell 

Island and assess the significance of that population relative to the 

southern GMU 3 islands complex, and to GMU 3 and the Tongass 

National Forest as wholes. The DEIS provides no information about the 

Wrangell Island wolf population at all, and ignores the significance of 

whatever wolf packs remain on the island relative to the species viability 

across its range.

Dr. Person’s statement regarding the Big Thorne Project identified GMU 

3, including Wrangell Island, as an area of significant concern for AA 

wolves:

Other areas of Southeast Alaska where wolves historically were 

abundant have conditions similar to the Prince of Wales Archipelago. 

Extensive logging and road construction have similarly changed 

conditions for deer and wolves on Kuiu, Kupreanof, Mitkof, Zarembo, 

Revillagigedo, and Wrangell Islands. In conjunction with the Prince of 

Wales Archipelago, those islands sustain most of the wolf population in 

Southeast Alaska. (Person et al. 1996). Decay in sustainable predatorprey communities will occur throughout the most productive areas for 

deer and wolves in Southeast Alaska because those areas are 

correlated with the most productive forest stands selected for timber 

harvest. [634_0154 at ¶13e (Person 2013 Dec’l)].

ADF&G considers the wolves on the southern GMU 3 island complex 

(Etolin, Wrangell and Zarembo Islands) and the northern GMU 3 island 

complex (Kuiu, Kupreanof, Woewodski and Mitkof Islands) to be 

separate populations for management purposes. [Exh. D-03 at 24- 25 

(ADF&G 2012, IM Feasibility Assessment, Unit 3)]. The agency’s GMU 3 

AA wolf population estimates are “crude” and rely on Dr. Person’s Prince 

of Wales Island research and reflect average territory and pack size from 

similar habitat. [Id. at 5; Exh. D-48 at 39 (Lowell 2006); Exh. D-49 at 

41(Lowell 2009)]. Historical population estimates for the GMU 3 wolf 

population are between 125 and 235 wolves in 21 packs, based on the 

amount of suitable habitat below 1,800 feet in elevation. [Lowell 2006(b) 

Available wolf population estimates are presented in the “Wildlife 

Habitat” section of chapter 3 of the EIS and in the Wildlife 

Resource Report. Wolf harvest and trapping information is 

provided by ADF&G. Wolf harvest in GMU 3 fluctuates on a 

yearly basis; between 1998-2007 annual wolf harvest was 47 

and from 2008-2010 it slightly increased to 50, which is above 

their 10-year mean annual harvest (Lowell 2012). For most wolf 

harvest, trapping is the primary means of taking wolves, however 

in three of the last ten years, use of firearms has exceeded those 

taken by conventional methods (Lowell 2012). Reported wolf 

harvest on Wrangell Island has averaged 2.7 wolves per year 

(range 0-6) over the last 24 years (Lowell, personal 

communication 2015). 

The documents cited in the comment have been reviewed and 

included in the project record. 

Please see response to comment 061-GSACC-38.
BAppendix

Wrangell Island Project FEIS ♦ 246

Comment 

Number Comment Response

at 39; Lowell 2009 at 42]. However, the agency recently determined, 

concurrently with the development of proposals to implement predator 

control, that its population estimates for AA wolves in GMUs 3 and 1A 

may be high. [Exh. D-04 (ADF&G 2012(b))].

In 2012 an ADF&G Division of Wildlife Conservation white paper 

indicated that using the results from Dr. Person’s Prince of Wales Island 

research were likely to over-estimate wolf populations in other areas:

However, Person et al. (1996) derived the region-wide estimate based 

on a calibration of wolf density in GMU 2, which represents some of the 

more productive habitat in Southeast Alaska with respect to deer, a 

primary prey of wolves. Also, the wolf estimate was based on habitat 

capability for deer, not actual deer population numbers. Consequently, 

the region-wide estimate of the 1990s may have been biased high. [Exh. 

D-04 at 2 (ADF&G 2012(b))].

Because “[w]olf populations are closely tied to populations of deer,” Dr. 

Person has stated that “[i]f deer populations decline substantially, wolf 

populations are very likely to decline eventually because of a reduced 

prey base.” [634_0150 at ¶23]. For this reason, it is important to 

recognize that actual deer population numbers are extremely low in 

portions of GMU 3. GMU 3 deer populations in general “have existed 

largely at levels well below carrying capacity since the 1960s.” [Exh. D03 at 2 (ADF&G 2012(a), IM Feasibility Assessment)]. In GMU 3, 

particularly the northern island complex (Kuiu, Kupreanof and Mitkof) 

pellet densities and deer harvests are at extremely low levels following a 

series of severe winters. [Id.; Exh. D-50 at 7-24 (Lowell 2013, 

Powerpoint on the 2012(a) IM FA)85]. Thus, the current status of deer 

populations in GMU 3 suggests that the higher range of AA wolf 

population estimates likely suffers from the upward bias indicated in the 

Division of Wildlife Conservation’s white paper.

061-GSACC382. Comments on the carrying capacity for AA wolves primary 

prey, deer

The Wrangell Island Project violates the Forest Plan and NFMA because 

Wrangell Island (WAA 1903) currently has far less carrying capacity for 

deer than the 18 deer/mi2 threshold in Forest Plan standard and 

guideline XIV.A.2. [See the carrying capacity discussions in ¶¶B.2 & B.3 

above]. Nonetheless, the project would decrease carrying capacity even 

more, and the impacts this habitat loss are non-linear [Person 2001]  a 

fact not taken into account by the DEIS. The carrying capacity on 

Wrangell Island is far below this threshold needed to ensure an 

adequate supply of deer for both wolves and hunters. In this case, and 

given the non-linearity of the system (not recognized by the deer model) 

Please see response to comment 061-GSACC-35 and 56-DOW04.

The comment overstates the 18 deer/mi2 guidelines and Forest 

Plan and NFMA requirements.

The deer carrying capacity estimates do not represent actual 

deer densities or populations, but only theoretical estimates of 

habitat capability and are most useful in comparing the 

alternatives. Other factors were considered during the analysis 

for the Forest Plan when determining whether viable populations 
Appendix B

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Comment 

Number Comment Response

and the known low deer population, a seemingly small decline further 

decline in carrying capacity (e.g. by the 0.3 deer/mi2 stated in the DEIS 

at 92) could well prove catastrophic for the deer population and the 

deer/wolf/hunter system. Accordingly, the scale of the project is 

inappropriate, and the project must be terminated.

of wolves would be maintained. Even with these lower estimates 

of habitat capability, the Forest Service determined that there 

was sufficient habitat to maintain viable and well distributed wolf 

populations on the Tongass (2016 Forest Plan Amendment FEIS 

p. 3-224). 

061-GSACC393. Comments on road density related impacts to AA wolves

Our previous scoping comments requested a detailed discussion of the 

impacts of increased road density on wolves in the project area. The 

construction of significant additional roads will increase road density. 

2004 road densities were 0.64 mi/mi2 on Wrangell Island as a whole, 

with high road densities at the watershed scale. [634_0842 at 3- 20 

(Shady EA/FONSI), 634_0121 at 61 (WIA)]. Notably, portions of 

Wrangell Island (the entirety of WAA 1903) identified as otherwise 

having the highest quality wolf habitat have road densities higher than 1 

mi/mi2. [634_0844, Appx. B at B-43 – B-44 (Wrangell Island Roads 

Anal.)]. In particular, the Pat and Salamander Landscape Units have 

road densities of 1.38 mi/mi2 and 1.23 mi/mi2 respectively, causing 

Forest Service planners to identify a concern about impacts to wolves. 

[634_0121 at 21, 27 (1998 WIA)]. The proposed action would 

significantly increase road densities – island-wide – to 1.5 mi/mi2 across 

the island. [DEIS at 93]. Most of the wolf take in GMU 3 occurs in close 

proximity to communities. [634_0844, Appx. B at B-44]. Yet the DEIS 

never provides any information about trapping effort on the island, or 

where it occurs.

The analysis on the effects to wolves includes discussions on 

road density and human predation on wolves. Please see the 

“Wildlife Habitat” section of chapter 3 and the Wildlife Resource 

Report. Current road densities are provided.

Please see response to comment 061-GSACC-37.

061-GSACC404. The DEIS analyses for “NFS-only” lands are of the wrong scale 

for direct & indirect impacts to wolves

A further problem is that the DEIS engages in an analysis of direct and 

indirect impacts to wolves on the basis only of National Forest System 

lands (i.e. “NFS-only”), both regarding deer carrying capacity and road 

density. [DEIS at 91-92, including Tables 19 & 20]. This results in a scale 

of analysis that is not supported by the science, because it has been 

determined that analysis needs to be performed on a whole WAA 

because that approximates the size of a wolf pack home range. 

[634_0575 (Wolf Cons. Assessment); 634_0579 (Person et al. 1997); 

Exh. D-62 (Person 2001)88]. There is a considerable amount of nonfederal land on Wrangell Island (WAA 1903), and when they are not 

included the analysis results are unrealistic and meaningless. Analysis 

that in unrealistic does not comport with the purpose and requirements of 

NEPA.

Wolf analysis needs to be atypical of the commonly used 

direct/indirect/cumulative sequence of analysis that is commonly used for 

The cumulative effects analysis for wolves correctly included all 

lands and were analyzed as such at the WAA scale. See the 

“Wildlife Habitat” section of chapter 3 of the EIS and the Wildlife 

Resource Report.

The deer model was run under current policy direction. 
BAppendix

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timber project issues on the Tongass National Forest, because of the 

pack size related habitat use by wolves. The direct, indirect and 

cumulative impact assessments all need to work at the same scale in 

this case (i.e. “all lands”). The direct effect is distinguishable from each 

other by the element of time (immediate vs future), but the indirect and 

cumulative effects can meld into one that looks both forward and 

backward in time. NEPA accommodates doing the analysis in this a way, 

to fit with the reality of this species habitat use, and it leaves no kinds of 

impacts unconsidered. In contrast, the direct/indirect analysis in the 

DEIS gives false impressions and has no place in an EIS.

To the extent that doing the analysis here may conflict with the 2011 

deer modeling directive, the directive needs to reexamined and modified.

061-GSACC415. Be aware that there are flaws in the recent Archipelago Wolf 

ESA listing decision

In further work on the WIP project, the Forest Service should bear in 

mind that there are key flaws in the recent Endangered Species Act 

(ESA) listing decision for Alexander Archipelago wolves (Canis lupus 

ligoni). In January 2016, the U.S. Fish and Wildlife Service (FWS) issued 

a listing decision finding that Archipelago wolves were not threatened 

throughout all or a significant portion of their range. That decision was 

based on the conclusion that none of the existing threats to Archipelago 

wolves threaten their continued existence throughout southeast Alaska 

and coastal British Columbia. The decision also concluded that the 

Prince of Wales (POW) Island wolf population did not constitute a distinct 

population segment (DPS) or a significant portion of the range (SPR) of 

the entire Archipelago wolf subspecies.

First, there were a number of key flaws in the FWS’ decision. The 

agency erroneously combined wolf populations in Game Management 

Units (GMUs) 1 and 5A -- spanning from Dixon Entrance to Yakutat 

along the mainland (but including some major islands) -- for analyzing 

gene flow and threats. That combination minimizes the existence of 

serious habitat problems in GMU 1A, which has seen extensive logging. 

The FWS also used a flawed road density threshold, mistakenly 

believing that the recommended threshold was 1.5 miles per square 

mile, when unsustainable mortality can occur at road densities of 0.7 

miles per square mile “or less.” [Person & Russell 2008 (769-05-0525); 

TLMP S&G XIV.A.1(c)].

Among emerging issues with the listing decision, are these (briefly):

● FWS used an unjustifiably low predation rate (15 

deer/wolf/year) in modeling the predator-prey dynamics and determining 

wolf population sustainability;

The analysis included reviewing the 2015 USFWS determination

to list the wolf under the Endangered Species Act. The USFWS 

determination is the responsibility of that agency and any 

reconsideration of that determination for the wolf is outside the 

scope of this project analysis.
Appendix B

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● FWS treated future winter severity as a controllable variable 

(but it will be what it will be), using different values for different the 

scenarios. Each severity level should have been run for each model

scenario;

● FWS relied, except on POW, on ungulate food sources “other 

than deer” but failed to analyze the density and distribution of those 

sources of prey;

● FWS assumed that wolf migration is unidirectional into GMU 2, 

contrary to unconsidered science that it is in the opposite direction.

Secondly, the FWS failed to apply the proper analysis under the ESA 

regarding whether Prince of Wales (POW) Island constitutes a significant 

portion of Archipelago wolf range. The FWS also failed to analyze the

southeast Alaska population as its own DPS and the POW Island 

population as a SPR of that DPS.

A new listing petition could raise these issues.

061-GSACC42D. Comments on analysis of impacts to Queen Charlotte 

Goshawks (QCGs)

There are significant uncertainties about the current status of goshawk 

populations and the adequacy of nest protection measures. Our scoping 

comments requested that the DEIS undertake site-specific analysis of 

impacts to habitat in the vicinity of known nest areas given significant 

scientific concern about eliminating important foraging habitat in the 

vicinity of known nests. [See e.g. 634_0860 at 18.]90 The findings of 

FWS status reviews and prior risk assessments, as well as other recent 

studies, demonstrate the risks of continued and serious population 

decline associated with further loss of habitat caused by old-growth 

logging.

The DEIS acknowledges that the project likely will affect the fitness and 

breeding potential of project area goshawks due to reduced foraging 

capacity. [DEIS at 89]. But it then states that although project 

alternatives may adversely impact individual goshawks, but would not 

likely result in a loss of viability on the island or cause a trend toward 

federal listing. [DEIS at 87]. The DEIS justifies this analysis in part based 

on the absence of known goshawk nests within proposed harvest units. 

[Id.]. The DEIS also references the amount of remaining old-growth on 

federal land, which at large scales exceeds the identified threshold 

requiring that more than 50% of the landscape consist of more than 50% 

old-growth and mature second growth. [Id.]. However, within some value 

comparison units (VCUs), the amount of total productive old-growth 

forest (POG) has been reduced by logging nearly to that landscapescale threshold. An important factor of this loss is that less than 40% of 

See response to comment 061-GSACC-43. 

Existing conditions of goshawks were provided in the BE (pages

17-19) and showed there are three known nest sites with the last 

survey being done in 2012 on Wrangell Island and 68 percent 

POG remaining on all lands within the WAA. 

The analysis on effects to goshawk is provided in the “Wildlife 

Habitat” section of chapter 3 of the EIS and in the Wildlife 

Resource Report. 
BAppendix

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the historical high-value POG remains. [Id. at 89]. Future timber 

extraction on non-federal lands would result in further reductions that 

were not quantified in the DEIS. [Id.]. The DEIS also suggests that 

uneven-aged harvest may reduce effects, [id.], even though this 

assumption has been questioned in more recent scientific studies 

specific to Queen Charlotte goshawks, as explained in the following subsections.

Even though Wrangell Island likely hosts a critical portion of the 

remaining goshawk population in southeast Alaska, the DEIS does not 

indicate whether surveys were done and does not even disclose the 

relationship between historical nest sites and surrounding areas. The 

historical nest sites may be essential to the species but were not 

considered. The DEIS simply does not justify or explain its conclusions 

on the project’s effects, and ignores relevant scientific analyses or known 

problems with goshawk viability in the project area. The Forest Service 

needs to prepare a revised DEIS that provides an adequate hard look 

under NEPA and reconsider whether it is possible to implement this 

project while meeting the agency’s obligations to maintain species 

viability.

061-GSACC431. QCGs are a small and vulnerable population and Wrangell 

Island QCGs are a significant portion of this population

QCGs are a small, isolated and almost certainly declining population. 

Both compositional analyses and radiotelemetry studies show that 

breeding pairs of QCGs “in managed landscapes of southeast Alaska 

likely rely almost entirely on productive old-growth forests as foraging 

and nesting habitat” to meet life history needs and avoid second-growth 

or non-forested habitats.” [634_0861 at 7 (Smith 2013)]. Intensive 

clearcutting in southeast Alaska “has converted many watersheds to 

very low quality habitat, or non-habitat, for goshawks. Loss of this habitat 

has likely contributed to at least local declines in QCG populations.” 

[634_0683 at 81 (FWS 2007 QCG status review)].

Population levels are unknown. According to the Fish and Wildlife 

Service, southeast Alaska may support just a few to several hundred 

breeding pairs. [Id. at 48-49]. Survey efforts during the 1990s identified 

only 62 known nest areas, concentrated in significant part (44% (i.e., 

27/62)) in the central portion of the Alexander Archipelago (Stikine 

District). [634_0863 (Flatten et al 2001)]. By 2005, experts had identified 

only 72 unique nest areas, with most of them reportedly inactive, and 

new nests were not being found. [634_0658,95 slides 9–12 (2006 CSR 

QCG panel)]. In sum, there are unknown but small and vulnerable QCG 

populations on the Tongass National Forest, raising substantial 

The references cited in the comment have been reviewed and 

added to the project record. 

The Wrangell Island Project analysis included a thorough 

assessment of the effects of the alternatives on goshawk. The 

known information on populations, habitat, nests and 

vulnerabilities were included. 

In order to protect these Alaska Region sensitive species, the 

Forest Service does not publicly disclose nest locations.

Wrangell Island was surveyed for goshawks in 2010 & 2012, and 

one new territory was discovered which makes a total of three

known territories on the Island. The Forest Plan provides 

guidelines for working near known goshawk territories. See 

Wildlife Resource Report.

According to USFWS (2010), there were historically (year 1900) 

6,395,070 acres of mature old forest. By 2005, approximately 87 

percent of that forest was remaining, and by year 2100, at 
Appendix B

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questions about the possibility of significant adverse environmental 

impacts arising from the Wrangell Island Project on the few remaining 

breeding pairs.

QCGs select primarily for very highly to moderately productive oldgrowth (250 years or older). [Exh. D-42(a) at 36-37 (Iverson et al. (1996) 

QCG conservation assessment)]. There is very little use of low 

productivity forests, and QCGs actively avoid clearcuts, non- forested 

areas, and “mature sawtimber” stands (75 – 150 year old stands). [Id.]. 

The Fish and Wildlife Service’s 2007 status review explained that QCGs 

in southeast Alaska are highly vulnerable to additional stresses —–

because of the low population level, “low survival or reproductive rates 

could not be sustained long before viability of the subspecies would be at 

risk.” [634_0683 at 8-9 (FWS 2007)]. Further, a 2005 study of QCGs on 

the Haida Gwaii concluded that QCGs experience more breeding failures 

than other northern goshawks, and raised the concern that “at the 

present rate of productivity, insufficient young are possibly being 

produced to allow the population to be maintained.” [634_0858 at 1-2 

(Doyle 2005)]. Doyle’s study identifies a number of risks that were highly 

relevant to the analysis in the DEIS, including risks associated with low 

productivity, specific flaws with the use of the high probability foraging 

habitat methodology and uncertainties about using different timber 

management prescriptions to mitigate population effects:

(1) QCGs produce few young fledglings per breeding attempt 

relative to other northern goshawks, and were possibly not producing 

sufficient young in the study area (Haida Gwaii), raising the question of 

whether small insulated island populations with low breeding rates can 

maintain a viable population;

(2) successful breeding may require greater than 60% productive 

old growth;

(3) because of an absence of nest activities outside of known 

nests, it is unreasonable to rely on measurements of highly productive 

habitat as goshawks are not being detected in those areas;

(4) raising uncertainties about the effectiveness of a variable 

retention approach.

The DEIS failed to analyze the particular vulnerability of Wrangell Island 

QCG populations, their habitat needs and relevant risk thresholds. There 

are a number of historical known goshawk nests on Wrangell Island –

but the DEIS makes no effort to disclose the location of those nests in 

relations to past and future timber units. Central Alexander Archipelago 

QCGs – potentially among the most important remaining populations --

current harvest rates approximately 76 percent of old mature 

forest would remain.

Please see table 6 of the Wildlife BA/BE for more information 

about goshawk habitat by historic and existing goshawk habitat 

and by WAA and VCU, which are the scales at which impacts to 

goshawk habitat were analyzed for this project. 

The 2016 Tongass Forest Plan is fully consistent with the 

November 2007 status finding by the USFWS which provides a 

high likelihood of maintaining viable populations of goshawks.

The comment cites outdated information. The current (2008) 

Conservation Assessment was used in the analysis for the 

Wrangell Island Project.
BAppendix

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are particularly at risk relative to other areas managed by the Forest 

Service. The DEIS failed to review the Forest Service’s 1996 

Conservation Assessment which included a risk assessment that 

identified areas with harvest rates exceeding 13 percent by 1995 or 33% 

by 2055 as presenting “a higher risk of not providing the amount and 

distribution of habitat necessary to sustain goshawks” [Exh. D-42(a)(b) 

(Iverson et al. 1996; Iverson & DeGayner 1997)]. Where do Wrangell 

Island VCUs fit within these risk thresholds? Further NEPA analysis 

must address and answer these questions.

In sum, there are significant uncertainties about immediate and long term 

risks to Wrangell Island QCGs, and consequently, the viability of the 

species throughout southeast Alaska. Further NEPA analysis consider 

the population status and particular vulnerabilities of project area QCGs, 

and that recognizes uncertainties about the viability of the population, 

particularly in response to further logging in the vicinity of known nests.

061-GSACC442. The DEIS failed to evaluate and disclose responsible scientific 

opinion raising serious questions about the TLMP conservation strategy

Closely related to the question of current Queen Charlotte goshawk 

population status and risks is the issue of whether current TLMP 

standards and guidelines and the conservation strategy effectively 

sustain viability. For example, federal and state wildlife agencies believe 

that measures implemented in the 2008 TLMP Amendment will reduce 

conservation standards and necessitate a reconsideration of the 2007 

status review. [2008 TLMP FEIS, Appx. H at HA 14, 17, 39]. A 

subsequent study by one of the region’s leading goshawk experts 

identified uncertainties pertaining to whether TLMP conservation 

measures provide the habitat features necessary to sustain welldistributed goshawk populations across the Alexander Archipelago. 

[634_0861 (Smith 2013)]. Smith’s review follows several other important 

studies that provide important information about Queen Charlotte 

goshawk habitat needs and breeding success.

Dr. Smith’s analysis indicated that under the TLMP risks to goshawks 

are likely even greater than anticipated under the 1996 risk 

assessments. [Id. at 6]. Specifically, the 1996 risk assessment assumed 

that the TLMP conservation strategy, particularly the reserve system, 

would in part mitigate habitat loss from excessive timber harvest. [Id.]. 

However, Dr. Smith’s study indicates that contributions from reserves 

and other conservation elements (buffers) “might not mitigate the 

cumulative habitat loss in intensively managed landscapes.” [Id.]. Dr. 

Smith added that there is “evidence on nearby islands that extensive 

loss and fragmentation of habitat from clearcut logging contributed to 

Comments related to the Forest Plan conservation strategy and 

viability of goshawks are a Forest Plan issue and therefore 

outside the scope of this Wrangell Island Project analysis.

The references cited in the comment have been reviewed, and 

as appropriate, integrated into the Wildlife Resource Report. All 

of the references have been added to the project record. 
Appendix B

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population declines of QCGs.” [Id.]. Dr. Smith’s analysis explicitly stated 

that TLMP standards and guidelines “are unlikely to meet breedingseason habitat objectives established for goshawk populations” in other 

areas. [Id., citing Reynolds et al. 1992 (634_0552); 634_0859 (McClaren 

et al. 2005)98]. In a 2012 letter to the Forest Service regarding the Big 

Thorne Project, Smith explained that these findings “increase[d] 

uncertainty about conservation measures contributing sufficient habitat 

to sustain well-distributed viable populations of [QCGs].” [634_086299 

at 5 (Smith 2012)].

