USDA Forest Service - Wrangell Ranger District NEPA Projects - Wrangell Island Project EIS Page 1

http://www.fs.fed.us/nepa/nepa_project_exp.php?project=34831 9/7/13 14:23:58

Wrangell Island Project EIS

United States Department of Agriculture

Forest Service

Forest Service NEPA Projects

Develop/implement multi-year project involving a variety of timber harvest, road construction, forest

restoration and enhancement.

Location Summary

The project area is Wrangell Island, located within the Wrangell Ranger District of the Tongass

National Forest. The community of Wrangell (population 2,500) is located on the island's north end.

District: Wrangell Ranger District

Project Documents

Scoping

Wrangell Island Project EIS Proposed Action Map 20130729 (PDF 5476kb)

Wrangell Island Project EIS Scoping Letter 20130731 (PDF 727kb)

Wrangell Island Project EIS Mailing List Update Notice 20130731 (PDF 112kb)

Wrangell Island Project EIS Federal Register 20130815 (PDF 199kb)
1

Date: Tuesday, August 27, 2013 (17:23)

From: Larry Edwards ledwards@greenpeace.org

To: Tim Piazza <timpiazza@fs.fed.us>

Subj: Request - additional info for the public in the WIP scoping process

Hi Tim,

 I am writing concerning the scoping process for the Wrangell Island

Project, to ask that the public be timely provided an improved Proposed Action

Map before the period for scoping comments officially closes.

 The difficulties with the map provided for download on the project

website are:

(1) "existing managed stands" are shown in a very pale color which makes

judging the project's cumulative impact difficult, whereas use of a color of

similar weight to those used for project units would aid the interested public

in making such judgment;

(2) the map provides no indication of elevation or the varying quality of

vegetation and other landforms;

(3) the boundaries of units in the State of Alaska's Earl West Area (FYSTS for

2013-2017) are not shown.

 Attached are several maps which, in comparison, illustrate what the

map on the project website is lacking:

First is a the project map modified by substituting black for the pale color

that had been used for logged areas. (This was done in a graphics program,

since I don't have GIS capability.) However, this still does not indicate

elevation or portray vegetation and other land cover features.

Second is a Google Earth image with the same coverage as the Proposed Action

Map. Units have been outlined in red as best I could, given eyeball and mouse

methods (again, no GIS capability). The image has been adjusted for

brightness, contrast and color balance (since Google Earth images are

typically muddy). I believe this graphic, in comparison to the official map,

clearly shows the inadequacy of the latter for informing the public and

soliciting meaningful comments. Producing such a map is easily within the

capabilities of the Forest Service's mapping software.

Third and fourth are similar to the second attachment, except being in 3D,

from two aspect orientations. Such views give the clearest portrayal of the

proposed action and its potential impacts.

 I urge you to post GIS-based maps like the second, third and fourth

attachments on the website, and to extend the comment deadline if this can't

be done quickly. Additional features not on my map should be included: (1)

black outlines for "existing managed stands," since older units are not always

distinct on the satellite images; (2) colored road alignments; and (3)

boundary lines for non-NFS land areas, in a distinct color.

 I believe such maps are vital to the public's understanding of the

project, especially at the scoping stage, given the scale of the project and

the past logging activity in the area. Please let me know your opinion, and

call if you wish to discuss this.
2

Thanks,

-- Larry

Larry Edwards

907-747-7557

Greenpeace




1

Date: Friday, August 30, 2013 (13:29)

From: Piazza, Tim -FS timpiazza@fs.fed.us

To: "Larry Edwards (ledwards@greenpeace.org)"

 <ledwards@greenpeace.org>

cc:

Subj: wrangell island project eis greenpeace scoping comments

Date correction...thanks

---------------------

From: Piazza, Tim -FS

Sent: Friday, August 30, 2013 1:24 PM

To: Larry Edwards (ledwards@greenpeace.org)

Subj: wrangell island project eis greenpeace scoping comments

Hi Larry,

We've received your August 13, 2013 [August 19, 2013] scoping letter and your

August 27, 2013 E-mail message.

1) Scoping letter - Thank you for subscribing to the electronic

notification platform. We will retain your postal subscription and recognize

your request to receive hard copy EIS documents, and a complete project

record, in a timely fashion.

2) E-mail message - We appreciate your request for refinement of the

proposed action map shared on the project webpage. The intent of this map was

to provide general information, including contour lines and previously

harvested units, without too much clutter that may confuse the layperson.

Since this is our third scoping period, and the proposed action has become

considerably smaller, we feel as though our GIS resources need to be utilized

to move this project forward for analysis. We will be providing maps with more

detail in the DEIS for additional public comment.

We look forward to your additional comments and thanks for your participation.

[tree-conifer-icon[1]]Tim Piazza

 Planning Forester

 Tongass National Forest

 Ketchikan, Alaska

 907-228-6318 desk

 907-617-6057 cell

 timpiazza@fs.fed.us<mailto:timpiazza@fs.fed.us>

This electronic message contains information generated by the USDA solely for

the intended recipients. Any unauthorized interception of this message or the

use or disclosure of the information it contains may violate the law and

subject the violator to civil or criminal penalties. If you believe you have

received this message in error, please notify the sender and delete the email

immediately.
STATEMENT OF DAVID K. PERSON 

REGARDING THE BIG THORNE PROJECT, 

PRINCE OF WALES ISLAND 
Page 1 	 	

I, DAVID K. PERSON, state as follows: 

1. I am a wildlife scientist with 22 years of experience studying Alexander 

Archipelago wolves (Canis lupus ligoni) and Sitka black-tailed deer (Odocoileus hemionus 

sitkensis) in Southeast Alaska. My references to “wolves” and “deer” throughout this statement 

relate to these species. I began wolf research on Prince of Wales Island as a Ph.D. student at the 

University of Alaska Fairbanks in 1991. 

2. Prior to beginning wolf research in Alaska, I worked as a statistician for the 

Vermont Department of Health, studied coyotes for my Masters degree at the University of 

Vermont, and worked as a deer management biologist for the New Jersey Department of Fish, 

Game, and Wildlife. 

3. I received my doctorate degree in wildlife biology in 2001. By then, I was 

employed by the Alaska Department of Fish and Game (ADFG) to research wolf-deer predatorprey dynamics in Southeast Alaska. I worked for ADFG from 1998 to 2013, leaving the agency 

in May 2013. All told, I have more than 30 years of experience as a professional wildlife 

biologist. 

4. During my time in Alaska, I authored or co-authored more than 20 peer-reviewed 

papers on deer and wolves that were published in scientific journals, three book chapters, and 

many agency reports and publications. In addition, I am well trained in forestry, forest ecology, 

and silviculture, and am very knowledgeable about the forest ecology of Pacific Northwest 

temperate rainforests, including those of the Tongass National Forest. 

5. During 1996-1997, I worked closely with the U.S. Forest Service (Forest 

Service), ADFG, and U.S. Fish and Wildlife Service (USFWS) scientists tasked with developing 

the wildlife conservation strategy that was ultimately adopted by the 1997 Tongass Land 
Page 2 	 	

Management Plan (TLMP). Indeed, I was the senior author on the wolf conservation assessment 

(Person et al. 1996) the purpose of which was to guide the forest plan revision with respect to the 

conservation of wolves. I also assessed the population viability of the wolves on Prince of Wales 

Island as part of the analyses USFWS staff conducted when they were considering a petition to 

list wolves in Southeast Alaska as threatened under the Endangered Species Act. That 

assessment constituted a major focus of my Ph.D. dissertation. 

6. In 1996-1997, I was the principal resource expert for wolves and a resource expert 

for deer, advising expert panels of scientists convened by the Forest Service during development 

of the wildlife conservation strategy for the 1997 TLMP. 

7. Following adoption of the 1997 TLMP, I, with three other authors, two of whom 

were coauthors of the wolf conservation assessment (Person et al. 1996), wrote the Forest 

Service to point out several serious errors in the Forest Service’s interpretation the conservation 

assessment (Letter to Beth Pendleton 1997). In particular, we objected to how the Forest Service 

developed the wolf standard and guideline in the forest plan. The agency assumed that deer 

habitat capability was equivalent to actual deer density. Habitat capability represents the 

carrying capacity of winter range during an average snow year, not the actual density of deer. 

Essentially, it represents the potential of the habitat to support deer. In our letter, we 

demonstrated that deer density can never be at the level of habitat capability when additive 

predation from wolves, bears, and hunters acts on the population. In that case, actual density will 

always be well below habitat capability. We stated that a minimum density of 13 deer/ mi2 is 

important to reduce the risk of unstable predator-prey dynamics and provide for predators and 

subsistence hunters. The Forest Service uses deer habitat capability because they have no costeffective way to monitor actual deer density. Using deer habitat capability is a very poor 
Page 3 	 	

substitute for actual deer density. Subsequently, the Forest Service corrected TLMP’s deer 

habitat capability standard for wolves, increasing it from 13 to 17 deer/ mi2

 in 1998 (Powell 

1998) and to 18 deer/ mi2 in 2005 (Puchlerz 2002). 

8. In 2006, I was the principal expert for wolves at the Forest Service’s Tongass 

Conservation Strategy Workshop. I presented analyses based on my research that indicated 

several deficiencies in the TLMP conservation strategy with respect to wolves. Most notably, 

the large old-growth forest reserves (OGRs) are too small to encompass a single wolf pack home 

range. My analyses indicated that when about 40% of a pack’s total home range is logged and 

roaded, there is a very high risk that mortality (mostly from hunting and trapping) will exceed 

reproduction and the pack area becomes a population sink. Indeed, even when as little as 25% of 

a pack’s home range is logged, the ratio of reproduction to mortality is very close to one. Sinks 

are only maintained by immigration of wolves from other areas, which, as explained below, is 

not likely to happen on Prince of Wales Island given the population’s isolation and small 

numbers. 

9. For the past 22 years, I studied wolves in Game Management Unit (GMU) 2 

which includes the Big Thorne project area. Prince of Wales Island and the surrounding islands 

and GMU2 are essentially the same area with regard to wolves. I studied the predator-prey 

relationship in the area and tracked wolf populations to the extent that the work was funded. I 

participated in the Big Thorne environmental review process, including the review of the 

project’s Draft Environmental Impact Statement (DEIS), in my capacity as a biologist for 

ADFG. I participated in numerous meetings and discussions regarding Big Thorne. Among 

other meetings, I participated in an April 9, 2013 meeting with Forest Service officials, including 

Tongass Supervisor Forrest Cole, and representatives from USFWS. The objective of that 
Page 4 	 	

meeting was to discuss road closures and other mitigation measures that would reduce the effect 

of the Big Thorne timber sale on wolves. At the meeting, I showed the group maps of recent 

GPS locations of radio-collared wolves within the Big Thorne project area. Those locations 

clearly demonstrated that closing a few spur roads here and there would have a negligible effect 

on mortality because there were simply too many existing roads in the project area. Moreover, 

the data showed how vulnerable packs are to access via roads, even for the pack occupying the 

Honker Divide OGR because that OGR is simply too small to encompass their home range. The 

only road mitigation that would work would be to close down many of the major arterial roads, 

which is unlikely to happen. I urged the group to focus more on preserving deer habitat, meeting 

TLMP’s provided guidelines, and recommending ways to treat second-growth forest to improve 

the quality of deer range. The Forest Service did not indicate any serious effort to go forward 

with any specific recommendations. 

10. Additionally, I communicated directly with Forest Service personnel, including 

Brian Logan, a Forest Wildlife Biologist, through email and phone conversations. I explained 

during these informal discussions that the Big Thorne and Log Jam timber projects will have a 

serious impact on wolves and deer, and consequently wolf viability. They will remove the last 

high quality winter range for deer in the central portion of Prince of Wales Island and the 

cumulative effects of the Big Thorne and Log Jam timber projects along with previous logging 

over 60 years, has and will erode the resilience of deer to severe winter, predation, and hunting. 

In addition, land transfers to Sealaska Corporation and Alaska Mental Health Trust Authority, 

will reduce more deer habitat on other parts of the island such that the level of habitat loss within 

Big Thorne and Log Jam has been and will be duplicated in most of the Prince of Wales 
Page 5 	 	

Archipelago. Sealaska Corporation and Alaska Mental Health Trust lands are logged under state 

of Alaska regulations, which have no meaningful protections for wildlife whatsoever. 

11. The combined effects of Big Thorne and the other logging on wolves within the 

Prince of Wales Archipelago likely will be the collapse of a sustainable and resilient predatorprey ecological community. That community includes deer, wolves, black bears, and people. 

Because of pressures to sustain subsistence deer hunting as habitat is lost, there will be immense 

public and political pressure to kill wolves and bears. 

12. Because of my many years of research and related professional assignments, I am 

the most experienced and knowledgeable scientist in the United States with respect to wolves 

and the wolf-deer predator-prey ecological communities in Southeast Alaska. Over the past 

decade, I was one of the principal deer researchers on the Tongass. In addition, I am recognized 

by federal and state agencies as an expert on the effects of forest management on deer, wolves, 

and predator-prey dynamics. I am particularly qualified to address the effects of the Big Thorne 

timber sale on wolves and deer because so much of my research on those species during the last 

22 years was conducted within the project area. 

13. I wrote this statement because I have concluded that the Big Thorne timber sale, if 

implemented, represents the final straw that will break the back of a sustainable wolf-deer 

predator-prey ecological community on Prince of Wales Island, and consequently, the viability 

of the wolf population on the island may be jeopardized. I received no compensation for this 

statement. Copies of the studies and documents I cite in this statement are provided as exhibits 

at the end of the statement. My opinion is summarized as follows: 

a. Wolf populations in the Big Thorne project area have declined rapidly in recent 

years as a result of old-growth logging, which degrades deer winter habitat, road 
Page 6 	 	

building, which provides access for hunters and trappers, and high levels of wolf 

mortality (because roads increase human access) from legal and illegal hunting 

utilizing both open and closed roads; 

b. The Big Thorne project will harvest much of the best remaining mid and low 

elevation deer winter habitat in this part of Prince of Wales Island, which will 

most likely, over time, result in further declines in deer and wolf populations. On 

Prince of Wales Island, more than 50% of the island is already at or approaching 

levels of logging that will strongly increase the risk that the island will only be 

capable of supporting wolf packs that function as population sinks. To prevent 

this outcome the remaining mid and low elevation deer habitat on Prince of Wales 

Island needs to be protected and the number and size of OGRs need to be 

increased to increase the likelihood that more wolf packs are protected from 

unsustainable mortality from hunting and trapping. As explained below, the Big 

Thorne project puts the viability of the wolf population on the Prince of Wales 

and the surrounding islands (the Prince of Wales Archipelago) in doubt. 

c. Because so much winter range for deer has been logged, deer are not resilient to 

effects of both predation and severe winters. As a result, a bad winter could cause 

a significant decline in deer and the population remains low owing to predation 

and hunting (Person and Brinkman 2013). The Big Thorne project area is heavily 

used by subsistence hunters because it is close to all of the major towns on Prince 

of Wales Island. The project will cause immeasurable and permanent harm to 

those hunters and create an intractable management dilemma of trying to sustain 

deer in the face of dwindling habitat quality, predation, and human demands. 
Page 7 	 	

d. The wildlife conservation strategy in the 2008 TLMP is inadequate to deal with 

these issues both at the project level and at the biogeographic province. The 

cumulative effects of 60 years of clear-cut logging plus the Big Thorne project 

could result in the ecological collapse of the predator-prey system and result in 

wolf numbers well below minimum viability both demographically and 

genetically, which would eventually result in their extirpation or extinction within 

the Prince of Wales Archipelago. The Prince of Wales Archipelago makes up a 

large percentage of wolves in Southeast Alaska, perhaps as much as 30% (Person 

et al. 1996). They are a genetically and morphologically distinct group within the 

Tongass (Weckworth et al. 2005). As a result of these considerations, wolves on 

the Prince of Wales Island and the Prince of Wales Archipelago are an important 

part of the overall wolf population in the Tongass. 

e. 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 predator-prey 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. 
Page 8 	 	

Status of Wolves on Prince of Wales 

14. Genetic and telemetry data indicate that the wolf population on the Prince of 

Wales Archipelago is an isolated population from other wolves throughout the Tongass (Person 

2001; Weckworth et al. 2005; Person and Russell 2008), which complicates management of the 

population because it is not buffered by immigration and has limited genetic diversity. The wolf 

population on Prince of Wales Island is composed of resident pack members and nonresident 

wolves that are dispersing or are floating between several packs (Person 2001; Person and 

Russell 2008). Wolves primarily prey on deer, annually consuming an estimated 18 to 32 deer 

per wolf (Person et al. 1996). 

15. The population of wolves on Prince of Wales Island has declined substantially 

since the middle of the 1990s, especially within the north-central portion of Prince of Wales 

Island. I estimated the wolf population on the Prince of Wales Archipelago during autumn 1995 

to be approximately 300-350 animals (Person et al. 1996; Person and Russell 2008). That 

estimate was an extrapolation from my study areas on the Prince of Wales Archipelago and was 

based on aerial counts of wolves in packs containing radio-collared animals plus an estimate of 

the number of potential nonresident wolves in the population derived from rates of dispersal of 

radio-collared wolves. During 2000-2004, I estimated 250-300 wolves, again based on aerial 

counts within my study area on the Prince of Wales Archipelago. No formal wolf population 

estimations have been conducted since 2004. The Final Environmental Impact Statement (FEIS) 

for Big Thorne says that during a 2010 Alaska Board of Game meeting in Ketchikan, “ADF&G 

reported that anecdotal observations by state and Federal biologists, trappers, and hunting 

outfitters/guides suggested the wolf population had declined to as few as 150 wolves in GMU 2,” 
Page 9 	 	

which would mean that wolf numbers were down by roughly 50% compared with the previous 

decade. 

16. Since 2009 the Forest Service and ADFG have cooperated to fund a study to 

develop a method to estimate abundance of wolves in Southeast Alaska. The project, funded 

primarily by the Forest Service, collected wolf scats (feces) for Deoxyribonucleic acid (DNA) 

genotyping from which I hope to derive a population estimate (Person 2009-2012). I was the 

lead researcher on the study and we have provided regular progress reports to Forest Service and 

ADFG. Our study area was essentially coterminous with the Big Thorne project area. As part of 

this effort during 2009 and 2010, I searched roads and trails for fresh scats and located only 36 

feces. During 1993-1994, a graduate student from the University of Alaska Fairbanks and I 

collected more than 150 scats from the exact same area with much less effort (Kohiraand 

Rexstad 1997). In 2010, eleven known, previously used dens of five wolf packs were checked, 

and no denning activity was found. Also there was no indication of use on wolf trails that 

previously had been used regularly, and some were starting to grow over. We drove road 

transects within the study area (north-central Prince of Wales from Whale Pass south to 12-mile 

Arm, and from Thorne Bay west to Winter Harbor) and found very few signs of wolves. 

17. I estimate that in the mid-1990s, at the time the TLMP conservation strategy and 

viability assessment were being developed, the Big Thorne project area had the habitat to support 

45-50 wolves, making up approximately 3 separate packs and a portion of a forth pack. 

18. In the Fall of 2012, we determined through DNA hair trapping and radio-collaring 

work that there were approximately 29 wolves in the Big Thorne project area and only two 

remaining packs in the area. Changes in pack structure are a reflection of turmoil and 

disturbance (Ballard et al. 1997). One of the packs is large; the other is so small it that it appears 
Page 10 	 	

to be struggling to raise a successful litter of pups. The large group had two breeding females 

and covered an area that used to encompass the Honker Divide and Ratz Harbor wolf packs. 

Both females were killed last year; one was trapped legally and the other trapped illegally. 

19. In 2013, we continued our study based on work conducted between January and 

May and provided the Forest Service our progress report (Person and Larson 2013). In the 

Spring of 2013, based on our field work we could only account for six to seven wolves left in the 

Big Thorne project area. During the 2012 hunting season, trappers killed at least fifteen wolves 

in the Big Thorne project area, but that only accounts for legal, reported take. A few of these 

wolves could have been dispersing wolves (i.e., wolves travelling through the area and not a part 

of the resident packs), but the vast majority are likely to have been resident wolves. Some 

wolves we counted in autumn 2012 also could have dispersed out of the area. 

Logging, Deer, Wolves, and Hunters 

20. Sitka black-tailed deer and the Alexander Archipelago wolf are endemic to 

coastal temperate rainforests in Southeast Alaska and northern, coastal British Columbia. This 

deer species serves as the primary food source for the wolf and is also an important subsistence 

resource for residents of rural southeast Alaska. Deer, wolf, and humans in this region therefore 

exist in predator-prey relationship that depends in large part on the habitat provided by the 

Tongass National Forest. 

21. Deer rely on old-growth forest habitats in the Tongass for their survival because 

these forests provide important winter habitat (Wallmo and Schoen 1980). Less snow 

accumulates in these old-growth forests, and deer can still find forage during the winter months. 

Low elevation, high volume old-growth forests provide the best winter habitat for deer (Schoen 

and Kirchhoff 1990). The logging of old-growth forest can therefore result in declines of deer 
Page 11 	 	

populations, because with fewer acres of high quality winter habitat, fewer deer can survive the 

winter. Deer is also the most important terrestrial subsistence species in rural, Southeast Alaska. 

22. In 2011, Brinkman et al. published a study in which they estimated a mean deer 

density decline in three watersheds in north-central Prince of Wales Island of 32% over a threeyear period, from 13.1 deer/km2

 in 2006 to 8.9 deer/km2 in 2008, which the authors attributed to 

severe winters (Brinkman et al. 2011). Deer populations in unlogged areas (12 deer/km2

) were 

substantially higher than in recently logged areas (10 deer/km2

) and areas that were logged more 

than 30 year ago (7 deer/km2). This study was conducted in the same area that would be affected 

by the Big Thorne project. 

23. Wolf populations are closely tied to populations of deer. Wolves depend on deer 

for up to 90% of their diet during the winter months. (Person et al. 1996). In 1996, we estimated 

the number of deer per wolf required to maintain equilibrium between deer and wolves. Our 

work demonstrated that a ratio of deer to wolf of 170-180 deer to one wolf is needed for a 95% 

probability of equilibrium between the populations. (Person et al. 1996). If deer populations 

decline substantially, wolf populations are very likely to decline eventually because of a reduced 

prey base. Wolves and subsistence hunters both compete for available deer. As deer numbers 

inevitably decline on Prince of Wales Island as a consequence of on-going logging and the stillpending succession debt of past logging (Person and Brinkman 2013), subsistence and 

recreational hunters increasingly will perceive competition from wolves for deer. Legal and 

illegal take of wolves can be predicted to increase as a result, particularly in areas accessible by 

roads or boats (Person et al. 1996; Person 2001). My experience indicates that regulations 

designed to sustainably manage wolf populations will then be ineffective, because of unreported 

and illegal take of wolves (Person and Russell 2008). 
Page 12 	 	

24. The construction of roads associated with logging projects also increases the risk 

of wolf mortality by legal and illegal harvesting. Roads offer convenient pathways for wolves 

through logged watersheds, but they also provide access to humans, increasing risk of death of 

wolves from hunting and trapping. 

25. The current decline in wolves on Prince of Wales Island, including the Big 

Thorne project area, is caused primarily unsustainable hunting and trapping, which are facilitated 

by access provided by road development. From 1990 through 1999, wolf harvest reached 

unsustainable levels. Wolves can sustain about 35-38% total annual mortality (Person and 

Russell 2008). Natural mortality is about 5% (Person 2001; Person and Russell 2008), therefore, 

harvest mortality cannot exceed 30-33% without compromising sustainability. Risk of 

unsustainable harvest is particularly high within roaded watersheds (Person and Russell 2008; 

Person and Logan 2013). In 1996, the Alaska Board of Game passed a guideline harvest level 

for wolves in GMU 2. They did so because the USFWS was actively reviewing a petition to list 

wolves as threatened under the Endangered Species Act. The guideline was to be implemented 

in 1997. Knowing that, trappers and hunters on the Prince of Wales Archipelago intentionally 

made a strong effort in 1996 to kill as many wolves as possible. During that year they killed a 

record 136 wolves, roughly 45-50% of the population at the time. In 1999, the harvest reached 

the guideline level resulting in early closure of the trapping season (Person and Russell 2008). 

Subsequently, reported harvest declined dramatically after 1999. Person and Russell participated 

in a study that demonstrated a strong positive linear relation (r = 0.89) between road density less 

than or equal to 0.9 km/km2

 (1.5 miles/mile2) and wolf harvest rates (Person and Russell 2008). 

We determined that densities greater than 0.9 km/km2

 likely resulted in unsustainable losses of 

wolves. 
Page 13 	 	

26. We also reported that 87% of mortality of wolves on Prince of Wales Island was 

from hunting and trapping (Person and Russell 2008). We concluded that annually, about 50 to 

95 wolves are legally taken (including required reporting of the kill), but that illegal take may at 

times equal the legal harvest on Prince of Wales (Person and Russell 2008). 

27. Person and Logan (2012) concluded that after road closures in GMU 2 prescribed 

in the Forest Service’s Access and Travel Management plan approximately 71% of roaded 

landscapes will still be accessible to hunters and trappers. That includes the Big Thorne project 

area. This research was premised on the conservative assumption that hunters or trappers will 

walk one kilometer from a road to hunt or place traps. However, a study by Todd Brinkman for 

which he surveyed Prince of Wales hunters and trappers, reported that the median hunter is 

willing to travel on foot a distance of two kilometers away from the road to hunt deer, and some 

reported a willingness to walk as much as four kilometers (Brinkman 2006). That is, 50% of 

hunters are willing to walk-in at least two kilometers. As a result, Person and Logan 2012 

significantly underestimates the amount of the project area that is already accessible to hunting 

and trapping activities. More plausibly, the percent of the project area readily accessible to 

hunters and trappers actually exceeds 80%. 

28. Wolf harvest in the Prince of Wales Archipelago declined dramatically after 2000 

(Person and Russell 2008; Person and Logan 2012; Person and Brinkman 2013) and ADFG, 

Alaska Board of Game, and Federal Subsistence Board took no action to respond to the decline. 

Indeed, the Federal Subsistence Board responded by lengthening the hunting season for wolves. 

By 2010, there was evidence that the wolf population had greatly declined at least within the 

north-central portion of Prince of Wales Island (Person 2009-2012), which includes the Big 
Page 14 	 	

Thorne project area, and the Alaska Board of Game lowered the harvest guideline quota but to a 

level still above the reported annual harvest. 

29. I have modeled the viability of an insular wolf population and wolf-deer predatorprey dynamics on the Prince of Wales Archipelago (Person 1997; Person 2001; Person and 

Brinkman 2013). I concluded that under the TLMP wildlife conservation strategy the deer 

population would decline substantially and predator-prey dynamics would become much less 

stable. I also concluded that persistently low deer numbers or even the perception of low 

numbers would increase the risk of unsustainable take of wolves by hunters and trappers 

attempting to boost deer populations, an activity facilitated by easy access to shorelines by boat 

and to island interiors by vehicles using roads. If this occurs on widespread areas on the Prince 

of Wales Archipelago, the viability of wolves would be at risk. 

30. During the Tongass Conservation Strategy Review Workshop in 2006 (part of the 

process leading to the 2008 TLMP amendment), I presented an analysis based on empirical 

survival and reproductive data from telemetered wolves. This analysis indicated that when more 

than approximately 40% of a wolf pack home range on Prince of Wales Island is comprised of 

logging and roads that allow access for hunting and trapping, the area likely becomes a 

population sink in which mortality exceeds reproduction. The analysis showed that the ratio of 

reproduction to mortality for wolf packs was perilously close to one to one when as little as 25% 

of the home ranges were logged and/or provide road access. 

Consequences of the Big Thorne Timber Sale 

31. Based on the impacts to wolf and deer habitat and populations described above, 

Prince of Wales Island, including the Big Thorne project area, is at a tipping point with regard to 

a viable predator-prey dynamic between wolves and deer. The wolf populations on Prince Wales 
Page 15 	 	

have been declining precipitously, and wolves are already facing the possibility of extinction on 

Prince of Wales Island. Big Thorne logging, if it goes forward, will remove the most important 

remaining deer winter habitat in many of the affected watersheds, which will further reduce the 

abundance of deer in the project area (especially following severe winters), perhaps for decades 

to come. As a result, the predator-prey relationship between wolves and deer on Prince of Wales 

is likely to collapse. 