Specifically, Smith’s study showed that:

● TLMP conservation measures contribute about half the secure 

habitat recommended for post-fledgling areas of breeding pairs in other 

portions of the northern goshawk’s range

● Guidelines for northern goshawk populations in other areas 

may underestimate habitat needed by goshawks s due to limitations in 

prey resources

● Breeding pairs in southeast Alaska “likely rely almost entirely on 

productive old- growth forest as foraging and nesting habitat as few 

mammal species inhabit low- volume or managed forests and the 

structure of second growth stands renders prey unavailable to foraging 

QCGs. [(Exh. 45 at 6-7].

Another recent study, Sonsthagen et al 2012 [Exh. D-74],100 also is 

relevant to the analysis of cumulative effects and site-specific impacts. 

Sonsthagen et al indicate that a metapopulation framework actually 

suggests a heightened need for specific individual nest site protections 

because without those, the individuals would blink out, resulting in the 

loss of source populations and over time, the metapopulation would 

cease to exist.

In sum, Dr. Smith’s study in particular identified significant uncertainties 

and adverse risks to QCGs associated with the inadequacy of the TLMP 

conservation strategy that contradict assumptions made in the DEIS. 

Further NEPA analysis should discusses and respond to Smith’s 

analysis of the conservation strategy, and assess the implications of 

Sonsthagen’s discussion of metapopulations.

061-GSACC453. The DEIS needs to address the effects of the Wrangell Island 

Timber Project on Queen Charlotte goshawk habitat features through 

appropriate scales of analysis

Our scoping comments requested that the environmental analysis 

specifically consider prey availability and other features such as 

alternative nest sites for project area goshawks. The 1996 conservation 

The goshawk analysis was conducted at the appropriate scale. 

As explained in the “Wildlife Habitat” section of chapter 3 of the 

EIS and the Wildlife Resource Report. 

The wildlife analysis for the Wrangell Island Project considered 

relevant studies and literature. Impacts to goshawks are 
BAppendix

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assessment found that a “broad scale of analysis fails to consider 

distribution of habitat throughout southeast Alaska,” [D-42(a) (Iverson et 

al. 1996); 634_0858 (Doyle 2005)(explaining that it is unreasonable to 

rely on habitat measurements outside of known nests)]. We are also 

concerned about using impacts to high-probability nesting habitat as the 

primary metric for impacts to goshawks. This approach masks 

degradation to specific goshawk foraging habitat caused by logging in 

the vicinity of the nests. A site-specific analysis is possible and will 

generate a more accurate evaluation of impacts to goshawks. For 

example, the Forest Service has in the past evaluated timber projects by 

considering impacts to foraging habitat and disruptions within a 6,000 

acre foraging area surrounding each nest. [634_0839 (S. Lindenberg 

FEIS 1997)]. The DEIS essentially ignores site degradations because 

they are too small to affect the accomplishment of habitat measurements 

at the WAA scale.

But the DEIS arbitrarily relied on broad habitat measurements by VCU. 

Notably, the potential loss of habitat in some VCUs at even this scale 

implicates serious viability concerns. [DEIS at 90, Table 18]. We suspect 

the loss of habitat by nesting and foraging areas would be even more 

serious, but the DEIS never evaluates cumulative habitat loss at an 

appropriate scale.

Dr. Smith’s findings and other studies should have triggered the need for 

analysis of foraging habitat, alternative nest sites, and other habitat 

features. For example, the absence of sufficient prey, particularly 

mammals, can lead to food stress and starvation. [634_0683 (USFWS 

2007)(identifying a number of females on Prince of Wales Island that 

died of starvation during a 2002 study)]. The DEIS should analyze 

whether the project itself provides for alternate nests and post-fledgling 

habitat. Dr. Smith’s findings concluded that the TLMP strategy 

prescribed the reserve-based approach despite insufficient local 

information, and that “[m]ore importantly, the 1997 TLMP did not 

incorporate the concepts of nest area, post-fledging area, and foraging 

area habitat management that underpin the current paradigm of 

conservation planning to sustain viable populations of northern 

goshawks.” [634_0861 at 7]. Thus, “[p]lanners and managers may want 

to revisit assumptions that current standards and guidelines and other 

conservation measures provide sufficient breeding system habitat.” [Id.]. 

The DEIS ignored the 3 hierarchical biological components, “all of which 

need to be considered simultaneously in land-use planning or mitigation: 

... 1) nest area; 2) post-fledging (family (PFA); and 3) foraging area.” 

[634_0862 at 5; see also Exh. 43]. Dr. Smith’s review of the scientific 

literature showed that the majority of a PFAs should provide, at a 

assessed in terms of the reduction in total POG, which provides 

general habitat requirements especially foraging POG habitat (all 

SD classes) and High POG (SD 5N, 5S & 6/7) which represents 

optimal nesting habitat due to the presence of large-trees and 

snags. Reductions in forest cover, and the subsequent 

progression of forest succession of young-growth stands, also 

have the potential to affect the abundance and availability of 

prey. A recent genetic study by Sonsthagen et al. (2012), 

suggests that goshawks population surrounding Wrangell Island 

maybe be declining but have high immigrations rates from other 

neighboring island and that populations in the archipelago and 

adjacent mainland have persisted through recent time and do not 

exhibit the classic “blinking on and off” attributed to local 

extinctions and recolonizations. If timber harvest reduces the 

proportion of the landbase consisting of POG and mature younggrowth forest to below 50 percent, this could possibly result in 

portions of the landscape becoming marginal or unsuitable for 

goshawks. Therefore, alternatives that harvest the most POG 

and reduce the proportion of the landscape consisting of mature 

high POG, would be expected to have the greatest effect on 

goshawks. All action alternatives would maintain at least 91 

percent of the existing total POG within FS lands in WAA 1903 

and maintain a minimum of 88 percent high POG. At the VCU 

scale the most impacted is VCU 4750 maintaining a minimum of 

82 percent of foraging habitat and 74 percent of optimal nesting 

habitat.

In 2007, the Fish and Wildlife Service determined that listing the 

Queen Charlotte goshawk was not warranted, largely on the 

basis of protection provided by out conservation strategy. The 

system of old-growth reserves (OGRs) and other nondevelopment LUDs help maintain habitat for this species.

Comments on the Forest Plan are not a project-level issue and 

therefore are outside the scope of this analysis. Please see 

response to comment 061-GSACC-44
Appendix B

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minimum, 60% old growth forest. [634_0861 at 6; see also 634_0862 at 

4(finding that the mean proportion of POG in nest areas was 71% when 

excluding nest trees on clearcut sites or natural features creating an 

abrupt forest edge (e.g. shorelines)].

In sum, the DEIS failed to disclose and respond to Dr. Smith’s study and 

other risks identified in other relevant studies, including additional sitespecific and quantitative analysis of habitat features required by 

goshawks, and consideration of effective mitigation measures.

061-GSACC464. The DEIS needs to consider cumulative impacts to southeast 

Alaska QCG populations

Because there were serious concerns about QCG viability throughout 

the Alexander Archipelago, this project implicates serious concerns 

about the viability of the species across its range. The effects 

determinations in the DEIS failed to consider the significance of the 

project and cumulative impacts in terms of goshawk viability in a critical 

portion of its range on the central and southern Tongass. Given the low 

population numbers and known distribution of the species, the 

cumulative effects determinations should have involved consideration of 

three relevant spatial scales: regional, central southeast Alaska island 

ecosystems, and, as previously discussed, the cumulative effects of 

logging in the vicinity of known historical nest areas on a small and 

vulnerable population. Analysis at relevant spatial scales is particularly 

important in light of the ESA listing of the QCG in Canada because of the 

metapopulation structure of QCGs and conclusions that contributing 

populations in British Columbia have declined, resulting in increased risk 

to the metapopulation.

Further NEPA analysis needs to review the locations of known nest 

areas and consider the impacts of other projects. Nearly half of the 

historical goshawk nest sites lie within the jurisdiction of the Petersburg 

and Wrangell Ranger Districts. Currently, the Mitkof Island Project, 

Tonka Project, Navy Project, Kake-Petersburg Intertie Project and 

planned state of Alaska logging on Mitkof and Kuiu Island all occur in the 

vicinity of known nest areas.

The determination for goshawk from the alternatives in the 

Wrangell Island Project is “may adversely impact individuals but 

not likely result in a loss of viability in the planning area nor 

cause a trend towards Federal listing.” The analysis was 

conducted at the appropriate spatial scale by VCU and WAA. 

The goshawk analysis was conducted at the project-level scale, 

not the larger and less representative Forest-scale, to better 

depict the impacts to the home range of the individual goshawks 

of Wrangell Island. 

The determinations included consideration of cumulative effects. 

Please see the Wildlife Resource Report.

In sum, the cumulative effects analysis in the DEIS must consider how 

the Wrangell Island Project, in combination with recent and planned 

projects that log in the vicinity of PFAs and foraging areas associated 

with known historical nest sites throughout southeast Alaska, threatens 

QCG viability in light of the low population of the species, and the 

The cumulative effects analysis was conducted at the WAA scale 

(WAA 1903, specifically), and the timeframe was established as 

15 years, which is the generally accepted lifespan of a forest 

plan and would reasonably encompass foreseeable projects.
BAppendix

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importance of individual breeding pairs in the project area to the broader 

persistence of the species.

061-GSACC475. Address TLMP sensitive species mandates by developing 

adequate mitigation & alternative nest management measures

TLMP standards provide that “[s]pecial consideration should be given to 

the possible adverse impacts on habitat of sensitive, threatened and 

endangered species.” [2008 TLMP at 4-89]. We requested 

consideration of mitigation/alternative nest management measures as 

required by the TLMP, such as increased buffers for nests and increased 

forest structure retention requirements in the vicinity of known goshawk 

nests.

The DEIS analysis failed to demonstrate this special consideration of 

goshawk habitat and viability because all it did was provide broad 

measurements of POG reductions.

Because the DEIS never shows where the cutting units are in relation to 

historical nest sites or observations of goshawks, it is impossible to 

assess the extent to which the project will reduce foraging habitat or 

remove potential alternative nest sites. It was necessary to review the 

Biological Assessment to confirm that the Forest Service is aware that 

there are three nest territories – but even the Assessment failed to 

describe the landscape surrounding those territories. [634_1101 (2016 

biological assessment)]. In other words, the analysis is so incomplete 

that it is impossible to provide meaningful comments about how to 

mitigate impacts. Are cutting units within the scientifically recommended 

500 acre buffer? There is no way to know. Further NEPA work needs to 

include a site-specific habitat quality analysis that takes into account all 

available information on differential utilization of various forest types and 

structures.

During the 2008 TLMP Amendment process, ADF&G, the FWS, and the 

Forest Service’s Pacific Northwest Research Station each 

recommended, at a minimum, a 500-acre buffer as needed to minimize 

risks to QCGs. The TLMP required the Responsible Official to “[c]onsider 

surrounding landscapes when managing for goshawk nest sites” and 

provide for alternative nest management measures as appropriate. 

[TLMP at 4-99]. This project area with its high levels of past logging and 

fragmentation exemplifies the type of landscape that requires alternative 

All known and historical nest sites for goshawks are outside of 

harvest units and would be protected by the 100 acre buffer 

around known territory, as described in the Forest Plan 

(standards and guidelines). This buffer is considered adequate to 

protect goshawk nests and therefore additional nest 

management measures are not proposed.
Appendix B

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nest management measures in order to adequately implement the Forest 

Plan guideline.

061-GSACC486. The DEIS ignored known risks to project area goshawks and 

failed to provide survey and nesting data for QCGs and evaluate nest 

and breeding failures

Our scoping comments requested that the DEIS disclose the location of 

any known current or historical nests and any other observations of 

goshawk habitat use, including information about foraging habitat. There 

have been QCG observations on Wrangell Island. [634_0121 at 16, 28, 

33 (1998 Wrangell Island Assessment)]. Our review of Wrangell Ranger 

District EAs and other analyses raise serious concerns about QCG 

breeding and nesting failures on the island. The DEIS should include a 

discussion of possible reasons for these failures. Please also indicate 

how many surveys have been conducted and describe the survey 

methodologies. For example, there was an active nest found in the 

Shady project area, with a failed nesting attempt in 2001, and no 

successful nesting activity since that time despite goshawk observations 

in the project area (surveys done 2000 – 2003). [634_0842 at 3-15 

(Shady EA/FONSI)].

E. Comments on Impacts to other MIS

Our scoping comments requested that the Forest Service provide 

comprehensive analysis of project impacts on other project area MIS and 

consider adopting measures that will mitigate adverse impacts such as 

increased buffers, increased forest structure retention requirements and 

effective road closures. We requested that the DEIS document surveys 

for wildlife species present in the project area and then discuss the 

locations and the species preferred habitat uses. We also requested that 

the analysis do more than a quantitative assessment of productive old 

growth losses at various scales. In particular, we requested 

consideration of specific types of old growth forests that are valuable to 

old-growth dependent species.

In general, the cumulative loss of key habitat features ― and in particular 

for black bear, marten and other MIS such as endemic voles and interior 

forest birds ― on Wrangell Island is alarming, and it is hard to see how 

there will be sufficient habitat available to maintain well- distributed, 

viable populations of existing native species in the planning area [TLMP 

at 4-89]. The DEIS also raises serious questions about the project’s 

inconsistency with numerous TLMP goals and objectives for wildlife, 

which range from maintaining sufficient habitat capability needed to 

provide opportunities for hunting, trapping and wildlife viewing and 

Surveys, which include known nest sites and additional 

inventory, were conducted in 2010 and 2012 and found one 

additional nest. Survey results have been added to the BE. We 

were unable to determine any reason for breeding success or 

failures in known territories.

Habitat was used to assess impacts to MIS species and 

population information was used when available. See the 

discussion on goshawks in the “Wildlife Habitat” section of 

chapter 3 of the EIS. This section also shows the species 

analyzed in the EIS along with preferred habitat and how the 

units of measure apply to individuals and/or habitat.

The Wrangell Island Project is consistent with the Forest Plan 

goals and objectives for wildlife as well as timber production.
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preventing species from being listed as sensitive due to degraded habitat 

conditions. [TLMP at 2-1 – 2-9; 4-89].

061-GSACC491. Comments on impacts to black bears

Our previous scoping comments noted that over a third of the high value 

summer bear habitat on Wrangell, Zarembo and Etolin islands has been 

damaged. In its most recent game management report on black bears, 

ADF&G has continued to express concerns about habitat changes from 

logging. According to that state agency, “timber harvest poses the most 

serious threat to black bear habitat in [GMU 3] over the long term.” 

[634_0845 at 96 (ADF&G 2011 Black Bear Management Report)].

Black bears are an umbrella species with large area requirements and 

varied habitat uses. The health of black bear populations can be an 

indicator of overall ecosystem integrity. The 2008 TLMP FEIS explains 

that “[b]lack bears were chosen as an MIS because of their importance 

for hunting and for recreation and tourism.” [TLMP FEIS at 3-233]. There 

is considerable uncertainty about actual black bear populations on GMU 

3 islands but clear indicia of a general population decline. [634_0845].

Our scoping comments requested that the DEIS disclose impacts to high 

value bear habitat – low-elevation, old-growth forest with abundant and 

productive salmon streams - and discuss how much summer black bear 

habitat and denning habitat will be lost because of this project. We also 

requested an analysis of human caused disturbances to bears, 

particularly those related to roads and summer habitat loss and thinning 

activities near streams during spawning season. Finally, we requested 

that the DEIS recognize the impact of canopy closures and resulting loss 

of understory vegetation and habitat value for bear and consider impacts 

on forage availability due to impending canopy closures in past and 

future clearcuts.

In general, we are concerned about the project’s impacts to black bear 

viability in light of these concerns, and the analysis in the DEIS did not 

adequately address potential adverse impacts. Please address the 

following issues in further NEPA analysis with regard to the viability of 

the black bear MIS and include site-specific analyses of impacts to black 

bears by alternative:

1. We requested that the DEIS clarify whether black bear foraging 

areas will receive additional protections, citing experts recommendations 

for 500 foot riparian buffers to meet foraging needs. Our scoping 

comments requested that the DEIS carefully evaluate expanded riparian 

buffers for black bears and evaluate the recommendations of the recent 

studies on the importance of riparian buffers to bear populations. The 

Forest Service or other landowners have already removed nearly 20 

The WL resource report analyzed the effects on the 500-foot 

areas adjacent to Class I streams for bear foraging areas on 

Wrangell Island and shows that there can be up to a 3 percent 

reduction in POG within those areas from the alternatives and 

cumulative effects when considering past harvest.

The ADFG report cited addresses that the majority of historic 

harvest of black bears comes from Kuiu Island (48 percent) and 

Kupreanof-Mitkof Islands (49 percent) with the remaining 3

percent form a combination of Wrangell-Zarembo-Etolin Islands. 

While timber harvest does cause the most effects to black bear 

habitat, overharvest by hunters, climatic changes, and predation 

on young bears by wolves may also cause decreases in 

population trends. (Lowell 2011a Black Bear Management 

Report, p. 105).

All the riparian management areas which serve as stream 

buffers used in the analysis met the Forest Plan direction. Most 

of these buffers are wider than the TTRA buffers regulated by 

law and are based on the process group as described in the 

Forest Plan, appendix D. The lower elevation streams tend to 

require wider riparian management areas.

The Forest Plan specifically requires 500-foot buffers for brown 

bears at ‘important brown bear sites (e.g. waterfalls used as 

fishing sites)” based with consultation with ADF&G and 

evaluation. No important foraging sites for either black bears or 

brown bears have been identified and the existing foraging 

habitat was considered adequate based on the analysis. 

Please see figures in the “Aquatics” section of the EIS for more 

information on watersheds. 
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percent of historical old-growth habitat within 500 feet of Class I streams 

in the project area. [DEIS at 28]. The TLMP does not delineate specific 

buffers for black bear but does direct that riparian buffers be increased 

from the standard buffer to 500 feet in important brown bear foraging 

areas. Black bear are more secretive than brown bear and should 

receive additional protection. The availability of spawning salmon as a 

food resource is a major influence on bear habitat quality and bears have 

the highest vulnerability to human activities in low elevation riparian 

areas during summer months.

We thus requested that you consider enhanced 500 foot riparian buffers 

for bear as a project mitigation measure. The DEIS indicates that 

Alternative 5 would reduce timber removal impacts “in areas with higher 

specific wildlife values such as 500-foot no harvest buffers on streams 

that have brown bear feeding.” [DEIS at 20]. It suggests that Figure 7 

(Alternative 5) displays those buffers – if so, the display is unclear. The 

DEIS thus provides little clarity as to the extent to which class I streams 

will have only the minimum 100 foot buffer and fails to ensure that black 

bear foraging areas will receive additional protections pursuant to 2008 

TLMP guidance and the recommendations of regional bear experts. 

Wildlife experts recommend implementation of the 500 foot buffer for 

bears on both sides of class I streams regardless of whether or not there 

have been project field observations of an absence of anadromous fish.

Further NEPA analysis needs to apply 500 foot riparian bear buffers on 

all class I streams. The failure to include this measure in any action 

alternative means that the Forest Service has failed to consider its 

statutory mandates to take a hard look at adverse impacts to bear or 

meets its NFMA obligations to provide for wildlife viability.

061-GSACC502. We further requested a discussion of impacts to bear habitat at 

a fine scale, and requested that the DEIS do more than catalog oldgrowth removals at broad scales. Black bears repeatedly use specific 

habitats, and even small stream reaches may be important, thus 

triggering a need to identify high use riparian areas. [Exh. D-59 (Peacock 

2004, Ch.3)]. In general, 100 foot buffers are inadequate to meet bear 

foraging needs. Studies of brown bear riparian habitat utilization found 

that: (1) 500 foot riparian buffers should be applied “universally to all 

salmon streams”; (2) a 1,000 foot buffer would provide for 73% of female 

bear riparian habitat use in lightly altered landscapes and (3) 1,000 foot 

buffers are appropriate in areas where management objectives include 

healthy, abundant bear populations for hunting and viewing. [Id.].

For the above reasons and due to the significant cumulative impact on 

bear foraging habitat, we reiterate our request that you consider 

Because bears are an MIS species the minimum scale is the 

WAA because we are dealing with population trends, not the 

individual scale.
BAppendix

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expanding riparian bear buffers and evaluate this measure as a 

mitigating measure in the DEIS.

061-GSACC513. Old-Growth Forest Dependency: The DEIS should include 

information about black bear utilization of and impacts to large tree oldgrowth forest, which is the most used habitat type by all bears in all 

seasons. Our scoping comments explained that wildlife managers are 

increasingly associated black bear habitat with large-tree old-growth and 

expect population declines to correlate with reductions in this specific 

type of habitat.

Old-growth habitat is included in the analysis and documented in 

the Wildlife Resource Report. All POG was considered for 

denning habitat.

061-GSACC524. Denning habitat requires further analysis: The DEIS provides no 

analysis of denning habitat and simply states that there are no known 

dens within project cutting units. The analysis fails to disclose that black 

bears in southeast Alaska select for specific denning habitats, meaning 

that further NEPA analysis should consider site-specific features, and 

avoid clearcutting in areas that provide suitable denning habitat. [Exh. D23 at 1306, 1313-1314 (DeGayner et al. 2005)]. There is considerable 

re-use of existing den sites, which may indicate in part a lack of 

adequate alternative sites. [Exh. D-22 (Davis et al. 2011)]. In light of the 

likely importance of adequate den sites to black bear survivability and 

reproductive success, further analysis and consideration of mitigation

measures are needed.

Black bears have been found to nest or den in cavities high off the 

ground in tree boles, on Prince of Wales Island. [Exh. D-88 (Woodford 

2015)]. This was a recent discovery, and it is quite possible that this 

habitat use occurs on Wrangell Island as well. The referenced article 

explains concern over these and other bear denning or nesting 

resources:

As a wildlife biologist managing a population of black bears, [Boyd] 

Porter said the take home lesson is that existing dens are a valuable 

resource that should be protected if possible. That’s especially important 

in areas that are logged. Not only are the dens removed (the trees that 

create the dens) in the logging process, but the other old trees that could 

potentially become den sites over time are also removed.

He paraphrased a statement from a research project in British Columbia, 

where bears were using root wads and other woody structure as dens, 

year after year. “If you’re interested in managing black bears responsibly, 

you should be making special allocation for woody structures and insure 

there are plenty of potential sites available into the future,” he said.

“This could help us in terms of comments on timber sale designs and 

locations,” Porter said. “We went to the Forest Service with 50-some 

recent den locations, and suggested they provide some sort of individual 

Denning habitat is included in the analysis and documented in 

the Wildlife Resource Report (tables 31 and 32). 

Table 26 and Table 27 in the FEIS summarize effects to denning 

habitat by alternative.

There are no known bear dens in the analysis area. If a den is 

discovered, Forest Plan direction would apply.
Appendix B

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tree protection, or a small buffer around these known bear den sites. We 

discussed den sites with the Forest Service several times and were 

encouraged by some positive comments from Forest Service staff 

initially. However, in the end they did not incorporate our den site 

protection suggestions for some upcoming large timber sales in the 

same area. There’s nothing in the Forest Plan that says they have to 

make any allocations for black bear dens.”

We urge the Forest Service to take a step back on the Wrangell Island 

Project and do thorough field surveys for den sites in the unit pool. We 

also urge the agency to go beyond minimum requirements in the Forest 

Plan to ensure that these important sites (both present and possible 

future) are protected and well-buffered.

061-GSACC535. Habitat capability model: Please use the interagency habitat 

capability model in further analyses in order to systematically assess 

project impacts to black bears. [TLMP at 4-89].