32. In 2011, I raised these issues inside ADF&G. In particular, I set forth my opinion 

that the Big Thorne timber sale will likely threaten the ability of the watersheds involved to 

sustain wolves and deer over the long term. I provided maps demonstrating that the Big Thorne 

sale would result in the logging of the most important remaining winter habitat for deer in the 

Thorne watershed and in Steelhead Creek, among others. Several of the emails I sent to ADF&G 

staff are included in the Big Thorne record. The maps, however, do not appear to be included in 

the record, so I am including them as exhibits to this statement (Person ADF&G emails and 

maps). The third map shows the consequence of logging the whole unit pool rather than just the 

units included in the final Big Thorne decision, but although it therefore somewhat overstates the 

impact, it gives some indication of what is at stake. The Forest Service has not provided maps 

like these in the Big Thorne FEIS to show the sequence of loss of deer winter range over time, 

culminating with this project’s actual effects and alternatives. 

33. As I described above, it is not enough to maintain a sufficient deer population for 

wolves because hunters rely on those deer as well, and they can be expected to kill wolves 

legally or illegally to protect that resource. The situation is further compounded by the extensive 

road network already in existence, as well as the new roads into previously remote areas 

approved under the Big Thorne decision. This road system greatly facilitates human access and 
Page 16 	 	

eliminates refuge for wolves. The final complication is that the wolf population is genetically 

distinct and isolated from other wolves in the Tongass and, as a result, if wolves on Prince of 

Wales Island are extirpated or reduced to a small population, rescue or recolonization by 

dispersing wolves from the mainland is unlikely. 

Comments Concerning TLMP as the Guiding Document for the Conservation of Wolves 

and Deer 

34. TLMP, as amended in 2008, is the umbrella document guiding the conservation 

provisions incorporated in the Big Thorne timber sale. Because it is flawed, conservation 

measures derived from it and used in the Big Thorne project are also flawed. Prior to signing the 

predecessor 1997 Record of Decision for TLMP, the Forest Service convened several speciesspecific science panels to review the wildlife conservation strategy and seek professional opinion 

relative to its adequacy. The process involved creating a panel for each species of concern that 

consisted of a local resource advisor and three to four species experts from outside Southeast 

Alaska. I served as the local resource advisor for the wolf panel. I believe, based on that 

experience, my continuing research, and other published science since then, that there are major 

deficiencies in TLMP’s conservation strategy and its implementation with respect to wolves and 

deer, particularly on Prince of Wales and neighboring archipelago of islands (Prince of Wales 

Archipelago). Some of these major deficiencies, many of which I pointed out at the 2006 

Tongass Conservation Strategy Workshop, are: 

a. Wolves in Southeast Alaska are genetically related to those in north coastal 

British Columbia, Canada. 

b. Wolves in the Prince of Wales Archipelago are isolated from all other wolves in 

Southeast Alaska and coastal British Columbia. 
Page 17 	 	

c. The deer density guideline specific to wolves should be applied at the scale of a 

wolf pack home range (300 km2

). 

d. Roads strongly influence wolf mortality by facilitating legal and illegal harvest. 

e. Road density guideline of 0.7 mi/ mi2 needed to be changed such that it includes 

all roads rather than just “open” roads. 

f. Road density guideline should be applied at the scale of a single wolf pack (300 

km/km2). 

g. Lower wolf and deer populations are likely in the future under the current forest 

plan. 

h. OGRs are the only lands that may serve as population sources for wolves, but 

they are too small. 

i. High quality habitat for deer must be maintained within and outside the OGRs. 

j. Social and economic factors will complicate wolf conservation because declining 

deer numbers due to loss of habitat from logging will motivate subsistence 

harvesters to demand predator control for wolves. 

k. Illegal killing of wolves will make it difficult to regulate harvests, and roads will 

exacerbate that problem because they provide easy access to wolves. 

l. OGRs are not sufficiently large to encompass wolf pack home ranges (Person and 

Brinkman 2013). The average home range of wolf packs on the Prince of Wales 

Archipelago is 300 km2

 (115 mi2, [Person and Logan 2012]) or 73,800 acres. The 

largest contiguous OGR in the Prince of Wales Archipelago is 45,000 acres. 

Consequently, no OGRs completely protect any wolf pack within the Prince of 

Wales Archipelago. The Big Thorne DEIS refers to a >200,000 acre Honker-
Page 18 	 	

Sarkar lakes complex, implying a very large single reserve. This is no longer 

accurate because an identified connecting link between the Honker and Sarkar 

Lakes OGRs has been extensively clear-cut logged, most recently under the 

Logjam timber sale, and it is bisected by a major paved highway. Wolves 

frequently are killed by hunters and trappers within that connecting link. 

Individually, neither the Honker nor Sarkar OGRs encompass full wolf home 

ranges. 

m. The term “old-growth” reserve is misleading since reserves may contain as little 

as 50% productive old growth (POG). The liberal criteria used to define POG 

assure that much of it is of little value to deer during a snowy winter. Moreover, 

because of the extensive fragmentation and logging of most of the highest volume 

old-growth forest on the Prince of Wales Archipelago and in some cases the 

gerrymandering of OGR boundaries or locations that has occurred in individual 

logging projects, lands aggregated into OGRs do not necessarily contain the best 

or even adequate winter habitat for deer and hence wolves. They may be some of 

the better lands left after the past 60 years of industrial logging but still be 

inadequate. Indeed, only 36% of the historic (before industrial logging) habitat 

capability for deer (winter carrying capacity during an average snow year) is 

protected within OGRs and other lands deferred from logging (Albert and Schoen 

2007). In addition, a recent analysis of the amount of landscape-scale highvolume old growth on northern Prince of Wales Island has documented that this 

unique forest community (which is important as deer winter range in deep snow 

winters) was reduced by 93.8% from 1954 to 2004 (Albert and Schoen 2013). 
Page 19 	 	

n. Additional flaws in the TLMP wildlife conservation strategy stem from 

limitations in the Forest Service’s deer habitat capability model, which represents 

carrying capacity for deer during an average snow winter. Yet, a single severe 

winter or succession of such winters may determine deer population dynamics for 

many decades after the event, particularly if deer numbers drop very low and 

predation is high. The slow recovery of deer on Mitkof, Kupreanof, and Kuiu 

islands due to extreme winter events in the 1970s and the middle of the last 

decade illustrates this point. Decades after the severe winter snows, deer 

populations are still at levels far below carrying capacity. (Kirchhoff 1994; 

Lowell 2013 (presentation at the January 2013 Board of Game meeting)). To 

calculate the habitat needed for all predictable conditions, the deer model should 

assume deep snow winters instead of average winters. 

o. The TLMP guideline of deer habitat capability ≥18 deer/mi2

 is based on a 

calculation for the Prince of Wales Archipelago that assumed an average annual 

wolf population of 250 animals (Person et al 1996; Person et al. 1997). From a 

biological perspective, the deer guideline is a minimum value relative to 

maintaining resilience of the predator-prey system and, in the case of the Prince of 

Wales Archipelago, the potential to sustain a viable wolf population. If a timber 

sale project results in deer habitat capability below 18 deer/mi2, the likelihood is 

that predator-prey dynamics will become more erratic and the resilience of deer to 

predation, hunting, and winter weather is reduced. In addition, conflict between 

hunters and wolves for deer may increase, resulting in demands by deer hunters 

for predator control and also a heightened illegal take. Indeed, an incremental 
Page 20 	 	

reduction in deer habitat capability likely will result in a much larger effect on the 

predator-prey system owing to the nonlinear dynamics that characterize predatorprey-habitat interactions (Person et al. 2001; Person 2001; Bowyer et al. 2005; 

Person and Brinkman 2013). 

p. Additionally, during the 2006 conservation strategy review, I specifically advised 

the Forest Service that the deer guideline should be applied at the scale of a wolf 

pack home range (300 km2) and not at larger scales such as a biogeographic 

province. This means running the deer model at a scale of one or two wildlife 

analysis areas (WAAs) to best approximate an area the size of a wolf pack’s home 

range. 

35. The Forest Service also failed to account for the degree to which the Prince of 

Wales Archipelago WAAs are highly connected for deer hunter access by the extensive network 

of roads and marine waterways. Hunting effort by individuals from throughout the Prince of 

Wales Archipelago is easily transferable from one area to others as one becomes more depleted 

than others, likely causing a deer deficit in one area to have a far ranging indirect effect, 

weakening the predator-prey system the Prince of Wales Archipelago-wide. Forest Service 

projections that deer and wolf populations will not unduly suffer from major logging projects 

like Big Thorne are further undermined by the lack of accurate information regarding the actual 

state of the road system on Prince of Wales Island, including the Big Thorne project area. 

Roads, for example, can be closed on paper only, without the Forest Service (or other property 

owners) taking any action on the ground to prevent access. In other instances, the physical 

barriers are easily avoided and vehicles, including off-highway vehicles, can continue using the 

road despite the fact it has been listed as “closed”. The lack of information regarding the road 
Page 21 	 	

system (i.e., what roads are open, what is the length of the road and its spurs, what is closed, how 

was it closed, is the closure being maintained, etc.), makes it impossible to fully assess the 

adverse consequences of hunting and trapping access throughout Prince of Wales Island, 

including the Big Thorne project area. 

36. To summarize the effect of TLMP on conservation of wolves, several factors have 

materialized since its adoption in 1997 that were not addressed in the 2008 amendment to the 

plan. These factors invalidate several of the assumptions and inputs relied upon by experts on 

the mid-90s TLMP wolf science panel (and consequently by Forest Service decision makers). 

Nonetheless, the Forest Service continues to rely on outdated outcomes of the wolf panel to 

justify ecologically destructive projects such as Big Thorne and Logjam. These factors were 

discussed above, but briefly they are: (1) the precipitous declines in the numbers of wolves on 

Prince of Wales, (2) new information regarding the levels of illegal take as compared to legal 

take, (3) lack of an accurate road closure inventory, with reported closures often not effective at 

preventing access, and not providing the actual mitigation and/or protections that the Forest 

Service assumed they would when it adopted TLMP, and (4) the scientific knowledge that the 

OGRs simply are not large enough or adequately composed for a viable wolf population. 

This statement is true and accurate to the best of my scientific expertise and knowledge. 

Dated this 15th day of August, 2013. 

David K. Person, Ph.D 
i 

DOCUMENTS CITED IN THE STATEMENT OF DAVID K. PERSON 

Title PR No. 

Albert, D., and J. Schoen. 2007. A conservation assessment for the coastal 

forests and mountains ecoregion of Southeastern Alaska and the Tongass 

National Forest. In The coastal forests and mountains ecoregion of 

southeastern Alaska and the Tongass National Forest: A conservation 

assessment and resource synthesis, edited by J. Schoen and E. Dovichin, 

chapter 2. Anchorage, AK: Audubon Alaska and The Nature Conservancy 

(Albert and Schoen 2007) 

736_2140 

Albert, D., and J. Schoen. 2013. Use of historical logging patterns to identify 

disproportionately logged ecosystems within temperate rainforests of 

southeastern Alaska. Conservation Biology 27:774-784 

(Albert and Schoen 2013) 

Ballard, W. B., J. S. Whitman, C. L Gardner. 1987. Ecology of an exploited 

wolf population in south-central Alaska. Wildlife Monographs 98:1-54 

(Ballard et al. 1987) 

Bowyer, R. T., D. K. Person, and B. M. Pierce. 2005. Detecting top-down 

versus bottom-up regulation on ungulates by large carnivores: Implications 

for conservation of biodiversity. In Large carnivores and the conservation of 

biodiversity, edited by J. C. Ray, K. H. Redford, R. S. Steneck, and J. Berger, 

342-361. Covelo, CA: Island Press (Bowyer et al. 2005) 

736_2241a 

(Greenpeace 

Ex. 30) 

Brinkman, T. J. 2006. The Prince of Wales Island Deer Hunter Project: 

Preliminary Summary of Hunter Responses to Interview Questions.

Community Report, Department of Biology and Wildlife, University of 

Alaska Fairbanks, Fairbanks, Alaska (Brinkman 2006) 

736_443 

Brinkman, T. J., D. K. Person, F. S. Chapin III, W. Smith, and J. 

Hundertmark. 2011. Estimating abundance of Sitka black-tailed deer using 

DNA from fecal pellets. Journal of Wildlife Management 75(1):232-242 

(Brinkman et al. 2011) 

736_481 

Kohira, M., and E. A. Rexstad. 1997. Diets of wolves, Canis lupus, in logged 

and unlogged forests of southeastern Alaska. Canadian Field-Naturalist

111(3): 429-435. Ottawa ON (Kohira and Rexstad 1997)

Lowell, R. E. 2013. Petersburg Management Area. Presentation before 

January 2013 Board of Game meeting, available at 

http://www.adfg.alaska.gov/staticf/regulations/regprocess/gameboard/pdfs/2012-2013/southeast_1-11-

13/tab_5_section_1_petersburg_overview.pdf (Lowell 2013) (excerpts) 
ii 

Person, D. K., M. D. Kirchhoff, V. Van Ballenberghe, G.C. Iverson, and E. 

Grossman. 1996. The Alexander Archipelago wolf: A Conservation 

Assessment. General Tech. Report PMW-GTR-384. Juneau, AK: USDA 

Forest Service (Person et al. 1996) 

736_302 

Person, D. 1997. Letter to Theresa Woods, U.S. Fish and Wildlife Service, re: 

status review for the Alexander Archipelago wolf (Apr. 2, 1997) 

(Person 1997) 

Person, D. K. and R. T. Bowyer. 1997. Population Viability Analysis of 

Wolves on Prince of Wales and Kosciusko Islands, Alaska. Final Report to the 

U.S. Fish and Wildlife Service (Person and Bowyer 1997) 

736_2241a 

(Greenpeace 

submissions, 

scoping 

comments) 

Person, D., M. Kirchhoff, V. Van Ballenberghe, and R. T. Bowyer. Sept. 19, 

1997 Letter to Beth Pendelton, U.S. Forest Service (Letter to Beth Pendelton 

1997) 

736_367 

Person, D. K. 2001. Alexander Archipelago wolves: Ecology and population 

viability in a disturbed, insular landscape. Ph.D Dissertation, University of 

Alaska Fairbanks (abstract only) (Person 2001) 

736_303 

Person, D. K., R. T. Bowyer, and V. Van Ballenberghe. 2001. Density 

dependence of ungulates and functional responses of wolves: Effects of 

predator-prey ratios. Alces 37(2): 253-273 (Person et al. 2001) 

Person, D. K., and A. L. Russell. 2008. Correlates of mortality in an 

exploited wolf population. Journal of Wildlife Management 72:1540-1549 

(Person and Russell 2008) 

736_300 

Person, D. K. Estimating wolf populations in Southeast Alaska using 

noninvasive DNA sampling. Federal Aid Research Project Statement and 

Annual Progress Reports (Person 2009-2012) 

Person, D. K., and B. D. Logan. 2012. A spatial analysis of wolf harvest and 

harvest risk on Prince of Wales and associated islands, Southeast Alaska. 

Final Wildlife Research Report, ADF&G/DWC/WRR-2012-06 

(Person and Logan 2012) 

736_299 

Person, D. K., and T. J. Brinkman, Succession Debt and Roads: Short- and 

Long-Term Effects of Timber Harvest on a Large-Mammal Predator-Prey 

Community in Southeast Alaska. In North Pacific Temperate Rainforests, 

edited by G. H. Orians, and J. W. Schoen. Seattle, WA: University of 

Washington Press (Person and Brinkman 2013) 
iii 

Person, D. K. and K. Larson. 2013. Developing a Method to Estimate 

Abundance of Wolves in Southeast Alaska, Progress Report: 1 January 2013–

31 May 2013 (Person and Larson 2013) 

Person, D. K., 2011. Email messages and maps re: the Big Thorne Project 

(Person ADF&G emails and maps) 

Powell, B. E. 1998. Tongass Forest Plan Implementation Clarification, 

Tongass National Forest News (Aug. 7, 1998) (Powell 1998) (excerpt) 

Puchlerz, T. Directive re: Project Level Environmental Analysis (Aug. 6, 

2002) (Puchlerz 2002) 

Schoen, J. and M. Kirchhoff. 1990. Seasonal habitat use by Sitka black-tailed 

deer on Admiralty Island, Alaska. Journal of Wildlife Management 54:371-

378 (Schoen and Kirchhoff 1990) 

Wallmo, O. C. and J. Schoen. 1980. Response of deer to secondary forest 

succession in southeast Alaska. Forest Science 26:448-462 

(Wallmo and Schoen 1980) 

736_346 

(abstract only) 

Weckworth, B. V., S. Talbot, G. K. Sage, D. K. Person, and J. Cook. 2005. 

A signal for independent coastal and continental histories among north 

American wolves. Molecular Ecology 14:917-931 (Weckworth et al. 2005) 

736_347 
Original Article

Spatially Explicit Analysis of Contributions of

a Regional Conservation Strategy Toward

Sustaining Northern Goshawk Habitat

WINSTON P. SMITH,1 Institute of Arctic Biology, University of Alaska, Fairbanks, 2571-3 Douglas Highway, Juneau, AK 99801, USA

ABSTRACT Setting aside habitat is a common strategy to maintain viable wildlife populations, but

underlying assumptions or effectiveness are rarely evaluated. The Tongass National Forest prioritized habitat

management for sensitive species in Southeast Alaska’s rainforest, and standards and guidelines were

established for northern goshawks (Accipiter gentilis). I used guidelines from other portions of its range

and data from Southeast Alaska, USA, to evaluate the conservation strategy. I used published data and nests

from this study to define choice habitats; published juvenile movements and female use areas were used to

estimate an ‘‘average’’ post-fledging area and female breeding range, respectively. I used nest-tree locations

(n 1⁄4 136) to delineate corresponding virtual post-fledging areas and female home ranges, within which I

calculated acreage of 4 cover-type and 4 land-use categories. About 30% of nests had >51% of post-fledging

areas in choice habitat; 60% of nests had >51% in unsecure (unprotected from development) land-use

designations, whereas 16% had >51% in a protected old-growth designation. The female range was similar to

post-fledging areas, but the proportions predominantly (>75%) available for development (land use that

modifies landscapes) or with 26–50% of total area in choice habitat were larger than post-fledging areas, and

half as many nests had >51% of area in choice habitat. Among cover types, choice habitat averaged 39.4% of

the post-fledging area. These findings increase uncertainty about conservation measures contributing

sufficient habitat to sustain well-distributed, viable populations of northern goshawks throughout

Southeast Alaska and demonstrate the need and feasibility of evaluating assumptions of conservation plans.

 2013 The Wildlife Society.

KEY WORDS Accipiter gentilis, conservation strategy, land-use planning, northern goshawk, population viability,

southeastern Alaska, temperate rainforest.

Maintaining biological diversity, especially viability of endemic organisms, continues to rank high among land-management issues on public (Possingham et al. 1993, Szaro and

Johnston 1996, Iverson and Rene ́ 1997, Smith and Zollner

2005) and private lands (Lindenmayer and Possingham

1996) because wildlife species are valued by many segments

of society (Naess 1986, Catton and Mighetto 1998) and

because persistence of indigenous wildlife populations at

‘‘ecologically effective’’ densities (sensu Soule ́ et al. 2003,

p. 1,239) is a crucial component of healthy ecosystems

(Pimm 1991, Petchey 2000, Pyare and Berger 2003, Soule ́

et al. 2003). Loss or fragmentation of habitats due to human

activity are directly associated with the rapid decay of ecological and evolutionary diversity worldwide (Pereira et al.

2004, Reed 2004). Undoubtedly, global demands for natural

resources will continue to increase and land managers will

experience greater and more complex challenges to safeguarding ecosystem functions (Costanza et al. 1997,

Newton and Freyfogle 2005).

In Southeast Alaska, USA, the Tongass National Forest

responded to challenges of sustaining viable and widely

distributed wildlife populations across the planning area

by developing a comprehensive, regional conservation

plan. The 1997 Tongass Land and Resource Management

Plan established a system of small, medium, and large

reserves to provide large areas of protected, intact old-growth

forest and site-specific standards and guidelines to manage

locally important habitat for sensitive species (U.S. Forest

Service 1997). A fundamental assumption was that lands

managed for timber production would contribute little toward maintaining well-distributed and viable populations

(U.S. Forest Service 1997: appendix N); rather, reserves

and other protected lands would provide sufficient habitat

to sustain indigenous wildlife (Iverson and Rene ́ 1997).

Setting aside essential habitat is a common strategy to

maintain indigenous wildlife in modified landscapes, but

the underlying assumptions or the effectiveness of such

strategies are rarely evaluated (Smith et al. 2011).

Although land-use or conservation plans typically stipulate

long-term effectiveness monitoring of framework elements

and specific measures (U.S. Forest Service 1997: chapter 6),

the costs required to do so often are prohibitive, and

thus monitoring plans rarely are fully implemented (Patla

2005, Smith et al. 2011). More importantly, irreparable

negative impacts can occur before long-term monitoring

uncovers flaws in the underlying conceptual framework, or

Received: 12 June 2012; Accepted: 8 January 2013

1

E-mail: wsmith58@alaska.edu

Wildlife Society Bulletin; DOI: 10.1002/wsb.271

Smith  Assessment of Available Essential Goshawk Habitat 1
in deficiencies in the implementation of specific management

guidelines or conservation measures (Smith et al. 2011).

However, Smith and Person (2007) demonstrated the feasibility and value of evaluating elements and assumptions of

the underlying theoretical framework of a regional conservation plan.

The northern goshawk (Accipiter gentilis) in Southeast

Alaska received special consideration as a ‘‘sensitive species’’

in the revised forest plan (U.S. Forest Service 1997, pp. 4–

89), in part because of concerns over the viability of endemic

Queen Charlotte goshawk (A. g. laingi) populations (Iverson

et al. 1996, Iverson and Rene ́ 1997, U.S. Fish and Wildlife

Service 2007). Standards and guidelines for forest management actions were established using important ecological

aspects of this species’ biology (Iverson et al. 1996). The

1997 standard and guidelines specific to goshawk reproduction stipulated that managers should ‘‘preserve nesting habitat around all confirmed and probable nest sites’’ (U.S. Forest

Service 1997, pp. 4–89) and included several criteria for

identifying nest sites and guidance related to achieving

this objective.

Much of the science used to develop the Tongass standards

and guidelines and policy for managing habitat for northern

goshawks was based on studies conducted elsewhere because

local information was largely unavailable (Iverson et al.

1996). Since 1997, however, considerable effort has yielded

valuable empirical data about the life history, ecology, and

habitat needs of northern goshawks in Southeast Alaska,

especially during the breeding season (Flatten et al. 2001,

Lewis et al. 2006). In addition, there have been numerous

studies and reviews completed throughout its range

(Penteriani 2002, Andersen et al. 2005, Greenwald et al.

2005, Boal et al. 2006). Moreover, reviews and studies in

British Columbia, Canada, have substantially increased our

knowledge about goshawks in temperate rainforests (Cooper

and Stevens 2000; McClaren et al. 2002, 2003, 2005; Mahon

and Doyle 2005, Doyle 2006).

In western North America, the breeding home ranges of

northern goshawks often are represented as a hierarchical

sequence of 3 areas (Andersen et al. 2005), all of which need

to be considered simultaneously in land-use planning or

mitigation (Reynolds et al. 2006, Northern Goshawk

Accipiter gentilis laingi Recovery Team 2008): 1) nest area,

2) post-fledging (family) area, and 3) foraging area. Nest

areas provide alternate nest trees, roost trees, prey-plucking

posts, and serve as centers of essential breeding behaviors

or life-history events (Reynolds et al. 1992, 2006). Postfledging areas surround active nest trees and represent the

core-use area of an adult female and of young goshawks after

fledging but before becoming independent of adults and

dispersing (Kennedy et al. 1994). McClaren et al. (2005)

suggested the biological role of post-fledging areas and

nest areas are similar and therefore it is useful to consider

them as one functional component. Regardless, the habitat

composition (i.e., overstory) of post-fledging areas should

be similar to nest areas (Reynolds et al. 2008). Foraging

areas comprise the majority of northern goshawk breeding

home ranges and are especially important for adults providing food to young and for juveniles prior to natal

dispersal. Adults may have foraging areas that are a considerable distance from nests and may change their foraging

areas seasonally or from 1 year to the next (Titus et al.

1994). Foraging areas generally are large (2,000 ha)

but vary among localities and according to individual

experience, hunting efficiency, food requirements (brood

size), and availability of food within home ranges

(Kennedy et al. 1994). Also, the combined home range of

male and female pairs can be substantially larger than that of

individual birds (Boal et al. 2003). The most imminent

threats to breeding populations are loss or fragmentation

of nesting and foraging habitat, especially reductions in prey

diversity and availability (Reynolds et al. 1992, 2006, 2008;

Finn et al. 2002, McGrath et al. 2003, Salafsky et al. 2007,

Northern Goshawk Accipiter gentilis laingi Recovery Team

2008).

Despite a substantial increase in knowledge since the

revision of the 1997 Tongass Land and Resource

Management Plan, the implications of those new insights

to goshawk conservation and land-use policies in Southeast

Alaska have not been rigorously examined. In particular, it is

unclear whether a system of old-growth reserves designed

explicitly for other wildlife species and protection of goshawk nest trees in landscapes intensively managed for timber

(clearcut logging) would provide sufficient habitat to sustain

breeding populations of the northern goshawk across the

planning area (Finn et al. 2002). The purpose of this study is

to evaluate the underlying framework and assumptions of

the Tongass conservation strategy to sustain well-distributed, breeding populations of a species whose home range

encompasses entire watersheds and whose life history in

Southeast Alaska appears to require vast amounts of oldforest habitat (Iverson et al. 1996). To accomplish this, I

undertook a spatially explicit analysis that quantified contributions of the 1997 Tongass conservation strategy

toward sustaining suitable habitat in 2 essential components

of northern goshawk breeding pairs’ home ranges: postfledging area and breeding home range of females.

Specific objectives were to 1) use the findings of habitatuse analyses from Southeast Alaska (Iverson et al. 1996) in

conjunction with the observed habitat composition of nest

sites to identify choice habitat for nest areas; 2) use juvenile

post-fledging movements to estimate the radii of circular,

virtual post-fledging areas and broader landscapes represented by the median 90% minimum convex polygons

breeding home range (‘‘use areas,’’ Iverson et al. 1996) of

females; 3) quantify contributions (total acreage) of the

Tongass conservation elements to conserving secure (protected from development) habitat in projected goshawk

post-fledging area and female breeding home ranges; 4)

compare the cover-type composition of virtual post-fledging

areas with the observed composition of nest sites in

Southeast Alaska and to published recommendations for

post-fledging area composition (Reynolds et al. 1992,

2006, 2008); and 5) classify projected northern goshawk

post-fledging and breeding home ranges according to the

extent (percentage categories) that the habitat composition

2 Wildlife Society Bulletin
approached recommended guidelines or the observed percentages of habitat types among nest sites in Southeast

Alaska.

STUDY AREA

The Tongass National Forest encompassed about 95% of

southeastern Alaska; this included the Alexander

Archipelago with thousands of islands, and a narrow mainland region that extended from Dixon Entrance (548300

N

latitude) to the Malaspina Glacier (598450

N latitude; U.S.

Forest Service 1997). The Tongass was unique among national forests in several ways (Everest et al. 1997), including a

dynamic geological history, naturally fragmented and isolated landscapes, and extraordinary environmental complexity

(MacDonald and Cook 1996).

Southeastern Alaska had glaciated mountain ranges and

fjords, and a cool, wet (200- to 600-cm precipitation) maritime climate with mean monthly temperatures ranging from

138 C in July to 18 C in January (Searby 1968). About

4 million ha (60%) was forestland (U.S. Forest Service

1997), of which 2.2 million ha was productive forests

(Julin and Caouette 1997). Coniferous rainforest dominated

the landscape from shoreline to about 600 m elevation, with

approximately 90% of productive forests in Sitka spruce

(Picea sitchensis)—western hemlock (Tsuga heterophylla) forests, which typically are the old-growth forests of upland

sites; remaining areas were alpine, muskeg, or riparian

(Hutchinson and LaBau 1974). Unmanaged forests typically

had a multi-layered overstory of uneven-aged trees, dominant trees that generally were >300 years old, and extensive,

structurally diverse understories (Ver Hoef et al. 1988).

These forests varied in structure from ‘‘scrub’’ or low-volume

communities of short (<10 m), small (<0.5-m diam) trees

with open canopies and dense, shrubby understories on

poorly drained sites (peatland), to highly productive sites

that supported high-volume stands with a closed canopy; tall

(>60 m), large (>3-m diam) trees; and a predominantly

herbaceous understory (Harris and Farr 1974, Alaback

1982). The Tsuga–Picea forest type constitutes most of the

closed-canopy forests in the region (Alaback 1982). It was

spatially heterogeneous at a fine scale—<1 ha (Schoen et al.

1984)—and typically occurred on low elevation, well-drained

sites, frequently as a mosaic with muskegs (Neiland 1971).

The primary disturbance was wind, with infrequent (100–

200 yr) catastrophic windstorms blowing down tens to hundreds of hectares of old-growth rainforest, which produced

relatively homogeneous, naturally regenerated second

growth with dense canopies (i.e., wind-originated stands;

Nowacki and Kramer 1998). More frequent, but less severe,

windstorms blow down one or a few trees, which produces

gap-phase old-growth stands with more fine-scale heterogeneity and much larger and older trees (Alaback 1982).

METHODS

Discerning Post-Fledging Area Habitat

I used the 2003 geographic information system (GIS)

database of northern goshawk nest-tree locations obtained

during 1989–2003 from annual surveys of nests conducted by

the Tongass National Forest, Alaska Department of Fish and

Game, and U.S. Fish and Wildlife Service (Flatten et al.

2001). Some nests were found by tracking radiocollared

goshawks, coincidentally while conducting other fieldwork

(e.g., timber sale surveys), or from reports by individuals

recreating on the National Forest (Iverson et al. 1996). I

updated the 2003 database with new nest trees obtained from

surveys conducted through July 2005 by the Tongass

National Forest and cooperators. Because many goshawk

nests were located during timber-sale surveys or layout

(Iverson et al. 1996), the relative amount of high- and

medium-volume old growth distributed among land-use

designations might have been biased toward the

Development category (lands available for timber production

and other uses that modify landscapes) as compared with a

random sample collected across the region (Daw et al. 1998).

However, Schempf et al. (1996) used standardized protocols

to survey 724 points within 62 plots across 67 km2 of roadless

areas in Southeast Alaska. They recorded responses from

only a single adult goshawk and concluded that the much

lower (order of magnitude) detection rate (compared with

similar surveys in other portions of this species’ range) suggested a low density and widely dispersed goshawk population across the sampling area.

The desired condition of a post-fledging area is habitat

composition similar to the nest area (Reynolds et al. 1992,

McClaren et al. 2005). Therefore, I identified habitat for

post-fledging areas by averaging the composition of cover

types (e.g., old-growth forest, muskeg, managed forest)

within nest areas of previously occupied nest sites in the

region. Post-fledging area habitat was delineated according

to the findings of an analysis of habitat selection during the

breeding season that compared the proportion of radiotelemetry locations in each habitat type with the proportion that

each corresponding habitat type comprised in ‘‘use areas’’

represented by 100% minimum convex polygons (Iverson

et al. 1996). During the breeding season, goshawks selected

high-volume (forest-wide mean  95% CI 1⁄4 201.5 

4.7 m3

/ha) and medium-volume (146.2  4.5 m3/ha) strata

old-growth forests (Julin and Caouette 1997). Mature sawtimber (75- to 150-yr second growth), low-volume

(91.5  4.5 m3

/ha), and scrub forests (<76 m3/ha) received

much less use, which did not differ from that expected

according to availability; clearcut (approx. 0–40 yr) and

non-forest cover types were avoided. Because nest areas

typically are 10- to 12-ha areas immediately surrounding

the nest site (Reynolds 1983; Reynolds et al. 1992, 1994), I

used a 10.5-ha nest area to accomplish English GIS queries.

To discern available vegetation community types comprising goshawk habitat, I overlaid the location of each nest tree

on a 2003 Tongass National Forest data layer of forest stand

volume and totaled the area within each polygon that represented a unique volume strata of old-growth forest (low,

medium, high). I summed total area of each stratum to

determine relative composition of a nest area, centered on

the nest tree, and to determine the frequency distribution of

nest areas by low-, medium-, or high-volume old-growth

Smith  Assessment of Available Essential Goshawk Habitat 3
forest. Because the vast majority of second-growth was <50

years old (Barbour et al. 2005), mature sawtimber represented a very small (approx. 1%) component of the forested

landscape. Scrub forests are peatlands with little or no forest

canopy (Harris and Farr 1974). None of the 136 nests were in

sawtimber or scrub forests. Therefore, I assumed that medium- or high-volume old-growth forests provided the resources needed by northern goshawks during the breeding season

based on the previous findings of habitat selection (Iverson

et al. 1996) and because nest trees were invariably in medium- or high-volume old-growth stands.

Composition of Virtual Areas

To determine contributions of the Tongass conservation

strategy toward meeting breeding-season habitat objectives,

I estimated the size of a post-fledging area in Southeast

Alaska according to concepts in Kennedy et al. (1994),

the behavior of post-fledged juveniles (Kenward et al.

1993), and published data on juvenile movements during

the post-fledging period (Iverson et al. 1996). I used 1,600 m

to estimate the average limit of all movements of postfledged juveniles because this was assumed to be the distance

that defined when juveniles were undertaking post-fledging

movements (Kenward et al. 1993) and because 23 of 28

juvenile goshawks monitored with radiotelemetry in

Southeast Alaska moved 1,600 m (Iverson et al. 1996). I

then used this estimate of distance moved during the postfledging period as the radius of circular areas centered on a

nest to represent an ‘‘average post-fledging area.’’ I used the

median home range (90% mononuclear probability polygon;

Iverson et al. 1996) of adult females during the breeding

season (21 km2

) to delineate broader landscapes that comprised essential foraging habitat (Reynolds et al. 1992, 2006,

2008). Because goshawk males typically do most of the

hunting during the nesting period (Kenward 1982), this

approach assumes that the male’s breeding-season range,

which averaged about 50% larger than females, did not differ

substantially in habitat composition. I overlaid each nest’s

virtual post-fledging area and breeding home range on GIS

layers of cover types and land-use designations based on

stand volume and management history. The area within

each polygon that represented a unique land-use description

was summed to determine relative composition of 4 land-use

categories: Development—lands available for timber production and other uses that modify landscapes; NonNational Forest lands; Natural Setting—lands that maintain

a natural setting, such as wild and scenic rivers and remote

recreational areas; and Old Growth—protected old-growth

forests. The same procedure was used to determine composition of 4 cover types: Habitat—high or medium-volume

old-growth forests; Low—low-volume old-growth forests;

Clearcut—all lands harvested between 1954 and 2005; Nonforest—all lands that do not support productive forests (Julin

and Caouette 1997). The extent to which the female home

range and post-fledging area differed in composition served

as a metric of landscape heterogeneity that also provided

insights about the sensitivity of this analysis to sampling error

and the likelihood that habitat composition of male breeding

ranges differed from females. Results are presented as separate summaries of average land-use designation or cover-type

composition for post-fledging areas and seasonal home

ranges.

RESULTS

Nest Area and Habitat

I determined habitat used by goshawks for the post-fledging

area analysis using the habitat composition of 136 nest areas

across the Tongass National Forest: overall, 100% of the nest

trees were in productive (low-, medium-, or high-volume)

old-growth forests, which comprised 66.1% (SD 1⁄4 0.05) of

goshawk nest areas. The remainder of nest areas was in scrub

forests (fens), non-forested areas (muskegs), or regeneration

stands following clearcut logging. A total of 58 nest areas

primarily (>50%) consisted of high-volume old growth; 57

and 15 nest areas primarily consisted of medium- and lowvolume old growth, respectively. Six nest areas did not

contain any old-growth forest; according to notes in the

database file, those nest trees were located in portions of

the forest that were clearcut-logged after a breeding pair had

selected a nest tree. If nest trees on clearcut sites or near a

natural feature creating an abrupt forest edge (e.g., shoreline)

were excluded (n 1⁄4 11), mean proportion of productive oldgrowth forest in nest areas was 0.712 (SD 1⁄4 0.041). The

mean proportions of volume strata in the remaining

nest areas (n 1⁄4 125) were 0.097 (SD 1⁄4 0.025), 0.283

(SD 1⁄4 0.039), and 0.289 (SD 1⁄4 0.039) for low-, medium-, and high-volume forests, respectively. Based on the

habitat at 125 nest sites and within corresponding nest areas

and on the findings of a previous habitat selection study

(Iverson et al. 1996), I refer to medium- or high-volume old

growth in virtual areas below as ‘‘choice habitat.’’

Land-Use Designation and Habitat Composition of

Virtual Areas

The composition of land-use designations of an average

post-fledging area contained a relatively large proportion

of Development (land uses that modify landscapes) lands,

with >30% of all nest areas having >91% of the postfledging area as lands available for timber production

(Fig. 1a; Appendix A). Cover-type composition of postfledging areas contained a relatively large proportion of

non-forest cover types (Fig. 1b). About 30% of the nests

had >51% (i.e., 51–75%, 76–90%, or >90%) of the corresponding post-fledging area in medium- or high-volume old

growth (choice habitat); 51% of nests had 26–50% of the

post-fledging area in choice habitat. Most (60%) of this

choice habitat was in the Development land-use designation

or Non-National Forest designation (Fig. 1a); 16% of the

nests had >51% of the post-fledging area in the Old-Growth

land-use designation, with the remainder in Natural Setting.

Across all nest areas, the Old-Growth land-use designation

averaged 14.8% (100 ha; SE 1⁄4 4.6) of the total post-fledging area acreage. Development, Non-National Forest, and

Natural Setting averaged 41.1% (278 ha; SE 1⁄4 7.6), 13.5%

(91 ha; SE 1⁄4 4.6), and 27.2% (184 ha; SE 1⁄4 6.9), respectively. Among cover types, choice habitat averaged 39.4%

4 Wildlife Society Bulletin
(266 ha; SE 1⁄4 9.3) of the post-fledging area; low volume

forest, clearcut, and non-forest lands averaged 8.3% (56 ha;

SE 1⁄4 2.6), 3.9% (27 ha; SE 1⁄4 1.5), and 45.0% (304 ha;

SE 1⁄4 10.3), respectively.

Similar results were obtained from an analysis of the female

breeding home range, but with 3 notable differences. The

percentage of this broader landscape that consisted predominantly (>75%) of lands available for development was greater than in post-fledging areas (Fig. 2a; Appendix A). The

percentage of the total area with 26–50% of the total area in

choice habitat also increased in comparison with the postfledging area, whereas about half as many nests had 51% of

this broader landscape in choice habitat as compared with the

post-fledging area (Fig. 2b).

DISCUSSION

The 1997 Tongass Land and Resource Management Plan

included multiple conservation measures to maintain habitat,

with a goal of sustaining viable and widely distributed populations of indigenous wildlife throughout the planning area.

Although some elements of the 1997 Tongass Land and

Resource Management Plan have undergone revision, the

wildlife conservation strategy remains largely unchanged

(Smith et al. 2011). Individual species, such as the northern

goshawk, received specific conservation measures to reduce

viability risks (Iverson et al. 1996). According to the conservation assessment, implementation of the 1997 Tongass

Land and Resource Management Plan for 100 years would

result in ‘‘a moderately high likelihood of providing the

amount and distribution of habitats to sustain long-term

well distributed viable populations of goshawks throughout

the Tongass’’ (U.S. Forest Service 1997: appendix N38).

This long-term projection, an inherent assumption of the

conservation strategy, was based on analyses at multiple

spatial scales (U.S. Forest Service 1997). This study used

contributions of various elements of the conservation strategy

b Post-fledging area – cover type

0%

10%

20%

30%

40%

50%

60%

70%

80%

Habitat Low Clearcut Non-forest.

Cover type

0–5%

6–25%

26–50%

51–75%

76–90%

91–100%

a Post-fledging area – LUD

0%

10%

20%

30%

40%

50%

60%

70%

80%

Development NNF Natural OG

Land-use designation

Mean percent occurrence of relative frequency

0–5%

6–25%

26–50%

51–75%

76–90%

91–100%

Mean percent occurrence of relative frequency 

Figure 1. Mean percent occurrence of relative frequency (%) categories of

land-use designations (a) and cover types (b) in 136 virtual northern goshawk

(Accipiter gentilis) post-fledging areas (800 ha) in Southeast Alaska, USA.

Total area was calculated from an estimate of the average post-fledgling

movements (1,600 m), which served as radius of a circular area.

Development 1⁄4 lands available for timber production and other uses that

modify landscapes; NNF 1⁄4 non–national forestlands; Natural 1⁄4 lands that

maintain a natural setting, such as wild and scenic rivers and remote recreational areas; and OG 1⁄4 protected old-growth forests. Cover types:

Habitat 1⁄4 high- or medium-volume old-growth forests; Low 1⁄4 lowvolume old-growth forests; clearcut 1⁄4 all lands harvested between 1954

and 2005; Non-forest 1⁄4 all lands that do not support productive forests

(Julin and Caouette 1997).

a Home range – LUD

0%

10%

20%

30%

40%

50%

60%

70%

80%

Development NNF Natural OG

Land-use designation

0–5%

6–25%

26–50%

51–75%

76–90%

91–100%

b Home range – cover type

0%

10%

20%

30%

40%

50%

60%

70%

80%

Habitat Low Clearcut Non-forest

Cover type

0–5%

6–25%

26–50%

51–75%

76–90%

91–100%

Mean percent occurrence of relative frequency Mean percent occurrence of relative frequency 

Figure 2. Mean percent occurrence of relative frequency (%) categories of

land-use designations (a) and cover types (b) in virtual female breeding home

ranges (2,100 ha) encircling 136 northern goshawk (Accipiter gentilis) nest

sites in Southeast Alaska, USA. Total area was calculated from an estimate of

goshawk movements (2,600 m), which served as radius of a circular area.

Land-use designations: Development 1⁄4 lands available for timber production and other uses that modify landscapes; NNF 1⁄4 Non-National Forest

Lands; Natural 1⁄4 lands that maintain a natural setting, such as wild and

scenic rivers and remote recreational areas; and OG 1⁄4 protected old-growth

forests. Cover types: Habitat 1⁄4 high- or medium-volume old-growth forests; Low 1⁄4 low-volume old-growth forests; clearcut 1⁄4 all lands harvested

between 1954 and 2005; Non-forest 1⁄4 all lands that do not support forests

(Julin and Caouette 1997).

Smith  Assessment of Available Essential Goshawk Habitat 5
to biological components of the breeding range centered on

specific nest sites. This approach allowed an examination of

the underlying assumption that the 1997 Tongass Land and

Resource Management Plan provides habitat needed to sustain breeding populations of goshawks across the planning

area. Productive old-growth forests unavailable for timber

harvest were used frequently by northern goshawks and ‘‘thus

the contribution of these habitats must be included in an

assessment of overall risk to sustainability of goshawk habitat’’ (U.S. Forest Service 1997: appendix N38).

Standards and guidelines prescribed for protection of goshawk nest areas (40 ha) in Southeast Alaska are unlikely to

meet breeding-season habitat objectives established for goshawk populations elsewhere (Reynolds et al. 1992,

McClaren et al. 2005). The expectation that, in landscapes

managed intensively for timber products, habitat contributed

by other elements of the Tongass conservation strategy (e.g.,

old-growth reserves) will mitigate this deficiency was not

supported by my analysis. An ideal northern goshawk home

range consists entirely of older forests with small, dispersed

openings (Reynolds et al. 2006, 2008). Guidelines for the

composition of post-fledging areas stipulate that ‘‘the majority (60%)’’ of a post-fledging area should be in forest of older

age classes (Reynolds et al. 1992, p. 23), which continues to

be corroborated by further study in other portions of this

species’ range (Daw and DeStefano 2001), including temperate rainforests (McClaren et al. 2005). In my study, nest

areas averaged 71% productive old growth; 58% of the nest

area consisted of medium- or high-volume old growth.

Before logging, landscapes across Southeast Alaska likely

were similar in composition to current nest areas (U.S.

Forest Service 1997). At the time of my study, only about

one-third of 136 virtual post-fledging areas contained >51%

choice habitat. More importantly, the average composition

of ‘‘unsecure’’ (i.e., Development or Non-National Forest

land-use designations) habitat was 55%, and 60% of all postfledging areas consisted of >51% unsecure habitat.

Regardless of whether I compare these results with guidelines from the southwestern United States or the habitat at

nest sites and in nest areas of Southeast Alaska (i.e., desired

future condition of goshawk post-fledging areas; Reynolds

et al. 2008), the observed composition of post-fledging areas

was less than the minimum recommended or desired amount

of habitat.

This conclusion differs from a general forest-wide habitat

availability assessment (i.e., not linked to specific goshawk

nest sites) based on analyses at multiple spatial scales (U.S.

Forest Service 1997: appendix N43). I believe the disparity

can be explained by differences in scale and biological relevance (i.e., linked to specific life-history needs; Reynolds

et al. 2006) of analyses between this study and previous

analyses (Iverson et al. 1996, U.S. Forest Service 1997:

appendix N38). Some of the analyses cited in the summary

appraisal were at a regional scale (forest-wide) and spatially

neutral. For example, the conclusion that 95% of the northern goshawk range in the region has a high likelihood of

sustaining habitat because 93% of the forests would have

<47% of productive old-growth harvested over the planning

horizon provides little spatially explicit information about

breeding-season habitat, especially for populations occurring

on islands. Also, results of stand-level analyses cited in the

summary largely focused on aspects of forest management

that were not immediately relevant to the life-history needs

of breeding pairs. Conclusions that only a small percentage of

nest areas examined had experienced any logging or that only

a small proportion of nest areas were harvested says little

about breeding-season habitat or resources available to

breeding pairs, especially across the broader landscape.

Intermediate-scale analyses and protective measures, such

as limiting total harvest to 33% of a watershed during

the planning horizon (effectively a 300-yr rotation), are

spatially explicit and potentially have biological relevance

(i.e., approximate size of goshawk home ranges).

However, management guidelines not explicitly coupled to

northern goshawk breeding ranges or life history are at risk of

not meeting habitat needs of individual breeding pairs

(Reynolds et al. 2006, Northern Goshawk Accipiter gentilis

laingi Recovery Team 2008).

At the time of the summary assessment (U.S. Forest

Service 1997), about 5% (35/678) of the watersheds exceeded

the stipulated threshold of total harvest, with 33–47% of the

total available productive old-growth forests already harvested; 26 of those (74%) were concentrated in one

Biogeographic Province (North Prince of Wales Island).

The assessment acknowledged the higher risks of exceeding

watershed thresholds of total harvest, especially across North

Prince of Wales Island, but assumed that large reserves in

those landscapes would mitigate the habitat loss from excessive timber harvest. The findings of this study suggest that

contributions of old-growth reserves and other conservation

elements (e.g., riparian or shoreline buffers) might not mitigate the cumulative habitat loss in intensively managed

landscapes. This conclusion is supported by evidence on

nearby islands that extensive loss and fragmentation of habitat from clearcut logging contributed to population declines

of Queen Charlotte goshawks (Doyle 2006).

The threshold composition of suitable habitat to ensure

successful breeding by goshawks in Southeast Alaska is

unknown. To gain this knowledge requires extensive monitoring and research that chronicles reproductive histories of

individual breeding pairs and links fitness to nesting habitat

condition (Patla 2005, Reynolds et al. 2005, Salafsky et al.

2007). Still, the findings of this study increase uncertainty

that northern goshawk breeding-season habitat objectives

are being met in managed landscapes of Southeast Alaska.

Two lines of reasoning support this conclusion.

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

6 Wildlife Society Bulletin
landscape has been clearcut-logged and half the remaining

choice habitat is in the Development land-use designation

available for timber harvest. The potential for second-growth

stands to become useable habitat (mature sawtimber) over

the Tongass planning horizon is limited because unmanaged

second growth typically requires 300 years following disturbance to develop old-forest features (Nowacki and

Kramer 1998). Active management can hasten the development of old-forest condition, but pre- and commercial thinning has occurred in only about 30% of 267,000 ha that have

been harvested across the region (Barbour et al. 2005).

Secondly, guidelines developed for northern goshawk populations in the southwestern United States may underestimate habitat needed by breeding pairs in Southeast Alaska. A

critical consideration in conserving habitat to support breeding populations is sufficient habitat to sustain prey resources

(Reynolds et al. 2006; Salafsky et al. 2005, 2007). Despite

possible differences in life history or ecology across the range

of northern goshawks, the nesting and foraging habitat of

successful breeding pairs must support adequate prey populations. 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, Russell 1999; Smith et al.

2001, 2004, 2005). Consider further that the mammal fauna

of Southeast Alaska is depauperate (MacDonald and Cook

1996); 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 (Beier and Drennan 1997). 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 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 life-history needs was reflected in the findings of

compositional analyses and radiotelemetry 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 (Iverson et al.

1996).

PLANNING AND MANAGEMENT

IMPLICATIONS

Management guidelines for northern goshawks in the southwestern United States recommend active management of the

entire planning area to regenerate forests as well as provide

nesting and foraging habitat. Despite insufficient local information to prescribe the design of a reserve-based approach

to sustain northern goshawks, a hierarchical system of habitat

reserves became the cornerstone of the TLMP wildlife conservation strategy to sustain viable and well-distributed populations across Southeast Alaska. This was to a large part a

result of having to consider the risk to viability of multiple

species for which there was more theoretical or empirical

evidence that habitat reserves would sustain viable populations. Because additional conservation measures were incorporated at multiple spatial scales in the 1997 TLMP to

provide sufficient nesting and foraging habitat for northern

goshawks, the conservation strategy for northern goshawks

in southeastern Alaska became a composite of conservation

measures superimposed on a conceptual framework developed for other vertebrate species of concern.

More 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 across a significant portion of its range.

However, applying these concepts to temperate rainforests

and to a planning area that differs markedly in natural

history, forest type, landscape structure, and management

history requires a thorough understanding of differences and

similarities in goshawk behavior and ecology among regions.

Still, managing for uncertainty and avoiding the risk of

trending the population downward can be improved by using

biological concepts applied elsewhere to sustain northern

goshawk habitat and populations throughout southeastern

Alaska. The nuances of local ecological variability and subsequent refinement of management guidelines can be uncovered with additional field study. Meanwhile, biologists and

land managers may want to consider ecological consequences

to northern goshawk populations (and associated ecological

communities) of potential habitat deficiencies in managed

landscapes across the region. Planners and managers may

want to revisit assumptions that current standards and guidelines and other conservation measures provide sufficient

breeding season habitat to sustain viable and widely distributed goshawk populations. In the interim, project planning

and land use management can be used to increase the longerterm security of preferred habitat (e.g., deferred harvest) or

improve (e.g., thinning) marginal or unsuitable habitat in

managed landscapes, especially across the North Prince of

Wales Island Biogeographic Province.

Conservation plans rely on setting aside essential habitat to

assure viability of indigenous wildlife communities in intensively developed landscapes. More often than not, little local

information exists upon which to develop a sound conceptual

framework or identify effective conservation measures. Thus,

land-use planning frequently relies on biological data from

other regions or incorporates multiple assumptions, many of

which lack an underlying empirical or theoretical foundation.

Determining the effectiveness of a conservation strategy is a

daunting task, requiring long-term habitat and wildlife population monitoring. However, shorter term evaluations are

possible and desirable to scrutinize underlying assumptions,

identify deficiencies, refine elements and procedures, and

prevent irreparable negative effects, should a conservation

plan depend on long-term monitoring.

ACKNOWLEDGMENTS

I conducted this study and submitted this article for internal

technical and policy review while employed as a research

wildlife biologist with the U.S. Forest Service, Pacific

Smith  Assessment of Available Essential Goshawk Habitat 7
Northwest Research Station. The manuscript was approved

for submission and subsequently submitted following my

retirement. The Tongass National Forest funded the study.

N. Crumley conducted the GIS queries that produced the

results of my spatially explicit analysis of nest areas and

virtual post-fledging areas and breeding home ranges. I

also thank C. Rose and the biologists on the ranger districts

of the Tongass National Forest, especially G. Ith, all of

whom assisted with updating the northern goshawk nest

database. C. Crocker-Bedford, D. Boyce, M. Goldstein,

T. Hanley, G. Hayward, C. Iverson, M. Raphael, R.

Reynolds, L. Suring, and K. Titus reviewed early drafts of

this manuscript and provided useful comments. I greatly

appreciate the reviews of V. Penteriani, R. Steidl, and C.

Boal, all of whom offered comments that ultimately improved the quality of this contribution.

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southeastern Alaska. Journal of Mammalogy 85:540–551.

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Associate Editor: Boal.

Smith  Assessment of Available Essential Goshawk Habitat 9
Appendix A. Percentage of relative frequency (%) classes of 4 land-use designations (LUD) and 4 cover types in 2 types of ecological areas encircling 136

northern goshawk (Accipiter gentilis) nest sites in Southeast Alaska, USA. The radius of the post-fledging area (PFA) is based on the average movement

(1,600 m) and the radius of the broader landscape is based on the average use area (90% mononuclear probability polygon) of radiocollared adult female goshawks

during the breeding season (Iverson et al. 1996).

Ecological areas LUD composition (%) Cover-type composition (%)

Percentage categories Development NNF Natural OG Habitata Low-volume old growth Clearcut Nonproductive forest

PFA

0–5 46 75 52 71 1 46 68 1

6–25 5 4 9 7 18 47 29 13

26–50 7 4 15 6 51 7 3 47

51–75 7 13 4 8 23 0 0 33

76–90 4 1 2 1 7 0 0 6

>90 32 3 17 7 0 0 0 1

Total 100 100 100 100 100 100 100 100

Home range

0–5 37 74 38 56 1 46 68 0

6–25 6 7 19 21 19 54 30 7

26–50 13 9 17 14 63 1 2 35

51–75 10 9 7 7 15 0 0 50

76–90 13 1 4 1 3 0 0 7

>90 21 1 15 1 0 0 0 0

Total 100 100 100 100 100 100 100 100

a Medium- or high-volume strata old-growth rainforest (Iverson et al. 1996).

10 Wildlife Society Bulletin
Big Thorne Project – Comments

Winston P. Smith, Ph.D.

I begin my comments by challenging the statement in the Summary on page S3,

last paragraph, line 1 of SDEIS Volume 1: “All action alternatives to the proposed

action are consistent with the Forest Plan.” The evidence I offer (below) in

support of this challenge comes from data and analyses published in multiple

peer-reviewed journal articles on the Prince of Wales (POW) flying squirrel

(Glaucomys sabrinus griseifrons) cited below and a blind peer reviewed

completion report (attached) and a similar paper recently accepted for publication

with an international peer-reviewed journal regarding contributions of TLMP to

breeding season habitat for the northern goshawk (Accipiter gentilis) in southeast

Alaska. The basis of this challenge is that the Forest Plan is supposed provide

sufficient habitat to maintain viable and well-distributed wildlife populations, with

special consideration of endemic small mammals (Appendix N; USDA Forest

Service 1997) and the sensitive Queen Charlotte goshawk (Chapter 4;USDA

Forest Service 1997). Below, I present findings that support the conclusions that

existing habitat and landscape condition do not support 1) functionally connected

populations of POW flying squirrels without which viable populations will unlikely

persists on north POW; nor 2) sufficient nesting and foraging habitat for northern

goshawk breeding pairs.

POW flying squirrel

Smith and Nichols (2003) and Smith et al. (2005) demonstrated that productive

old-growth forest (POG) is the primary habitat of the POW flying squirrel.

Although squirrels do occur in non-commercial forests these habitats are sinks

and do not support breeding populations. Managed habitats (i.e., recent clearcuts

and second-growth) do not support flying squirrel populations and empirical

evidence indicates that regenerating forest patches ≤40 yrs. old are selected

against at the broader scale (Shanley et al. 2012); flying squirrels rarely even use

those habitats (Smith 2012). Thus, across managed landscapes POG is the only

cover type that supports breeding populations of POW flying squirrels. Habitat

patches require ≥73% old-growth forest cover or a minimum total area of 73 ha

(170 acres) of old-growth forest to be even occupied by flying squirrels (Shanley

et al. 2012). To sustain isolated breeding populations for an extended period (50

years) with a high probability (0.95), old-growth reserves need to be over 5000

ha (12,500 acres) and comprised of 100% POG); the existing small OGRs

(designed for flying squirrels; USDA Forest Service 1997) have about an 80%

probability of supporting flying squirrel populations for 50 years (Smith and

Person 2007). Smith and Person also reported that flying squirrels were not

captured in a 40-ha (100 acre) patch of POG on Kosciusko Island that was

surrounded by managed forest (40 years), whereas a similar amount of effort

captured several squirrels in a nearby large (several thousand acres) POG patch.