Interagency habitat models were developed (Suring 1993) prior 

to the 1996 Revised Supplement DEIS for the 1997 Forest Plan 

Revision for each of the 13 identified MIS species. Further 

analysis and evaluated found that few of these models had 

received adequate field review or testing and were expressed in 

population numbers which gave a misleading impression that 

these may be actual population numbers that varied solely on 

habitat capability. Because of this factor and the other model

limitations, most of these models were not used in the 1997 

Forest Plan revision or subsequent analyses (See 1997 Forest 

Plan revision FEIS, p. 3-352). Instead, for the Forest Plan 

revision, expert panel evaluations were used and reevaluated 

during the amendments. 

061-GSACC546. Road density impacts: The DEIS does not adequately address 

road density impacts to bears. Additional NEPA analysis should be 

provided.

Road density is discussed in the “Black and Brown Bears”

subsection of the “Wildlife Habitat” section of chapter 3 of the 

EIS, and in the Wildlife Resource Report.

061-GSACC557. Further NEPA analysis should consider specific riparian habitat 

needs and discuss site-specific mitigation measures: the extensive rate 

of past planned harvest in the vicinity of project area anadromous 

streams is likely to significantly reduce riparian bear habitat and lead to 

population declines. Access to riparian habitat is a major influence on 

bear habitat quality and critical to black bear cub production and survival. 

Bears strongly select for less altered, closed forest riparian habitats. 

Bears using heavily altered habitats consume less salmon and restricted 

access to salmon means that there will be reduced survival and fewer 

hunting and viewing opportunities.

Riparian bear habitat is discussed in the “Black and Brown 

Bears” subsection of the “Wildlife Habitat” section of chapter 3 of 

the EIS, and in the Wildlife Resource Report.

061-GSACC568. Bear population status: Our scoping comments requested that 

the DEIS discuss current trends in black bear abundance in GMU 3 and 

The most current population status available for black bears 

within GMU 3 has been included in the FEIS and the Wildlife 
BAppendix

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disclose indicia of a population decline. Analyze the extent to which 

intensive habitat alteration caused by logging may reduce carrying 

capacity for bears and exacerbate other environmental factors 

contributing to a suspected population decline.

Resource Report. New information has not changed the 

determination.

061-GSACC572. Comments on Project Impacts to marten

Our September 2013 scoping comments identified a significant concern 

about marten mortality on Wrangell Island due primarily to the limited 

amount of roadless refugia on the island and the large proportion of land 

area accessible within 0.9 miles of existing roads. ADF&G noted in 2007 

a potential for the population to become “severely depressed,” given the 

high road density at that time. [2013 scoping comments of Greenpeace 

et al., at 13]. Thus ― given the potential for extinction of marten on 

Wrangell Island, or at least excessive mortality there ― we requested 

that the Forest Service undertake systematic surveys and an in-depth 

assessment of the status of marten on the island and the potential 

cumulative impacts on the population that would result from the WIP 

project.

The DEIS provides no information on current trapping effort or the 

existing status of marten populations. It relies on overall habitat 

measurements to assess impacts. [DEIS at 94-96]. It even suggests that 

existing roadless refugia would be adequate to allow martens to persist 

on the island despite a clear statement that there is a limited amount of 

this habitat. [Id. at 96]. In sum, the DEIS does not adequately assess 

habitat conditions for marten, or justify its conclusions. Without this 

information, it is impossible to evaluate project-level impacts to marten. 

We request that further analysis address the following concerns:

1. Road density risks need further analysis: The DEIS discusses 

road density, but fails to identify relevant thresholds or to what extent 

road density increases would result in the entire population being 

vulnerable to overharvest. [DEIS at 96]. Further NEPA analysis should 

provide a more detailed assessment of road density risks, particularly the 

potential for local extirpations.

Road density effects on marten are included in the “American 

Marten” subsection of the “Wildlife Habitat” section in chapter 3 

of the EIS and in the Wildlife Resource Report. 

ADF&G manages the hunting and trapping of marten and can 

impose restrictions to protect marten, as needed.

The best available information was used in the analysis. Marten 

information was obtained from ADF&G. Trapping statistics are 

included in the Wildlife Resource Report.

061-GSACC582. Further NEPA analysis should include use of the habitat 

capability model: The TLMP specifically recommends using a habitat 

capability model for MIS in order to systematically assess project 

impacts. The need for an interagency model is particularly critical in light 

of project record materials which make clear that marten populations 

cannot remain viable at the proposed levels of habitat loss. [See e.g. 

Exhs. D-18 ( Cheveau et al. 2013); D-39 (Hargis et al. 1999)(marten 

cannot tolerate landscapes that are 25 – 30% clearcut); D-20 (Cushman 

e-a 2011)(marten dependence on forested areas makes them 

Please see response to comment 61-GSACC-53.

The Forest Plan (p. 4-85) suggests the use of models for “any or 

all” of management indicators. However, these models would 

have needed to be periodically reviewed and updated to reflect 

the most current habitat relationships and modeling technology. 

In many instances, the models were not found to be sensitive 

even at the Tongass National Forest scale. The development of 
Appendix B

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particularly vulnerable to local extinctions); & D-40 (Harper 2010)]. 

Please include a road density factor when using a habitat capability 

model as this factor provides a more accurate presentation of cumulative 

habitat loss which is likely understated using the approach in the DEIS.

the Size Density model allows better habitat descriptors for 

various species and those are now used. See Table 12 in 

chapter 3, Wrangell Island Project FEIS.

The marten model has not been recently reviewed and accepted 

by interagency personnel, and in 2008, Tongass Wildlife 

biologists reached a consensus that a different analysis was 

more useful than the models. It is used to determine effects on 

marten habitat for this and other projects. The analysis method 

used for the Wrangell Island Project can be found in the Wildlife 

Resource Report.

061-GSACC593. The DEIS needs to consider forest retention prescriptions for 

marten: Our scoping comments requested that the Forest Service 

consider additional retention requirements in clearcut units. The Saddle 

Lakes area lies within a high risk province for marten but the 2008 TLMP 

provides for no additional forest retention. The cumulative loss of winter 

habitat is massive, reducing historical winter habitat by 40 percent 

across the island [DEIS at 96]. When planned logging will threaten 

viability, partial harvest aimed at maintaining productivity of small 

mammals, retaining habitat features for dens and nest sites, leaving 

substantial amounts of vertical structure are key features that must be 

considered in further NEPA analysis. [Exhs. D-30 (Flynn 2004); D-31 

(Flynn et al. 2004)]. Given this potential impact, further NEPA analysis 

needs to demonstrate consideration of mitigation measures such as 

increased forest structure retention in clearcuts.

The identification of high risk biogeographic province refers to 

the outdated marten standards and guidelines in the 1997 Forest 

Plan (1997 Forest Plan, pages 4-118 and 4-119). This direction 

was changed in the amended Forest Plan in 2008 (Forest Plan 

ROD, pages 23, 25 through 27) to the legacy standard and 

guideline (Forest Plan pages 4-86 to 4-87) which was applied to 

watersheds (represented by VCUs) with past or anticipated high 

levels of harvest. This change was to provide a more 

comprehensive approach to retaining old-growth structure rather 

than a single species approach. The legacy standard was 

retained in the 2016 Forest Plan (p. 4-87) and only slightly 

modified to require the verification during project planning and 

analysis to see if the VCUs in the project area meet the criteria to 

require application of the legacy standard. The analysis found 

that no VCUs on Wrangell Island require the legacy standard 

and guidelines. 

061-GSACC604. Trapping Refugia and Prey Availability: Further NEPA analysis 

should include some additional discussion of trapping refugia and prey 

availability. The analysis would be improved by reviewing the 

recommendations of expert scientists from the 2006 Conservation 

Strategy Review Workshop [Exh. D-32 (Flynn et al. 2006)], and 

considering responsive measures, such as matrix management and 

enhanced corridors between OGRs.

See figure 3 in the FEIS, showing the areas not available for 

timber harvest which can serve as refugia. 

Marten prey was included in the analysis of the alternatives 

effects on marten. The OGR provide refugia for marten. Table 24 

of the Wildlife Resource Report provides a patch analysis of 

POG habitat.

061-GSACC615. Review updated scientific literature on logging impacts to 

marten: We have submitted two recent studies – one indicates how 

marten are one of the most sensitive species to environmental changes, 

including climate change, and bears on project impacts, [Exh. D-55 

(Moriarty et al. 2016)], and the second address how even lighter touch 

logging prescriptions can adversely affect marten movement patterns 

Thank you for your comment. We have reviewed the provided 

reference materials along with others, in the marten analysis and 

included them in the project record. 
BAppendix

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and ecological needs, and indicates that partial harvest prescriptions 

thus can also have adverse impacts and should not be relied on to 

mitigate project impacts. [Exh. D-10 (Aubry & Raphael 2014)].

061-GSACC623. Comments on the project’s impact on the Red backed vole

We are also concerned about the lack of information on the endemic 

southern red-backed vole. MacDonald and Cook’s 2007 publication, 

Mammals and Amphibians of Southeast Alaska [634_0675], suggests 

that this species – also known as the Wrangell Island red- backed mouse 

– may exist solely on Wrangell Island. The DEIS concludes that the 

species would continue to persist, but fails to provide enough information 

to support its conclusions. [DEIS at 110]. It does not disclose the current 

population status of the species or population trends, or explain whether 

surveys are necessary to assess project level impacts as required by the 

TLMP. In sum, further NEPA analysis needs to show how the Forest 

Service intends to comply with Forest Plan standards for endemic 

mammals and NFMA’s viability requirements.

Determinations for southern red-backed voles have been 

reviewed and clarified to state that populations may persist but at 

decreased densities because of the resulting loss of habitat and 

cumulative effects. 

Please see response to comment 055-WS-01 -02, and -03. 

061-GSACC63F. Comments on the Conservation Strategy: Fragmentation, 

Connectivity and OGRs

1. Fragmentation, connectivity and OGRs

The DEIS is incomplete because it lacks a description of the project area 

OGRs and maps that accurately show current levels of fragmentation 

and connectivity corridors. The omission of this information, and a review 

of how the Conservation Strategy is applied on Wrangell Island is a 

major omission. Previous planning on this project contemplated potential 

adjustments to old-growth reserves. But a prior scoping notice indicated 

that because of the pending TLMP Amendment process, “the project will 

not propose any project- specific Forest Plan amendments.” [80 Fed. 

Reg. at 65692]. Further NEPA analysis should discuss in detail the 

nature of the proposed changes, and how possible changes to the TLMP 

conservation strategy bear on the project. The 2015 LRMP Amendment 

process provided no indication that the Forest Service intends to improve 

the reserve system on Wrangell Island, and it is arbitrary to rely on that 

process to avoid site-specific evaluation of potential improvements in the 

reserve system, or analyze existing shortcomings.

We requested that the DEIS include information regarding past 

discussions about OGR placement. The reserve system on Wrangell 

Island is inadequate to meet TLMP acreage criteria for both small and 

medium old growth reserves. [634_0121 at 62-63 (Wrangell Island 

Assessment)]. Previous projects have reflected efforts to add acreage to 

the OGRs to improve connectivity and bring the acreage up to TLMP 

requirements. [See, e.g. 634_0820 (Doughnut EA). Thus the analysis 

The EIS contains maps of the OGRs, existing young growth and 

proposed harvest units from which fragmentation and 

connectivity can be assessed. The OGR conservation strategy is 

described in the Wildlife Resource Report. The IDT considered 

adjusting OGR boundaries and developed the Interagency 

Biologist Review of the Old-Growth Reserve in the Wrangell 

Island Timber Sale Project Area OGR design, which is included 

in the project record. Any adjustments to OGR boundaries would 

require an amendment to the Forest Plan. However, the 

Wrangell Island Project does not propose any amendments to 

the Forest Plan, including changing OGR boundaries. 

The wildlife analysis considered all OGRs on Wrangell Island. 

This can be found in the Wildlife Resource Report.

The wildlife analysis includes an assessment on habitat 

fragmentation and connectivity is documented in the “Wildlife 

Habitat” section of chapter 3 of the EIS and in the Wildlife 

Resource Report.
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needs to address how this project would remove habitat that could 

otherwise be added to improve the reserve system.

The discussion of the OGR system is improperly excluded from the 

DEIS, and requires review of the wildlife resource report. That report only 

heightens the need to consider the reserve system, connectivity and 

fragmentation in the DEIS itself. It is clear that the existing reserve 

system does not meet TLMP criteria. [634_1102 at 40-45]. It indicates 

that there are recommendations for improvements, and that efforts to 

modify the OGRs by adding acreage within IRAs was deemed 

inadequate by the interagency review team due to the lower quality 

habitat within the IRAs. Why, then, is there no consideration of moving 

acreage from other LUDs in order to address the existing deficiencies

with the reserve system? Further NEPA analysis should consider the 

interagency team recommendations, and acknowledge that under the 

status quo the conservation strategy is inadequate.

Please include in further NEPA analysis a discussion of past or ongoing

TLMP inter- agency recommendations for a project area old growth 

reserve network. This information is important for the public to 

understand project level impacts to wildlife. If the existing OGRs differ 

from the interagency recommendations, the DEIS should provide a map 

that compares the interagency recommendations to the existing OGRs.

We also note that the DEIS and resource report fail to show how the 

Forest Service will maintain connectivity among the reserves even under 

the current configuration. The wildlife resource report does provide a 

map of existing corridors, but does not display them in relation to past or 

planned harvest. [634_1102 at 51]. How will proposed cutting units affect 

these corridors? Further NEPA analysis needs to take a hard look at 

connectivity issues.

061-GSACC642. The Tongass Conservation Strategy is insufficient regarding 

deer, wolves & hunting

On February 22, 2016, in our comments on the Tongass Land 

Management Plan Amendment DEIS, we commented extensively on the 

failings of the TLMP’s conservation strategy to protect deer, wolves and 

hunters. The comments identified the need for (and requested) an 

immediate revision and strengthening of the conservation strategy. The 

problems surfaced in part through a 2006 retrospective memo by the 

conservation strategy’s chief architect, former Forest Service planner 

Chris Iverson. [Exh. D-43 (Iverson 2006)]. The problems identified in our 

TLMP comments are applicable to WIP and the project’s compliance 

with NFMA, because the project tiers to TLMP. The problems identified 

are significant.

The conservation strategy is a Forest Plan issue and are outside 

the scope of this project analysis.
BAppendix

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In Appendix A we provide in its entirety the section on the conservation 

strategy from our February TLMP comments. The appendix is intended 

to be read at this point in the present comments.

061-GSACC65G. Cumulative Effects

Our scoping comments requested that those few areas that do provide 

some level of unfragmented habitat, such as the Earl West Cove area, 

should be left alone to buffer impacts of past and future timber 

extraction, particularly in light of pending state timber sales. [See 

634_0842]. On Wrangell Island across all land ownerships, 10,836 acres 

of forest have been logged and over 130 miles of road have been built 

[DEIS at 18 and 7], and the Southeast State Forest Management Plan 

will add to this [DEIS at 9]. The cumulative effects analyses for wildlife 

also list these projects, but they limit the analysis to the Earl West Cove 

project and one ongoing federal project. [See, e.g. DEIS at 96, 99, 103]. 

The DEIS thus omits several adjacent or on-island logging projects 

authorized under the state of Alaska’s Southeast State Forest 

Management Plan – for example, the Pat’s Creeks and Eastern Passage 

state forest lands would add another 3,000 plus acres of degraded 

habitat over time, including lost or degraded deer winter range. 

The cumulative effects analysis needs to include the full amount of state 

land.

Additionally, the DEIS fails to analyze the cumulative effects of pending 

changes to the Conservation Strategy. Specifically, the pending LRMP 

Amendment would authorize logging riparian management areas and 

beach fringe buffers that provide essential connectivity between reserves 

for a variety of old-growth depending wildlife species. This significant 

weakening of the Conservation Strategy received strong opposition from 

leading wildlife experts, [Exh. D-46 (Kirchhoff 2015); Exh. D-07 (Alaback 

et al. 2015)] and warrants disclosure and evaluation in further NEPA 

analysis.

The cumulative effects analysis considered all reasonably 

foreseeable projects. These are listed in chapter 1 of the EIS, 

under Past, Present and Reasonably Foreseeable Management 

Activities in the Project Area.

The wildlife analysis for the Wrangell Island Project did consider 

all lands within WAA 1903 (all of Wrangell Island) into the 

cumulative effects analysis. The direct/indirect effects analysis 

addressed National Forest land while the cumulative effects 

analysis included all land ownerships.

Changes to the conservation strategy related to the 2016 Forest 

Plan are addressed in the reviewing officers Response to Eligible 

Objections. The reviewing Officers response states:

“The 2016 Plan Amendment FEIS (including appendices) and 

the planning record, in conjunction with the 1997 and 2008 

FEIS’s and planning records (and associated references), 

thoroughly discuss the critical characteristics of the Tongass 

conservation strategy, the scientific basis for the Strategy, 

modifications to the contributing elements of the Strategy 

proposed by each of the Plan Amendment alternatives, and the 

extent to which the Amended Plan would function to retain the 

integrity of the conservation strategy and therefore meet the 

objective to conserve old-growth associated species, providing 

reasonable assurance of viability.

“In my opinion, the planning record clearly supports the FEIS’s 

conclusion that: [N]one of the alternatives, when considered in 

whole, would reduce the ability of the conservation strategy to 

maintain a functional and interconnected old-growth ecosystem 

across the planning area and the overall functioning of the

conservation strategy in terms of its ability to maintain viable, 

well-distributed populations of wildlife across the planning area 

would remain.”

(2016 Forest Plan, pages 69 to 72)
Appendix B

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061-GSACC66IV. Comments on Significant Issue 4: Access Management

It is important that the decision to include travel management in this EIS 

is taken seriously, and that travel management decisions are carefully 

considered. The scope of the EIS, including effects analysis and the 

range of alternatives, needs to match the scope of the decision for travel 

management. It is disappointing that the Draft EIS fails to do so. Travel 

management seems to have been shoe-horned in to this decision 

without making the analysis required to make it a good, long-term 

decision.

The DEIS chooses only two indicators, the miles of road, and percentage 

changes in cost, for the travel management issue. [DEIS at 144]. Those 

indicators however fail to capture the enumerated regulatory factors in 

36 CFR 212.55(a), or provide a reasonable basis for the decision.

A. The agency has not done the required scientific roads analysis

A few pages in the transportation resource report notwithstanding, the 

DEIS and project record entirely fail to implement the road regulations by 

conducting a scientific roads analysis.

The project record includes meeting notes from a March 4-8, 2013 travel 

analysis review. This process apparently is the basis for the new travel 

management recommendations. The notes include a table listing 

changes, although many roads do not have any reason at all for 

changes. We find it impossible to comment meaningfully on a black-box 

process such as that.

The agency used five units of measure to analyze this issue: miles of (1) 

open road (2) motorized trail (3) closed road (4) designated for 

decommissioning, and (5) percent change in road maintenance costs. 

These units of measure are geared only towards timber sale design and 

timber roads. The decision being made however involves a variety of 

other factors, including access for things like recreation and subsistence. 

The factors considered should be broader and should, at a minimum, 

encompass the range of considerations in 36 CFR 212 and under the 

Forest Plan.

The travel management regulations are directly at issue here. 36 CFR 

212.5(b) says:

(b) Road system—

(1) Identification of road system. For each national forest, national 

grassland, experimental forest, and any other units of the National Forest 

System (§ 212.1), the responsible official must identify the minimum road 

system needed for safe and efficient travel and for administration, 

utilization, and protection of National Forest System lands. In 

Access management has always been an integral component of 

the Wrangell Island Project. The importance of public access 

became apparent in the public scoping comments and it was 

identified as a key issue. Each of the alternatives address 

access management in ways that represent the theme of each 

alternative and the scoping comments. The access management 

for each road in each of the alternatives is show on the figures 9 

to 13. Also see the “Access Management” section of chapter 3 of 

the EIS and the Transportation Resource Report.

See the “Decisions to be Made” section of chapter 1 of the EIS.

The IDT conducted an analysis of each road. The 

WiLAND_TRAVEL_ANALYSIS_WORKSHEET contains the raw 

data which was incorporated into a GIS feature class titled 

ALLROADS_PROJECT. This worksheet has been reformatted to 

display all of the analysis data and is available in the project 

record. The analysis was conducted in an interdisciplinary 

manner and evaluated the affected resources.

The comment misinterprets the regulatory requirements for a 

forest-wide analysis with this project analysis which only 

addresses access management on the roads that pertain to each 

alternative. The project analysis did include the public, the local 

tribal government and other agencies. The environmental effects 

associated with road construction, reconstruction and 

decommissioning. Road maintenance was addressed.

The roads that are not needed for future resource objectives 

under each alternative are identified for decommissioning, 

closure or transition to ATV trail. 

The access management in each alternative and the decision 

are clearly presented in the EIS. In chapter 1 of the EIS, see 

Decision To Be Made, and in chapter 2, see the alternatives 

descriptions and figures 9 to 13. Each alternative includes a 

specific access management proposal for the roads in that 

alternative. The effects related to the access management 

include environmental effects on the different resources, effects 

on recreation and subsistence, and maintenance costs. The 
BAppendix

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determining the minimum road system, the responsible official must 

incorporate a science-based roads analysis at the appropriate scale and, 

to the degree practicable, involve a broad spectrum of interested and 

affected citizens, other state and federal agencies, and tribal 

governments. The minimum system is the road system determined to be 

needed to meet resource and other management objectives adopted in 

the relevant land and resource management plan (36 CFR part 219), to 

meet applicable statutory and regulatory requirements, to reflect longterm funding expectations, to ensure that the identified system minimizes 

adverse environmental impacts associated with road construction, 

reconstruction, decommissioning, and maintenance.

(2) Identification of unneeded roads. Responsible officials must 

review the road system on each National Forest and Grassland and 

identify the roads on lands under Forest Service jurisdiction that are no 

longer needed to meet forest resource management objectives and that, 

therefore, should be decommissioned or considered for other uses, such 

as for trails. Decommissioning roads involves restoring roads to a more 

natural state. Activities used to decommission a road include, but are not 

limited to, the following: reestablishing former drainage patterns, 

stabilizing slopes, restoring vegetation, blocking the entrance to the road, 

installing water bars, removing culverts, reestablishing drainage-ways, 

removing unstable fills, pulling back road shoulders, scattering slash on 

the roadbed, completely eliminating the roadbed by restoring natural 

contours and slopes, or other methods designed to meet the specific 

conditions associated with the unneeded road. Forest officials should 

give priority to decommissioning those unneeded roads that pose the 

greatest risk to public safety or to environmental degradation.

Here, the Forest-level roads analysis and District-wide roads analyses 

were done prior to the 2007 Wrangell ATM plan. The project decision is 

represented variously as the third tier and as a replacement to the 2007 

Wrangell ATM plan. The approach taken by the agency here is 

confusing. Please provide a clear explanation of the scope and nature of 

the ATM decision being made here.

The DEIS contains essentially no information regarding roads analysis. 

Our efforts to dig for the roads analysis in the project record did not 

satisfy curiousity. The transportation resource report says that during a 

week in March, 2013, resource specialists conducted a Travel Analysis 

per 36 CFR 212.5, FSM 7712 and FSH 7709.55. Powell 2015 at 18-19. 

This “analysis,” actually nothing more than a table listing decisions, is 

contained in an Appendix to that report.

The Roads Analysis appendix

public input is described in the “Public and Agency Involvement”

section of chapter 1 of the EIS, as well as the public scoping and 

DEIS comments themselves. 