The proposed Big Thorne project area (and except for Honker Divide, all of north

POW) is highly fragmented with few (if any) large (>10,000 acres) patches of

100% POG habitat. Thus, there are few (if any) OGRs or any POG habitat
6 November 2012 Big Thorne Project Comments – Winston P. Smith Ph.D. 2

patches (except Honker Divide) in the Big Thorne Project area (and all of north

POW) that likely can support POW flying squirrel populations in isolation (Smith

et al. 2011). Any further logging of POG will further reduce the size of existing

POG habitat patches, further fragment the landscape, and thus increase the risk

of extinction in managed watersheds across north POW.

Because of their findings, Smith and Person (2007) concluded that POW flying

squirrel populations across north POW need to be functionally connected (matrix

is permeable to dispersal) to ensure viable populations in managed landscapes.

However, several studies demonstrated that flying squirrels are unlikely to move

through young second growth because they cannot perceive POG (while in

second growth) beyond 50 m from the POG forest edge (Flaherty et al. 2008),

and food availability in managed habitats is significantly less than POG (Flaherty

et al. 2010a). Also, POW flying squirrels are unable to move efficiently and safely

through managed habitats because the forest structure does not allow them to

use their primary mode of locomotion (Scheibe et al. 2006), it costs flying

squirrels more than twice the energy to run than glide (Flaherty et al. 2010b), and

flying squirrels experience more predator attacks in managed habitats (most in

clearcuts) than POG (Smith 2012). An experimental study demonstrated that it

takes POW flying squirrels 10 X more time to move through clearcuts than POG

(Smith et al. 2011), increasing the time 10-fold in which they are exposed to

higher predator attacks and require more food to offset higher energy costs of

transportation in habitats with less food (Flaherty et al. 2010a,b). The result of all

of this is that young squirrels have a very low probability of natal dispersal in

managed landscapes of north POW and more than 50% of the POG habitat

patches (OGRs, stream and shoreline buffers, OG LUD, etc.) are not functionally

connected (Smith et al. 2011). The proposed actions in the Big Thorne Project

will further fragment and isolate POG patches and POW flying squirrel

populations, all of which will increase the risk of extinction in managed

watersheds of north POW. Moreover, because of obligate or facultative symbiotic

relationships between POW flying squirrels and multiple members of its forest

community (Smith 2012), significant biodiversity is also at risk.

Northern Flying Squirrel References (chronological)

Smith, W. P. 2012. Sentinels of ecological processes: The case of the northern

flying squirrel. BioScience 62(11): November.

Holloway, G. L., W. P. Smith, C. B. Halpern, R. A. Gitzen, C. C. Maguire, and S.

D. West. 2012. Influence of forest structure and experimental green–tree

retention on northern flying squirrel (Glaucomys sabrinus) abundance.

Forest Ecology and Management 285:187-194.

Shanley, C. S., S. Pyare, and W. P. Smith. 2012. Landscape requirements of

an ecological indicator: implications for functional units of temperate

rainforest ecosystems. Ecological Indicators http://dx.doi.org/

10.1016/j.ecolind.2012.05.027 (2013, 24:68-74).

Smith, W. P. 2012. Flying squirrel demography varies between island
6 November 2012 Big Thorne Project Comments – Winston P. Smith Ph.D. 3

communities with and without red squirrels. Northwest Science 86:27-38.

Smith W. P., D. K. Person, and S. Pyare. 2011. Source-sinks, metapopulations,

and forest reserves: conserving northern flying squirrels in the temperate

rainforests of Southeast Alaska. Pages 399 – 422 in Chapter 19. Sources,

Sinks, and Sustainability across Landscapes (J. Liu, V. Hull, A. T. Morzillo,

and J. Wiens, editors). Cambridge University Press.

Holloway G, and W. P. Smith. 2011. A meta-analysis of forest age and

structure effects on northern flying squirrel densities. Journal of Wildlife

Management 75(3):668–674; 2011; DOI: 10.1002/jwmg.77.

Pyare, S., W. P. Smith, and C. Shanley. 2010. Den selection by northern flying

squirrels in fragmented landscapes. Journal of Mammalogy 91:886-896.

Flaherty, E. A., M. Ben-David, and W. P. Smith. 2010a. Diet and food

availability of the endemic Prince of Wales flying squirrel (Glaucomys

sabrinus griseifrons) in Southeast Alaska: implications for dispersal across

managed landscapes. Journal of Mammalogy 91:79-91.

Flaherty, E. A., M. Ben-David, and W. P. Smith. 2010b. Quadrupedal locomotor

performance in two species of arboreal squirrels: predicting energy

savings of gliding. Journal of Comparative Physiology B: DOI

10.1007/s00360-010-0470-1 (online April 10, 2010).

Flaherty, E. A., W. P. Smith, S. Pyare, and M. Ben-David. 2008. Experimental

trials of the northern flying squirrel (Glaucomys sabrinus) traversing

managed rainforest landscapes: perceptual range and fine-scale

movements. Canadian Journal of Zoology 86:1050-1058.

Smith, W. P. 2007. The northern flying squirrel: a biological portrait of a forest

specialist in post-European North America. Journal of Mammalogy 88:

837-839.

Smith, W. P. 2007. Ecology of Glaucomys sabrinus: habitat, demography,

and community relations. Journal of Mammalogy 88:862-881.

Smith, W. P., and D. K. Person. 2007. Estimated persistence of northern

flying squirrel populations in old-growth rain forest fragments. Biological

Conservation 137:626-636.

Scheibe, J. S., W. P. Smith, J. Basham, and D. Magness. 2006. Cost of

transport in the northern flying squirrel, Glaucomys sabrinus. Acta

Theriologica 51:169-178.

Smith, W. P., J. V. Nichols, and S. M. Gende. 2005. Correlates of microhabitat

use and density of Clethrionomys gapperi wrangeli and Peromyscus keeni

macrorhinus in temperate rainforests. Acta Zoologica Sinica 51:973-988.

Smith, W. P., J. V. Nichols, and S. M. Gende. 2005. The northern flying

squirrel as a management indicator species of north temperate rainforest:

test of a hypothesis. Ecological Applications 15:689-700.

Smith, W. P., J. V. Nichols, and S. M. Gende. 2004. Ecological correlates of

flying squirrel microhabitat use and density in temperate rain forests of

southeastern Alaska. Journal of Mammalogy 85:663-674.

Smith, W. P., and J. V. Nichols. 2004. Demography of two endemic forest-floor

mammals in southeastern Alaskan temperate rain forest. Journal of

Mammalogy 85:540-551.
6 November 2012 Big Thorne Project Comments – Winston P. Smith Ph.D. 4

Smith, W. P., and J. V. Nichols. 2003. Demography of the Prince of Wales

flying squirrel (Glaucomys sabrinus griseifrons): an endemic of

southeastern Alaska temperate rain forest. Journal of Mammalogy 84:144-

158.

Queen Charlotte goshawk

The Queen Charlotte goshawk (Accipiter gentilis laingi) is an endemic

subspecies that lives in the temperate rainforest archipelagos of Southeast

Alaska and coastal British Columbia (AOU 1957). The British Columbia Distinct

Population Segment (DPS) was recently listed as a threatened DPS in Canada

under the Endangered Species Act (Federal Register 2012). According to the

status review associated with this listing, the Queen Charlotte goshawk (QCG)

population is considered a meta-population of subpopulations occurring among

the islands of British Columbia and Alexander Archipelagos and the mainland of

Southeast Alaska south of the international border between Mount Foster and

Mount Fairweather (USFWS 2007). However, based on an analysis of birds in

this region Webster (1998) concluded the northern limit of the range of QGC was

Baranof Island and the southern limit of Taku Inlet. Nevertheless, the viability of

QGC hinges on maintaining as many (if not all) of the existing subpopulations

(USFWS 2007, Federal Register 2012).

Prince of Wales Island represents the largest amount of contiguous habitat

available in the Alexander Archipelagos and may be the largest amount of

contiguous habitat for QCG in the United States (Webster 1988). Therefore,

maintaining sufficient habitat to support a QCG breeding population on POW is

fundamental to maintaining the viability of the QCG. The proposed actions under

the Big Thorne Project will further reduce essential habitat available to

breeding QCG on POW beyond the 33% watershed harvesting thresholds

stipulated in the Forest Plan, and more importantly, beyond levels that are

recommended to sustain viable and well-distributed populations across managed

watersheds of the island, thus increasing the risk of extinction of the QGC

subspecies (Reynolds et al. 1992, Smith, In Revision). Below, I detail my

rationale with the support of empirical data and analyses (Smith and Goldstein

2006, Smith, In Revision).

The Big Thorne Project proposes to protect all existing and new goshawk nests

discovered during implementation of the selected action alternative. However,

QCG on POW are not limited by nest trees or nest areas (sensu Reynolds et al.

1992) and successful breeding is dependent on habitat elements that also

provide food and protection (Reynolds et al. 1992, McClaren et al. 2005). The

pattern of numerous previously occupied nest areas being abandoned by QCG

following timber sale projects (Titus et al. 1994, Flatten et al. 2001) underscores

the futility of just protecting nest areas as a conservation measure. Furthermore,

a widely acknowledged life history pattern in western North America is that

breeding home ranges of northern goshawks are comprised of three
6 November 2012 Big Thorne Project Comments – Winston P. Smith Ph.D. 5

hierarchical biological components (Reynolds et al. 1992, Kennedy et al.

1994, Andersen et al. 2005, McClaren et al. 2005), all of which need to be

considered simultaneously in land-use planning or mitigation (Northern

Goshawk Accipiter gentilis laingi Recovery Team 2008): 1) nest area; 2) postfledging (family) (PFA); and 3) foraging area. Nest areas provide alternate nest

trees, roost trees, and prey plucking posts, and serves as centers of essential

breeding behaviors or life history events, such as adult courtship and fledgling

movements during the post-fledging period (Reynolds et al.1992). PFAs surround

active nest trees and represent the core-use area of an adult female and the area

young goshawks use after fledging and before becoming independent of adults

and dispersing (Kennedy et al. 1994). McClaren et al. (2005) suggested the

biological role of PFAs and nest areas are similar and thus it is useful to consider

them as one functional component. Regardless, the habitat composition (i.e.,

overstory) of PFAs should be similar to nest areas (Reynolds et al. 2008).

Foraging areas comprise the majority of northern goshawk breeding home range

size and are especially important for adults providing food to young and for

dispersing juveniles.

At the request and with the financial and personnel support of the Tongass

National Forest, Smith and Goldstein (2006) undertook a spatially explicit

analysis of the contributions of the Tongass conservation strategy elements

(USDA Forest Service 1997) to QCG breeding season habitat. Because the nest

protection provision (i.e., buffer surrounding each nest tree) of 40 ha (100 acres)

prescribed under forest wide S&Gs represented approximately the size of a nest

area, this analysis focused on the other two biological components: PFA and

foraging areas using a database of known nest sites and published ecological

data from southeast Alaska (Iverson et al. 1996). This analysis examined the

composition of habitat types and the composition of landuse designations (LUDs)

in hypothetical (virtual) PFAs and foraging areas surrounding the 136 nest trees,

the areas of which was determined according to QCG movements in Southeast

Alaska (Iverson et al. 1996). Only 30% of nest trees had >51% of PFAs in

preferred habitat; 55% had >51% in unsecure LUDs, whereas 16% had >51% in

a protected old-growth forest LUD. Foraging area composition was similar to

PFAs, but proportion predominantly (>75%) available for development or with 26-

50% of total area in preferred habitat were larger than PFAs, and half as many

nests had >51% of area in preferred habitat. Among covertypes, preferred habitat

averaged 39.4% of the PFA. The methods and results of this analysis can be

found in the attached completion report previously provided to the Alaska

Region. These findings increase uncertainty about conservation measures

contributing sufficient habitat to sustain well-distributed, viable populations of

northern goshawks throughout Southeast Alaska (Smith, In Revision). Below, I

discuss in detail why further logging of north POW will further reduce essential

habitat for breeding QCG and increase the risk of extirpation of the POW

subpopulation of QCG, which ultimately increases the risk of extinction of the

already threatened DPS (USFWS 2007).
6 November 2012 Big Thorne Project Comments – Winston P. Smith Ph.D. 6

Standards and guidelines prescribed for individual nest trees in Southeast Alaska

(40 ha) are unlikely to meet breeding season habitat objectives established for

northern goshawk populations in the southern portion of its range (Reynolds et

al. 1992). The expectation that, in intensively managed landscapes, preferred

habitat contributed by other elements of the TLMP conservation strategy (e.g.,

old-growth reserves, riparian or shoreline buffers) will mitigate this deficiency was

not supported by a spatially explicit analysis of 136 virtual PFAs. An ideal

northern goshawk home range consists entirely of older forests with small,

dispersed openings (Reynolds et al. 2008). Guidelines for the composition of

PFAs stipulate that “the majority (60%)” of a PFA should be in forest of older age

classes (Reynolds et al. 1992:23). Nest areas in Southeast Alaska averaged

71% productive old growth; 58% of the nest area was comprised of preferred

habitat. Before logging, landscapes likely were similar in composition to nest

areas, although a disproportionate amount of high and very high volume oldgrowth was clearcut during the three decades preceding the 1997 TLMP revision,

especially on Prince of Wales and other southern islands (USDA Forest Service

1997). In this study, only about a third of 136 virtual PFAs contained >51%

preferred habitat. More importantly, the average composition of ‘unsecure’ (i.e.,

Development or NNF LUDs) habitat was 55%, and 60% of all PFAs were

comprised of >51% unsecure habitat. Regardless of whether I compare the

results of this study to habitat guidelines from the southwestern US or to the

composition of Southeast Alaska nest areas (i.e., desired future condition of

goshawk PFAs; Reynolds et al. 2008), the observed PFA habitat composition

was less than the minimum recommended or desired amount of suitable habitat.

At the time of the summary assessment of the conservation strategy (USDA

Forest Service 1997), about 5% (35/678) of the watersheds exceeded a

stipulated threshold, with 33 – 47% of productive old-growth forests already

harvested; 26 of those (74%) are concentrated in one Biogeographic Province

(North Prince of Wales Island). Moreover, full implementation of the Forest Plan

would result in 51 watersheds with >47% of the productive old-growth harvested,

29 of which would occur in the North Prince of Wales Island Province. The

summary assessment acknowledged the higher risks of exceeding watershed

thresholds, especially across North Prince of Wales Island, but assumed that

large reserves in those landscapes would mitigate the habitat loss from

excessive timber harvest. The findings of this study suggest that contributions of

habitat reserves and other conservation elements might not compensate for

cumulative habitat loss in intensively managed landscapes. Similar conclusions

were obtained for managed landscapes across another large island comprised of

coastal temperate rainforest (Northern Goshawk Accipiter gentilis laingi Recovery

Team 2008). Extensive loss of habitat from clearcut logging on Vancouver Island,

British Columbia evidently contributed to population declines; perceived threats

to habitat and concerns over population viability led to a review by the U.S. Fish

and Wildlife Service (2007) and listing of the Queen Charlotte goshawk DSP as

Threatened under ESA (Federal Register 2012) and by the Committee on the

Status of Endangered Wildlife in Canada (Northern Goshawk Accipiter gentilis
6 November 2012 Big Thorne Project Comments – Winston P. Smith Ph.D. 7

laingi Recovery Team 2008). Prince of Wales Island is near the northern limit of

the range of the Queen Charlotte subspecies and represents a significant portion

of its available habitat in the United States (U.S. Fish and Wildlife Service, 2007;

Northern Goshawk Accipiter gentilis laingi Recovery Team 2008).

The threshold composition of suitable habitat to ensure successful breeding on

POW Island is unknown. To gain this knowledge requires extensive research that

chronicles reproductive histories of individual breeding pairs and links fitness to

nesting habitat condition (Salafsky et al. 2007). The opportunity to compile

demographic data for Southeast Alaska is remote because nest monitoring has

been discontinued. Alternatively, biologists, policy makers, land managers, and

researchers often rely on habitat selection as the basis for assigning habitat

quality; i.e., conditions that facilitate successful reproduction (e.g., Reynolds et al.

1992; Iverson et al. 1996). Based on a similar rationale, the findings of this study

increase uncertainty that northern goshawk breeding season habitat objectives

are being met in managed landscapes of Southeast Alaska. Two lines of

reasoning support this conclusion.

First, spatially explicit analyses of contributions to northern goshawk breeding

season habitat revealed that TLMP conservation measures contribute about half

the secure habitat recommended for PFAs of breeding pairs in the southern

portion of this species range (Reynolds et al. 1992) and was less than half the

relative amount of preferred habitat documented in nest areas in Southeast

Alaska. A similar conclusion was obtained for the broader landscape (21 km2)

surrounding each nest. This is because much of the preferred habitat across the

landscape has been clearcut logged and half the remaining preferred habitat is in

Development LUDs available for timber harvest. The potential for second-growth

stands to become useable habitat (mature second growth) over the TLMP

planning horizon is limited because unmanaged second growth typically requires

≥300 years following disturbance to develop old-forest features (Nowacki and

Kramer 1998). Active management can hasten the development of old-forest

condition, but pre- and commercial thinning has occurred in only about 30% of

267,000 ha that has been harvested across the region (Barbour et al. 2005).

Although it is unlikely that all of the available old-growth forest in Development

LUDs will be harvested during the planning period, substantial preferred habitat

can be reduced because a disproportional amount of future harvest likely will

occur in portions of the landscape with larger tracts near existing roads (i.e.,

cumulative impacts) such as the proposed Big Thorne Project, which increase

the economic viability of timber sales. Furthermore, full implementation of TLMP

would exceed stipulated harvest thresholds of 33% by ≥33% (>47%) within 29

watersheds in the North Prince of Wales Island Province, thereby increasing

viability risk across a significant portion of the QCG range in Southeast Alaska

(USDA Forest Service 1997: Appendix N40; U.S. Fish and Wildlife Service

2007). Regardless, the average composition of all preferred habitat in PFAs

(39%) is well below the recommended or desired condition, even if another acre

is not harvested (Smith, In Revision, Smith and Goldstein 2006).
6 November 2012 Big Thorne Project Comments – Winston P. Smith Ph.D. 8

Secondly, there appears to be sufficient justification to question whether

guidelines developed for northern goshawk populations in the southwestern

United States underestimate habitat needed by breeding pairs in managed

landscapes of Southeast Alaska. A critical consideration in conserving habitat to

support breeding populations is sufficient habitat to sustain prey resources

(Salafsky et al. 2007). Despite possible differences in life history or ecology

across the range of northern goshawks, the nesting and foraging habitat of

successful breeding pairs must support adequate prey. Reynolds et al.

(1992:23) recommended that older forest in PFAs be distributed among 3 age

classes, with “20% each in mid-age (ca. 140 yr.), mature (ca. 200 yr.) and old

(240 yr.) trees" to provide for a diversity of prey. In Southeast Alaska, the most

important (frequency and biomass) prey 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, Russell 1999,

Smith et al. 2001, Smith et al. 2004, 2005). Consider further that the mammal

fauna of Southeast Alaska is depauperate (MacDonald and Cook 1996); 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 managed stands effectively renders prey unavailable to foraging goshawks.

Avian communities in managed habitats include few if any additional prey for

northern goshawks (Smith et al. 2001). Thus, breeding pairs in managed

landscapes of Southeast Alaska likely rely almost entirely on productive oldgrowth forests as foraging and nesting habitat. That breeding pairs in

managed landscapes of Southeast Alaska depend on productive old-growth

forests to meet life history needs is reflected in the findings of compositional

analyses and radio-telemetry studies, both of which determined that northern

goshawks strongly preferred medium and high volume old-growth forests and

avoided recently managed or non-forested habitats (Iverson et al. 1996).

Queen Charlotte Goshawk References (alphabetical)

Andersen, D. E., S. DeStefano, M. I. Goldstein, K. Titus, C. Crocker-Bedford, J.

J. Keane, R. G. Anthony, and R N. Rosenfield. 2005. Technical review of

the status of Northern Goshawks in the western United States. Journal of

Raptor Research 39:192–209.

AOU (American Ornithologist's Union). 1957. Check-list of North American birds.

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th ed., American Ornithologist's Union, Baltimore, Maryland.

Barbour, R., R. Zaborske, M. McClellan, L. Christian, and D. Golnick. 2005.

Young-stand management options and their implications for wood quality

and other values. Landscape and Urban Planning 72:79–94.

Beier, P., and J. E. Drennan. 1997. Forest structure and prey abundance in

foraging areas of northern goshawks. Ecological Applications 7:564–571.

Boal, C. W., D. E. Andersen, and P. L. Kennedy. 2003. Home range and

residency status of northern goshawks breeding in Minnesota. Condor

105:811–816.

Bright-Smith, D. J., and R. W. Mannan. 1994. Habitat use by breeding male
6 November 2012 Big Thorne Project Comments – Winston P. Smith Ph.D. 9

northern goshawks in northern Arizona. Studies in Avian Biology 16:58–

65.

Cooper, J. M., and V. Stevens. 2000. A review of the ecology, management and

conservation of the northern goshawk in British Columbia. Wildlife Bulletin

No. B–10. Lands and Parks, Ministry of Environment, Victoria, BC.

Daw, S. K., and S. DeStefano. 2001. Forest characteristics of Northern Goshawk

nest stands and post-fledging areas in Oregon. Journal of Wildlife

Management 65:59–65.

Daw, S. K., S. DeStefano, and R. J. Steidl. 1998. Does survey method bias the

description of northern goshawk nest-site structure? Journal of Wildlife

Management 62:1379–1384.

Drennan, J. E., and P. Beier. 2003. Forest structure and prey abundance in

winter habitat of northern goshawks. Journal of Wildlife Management

67:177–185.

Federal Register. 2012. Endangered and Threatened Wildlife and Plants; Listing

the British Columbia Distinct Population Segment of the Queen Charlotte

Goshawk Under the Endangered Species Act; Final Rule. Volume 77, No.

148: 45870.

Finn, S. P., J. M. Marzluff, and D. E. Varland. 2002. Effects of landscape and

local habitat attributes on Northern Goshawk site occupancy in western

Washington. Forest Science 48:427–436.

Flatten, C., K. Titus, and R. Lowell. 2001. Northern goshawk monitoring,

population ecology and diet on the Tongass National Forest. Final

Research Performance Report, Endangered Species Conservation Fund

Grant SE–4–2–6:33, Studies 2–6. Alaska Department of Fish and Game,

Juneau, USA.

Good, R. E. 1998. Factors affecting the relative use of northern goshawk

(Accipiter gentilis) kill areas in southcentral Wyoming. Thesis, University of

Wyoming, Laramie, USA.

Greenwald, D. N., D. C. Crocker-Bedford, K. F. Suckling, T. Tibbitts, and L.

Broberg. 2005. A review of northern goshawk habitat selection in the

home range and implications for forest management in the western United

States. Wildlife Society Bulletin 33:120–129.

Grubb, T. G., L. L. Pater, and D. K. Delaney. 1998. Logging truck noise near

nesting northern goshawks. U.S. Forest Service Research Note RMRS–

RN–3, Fort Collins, Colorado.

Iverson, G. C., and B. Rene. 1997. Conceptual approaches for maintaining welldistributed viable wildlife populations: a resource assessment. Pages 1–23

in K. R. Julin, compiler. Assessments of wildlife viability, old-growth timber

volume estimates, forested wetlands, and slope stability. U.S. Forest

Service, General Technical Report PNW–392. Portland, Oregon.

Iverson, G. C., G. D. Hayward, K. Titus, E. DeGayner, R. E. Lowell, D. C.

Crocker-Bedford, P. F. Schempf, and J. Lindell. 1996. Conservation

assessment for the northern goshawk in Southeast Alaska. U.S. Forest

Service General Technical Report PNW–387, Portland, Oregon.

Keane, J. J. 1999. Ecology of the northern goshawk in the Sierra Nevada,
6 November 2012 Big Thorne Project Comments – Winston P. Smith Ph.D. 10

California. Dissertation, University of California, Davis.

Kennedy, P. L., J. M. Ward, G. A. Rinker, and J. A. Gessaman. 1994. Postfledging areas in northern goshawk home ranges. Studies in Avian Biology

16:75–82.

Kenward, R. E. 1982. Goshawk hunting behaviour, and range size as a function

of food and habitat availability. Journal of Animal Ecology 51:69–80.

Kenward, R. E., V. Marcstrom, and M. Karlbom. 1993. Post-nestling behavior in

goshawks, Accipiter gentilis: The causes of dispersal. Animal Behavior

46:365–370.

La Sorte, F. A., R. W. Mannan, R. T. Reynolds, and T. G. Grubb. 2004. Habitat

associations of sympatric red-tailed hawks and northern goshawks on the

Kaibab Plateau. Journal of Wildlife Management 68:307–317.

Lewis, S. B. 2001. Breeding season diet of Northern Goshawks in Southeast

Alaska with a comparison of techniques used to examine raptor diet.

Thesis, Boise State University, Idaho.

Lewis, S. B., K. Titus, and M. R. Fuller. 2006. Northern goshawk diet during the

nesting season in Southeast Alaska. Journal of Wildlife Management

70:1151–1160.

MacDonald, S. O., and J. A. Cook. 1996. The land mammal fauna of southeast

Alaska. Canadian Field-Naturalist 110 571–598.

McClaren, E. L., P. L. Kennedy, and S. R. Dewey. 2002. Do some Northern

Goshawk nest areas consistently fledge more young than others? Condor

104:343–352.

McClaren, E. L., P. L. Kennedy, and P. L. Chapman. 2003. Efficacy of male

goshawk food delivery calls in broadcast surveys on Vancouver Island.

Journal of Raptor Research 37:198–208.

McClaren, E. L., P. L. Kennedy, and D. D. Doyle. 2005. Northern Goshawk

(Accipiter gentilis laingi) post-fledging areas on Vancouver Island, British

Columbia. Journal of Raptor Research 39:253–263.

McGrath, M. T., S. DeStefano, R. A. Riggs, L. L. Irwin, and G. J. Roloff. 2003.

Spatially explicit influences on Northern Goshawk nesting habitat in the

interior Pacific Northwest. Wildlife Monographs 154:1–63.

Northern Goshawk Accipiter gentilis laingi Recovery Team. 2008. Recovery

strategy for the Northern Goshawk, laingi subspecies (Accipiter gentilis

laingi) in British Columbia. Ministry of Environment, Victoria, B.C.

Patla, S. M. 1997. Nesting ecology and habitat of the northern goshawk in

undisturbed and timber harvest areas on the Targhee National Forest,

Greater Yellowstone Ecosystem. Thesis, Idaho State University,

Pocatello.

Pendleton, G. W., K. Titus, E. DeGayner, C. J. Flatten, and R. E. Lowell. 1998.

Compositional analysis and GIS for study of habitat selection by goshawks

in southeast Alaska. Journal of Agricultural, Biological, and Environmental

Statistics 3:280–295.

Reich, R. M., S. M. Joy, and R. T. Reynolds. 2004. Predicting the location of

northern goshawk nests: modeling the spatial dependency between nest

locations ad forest structure. Ecological Modeling 176:109–133.
6 November 2012 Big Thorne Project Comments – Winston P. Smith Ph.D. 11

Reynolds, R.T., 1983. Management of western coniferous forest habitat for

nesting accipiter hawks. USDA Forest Service General Technical Report

RM-102, Fort Collins.

Reynolds, R. T., R. T. Graham, and D. A. Boyce, Jr. 2008. Northern goshawk

habitat: an Intersection of science, management, and conservation.

Journal of Wildlife Management 72:1047–1055.

Reynolds, R. T., R. T. Graham, M. H. Reiser, R. L. Bassett, P. L. Kennedy, D. A.

Boyce, Jr., G. Goodwin, R. Smith, and E. L. Fisher. 1992. Management

recommendations for the northern goshawk in the southwestern United

States. U.S. Forest Service General Technical Report RM–217, Fort

Collins, Colorado.

Reynolds, R. T., S. M. Joy, and D. G. Leslie. 1994. Nest productivity, fidelity, and

spacing of northern goshawks in Arizona. Studies in Avian Biology

16:106–113.

Russell, A. L. 1999. Habitat relationships of spruce grouse in Southeast Alaska.

Thesis, Texas Tech University, Lubbock.

Salafsky, S. R., R. T. Reynolds, B. R. Noon, and J. A. Wiens. 2007. Reproductive

responses of northern goshawks to variable prey populations. Journal of

Wildlife Management 71: 2274–2283.

Schempf, P., K. Merge, S. Patla, L. Daniel, and M. Jacobson. 1996. Goshawk

surveys in wilderness and roadless areas of southeast Alaska in 1995.

Final report. U.S. Fish and Wildlife Service, Juneau, Alaska.

Smith, W. P. In Revision. Spatially explicit analysis of contributions of a regional

conservation strategy toward sustaining essential wildlife habitat.(Wildlife

Society Bulletin: 6 November 2012)

Smith, W. P., and M. Goldstein. 2006. Spatially explicit analysis of contributions

of the 1997 TLMP Conservation Strategy to Northern Goshawk breeding

season habitat. Completion Report on file with USDA Forest Service,

Region 10, Juneau, Alaska.

Smith W. P., M. J. Stotts, B. A. Andres, J. M. Melton, A. Garibaldi, and K. Boggs.

2001. Bird, mammal, and vegetation community surveys on Research

Natural Areas in the Tongass National Forest. U.S. Forest Service

Research Paper–PNW–RP–535, Portland, Oregon.

Smith, W. P., S. M. Gende, and J. V. Nichols. 2004. Ecological correlates of

flying squirrel microhabitat use and density in temperate rainforests of

southeastern Alaska. Journal of Mammalogy 85:540–551.

Smith, W. P., S. M. Gende, and J. V. Nichols. 2005. Correlates of microhabitat

use and density of Clethrionomys gapperi wrangeli and Peromyscus keeni

macrorhinus in temperate rainforests. Acta Zoologica Sinica 51:973–988.

Smith, W. P., and J. V. Nichols. 2004. Demography of two endemic forest-floor

mammals in southeastern Alaskan temperate rain forest. Journal of

Mammalogy 85:540–551.

Stephens, R. M. 2001. Migration, habitat use, and diet of northern goshawks that

winter in the Uinta Mountains, Utah. Thesis, University of Wyoming,

Laramie.

Titus, K., C. J. Flatten, and R. E. Lowell. 1994. Northern Goshawk ecology and
6 November 2012 Big Thorne Project Comments – Winston P. Smith Ph.D. 12

habitat relationships on the Tongass National Forest: Goshawk nest sites,

food habits, morphology, home range and habitat data. First Annual

Progress Report, Contract 43–0109–3–0272. Alaska Department of Fish

and Game, Juneau.

U.S. Forest Service. 1997. Land and resource management plan: Tongass

National Forest. U.S. Forest Service R10–MB–338dd, Juneau, Alaska.

U.S. Fish and Wildlife Service. 2007. Queen Charlotte goshawk status review.

U.S. Fish and Wildlife Service, Juneau, Alaska.

Webster, D. J. 1988. Some bird specimens from Sitka, Alaska. Murrelet 69:46-

48.

Widen, P. 1997. How, and why is the goshawk (Accipiter gentilis) affected by

modern forest management in Fennoscandia? Journal of Raptor Research

31:107–113.
SARAH PALIN, GOVERNOR 

DEPARTMENT OF FISH AND GAME 

DIVISION OF WILDLIFE CONSERVATION 

P .0 . BOX 667 

PETERSBURG, AK 99833-0667 

PHONE: (907) 772-3801 

FAX (907) 772-9336 

February 16, 2007 

Quentin Smith, Transportation Planner 

Wrangell Ranger District 

Tongass National Forest 

P.O. Box 51 

Wrangell, AK 99929 

Quentin, 

After reviewing the WRD road density information provided by Melissa Cady, and following 

subsequent GIS analysis, the department has identified two islands within the WRD 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. Not having had 

sufficient opportunity to analyze the various road management alternatives in detail, we are 

currently unable to determine which, if any, of the alternatives in the EA would be sufficient to 

alleviate our current marten mortality concerns. Obviously, which roads remain open, and which 

roads are effectively closed to motorized vehicles will greatly influence our level of concern. For 

example, we are particularly concerned about open roads within or adjacent to Old Growth 

Reserves. 

The Forest Service acknowledges that motorized vehicle use continues to occur on some roads 

officially designated as closed. Not knowing if the closed road densities contained in the 

document provided by Melissa Cady represent simple administrative closures, or if they pertain 

solely to roads with effective barriers to motorized vehicle traffic, we see little alternative but to 

use total road density figures in our analysis of risks to marten. While 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. Furthermore, the department's level of concern increases in 

situations where the islands involved are relatively small and where there exists little or no 

potential for immigration. 

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 

00895
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 an 

extremely valuable for better evaluating population status and monitoring mortality rates of 

marten on Wrangell Island. 

 

With regard to Zarembo Island, our assessment of available refugia was conservative in that it 

failed to include recent road construction associated with the Skipping Cow Sale and possibly 

other ongoing projects. Nonetheless, our analysis indicates that approximately 80 percent of 

Zarembo’s overall land area is accessible within 0.9 miles of a road, therefore, very little refugia 

exists for marten. As you know, ADF&G’s fur sealing records indicate that marten are present 

on Zarembo. Given the department’s fur sealing records, high road density and the limited 

amount of refugia for marten, the department must conclude that the potential for overharvest of 

marten exists on Zarembo. Systematic surveys would be an extremely valuable for better

evaluating population status and monitoring mortality rates of marten on Zarembo Island. Until 

such time that surveys can be conducted, we must conclude that a management concern exists for 

marten on Zarembo. 

Sincerely,

Via Email

Rich Lowell

Area Wildlife Management Biologist

00896
UNITED STATES OF AMERICA

DEPARTMENT OF AGRICULTURE

UNITED STATES FOREST SERVICE

Before the Chief

USDA Forest Service

In re Appeal of the Big Thorne Project

Final Environmental Impact Statement and

Record of Decision.

GREATER SOUTHEAST ALASKA

CONSERVATION COMMUNITY,

Appellant.

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Appeal No. ___________

DECLARATION OF JOSEPH R. MEHRKENS

I, Joseph R. Mehrkens, declare as follows:

1. I am a retired resource economist residing at 15450 Glacier Highway, Juneau, 

Alaska 99801. I periodically consult on natural resource issues in Alaska.

2. I received a B.S. in Forestry from the University of Minnesota in 1970 and a 

Masters of Science in Forest Economics from Michigan State University in 1975. 
2

3. Since 1979 I have worked as an economist for the Forest Service, The Wilderness 

Society, the Alaska Department of Commerce and Economic Development, and Environmental 

Economics – Alaska (my former consulting business).

4. From 1979 to 1987 I was the Regional Economist for the USDA-Forest Service, 

Alaska Region. My duties included economic assessments of the Tongass NF timber program –

including the timber trade between Alaska and the Pacific Rim countries. I also prepared 

congressional reports on the annual supply and demand for Southeast Alaska timber.

5. From 1987 to 1991 I worked for The Wilderness Society as an economist and 

lobbyist to help gain passage of the Tongass Timber Reform Act of 1990. I testified before 

various congressional committees on the economic tradeoffs of the Tongass NF timber program 

– including taxpayer subsidies. I also analyzed the annual President’s budget for the Tongass NF 

and made recommendations for change to the House and Senate Appropriations committees.

6. From 1991 to 2000 I was a part-time consultant on various projects including an 

expert witness on the Alaska Pulp of America consolidated income statements. During this time 

I also commercial fished and worked full time for the Alaska Department of Law (1995-1998).

7. From 2000 to 2004, I worked for the Alaska Department of Commerce, 

Community and Economic Development. I developed the framework for the Alaska Economic 

Information System – a web based system to access federal, state and local economic data. I also 

reinitiated the Alaska Annual Economic Performance Report.

8. I worked as a part-time consultant from 2004 until I retired in May 2008. My

work included the determination of public subsidies for the Tongass NF timber program. The 

subsidy work was initially completed under two contracts to the Southeast Alaska Conservation 

Council (SEACC), but the final products were also shared with the Natural Resources Defense 

Council, The Wilderness Society, EarthJustice and other environmental organizations.
3

9. I have maintained a series of Excel spreadsheets and charts since 1987 and have 

included various versions and updates of these spreadsheets for clients such as SEACC. Under 

two contracts with SEACC in 2004 and 2007, I provided an up-to-date analysis of the cost of the 

Tongass Timber Program in terms of timber sale planning, preparation, administration and road 

construction, including the cost of purchaser road credits and purchaser-elect roads. 

10. Prior to my contractual work, SEACC published a report titled, “Taxpayer Losses 

and Missed Opportunities.” The report documented the public subsidies from 1998 to 2002 in 

terms of total dollars lost and the cost per Tongass timber dependent job. The SEACC report 

evolved from a Freedom of Information Act (FOIA) request prepared by another former Alaska 

Regional Economist, Dr. Guy Robertson. Dr. Robertson provided Forest Service information on 

timber receipts and expenditures, including the costs of road building. The SEACC report 

simply subtracted timber and road expenditures from timber revenues to calculate the net dollar 

loss to taxpayers. The SEACC loss calculations excluded road maintenance costs, and the 

estimated loss per timber job for 2002 was based on partial information – only two quarters of 

employment data.

11. My first contract in 2004 was designed to revise the 2002 information concerning 

timber employment and update the subsidy information for FY2003 and FY2004. My update 

followed the same approach as economist Robertson and SEACC. In addition, I included the 

prior analyses of two General Accounting Office reports released in 1989 and 1997, and the 

work of forest economist Randle O’Toole, “$64 million Dollar Question: How the Taxpayers

Paid the Pulp Mills to Clearcut the Tongass National Forest” ( Table 17, page 28) (1993). This 

supplemental information gave me consistent expenditure and revenue data from 1982 to 2002. 

12. Subsequent FOIA requests were made by SEACC to gain the same type of 

information as provided by Dr. Robertson for my analyses for FY 2003 and FY2004. Line item 
4

expenditures for the timber and road programs were taken from Forest Service budget and 

accounting documents. These expenditures were subtracted from timber receipts that are 

regularly published on the Forest Service web site. This yielded the public subsidy or net loss in 

total dollars. Tongass timber dependent employment numbers for 2002, 2003 and 2004 were 

taken from two draft Forest Service reports: the ANILCA Section 706(a) timber supply and 

demand report for fiscal years 2001 & 2002, and the same report for fiscal years 2001-2005. 

Based on my past experience, the employment numbers in these reports were reasonable and 

accurate. 

13. Using the total dollar loss and the Forest Service job employment numbers, I 

estimated net loss per Tongass timber dependent job for fiscal years 2003 and 2004, by following 

the same methodology/conventions from 1998 to 2002. Simply, the net loss in total dollars is 

divided by the Tongass timber dependent job numbers reported by the Forest Service. The only 

exception is that I used road maintenance costs in my estimates. I also corrected the FY2002 net 

loss per job calculated by SEACC by using the more complete Forest Service employment 

information – an entire year versus just two quarters. 

14. The subsidy analysis under my second contract with SEACC in 2007 was similar. 

A SEACC FOIA provided the same type of information on timber and roads expenditures for 

FY2005, FY2006 and FY2007. Again timber receipts were taken from the Forest Service web 

site. Tongass timber dependent employment was taken from another Forest Service draft Section 

706(a) report for 2006. The subsidy in total dollars lost and the net losses per job for FY2005 

and 2006 were calculated as before. 

15. The estimated subsidy for FY2007 and FY2008 had to go a couple of steps 

further. While the expenditures for 2007 were actual expenditures, the FY2008 program costs 

were the approved budget authorities for the timber and road programs, i.e., the maximum 
5

amount that can be expended. Simply stated, actual expenditures for FY2008 were not yet 

available. Also, the Tongass timber dependent job numbers for FY2007 and FY2008 were my 

independent estimates and are based on reduced logging in 2007 and the recent closure of the 

Ketchikan veneer mill in 2008. Nonetheless, my methodology was similar to the Forest Service 

methodology in the agency’s 706(a) reports and similar to what I used as Regional Economist in 

the mid-1980s. The employment estimates made by the Forest Service and me very closely 

tracked similar information reported by the Alaska Department of Labor and Work Force 

Development (ADOLWD). I have used to ADOLWD information to validate my employment 

estimates as well as the Forest Service estimates.

16. To make the dollar losses consistent over time, I had to fill in missing information 

about overhead costs in support of the timber and road programs. The overheads costs are 

expenditures for shared utilities, equipment, facilities, accounting, procurement, personnel,

supervision, etc. The overhead costs (now known as cost pools) were once an explicit line item

in the budgeting and accounting documents – that is until FY2004. From FY2004 to FY 2007 

the timber and roads construction cost pools were lumped together with all other programs,

making a timber and roads estimate more difficult. However, the FOIA information for FY2004 

did reveal the cost pool allocations for the roads program in the budget documents. 

Consequently, I used this explicit budget information to estimate the total road expenditures

(including overheads) for 2004. However, I could not do the same for the timber program. For 

the timber program I had to use an independent estimate for the overhead costs. This estimate 

was based on the ratio of actual overhead costs to direct timber program costs during FY2002 

and FY2003. This ratio ranged from 49% to 51% and I used the lower percentage to be 

conservative. It turns out this percentage is pretty consistent over time.
6

17. Again, for FY2006 and FY2007 there was no explicit information on overhead 

costs. However, the FOIA information for this period revealed the Regional Office and Tongass 

NF assessments for the cost pools (overheads) as a percentage of direct program costs. The

percentage applied to all resource programs – timber and non-timber alike. I assumed these

percentages have been applied to timber and road programs and they were the basis for the 

overhead costs for my FY2006 and FY2007 analysis. I also used these percentages to revise the 

FY2005 timber overheads since it is based on real information and not an assumption about 

historic rates. 

18. I used this information to produce Exhibit A to my declaration attached as Exhibit 

D to The Wilderness Society’s administrative appeal of the Record of Decision and Final 

Environmental Impact Statement for the 2008 Amendment to the Tongass Land Management 

Plan (appeal number 08-13-00-0028). Exhibit A was based entirely on publically available 

information, including numerous Forest Service documents that are available as hard copy or 

online documents. All information sources were documented in the spreadsheet, which was part 

of an Excel Workbook file I created entitled, “Final Tongass Budget Analysis 91-07.” The 

FOIA documents are available in hard copy from the Forest Service or SEACC. In my opinion, 

Exhibit A presented an accurate picture of Tongass costs, revenues, and jobs through 2007, and

represents the best data available.

19. After I retired in 2008 I continued to be involved in issues related to timber 

economics. In 2011 I helped to incorporate an Alaska non-profit corporation, the Greater 

Southeast Alaska Conservation Community (GSACC) and conduct extensive research work as a 

board member and volunteer on behalf of GSACC.

20. On June 11, 2012, I submitted a FOIA request on behalf of GSACC and requested 

information for fiscal years 2008, 2009, 2010 and 2011 showing expenditures and activity 
7

outputs for timber-program related budget codes and work plan documents. I also requested 

final fiscal year 2012 budget advice for the Alaska Region for timber-program related budget 

codes. The requested information was similar to the information requested on behalf of SEACC 

in 2007 and 2008.

21. After reviewing the information provided pursuant to the FOIA request, I updated 

the Excel Workbook file I created for the 2008 TLMP Amendment Appeal, “Final Tongass 

Budget Analysis 91-07” to include budget information for fiscal years 2008 – 2012. GSACC 

submitted the updated Excel Workbook file, now entitled “GSACC-EEA Tongass Budget 

Analysis 91-12” as Exhibit 202b to its comments on the Big Thorne Project Draft Environmental 

Impact Statement.

22. My methodology for calculating timber program costs for Exhibit 202b was 

similar to the methodology described in paragraphs 13 – 17. I updated the 2008 program costs 

which were previously based on approved budget authorities with costs based on actual 

expenditures provided in the 2011 FOIA request. As explained in paragraph 15, the cost figures 

for fiscal year 2012 are based on approved budget authorities rather than actual expenditures 

because the expenditure information was not yet available. All other program costs displayed in 

the spreadsheets reflect actual expenditures.

23. I again added missing information about overhead costs in support of the timber 

and road programs. From FY2010 to FY2012 overhead costs are based on constant percentages 

applied to timber and road related costs but with different percentages applied to the Regional 

Office (39%) and the Tongass National Forests (31%). These percentages were derived from 

separate analyses of past actual cost pool expenditures for all programs reported by the Forest 

Service each fiscal years from 2006 to 2012.
8

24. On September 25, 2012, I submitted an additional FOIA request seeking reports 

related to the administrative costs of NEPA preparation, sale preparation, sale administration and 

engineering support and any other documents or reports regarding average administrative cost 

reports, budget monitoring and cost monitoring. The materials provided by the Forest Service 

did not include any budget preparation documents or reviews that support the agency’s 

administrative cost estimates for the Tongass timber sale program.

25. On January 15, 2013, I submitted a FOIA request on behalf of GSACC and 

requested information for fiscal years 2012 and 2013. For FY 2012 I requested actual 

expenditure information for timber-and road construction budget codes. For FY2013 I requested 

the final budget allocations for Alaska Region for the same budget codes as is FY2012. Again, 

the final budget advice is used as a proxy for actual expenditures until the actual expenditure 

information for FY2013 is finalized and publically available.

26. Using the information described in paragraph 25 I once again updated the series 

of Excel spreadsheets described in paragraph 9 and replaced the final budget advice for FY2012 

with actual timber related expenditures for FY2012. My methodology for calculating timber 

program costs was consistent with to the methodology used in prior updates as described in 

paragraphs 13 – 17. This most recent Excel spreadsheet update is the basis for specific findings 

about the economic and financial analysis found in the Big Thorne Project (BTP) planning 

record. 

27. More specifically I have reviewed the updated analysis of timber sale program 

costs based on a “snapshot” review of fiscal years 2010, 2011 and 2012. The one page document 

does not provide any underlying data to support the cost assumptions, and omits substantial 

timber program costs, including, but not limited to overhead costs, transportation system costs, 
9

post-project habitat treatment costs and numerous other public expenditures that would not be 

incurred but for the Tongass timber sale program. 

28. The single most important failing of the BTP economic analysis is the lack 

credible information on the total costs to conduct the Tongass timber sale program. The total 

unit cost to produce a thousand board feet of timber averaged $1,335/mbf from FY2010 to FY 

2012 (the base period used in the BTP financial analysis).

29. In comparison, the total unit costs of $1,335/mbf is 13 times greater than the 

purported agency unit costs of $101/mbf for the BTP economic/financial analysis (which has 

been recently amended to $103/mbf).

30. The much higher total unit cost of $1,335/mbf is based on actual U.S. Forest 

Service expenditures rather than agency estimates to prepare future Tongass budget requests. 

The latter is supposedly the basis for the unit costs of $101/$103/mbf used in the BTP financial 

analysis. Again, the lower unit costs are not explicitly documented

31. In contrast, the $1,335/mbf is explicitly documented and is calculated from 

readily available agency information. The $1,335/mbf includes costs for timber management 

and logging roads and includes estimated overhead costs. It is also based on actual Tongass 

timber consumption.

32. With the exception of engineering support (the design and location of logging 

roads), the Forest Service also routinely ignores the total costs of road construction, 

reconstruction and maintenance in the BTP economic analysis. Logging road related costs are 

substantial and create a financial liability that stems both past and new timber sales.

33. While there are many differing and valid arguments on how to account for road 

costs, the simple fact is if you ignore all Tongass road construction, reconstruction and 

maintenance cost over the period FY2010 to 2012, the average total unit cost is still $938/mbf 
10

for Tongass timber — again about 9.5 times greater the purported agency costs of $101-103/mbf 

and used in the BTP economic/financial analysis.

34. While it is uncertain to the public just how the $101/$103/mbf unit costs are 

derived, it is very certain that they are inconsistent with real data reported by the Forest Service 

in the past. Forest Supervisor Cole explained in a 2004 deposition that the unit costs were 

$101/mbf and pretty constant. The BTP planning record states the $101/mbf is derived from 

information used to build annual budget requests. 

35. In any case, Supervisor Cole’s unit cost have not changed over a long period of 

time and the BTP planning records simply reiterated the same unit costs as $29/mbf for timber 

preparation, $9/mbf for timber sale administration and $28/mbf for engineering support. In 2012

these values have been revised slightly upwards by Robert Vermillion to $20.78/mbf for timber 

preparation, $12.28/mbf for timber sale administration and $22.67/mbf for engineering support.

36. The first issue is how either set of unit costs (Cole or Vermillion) can remain so 

static after years of inflation – albeit relatively low inflation. 

37. Past unit costs are indeed available from budget documents covering FY1981 to 

FY1990 (the last time period that unit costs were reported in public budget documents). Simply 

inflating the historic past unit costs to reflect 2012 dollars indicates that BTP unit costs are 

substantially underestimated.

38. Comparing Vermillion’s revised unit costs to the inflated historic unit costs shows

$20.78/mbf versus $38.41/mbf for timber preparation, $12.28mbf versus $25.89/mbf for timber 

administration and $22.87/mbf versus $60.87/mbf for engineering support.

39. While the forestry and engineering technology has no doubt improved over time 

there is nothing to suggest improved efficiencies of 46%-63% -- the gains needed to account for 

the lower unit costs used in the BTP financial analysis. Moreover, if such technological 
11

efficiencies are indeed real they have not been carried over into recent annual Tongass budget 

requests from Congress. Simply stated, total program budget requests remain high. Actual 

program expenditures are the best and most informative measures for disclosing economic 

impacts.

40. In the BTP, the Forest Service ignores overhead costs which are a substantial

component in day to day operations. Two past GAO audits of the timber program included 

overhead costs (now called cost pools). To be consistent with the GAO methodology my 

subsequent spreadsheet analyses have always included estimates of overhead costs.

41. Again, using the budget data from 1981-1990, the proportion of overhead costs 

for timber preparation, timber administration and engineering support ranged from 16% to 63%. 

More recently, from FY2010 to 2012 the estimated overhead costs are 39% for the Regional 

Office related expenditures and 31% for Tongass National Forest expenditures. These overhead 

percentages were applied to Timber Management (NFTM budget line item) and the Construction 

Maintenance Roads (CMRD budget line item). In any case, overhead costs have always been a 

substantial cost of doing the business in the offering and selling of Tongass timber.

42. To ignore overheads in the BTP financial analysis is like rationalizing the cost of 

home ownership to only the costs for heat, utilities and maintenance, while ignoring major cost 

components such as the mortgage, insurance and taxes.

43. Timber related employment is overestimated in the BTP economic analysis. 

While the Forest Service correctly estimates the direct timber industry jobs, they inappropriately 

then add estimates for indirect and induced jobs.

44. Conventional economic impact assessments recognize the relationship between 

direct jobs and the additional indirect and induced jobs supported by the existence of the direct 

jobs in a local economy. Indirect jobs are from local firms that are not part of the sawmill 
12

industry but who supply the mills with goods and services used by mill operators, e.g., a fuel oil 

delivery jobs. Induced jobs are the jobs created to support direct and indirect jobs, such as 

school teachers, retailers and local government employees. However, the relationships between 

direct, indirect and induced jobs have been found to be invalid by Forest Service economists Dr. 

Guy Robertson and Dr. Lisa Crone – especially for small communities similar to those affected 

by BTP.

45. While the findings by Robertson and Crone are cited in the BTP planning records,

their cautions and recommendations are ignored. Thus, for the BTP, the Forest Service is using a 

sawmilling multiplier of 2.68 jobs/mmbf/sawn composed of 1.68 direct jobs and 1.0 jobs for 

indirect and induced – a 60% overestimation.

46. Estimating Tongass timber dependent employment has become increasingly 

difficult because of structural changes in the Southeast timber industry and changes in federal 

timber export policies.

47. The decline of the timber industry is now sufficient to withhold employment 

information that was previously available from traditional sources such as the Alaska 

Department of Labor and Workforce Development. This is due to disclosure policies which are 

designed to prevent the identification of an individual firm’s employment and payroll 

information.

48. Good regional information is still publically available for direct Southeast logging 

and sawmilling for the years prior to 2011. However, starting in 2011 region-wide logging jobs 

are combined with sawmilling and mining in order to not violate disclosure policies. However, I 

was able to get timber industry employment information for logging and sawmills combined for 

FY2011 via a special request to the Alaska Department of Labor and Workforce Development.
13

49. Using Alaska Department of Labor and Workforce Development employment 

information for years 1991-2001, I have been able to validate the employment data collected by 

the Forest Service in their periodic sawmill surveys and the implied multipliers for sawmill 

production.

50. To the agency’s credit, starting in 2002 the Forest Service had to adjust their 

employment estimates by taking into account the amount of timber supplied to sawmills from 

sources other than the Tongass NF.

51. As cited in the BTP planning record, prior to 2002 nearly all the saw timber was 

supplied from the Tongass National Forest, but during 2002-2012 the Tongass share ranged from 

59% to 87%.

52. Now, timber sale operators can elect to export up to 50% of the saw-log volume 

in a timber sale as round logs. These exports were originally required to undergo primary 

processing in Alaska mills and supported local sawmill jobs.

53. To obtain better sawmill employment information and to compensate for the 

factors described in paragraphs 49, 51 and 52, the Forest Service conducts periodic mill surveys.

More specifically, these surveys monitor saw-log consumption, export volumes and employment 

information. 

54. Using the Forest Service sawmill surveys, an implied the number for direct jobs in 

sawmills averaged 1.68 jobs/mmbf of timber sawn from all sources from 2002 to 2010 (BTP 

planning record). This multiplier is very consistent with previous multipliers derived from past 

Forest Service and ADOLWD information. In contrast, a higher 2.68 jobs/mmbf multiplier is 

used in the BTP economic analysis and overestimates supported employment by 60%. The 

overestimate is because it supposedly includes indirect and induced jobs, which again is contrary 

to the findings of their own agency economists.
14

55. Likewise, the Forest Service is erroneously using a logging multiplier of 2.26 

jobs/mmbf in the BTP analysis. A multiplier without the indirect/induced jobs components

should be about 1.80 logging jobs/mmbf. The lower multiplier is also consistent with previous 

multipliers derived from past Forest Service and ADOLWD information prior to 2012. 

56. Other anecdotal evidence supports the exclusion of the indirect and induced jobs 

from the BTP analyses. The timber industry has repeatedly claimed that the prolonged industry 

contraction has resulted in the loss of more and more local vendors that once catered to the 

timber industry and the closure of rural schools, i.e., the indirect and induced jobs.

57. The whole premise for additional timber sales like the BTP is based on flawed 

methodologies which forecast how much Tongass timber sawmills will need, the volume of new 

timber sales to prepare for sale and the longer term future demand for Tongass timber.

58. The first wrong-headed methodology is commonly known as the Morse 

methodology and is named after former Forest Service economist. It has been used since 2000 

and has consistently overestimated the need for additional Tongass timber sales as well as the 

amount of Tongass timber the industry is willing to buy.

59. The fundamental flaw in the Morse methodology is demonstrated by the trends in 

actual Tongass timber purchases and the utilization rates of mills sawing Tongass timber.

60. There has been a huge disparity (called a fall-down), between Tongass timber 

offered and the amount actually sold. This disparity is part due to the Morse methodology. 

From 1997 to 2007, 948 mmbf of timber was offered for sale. Of this amount nearly 45% of this 

timber volume did not receive a single bid from the industry. Moreover, 23% of the timber sold 

ended up in cancelled sales.
15

61. The fall-down between volume offered and sold has abated somewhat since 2007 

but is primarily due to the chronic low level of mill activity and not any new policies to better 

bring timber offers like BTP more in line with actual demand.

62. In fact, the Forest Service now wants to offer and sell 600 mmbf in timber sales 

over the next few years. In stark contrast, the Forest Service sawmill surveys show a persistent 

long term decline in installed and operable mill capacity and very low utilization rates

63. Installed and operable mill capacity has decreased from 453 mmbf in 2002 to 155 

mmbf in 2010. If the Forest Service succeeds in selling the 600 mmbf of timber over the next 

few years, the backlog uncut timber under contract will be near or exceed a four year timber 

supply. Such a backlog will even exceed the industry norms for big timber operations in the 

Pacific Northwest. This backlog will certainly exceed the historic norms for Tongass timber 

industry.