Road management for the Wrangell District is prescribed in the 

Forest Road Atlas, a compilation of information which serves as 

the Forest development road system plan. The Road Atlas 

includes the road management objectives for NFS roads. The 

road management objectives define the motorized access for 

each NFS road. Access management for the NFS roads is 

implemented through the Motorized Vehicle Use Map (MVUM) 

which designates roads for motor vehicle use by vehicle class 

under 36 CFR §212.51. The management is required to be 

dynamic and the MVUM is reviewed and published annually.
Appendix B

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Comment 

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● Takes no account for road maintenance costs or budgets;

● Takes no account of red culverts, roads on steep slopes, roads 

that are in riparian areas or conservation LUDs, or any other natural 

resource issues;

● Does not reflect an inter-disciplinary process for decisionmaking. No resource- specific comments are made, no public process is 

identifies, and none of the notes and analysis one would expect to find in 

the project file for a transportation analysis seem to be in the record.

● Took place prior to changing the project to omit the proposed 

TLMP amendments and the DEIS.

Please give priority to conducting a scientific transportation analysis in 

accordance with the regulations.

061-GSACC67B. Rationally consider a reasonable range of Access & Travel 

Management alternatives

The relation between the logging alternatives and the access & travel 

management alternatives is perplexing. It makes no logical sense. Any of 

the ATM alternatives could be implemented under any of the logging 

alternatives, with the exception of new road construction. If there is a 

rhyme or reason to the grouping, it is not stated. The preferred ATM 

alternative grows apparently from the IDT and Borough, Alternative 3 

from the IDT, Alternative 4 from the “IDT of resource specialists,” and 

Alternatives 1 and 5 implement the existing ATM. How can the IDT 

recommendation be being followed under different alternatives? How are 

the IDT and Borough, IDT, and IDT of resource specialists different? 

Please disclose more completely where these alternatives come from, 

and what reason there is behind them.

Please consider an ATM alternative that maximizes road 

decommissioning and brings down long-term road maintenance needs 

and environmental costs. The DEIS approach is a wholly inadequate 

consideration of the available alternatives. None of the analyzed 

alternatives prioritizes conservation or maintenance budgets. That is a 

critical failure because economics and wildlife are highly significant, 

alternative-driving issues. The importance of travel management to those 

issues cannot be considered if no effort is made.

The analysis includes a reasonable range of alternatives. Each 

alternative contains a specific road access management 

proposal. Each road in the alternative was analyzed by the IDT 

as described in the resource report and then assigned an access 

management proposal which was compatible with the theme of 

that alternative. Public input was considered for each road. 

Alternative 1 provides the most miles of road decommissioning 

and proposes no new road construction. Alternative 5 provides 

the same amount of road decommissioning and proposes the 

fewest miles of road construction among the action alternatives. 

This alternative was designed to minimize effects to wildlife while 

still meeting the purpose and need of the project. Maintenance 

was considered in all alternatives.

The DEIS and resource report are incorrect that Alternative 1 would 

“forfeit any opportunity” for future road development, or fail to move the 

forest towards its desired condition. Powell 2015 at 21. Roads that are 

needed could still be developed if there were some reason to; no 

opportunity is being forfeited. 

Thank you for your comment. This statement has been reworded in the FEIS for clarity. 

The 2007 District-wide ATM was conducted to bring the District 

into compliance with the 2005 Road Rule (36 CFR Parts 212, 

251, 261, and 295) where previously NFS lands and roads had 
BAppendix

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Number Comment Response

It is incorrect to say that the current road system is insufficiently vast, as 

evidenced by the ATM plan decision to close a large number of existing 

roads.

been open unless closed, to now being closed unless designated 

open. The ATM was also needed to address road management 

with shrinking maintenance budgets. To conclude the existing 

infrastructure is adequate for all current or future needs based on 

the management strategies of existing roads in an ATM decision 

is not correct.

061-GSACC68C. Road Costs are critically understated in the DEIS.

The transportation resource report provides some hard costs related to 

road development. See Powell 2015 at 20, App. B. New roads come in 

at $146,559/mile; new temporary roads at $131,523/mile, Reconstruction 

at $40,000/mile; and reconditioning of stored road at $3,000/mile. This is 

the sort or hard data that is useful for decision-making, but unfortunately 

the figures seem to have been plucked out of thin air using a deeply 

flawed methodology. Regarding maintenance budgets, the transportation 

report states the annual budget is $140,000. That total maintenance 

budget figure is then used to determine maintenance cost impacts by 

dividing it by the total number of road miles, arriving at an average 

$545.60/mile maintenance cost, then calculating maintenance costs 

post- implementation based on that average figure.

There are many problems with this simplistic measure. First, it doesn’t 

take account of deferred maintenance. In reality, current budgets and 

open road miles don't’ align exactly. In fact, budgets are known to be 

inadequate currently, so the DEIS projection of budget impacts is 

certainly lower than it will actually be. Second, it fails to account for 

maintenance costs on closed and stored roads, which are not nothing. 

Every road requires, at absolute minimum, annual monitoring. While it is 

a neat rhetorical trick and a nice objective, there is no such thing as a 

“self-maintaining road.” Third, it doesn’t account for differences in 

maintenance costs for different roads. In reality maintenance costs vary 

depending on many factors (slope, hydrology, gravel quality, distance, 

traffic, etc.) making some roads far more expensive to maintain than 

others. These differences are critical to evaluating a minimum road 

system. These differences are known to the agency and no reason is 

given why the better information is not being used. By accounting for 

differentials in maintenance costs the decision-maker would be able to 

direct limited funds in the most efficient manner. Fourth, the metric is 

misleading because a decrease is open road miles does not impact road 

maintenance budgets in so direct a manner. In reality, the district easily 

spends whatever budget it is given for transportation maintenance, and 

would continue to do so even under full implementation of the ATM plan.

The Transportation Resource Report, “Road Costs” section, 

discusses how road development costs were derived. These 

costs come from the Regional Cost guides. All costs are 

estimates and they are intended to provide a relative comparison 

among alternatives. 

The maintenance costs estimates are adequate for the analysis 

and the decision. They are considered in the decision but 

environmental effects and management considerations carry a 

heavier weight. The annual maintenance budget accounts for 

both annual and deferred maintenance (excluding “red” pipes 

and bridges, which are funded at the Forest level. Please see 

response to comment 061-GSACC-75). Monitoring of closed 

roads is not considered maintenance. The maintenance costs 

provide a relative comparison among alternatives and, because 

of the calculation method, actually provide an overestimate of 

maintenance costs. ML 3 roads require more maintenance, or 

about 80 percent of the maintenance budget, and ML 2 roads 

receive about 20 percent. Road maintenance budget allocations 

for the Wrangell Ranger District are directly impacted by 

changes in the miles of Objective Maintenance Level 2+ roads.

Road decommissioning costs associated with harvest units are 

accounted for in logging costs. Road decommissioning and costs 

not associated with harvest units were analyzed in the 2007 ATM 

and do not factor into this project. This project proposes 

additional miles of road to be decommissioned. Road 

decommissioning is a one-time cost whereas maintenance is a 

reoccurring, annual cost. “Red” culverts are prioritized and 

funded in a Forest-wide program. 

Table 1 in the Transportation Resource Report displays the 

implementation of the 2007 ATM plan to date. 
Appendix B

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On top of all those problems there appear to also be mundane 

oversights in calculation. The calculation of the change in road 

maintenance costs under alternatives appears not to account for costs to 

decommission roads. Ongoing maintenance work and red culvert 

projects are ignored. Please ensure that the data used is both accurate 

and reliable.

Major deferred maintenance such as bridges and “red” culverts, 

are included in the Transportation Resource Report. However, 

these are prioritized and funded at the Forest level. Other 

deferred maintenance items, such as road brushing, ditching, 

and non-fish culvert replacement, occur on a regular, periodic 

basis.

061-GSACC69D. Deferred Maintenance should be specifically disclosed and 

considered

Please provide some information regarding the delayed implementation 

of the current ATM plan. Why is the current plan not being implemented? 

Or if it is being implemented, why has a decade passed without any road 

decommissioning. There seems to be an implication that lack of funding 

to close roads is the reason, although this is never addressed. How long 

does the agency suppose it will take, under a “No Action” alternative, for 

the existing ATM plan to be implemented?

We are also concerned that implementation of the road 

decommissioning and closures will be delayed. The DEIS completely 

ignores this salient factor. The sale itself is a full decade at least, 

followed by an unspecified number of years during which roads would be 

left open for local use. Further delays can be expected due to budgeting 

constraints, logistical issues or other complications. The current ATM 

plan is about a decade old and still has only been partly implemented. 

Similar delays are reasonable to expect for the new plan, too. During this 

extended period of time the road density, and road maintenance costs, 

will be far higher than is being considered in the EIS. Please consider 

and disclose this “maximum” road density as it relates to (1) project 

economics, (2) wildlife effects (particularly the wolf), (3) transportation 

management and (4) aquatic and fisheries impacts.

The DEIS makes passing mention to deferred maintenance, a longstanding problem on the forest. It is notable that there are currently many 

more miles of road that are open than intended under the ATM plan. 

Clearly that plan is not being implemented. Please consider and disclose 

the reasons why that has not been implemented. It is imperative that the 

maintenance backlog be disclosed and analyzed specifically.

First, the shortage of maintenance funds is relevant to implementation of 

proposed mitigation measures. The proposed action, in terms of both the 

logging project and long-term access management, relies heavily to 

mitigation measures to, for example, comply with Clean Water Act rules 

as to fish passage, and implement a variety of protections for essential 

fish habitat. Watershed impacts here are considered not a significant 

issue as a direct result of these proposed mitigation measures. Where 

Comments on the Forest’s deferred maintenance program are 

outside the scope of this project analysis. Please see the 2007 

ATM Decision and the Transportation Resource Report for 

information on the implementation of the ATM plan.

The major deferred maintenance items such as bridges and “red” 

culverts in the project area are identified Deferred Maintenance. 

These are prioritized and funded in the Forest Maintenance 

program. Other deferred items such as road brushing, ditching, 

non-fish stream culvert replacement occurs on a regular and 

periodic basis. 

Road decommissioning would occur after harvest activities are 

complete. 

Thank you for your comment on the 4 percent decrease, this has 

been clarified in the FEIS.
BAppendix

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Comment 

Number Comment Response

an agency relies on mitigation to avoid considering a significant issue the 

result is closely analogous to a “mitigated FONSI,” which triggers 

heightened attention to the practicability of mitigation.

The DEIS and proposed access plan do not admit even of the possibility

that planned mitigation (e.g. road decomissioning) will not be done in a 

timely manner, or will be done incorrectly or poorly. A general “good” 

record at implementing BMPs is not an adequate surrogate for the 

necessary analysis.

Second, the maintenance budget backlog is directly relevant to the 

analysis of the minimum road system under 36 CFR 212.55(a). Available 

budgets are one of the enumerated factors that must be considered. It is 

impossible to say what the minimum road system is without this 

information. The DEIS and transportation reports make the major logical 

error of simply assuming that budgets now are perfectly correlated to 

need, and work from there to arrive at road costs and maintenance 

projections. That approach is wholly irrational where, as here, existing 

budgets are known to fall short.

Incredibly, the transportation resource report contains only a single 

reference to deferred maintenance, in an appendix of definitions. It says:

Deferred Maintenance. Maintenance that was not performed when it 

should have been or when it was scheduled and which, therefore, was 

put off or delayed for a future period. When allowed to accumulate 

without limits or consideration of useful life, deferred maintenance leads 

to deterioration of performance, increased costs to repair, and decrease 

in asset value. Deferred maintenance needs may be categorized as 

critical or non-critical at any point in time. Continued deferral of noncritical maintenance will normally result in an increase in critical deferred 

maintenance. Code compliance (e.g. life safety, ADA, OSHA, 

environmental, etc.), Forest Plan Direction, Best Management Practices, 

Biological Evaluations other regulatory or Executive Order compliance 

requirements, or applicable standards not met on schedule are 

considered deferred maintenance. (Financial Health - Common 

Definitions for Maintenance and Construction Terms, July 22, 1998)

Powell 2015 at 36. Deferred maintenance by definition has 

consequences that need to be considered.

One major area of deferred maintenance are the red culverts, each one 

of which by definition is a violation of BMPs and, by extension, the Clean 

Water Act itself. Despite awareness of the issue for decades, there is no 

evidence that the agency has made any progress at reducing the 

number of red culverts.
Appendix B

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Comment 

Number Comment Response

Related to the problem of deferred maintenance, the DEIS under-counts 

the private and public cost of transportation facilities for this project. To 

start with, the road analysis is unclear and confusing. The DEIS indicates 

that implementing the ATM would decrease annual maintenance costs 

by 19%, and that the preferred alternative would decrease cost by 4% 

from current costs, but increase them by 19% as compared with ATM 

implementation. [DEIS at 148]. Where has the extra 4% come from?

The confusion is magnified by the DEIS failure to use specific 

information, even though it is available, preferring instead to guess as 

averages. DEIS never says what the current road costs are, or what the 

budget is, or what the consequence is if those figures don’t match.

Those are the most critical factors related to access management and 

they are central to the minimum road system.

061-GSACC70E. Please carefully consider bridge maintenance issues

Table 52 identifies a large number of bridges that are in poor or serious 

condition. This is a potential concern not only for safety, but also for 

project economics and travel management. Please disclose the safety 

status of these bridges in the FEIS and plan to avoid any safety 

problems. Please also disclose the projected cost to repair and maintain 

the faulty bridges. That information should be applied to prioritizing roads 

for decommissioning, and to inform the economic analysis of this project. 

The transportation resource report indicates that bridges with less than 

satisfactory rating will require maintenance prior to log haul.

Powell 2015 at 5. Table 2 in that report shows three “fair” bridges on the 

6270 road, and a “poor” bridge on the 6299. Powell 2015 at 6. Yet the 

cost to repair these bridges does not appear to have been included 

among the economic costs of the project.

Thank you for your comment. 

The maintenance of these bridges is done as part of the 

Tongass bridge program and work on them is independent of 

this project. Bridges are routinely inspected, and they are closed 

or load-restricted when they become unsafe.

The bridges listed as “fair” or “poor” condition in the 

Transportation Resource Report require little work to bring them 

to standard and are currently being addressed at the Forest 

level. Please see response to comment 061-GSACC-75.

061-GSACC71F. Road decomissioning opportunities should be identified and 

pursued

The DEIS does not reflect any effort being made to analyze roads for 

decommissioning. The operating assumption has become that all roads 

will be “stored.” Storage might be the best decision in some cases, but 

consideration of decommissioning is mandatory under the Forest Plan 

and the roads regulations at 36 CFR, and needs to be undertaken. 

In light of the second-growth transition, maintenance budget shortfalls, 

and negative ecological consequences of existing high road densities, 

we urge the agency to aggressively pursue road decommissioning.

Please refer to the Transportation Resource Report for the 

definition of decommission and the definition of a National Forest 

System road.

Road decommissioning opportunities have been identified and 

are being proposed in all Alternatives. See table 1 of the 

Transportation Resource Report or table 51 of the FEIS for total 

miles of roads which have already been decommissioned. The 

Forest Service had previously been through the exercise of 

identifying unneeded roads and have implemented the majority 

of the road decommissioning, such as in Old-Growth Reserves. 

Roads not identified for decommissioning are needed for the 

long-term management of National Forest System lands.
BAppendix

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Comment 

Number Comment Response

V. Comments on the Aquatics Resource Chapter

The DEIS identified four significant issues: (1) timber supply and 

demand; (2) wildlife habitat; (3) scenic quality and (4) access 

management. [DEIS at 10-11]. Our November 2015 scoping comments 

explained that Wrangell has undertaken a market-based transition 

toward fisheries, marine repair and tourism. For this reason, we 

requested that you consider adverse impacts to fishery resources in your 

economic analysis as it is unreasonable to exclude externalized costs 

from the assessment of economic impacts.

Our scoping comments also explained that, in light of the importance of 

fisheries to the local economy, impacts to aquatic habitat, and 

particularly fisheries, should be a significant, alternative driving issue. 

[See, e.g. 40 C.F.R. § 1501.7]. Across the biogeographic province, 

riparian forests have been logged at a much higher rate than is shown by 

cumulative watershed harvest. The prior landscape analysis identified 

significant concerns about the cumulative effects on high quality fisheries 

habitat, particularly on sensitive central Wrangell Island watersheds. 

[634_0767 at 8, 16, 21-22, 27 (1998 Wrangell Island Analysis)]. Because 

of the level of past development in this area, the likelihood of increased 

sediment-yield risks or erosion potential, and the high density of existing 

and proposed roads along with past maintenance problems, we reiterate 

request a full watershed analysis be conducted as required by the TLMP. 

As indicated in the aquatics resource report, the Forest Service has 

failed to collect baseline data on watershed conditions. [634_1106 

(Aquatics resource report) at 38]. The failure to produce a watershed 

analysis is thus a major omission.

061-GSACC72A. The DEIS failed to take a hard look at risks to Wrangell Island 

salmon populations

The following sub-sections provide more detailed comments on specific 

issues we recommend for detailed discussion in further NEPA analysis. 

The DEIS failed to include a comprehensive review of adverse impacts 

to salmon, and arbitrarily failed to consider alternative or mitigation 

measures that reduce these impacts. [DEIS at 6 (refusing to consider red 

pipe replacement as part of the project), 23 (refusing to consider 

alternatives that would reduce adverse impacts to salmon by deferring 

timber extraction in heavily degraded watersheds and avoiding road 

construction)]. Coho and pink salmon are Tongass National Forest 

indicator species as well as commercially important, [2008 TLMP FEIS at

3- 74], and yet the DEIS fails to even include a “fisheries” section, thus 

demonstrating the failure to take a hard look at adverse impacts to fish. 

[Cf. Exh. D-85 at pdf-p.27 (Kosciusko Final EA, 2015 )(showing that the 

Kosciusko and Wrangell Island are very different projects. 

Kosciusko Final EA, 2015 has specific treatments within the 

riparian area, whereas no activities are proposed within riparian 

areas in the Wrangell Island Project alternatives. Units in the 

Wrangell Island Project were designed to avoid all fish bearing 

streams. Please see the EFH discussion in the “Aquatics”

section of chapter 3 of the EIS, as well as the Aquatics Resource 

Report.
Appendix B

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Comment 

Number Comment Response

Forest Service reviews impacts to fisheries in a separate resource 

section in an EA)].

061-GSACC731. The DEIS should have included alternatives that entail no road 

construction to mitigate impacts to salmon, particularly for sensitive 

watersheds

We reiterate the previous request from the Center for Biological 

Diversity’s previous scoping comments and request alternatives that do 

not entail road construction. Road construction is by far the greatest 

contributor of sediment to aquatic habitat of any forest- management 

activity. In particular, the Forest Service should have developed 

alternatives that take care to avoid constructing roads and placing cutting 

units near high value fish habitat and recreational fishing areas and/or 

areas heavily impacted by previous timber harvest and road construction 

activities such as McCormack Creek, Thoms Creek, Salamander Creek 

and Pats Creek. The cumulative harvest levels and road densities in 

some of these watersheds are alarming, and yet the DEIS fails to even 

provide any analysis of how these impacts will reduce salmon 

productivity. [See DEIS at 3-170-171].

We also requested that further NEPA analysis disclose and consider 

scientific studies that have found strong negative correlations between 

logging road density and salmon productivity. For example, NMFS has 

found that logging has:

... degraded coho salmon habitat through removal and disturbance of 

natural vegetation, disturbance and compaction of soils, construction of 

roads and installation of culverts. Timber harvest activities can result in 

sediment delivered to streams through mass wasting and surface 

erosion that can elevate the level of fine sediments in spawning gravels 

and fill the substrate interstices inhabited by invertebrates. The most 

pervasive cumulative effect of past forest practices on habitats for 

anadromous salmonids has been an overall reduction of habitat 

complexity from loss of multiple habitat components. Habitat complexity 

has declined principally because of reduced size and frequency of pools 

due to filling with sediment and loss of LWD (large woody debris).... As 

previously mentioned, sedimentation of stream beds has been implicated 

as a principal cause of declining salmonid populations throughout their 

range .... Several studies have indicate that, in [southern 

Oregon/northern California], catastrophic erosion and subsequent 

stream sedimentation [from major floods] resulted from areas which had 

been clearcut or which had roads constructed on unstable soils.

Alternative 1 is the no action alternative and proposes no road 

construction or timber harvest. The other alternatives provide 

riparian management protection to all fish streams. The harvest 

units for this project have been designed to avoid all riparian 

management areas (RMA). All fish bearing stream crossing 

constructed as part of this project would follow handbook 

guidance for aquatic organism passage design. The Aquatics 

Resource Report uses both cumulative harvest and road 

densities to analyze peak flows effects. 

The scientific papers used in the analysis and others provided by 

commenters have been considered and are included in the 

project record, as applicable. 

It should be noted that there are no ESA-listed salmon stocks in 

Alaska. 
BAppendix

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Comment 

Number Comment Response

These findings reflect a significant number of scientific studies showing 

that logging and road construction activities will harm fishery resources 

that are most important to TLMP local and regional economy objectives.

061-GSACC742. Analyze cumulative watershed effects of previous, ongoing and 

future state logging projects

Additionally, there are significant questions about regulation of logging

practices on state of Alaska and private timberlands in the project area. 

The DEIS failed to evaluate the impacts of state and private logging 

projects on Wrangell Island and analyze whether the Alaska Forest 

Resources and Practices Act: (1) provides adequate riparian buffers; (2) 

allows operations within those buffers that degrade salmon habitats; (3) 

allows for operations on high-risk landslide areas or (4) adequately limits 

cumulative watershed effects and road densities.

Cumulative effects on watersheds were addressed in the 

“Aquatics” section of chapter 3 of the EIS. Activities on State 

lands were taken into account where information was available. 

For instance, while a plan has not yet been put forth for harvest 

of trees on State-owned land in the Earl West Cove area, we 

have reason to believe that logging will occur there in the 

foreseeable future, and analyzed the cumulative impacts in the 

area accordingly. 

Regarding the Alaska Forest Resources and Practices Act, the 

Forest Service has no authority over State lands, and a complete 

analysis of the efficacy of this State law is out of the scope of the 

Wrangell Island Project.

061-GSACC753. The DEIS failed to consider an alternative or mitigation 

measure that addresses fish passage concerns

Our previous scoping comments expressed concern about the number of 

culverts on Wrangell Island that are currently inadequate for fish 

passage. The TLMP clearly recommends that the Forest Service 

undertake measures to ameliorate the past and ongoing damage done to

the fisheries economy, [TLMP at 4-10 – 4-13], but the DEIS failed to 

develop appropriate mitigation measures. There were 46 failed culverts 

on Wrangell Island in 2007, including five red pipes identified as “urgent” 

for replacement due to blockage of more than 500 meters of upstream 

habitat in Class I streams. [634_0844, Appx. B at B-22 – B-23 (Wrangell 

Island Roads Analysis)]. Failed culverts on Road 6267 alone block over 

7 miles of spawning habitat, and even red culverts identified as moderate 

priority for replacement cumulatively block over 3 miles of spawning 

habitat. [Id. at B-23 – B-24]. While the Wrangell Ranger District’s ATM 

EA recognizes that failed culverts have negative effects on aquatic 

habitat and identifies studies establishing a correlation with decreasing 

fish densities, it cites an absence of research in southeast Alaska as 

creating some uncertainty about the extent to which failed culverts are 

harming aquatic species. [634_0843 at 3-20-21 (Access Travel 

Management Plan EA)]. Thus, even though the ATM EA notes that “[t]he 

most substantial direct impact of road on fish species is through the 

presence of red pipes, which can prevent migration of fish,” the ATM 

included no alternatives that specifically addresses repairing red pipes. 

[Id. at 3-21]. The suggestion that there is uncertainty about the extent of 

Culvert replacement is identified as a potential stewardship 

project in chapter 1 of the EIS and as such, would be considered 

as separate projects with separate NEPA and planning.