64. Also important is the utilization rate for Southeast Alaska mills in terms of 

installed capacity. Since 2002 this rate has been less than 11 percent This is further evidence 

that BTP contribution of 131-148 mmbf towards the Forest Service goal of 600 mmbf of 

Tongass timber sold over the next few years is excessive and well beyond the industry needs.

65. Periodically the Morse methodology is reinforced by longer-term timber demand 

projections by Forest Service Research. Five separate Tongass timber demand projections have 

been conducted covering various periods covering 1980 to 2025. Similar to the Morse 

Methodology, each of these five demand projections has resulted in unrealistic future timber 

demands. More importantly, each projection failed to materialize and is totally inconsistent with 

actual Tongass timber demands.

66. In each of the five timber demand projections, the Forest Service simply assumed

that Tongass timber producers will remain competitive and maintain historic market shares. 

NORTH 

PACIFIC 

TEMPERATE 

RAINFORESTS 

Ecology & Conservation 

Edited by 

GORDON H. ORIANS and 

JOHN W. SCHOEN 

AUDUBON ALASKA and 

THE NATURE CONSERVANCY OF ALASKA 

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LIBRARY OF CONGRESS CATALOGING-IN-PUBLICATION DATA 

North Pacific temperate rainforests : ecology and conservation / 

edited by Gordon Orians and John Schoen. 

pages cm 

ISBN 978-0-295-99261-7 (hardback) 

1. Temperate rain forest ecology—British Colombia. 2. Temperate 

rain forest conservation—British Colombia. 3. Temperate rain 

forest ecology—Alaska. 4. Temperate rain forest conservation—

Alaska. I. Orians, Gordon H., editor of compilation. II. Schoen, 

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6 

Succession Debt and Roads 

SHORT- AND LONG-TERM EFFECTS OF TIMBER 

HARVEST ON A LARGE-MAMMAL PREDATOR-PREY 

COMMUNITY IN SOUTHEAST ALASKA 

David K. Person and Todd J. Brinkman 

INTRODUCTION 

Unlike most regions of North America, the rainforests of southeast 

Alaska and northern coastal British Columbia retain most of their postglacial legacy of wildlife (MacDonald and Cook 2007). Along with fish and 

other marine foods, those wildlife resources helped to sustain human 

populations for at least 9,000 years before the arrival of Europeans, despite 

dramatic postglacial geological and ecological changes to the landscape 

(Baichtal and Swanston 1996; Larsen et al. 2005; Carstensen 2007). Beginning in the 1950s, industrial-scale harvesting of timber occurred throughout much of the region. In coastal British Columbia, 67% of watersheds 

greater than 5,000 ha were developed by 1991, mostly for logging (Lertzman and MacKinnon, this volume, chapter 8). From 1954 to 2008, greater 

than 325,000 ha of rainforest were clear-cut logged and greater than 6,000 

km of road were built in southeast Alaska (Albert and Schoen 2007a). Prior 

to logging, the coastal forest landscape was a product of edaphic factors, 

long-term abiotic forces, and short-term agents of disturbance such as 

wind and disease (Alaback et al., this volume, chapter 4). Industrial-scale 

clear-cut logging does not mimic the natural agents and patterns of disturbance, and it initiates a chain of events that have complex ecological and 

social implications (Hanley 1993; Kramer et al. 2001; DellaSala et al. 2011; 

143 
Alaback et al., this volume, chapter 4). In addition, roads built to facilitate 

logging provide new pathways of access, enabling the footprint of human 

activity to extend into previously remote inland areas. Roads alter ecosystems in ways that affect ecological processes, populations of plants 

and animals, and human interactions with landscapes (Forman and 

Alexander 1998; Trombulak and Frissell 2000; Forman et al. 2003; Brinkman et al. 2007; Brinkman et al. 2009). In southeast Alaska and coastal 

British Columbia, those changes have profound and long-term effects on 

many wildlife species and the ecological communities with which they 

are linked. 

The inexorable process of forest succession following clear-cut logging 

in North Pacific rainforests transitions through several distinct stages 

with varying effects on wildlife, but it ultimately reaches a condition (corresponding to the stem exclusion stage) that is largely unproductive for 

many species (Alaback 1982; Schoen et al. 1988; Alaback et al., this volume, 

chapter 4). We refer to circumstances affecting wildlife populations resulting from that chain of events as succession debt (Person 2001). Short-term 

economic and social benefits of industrial harvesting of timber will be paid 

for by long-term ecological consequences resulting from patterns and 

processes of forest succession and roads. There may be short-term benefits 

for some wildlife species, but succession debt implies that those benefits are 

ephemeral and do not reflect conditions for those species over the long term. 

Although succession debt will affect many species of forest-dependent 

wildlife within coastal British Columbia and southeast Alaska, we chose 

to illustrate this concept by focusing on the realized and potential effects 

of timber harvest and roads on a predator-prey ecological community 

located on Prince of Wales Island in southeast Alaska. The system is a 

complex network of marine and terrestrial influences and includes several 

predators, fish and ungulate prey, human hunters, and the land and seascapes upon which they all depend. Although our case study focuses on 

predator-prey dynamics within North Pacific temperate rainforests, it 

highlights the general difficulties of conserving large mammalian carnivores within rapidly changing landscapes and is relevant to other forest 

ecosystems exposed to large-scale anthropogenic disturbance. Moreover, by 

discussing changes at a community level, we encourage a systems approach 

to thinking about effects of those disturbances rather than focusing on 

individual species (Dörner 1996). 
THE PREDATOR-PREY COMMUNITY 

ON PRINCE OF WALES ISLAND 

Prince of Wales Island is located within the southern portion of the Alexander Archipelago in southeast Alaska (fig. 6.01). It is 6,700 km2and is the 

third largest island in the United States. The landscape is dominated by 

rugged mountains less than 1,20o m high, the slopes of which are covered 

mostly by a mosaic of coniferous forests and muskeg heaths. Most of the 

land is encompassed by the Tongass National Forest, however, more than 

178,000 ha (8%) are owned by the state of Alaska and private landowners, 

which include Alaska Native corporations. Under provisions of the Alaska 

Native Claims Settlement Act (1971), more than 30,000 ha of additional 

forest land may be conveyed to Native corporations within the next decade. 

Approximately 130,000 ha of productive timberland (about 29% of the 

productive old growth) were clear-cut logged on private, state, and federal 

lands from 1955 to 2005 (Albert and Schoen 2007a). Most nonfederal lands 

were logged from 1980 through 2009. In addition, more than 4,000 km of 

road were built, mostly to facilitate logging. About 20% of the land area was 

logged and is in various stages of forest succession; 39% of the area is oldgrowth forest containing a volume of timber more than 45 m3/ha, and the 

rest is alpine, muskeg heath, or scrub forest. Sitka black-tailed deer (Odocoileus hemionus sitkensis), wolves (Canis lupus ligoni), black bears (Ursus 

americanus), and beaver (Castor canadensis) are the principal components of a complex large-mammal predator-prey system. Numerous lakes 

and streams sustain large populations of anadromous and resident fish. 

Salmon (Oncorhynchus spp.) are important prey for both wolves and bears 

and serve as key agents in cycling nutrients between aquatic and terrestrial ecosystems (Willson and Halupka 1995; Hocking and Reimchen 

2002; Gende et al. 2004; Darimont and Reimchen 2002). Hunting deer for 

subsistence is an important activity. For many local residents, venison 

constitutes their only supply of red meat (Brinkman et al. 2009). In addition, bear, wolves, beavers, and salmon are harvested by hunters, trappers, 

and fishers. Consequently, humans also play a critical role in the predatorprey community as predators on all component species and agents of habitat change. 

The US Forest Service's Tongass Land and Resource Management 

Plan (TLMP) established a series of old-growth forest reserves as part of 

CHAPTER 6 • 145 
ra. 

Kosciusko I. 

Heceta I. 

it, go 

0 

ea 

-41 

50 km 

c 

FIGURE 6.01. Prince of Wales Island in southeast Alaska. Also shown are Heceta 

and Kosciusko islands. Game management unit 2 designated by the Alaska Department of Fish and Game encompasses Prince of Wales and all of the smaller adjacent 

islands. 

a comprehensive strategy for the conservation of biodiversity (USDA 

Forest Service 1997a, 2008a). In theory, the reserves are expected to preserve sufficient high-quality habitat to sustain ecological communities, 

such as the wolf-bear-deer predator-prey system on Prince of Wales 

Island, in the absence of suitable habitats within the intervening matrix 

of managed lands. In addition, TLMP-specified guidelines for managed 

lands are intended to reduce the risk of wildlife populations becoming 

extirpated or ecological functions becoming impaired (USDA Forest 

Service 2008a). 

146 • PERSON AND BRINKMAN 
Prey 

Suitable habitats for deer, beavers, and salmon are essential for the viability 

of the predator-prey ecological community on Prince of Wales Island. 

Humans have altered habitats and landscapes that affect each of those prey. 

DEER. Prince of Wales Island supports 6o,000 to 70,000 Sitka black-tailed 

deer, a small subspecies of mule deer adapted to northern Pacific old-growth 

rainforests (Person et al. 2009). Deer are the principal prey of wolves and 

an important prey for black bears (Person et al. 1996, Kohira and Rexstad 

1997). Old-growth forest stands contain a mix of young, subdominant, and 

older dominant trees that create a canopy of multiple layers (see Alaback 

et al., this volume, chapter 4). The dense forest canopy intercepts snow and 

rain, but numerous gaps allow sunlight to penetrate to the forest floor, 

enabling understory plants that provide important food for deer to flourish. 

Within five years after the forest canopy is removed by logging, vegetative 

growth responds to unrestricted sunlight by producing an abundance of 

forage, although much is of lower quality compared with the same species 

of plants grown in shade (Hanley and McKendrick 1983). Forage biomass 

reaches maximum abundance on productive sites 12 to 19 years after logging 

(table 6.1; Alaback 1982; Farmer and Kirchhoff 2007). Consequently, over the 

short-term (0-19 years after logging), clear-cutting enhances the quantity 

(but not the quality) of forage available to deer during summer and mild 

winters. Nonetheless, naturally regenerating conifers begin to form a dense 

canopy 20 to 3o years after logging that shades out understory plants (Alaback 1982). Eventually, young seral stands enter a stem exclusion stage in 

which the dense canopy of even-aged young trees almost completely eliminates forage plants, creating unproductive year-round habitat conditions 

that may last more than 15o years. Although during summer and mild winter conditions, deer may benefit from young clear-cuts, the long-term prognosis is permanent loss of suitable foraging habitat. 

Deer populations in southeast Alaska and coastal British Columbia 

contain resident and migratory deer (Schoen and Kirchhoff 1985; McNay 

and Voller 1995). During summer, migratory deer move up in elevation as 

snowline recedes and eventually occupy lush alpine meadows composed 

of highly nutritious deciduous forbs situated above 600 m elevation. 

Migratory deer remain there until snowfall or senescence of deciduous 

plants in autumn forces them to move down to forested hillsides at lower 

CHAPTER 6 • 147 
TABLE 6.1. Forage biomass (kg/ha) available to deer during summer 

in different habitats on Heceta Island in southeast Alaska (Farmer 2002; 

Farmer and Kirchhoff 2007). Data represent averages of oven-dried 

weights of evergreen and deciduous herbaceous forbs and Vaccinium 

spp. shrubs (current annual growth) sampled within 0.2-ha circular 

plots (n = 394). 

HABITAT CLASS (N) 

EVERGREEN 

FORBS SE 

DECIDUOUS 

FORBS SE SHRUBS SE 

Clearcuts <20 years old (73) 290.8 23.0 7.6 1.3 67.0 4.5 

Clearcuts 20-39 years old (47) 168.5 47.0 8.6 2.2 71.7 10.3 

Open-canopy old growth' (77) 165.1 16.9 19.9 2.8 38.8 3.7 

Productive old growthb(118) 105.3 11.9 9.0 1.3 46.8 3.1 

Nonforestc(29) 94.6 16.9 32.0 8.3 14.5 3.3 

Riparian spruce old growths (5) 57.1 49.7 12.1 7.7 29.2 17.8 

Stem-exclusion seral forest' (45) 10.6 7.8 1.3 1.2 2.4 1.0 

a Old-growth forest with timber volume <58.3 m3/ha. 

b Old-growth forest with timber volume >=58.3 m3/ha. 

c Sparsely forested and nonforested lands, mostly muskeg heaths and alpine habitats. 

d Closed-canopy old-growth forest with timber volume >=290 m3/ha situated on productive alluvial soils. 

e Clear-cuts >39 years old. 

elevations. Migratory deer tend to overwinter in forested habitat at higher 

elevations than resident (nonmigratory) deer, although severe winter 

weather may force them to move down into valley bottoms where they 

compete with resident deer for winter forage. Resident deer do not move 

to alpine habitat during summer and remain within the same home ranges 

throughout the year. On Prince of Wales Island, resident deer generally 

select young clear-cuts (<20 years post-logging) and open-canopy forest 

stands during summer and mild winters (Yeo and Peek 1992; Farmer 2002; 

Doerr et al. 2005; Person 2009). When snow depths exceed 10 cm, most of 

the herbaceous plants in open habitats are buried, making important forage unavailable to deer. Cost of locomotion increases dramatically as 

depth of snow approaches chest height (5o cm) (Parker et al. 1984), and 

deer (resident and migratory) select old-growth forest stands with basal 

areas greater than 45 m3/ha where snow depth is less and evergreen forbs 

148 • PERSON AND BRINKMAN 
and shrubs are still available. During severe winters when snow depth 

exceeds brisket height, most deer select productive old-growth stands with 

a volume of timber greater than 175 m3/ha at elevations below 24o m and 

avoid northerly exposures (Kirchhoff and Schoen 1987; Schoen and Kirchhoff 1990). Some deer may escape deep snow by moving to beaches and 

feeding on kelp and other seaweed. Mortality of deer from malnutrition, 

disease, and predation often is high during those winters (Schoen et al. 

1988; Farmer et al. 2006; Person et al. 2009; Brinkman et al. 2011). Climate 

change may bring milder winter conditions on average, and it is tempting 

to speculate that winter habitat will become less important in the future 

(Scenarios Network for Alaska Planning 2009). Nonetheless, precipitation 

and probability of extreme storms may increase, and with it, risks of deep 

snow. Indeed, despite almost 3o consecutive years of relatively mild conditions, extreme snowfall occurred during the winter of 2006-2007 that 

substantially reduced deer numbers throughout southeast Alaska. Predation during and shortly after those winters can drive ungulate populations 

to very low levels, from which it may take years to recover. Consequently, it 

is not average conditions that really matter, but the probability of extreme 

events. 

Clear-cut logging fragments forest patches, increasing edges; roads 

built to facilitate logging also contribute to forest fragmentation. Deer are 

attracted to forest edges and roadsides presumably because penetration of 

sunlight supports abundant forage production (Doerr et al. 2005). Nonetheless, deer that use edges and areas adjacent to roads frequently are at 

increased risk of predation by wolves, harvesting by hunters, and vehicular 

collisions (Person 2001; Farmer et al. 2006). Fragmented landscapes composed of small patches of old-growth timber may trap deer in those 

patches during winters in which snow hinders movement between patches 

(McNay 1995). Indeed, habitat suitability models for black-tailed deer in 

coastal British Columbia include distances between forest patches as a 

critical parameter (BC Ministry of Forests 1996). Mortality from predation 

and malnutrition may be high in logged and fragmented watersheds during snowy winters (Farmer et al. 2006), and deer populations may decline 

rapidly as a result (Brinkman et al. 2011). 

OTHER PREY. Although deer are the principal prey of wolves, other species are important, particularly when deer abundance is low. Beaver frequently are consumed by wolves, but very little is known about their 

CHAPTER 6 • 149 
ecology in the region (Person et al. 1996; Kohira and Rexstad 1997). In 

coniferous forests of the Pacific Northwest, hardwoods such as alder 

(Alnus spp.) established along streams and on disturbed sites are important sources of food for beavers (Leidholt et al. 1989). In southeast Alaska, 

anecdotal evidence from trappers suggests beavers may benefit from alder 

regeneration on roadbeds and sites disturbed by logging; however, there 

are no data useful for evaluating population effects of logging or roads. 

Certainly, beavers take advantage of roadbeds adjacent to stream crossings by blocking culverts and allowing the road to dam the watercourse. 

Nonetheless, roads also provide trappers with convenient access to beaver 

habitat. Dams created by beavers may have negative effects on some anadromous fish such as sockeye (Onchorhynchus nerka) and chum (0. keta) 

salmon by blocking spawning migrations (McCurdy 2008) and a positive 

effect, particularly for coho salmon (0. kisutch), by creating pools (Bryant 

and Everest 1998). 

Salmon are very important seasonal prey for wolves and bears (Person 

et al. 1996; Kohira and Rexstad 1997; Darimont and Reimchen 2002; Peacock 2004). Indeed, wolves often locate rendezvous sites near spawning 

streams and estuaries where they have easy access to salmon during 

August through October (Person and Russell 2009). In coastal British 

Columbia, Darimont et al. (2008) concluded that the availability of salmon 

seasonally decoupled wolves from their reliance on ungulate prey. Salmon 

are a critical resource for bears prior to hibernation and are likely a principle factor in sustaining high densities of black bears on Prince of Wales 

Island and elsewhere in the northern rainforests of Alaska and British 

Columbia. Fish, particularly salmon, are a vital food source for human 

subsistence. In addition, commercial and recreational fishing industries 

are the largest and most stable contributors to the island economy (Everest 

2005; Crone and Mehrkens, this volume, chapter 5), but this is not necessarily the case on much of the north coast of British Columbia. 

Clear-cuts and roads can change patterns of runoff and water flow and 

remove trees that are the sources of large woody debris in streams (Heifetz 

et al. 1986; Murphy and Koski 1989). In logged areas, streams may become 

channelized, banks destabilized, and pools for rearing fish lost, although 

unlogged forest buffers along streams and rivers can provide a source of 

woody debris and stabilize banks if they are wind firm (Murphy et al. 1986). 

Logged hillsides and roads increase the frequency of landslides, leading to 

soil erosion and sedimentation (Montgomery 1994; Swanston 1997). More 

150 • PERSON AND BRINKMAN 
immediately, roads may impair movement of fish throughout watersheds 

when culverts and other stream crossing structures are improperly 

designed or installed, or become blocked because of inadequate maintenance (Flanders and Cariello 2000; USDA Forest Service 2002). Many 

species of anadromous and resident fish must be able to migrate seasonally 

within watersheds to reach spawning and rearing habitats (Armstrong 

1974; Bryant and Lukey 2004). 

Abundant rainfall in the region creates high densities of streams and 

rivers that must be crossed when roads are built. In the Tongass National 

Forest, permanent roads cross anadromous fish streams more than 920 

times and resident (nonanadromous) fish streams more than 1700 times 

(Flanders and Cariello 2000). Those numbers do not include temporary 

roads designed for short-term use, roads built on state and private lands, 

or roads crossing streams in which fish populations have not been documented. A survey of road conditions on national forest lands, including 

Prince of Wales Island, indicated that only 34% of culverts and bridges 

intersecting anadromous fish-bearing streams were adequate for adult and 

juvenile fish passage, and only is% were adequate for passage of resident 

fish (Flanders and Cariello 2000). Surveys of forest roads on private lands 

on Prince of Wales Island showed similar results (Nichols and Frenette 

2003). Most culverts were perched above the water level of the stream or 

the slope gradient was too steep to accommodate fish. Structures that did 

not block fish generally were recent installations, indicating that current 

standards may be adequate. Nonetheless, the legacy of older bridges and 

culverts is a persistent problem that affects the functioning of riparian 

ecosystems and may influence fish populations over the long term. 

Predators 

Wolves, bears, and humans all consume or exploit deer, beavers, and salmon 

on Prince of Wales Island, and therefore, they may compete for those 

resources during periods of scarcity. In addition, anthropogenic changes to 

landscapes and habitats influence the availability of prey to wolves and bears, 

and roads increase the risk of wolves and bears being killed by humans. 

WOLVES. Wolves on Prince of Wales Island are an insular population 

(about 250-300 animals) probably derived from a few founders that 

reached the island before it was isolated from other islands and the mainCHAPTER 6 • i i 
1.4 0- 

1.2 0- 

1.0 0- 

0.8 0- 

Road density s 0.9 ~--- ---► Road density > 0.9 

0 

y = (0.073 + 1.126x)2 

O 

0 

0 

0 

00 

0 

0 0 

0.6 0- 0 0 

0.4 

0.2 

0- 

0- 

o g, 

0 

0 

0 

0 0 

0 

0 

0.0 0- 

I 1 I I I I I i I I 1 

0.00 0.20 0.40 0.60 0.80 1.00 1.20 1.40 1.60 1.80 2.00 

Road density (km/km2) 

FIGURE 6.02. Relationship between road density (km/km2) and average annual 

harvest rate of wolves (wolves/100 km2) within all 32 wildlife analysis areas in game 

management unit 2 (Prince of Wales and adjacent islands), 1990-1999. Harvest rate 

is square root transformed to stabilize variance for analysis by linear regression. 

Data and figure are from Person and Russell (2008). 

land by postglacial rise in sea level (Weckworth et al. 2005). Wolf populations are composed of resident pack members and nonresident wolves that 

are dispersing or are floating between several packs prior to or shortly 

after terminating dispersal (Person 2001; Person and Russell 2008). Wolves 

primarily prey on deer, annually consuming an estimated 18 to 32 deer per 

wolf (Person et al. 1996). In addition, salmon and beavers may constitute 

as much as 25% of the volume of their diet (Kohira and Rexstad 1997; Person et al. 1996; Szepanski et al. 1999). 

Wolves strongly avoid young seedling and shrub-sapling stage clearcuts but may move through older stem exclusion stands (Person 2001). 

Wolves avoid clear-cuts and seral forest stands when selecting den sites, 

however, they tend to be tolerant of logging and other human activity near 

dens if the disturbances are of short duration (Person and Russell 2009). 

Roads offer convenient pathways for wolves through logged watersheds, but 

they also provide access to humans, increasing risk of death of wolves from 

152 • PERSON AND BRINKMAN 
Season Closed Early 

By Emergency Order 

30% Harvest Cap _....~ 

Implemented In 

1997 

Harvest Cap 

Wolf Harvest 

140-

120-

100-

80-

60— 

40 -

20-

0— 

I 1 1 I I I 

1990 1991 1992 1993 1994 1995 

I I I I I I I I I 

1996 1997 1998 1999 2000 2001 2002 2003 2004 

Year 

FIGURE 6.03. Wolf harvest in game management unit 2 (Prince of Wales and adjacent islands), 1990-2004. Harvest reached unsustainable limits in the mid-1990s, 

and the Alaska Board of Game implemented a harvest cap in 1997. The harvest quota 

was set at 30% of the estimated autumn wolf population in the unit. In 1999, the 

wolf-trapping season was closed by emergency order to prevent overharvest. Doubleheaded arrows indicate periods in which reliable population estimates of wolves were 

available. Figure and data are from Person and Russell (2008). 

hunting and trapping (Person and Russell 2008). Even roads that are closed 

to vehicular travel provide convenient trails that facilitate harvest by 

humans. Person and Russell (2008) demonstrated a strong positive linear 

relation (r = 0.89) between road density less than or equal to 0.9 km/km2 

and harvest rates (fig. 6.02). They reported that densities greater than o.9 

km/km2 likely resulted in unsustainable harvest. They also reported that 

87% of mortality of wolves on Prince of Wales Island was from hunting and 

trapping. Annual survival rate of dispersing wolves (17%) was very low, with 

most shot or trapped before settling. Wolves are harvested legally during 

hunting and trapping seasons. Annually, about 50 to 95 wolves are killed 

and reported, but illegal take may at times equal the legal harvest (Person 

and Russell 2008). From 1990 through 1999, wolf harvest reached unsusCHAPTER 6 • 153 
tainable levels, particularly within roaded watersheds, resulting in early 

closure of the trapping season in 1999 (fig. 6.03; Person and Russell 2008). 

BLACK BEARS. There are few data concerning the ecology and demography 

of black bears in northern temperate rainforests; only harvest data are available for bears on Prince of Wales Island. Nonetheless, in southeast Alaska 

the densities of black bears were reported as high as 1.5 bears/km2within 

watersheds containing productive salmon streams and clear-cuts less than 

25 years old (Peacock 2004). Bears are inactive in dens from November 

through April; dens are often located in hollow logs, dead standing trees, 

rock crevices, and ground nests on northern aspects (Erickson et al. 1982). 

When bears emerge in late March and early April, they forage on emergent 

vegetation and marine foods found along beaches. They feed on carcasses 

of deer that died during winter; however, they also may kill adult deer 

when the opportunity arises (Person 2009). The most important predation 

is on neonate fawns during late May and early June. For example, during a 

3-year study of mortality of deer fawns on a portion of Prince of Wales 

Island, bears killed 6o (39%) of 154 radiocollared neonate fawns within 1 

month of birth. (Alaska Department of Fish and Game 2010, 2011, 2012). 

During midsummer, bears consume large quantities of berries and appear 

to be attracted to young clear-cuts because of the abundance of blueberry 

shrubs (Vaccinium spp). Indeed, Schwarz and Franzmann (1991) reported 

black bear density to be higher in watersheds dominated by early successional forests compared with landscapes composed of older-seral forests. 

When salmon spawning begins in August, bears congregate in estuaries 

and along streams and rivers where low tide or shallow pools enable them 

to catch fish. Bears play an important role in transferring nutrients from 

anadromous fish to terrestrial ecosystems via their feces (Hildebrand et al. 

1999). Spawning ebbs in late September, and thereafter bears consume deer, 

vegetation, and late-season berries as they make their way to winter dens. 

Black bears are harvested year round except June 15 through August 31. 

From the years 2000 to 2009, 300 to 500 bears were harvested annually on 

Prince of Wales Island by mostly nonresident recreational hunters (Porter 

2008). Providing logistic support to those hunters is a significant source of 

revenue for many local people, particularly during spring before popular 

summer fishing seasons open. Many hunters prefer to hunt for bears along 

logging roads that give them access to young clear-cuts, muskegs, and 

stream crossings where bears are visible. Roads and young clear-cuts may 

154 • PERSON AND BRINKMAN 
facilitate unsustainable harvesting of bears. Indeed, in 2009 the Alaska 

Department of Fish and Game restricted hunters from using road vehicles 

to access bear habitat on Prince of Wales Island in an attempt to reduce 

harvest to a sustainable level (Boyd Porter, pers. comm.). 

HUMANS. Human occupants on Prince of Wales Island historically 

focused on marine food resources such as fish and shellfish. They also used 

boats to hunt deer and trap furbearers along beaches, particularly during 

winter. Thus, island interiors served as refugia for deer, wolves, bears, and 

furbearers. As logging proceeded in southeast Alaska and roads were built, 

subsistence hunters and trappers began changing their harvesting practices 

from using boats to using vehicles on roads to hunt inland areas (Ellanna 

and Sherrod 1987; Brinkman et al. 2009). Young clear-cuts, dominated by 

seedling conifers, became important habitat for hunters because deer were 

visible from roads. Roads increased the desirability of deer as a stable food 

resource because they were available during times of the year when marine 

resources were less abundant, and bad weather conditions had less effect 

on vehicle use than on boats. Hunting deer from roads required less time 

and effort than traditional strategies (Brinkman et al. 2009), causing most 

hunters to focus more on deer and less on marine resources (Ellanna and 

Sherrod 1987). Further, the timber industry attracted workers to southeast 

Alaska from the contiguous United States who were already accustomed 

to road-based hunting and trapping (Mazza 2003). Within one generation 

from the beginning of industrial-scale logging, hunting and trapping from 

roads largely replaced the traditional shoreline harvesting patterns of 

many local people (Brinkman et al. 2007). Hunters legally harvest 2,500 to 

3,000 deer annually on Prince of Wales and adjacent islands; however, 

many more deer are killed illegally (Porter 2007). The area supports about 

60,000 to 70,000 deer (Person et al. 2009), therefore, harvest removes 4%-

8% (mostly adult and yearling males) of the deer population each year. 

SUCCESSION DEBT: SHORT-TERM BENEFITS 

VERSUS LONG-TERM CONSEQUENCES 

Predator-prey dynamics frequently are described as top-down (predator 

mediated) or bottom-up (habitat mediated), divisions that cannot be applied 

as discrete explanations of the dynamics of complex predator-prey systems, particularly those involving long-lived mammals within rapidly 

CHAPTER 6 • 155 
changing environments (Ballard et al. 2001; Bowyer et al. 2005; Jedrzejewska and Jedrzejewski 2005). Bottom-up systems generally are regulated by 

the productivity of habitats and intrinsic rates of growth of prey, whereas 

top-down systems are governed by the density of predators and rates of 

kill. In reality, the dynamics of predator-prey systems shift along a continuum of integrated processes that are mostly bottom-up at one extreme 

or mostly top-down at the other (Bowyer et al. zoos; Jedrzejewska and 

Jedrzejewski 2005), and they may change over time. In temperate rainforest ecosystems such as that on Prince of Wales Island, industrial-scale 

timber harvest reduces carrying capacity for deer, shifting predator-prey 

dynamics from a largely bottom-up driven system to one in which topdown forcing (predator limitation) exerts greater control (Person 2001). 

Clear-cuts younger than 3o years and open-canopy forest provide deer with 

abundant forage during snow-free months. Those habitats also offer deer 

some protection from predation by wolves. Mortality of deer in extensively 

logged watersheds is high during severe winters, but their numbers 

rebound quickly during mild years despite effects of predation and hunting, indicating that population regulation is strongly influenced by bottom-up processes. Therefore, deer thrive in watersheds dominated by early 

successional forest stands, provided winters are mild. 

Between 1955 and 2005, about 22% of deer summer range was clear-cut 

logged on state, federal, and private lands on Prince of Wales Island. Of the 

subset of those lands below 24o m elevation and on southerly aspects 

(90o-270o that constitute important winter range for deer, 38% was clearcut by 2005. It is likely that an additional 5%-1o% of deer winter range will 

be logged in the next 20 years, depending on the implementation of TLMP 

and transfers of lands to private timber corporations. Currently, the 

median age of a hectare of second-growth forest on federal lands is 34 

years. About 75% of all second growth on federal lands is greater than 20 

years old. On state and private lands the median age likely is about 5 to 10 

years less. Deer are abundant and may remain so during part of the next 

decade (Brinkman et al. 2011). Nonetheless, as clear-cuts continue to age, 

carrying capacity for deer within logged watersheds (that have transitioned into sterile second-growth habitat) will decline, and the resilience of 

deer to winter weather, predation, and hunting will diminish. Netannual 

recruitment of deer also will decline, but in a disproportionate and nonlinear fashion (fig. 6.04). Net annual recruitment represents the portion of 

a deer population that can be removed additively by predation and hunting 

156 • PERSON AND BRINKMAN 
Removed 

By 

Predators 

POPULATION OF DEER 1,000 

K =1,000 

K = 800 

K = 600 

0— 

NET RECRUITMENT 

- 62% 

- 38% 

~ t 

11111 

1,000 800 600 400 200 

K 

FIGURE 6.04. Relationships between net annual recruitment for deer and population density (top graph), and area under recruitment curve and changes in carrying 

capacity (K) (bottom graph). Area under the recruitment curves is reduced in a negative exponential fashion as K is reduced. That area represents the pool of recruits 

available for removal by predators and hunters without causing a decline in deer 

population. A 38% decline from historical levels in deer habitat capability (carrying 

capacity) would reduce the area under the curve by 68%. Time lags in the numerical 

response of predators to declining deer abundance will mean that they will remove 

a larger portion of net annual recruitment as K declines. That will increase competition between predators and hunters for deer and will shift the predator-prey systems 

more strongly toward top-down limitation. 

without causing a decline in population. Wolves and bears will remove an 

increasing proportion of that recruitment until deer populations decline in 

heavily logged watersheds dominated by stem exclusion seral forest (Person 

2001). Future harvesting of seral forest may return those stands to states 

that are productive for deer but will still leave them vulnerable to severe 

winter weather with deep snow packs. Moreover, harvesting second growth 

depends on future demand for Alaska timber, which may be weak owing to 

the high costs of production, transportation, and competition from producers located where wood is cheaper to grow, harvest, and transport (Crone 

2005; Crone and Mehrkens, this volume, chapter 5). 

W 

0 

CHAPTER 6 • 157 
Wolf packs will respond to a decline in deer density in logged watersheds by focusing on areas where deer abundance is higher (unlogged 

watersheds) or by expanding home ranges into neighboring pack territories, causing strife between packs. Wolves may also focus on alternative 

prey, but it is unlikely that salmon, which are only seasonally available, and 

beavers will sustain them indefinitely if deer abundance becomes very low 

(Person et al. 1996; Person 2001). Nonetheless, predation on salmon may 

temporarily decouple synchrony between deer and wolf population trends 

by subsidizing summer survival of wolves, particularly pups (Person 2001; 

Darimont et al. 2008). Thus, the time delay between a decline in deer 

population and similar trend in wolves would be lengthened, causing a 

stronger and more rapid shift toward top-down forcing. 

Black bears are not obligate predators of deer; thus in the short term, a 

decline in deer will not precipitate a simultaneous decline in bears, a circumstance that likely will exacerbate the effects of bear predation on deer. 

Eventually, the predator-prey system will shift strongly toward top-down 

forcing, resulting in a more rapid decline in deer population than would 

be predicted from simply loss of carrying capacity, as well as periods in 

which deer populations within logged watersheds are suppressed well 

below carrying capacity by predation (fig. 6.05; Person 2001). 

Migratory deer tend to be at lower risk of predation and benefit from 

abundant forage in alpine areas during snow-free months (McNay and 

Voller 1995). They will be less affected by loss of carrying capacity within 

logged stands, which tend to be concentrated at low elevations. However, 

during severe winters when they are pushed down into the valley bottoms, 

migratory deer will be exposed to the same habitat conditions and risks of 

predation endured by resident deer. Populations of migratory deer should 

rebound more quickly than resident deer during mild years because they 

have access to high-quality range in summer and have lower risk of predation. Consequently, the ratio of migratory deer to resident deer within 

logged watersheds adjacent to alpine terrain should increase over time. 

As deer numbers decline and predator-prey dynamics shift more 

strongly toward predator limitation, subsistence and recreational hunters 

increasingly will be alarmed at what they perceive as competition by 

wolves and bears for deer. Strong proprietary attitudes concerning deer 

exist within many communities on the island and many resident hunters 

resent sharing "their deer" with off-island hunters. Protective attitudes will 

precede actual changes in deer population because clear-cuts greater than 

158 • PERSON AND BRINKMAN 
• 500• 

0 

r-4 400 

-J 

o. 300 ' 

0 

LL 200 

100 

- 

— Mean 

--- 95%C. I. 

— • Minimum 

0 

1955 1975 1995 2015 2035 

YEAR 

DEER POP. (x1,000) 

120' 

100 

80 "--"-~_ 

60• 

40 —.,- Mean 

20 --- 95% C. I. 

— • Minimum 

K 

0

1955 1975 1995 2015 2035 

YEAR 

FIGURE 6.o5. Results averaged for 2,000 Monte Carlo simulations of a predatorprey model described by Person (2001) that represents past and future conditions 

on Prince of Wales and Kosciusko islands in southeast Alaska. Simulations account 

for timber harvest and road construction on federal, state, and private lands; harvest 

of wolves and deer; and periodic severe winters in which all recruitment to the deer 

population is lost. Changes in carrying capacity (K) represent loss of deer habitat 

capability predicted in the Tongass Land Management Plan. Results indicate that 

wolf and deer populations will decline substantially by 2045. Decline in the deer population will be disproportionately greater than the proportional loss of K. Simulations 

10do not account for bear predation on deer. 

 years old usually are unsuitable for hunting (as a result of increasing 

cover) despite supporting abundant deer (Brinkman 2007; Brinkman et al. 

2009). Therefore, unless new cuts are created at the rate existing ones 

become too old to hunt, there will be a net loss of land preferred for hunting, even along roads that remain open to vehicle use. As a result, as clearcuts age, hunters will perceive fewer deer in popular hunting areas; feelings 

of competition with wolves, bears, and other hunters will increase 

demands for liberal harvests of predators and restrictions on hunting by 

off -island hunters. Indeed, a perception of competition led to federal regulations implemented in 2003 that restricted hunting opportunities for 

most off-island hunters (Brinkman et al. 2007). Legal and illegal take of 

CHAPTER 6 • 159 
deer, wolves, and bears likely will increase particularly in watersheds 

accessible by roads or from boats (Person et al. 1996; Person 2001), and they 

may be overharvested despite regulations designed to sustainably manage 

their populations (Person and Russell 2008). In time, subsistence harvesters may return to a diet that focuses more on seafood. However, salmon 

spawning and survival of young may be impaired if the long-term effects 

of logging and roads on stream habitat are not properly addressed. In that 

event, fewer fish would be available to sustain populations of black bears, 

provide alternative prey for wolves, and satisfy subsistence needs. Eventually, populations of deer, bears, and wolves in logged landscapes dominated 

by stem-exclusion forest may only be a fraction of what they were historically (Person 2001). 

Succession debt refers to the fact that a healthy predator-prey ecological community during the early stages of forest succession after logging is 

not a reliable indicator of future conditions. As the capacities of logged 

landscapes to support deer diminish, nonlinear predator-prey dynamics 

will dramatically alter those conditions such that populations of wolves, 

black bears, and deer likely will decline substantially. Moreover, social factors will complicate the situation and could result in further depletion of 

some species, particularly if harvest (both legal and illegal) is facilitated by 

roads that leave few inaccessible refugia. In particular, the viability of the 

wolf population on Prince of Wales and adjacent islands could be at risk 

(Person 2001). 

A similar process involving black-tailed deer, wolves, black bears, and 

cougars (Fells concolor) developed on Vancouver Island in British Columbia (Hatter 1982; Atkinson and Janz 1994; BC Ministry of Forests 1996). 

Beginning in the 1960s, extensive logging eliminated important winter 

range for deer, compromising their resilience to predation, hunting, and 

winter weather (BC Ministry of Forests 1996). Deer numbers declined, 

hunting opportunities for deer were restricted, and predator control was 

implemented as an emergency measure to restore deer (Hatter 1982; Atkinson and Janz 1994). Despite reducing predators, deer population density 

remains much lower than historical levels, and wildlife managers chronically are concerned about the effects of predators on deer. In a further 

twist, because of low deer population and isolation of habitat, wolves were 

suspected of being significant predators of Vancouver Island marmots, an 

endangered species (Bryant and Page 2005). 

160 • PERSON AND BRINKMAN 
DISCUSSION AND MANAGEMENT IMPLICATIONS 

Globally, the conservation of large-mammal predator-prey systems disturbed by extensive environmental changes and subject to competing 

human interests is a daunting challenge, because the objective must be to 

sustain the entire ecological community rather than focusing on individual species. In many places, including southeast Alaska, planning for and 

implementing actions to conserve ecological communities is more difficult 

because multiple management agencies are responsible for different components and often have priorities and mandates that are contradictory. 

Treating individual discrete components of a complex system without 

regard to interactions between those components is a recipe for failure 

(Dörner 1996). For example, on Prince of Wales Island, simply closing 

roads or changing harvest regulations to protect wolves will not guarantee 

the population remains viable if landscapes can no longer sustain abundant and resilient deer populations (Person 2001). Indeed, it is likely that 

as the predator-prey system shifts more strongly towards top-down limitation, wolves will need to be harvested to some extent to prevent depletion of deer (fig. 6.06). The challenge will be how to manage that harvest 

to boost deer population without risking the viability of wolves. It is not 

enough to maintain deer abundance sufficient for wolves because subsistence hunters rely on those deer as well, and they will kill wolves legally or 

illegally to protect that resource. The situation is compounded by the 

extensive road network that greatly facilitates human access and eliminates many refugia for wolves. An additional complication is that the wolf 

population is genetically distinct and isolated. If wolves are extirpated or 

reduced to a small population, rescue or recolonization by dispersing 

wolves from the mainland is unlikely. Deer populations must also be resilient to bear predation, which can have a substantial effect on annual 

recruitment. Underlying everything are the social and economic pressures 

to continue logging and sustain a timber industry. As more old-growth 

forest is logged and additional roads constructed, fewer options remain to 

conserve intact ecological systems, yet human interests and needs cannot 

be dismissed easily. 

The Tongass Land Management Plan incorporates a conservation 

strategy that attempts to protect the integrity and functioning of ecological systems on national forest lands in southeast Alaska while allowing 

CHAPTER 6 • 161 
1975 

0 

1955 1995 2015 2035 

YEAR 

120 

c 100 

Tc"80 

Ó 60 

a 40 — Mean 

u

o

j 20 -- - 95% C. I. 

0 — • Minimum 

Wolf Harvest Curtailed 

K 

700 

600 

500 

Wolf Harvest Curtailed 

Mean ' 

--- 95% C. I. 

— • Minimum 

1975 1995 2015 2035 

YEAR 

FIGURE 6.06. Results averaged for 2,00o Monte Carlo simulations of a predatorprey model described by Person (2001) that represents past and future conditions 

on Prince of Wales and Kosciusko islands in southeast Alaska. Simulations account 

for timber harvest and road construction on federal, state, and private lands; harvest of wolves and deer; and periodic severe winters in which all recruitment to the 

deer population is lost. Wolf harvest is hypothetically curtailed in 1996, representing 

changes in regulations if wolves had been listed as threatened under the Endangered 

Species Act by the US Fish and Wildlife Service (see Person et al. 1996). Changes in 

carrying capacity (K) represent loss of deer habitat capability predicted in the Tongass Land Management Plan. Results indicate that if wolf harvest were curtailed, the 

wolf population would still decline in the long term as deer are reduced to very low 

levels. Deer hunters would be alarmed at competition by wolves for deer and likely 

would demand harvests of wolves or kill them illegally. Simulations do not account 

for bear predation on deer. 

industrial-scale harvesting of timber. The plan specifies guidelines for 

densities of roads to reduce risk of mortality of wolves from hunting and 

trapping. It also sets minimum limits for habitat capability (carrying 

capacity) for deer; it is presumed that these limits will sustain deer abundance capable of supporting viable wolf populations and meeting the 

needs of subsistence hunters. Thus, it attempts to address wolves and deer 

at a community level while also trying to satisfy human desires. The heart 

of the plan is the establishment of a system of forest reserves and other 

162 • PERSON AND BRINKMAN 

WOLF POPULATION 

400 

300 

200 

100 

0 

1955 
lands on which logging is deferred; these lands encompass a portion of 

the productive old-growth forest left on national forest lands (see Lertzmann and MacKinnon, this volume, chapter 8, for a discussion of reserves 

and a case study in coastal British Columbia). Unlike other areas in the 

Pacific Northwest, southeast Alaska still has many intact and ecologically 

functioning watersheds distributed throughout the region. Some of those 

watersheds are part of the old-growth forest reserve system established by 

the Tongass Land Management Plan (USDA Forest Service 1997a, 2008a). 

They are critical to ensuring the long-term sustainability of populations of 

fish and wildlife (Bryant and Everest 1998; USDA Forest Service 1997a; 

Albert and Schoen 2007a). Protected and roadless lands at a watershed or 

larger scale can safeguard important salmon streams from headwaters to 

their outlets. They maintain the natural composition and connectivity of 

landscapes, minimize forest fragmentation from roads and other human 

activities, and limit accessibility of wildlife to human exploitation. 

On Prince of Wales Island, about 62% of the habitat capability (surrogate for carrying capacity of winter range) for deer remains after 5o years 

of industrial-scale logging (Albert and Schoen 2007a). About 58% of that 

capability is located on lands currently deferred from logging. A key 

assumption in the TLMP is that deferred lands are sufficient to conserve 

viable populations of all wildlife species currently inhabiting the island 

with little additional contribution from managed lands. That untested 

expectation requires evaluation, using monitoring programs and research 

focusing on its implicit assumptions (see Smith and Zollner 2005; Smith 

and Person 2007; Smith et al. zon). For example, with respect to wolves, no 

single reserve or aggregate patch of deferred lands is sufficiently large to 

encompass an entire wolf pack home range. Therefore, very few wolf packs 

will be immune from logging, road access, hunting, and trapping; managed lands should be considered an integral part of the conservation strategy. Indeed, conservation strategies that focus primarily on systems of 

habitat reserves and roadless patches frequently fail to meet their objectives because they ignore the importance and function of the intervening matrix of unprotected lands (Noon and Blakesly 2006; Franklin and 

Lindenmayer 2009). That is particularly true for the conservation of large 

vagile mammals such as wolves and bears. Moreover, selection of reserve 

lands must be based on thorough ecological evaluation (Murphy and Noon 

1992; Lertzmann and MacKinnon, this volume, chapter 8), rather than 

simply selecting lands that have not yet been developed or that are not 

CHAPTER 6 • 163 
economically valuable. Indeed, a conservation area design proposed for 

Prince of Wales Island included the protection of intact watersheds with 

the highest biological values (including winter deer habitat) and restoration for high-value watersheds that had previously been logged and roaded 

(Schoen and Albert 2007). In the conservation strategy in the TLMP, oldgrowth forest reserves comprise existing congressionally protected lands 

and a selection from some of the largest remaining roadless patches of 

unmanaged forest within the Tongass National Forest (USDA Forest Service 1997a). In extensively logged areas such as Prince of Wales Island, 

timber harvest targeted the most productive forested watersheds first; 

therefore, less productive forest often predominates in the unlogged and 

unroaded watersheds aggregated into forest reserves (Albert and Schoen 

2007a). Any strategy to conserve large-mammal predator-prey communities must be able to accommodate their nonlinear dynamics; therefore, 

they should have large margins for error. In the case of Prince of Wales 

Island, that includes maintaining as much functionality within the matrix 

of managed lands as possible, while also maintaining current reserves and 

adding new high-quality landscapes within reserves. The objective should 

be to maximize the amount of suitable summer and winter range available 

to deer, providing habitat capability well in excess of the minimums established by the TLMP so that resilience of deer to predation, hunting, and 

winter snow conditions is maintained. 

The matrix of managed lands surrounding reserves contains the most 

productive forest lands in southeast Alaska and likely will play a critical 

role, along with reserve lands, in sustaining wildlife and meeting human 

subsistence needs. Timber harvest on managed lands on Prince of Wales 

Island will need to shift away from old growth to seral forest. Indeed, we 

suggest that all old-growth forest left on federal lands on Prince of Wales 

and immediately adjacent islands be protected permanently to assure 

future conservation options and provide a hedge against the transfers of 

many parcels of productive forested lands to private ownership under 

provisions in the Alaska Native Claims Settlement Act of 1971. Conveyed 

lands almost certainly will be logged with little consideration for ecological values and wildlife. If harvest of old growth on federal lands is 

inevitable, then logging should be done in ways that approximate natural 

disturbances spatially and temporally (see Alaback et al., this volume, 

chapter 4 and Beese, this volume, chapter 9). Because highly productive 

164 • PERSON AND BRINKMAN 
old-growth forest is underrepresented within reserves, it is important that 

the structure and heterogeneous character of old-growth forest be restored 

in as many logged watersheds as possible. For example, within stem exclusion seral forest, habitat for deer may be enhanced by thinning and small 

patch cuts that create gaps in the forest canopy sufficient to reestablish 

understory plants preferred as forage (Hanley et al. 2005; Alaback et al., 

this volume, chapter 4). Silvicultural treatments to enhance deer habitat 

(as well as other species) need to be widespread; however, concentrating 

much of the effort in areas accessible to subsistence hunters by road may 

help sustain hunters' needs while reducing their motivation to kill wolves 

and bears illegally. It would also be helpful if timber harvest of seral forest 

targeted hunter-accessible areas whenever possible. 

Most logging roads built in southeast Alaska, and particularly those 

within the Tongass National Forest, were conceived as long-term capital 

improvements. Their status as permanent additions to the landscape mandates a commitment by land managers to maintain them and monitor 

their ecological effects over many years. Weather, climate, topography, and 

remoteness of the region make maintaining and monitoring roads very 

expensive and difficult. In addition, managing road access on national forest lands is a difficult process because local residents usually demand use 

of forest roads, which were paid for by public funds, often making road 

closures for conservation purposes contentious. Budgets used to maintain, 

monitor, and close roads, particularly on national forest lands, usually are 

linked to timber harvesting activities. Timber harvesting, which may 

entail the construction of new roads, is necessary to pay for the maintenance, monitoring, and decommissioning of old ones. Fluctuations in the 

amount of timber put up for sale have a direct influence on funds available 

for roads. Consequently, funding for long-term maintenance and monitoring may not be stable or adequate for the task. That problem is particularly 

acute on Prince of Wales Island because it has the highest density of logging roads in southeast Alaska. 

New roads construction should be avoided or kept to a minimum by 

careful planning to reduce fragmentation of remaining productive forest 

stands and wetlands. Where roads are necessary, construction should 

employ best management practices with respect to methods of construction and placement of drainage and stream-crossing structures. Existing 

roads that penetrate old-growth reserves should be decommissioned by 

CHAPTER 6 • 165 
removing culverts, pipes, and bridges to restore the natural flow of water 

and limit human access. Culverts and bridges that are inadequate for fish 

passage should be replaced. Long-term monitoring of the condition of 

roads within a diverse array of landscapes and research examining the 

hydrological and ecological effects of roads should be supported. This is 

particularly critical given the unknown impacts of climate change on the 

hydrology of this rainforest ecoregion. Alternative sources of funding 

independent of timber harvesting likely will be needed to sustain those 

long-term monitoring and research programs. 

Rates of harvest and population trends of wolves, bears, deer, and furbearers should be closely monitored to prevent unsustainable harvesting 

and enable informed decisions concerning seasons and bag limits. Harvest 

reporting is mandatory for wolves, bears, and deer; however law enforcement efforts to insure compliance need to be stepped up. We urge fish and 

wildlife managers to take an ecological perspective when setting harvest 

objectives, to avoid overemphasizing human desires and neglecting the 

requirements of other species and their interactions within the system. 

Long-term programs for adequately monitoring deer, wolf, and bear populations (and other forest-dependent species) need to be implemented. They 

should take advantage of new developments in estimating populations 

using noninvasive techniques (Peacock 2004; Brinkman et al. 2011) whenever possible and cost effective. Finally, the responsible management agencies need to agree on a common set of goals to conserve the predator-prey 

community, and results from monitoring and research should be used to 

set population, harvest, and ecological thresholds that trigger appropriate 

management actions in a timely fashion. 

We focused on a subset of wildlife species inhabiting North Pacific 

rainforests and ignored other forest-dependent species. For example, 

brown bears (U. arctos), northern flying squirrels (Glaucomys sabrinus), 

marten (Martes caurina), goshawks (Accipitergentilis), and spruce grouse 

(Falcipennis canadensis) also are affected by timber harvesting and roads 

in southeast Alaska and coastal British Columbia (Schoen 199o; Iverson 

et al. 1996; Small et al. 2oó3; Smith et al. 2005). Nonetheless, our case study 

illustrates the overarching importance, regardless of species involved or 

geographic location, of addressing conservation at the level of ecological 

communities rather than individual species. We demonstrate that forest 

management practices or developments in North Pacific temperate rainforests that deviate from natural patterns of disturbance likely will have 

166 • PERSON AND BRINKMAN 
long-term and possibly intractable consequences for wildlife, humans, and 

ecosystems. We also emphasize the need to consider social factors, hunting and trapping in our case, when designing and implementing plans to 

conserve biodiversity. Indeed, ignorance or denial of those factors could 

easily derail an otherwise scientifically sound conservation strategy. 

ACKNOWLEDGMENTS 

The authors thank the senior leadership of the Alaska Department of 

Fish and Game, particularly Dale Rabe, Doug Larsen, and Rod Flynn 

for their support of the conference that spawned this chapter. We also 

thank the sponsors and organizers of that conference. Finally, we appreciate the thorough comments provided' by anonymous reviewers of our 

manuscript. 

CHAPTER 6 • 167 
From: B Knight

To: Piazza, Tim -FS

Subject: Scoping Comments - WIP

Date: Monday, September 16, 2013 7:19:44 PM

Attachments: Exh-A Dave Person Admin Appeal Statement (FINAL).pdf

Exh-B Rhodes Declaration.pdf

Exh-C - Mehrkens Declaration 8-5-13.pdf

Knight_Scopingcmts._ WIP.pdf

Hello Mr. Piazza,

Attached are my scoping comments for the Wrangell Island Project along with three exhibits.

Can you please reply that you received all four documents and are accepted?

Thanks,

Rebecca Knight

Petersburg
STATEMENT OF DAVID K. PERSON 

REGARDING THE BIG THORNE PROJECT, 

PRINCE OF WALES ISLAND 
Page 1 	 	

I, DAVID K. PERSON, state as follows: 

1. I am a wildlife scientist with 22 years of experience studying Alexander 

Archipelago wolves (Canis lupus ligoni) and Sitka black-tailed deer (Odocoileus hemionus 

sitkensis) in Southeast Alaska. My references to “wolves” and “deer” throughout this statement 

relate to these species. I began wolf research on Prince of Wales Island as a Ph.D. student at the 

University of Alaska Fairbanks in 1991. 

2. Prior to beginning wolf research in Alaska, I worked as a statistician for the 

Vermont Department of Health, studied coyotes for my Masters degree at the University of 

Vermont, and worked as a deer management biologist for the New Jersey Department of Fish, 

Game, and Wildlife. 

3. I received my doctorate degree in wildlife biology in 2001. By then, I was 

employed by the Alaska Department of Fish and Game (ADFG) to research wolf-deer predatorprey dynamics in Southeast Alaska. I worked for ADFG from 1998 to 2013, leaving the agency 

in May 2013. All told, I have more than 30 years of experience as a professional wildlife 

biologist. 

4. During my time in Alaska, I authored or co-authored more than 20 peer-reviewed 

papers on deer and wolves that were published in scientific journals, three book chapters, and 

many agency reports and publications. In addition, I am well trained in forestry, forest ecology, 

and silviculture, and am very knowledgeable about the forest ecology of Pacific Northwest 

temperate rainforests, including those of the Tongass National Forest. 

5. During 1996-1997, I worked closely with the U.S. Forest Service (Forest 

Service), ADFG, and U.S. Fish and Wildlife Service (USFWS) scientists tasked with developing 

the wildlife conservation strategy that was ultimately adopted by the 1997 Tongass Land 
Page 2 	 	

Management Plan (TLMP). Indeed, I was the senior author on the wolf conservation assessment 

(Person et al. 1996) the purpose of which was to guide the forest plan revision with respect to the 

conservation of wolves. I also assessed the population viability of the wolves on Prince of Wales 

Island as part of the analyses USFWS staff conducted when they were considering a petition to 

list wolves in Southeast Alaska as threatened under the Endangered Species Act. That 

assessment constituted a major focus of my Ph.D. dissertation. 

6. In 1996-1997, I was the principal resource expert for wolves and a resource expert 

for deer, advising expert panels of scientists convened by the Forest Service during development 

of the wildlife conservation strategy for the 1997 TLMP. 

7. Following adoption of the 1997 TLMP, I, with three other authors, two of whom 

were coauthors of the wolf conservation assessment (Person et al. 1996), wrote the Forest 

Service to point out several serious errors in the Forest Service’s interpretation the conservation 

assessment (Letter to Beth Pendleton 1997). In particular, we objected to how the Forest Service 

developed the wolf standard and guideline in the forest plan. The agency assumed that deer 

habitat capability was equivalent to actual deer density. Habitat capability represents the 

carrying capacity of winter range during an average snow year, not the actual density of deer. 

Essentially, it represents the potential of the habitat to support deer. In our letter, we 

demonstrated that deer density can never be at the level of habitat capability when additive 

predation from wolves, bears, and hunters acts on the population. In that case, actual density will 

always be well below habitat capability. We stated that a minimum density of 13 deer/ mi2 is 

important to reduce the risk of unstable predator-prey dynamics and provide for predators and 

subsistence hunters. The Forest Service uses deer habitat capability because they have no costeffective way to monitor actual deer density. Using deer habitat capability is a very poor 
Page 3 	 	

substitute for actual deer density. Subsequently, the Forest Service corrected TLMP’s deer 

habitat capability standard for wolves, increasing it from 13 to 17 deer/ mi2

 in 1998 (Powell 

1998) and to 18 deer/ mi2 in 2005 (Puchlerz 2002). 