The Tongass considers fish passage to be an important priority 

and has an ongoing program to eliminate or replace culverts that 

do not provide passage. Approximately 340 “red crossings” have 

been corrected throughout the Forest since 1999, not including 

“red” culverts removed through storage of approximately 200 

miles of road across the Forest in 2011. It may not be advisable 

or feasible to replace all existing “red” culverts with fish passage 

designed crossings. Though a crossing may be categorized as 

red, it may not impede larger fish and may even pass fish of all 

sizes during certain stream flow levels. Furthermore, many of the 

crossings have very limited amounts of fish habitat upstream. 

The replacement of “red” culverts to improve fish passage is 

prioritized on a Forest level, and is anticipated to reflect the best 

use of funds allocated by Congress for this purpose. 

The Aquatics Resource Report has been updated to provide 

more information on aquatic organism passages.
Appendix B

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harm to fish species arising from fish passage blockages is 

unreasonable, and the DEIS should review scientific information that 

addresses this “uncertainty” and develop an alternative or mitigation 

measure that would fix fish passage problems.

...

The DEIS states that the Forest Service did perform surveys to 

determine the number of stream blockages, and yet this number is not 

disclosed in the DEIS. [DEIS at 3-158]. Information about red pipes is 

critical to the analysis of impacts to salmon, and further NEPA analysis 

needs to include a discussion of stream passage concerns. The only 

information about red pipes is inappropriately included in the resource 

report rather than the DEIS. The resource report itself is incomplete; it 

does identify 38 red and 4 gray stream crossings that are unsuitable for 

fish migration, but nowhere discloses the amount of miles of stream 

habitat blocked, or indicate any plans to fix these red pipes – even 

though such an effort would better meet the Forest Service’s local and 

regional economy goals and objectives much more effectively than the 

proposed action which authorizes timber harvest by what are likely 

mostly out of state loggers for foreign processors. Instead, through 

mitigation measures that emphasize red pipe replacement, the Forest 

Service could employ any of the numerous local workers from the road 

construction industry on a project aimed at supporting local, marketbased industries. The agency clearly has the capacity to implement such 

a program as part of a logging project. [See Exh. D-85 at pdf-p.119 

(2015 Kosciusko Vegetation Project Draft Decision Notice and 

Environmental Assessment) (planning to fix all red pipes on federal lands 

in the project area].

We thus reiterate that the DEIS must consider a mitigation measure that 

restores fish passage in the project area. The issue of blocked culverts is 

so important to salmon habitat that tribes have sued the state of 

Washington in order to require it to fix barrier culverts in order to 

increase salmon populations in the region. [634_0856 (amici curiae brief 

of Pacific Coast Federation of Fishermen’s Associations, 2014); D-25 

(Court decision in US v. State of WA)]. As explained by EarthJustice in 

an amicus brief filed on behalf of commercial fishermen in the state of 

Washington:

... because barrier culverts block access to habitat entirely, barrier 

removal is frequently the most effective recovery measure (and often the 

measure with the most immediate positive impact) when compared with 

other habitat recovery efforts, such as reforestation, repairing streamstraightening or channelization, or increasing flows. And obviously, other 
BAppendix

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habitat restoration efforts will be futile if salmon are unable to access the 

restored habitat.

EarthJustice briefly noted that the district court agreed that barrier 

culverts “have a significant total impact on salmon production” due to “a 

negative impact on spawning success, growth and survival of young 

salmon, upstream and downstream migration, and overall production.” 

Thus, removing them “provides immediate benefit in terms of salmon 

production, as salmon rapidly re-colonize the upstream area and 

returning adults spawn there.” [634_0856 at 14-16]. We believe that 

fixing these problems is an obligation under the Clean Water Act and 

Alaska state law, and that there is a NEPA obligation to develop an 

alternative or mitigation measure that prioritizes the remediation of fish 

passage problems.

061-GSACC764. The DEIS ignored stream temperature concerns

Our scoping comments requested that the Forest Service acquire 

baseline stream temperature data and develop a stream temperature 

monitoring plan for Wrangell Island. We also requested that you seek out 

updated scientific literature regarding the impacts of vegetation removals 

at multiple scales on stream temperature and the effectiveness of 

riparian buffers and discuss this material in the DEIS. The DEIS 

mentions Alaska water quality standards and acknowledges that logging 

can increase stream temperatures, but makes no effort to explain how 

these impacts increase risks to project area fish populations. [DEIS at 

167]. The analysis thus omits an important factor necessary to analyzing 

project impacts, and we request that a revised DEIS include a full 

analysis of risks of stream temperature increases and how those 

increases reduce salmon productivity.

The indirect effects to fish from stream flow and temperature 

change as a result of logging activities were identified and 

addressed in the Aquatics Resource Report. The primary 

conclusion is that effects to fish from this association would be 

minimal due to the application of Forest Plan fish and riparian 

standards and guidelines, and the application of BMPs.

061-GSACC775. The DEIS failed to disclose how LTFs will adversely impact 

fishery resources

The DEIS indicates that the Forest Service intends to allow for in-water 

log storage at the Pats Creek and Earl West Cove marine access 

facilities. [DEIS at 140]. There has not been a benthic dive survey at 

either facility since 2001, with the historical surveys showing levels of 

bark accumulation in compliance with permit conditions. [Id. at 140-141].

The discussion of adverse impacts to marine resources is 

incomplete – the DEIS fails to disclose potential harm to salmon, crab 

and other marine species, or consider how LTF operations will interfere 

with the more valuable commercial fisheries. [DEIS at 3-176-177]. It 

relies solely on dive surveys to mitigate impacts of in-water log storage, 

and never discloses that the Forest Service could require Alcan to take 

The Wrangell Island Project identifies the existing Pat and Earl 

West Marine Access Facilities (MAFs). Their use is at the 

discretion of the successful bidder. The State of Alaska is 

responsible for the permitting and monitoring of MAFs. The 

Forest Service holds State permits and would perform all 

required monitoring and reporting related to harvest from the 

Wrangell Island Project, we are not the exclusive permit holder of 

the MAFs on Wrangell Island. The permits require pollution 

control plans and monitoring based on volume usage.

The “Aquatics” section of chapter 3 of the EIS and the Aquatics 

Resource Report describes the effects to the marine 

environment. As noted, Pat MAF has operate for decades and 

has not impacted commercial fisheries. Future timber purchasers 
Appendix B

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measures to clean up its mess or consider prohibiting in- water log 

storage altogether. [DEIS at 178].

Additionally, as noted in previous comments on LTFs from retired ADF & 

G habitat biologist Ben Kirkpatrick, the authorization of log rafting 

operations should include a review and replication of previous southeast 

Alaska studies. [634_0850; see also 634_0857].

It is almost certain that Alcan will utilize the LTFs because of the 

project’s design for an off-island purchaser. [634_0842 at 3-42 (Shady 

EA/FONSI)]. We thus have significant concerns about the environmental 

impacts of in-water log storage in particular. The Pats Creek LTF occurs 

in the vicinity of fishing grounds for commercial and personal use 

species including salmon, shrimp and crab. [Id.]. Over 127 MMBF was 

transferred at this LTF dating back to the 1960s, and the previous permit 

did not require monitoring. [Id.]. The Earl West LTF was constructed in 

the early 1980s and roughly 30 MMBF of timber has been transferred 

through it, and there are no monitoring requirements, no information 

available on marine life, or the biological productivity and diversity of the 

area. [Id. at 3-43]. This project could likely involve higher timber volume 

transfers through these LTFs at a more intensive rate than past use, 

heightening our concerns about adverse environmental impacts.

The TLMP recognizes the importance of ensuring that log storage 

facilities not impair other business and recreational activities. It requires 

that the Forest Service “[a]void, where practicable, siting log transfer, 

rafting and storage facilities in areas with established commercial, 

subsistence, and sport fishing activity, high levels of recreation use, 

areas of high scenic quality, or documented concentrations of species 

commonly pursued by commercial, subsistence, and sport fishers.” 

[TLMP at 4-85]. Also, LTFs should not be located “in areas known to be 

important for fish spawning and rearing because of “the high value of the 

fisheries resources.” [TLMP, Appx. G at G-2]. We request that further 

NEPA analysis reflect new surveys to document baseline conditions, and 

specific topics identified in the following discussion.

(1) Evaluate adverse impacts to fishery resources: The existing 

LTFs overlap with important local fishing areas, creating conflicts with 

existing commercial and other fisheries. It is well known that log storage 

degrades water quality below levels necessary to protect existing 

commercial fisheries. As recognized by other resource managers and 

scientists, toxins, bark debris accumulations and the low dissolved 

oxygen levels they cause adversely impact shellfish species such as 

Dungeness crab in numerous ways, causing reproductive problems, 

disease, deformities, prey depletion.

are not known at this time. While the MAF would be available for 

their use, it would be a business decision whether to use the 

MAF or not. Any use of the MAF would comply with all State and 

Federal laws and permit conditions. Additional information of 

MAFs and marine impacts can be found in the EFH discussion of 

the Aquatics Resource Report and the BE.
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(2) Evaluate impacts to marine traffic, safety hazards, and 

interference with fishing operations: Log staging activities will disrupt a 

variety of fishing activities and create safety hazards for recreational and 

marine traffic because of the much higher log escapement rate 

associated with in-water log storage facilities. [634_0847]. Meaningful 

guidelines should also consider impacts to marine traffic in terms 

important anchorages and travel routes.

(3) Discuss and ensure adequate monitoring and mitigation: There 

should be an effort to develop and implement a pollution prevention plan 

and to prepare a proposed remediation plan. LTF monitoring 

requirements should be “site-specific and determined by such factors as 

volume, site characteristics, life of project, and type of operation, 

because these factors may determine the extent of environmental 

impacts.” [TLMP, Appx. G at G-10]. Timber operators in British Columbia 

employ site deactivation procedures in order to minimize long-term 

impacts. [634_0846; _0847]. The Washington Department of Fish and 

Wildlife recommends replanting marine vegetation and removing woody 

debris in order to mitigate LTF effects on crab. [634_0848].

061-GSACC786. The DEIS failed to disclose the external costs of logging in 

terms of lost fishery resource production

Our scoping comments requested that that the DEIS include economic 

losses in the economic analysis. In particular, the DEIS needed to 

evaluate losses associated with lost fishing revenues caused by logging 

and road construction. Habitat loss has a substantial impact on the 

commercial fisheries that are an important component of Wrangell’s 

market- based transition. It is possible to estimate the loss of salmon 

related economic values caused by logging and related road 

construction. [634_0852; _0853; _0854]. Canadian researchers in 2003 

developed habitat values (which the authors described as conservative 

estimates) that ranged from $.026 to $1.40 per acre of watershed, or 

$1,491 to $7,914 per mile of spawning stream (converted to 2003 U.S. 

dollars – or roughly $10,000 per mile of spawning stream today). 

[634_0854]. A 1988 study identified significant economic losses to 

salmon fisheries caused by logging and road construction on just 21% of 

the Siuslaw National Forest. The author noted that even “while improved 

timber harvesting practices of leaving buffer strips and use of better road 

design have reduced the extent of fisheries losses, there are still 

substantial ‘unavoidable’ losses associated with timber harvesting.” 

Another study found that “if habitat improvements resulting from salmonrelated logging restrictions generated one additional fish for the 

recreational fishery per year per acre for the foreseeable future, the 

Through alternative design and the application of BMPs and the 

Forest Plan standards and guidelines, including riparian buffers, 

only slight effects to the fisheries resource are anticipated.

The affected watersheds are in a fully functioning condition 

(National Watershed Condition Framework database, 2015). The 

external costs suggested in the comment are highly speculative 

and not appropriate for the scale of this analysis. 

Please see response to comment 061-GSACC-75.
Appendix B

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asset value of the habitat would be about $2,800 per acre” or seven 

times the forgone timber asset value of the land. [634_0855]. Similar 

significant external costs associated with the Wrangell Island project 

need to be specifically addressed in the economic analysis.

We note that this project was initially estimated to generate a mere 

$70,000 in revenue per MMBF – or $1.3 million at an estimated public 

cost of $5.9 million. [634_0832 at 3, 17]. Given this substantial loss, 

further NEPA analysis needs to consider whether economic benefits –

for example, fixing fish passage problems as explained in the following 

section – would better meet local and regional economic objectives.

061-GSACC797. Best available information should be applied to aquatic issues, 

and data quality should be addressed explicitly.

Please consider and disclose the quality of information that is being 

used, especially with regard to road condition. The DEIS says that 

district-wide RCS with GIS were used to generate road and stream data, 

and that field surveys were done. Both datasets tend to be very 

incomplete and have varying levels of reliability. When we visited the 

island last week culvert replacements were actively being done, so 

obviously this situation is dynamic. It would stand to reason too that if 

culvert replacements are being done that better site-specific and 

aggregate information regarding road condition and culverts is available 

to the agency.

Data for roads and watersheds are contained in the Watershed 

Improvement Tracking (WIT) and Infrastructure (INFRA) 

databases, which are updated regularly. The active culvert 

replacement observed by the commenter on Wrangell Island was 

performed by the Wrangell Cooperative Association (local tribal 

organization) under project agreement number #13-RO11100522-520. The replacements are of non-fish bearing and 

cross-drain culverts as part of a multi-year maintenance 

agreement.

The review of IDT meeting notes suggest watershed issues were given 

unsteady attention and we are concerned that there may be data gaps. 

For example, in April of 2014 the team had no hydrology data and there 

was substantial watershed work to be done. Only a month later, on May 

17, 2014, the hydrology work on “99%” done. The aquatic resource 

report was apparently done prior to some changes in project design and 

alternatives, making the data and the report’s conclusions unreliable.

All analyses for the Aquatics Resource Report used in the DEIS 

were conducted in FY15 using the most current methods and 

data.

061-GSACC808. Please take a hard look at sedimentation and peak flow impacts 

to stream channels and fish habitat

The DEIS says it uses only two measures are used related to sediment: 

the percentage of the basin that is road, and the number of new Class I 

and II stream crossings. [DEIS at 158]. With regard to streamflow the 

DEIS uses percentage change, per Grant (2008). [Id.]

Please clarify what units of measure the decision-maker is actually going 

to apply to the decision. In various places the actual analysis uses 

different measures (e.g. percentage of basin logged; logged riparian 

habitat, etc.). The limited units of measure applied in the EIS fail to 

reasonably capture the issues involved and omit many critical factors.

The DEIS and Aquatics Resource Report discussion 

acknowledges and addresses the effects of roads on water 

quality, streamflow, and watershed condition. All roads continue 

to have some effects, even when stored or decommissioned. 

This is why all roads are considered in the affected environment 

and cumulative effects. Refer to the “Water Quality” section of 

the Aquatics Resource Report for discussions that link the 

effects of extended stream networks to road-generated 

sediment, road connectivity to streams, and road density. Road 

effects on streamflow are considered in the Streamflow sections.
BAppendix

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For instance, the DEIS entirely fails to consider impacts of sediment and 

increase peak flow on channel condition. Sedimentation is not only a 

water quality issue, it is also (primarily, in fact) a problem of stream 

channel structure and fish habitat. The DEIS indicates that sediment is 

not a very bad water quality issue because additional sediment would be 

deposited in pulses and would tend to rapidly drop out of the water 

column. If additional sediment is not in the water column, however, then 

that means it is now on the bed of the stream. Depending on site-specific 

channel type and channel condition that sreambed sediment can have 

major effects by filling pools used for rearing, and gravels used for 

spawning. Added streambed sediment that fills pools also tends to make 

streams shallower and wider (especially where LWD is deficient, as is 

the case in most area watersheds), which compounds stream 

temperature impacts of direct sunlight. See D-69 (Rhodes Declaration).

Additionally, the DEIS fails to adequately consider sedimentation impacts 

from roads, quarries and landings. The DEIS analysis of road crossing 

impacts to sedimentation effects is incomplete. [DEIS at 168]. The DEIS 

and aquatic resource report erroneously treat the effect of road crossings 

on sediment as being related primarily to potential for culverts to block 

and roads wash out. That is only one concern. This incorrect 

understanding results in a failure to adequately seek to avoid roads that 

are located close to streams and stream crossings. The aquatic resource 

report lists roads within 300 ft of streams, and Class I – III stream 

crossings, and recognizes those things as factors for sediment. Estes at 

35 et seq. The same report shows the action alternatives increase the 

amount of road close to streams by over ten miles under action 

alternatives. Id. As explained in more detail by Dr. Rhodes (See Exhibit 

D-69), roads in proximity to streams pose problems for sediment in many 

ways, including:

● Roadside ditches increase sediment delivery to streams;

● Increased traffic on roads increases sediment generated by 

roads;

● Roads near streams result in deficiencies of LWD, making other 

impacts to aquatic habitat (e.g. temperature, peak flow, loss of pools, 

streambank erosion) that much worse;

● Road near and crossing over Class IV streams also can be 

major sources of sediment to fish habitat.

The Aquatics Resource Report cites relevant turbidity monitoring 

efforts in the Tongass National Forest (e.g. Thompson 2002, 

Tucker and Thompson 2010). Based on these data temporary, 

localized increases in turbidity (and sediment) are 

acknowledged, but are expected to be similar to what occurs 

during storms and return to natural conditions within a couple of 

days. Effects of roads on resources are reduced through 

application of Forest Plan standards and guidelines and BMPs. 

The methods used for erosion control and prevention of 

sediment delivery to water bodies including road storage and 

decommissioning, as outlined in the Forest Plan standards and 

guidelines, is incorporated in the Aquatics Resource Report and 

the EIS.

061-GSACC819. Cumulative and synchronistic watershed impacts need to be 

considered

With regard to cumulative effects especially, the long-term harm caused 

by logging to aquatic habitat needs to be considered in a more holistic 

The literature cited in the “Aquatics” section of the DEIS and in 

the Aquatic Resource Report documents the effects of timber 

harvest and road building on various parameters related to 

hydrology and fisheries resources. Most studies referenced 
Appendix B

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fashion. A watershed analysis should be conducted on each of the 

impact watersheds at the appropriate scale, and that information should 

be used to help guide the decision.

A particular failure of the chose piece-meal approach is that 

synchronistic and cumulative effects to habitat are lost. Woody debris 

deficiencies, sediment, temperature, peak flow, and fish passage are 

treated separately. The best available watershed science however is to 

consider these effects as a whole as they relate to site-specific 

watersheds and stream reaches.

One critical factor, particularly where riparian areas have been logged, 

are declines in large woody debris. This effect is very long-term; on the 

order of centuries even where logged areas are thereafter protected. 

Shortages of LWD have cascading impacts on watersheds. The impact 

of sedimentation is compounded in systems where LWD is deficient, for 

example, because channels lose sediment storage capacity. Stream 

temperature impacts are compounded by the resulting loss of deeper 

pools. Impacts from increased peak flow such as scouring and erosion 

tend to be more pronounced where LWD is deficient. The problem of 

LWD deficiencies is not solved by TLMP and TTRA buffers for Class III 

and IV streams. These factors are well known to hydrologists and 

fisheries biologists, so it is perplexing why that information is not carried 

through to the EIS analysis. The aquatic resource report for example 

says:

Large woody debris in stream channels plays an important role in 

physical and biological processes by influencing channel width and 

meander patterns, trapping organic matter, providing storage for 

sediment and bedload, and forming pools used by fish and aquatic 

insects for cover (May and Gresswell, 2003; Gomi et al., 2001; Bilby, 

1984; Ralph et al., 1994; Beechie and Sibley, 1997). ... All of the large, 

anadromous streams contain many LWD dependant channels. These 

are typically low gradient, gravel bed channels typical of floodplain (FP) 

and moderate-gradient mixed control (MM) process groups.

Stream habitat complexity depends on a continuous supply of large 

wood from conifer riparian forests.

[Endres 2016 at 27]. Given that is the case, these important factors now 

should be applied to the watersheds.

occurred in the Pacific Northwest or British Columbia, Canada, 

due to regional similarities in climate, physical and biological 

conditions, and harvest histories. In addition to citing the most 

relevant studies for the proposed project, watersheds within the 

project area were analyzed in some detail in the DEIS and 

Aquatics Resource Report. The DEIS provides direct, indirect, 

and cumulative effects of the proposed activities using 

quantifiable measures.

The Forest Plan (appendix C) does not require watershed 

analysis unless Riparian standards and guidelines are modified 

or public water supply is involved. Nevertheless, a field-based 

and GIS assessment was completed and the EIS presents a 

thorough effects analysis. The application of BMPs and 

standards and guidelines during layout, implementation, and 

maintenance would maintain water quality and limit in-stream 

impacts for all alternatives. 

Riparian no-harvest buffers (RMA), along with reasonable 

assurance windfirmness (RAW) buffers, along Class I, II, and III 

streams, would minimize erosion and sediment transport to 

streams and maintain cool stream temperatures (Gomi et al. 

2006). Although Class IV streams within harvest units do not 

receive buffers, disturbance would be minimized through BMPs. 

Site-specific stream buffers are described in the unit and road 

cards. Special attention is given to verification of fish streams 

and upper limits of fish habitat as depicted on unit cards and 

updated during sale preparation as needed. Additional 

documentation of field surveys is available in the project record. 

This would avoid compromising spawning and rearing habitat 

which supports anadromous and resident fish populations. All 

watersheds are expected to continue to support anadromous 

and resident fish populations and maintain water quality into the 

future, regardless of which alternative is selected.

All field data collected was available in a reasonable time frame 

to completely analyze for effects to watersheds and aquatic 

habitat for the DEIS. We agree that we must use the best 

information we have at the time, and the FEIS and Aquatics 

Resource Report have been updated to reflect any new 

information collected.
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061-GSACC82VI. Comments on Silviculture and Plant Resource Sections

A. Comments on Yellow Cedar Decline

We request that further NEPA analysis be done for the WIP project, to: 

provide a more thorough discussion of the high-grading of red and yellow 

cedar; consider yellow cedar decline and climate change; and provide 

information about regeneration in logged areas. Overall, well over onefourth of the sawlog volume from the selected alternative consists of 

Alaska yellow cedar and western red cedar, including 10.4 MMBF of 

yellow cedar. [DEIS at 66]. The 2008 TLMP Amendment FEIS 

recognizes that cedar decline is “one of the most widespread and 

important forest problems on the Tongass,” making it critical to provide 

detailed NEPA analysis. [TLMP FEIS at 3-120]. We recognize that 

agency scientists are actively engaged in research on these topics. For 

these reasons, we hoped that the DEIS would provide a more thorough 

analysis and include alternatives that avoid healthy yellow cedar stands. 

The DEIS references the latest research effort, [DEIS at 218], but fails to 

disclose its recommendations even though the report breaks down the 

cedar decline issue into 33 management zones – a scale that would 

allow for meaningful analysis of impacts on Wrangell Island. Further 

analysis should address the following concerns:

1. Cumulative Effects of climate change: Further NEPA analysis 

should revisit projected climate change impacts on yellow cedar through 

a more thorough discussion and literature review. There are roughly 

500,000 acres of cedar decline across the forest, and nearly 13,000 

acres with cedar decline on Wrangell Island alone. [DEIS at 218]. 

Scientists project a 75% decline in the frequency of the species over the 

next century due to climate change alone. [Hamman and Wang 2006]. 

As explained in our recent petition for listing the species under the 

Endangered Species Act, yellow cedar is in danger of extinction 

throughout all or a significant portion of its range, and further NEPA 

analysis should disclose and discuss this risk, particularly in light of the 

large amount of healthy yellow cedar stands proposed for logging as part 

of this project.

Please see the yellow-cedar discussion in the “Silviculture” 

section of chapter 3 of the EIS, in the Silviculture Resource 

Report and in the silvicultural prescriptions.

Yellow-cedar decline has been studied extensively and more 

study continues (Hennon et al. 2016). The petition to list yellowcedar under the Endangered Species Act is currently under 

review by the US Fish and Wildlife Service. Yellow-cedar decline 

has been used as an example of how changing climate can 

impact a tree species. A recent publication that indicates yellowcedar is not decreasing in Alaska has been added to the project 

record. 

The Wrangell Ranger District has recorded substantial yellowcedar regeneration in many stands across Wrangell Island and 

continues to collect this data as part of the larger data set 

included in the Strategy publication (Table 58 – Young-growth 

forest stands on Tongass National Forest land that are known to 

contain a regenerated yellow-cedar component, p. 372).

The yellow-cedar volume displayed in the DEIS is in proportion 

to the species composition collected from stand exams. The 

proposed action (Alternative 2) displays the yellow-cedar volume 

at 10.4 MMBF in the DEIS, which is 18 percent of that 

alternative’s total sawlog volume of 57.7 MMBF. The yellowcedar composition for the unit pool, collected from stand exams, 

is 17 percent.

Your comment suggests further NEPA analysis is needed on the 

projected climate change impacts on yellow-cedar through a 

more thorough discussion and literature review. This is not 

necessary because the Strategy publication has already done 

this (see Section 4 for model results that describe future risk of 

forest decline to yellow-cedar forests throughout Alaska). 

The Wrangell Island Project does not propose to harvest a large 

amount of healthy yellow-cedar stands.

061-GSACC832. Direct Effects of Logging and Red and Yellow Cedar Highgrading: The NEPA analysis should disclose or evaluate the extent to 

which project alternatives are high-grading both cedar species at multiple 

See discussions on cedar in the “Silviculture” section of chapter

3 of the EIS and the Silviculture Resource Report.
Appendix B

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scales. As previously noted, this project entails the removal of a 

disproportionate amount of cedar relative to its prevalence across the 

Tongass National Forest. The Forest Service has high-graded both 

cedar species on a geographic scale because timber harvest primarily 

occurs on southern Alexander Archipelago island ecosystems where 

there is higher percentage of both cedar species. [Exh. D-87 (Wilson 

2002)]. At the project level, the Forest Service then further high-grades 

both cedar species at a finer scale by selecting project areas with higher 

than average cedar components, or designating the removal of a greater 

proportion of cedar than occurs naturally within a project area in order to 

address timber sale economics. [Id.].

The project prescriptions are not prescriptions for high grading; 

see response to comment 061-GSACC-29. The project does not 

propose to harvest cedar disproportionately to its prevalence in 

the analysis area. The project does not high grade cedar. 

In the project area, the Mixed Conifer forest type is typically 

where both cedars are major components, but both cedars are 

also minor components in the other forest types. This is 

especially true for yellow-cedar in the project area. The redcedar 

component is minor in all forest types across the project unit 

pool. The cedar sawlog volume the proposed action would 

harvest is approximately 26 percent of the total sawlog volume 

for the alternative. This volume estimate is based on clearcut 

acres and 33 percent basal area removal from partial-cut acres. 

061-GSACC843. Cumulative and Indirect Effects of Logging: Further NEPA 

analysis should discuss the cumulative impacts of logging and cedar 

decline and disclose indirect effects of logging yellow cedar. For 

example, the DEIS should also discuss how logging can exacerbate

cedar decline by creating canopy gaps that exacerbate the freeze/thaw 

cycle responsible for yellow-cedar decline by creating conditions that 

cause more extreme temperature fluctuations. [Exh. D-21 (D’Amore & 

Hennon 2006)]. It should also consider whether logging healthy yellow 

cedar stands will reduce genetic diversity and further fragment the 

landscape, hindering yellow cedar adaptation and migration to suitable 

areas. [Exh. D-12 (Bunnell and Kremsater 2012)].

The cumulative and indirect effects on yellow-cedar are 

described in the “Silviculture” section of chapter 3 of the EIS and 

the Silviculture Resource Report. Aerial surveys have mapped 

nearly 13,000 acres of decline on Wrangell Island. The large 

acreage of affected forests coupled with the slow deterioration of 

yellow-cedar snags suggests an opportunity to shift some of the 

yellow-cedar timber production from healthy forests to declineaffected forests on lands that are actively managed (Hennon et 

al. 2016).

Gap dynamics are a natural process of old-growth forest 

ecology.

The preliminary results on the broad-scale genetic structure of 

yellow-cedar suggest remarkably mixed genetics, high gene 

flow, and little genetic differentiation for the species throughout 

Alaska. There are no known rare or unique genetic populations 

that need to be preserved by seed collection, tissue 

preservation, or tree culturing as a form of genetic ex situ 

conservation, even in the areas where seed has not been 

collected (Hennon et al. 2016). Quantitative genetic studies and 

molecular genetic studies paint a picture of yellow-cedar as a 

generalist species that has responded to historical climate 

change and heterogeneous environments with phenotypic 
BAppendix

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plasticity and frequent migration, as opposed to local adaptation 

(Hennon et al. 2016).

061-GSACC854. Regeneration and species diversity: The 2008 TLMP 

amendment requires the Forest Service to monitor forest health and 

evaluate silvicultural prescriptions in light of future stand diversity, 

particularly overstory species such as yellow cedar. [2008 TLMP at 4-70-

4-71, 4-14]. The analysis in the DEIS fails to analyze yellow cedar 

regeneration in any meaningful way. Past regeneration surveys across 

the region strongly suggest that this project will convert substantial 

acreage from cedar forests to low-value hemlock forests and further 

NEPA analysis should revisit the conclusion in the DEIS and disclose 

likely changes in post-harvest species composition. In particular, further 

NEPA analysis needs to more clearly identify barriers to regeneration 

and discuss any recent research. What is the regeneration rate of 

yellow cedar versus other species in the project area? Have there been 

any additional considerations with regard to whether the experimental 

method of using leave trees has been successful? Is natural 

regeneration so poor that mitigating measures will be necessary? Is deer 

browse having the same dramatic effect on cedar regeneration as it does 

in northern British Columbia islands? [Exh. D-76 (Stroh et al. 2008)].

Please see response to comment 061-GSACC-83

Yellow-cedar regeneration is discussed in the “Silviculture”

section of chapter 3 of the EIS and the Silviculture Resource 

Report. Yellow-cedar would continue to be present after harvest 

in all stands in which it presently occurs. 

Many previously harvested stands in the project area have 

regenerated with a significant component of yellow-cedar. The 

district has compiled a “working list” of stands recording yellowcedar regeneration and is collecting this data as part of the 

Strategy data set. 

In addition, the district tree thinning program emphasizes the 

retention of yellow-cedar by selecting the species as the 

preferred crop tree. Porcupines are abundant in the project area 

and do considerable damage to spruce and hemlock young 

growth, but do not feed on cedar. Preference for yellow-cedar in 

thinning contracts has been a common practice on the Tongass 

National Forest for more than a decade (Hennon et al. 2016).

Stands proposed for harvest in this project would be monitored 

following treatment with regeneration surveys to verify stocking 

levels and that species diversity, particularly the yellow-cedar 

component, is maintained. Any subsequent treatments, such as 

pre-commercial thinning, would also promote the cedar 

component.

To date, deer browse has not been noted as a concern on cedar 

regeneration in the project area. 

061-GSACC865. Mitigation Measures: Because of the forest-wide significance of 

this issue and because of the extent of cedar decline in the project area, 

further NEPA analysis should include alternatives that avoid taking 

healthy yellow cedar stands. The DEIS should also provide a description 

of specific cutting units for alternatives that do involve taking yellow 

cedar and particularly consider whether cutting units occur in areas of 

adequate soil drainage where cedar decline is less likely to occur. For 

example, the DEIS discloses that 60 percent of the units had low or no 

cedar decline, [DEIS at 218], but the fails to disclose the volume and 

See responses to comments 061-GSACC-82, -83, -84, -85, the 

“Silviculture” section of chapter 3 of the EIS and the Silviculture 

Resource Report.

The scientific data and information currently available on cedar 

decline does not indicate a degree of cedar decline which would 

suggest avoiding harvest of yellow-cedar. 
Appendix B

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Comment 

Number Comment Response

extent of yellow cedar removals in those units or describe site 

characteristics.

The “Silviculture” section of chapter 3 of the EIS provides the 

current available information on yellow-cedar decline. Each unit 

was rated based on the percentage of the unit affected by 

yellow-cedar decline. The FEIS lists specific units for each 

alternative. The silvicultural prescription describes timber to be 

removed. The volumes by species are based on a per acre basis 

from the coarse stand exam inventory data. 

Site and stand characteristics are described in the “Affected 

Environment” subsection of the “Silviculture” section of chapter 3 

of the FEIS. Specific unit site and stand characteristics are 

contained in the stand diagnosis portion of the silvicultural 

prescription, located in the project record. 

061-GSACC87B. Comments on the Sensitive Plants Resource Chapter: Further 

NEPA Analysis Needs to Revisit Conclusions about Impacts to PLOR 4

The DEIS indicates that 11 occurrences of the lesser roundleaved orchid 

(PLOR4) in the project area. [DEIS at 187]. Timber extraction and related 

activities increase risks to the viability of PLOR4, particularly in light of 

the relatively small number of plants and the species’ concentration in 

the southern Alexander Archipelago island ecosystems. [634_0340 at 17 

(Dillman 2008, PLOR4 conservation assessment)]. The northernmost 

occurrences of PLOR4 are within the Wrangell Ranger District. [Id. at 5-

6]. The proposed action would remove 2,050 of suitable PLOR4 habitat. 

In general, we are concerned that project impacts to PLOR4 are 

inconsistent with TLMP goals and objectives for sensitive species and 

their habitats and for maintaining viable plant communities and 

populations. [TLMP at 2-1, 2-5]. We request that further NEPA analysis 

address the following concerns:

1. Clarify number of affected plants, populations and suitable 

habitat: The DEIS identifies low to moderate impacts on PLOR4 

populations. [DEIS at 190]. Neither the DEIS nor the relevant resource 

report indicate where the known occurrences were observed, or where 

suitable habitat exists. In general, PLOR4 associates with medium to 

high volume old-growth hemlock-red cedar forest types which are heavily 

targeted for timber extraction in this project. [634_0340 at 15]. Ensuring 

the long-term persistence of the species requires not just protection of 

known plants, but also areas of potential suitable habitat. [Id.; Exec. 

Summary]. There is also considerable uncertainty about the abundance 

and distribution of the species and the validity of survey data. [Exh. D-75 

at 7 (Stensvold 2006)]. The sensitive plant biological evaluation indicates 

Information on PLOR4 is in updated the “Plants: Sensitive and 

Rare” section of chapter 3 of the EIS and the Sensitive and Rare 

Plants Resource Report. The analysis complies with the policy 

and direction of the Forest Plan.

Tongass Forest Plan standards and guidelines for sensitive 

plants were followed during the design of timber harvest units 

and new road corridors. As a result, no known PLOR4 actual 

occurrences are located in areas that could be directly or 

indirectly affected by project activities under any project 

alternative. There would be no impacts to known PLOR4 

populations under any project alternative. 

The locations of known PLOR4 occurrences and suitable habitat 

in relation to the locations proposed activities are discussed in 

the sensitive plant biological evaluation and FEIS. The eleven 

specific occurrences of PLOR4 in the analysis area represent 

known sightings and do not represent defined populations (in 

accordance with the formal definition of population). The March 

2015 mapping conducted by the Alaska Natural Heritage 

Program, indicates that the 11 known occurrences of the lesser 

round-leaved orchid occupy two distinct populations within the 

project area. This represents about 3 percent of the known 

populations within the Tongass National Forest.

Specific locations of actual PLOR4 occurrences are not 

identified in order to protect these sensitive plants. 
BAppendix

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that recent survey efforts were limited to 128 acres within the timber 

harvest pool, and 448 acres within the project area overall. [634_0334 at 

4 (Biological Evaluation For Sensitive Plants)]. Further work on the EIS 

should include a map displaying known locations and suitable habitat so 

that the public can review where timber units contain suitable habitat, 

and where the known occurrences are in relation to proposed cutting 

units.

The analysis followed Forest Service policy which is to “analyze, 

if impact cannot be avoided, the significance of potential adverse 

effects on the population or its habitat within the area of concern 

and on the species as a whole” (FSM 2670). Because no 

impacts to any known occurrence of this plant would occur, 

avoidance would be possible.

The analysis is based on data obtained during field 

reconnaissance for sensitive plant occurrences and their 

associated populations. The habitat analysis includes a review of 

the likelihood of sensitive plants occurring within the project area 

by reviewing the general habitat types (e.g. beaches, estuaries, 

alpine areas, wetlands, forest, etc.) within it using existing 

inventory data, such as timber type, wetlands, soils, geology and 

other resource mapping. The sensitive plant field surveys were 

based on this mapping and GIS and aerial photographic pre-field 

review which identified areas that had some likelihood of having 

sensitive plants presence. These areas were identified as the 

highest priority and represented the areas that were actually 

surveyed. There is not enough information or understanding of 

the small scale niche habitats of PLOR4 to meaningfully map 

these as potential suitable habitats.

Because 100 percent of the project area was not surveyed, a risk 

assessment was conducted as part of the Biological Evaluation. 

The risk assessment was used to determine possible effects to 

both known and potentially unknown populations within the 

project area. 

Because not all potential habitats were surveyed, there is a 

possibility that some unknown occurrences may exist and thus 

may be directly or indirectly affected under the action 

alternatives. Therefore, the risk assessment in the sensitive plant 

biological evaluation determined that the project may affect 

PLOR4, and that the risk of impacts is low to moderate. In order 

to further reduce the potential for impacts, the project includes 

mitigation: should any previously undiscovered sensitive plants 

be encountered in timber harvest units or road construction 

areas during implementation, the Forest Plan standards and 
Appendix B

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Comment 

Number Comment Response

guidelines designed to protect sensitive plant populations would 

apply. 

The cumulative effects analysis was conducted appropriately 

and is documented in the “Plants: Sensitive and Rare” section of 

chapter 3 of the EIS, and in the Sensitive and Rare Plants 

Resource Report.

061-GSACC882. Cumulative effects analysis needs to consider the species 

range and revisit the conclusions in the DEIS: The cumulative effects 

analysis should use the PLOR4’s range in southern Alexander 

Archipelago island ecosystems. The DEIS limited the cumulative effects 

analysis to Wrangell Island without considering the cumulative effects of 

other timber projects and impacts across the species’ range in Alaska. 

[DEIS at 191]. It concluded that action alternatives would not 

cumulatively affect species viability without fully incorporating nonfederal lands and federal projects in other portions of the species’ limited 

range. [DEIS at 192].

Revilla provides habitat for a substantial portion of known PLOR4 

populations in Alaska. [634_0340 at 9]. There are 71 known populations 

on Revillagigedo Island and only 291 across the Forest. [Saddle Lakes 

FEIS at 3-303]. Nearly all of the known occurrences in federally 

managed public lands are in areas managed for timber extraction. 

[634_0340 at 16 (Cons. Assessment for PLOR4)]. As explained in a 

recent letter from EarthJustice to Forest Supervisor Cole, Forest Service 

employees have concluded that the Big Thorne Project alone would be 

“likely result in a loss of viability in the [Big Thorne] Planning Area, or in a 

trend toward federal listing.” [Exh. D-26 (EarthJustice letter to Cole, on 

PLOR4, 2014]. If the Big Thorne Project was believed to have such a 

result, it is hard to see how the Wrangell Island Project could do anything 

other than add to this risk given the species limited range and numbers 

and the plans for further logging on Revilla. Further NEPA analysis 

should disclose and respond to the materials from the Big Thorne 

planning record. [Exhs. D-36; D-37 (Greenpeace analysis of PLOR4 

decisionmaking for Big Thorne, and documentation)].

Wrangell Island was appropriately used as the geographic area 

in estimating the cumulative effects from the project on sensitive 

plants, including PLOR4. Wrangell Island provides an ecological 

basis because of its geographic isolation from nearby land 

masses by open sea passages which would make biological 

interactions with other PLOR4 occurrences on the Tongass 

National Forest unlikely. It is also consistent with direction in the 

Tongass National Forest Guidance for Sensitive Plant Biological 

Evaluations (Dillman et al. 2009). For Forest-level planning, the 

analysis area for sensitive plant species would be the species 

range within the Tongass National Forest, and would therefore 

include all biological populations existing in whole or in part of 

the plan area. However, the analysis area for individual projects, 

such as the Wrangell Island Project, do not require an evaluation 

for the entire Forest. 

A recent assessment of PLOR4 (USDA Forest Service 2015) 

provides updated information (e.g. more recent than the cited 

2008 PLOR4 Conservation Assessment) regarding the known 

occurrences in federally managed public lands which are in 

areas managed for timber extraction. This information has been 

included in chapter 3 of the FEIS. 

Of the total area occupied by the 61 known populations 

throughout the Tongass, 44 percent are located within nondevelopment LUDs where timber harvest in not planned and 56 

percent are located within development LUDs (USDA Forest 

Service 2015). The old-growth conservation strategy provides for 

large reserves of old-growth habitat, in particular within the Nondevelopment LUDs; resulting in conservation of at least 40 

percent of the known populations of lesser round-leaved orchid 

and their associated habitat across the Forest. On Wrangell 

Island, two populations of PLOR4 are known to exist, 
BAppendix

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Comment 

Number Comment Response

representing about 3 percent of the populations within National 

Forest System lands on the Tongass National Forest.

The Big Thorne and Saddle Lakes projects are located on distant 

islands, and are outside the cumulative effects analysis area for 

this project. Therefore the impacts to PLOR4 from these projects 

are not included in the analysis. The final sensitive plant 

biological evaluations for both the Big Thorne and Saddle Lakes 

projects both determined the effects to PLOR4 from all action 

alternatives as: "May adversely impact individuals, but is not 

likely to result in a loss of viability in the Planning Area, nor 

cause a trend toward federal listing." 

061-GSACC893. TLMP Standards and Guidelines: The TLMP requires the 

Forest Service to consider protection measures for sensitive plants, 

including partial retention of forest structure. [TLMP at 4-41]. Although 

the DEIS lack clarity on the relationship between specific units and 

identified suitable habitat, it appears that We note that action alternatives 

would include clearcutting of units with known PLOR4 suitable habitat. 

[See, e.g. DEIS at 190]. We believe that all units with PLOR4 

populations or suitable habitat should be eliminated from further 

consideration. However, at a minimum, the Forest Service should ensure 

that no clearcutting occurs in suitable habitat, and design affected units 

with partial removal prescriptions that avoid suitable habitat.

The alternative designs avoid all known sensitive plant 

populations. No timber harvest or road in any alternative would 

directly or indirectly impact any known PLOR4 populations. 

Because potential suitable habitat does not necessarily indicate 

presence of sensitive plants and is only an indication of the 

possibility they may occur, the project includes mitigation that if 

any previously undiscovered sensitive plants are encountered in 

timber harvest units or road construction areas during 

implementation of the project, Tongass Forest Plan standards 

and guidelines that are designed to protect sensitive plants 

would be applied.

061-GSACC904. Indirect and cumulative effects – climate change and indirect 

logging impacts: The climate change section in the DEIS is limited to a 

brief discussion of cedar decline and greenhouse gas emissions and 

does not discuss how climate change will affect other forest resources in 

any meaningful way. The cumulative effects analysis should provide a 

more thorough discussion about risks to PLOR4 associated with 

changes in solar radiation and hydrologic regimes and climate change. 

[634_0340 at 17]. The failure to include climate change in the cumulative 

effects analysis for this species was a major omission.

Indirect and cumulative effects are included in the “Plants: 

Sensitive and Rare” and “Air Quality and Climate Change”

sections of chapter 3 of the EIS, as well as the Rare Plants and 

Air Quality and Climate Change Resource Reports. Additional 

content was added to the sensitive plant cumulative effects 

discussion in the FEIS regarding climate change.

There is substantial uncertainty regarding the response of 

PLOR4 to climate change, and no research on this topic is 

currently available. No timber harvest or road in any alternative 

would directly or indirectly impact any known PLOR4 

populations. Therefore, the ability of this species to respond to 

climate change due to this project would likely not differ 

substantially from the existing condition. 

061-GSACC91C. Comments on Silvicultural Prescriptions

Previous entries have clearcut large blocks of forest – nearly 6,800 

acres, [DEIS at 224], to the detriment of old-growth dependent species 

The reasons for clearcutting are described in the EIS and the 

Silviculture Resource Report. The amount of previous harvest 

and remaining unharvested are provided in table 3 of the 
Appendix B

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and salmon runs. According to the Silviculture resource report (p. 7), a 

disproportionate amount of these clearcuts occurred in low elevation, 

high volume POG. Further NEPA analysis should consider the following 

concerns:

1. Justification for clearcutting: The justification for clearcutting in 

the DEIS reflected an emphasis on increasing stand volume for further 

entries and timber economics and arbitrarily failed to demonstrate 

consideration of other forest resources. Clearcuts are only acceptable “in 

exceptional circumstances” and when these exceptional circumstances 

exist, the Forest Service must closely examine effects on other forest 

resources. [Sierra Club v. Thomas, 105 F.3d 248, 251 (6th Cir. 1998); 

Ohio Forestry Ass’n v. Sierra Club, 523 U.S. 726 (1998)]. The NFMA 

requires that clearcuts occur “in a manner consistent with the protection

of soil, watershed, fish, wildlife, recreation, esthetic resources, and the 

regeneration of the timber resource.” 16 U.S.C. § 1604(g)(3)(F)(i)(v). The 

TLMP also recognizes that clearcutting should be limited only where 

“essential” and requires that prescriptions consider multiple resource 

objectives such as biological diversity and scenic integrity. [TLMP at 4-

71-4-72]. However, the justification provided in the DEIS relied primarily 

on considerations related to factors related to the commercial viability of 

the stands such as hemlock dwarf mistletoe. The DEIS needs to revisit 

the justification for clearcut prescriptions by incorporating the requisite 

consideration of other environmental values, particularly as described in 

our comments pertaining to wildlife and aquatic habitat. We would note, 

in particular, based on our review of the unit cards, that there are several 

clearcut units placed adjacent to very recent clearcuts from 2011 and 

2012, creating larger areas that will enter the stem exclusion phase 

concurrently. Further design should eliminate these units, or at least 

provide for lighter touch prescriptions.

Silviculture Resource Report. The application of clearcutting as 

proposed in the alternatives complies with NFMA and the Forest 

Plan. 

Units proposed for clearcutting underwent an inter-disciplinary 

review process to evaluate resource concerns. In some units, 

resource concerns were significant enough to change the 

prescription from clearcut to partial-cut, or defer the unit, or a 

portion of the unit. For some units, different prescriptions are 

proposed across alternatives to achieve different management 

objectives. National Forest Management Act requirements, 

particularly harvest acreage adjacency limits, are met.

Clearcutting is prescribed for all harvest units where there are no 

other conflicting resource issues to preclude or minimize the 

occurrence of potentially adverse impacts from hemlock dwarf 

mistletoe, other insect and disease infestations, logging system 

damage, and windthrow. Clearcutting would also minimize 

windthrow potential in the residual stands. Clearcutting 

maximizes the use of conventional yarding systems (cable and 

shovel), which maintains the potential for an economic timber 

sale offering. The objectives of clearcutting include growing the 

stand to maximize wood-fiber production in the shortest 

timeframe and to provide favorable timber sale economics and 

logging feasibility. Natural regeneration in these stands is 

expected to be abundant, and would represent the original 

species composition with trees of a single age. Even-aged 

systems (clearcutting), as part of this project, are integral for the 

long-term stability of the Forest’s timber program transitioning to 

an industry based on young growth.

061-GSACC922. Steep slope logging: The Forest Plan removed slope gradients 

of 72% or more from the timber base because of high risks but leaves an 

exception for approval of steeper slope logging on a case-by-case basis. 

[TLMP at 4-65]. The DEIS disclosed that action alternatives will include 

268 acres of steep slope logging and 1.34 miles of road on steep slopes, 

but it failed to provide detailed analysis. Studies show that it is difficult to 

assess landslide risks and that even partial cut helicopter harvests does 

not eliminate these risks, particularly at higher elevations. [Swanston 

2006]. We request that you observe the recommendations of leading 

scientists and the EPA and “[p]rohibit harvest from slopes greater than 

72%, even if an on-site slope stability analysis has been conducted.” 

The proposed harvest units and road locations located on slopes 

steeper than 72 percent were reviewed for slope stability issues. 

Reports are included in the project record as an appendix to the 

Soils Resource Report. The evaluation process considered the 

risk of activities affecting slope stability, as well as other 

resources which could be impacted if slope failure occurred. The 

effects on soil and other resources are provided in chapter 3 of 

the EIS and in the Soils Resource Report. Additional information 

was added to the Soils section of the FEIS about downslope 

resources which could potentially be affected. Site-specific unit 

design would minimize adverse effects to soil productivity.
BAppendix

Wrangell Island Project FEIS ♦ 292

Comment 

Number Comment Response

[Navy FEIS, Appx. B at B-53]. We request that either eliminate steep 

slope logging and road construction from the project, or at a minimum 

provide a more detailed explanation of potential adverse impacts.

061-GSACC93D. Climate Change and Forest Management

The Forest Service has recognized that the challenges posed by climate 

change are “one of the most urgent tasks facing the Forest Service” and 

“as a science-based organization, [the Forest Service needs] to be 

aware of this information and to consider it any time we make a decision 

regarding resource development, technical assistance, business 

operations or any other aspect of [its] mission.”123

1. We request that further NEPA analysis consider the cumulative 

effects of logging, road construction and climate change as part of this 

analysis and uncertainties about climate change. The DEIS limited its 

discussion of climate change to brief statements about yellow cedar 

decline and greenhouse gas emissions and one page discussion of 

carbon sequestration. [DEIS at 153-155]. But it failed to assess the 

implications of the changing climate were relevant to project area 

resources and project impacts. As previously noted, it did not consider 

climate change in its cumulative effects analyses of impacts on individual 

wildlife species or watersheds. [See, e.g. DEIS at 89, 93, 96, 175]. Every 

section of the DEIS, including timber economics, should have considered 

the impacts of our changing climate. There are numerous scientifically 

credible views pertaining to climate change impacts on Alexander 

Archipelago island ecosystems and project design prescriptions should 

have reflected an extra factor of caution due to the projected changes 

and increased risks to project area fish and wildlife. In particular, the 

discussion related to the no action alternative should include the merits 

of maintaining intact forest ecosystems.

The Tongass National Forest is committed to forest protection 

and its role in mitigating global climate change, and it is also 

committed to multiple use management of forest resources. The 

cumulative effect analysis of climate change has been clarified in 

the FEIS, including the assessment of the implications of the 

changing climate where relevant to the project area resources 

and project impacts.

061-GSACC942. We appreciate that the DEIS provided a discussion about 

greenhouse gas emissions associated with the project, but think that the 

analysis overly minimized the relevance of large scale logging projects 

by putting project impacts in the context of global emissions. The Ninth 

Circuit has concluded that the “impact of greenhouse gas emissions on 

climate change is precisely the kind of cumulative impacts analysis that 

NEPA requires agencies to conduct.”124 Ctr. For Biological Diversity v. 

Nat’l Highway Traffic Safety Admin., 538 F.3d 1172, 1215 (9th. Cir. 

2008). As noted in our scoping comments, it is well-established that 

optimal carbon storage is best obtained by leaving both old and young 

growth forests intact to the greatest extent possible. Further NEPA 

analysis needs to provide a more thorough analysis of the carbon cycle 

as it relates to logging.

Comment noted. The scope and scale of the analysis are 

important in addressing effects. The climate change analysis for 

this project is appropriate for the small scale of the project. 

Leaving both old and young-growth forests intact to the greatest 

extent possible does not fulfill the multiple use management 

mandate of the USFS of forest resources or the purpose and 

need of this document.
Appendix B

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Number Comment Response

061-GSACC95VII. Maps

In our 2013 comments, we discussed the need for better and additional 

maps. Criticized the light colors, showing side-by-side the map 

presented to the public with one we recolored to make both the past and 

proposed logging units easily apparent. [634_0146, at 4-5]. We 

requested that for each alternative maps with unit boundaries overlaying 

a satellite image be added to the project webpage or in the DEIS, and 

we embedded example maps in our comments both in plan-view and 

perspective views, with unit boundaries roughly hand drawn. [Id. at 6-8]. 

In our 2015 comments we again asked for alternatives maps with vivid 

colors (like our 2013 example) and that the public be provided with KMZ 

files for each alternative, so the unit boundaries could be viewed over a 

Google Earth image.

The maps provided in the EIS have been designed to effectively 

communicate a variety of information to the public. Bold or bright 

colors are used to bring attention to proposed activity locations. 

The existing young-growth stands are effectively displayed as 

background information.

Regarding the development of KMZ files, the Forest Service 

finds this idea helpful and innovative, and will take your 

suggestion into consideration for future projects.

061-GSACC96VIII. Unit cards

We have noted a number of errors and inconsistencies on the unit cards, 

but are out of time for providing details. The unit cards need a thorough 

review, and they should include substantially more information on nontimber resources and resource concerns. If necessary, revise the format 

and type size of the text pages of the cards to provide addition room for 

this.

The unit and road cards have been revised where needed. 

061-GSACC97

(out of 

sequence in 

the letter)

The ATM EA identified planning for a separate program that would be 

used to repair the culverts. [Id. at 3-21]. What happened to that budget? 

The ATM EA disclosed a cost of $2,710,028 for fixing fish passage 

problems on the Wrangell Island road system, but noted that there is no 

maintenance budget for funding fish passage problems. [Id. at 3-60]. 

Instead, fish passage problems are merely “a factor in determining the 

cost-benefit for a road” that affects decisions whether to close or 

decommission a road. [634_0844, Appx. B at B-52]. As this project 

encompasses the entire island, we requested that the DEIS include a 

comprehensive update of the ATM and road analysis, which are now 

nearly a decade old. The DEIS should have reviewed the level of culvert 

installation and repair over the past decade and indicated the costs of 

past and future repairs and whether there are suitable funds reserved to 

ameliorate road construction impacts from this project.

Please see response to comment 061-GSACC-69.

Conducting a District-wide road analysis and ATM is beyond the 

scope of this project. Please see response to comment 061-

GSACC-66.

062-WCA WRANGELL COOPERATIVE ASSOCIATION

P.O. Box 2021 • Wrangell, Alaska 99929

Tel: (907) 874-4304 Fax: (907) 874-4305

wcatribe@gmail.com
BAppendix

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Comment 

Number Comment Response

July 14, 2016

Earl Stewart, Forest Supervisor

648 Mission Street

Federal Building

Ketchikan, AK 99901-6591

Mr. Stewart,

This letter is written on behalf of the Wrangell Cooperative Association 

(WCA) Tribal Council in regards to the Wrangell Island Project.

The Wrangell Island Project was brought to the attention of the Tribal 

Council by a tribal member, and meetings have been held in the 

Wrangell Ranger District and WCA Tribal Office with Bob Dalrymple and 

members of his staff. Mr. Dalrymple has done an admirable job 

communicating with the WCA on all pertinent USFS issues, including 

presenting all five alternatives of the Wrangell Island Project. The Tribal 

Council spoke of no objections to any of the five alternatives. Below are 

their comments:

062-WCA-01 The WCA Transportation program would appreciate the opportunity to 

not only add any new roads to their inventory, allowing for potential upkeep in the future, but to be approached before closing any roads, as 

funding may allow WCAT to fund maintenance of these roads, partially 

or fully, allowing for continued use by tribal members .

Thank you for your comment. We will continue our cooperative 

relations with the Tribe and keep you informed of any planned 

road construction or planned road closures.

062-WCA-02 The Tribe wishes to have access to roads after projects are complete 

and before any potential permanent closures. Byproduct from the 

Wrangell Island Project sale(s) could go a long ways to supply locals 

with firewood, traditional foods that were suddenly made more 

accessible, or materials for Native art, such as cedar bark for weaving.

Thank you for your comment. Your support for temporarily 

delaying road decommissioning and closure activities after 

harvest activities for subsistence and traditional uses by Tribal 

members is noted.

062-WCA-03 The WCA hopes that, when the time comes to advertise the sale, the 

USFS includes some smaller, truck-accessible sales, which would 

provide smaller, locally-owned mills an opportunity to bid.

The Wrangell Island Project would be offered in multiple sales to 

provide an opportunity for different sized operators. Please see 

response to comment 054-CBW-04.

WCA also requests to be notified when the final comment period is 

approaching. As a federally recognized Tribe we appreciate a seat at the 

table, and have a genuine interest in how our traditional lands are being 

utilized.

The WCA's mission is to support the cultural, ceremonial and 

subsistence lifestyle for all Alaskans, and to promote the safe use and 
Appendix B

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Comment 

Number Comment Response

availability of a healthy environment for present and future generations. 

The Tribe believes, that if done safely and correctly, the Wrangell Island 

Project could really benefit the local economy and make areas of the 

island more accessible to all Wrangellites.

The USFS goes above and beyond to recognize tribal governments. The 

partnership between WCA and the Wrangell Ranger District is one that 

the Tribe truly values.

Thank you for your time,

Aaron Angerman, WCA Tribal Administrator

063-EPA UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION 10

1200 Sixth Avenue, Suite 900

Seattle, WA 98101-3140

OFFICE OF ENVIRONMENTAL REVIEW AND ASSESSMENT

Robert Dalrymple, District Ranger Wrangell Ranger District

PO Box 51

Wrangell, AK 99929 Dear Mr. Dalrymple,

July 18, 2016

Thank you for the opportunity to review the Draft Environmental Impact 

Statement for the Wrangell Island Project, in southeast Alaska (EPA 

Project #11-003-AFS). We have reviewed the Draft EIS in accordance 

with our responsibilities under the National Environmental Policy Act, as 

well as Section 309 of the Clean Air Act. Section 309, independent of 

NEPA, specifically directs the EPA to review and comment in writing on 

the environmental impacts associated with all major federal actions. 

Under our policies and procedures we also evaluate the document's 

adequacy in meeting NEPA requirements. A description of our rating 

system is provided in Enclosure 2.

According to the Draft EIS, this multi-year project is being proposed for 

the purposes of timber harvest, the construction of new roads and 

landings, and the reconditioning of existing roads. It is also intended to 

update some road access management decisions on Wrangell Island in 
BAppendix

Wrangell Island Project FEIS ♦ 296

Comment 

Number Comment Response

the Tongass National Forest. Five alternatives are detailed in the Draft 

EIS, providing differing outputs and responses to issues identified 

through the scoping process for this project. The U.S. Forest Service has 

identified Alternative 2 as its preferred alternative (even- and unevenaged harvest of timber from approximately 5,309 acres of forested land, 

producing an estimated 65 million board feet (MMBF) of sawtimber and 

utility wood, 17..2 miles of new road construction, 5.8 miles of 

reconditioning and 14.9 miles of temporary road construction).

Overall, we commend the USFS for the thorough environmental analysis 

of the various impacts associated with each of the alternatives. We are 

particularly pleased with the integration of direct, indirect and cumulative 

impacts analyses, as well as the identification of impacts by issue and 

resource. The extensive use of maps, tables and figures is very 

beneficial to the reader. Descriptions of the applicable statutes and 

policies which apply to this analysis are also quite comprehensive and 

useful.

063-EPA-01 Based on our review of the Draft EIS, we have assigned a rating of EC-2 

(Environmental Concerns- Insufficient Information) to Alternative 2. This 

rating is based primarily on concerns about potential impacts to water 

quality, wildlife habitat and habitat connectivity, subsistence activities, 

and scenic qualities. Detailed information regarding these concerns is 

included in Enclosure 1.

Comment noted.

063-EPA-02 We recognize that all proposed action alternatives respond to the goals 

and objectives identified by the 2008 Tongass Land and Resource 

Management Plan, and help provide a "bridge" supply of timber to 

support local jobs and industry transition to a more sustainable wood 

product industry. While Alternative 2 does increase the opportunity for 

partial harvest using helicopter compared to the other action alternatives, 

we believe that, in general, Alternatives 3, 4 and 5 are environmentally 

preferable to Alternative 2 because these alternatives would reduce 

impacts to the various resources of concern while also meeting project 

goals. We also believe the selection of any of the action alternatives 

necessitates a clear mitigation and monitoring program employing 

adaptive management to ensure that any unanticipated impacts are 

identified in a timely manner and are properly managed. The Draft EIS 

does identify a comprehensive program of best management practices 

and associated monitoring to be employed under the proposed 

alternatives.

Environmental effects resulting from the alternatives are 

mitigated through alternative design and the use of Forest Plan 

standards and guidelines, BMPs, and other resource protection 

measures. All applicable BMPs apply to the proposed activities. 

The Forest Service BMPs are in the project record. 

Monitoring is presented in the chapter 2 “Monitoring” section.
Appendix B

Wrangell Island Project FEIS ♦ 297

Comment 

Number Comment Response

063-EPA-03 Finally, if there are particular changes anticipated in the current Tongass 

Land and Resource Management Plan Amendment which could 

substantially affect the decisions made in this EIS, we recommend that 

the FS consider delaying this project until finalization of the Tongass 

Land and Resource Management Plan (Final EIS and Draft Record of 

Decision appeal period closes August 1, 2016). We realize that the 

justification for and timing of this project is detailed in Appendix A. The 

relation between this action and the current Tongass LRMP amendment 

does not appear to be specifically addressed. We recommend that 

additional information regarding this issue be included in the Final EIS.

Again, we appreciate the opportunity to review the Draft EIS. Should you 

have any questions regarding our comments please contact Jennifer 

Curtis of my staff in Anchorage at (907) 271-6324 or by electronic mail at 

curtis.jennifer@epa.gov.

Sincerely,

Christine B. Littleton, Manager

Enviromnental Review and Sediments Management Unit

Enclosures: [not included in this table]

Comment noted. A discussion of the 2016 Forest Plan has been 

included in chapter 1 the FEIS. 

063-EPA-04 Water Quality

Each action alterative has the potential to impact various waterbodies 

and wetlands, as well as other associated aquatic resources. Impacts 

are primarily associated with road and bridge construction, placement of 

fill, and harvest activities (particularly on steep slopes). We believe that 

strict adherence to USFS BMPs is critical to minimize impacts, 

particularly to avoid sediment runoff into lakes and streams which 

support anadromous fish species. Also, if BMPs are not as effective as 

anticipated, appropriate adaptive management programs need to be in 

place to quickly adjust mitigative actions.

We also recommend that the USFS consider whether additional analysis 

may be warranted to determine if there are opportunities in the planned 

road alignment to avoid or minimize the placement of fill, especially in 

higher value wetlands. This may require on-the-ground reconnaissance 

and the completion of a wetlands functional assessment.

Best management practices are used during the implementation 

of projects in order to minimize environmental impacts. The 

careful application of BMPs is the cornerstone in minimizing 

impacts to water quality. The Tongass BMP program has 

monitoring and adaptive management components, which allow 

for modification of actions to enhance protections. The program 

evaluates the efficiency of these measures and updates and 

adapts the prescribed protections.

The BMPs are included in the project record. The Forest Service 

monitors the effectiveness of BMPs through the Forest-wide 

BMP monitoring program. A description of this monitoring can be 

found in the chapter 2 “Monitoring” section. 

063-EPA-05 Habitat and Wildlife Corridors Comment noted. Wildlife corridors are shown in figure 13 of the 

Wildlife Resource Report. 
BAppendix

Wrangell Island Project FEIS ♦ 298

Comment 

Number Comment Response

The potential for substantial impacts to habitat and habitat connectivity 

exist with each action alternative. This is a particular concern given the 

decline in suitable habitat for several species on Wrangell Island since 

intensive logging occurred in the latter part of the twentieth century. 

While many of these areas have been identified for future youth (second) 

growth harvest in the future, the loss of these areas necessitates greater 

protection of those areas where high quality habitat and corridors 

remain. As such, we recommend that the action alternatives include 

actual wildlife corridors (in addition to the currently identified productive 

old growth corridors) and that the final EIS include additional 

opportunities to avoid high quality habitat and documented corridors.

063-EPA-06 Scenic Qualities

We recognize that each alternative includes harvest prescriptions that 

meet or, many times exceed, the scenic integrity objectives identified for 

the corresponding unit. We believe there are additional opportunities to 

further minimize the harvest activity or harvest area to reduce impacts to 

the areas identified as "moderate" and "high" scenic integrity. We 

recommend that additional consideration be given to this issue and, if 

practical, be incorporated into the corresponding alternatives in the Final 

EIS.

Comment noted. Scenic quality is a key issue in the analysis. 

The alternatives were designed to meet or exceed Forest Plan 

scenic integrity objectives. 

063-EPA-07 Subsistence

We note that the Draft EIS states that "the direct effects from the 

Wrangell Island Project could affect subsistence uses of deer, black 

bear, marten, wolves, and timber, as well as the collection of firewood, 

berries and other forest products" (p. 234). Given the depressed 

economy in southeast Alaska, including the community of Wrangell and 

Thom's Place, we recommend that, in addition to the Alaska National 

Interest Land Conservation Act Section 810 analysis, the USFS consider 

additional measures to further mitigate these impacts. For example, 

relocation of species from other nearby areas may be a way to address 

any decline in population numbers and species availability.

Comment noted. Although there could be direct effects to 

subsistence resources the following determination was made 

“The potential foreseeable and cumulative effects from 

implementing of the proposed action, do not present a significant 

possibility of a significant restriction to subsistence uses of black 

bear, marten, wolf, otter, marine mammals, waterfowl, salmon, 

other finfish, marine invertebrates, timber or the collection of 

firewood, mushroom, berries and other foods themselves, but 

access to these resources would be affected. A possibility of a 

restriction may already exist for deer in the long term, and under 

all alternatives of the proposed action” (Subsistence Resource 

Report, and “Subsistence” section of chapter 3 of the FEIS).

The anticipated low level of impact to subsistence does not 

warrant the need for relocation of wildlife, which would fall under 

the jurisdiction of the ADF&G.

The alternatives are designed, along with Forest Plan standards 

and guidelines and BMPs, to minimize the impacts to wildlife. 
Appendix B

Wrangell Island Project FEIS ♦ 299

Comment 

Number Comment Response

A key component of the access management issue is access to 

subsistence resources including firewood. Alternatives 2, 3, and 

4 provide special provisions for firewood collection.

063-EPA-08 Specific Comments

Figure 2 identifies two "Non-FS Land" classifications in the key but does 

not differentiate between the two. Please correct if this is an oversight.

The map has been clarified. Figure 2 now correctly indicates the 

non-NFS land classification.

064-DK Robert Dalrymple

District Ranger

Wrangell Ranger District

P.O. Box 51

Wrangell, AK 99929

E: comments-alaska-tongass-wrangell@fs.fed.us

Re: Wrangell Island Project

Dear Mr. Dalrymple,

Thank you for the opportunity to offer comments on the Wrangell Island 

Project. The Alaska Wilderness League represents members throughout 

the country with an interest in protecting Alaska’s public lands for their 

natural and cultural values. Please accept the attached comments and 

signatures of the more than 13,000 people requesting that the Forest 

Service not pursue this project.

064-DK-01 Though the Tongass has a long history of controversy, the Alaska 

Wilderness League has supported the Forest Service’s commitment to 

transition out of old-growth logging. We are supportive of the 

commitments that the agency has made in the draft amendment to the 

Tongass Land Management Plan to shift focus away from old-growth 

clear cuts as well as the commitment to protect critical salmon habitat. 

The Wrangell Island Project is not consistent with these commitments. 

This project doubles down on clear-cut old-growth logging while opening 

the Thoms Lake VCU, recognized for its outstanding wild fish values, to 

logging, all the while failing to the provide a single alternative that 

appraises positively. We believe that this demonstrates a missed 

opportunity to support alternative opportunities for economic opportunity, 

such as tourism, fisheries and small scale timber.

Comment noted. The project will comply with the Forest Plan 

Decision in place at the time the Record of Decision for this 

project is signed. Please see Chapter 1 - Purpose and Need. 

Even though there are existing harvest units and roads in VCU 

4790, the proposed units in the Wrangell Island Project DEIS 

have been removed from the alternatives for the FEIS.

064-DK-02 Despite proposals that would have maximized long-term opportunity for 

local processors in Wrangell, the Wrangell project maintains the focus on 

Please see response to comment 051-SEACCWRC-07. Much of 

the harvest area would be designed for partial harvest. It is not 
BAppendix

Wrangell Island Project FEIS ♦ 300

Comment 

Number Comment Response

old-growth clear-cuts for an export market with a preferred alternative 

that far exceeds previous volume estimates. This continued focus on 

exporting oldgrowth will mean minimal benefits for communities at the 

expense of wildlife habitat. 

known at this time whether any timber from the project would be 

exported without domestic manufacturing. On the contrary, the 

timber volumes of the preferred alternative are substantially 

lower than previous volume estimates.

064-DK-03 The cumulative impact of logging and the accumulated succession debt 

will mean decreased winter habitat for deer, and impacts on the people 

who depend on deer.

Please see response to comment 021-LS-04. 

064-DK-04 The Wrangell Island Project would impact and jeopardize the valuable 

Thoms Lake VCU which contains two major and six minor anadromous 

fish-bearing streams. As the most productive fishery on Wrangell Island, 

Thoms Creek provides a diversity of stream, lake and estuary habitats, 

supporting an important subsistence sockeye fishery. 

VCU 4790, which contains the Thoms Creek watershed, is no 

longer available for old-growth timber production under the 2016 

Forest Plan.

064-DK-05 As recreation and tourism continue to drive the economy of Southeast 

Alaska, the Forest Service should be placing less of a focus on planning 

obsolete old-growth sales and placing a greater focus on supporting 

sustainable industries, such as fishing and tourism, which combined 

drive around $2 billion in economic activity each year. 

Comment noted. Please see response to comments 029-BHD03 and 058-SEACC-07. 

064-DK-06 Each year, more than one million people come from around the world to 

see Alaskan scenery and wildlife such as the coastal brown bear. The 

Alaska Department of Fish and Game has identified the Thoms Creek 

area as one of the best places to view bears on Wrangell Island. This 

entire watershed should be prioritized for its fish and recreation values.

Jeopardizing the recreational and tourism opportunities as well as wildlife 

and fish values for the negative economic value of this timber sale does 

not make sense for the local community, Southeast Alaska or the 

American people. We urge you to not pursue the Wrangell Island Project 

and to modify it so that it can support a healthy forest and sustainable 

economic opportunity.

Sincerely,

Dan Kirkwood

Rainforest Campaign Manager

224 Gold St.

Juneau Alaska, 99801

dan@alaskawild.org

Comment noted. VCU 4790, which contains the Thoms Creek 

watershed, is no longer available for old-growth timber 

production under the 2016 Forest Plan.

065-DO June 18, 2016
Appendix B

Wrangell Island Project FEIS ♦ 301

Comment 

Number Comment Response

Wrangell Ranger District

District Ranger Robert Dalrymple

P.O. Box 51

Wrangell, AK 99929

Re: Wrangell Island Timber Sale

Wrangell Island is our home. "Out the road" is literally our back yard. It is 

where we recreate to escape the life's stresses, to connect with nature 

and grow land stewards of the next generations. We camp, hike, fish, 

pick berries, drive, picnic, and more. Many island residents have no boat 

to get off the island. This IS their only recreation and subsistence 

opportunity.

065-DO-01 To propose a timber sale of the proposed magnitude flies in the face of 

what we cherish in this land. It was the mistake on someone's part to 

propose this sale, on this island, so close to one of the few communities 

of this area! The Forest Service fails to recognize the value of standing 

timber in the face of daunting climate change, as temperatures rise every 

year and our rain forest dries out.

Your opposition to the Wrangell Island Project is noted. The 

reasons for this project are provided in the Purpose and Need, 

chapter 1 of the FEIS, and in appendix A. A discussion of the 

project’s effects on climate change are provided in chapter 3, Air 

Quality and Climate Change. 

065-DO-02 There are not many trails and lakes in this island that are accessible. In 

particular - Long Lake is a jewel of our back yard. It is the one lake, 

surrounded by a beautiful patch of forest, with a safe trail that is doable 

for families. Along with the shelter, campfire ring and row boat, it is a day 

and overnight package unmatched on this island. To go into this pristine 

area is unthinkable and insensitive. All logging will be seen in one way or 

another. Your own resource reports state that this will change (= destroy) 

the recreation value of this and many sites on this, our home island.

Comment noted. The effects of the project on recreation sites 

are discussed in the “Recreation” section of chapter 3 of the 

FEIS.

065-DO-03 Large scale timber sales are a thing of the past. We have no big mills to 

keep running at the risk of losing wildlife, plant life, and recreation and 

subsistence opportunities. We cannot turn this into a landscape of clear 

cuts. Is this what we should teach our children? To cut down our forests, 

sell the timber overseas, at the risk of never seeing a wolf, a marten, 

only waste lands?

I could cite your own resource reports which would be redundant. Timber 

sales do not pay for themselves. Expensive helicopter logging will not 

pencil out a profit. Keep any cutting to small clear cuts. We have one 

small mill operator. Take care of the land, stay away from popular 

Comment noted.
BAppendix

Wrangell Island Project FEIS ♦ 302

Comment 

Number Comment Response

recreation sites, we don't have much. Be true stewards of the land and 

seek opportunities to improve it, not cut it to the ground.

Thank you for this opportunity to comment.

Sincerely,

Diane O’Brien

097-P1-01 In the 1980's the Sierra Club and others exposed the depredations of big 

corporations on the magnificent old growth forests in the Tongass 

National Forest of Southeast Alaska. After a long battle, the forests won. 

These forest s are now under attack by big industry, again. The Wrangell 

Island Project proposes to cut 65 million board feet of old growth. The 

island is 210 square miles in area. There is approximately 16 square 

miles of "productive' old growth forest left. The Wrangell Island Project 

proposes to cut 8 square miles of that old growth. This undermines the 

Roadless Initiative and flies in the face of common sense regarding 

Global Warming.

[This is the petition statement]

Comment noted. Please see figure 3 of the FEIS, which 

illustrates the land of Wrangell Island designated as unavailable 

for timber harvest. Inventoried roadless areas and climate 

change are addressed in chapter 3 of the EIS.

097-JM-01 After a decades long struggle to redefine itself after the collapse of the 

timber industry, Wrangell is emerging stronger than ever with the 

commercial fishing and tourism industries leading the charge. The 

potential to inflict devastating, lasting harm to both of these sustainable 

industries by destroying pristine view sheds and spawning grounds is 

very real. This plan sacrifices long-term economic health for a relatively 

small short term gain that will mostly benefit outside interests. The 

citizens of Wrangell who have remade themselves and are looking 

toward the future deserve better than this.

[James Montgomery]

Comment noted. The viewsheds and fish bearing streams would 

be protected to minimize adverse effects. Please see the 

scenery and aquatics discussions in chapter 3 of the FEIS.

097-RD-02 Tourism and recreation have more potential, less cost to tax payers, 

more income long term income to local business. more income to the 

state and better foe the environment Think long term not short term.

[Richard DeBusman]

Comment noted.

097-ZB-03 I am signing because the current preferred alternative of the USFS for 

the Wrangell Timber Sale is a disaster, both economically and 

ecologically.

[Zachary Brown]

Your opposition to Alternative 2 is noted.
Appendix B

Wrangell Island Project FEIS ♦ 303

Comment 

Number Comment Response

097-MM-04 We need to prioritize the needs of the islands small mills, who could 

provide lumber for the community for generations on what this sale will 

ship overseas as round log in a few years.

[Malena Marvin]

Comment noted. A small mill-based alternative was considered 

but eliminated. Harvesting a small amount of timber would not 

satisfactorily contribute to the Forest Service’s annual or 

planning cycle demand. In addition, access to most of the 

suitable timber on Wrangell Island would require additional road 

construction or helicopter yarding, which is generally too 

expensive for a small mill operator. The Wrangell Island Project 

would provide both large and small sales.

097-GS-05 This sale is not good for anyone. It is too small for a large investor, too 

large for small mills, and too destructive for subsistence users and 

wildlife.

[Gabe Scott]

Comment noted. Market conditions are individual timber industry 

decisions would determine the outcome of any timber sales that 

result from this project.

097-BL-06 I'm signing because it fails to ensure a consistent, long-term supply of 

economic timber to Wrangell's small mills and won't maintain Wrangell 

Island's deer population.

[Buck Lindekugel]

Comment noted. Please see “The Project Purpose and Need” 

section in chapter 1, and a discussion of deer in the 

“Subsistence” section of chapter 3 of the FEIS.

098-P2-01 I oppose the Wrangell timber sale. We should not be spending significant 

taxpayer dollars to clear-cut old-growth trees in critical Tongass salmon 

habitat. I urge you to prioritize the continued abundance of wild salmon.

[This is the petition statement]

Your opposition to the Wrangell Island Project is noted.

098-CB-02 As a resident of the Tongass National Forest (I live in Sitka), it's time to 

stop old-growth clear-cutting and move into more selective secondgrowth harvests. The second-growth harvests, which are part of the 

Tongass Transition Plan, provide more local jobs, cause less damage to 

critical fish and game habitat, and are the way we should be moving with 

our forest practices. No more old-growth clear-cuts in the Tongass.

[Charles Bingham]

Comment noted. All of the action alternatives of the Wrangell 

Island Project propose a mix of clearcut and partial harvest. 

098-JM-03 I oppose the Wrangell Timber Sale. It is a clear example of the Forest 

Service's failure as steward of the Tongass, a national treasure. 

Taxpayer dollars should not be spent to clearcut old-growth timber and 

damage salmon and wildlife habitat. Moreover, this sale--even with the 

export allowance included (which is disgusting in itself) still appraises 

negatively, meaning it legally can't be offered. So now I expect the 

Forest Service will likely seek units of timber within the sale area that 

appraise positively and offer them for sale. This is the very definition of 

high-grading. Also, the fact that this sale appraises negatively is 

evidence that the Forest Service has run out of timber.

Your opposition to the Wrangell Island Project is noted.
BAppendix

Wrangell Island Project FEIS ♦ 304

Comment 

Number Comment Response

[James Mackovjak]

098-JM-04 Instead of offering sales that don't work, or high-grading the remaining 

good stands of timber, the Forest Service needs to start focusing on the 

non-timber values of the forest: salmon habitat, carbon sequestration, 

and recreation and subsistence opportunities. The agency should also 

focus on repairing the damage done by prior logging. As former regional 

forester Dennis Bschor said to us at a hallway gathering at a Society of 

American Foresters convention in Portland, Oregon, a number of years 

ago, "Past management practices have created numerous opportunities 

for restoration projects."

[James Mackovjak]

Your comments are noted.

098-JM-05 Additionally, I notice that the Forest Service is using an outdated timber 

demand report in its attempt to justify this project. I would expect more of 

a high school student. The Wrangell Timber Sale should be cancelled.

[James Mackovjak]

Comment noted. The Wrangell Island Project analysis used the 

most current information available.

098-TE-06 The old glory days for the timber industry are over. It's past due to make 

the transition to small scale value added timber harvesting.

[Thomas Ely]

Comment noted.

098-AT-07 I am a taxpayer. Please stop selling my share of the forests, the wild 

lands, the national parks, and the resources, in this case, salmon, from 

being sold. We live in a transforming world, with accelerating climate 

change. We need every inch, every foot, every acre of land left 

undeveloped. These lands are the lungs of our earth, the diverse 

ecologies maintain a sustainable working infrastructure from breathable 

air to restoring aquifers, to clean waters. We are, we have moved into an 

age of alternative materials, of redevelopment not new development, of 

reclamation not continued consumption of rapidly dwindling resources. 

Companies and corporations need to adapt. We in the United States 

need to stop selling our heritage and our legacy for the future to a 

transient sale of our land. STOP THIS SALE.

[Anne Terry]

Comment noted. Alternative 1, the no action alternative, 

proposes no timber harvest. 

098-JW-08 These logs will be shipped overseas, and hence won't even have the 

advantage of providing jobs for Americans. The fishing industry does 

provide lots of U.S. jobs, and brings in much money besides. It makes 

sense to give priority to the salmon industry over logging in this case.

[Jessie Weil]

The Regional Forester must approve the export policy for any 

timber harvest contract before logs are shipped out of the State 

of Alaska. The current export policy does not allow all logs to be 

exported unless approved by the Regional Forester on a caseby-case basis, as requested by the purchaser, and follows the 

timber contract and Forest Service handbook direction, R10 

supplement to FSH 2409.15, section 29. More information on the 

export policy is also in the 2016 Forest Plan Amendment FEIS, 
Appendix B

Wrangell Island Project FEIS ♦ 305

Comment 

Number Comment Response

Appendix H, pages H-3 through H-6 and Appendix I, pages I-168 

through I-170.

This project would have minimal effect to Essential Fish Habitat.

098-BM-09 Not just the salmon, the planet. We must begin seriously protecting the 

forests. Every tree downed released its stored carbon back into the 

atmosphere and will never again absorb it. We are cutting timber at an 

alarming rate to feed Europe's loophole regarding clean energy. For the 

love of the planet, stop this sale. 

[B Manderscheid]

Your opposition to the Wrangell Island Project is noted.

098-PM-10 Please keep the Tongass National Forest completely off limits to ALL 

commercial activities that change the nature of the land, ecosystem, and 

natural environment, including ALL logging.

Please also DO NOT CREATE ANY ROADS OF ANY KIND, no matter 

what you call them or how you designate them, as this profoundly 

disrupts the natural ecosystem.

Please also understand that this land is owned by the citizens and 

taxpayers of the United States and should not be rented, sold, or in any 

way bartered to private corporate interests. PERIOD!

And: please let native, aboriginal, and first nation people have priority 

voice in all decisions regarding their local lands and ecosystems.

Thank you.

Peter [Metzler]

Your opposition to the Wrangell Island Project is noted.

098-ME-11 Logging in the Tongass has always been a 'below cost' operation. Why 

exactly are we taxpayers footing the bill for the destruction of our 

precious old growth forests? They're not making any more of it, and SE 

Alaska is nearly the last place where such intact forests are to be found. 

[Marianne Edain]

Your comment is noted.

098-ME-12 Have you perhaps noticed that glaciers are retreating? That places 

formerly either gray or white are now green? Less snow? Having to 

import snow for the Iditarod? Destruction of the Tongass forest 

ecosystem is a direct cause of global climate change, along with the 

destruction of all of the species which are an integral part of that forest 

ecosystem.

Comment noted. Please see the discussions on climate change 

and aquatic resources in chapter 3 of the FEIS.
BAppendix

Wrangell Island Project FEIS ♦ 306

Comment 

Number Comment Response

It is truly and painfully ironic that the very same US government which 

pays millions of dollars to protect salmon habitat then authorizes the 

destruction of that very same habitat.

To quote Nancy Reagan, "Just say NO!"

[Marianne Edain]

098-JM-13 I want to know how exactly this timber sale plans to keep salmon safe 

from any harm. We are losing critical salmon habitat all over the West 

and if we are not diligent about maintaining ideal riparian habitats we will 

lose all of the salmon. It is essential that water stays clear and are 

disrupted by the sediment cause by logging which kills salmon eggs. It is 

essential that no trees are removed from around waterways and thus 

keeping the water as sheltered from sun and cold as possible because 

salmon need cold water to survive. 

[Jordanna MacIntyre]

Comment noted. Fisheries resources are protected through the 

application of BMPs, stream buffers and other specific 

protections put in place by the Forest Service.

098-JM-14 It is also essential that we look at logging in terms of carbon, as logging 

is a gigantic cause of carbon being unnaturally released in our 

atmosphere, leading to increased climate chaos. 

[Jordanna MacIntyre]

The action alternatives analyzed in the FEIS would increase 

carbon releases whether through the burning of fossil fuels 

associated with harvest, transportation, and processing activities 

and through increases in CO2 due to increases in organic matter 

decomposition rates, post-harvest. The effects of the project on 

climate are discussed in the climate change section of chapter 3 

of the FEIS.

098-JM-15 I want to know what specific measure you are taking to protect our 

salmon, our climate and our quiet recreation.

[Jordanna MacIntyre]

The measures used to minimize the effects to forest resources 

are the design criteria, standards and guidelines, BMPs and 

other applicable laws are identified in the FEIS. Site-specific 

measures are described in the unit and road cards.

098-MI-16 A timber sale in the Tongass National Forest will allow for logging 

alongside one of the most important wild salmon streams in southeast 

Alaska.

Logging near important wild salmon habitat can hurt the fish born in 

these freshwater streams and the bears that depend on them. And it 

could have negative consequences for southeast Alaskans as well, 

especially those who rely on the land to gather food or rely on salmon for 

their livelihood.

[Multiple individuals submitted this additional statement]

All fish bearing streams would be protected through the 

application of buffers and BMPs. Impacts to salmon and 

subsistence resources are discussed in chapter 3 of the EIS. 

098-MI-17 But that's not all. This sale will leave the American taxpayers in the red 

while many of these trees could be exported overseas without local 

processing, meaning that the sale won't support many American jobs.

Please note that any timber sales that result from the Wrangell 

Island Project would not be advertised unless they appraise 

positively.
Appendix B

Wrangell Island Project FEIS ♦ 307

Comment 

Number Comment Response

[Multiple individuals submitted this additional statement]

098-MI-18 Both the people and wildlife of the Tongass rely on abundant wild 

salmon. Southeast Alaska's fishing industry brings in $1 billion in 

revenue every year, and Tongass salmon support iconic wildlife like 

Alaska's coastal brown bears.

[Multiple individuals submitted this additional statement]

Your comment is noted.

098-NZ-19 The USDA Forest Service should have enough of a body of 

management knowledge to know how disruptive to an ecosystem 

logging is, especially in an area of old growth where forest is at climax. 

It's not just the trees but the entire forest ecosystem - green and blue -

that is impacted and, in this specific case, Tongass salmon habitat.

You are supposed to be stewards of the Public lands you oversee - not 

timber industry lackeys. The people who pay your salaries expect you to 

be managing these Public treasures with a balanced understanding of 

the ecosystems involved and act accordingly. 

I therefore respectfully submit, as a forestry professional and an avid 

outdoors person, my complete and total disapproval of the planned 

Wrangell timber sale and ask that you re-visit your decision and set it 

aside. Nothing less will do.

[Naomi Zurcher]

Your opposition to the Wrangell Island Project is noted.

098-PB-20 Too many roads. Too much environmental damage for profit. The Plan is 

not able to meet the obligations to manage habitat for well-distributed, 

viable wildlife populations. The old growth that supports a whole variety 

of uses on Wrangell Island. We need to preserve the forests because 

they are beautiful, because they are refuges for the wild creatures of the 

wilderness, and because they are a buffer for pollution. We need to 

protect this important habitat. Forests are living systems - trees grow up, 

grow old and die - a natural process. Forests are covered in trees and 

other woody plants and are filled with living animals. The timber industry 

has no economic incentive to be careful or prudent in their destruction of 

this ecosystem. They have an incentive to get what they can and leave 

the damage they cause. Profits over ecology and environment. We do 

not need to give up careful and prudent management of this area for 

corporate profits. salmon enrich terrestrial and freshwater ecosystems 

with essential marine-based nutrients when they complete their lifecycle. 

Salmon are economically and culturally important around the world.

[Peter Bisschop]

Comment noted. Please see the discussion on wildlife in chapter

3 of the FEIS. Viable, well-distributed populations would continue 

to exist in the analysis area.
BAppendix

Wrangell Island Project FEIS ♦ 308

Comment 

Number Comment Response

098-LL-21 [This is] critical habitat for salmon, they feed the Orcas, many Orcas 

have been malnourished too! 

Don't allow big business to destroy the natural world, protect wild 

creatures and wild habitat. We are all one and when you sentence one to 

death, we all lose. 

[Leslie Lund]

Your comment is noted.

098-AS-22 We must restore our salmon or we will lose our whales

[Andrea Simmons]

Your comment is noted.

098-BW-23 When timber sales cost the Taxpayers more than they generate it's time 

to consider other means of community employment.

Last I heard, there is a thriving tourism business in the Tongass, one that 

would benefit nicely from additional support from the Federal 

Government and not at the expense of the timber.

[Bruce Wade]

Your comment is noted.

098-CH-24 There are so many reasons not to do this sale that it seems 

preposterous to even consider it. It will only cost tax payers money. It will 

harm the ecosystem which is fragile. Take years to replace itself. 

Meanwhile it will not help with jobs, considering much of the wood will go 

to China. Their ships, their crews, their factories. Why should America 

(Alaska in particular) sell at a loss a product that has taken untold years 

to grow. We pay for the roads. Later we buy the product back from the 

Chinese factories at full price. And American economy takes another hit. 

This is just not good business for fish, fowl, or citizens. Please stop this 

foolishness. Wild salmon and the rest of the wildlife in the area should 

not be jeopardized so a very few can profit. Stop this deal Mr. Stewart. 

Do the right thing for Alaska, the United States and the global climate. 

Thank You Sir!

[Clifford Haugen]

Your opposition to the project is noted.

098-JS-25 This magnitude of logging is an audacious repudiation of everything the 

Forest Service has promised for a sustainable future in the Tongass, and 

would instead ensure that the timber mills and associated obsequious 

local politicians cling to Tongass logging for their economic hopes. This 

exchange of a national biological treasure for a low-value commodity of 

wood pulp is grossly misguided. Continued old-growth logging ignores 

the overriding national interest in protecting our precious ancient forest, a 

critical component of Earth’s life-support system for humanity. The 

Tongass is home to a large portion of the ancient forest remaining in 

Your opposition to the project is noted.
Appendix B

Wrangell Island Project FEIS ♦ 309

Comment 

Number Comment Response

American jurisdiction, and destruction of the Tongass constitutes a 

heinous abdication of America's responsibility to maintain Earth's lifesustaining capacities of oxygen production, carbon sequestration, and 

nutrient cycling. Our planet is already losing a terrifying amount of its 

forest cover. The US government must maintain the extremely highbiomass stands of the Tongass on every last acre that it yet controls, 

and not transfer them to timber interests who disavow any concern for 

Earth's life support systems.

[Jim Steitz]

098-BC-26 Please protect both uninventoried and inventoried roadless areas in this 

our largest national forest which is a major carbon sink.

Please cancel the Wrangell timber sale and consider the ancient forestdependent species such as native salmon.

[Bruce Campbell]

Your opposition to the project is noted. Inventoried roadless 

areas are protected by the 2001 Roadless Rule.

098-KL-27 We have a duty to be good stewards of our native wildlife and many 

species depend on the unique habitat of the Tongass forest. Like many 

other Americans I love wildlife and want to see these animals protected. 

Don't sacrifice the forests that shade the rivers salmon use to spawn and 

that create the deep pools in which they take refuge. Protect the tallest 

old growth trees that shelter the forest floor from deep snow, as well as 

provide cavities, snags, logs, and thick bark that a wide variety of 

animals need for shelter and food. Old growth forests take hundreds of 

years to develop and humans have destroyed all but a fraction of what 

was once here. These forest provide us all huge benefits in terms of 

fresh air, water and protection from climate change. It is vital that we 

protect them for ourselves and our fellow earthlings.

[Kathryn Lezenby]

Your comment is noted.

098-MM-28 We've been to the Tongass/Wrangell area! It's incredibly beautiful, 

except for the areas that have been clear-cut. Think about those of us 

that have ventured here on a cruise ship. We cringe when seeing the 

ugly timber mismanagement. Support tourism, not destroying the oldgrowth and the environment!

[Michelle Mitchell]

Your opposition to the project is noted.

098-MH-29 If logging is truly a renewable resource, then logging in virgin areas 

should not be necessary. I believe that timber is a renewable resource. I 

think the real question is, where is the demand for the added wood? The 

answer is probably that the wood from this logging will probably go to 

Asia, and is simply a way for the logging industry to make more profit. 

Your comment is noted.
BAppendix

Wrangell Island Project FEIS ♦ 310

Comment 

Number Comment Response

Please don't sell out our very important wild areas for the interests of 

private corporations and foreign markets. 

[Mathew Hart]

098-NC-30 The fishing industry depends upon cool, clear water. This industry brings 

many travels to Alaska for fishing as well as tourists who want to see the 

area and eat the fish. Loss of this area will do enormous, irreversible 

damage to the industry and tourism. Trees cut are not great scenery and 

the years if ever it will take to replace them means a short term benefit 

for a now permanent problem. The benefactor is China, the loser is your 

fishing industry. Tourists come to see the beauty not a series of 

clearcuts. We have these here and they are devastating to the 

environment. 

[Nancy Church]

Your comment is noted.

098-SW-31 Logging along waterways instantly affects hydrology by raising stream 

temperatures and causing changes to water chemistry and pH levels. 

These changes could destroy fish habitat.

[Sondra Wolferman]

All fish bearing streams would be protected through the 

application of BMPs and Forest Plan standards and guidelines, 

including riparian buffers. Impacts to salmon and subsistence 

resources are discussed in chapter 3 of the EIS and in the 

Aquatics Resource Report. 

098-EA-32 The time has come for Southeast Alaska to no longer rely on the timber 

industry as an economic driver. The Forest Service should manage the 

National Forests in Southeast Alaska for a host of public values that 

support the tourism and fishing economy of today; the driving economic 

forces are, and continue to be, tourism and recreation.

[Elise Allen]

Comment noted. 

098-EA-33 The Tongass offers the country’s largest remaining swath of ancient 

forest, as well as an estimated one third of the world’s remaining 

temperate rainforest. It is far past time for an end to old-growth logging 

and destruction of habitat essential for endemic species found only in 

this biologically rich region. I support Alternative 1, the “no-action” 

alternative because in this alternative, none of the proposed logging 

activities would occur.

[Elise Allen]

Your support for Alternative 1 is noted.

099-FL1 Forest Supervisor Stewart,

Dear Forest Supervisor Stewart:

099-FL1-01 I am writing to express my opposition to the proposed Wrangell Island 

Timber Sale. 

Your opposition to the project is noted.
Appendix B

Wrangell Island Project FEIS ♦ 311

Comment 

Number Comment Response

099-FL1-02 While I was encouraged by the recent forest plan amendment that 

proposed new protections for the Tongass 77 and other conservation 

priority areas, the Wrangell Island Sale runs counter to this. The sale 

units in Thoms Lake and in important deer winter habitat are particularly 

troubling and should be removed from the sale. 

Please see response to comment 048-TUSCS-02.

099-FL1-03 In addition, I am concerned that by the Forest Service’s own estimate the 

project will not be economically viable and will cost taxpayers money. I 

encourage you to halt planning this project and redirect the Forest 

Service’s limited resources toward more productive projects that better 

suit the needs of Southeast Alaska.

Please see the “Timber Economics and Availability” section in 

chapter 3 of the DEIS and the Timber Economics Resource 

Report. The current economic model was used to provide a 

general economic comparison of each alternative as a whole. 

The model is based on historical timber values and costs and 

does not indicate future market conditions at the time each sale 

is put up for competitive bid. No sales would be offered unless 

they meet a positive advertised rate.

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