8. In 2006, I was the principal expert for wolves at the Forest Service’s Tongass 

Conservation Strategy Workshop. I presented analyses based on my research that indicated 

several deficiencies in the TLMP conservation strategy with respect to wolves. Most notably, 

the large old-growth forest reserves (OGRs) are too small to encompass a single wolf pack home 

range. My analyses indicated that when about 40% of a pack’s total home range is logged and 

roaded, there is a very high risk that mortality (mostly from hunting and trapping) will exceed 

reproduction and the pack area becomes a population sink. Indeed, even when as little as 25% of 

a pack’s home range is logged, the ratio of reproduction to mortality is very close to one. Sinks 

are only maintained by immigration of wolves from other areas, which, as explained below, is 

not likely to happen on Prince of Wales Island given the population’s isolation and small 

numbers. 

9. For the past 22 years, I studied wolves in Game Management Unit (GMU) 2 

which includes the Big Thorne project area. Prince of Wales Island and the surrounding islands 

and GMU2 are essentially the same area with regard to wolves. I studied the predator-prey 

relationship in the area and tracked wolf populations to the extent that the work was funded. I 

participated in the Big Thorne environmental review process, including the review of the 

project’s Draft Environmental Impact Statement (DEIS), in my capacity as a biologist for 

ADFG. I participated in numerous meetings and discussions regarding Big Thorne. Among 

other meetings, I participated in an April 9, 2013 meeting with Forest Service officials, including 

Tongass Supervisor Forrest Cole, and representatives from USFWS. The objective of that 
Page 4 	 	

meeting was to discuss road closures and other mitigation measures that would reduce the effect 

of the Big Thorne timber sale on wolves. At the meeting, I showed the group maps of recent 

GPS locations of radio-collared wolves within the Big Thorne project area. Those locations 

clearly demonstrated that closing a few spur roads here and there would have a negligible effect 

on mortality because there were simply too many existing roads in the project area. Moreover, 

the data showed how vulnerable packs are to access via roads, even for the pack occupying the 

Honker Divide OGR because that OGR is simply too small to encompass their home range. The 

only road mitigation that would work would be to close down many of the major arterial roads, 

which is unlikely to happen. I urged the group to focus more on preserving deer habitat, meeting 

TLMP’s provided guidelines, and recommending ways to treat second-growth forest to improve 

the quality of deer range. The Forest Service did not indicate any serious effort to go forward 

with any specific recommendations. 

10. Additionally, I communicated directly with Forest Service personnel, including 

Brian Logan, a Forest Wildlife Biologist, through email and phone conversations. I explained 

during these informal discussions that the Big Thorne and Log Jam timber projects will have a 

serious impact on wolves and deer, and consequently wolf viability. They will remove the last 

high quality winter range for deer in the central portion of Prince of Wales Island and the 

cumulative effects of the Big Thorne and Log Jam timber projects along with previous logging 

over 60 years, has and will erode the resilience of deer to severe winter, predation, and hunting. 

In addition, land transfers to Sealaska Corporation and Alaska Mental Health Trust Authority, 

will reduce more deer habitat on other parts of the island such that the level of habitat loss within 

Big Thorne and Log Jam has been and will be duplicated in most of the Prince of Wales 
Page 5 	 	

Archipelago. Sealaska Corporation and Alaska Mental Health Trust lands are logged under state 

of Alaska regulations, which have no meaningful protections for wildlife whatsoever. 

11. The combined effects of Big Thorne and the other logging on wolves within the 

Prince of Wales Archipelago likely will be the collapse of a sustainable and resilient predatorprey ecological community. That community includes deer, wolves, black bears, and people. 

Because of pressures to sustain subsistence deer hunting as habitat is lost, there will be immense 

public and political pressure to kill wolves and bears. 

12. Because of my many years of research and related professional assignments, I am 

the most experienced and knowledgeable scientist in the United States with respect to wolves 

and the wolf-deer predator-prey ecological communities in Southeast Alaska. Over the past 

decade, I was one of the principal deer researchers on the Tongass. In addition, I am recognized 

by federal and state agencies as an expert on the effects of forest management on deer, wolves, 

and predator-prey dynamics. I am particularly qualified to address the effects of the Big Thorne 

timber sale on wolves and deer because so much of my research on those species during the last 

22 years was conducted within the project area. 

13. I wrote this statement because I have concluded that the Big Thorne timber sale, if 

implemented, represents the final straw that will break the back of a sustainable wolf-deer 

predator-prey ecological community on Prince of Wales Island, and consequently, the viability 

of the wolf population on the island may be jeopardized. I received no compensation for this 

statement. Copies of the studies and documents I cite in this statement are provided as exhibits 

at the end of the statement. My opinion is summarized as follows: 

a. Wolf populations in the Big Thorne project area have declined rapidly in recent 

years as a result of old-growth logging, which degrades deer winter habitat, road 
Page 6 	 	

building, which provides access for hunters and trappers, and high levels of wolf 

mortality (because roads increase human access) from legal and illegal hunting 

utilizing both open and closed roads; 

b. The Big Thorne project will harvest much of the best remaining mid and low 

elevation deer winter habitat in this part of Prince of Wales Island, which will 

most likely, over time, result in further declines in deer and wolf populations. On 

Prince of Wales Island, more than 50% of the island is already at or approaching 

levels of logging that will strongly increase the risk that the island will only be 

capable of supporting wolf packs that function as population sinks. To prevent 

this outcome the remaining mid and low elevation deer habitat on Prince of Wales 

Island needs to be protected and the number and size of OGRs need to be 

increased to increase the likelihood that more wolf packs are protected from 

unsustainable mortality from hunting and trapping. As explained below, the Big 

Thorne project puts the viability of the wolf population on the Prince of Wales 

and the surrounding islands (the Prince of Wales Archipelago) in doubt. 

c. Because so much winter range for deer has been logged, deer are not resilient to 

effects of both predation and severe winters. As a result, a bad winter could cause 

a significant decline in deer and the population remains low owing to predation 

and hunting (Person and Brinkman 2013). The Big Thorne project area is heavily 

used by subsistence hunters because it is close to all of the major towns on Prince 

of Wales Island. The project will cause immeasurable and permanent harm to 

those hunters and create an intractable management dilemma of trying to sustain 

deer in the face of dwindling habitat quality, predation, and human demands. 
Page 7 	 	

d. The wildlife conservation strategy in the 2008 TLMP is inadequate to deal with 

these issues both at the project level and at the biogeographic province. The 

cumulative effects of 60 years of clear-cut logging plus the Big Thorne project 

could result in the ecological collapse of the predator-prey system and result in 

wolf numbers well below minimum viability both demographically and 

genetically, which would eventually result in their extirpation or extinction within 

the Prince of Wales Archipelago. The Prince of Wales Archipelago makes up a 

large percentage of wolves in Southeast Alaska, perhaps as much as 30% (Person 

et al. 1996). They are a genetically and morphologically distinct group within the 

Tongass (Weckworth et al. 2005). As a result of these considerations, wolves on 

the Prince of Wales Island and the Prince of Wales Archipelago are an important 

part of the overall wolf population in the Tongass. 

e. 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 predator-prey 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. 
Page 8 	 	

Status of Wolves on Prince of Wales 

14. Genetic and telemetry data indicate that the wolf population on the Prince of 

Wales Archipelago is an isolated population from other wolves throughout the Tongass (Person 

2001; Weckworth et al. 2005; Person and Russell 2008), which complicates management of the 

population because it is not buffered by immigration and has limited genetic diversity. The wolf 

population on Prince of Wales Island is composed of resident pack members and nonresident 

wolves that are dispersing or are floating between several packs (Person 2001; Person and 

Russell 2008). Wolves primarily prey on deer, annually consuming an estimated 18 to 32 deer 

per wolf (Person et al. 1996). 

15. The population of wolves on Prince of Wales Island has declined substantially 

since the middle of the 1990s, especially within the north-central portion of Prince of Wales 

Island. I estimated the wolf population on the Prince of Wales Archipelago during autumn 1995 

to be approximately 300-350 animals (Person et al. 1996; Person and Russell 2008). That 

estimate was an extrapolation from my study areas on the Prince of Wales Archipelago and was 

based on aerial counts of wolves in packs containing radio-collared animals plus an estimate of 

the number of potential nonresident wolves in the population derived from rates of dispersal of 

radio-collared wolves. During 2000-2004, I estimated 250-300 wolves, again based on aerial 

counts within my study area on the Prince of Wales Archipelago. No formal wolf population 

estimations have been conducted since 2004. The Final Environmental Impact Statement (FEIS) 

for Big Thorne says that during a 2010 Alaska Board of Game meeting in Ketchikan, “ADF&G 

reported that anecdotal observations by state and Federal biologists, trappers, and hunting 

outfitters/guides suggested the wolf population had declined to as few as 150 wolves in GMU 2,” 
Page 9 	 	

which would mean that wolf numbers were down by roughly 50% compared with the previous 

decade. 

16. Since 2009 the Forest Service and ADFG have cooperated to fund a study to 

develop a method to estimate abundance of wolves in Southeast Alaska. The project, funded 

primarily by the Forest Service, collected wolf scats (feces) for Deoxyribonucleic acid (DNA) 

genotyping from which I hope to derive a population estimate (Person 2009-2012). I was the 

lead researcher on the study and we have provided regular progress reports to Forest Service and 

ADFG. Our study area was essentially coterminous with the Big Thorne project area. As part of 

this effort during 2009 and 2010, I searched roads and trails for fresh scats and located only 36 

feces. During 1993-1994, a graduate student from the University of Alaska Fairbanks and I 

collected more than 150 scats from the exact same area with much less effort (Kohiraand 

Rexstad 1997). In 2010, eleven known, previously used dens of five wolf packs were checked, 

and no denning activity was found. Also there was no indication of use on wolf trails that 

previously had been used regularly, and some were starting to grow over. We drove road 

transects within the study area (north-central Prince of Wales from Whale Pass south to 12-mile 

Arm, and from Thorne Bay west to Winter Harbor) and found very few signs of wolves. 

17. I estimate that in the mid-1990s, at the time the TLMP conservation strategy and 

viability assessment were being developed, the Big Thorne project area had the habitat to support 

45-50 wolves, making up approximately 3 separate packs and a portion of a forth pack. 

18. In the Fall of 2012, we determined through DNA hair trapping and radio-collaring 

work that there were approximately 29 wolves in the Big Thorne project area and only two 

remaining packs in the area. Changes in pack structure are a reflection of turmoil and 

disturbance (Ballard et al. 1997). One of the packs is large; the other is so small it that it appears 
Page 10 	 	

to be struggling to raise a successful litter of pups. The large group had two breeding females 

and covered an area that used to encompass the Honker Divide and Ratz Harbor wolf packs. 

Both females were killed last year; one was trapped legally and the other trapped illegally. 

19. In 2013, we continued our study based on work conducted between January and 

May and provided the Forest Service our progress report (Person and Larson 2013). In the 

Spring of 2013, based on our field work we could only account for six to seven wolves left in the 

Big Thorne project area. During the 2012 hunting season, trappers killed at least fifteen wolves 

in the Big Thorne project area, but that only accounts for legal, reported take. A few of these 

wolves could have been dispersing wolves (i.e., wolves travelling through the area and not a part 

of the resident packs), but the vast majority are likely to have been resident wolves. Some 

wolves we counted in autumn 2012 also could have dispersed out of the area. 

Logging, Deer, Wolves, and Hunters 

20. Sitka black-tailed deer and the Alexander Archipelago wolf are endemic to 

coastal temperate rainforests in Southeast Alaska and northern, coastal British Columbia. This 

deer species serves as the primary food source for the wolf and is also an important subsistence 

resource for residents of rural southeast Alaska. Deer, wolf, and humans in this region therefore 

exist in predator-prey relationship that depends in large part on the habitat provided by the 

Tongass National Forest. 

21. Deer rely on old-growth forest habitats in the Tongass for their survival because 

these forests provide important winter habitat (Wallmo and Schoen 1980). Less snow 

accumulates in these old-growth forests, and deer can still find forage during the winter months. 

Low elevation, high volume old-growth forests provide the best winter habitat for deer (Schoen 

and Kirchhoff 1990). The logging of old-growth forest can therefore result in declines of deer 
Page 11 	 	

populations, because with fewer acres of high quality winter habitat, fewer deer can survive the 

winter. Deer is also the most important terrestrial subsistence species in rural, Southeast Alaska. 

22. In 2011, Brinkman et al. published a study in which they estimated a mean deer 

density decline in three watersheds in north-central Prince of Wales Island of 32% over a threeyear period, from 13.1 deer/km2

 in 2006 to 8.9 deer/km2 in 2008, which the authors attributed to 

severe winters (Brinkman et al. 2011). Deer populations in unlogged areas (12 deer/km2

) were 

substantially higher than in recently logged areas (10 deer/km2

) and areas that were logged more 

than 30 year ago (7 deer/km2). This study was conducted in the same area that would be affected 

by the Big Thorne project. 

23. Wolf populations are closely tied to populations of deer. Wolves depend on deer 

for up to 90% of their diet during the winter months. (Person et al. 1996). In 1996, we estimated 

the number of deer per wolf required to maintain equilibrium between deer and wolves. Our 

work demonstrated that a ratio of deer to wolf of 170-180 deer to one wolf is needed for a 95% 

probability of equilibrium between the populations. (Person et al. 1996). If deer populations 

decline substantially, wolf populations are very likely to decline eventually because of a reduced 

prey base. Wolves and subsistence hunters both compete for available deer. As deer numbers 

inevitably decline on Prince of Wales Island as a consequence of on-going logging and the stillpending succession debt of past logging (Person and Brinkman 2013), subsistence and 

recreational hunters increasingly will perceive competition from wolves for deer. Legal and 

illegal take of wolves can be predicted to increase as a result, particularly in areas accessible by 

roads or boats (Person et al. 1996; Person 2001). My experience indicates that regulations 

designed to sustainably manage wolf populations will then be ineffective, because of unreported 

and illegal take of wolves (Person and Russell 2008). 
Page 12 	 	

24. The construction of roads associated with logging projects also increases the risk 

of wolf mortality by legal and illegal harvesting. Roads offer convenient pathways for wolves 

through logged watersheds, but they also provide access to humans, increasing risk of death of 

wolves from hunting and trapping. 

25. The current decline in wolves on Prince of Wales Island, including the Big 

Thorne project area, is caused primarily unsustainable hunting and trapping, which are facilitated 

by access provided by road development. From 1990 through 1999, wolf harvest reached 

unsustainable levels. Wolves can sustain about 35-38% total annual mortality (Person and 

Russell 2008). Natural mortality is about 5% (Person 2001; Person and Russell 2008), therefore, 

harvest mortality cannot exceed 30-33% without compromising sustainability. Risk of 

unsustainable harvest is particularly high within roaded watersheds (Person and Russell 2008; 

Person and Logan 2013). In 1996, the Alaska Board of Game passed a guideline harvest level 

for wolves in GMU 2. They did so because the USFWS was actively reviewing a petition to list 

wolves as threatened under the Endangered Species Act. The guideline was to be implemented 

in 1997. Knowing that, trappers and hunters on the Prince of Wales Archipelago intentionally 

made a strong effort in 1996 to kill as many wolves as possible. During that year they killed a 

record 136 wolves, roughly 45-50% of the population at the time. In 1999, the harvest reached 

the guideline level resulting in early closure of the trapping season (Person and Russell 2008). 

Subsequently, reported harvest declined dramatically after 1999. Person and Russell participated 

in a study that demonstrated a strong positive linear relation (r = 0.89) between road density less 

than or equal to 0.9 km/km2

 (1.5 miles/mile2) and wolf harvest rates (Person and Russell 2008). 

We determined that densities greater than 0.9 km/km2

 likely resulted in unsustainable losses of 

wolves. 
Page 13 	 	

26. We also reported that 87% of mortality of wolves on Prince of Wales Island was 

from hunting and trapping (Person and Russell 2008). We concluded that annually, about 50 to 

95 wolves are legally taken (including required reporting of the kill), but that illegal take may at 

times equal the legal harvest on Prince of Wales (Person and Russell 2008). 

27. Person and Logan (2012) concluded that after road closures in GMU 2 prescribed 

in the Forest Service’s Access and Travel Management plan approximately 71% of roaded 

landscapes will still be accessible to hunters and trappers. That includes the Big Thorne project 

area. This research was premised on the conservative assumption that hunters or trappers will 

walk one kilometer from a road to hunt or place traps. However, a study by Todd Brinkman for 

which he surveyed Prince of Wales hunters and trappers, reported that the median hunter is 

willing to travel on foot a distance of two kilometers away from the road to hunt deer, and some 

reported a willingness to walk as much as four kilometers (Brinkman 2006). That is, 50% of 

hunters are willing to walk-in at least two kilometers. As a result, Person and Logan 2012 

significantly underestimates the amount of the project area that is already accessible to hunting 

and trapping activities. More plausibly, the percent of the project area readily accessible to 

hunters and trappers actually exceeds 80%. 

28. Wolf harvest in the Prince of Wales Archipelago declined dramatically after 2000 

(Person and Russell 2008; Person and Logan 2012; Person and Brinkman 2013) and ADFG, 

Alaska Board of Game, and Federal Subsistence Board took no action to respond to the decline. 

Indeed, the Federal Subsistence Board responded by lengthening the hunting season for wolves. 

By 2010, there was evidence that the wolf population had greatly declined at least within the 

north-central portion of Prince of Wales Island (Person 2009-2012), which includes the Big 
Page 14 	 	

Thorne project area, and the Alaska Board of Game lowered the harvest guideline quota but to a 

level still above the reported annual harvest. 

29. I have modeled the viability of an insular wolf population and wolf-deer predatorprey dynamics on the Prince of Wales Archipelago (Person 1997; Person 2001; Person and 

Brinkman 2013). I concluded that under the TLMP wildlife conservation strategy the deer 

population would decline substantially and predator-prey dynamics would become much less 

stable. I also concluded that persistently low deer numbers or even the perception of low 

numbers would increase the risk of unsustainable take of wolves by hunters and trappers 

attempting to boost deer populations, an activity facilitated by easy access to shorelines by boat 

and to island interiors by vehicles using roads. If this occurs on widespread areas on the Prince 

of Wales Archipelago, the viability of wolves would be at risk. 

30. During the Tongass Conservation Strategy Review Workshop in 2006 (part of the 

process leading to the 2008 TLMP amendment), I presented an analysis based on empirical 

survival and reproductive data from telemetered wolves. This analysis indicated that when more 

than approximately 40% of a wolf pack home range on Prince of Wales Island is comprised of 

logging and roads that allow access for hunting and trapping, the area likely becomes a 

population sink in which mortality exceeds reproduction. The analysis showed that the ratio of 

reproduction to mortality for wolf packs was perilously close to one to one when as little as 25% 

of the home ranges were logged and/or provide road access. 

Consequences of the Big Thorne Timber Sale 

31. Based on the impacts to wolf and deer habitat and populations described above, 

Prince of Wales Island, including the Big Thorne project area, is at a tipping point with regard to 

a viable predator-prey dynamic between wolves and deer. The wolf populations on Prince Wales 
Page 15 	 	

have been declining precipitously, and wolves are already facing the possibility of extinction on 

Prince of Wales Island. Big Thorne logging, if it goes forward, will remove the most important 

remaining deer winter habitat in many of the affected watersheds, which will further reduce the 

abundance of deer in the project area (especially following severe winters), perhaps for decades 

to come. As a result, the predator-prey relationship between wolves and deer on Prince of Wales 

is likely to collapse. 

32. In 2011, I raised these issues inside ADF&G. In particular, I set forth my opinion 

that the Big Thorne timber sale will likely threaten the ability of the watersheds involved to 

sustain wolves and deer over the long term. I provided maps demonstrating that the Big Thorne 

sale would result in the logging of the most important remaining winter habitat for deer in the 

Thorne watershed and in Steelhead Creek, among others. Several of the emails I sent to ADF&G 

staff are included in the Big Thorne record. The maps, however, do not appear to be included in 

the record, so I am including them as exhibits to this statement (Person ADF&G emails and 

maps). The third map shows the consequence of logging the whole unit pool rather than just the 

units included in the final Big Thorne decision, but although it therefore somewhat overstates the 

impact, it gives some indication of what is at stake. The Forest Service has not provided maps 

like these in the Big Thorne FEIS to show the sequence of loss of deer winter range over time, 

culminating with this project’s actual effects and alternatives. 

33. As I described above, it is not enough to maintain a sufficient deer population for 

wolves because hunters rely on those deer as well, and they can be expected to kill wolves 

legally or illegally to protect that resource. The situation is further compounded by the extensive 

road network already in existence, as well as the new roads into previously remote areas 

approved under the Big Thorne decision. This road system greatly facilitates human access and 
Page 16 	 	

eliminates refuge for wolves. The final complication is that the wolf population is genetically 

distinct and isolated from other wolves in the Tongass and, as a result, if wolves on Prince of 

Wales Island are extirpated or reduced to a small population, rescue or recolonization by 

dispersing wolves from the mainland is unlikely. 

Comments Concerning TLMP as the Guiding Document for the Conservation of Wolves 

and Deer 

34. TLMP, as amended in 2008, is the umbrella document guiding the conservation 

provisions incorporated in the Big Thorne timber sale. Because it is flawed, conservation 

measures derived from it and used in the Big Thorne project are also flawed. Prior to signing the 

predecessor 1997 Record of Decision for TLMP, the Forest Service convened several speciesspecific science panels to review the wildlife conservation strategy and seek professional opinion 

relative to its adequacy. The process involved creating a panel for each species of concern that 

consisted of a local resource advisor and three to four species experts from outside Southeast 

Alaska. I served as the local resource advisor for the wolf panel. I believe, based on that 

experience, my continuing research, and other published science since then, that there are major 

deficiencies in TLMP’s conservation strategy and its implementation with respect to wolves and 

deer, particularly on Prince of Wales and neighboring archipelago of islands (Prince of Wales 

Archipelago). Some of these major deficiencies, many of which I pointed out at the 2006 

Tongass Conservation Strategy Workshop, are: 

a. Wolves in Southeast Alaska are genetically related to those in north coastal 

British Columbia, Canada. 

b. Wolves in the Prince of Wales Archipelago are isolated from all other wolves in 

Southeast Alaska and coastal British Columbia. 
Page 17 	 	

c. The deer density guideline specific to wolves should be applied at the scale of a 

wolf pack home range (300 km2

). 

d. Roads strongly influence wolf mortality by facilitating legal and illegal harvest. 

e. Road density guideline of 0.7 mi/ mi2 needed to be changed such that it includes 

all roads rather than just “open” roads. 

f. Road density guideline should be applied at the scale of a single wolf pack (300 

km/km2). 

g. Lower wolf and deer populations are likely in the future under the current forest 

plan. 

h. OGRs are the only lands that may serve as population sources for wolves, but 

they are too small. 

i. High quality habitat for deer must be maintained within and outside the OGRs. 

j. Social and economic factors will complicate wolf conservation because declining 

deer numbers due to loss of habitat from logging will motivate subsistence 

harvesters to demand predator control for wolves. 

k. Illegal killing of wolves will make it difficult to regulate harvests, and roads will 

exacerbate that problem because they provide easy access to wolves. 

l. OGRs are not sufficiently large to encompass wolf pack home ranges (Person and 

Brinkman 2013). The average home range of wolf packs on the Prince of Wales 

Archipelago is 300 km2

 (115 mi2, [Person and Logan 2012]) or 73,800 acres. The 

largest contiguous OGR in the Prince of Wales Archipelago is 45,000 acres. 

Consequently, no OGRs completely protect any wolf pack within the Prince of 

Wales Archipelago. The Big Thorne DEIS refers to a >200,000 acre Honker-
Page 18 	 	

Sarkar lakes complex, implying a very large single reserve. This is no longer 

accurate because an identified connecting link between the Honker and Sarkar 

Lakes OGRs has been extensively clear-cut logged, most recently under the 

Logjam timber sale, and it is bisected by a major paved highway. Wolves 

frequently are killed by hunters and trappers within that connecting link. 

Individually, neither the Honker nor Sarkar OGRs encompass full wolf home 

ranges. 

m. The term “old-growth” reserve is misleading since reserves may contain as little 

as 50% productive old growth (POG). The liberal criteria used to define POG 

assure that much of it is of little value to deer during a snowy winter. Moreover, 

because of the extensive fragmentation and logging of most of the highest volume 

old-growth forest on the Prince of Wales Archipelago and in some cases the 

gerrymandering of OGR boundaries or locations that has occurred in individual 

logging projects, lands aggregated into OGRs do not necessarily contain the best 

or even adequate winter habitat for deer and hence wolves. They may be some of 

the better lands left after the past 60 years of industrial logging but still be 

inadequate. Indeed, only 36% of the historic (before industrial logging) habitat 

capability for deer (winter carrying capacity during an average snow year) is 

protected within OGRs and other lands deferred from logging (Albert and Schoen 

2007). In addition, a recent analysis of the amount of landscape-scale highvolume old growth on northern Prince of Wales Island has documented that this 

unique forest community (which is important as deer winter range in deep snow 

winters) was reduced by 93.8% from 1954 to 2004 (Albert and Schoen 2013). 
Page 19 	 	

n. Additional flaws in the TLMP wildlife conservation strategy stem from 

limitations in the Forest Service’s deer habitat capability model, which represents 

carrying capacity for deer during an average snow winter. Yet, a single severe 

winter or succession of such winters may determine deer population dynamics for 

many decades after the event, particularly if deer numbers drop very low and 

predation is high. The slow recovery of deer on Mitkof, Kupreanof, and Kuiu 

islands due to extreme winter events in the 1970s and the middle of the last 

decade illustrates this point. Decades after the severe winter snows, deer 

populations are still at levels far below carrying capacity. (Kirchhoff 1994; 

Lowell 2013 (presentation at the January 2013 Board of Game meeting)). To 

calculate the habitat needed for all predictable conditions, the deer model should 

assume deep snow winters instead of average winters. 

o. The TLMP guideline of deer habitat capability ≥18 deer/mi2

 is based on a 

calculation for the Prince of Wales Archipelago that assumed an average annual 

wolf population of 250 animals (Person et al 1996; Person et al. 1997). From a 

biological perspective, the deer guideline is a minimum value relative to 

maintaining resilience of the predator-prey system and, in the case of the Prince of 

Wales Archipelago, the potential to sustain a viable wolf population. If a timber 

sale project results in deer habitat capability below 18 deer/mi2, the likelihood is 

that predator-prey dynamics will become more erratic and the resilience of deer to 

predation, hunting, and winter weather is reduced. In addition, conflict between 

hunters and wolves for deer may increase, resulting in demands by deer hunters 

for predator control and also a heightened illegal take. Indeed, an incremental 
Page 20 	 	

reduction in deer habitat capability likely will result in a much larger effect on the 

predator-prey system owing to the nonlinear dynamics that characterize predatorprey-habitat interactions (Person et al. 2001; Person 2001; Bowyer et al. 2005; 

Person and Brinkman 2013). 

p. Additionally, during the 2006 conservation strategy review, I specifically advised 

the Forest Service that the deer guideline should be applied at the scale of a wolf 

pack home range (300 km2) and not at larger scales such as a biogeographic 

province. This means running the deer model at a scale of one or two wildlife 

analysis areas (WAAs) to best approximate an area the size of a wolf pack’s home 

range. 

35. The Forest Service also failed to account for the degree to which the Prince of 

Wales Archipelago WAAs are highly connected for deer hunter access by the extensive network 

of roads and marine waterways. Hunting effort by individuals from throughout the Prince of 

Wales Archipelago is easily transferable from one area to others as one becomes more depleted 

than others, likely causing a deer deficit in one area to have a far ranging indirect effect, 

weakening the predator-prey system the Prince of Wales Archipelago-wide. Forest Service 

projections that deer and wolf populations will not unduly suffer from major logging projects 

like Big Thorne are further undermined by the lack of accurate information regarding the actual 

state of the road system on Prince of Wales Island, including the Big Thorne project area. 

Roads, for example, can be closed on paper only, without the Forest Service (or other property 

owners) taking any action on the ground to prevent access. In other instances, the physical 

barriers are easily avoided and vehicles, including off-highway vehicles, can continue using the 

road despite the fact it has been listed as “closed”. The lack of information regarding the road 
Page 21 	 	

system (i.e., what roads are open, what is the length of the road and its spurs, what is closed, how 

was it closed, is the closure being maintained, etc.), makes it impossible to fully assess the 

adverse consequences of hunting and trapping access throughout Prince of Wales Island, 

including the Big Thorne project area. 

36. To summarize the effect of TLMP on conservation of wolves, several factors have 

materialized since its adoption in 1997 that were not addressed in the 2008 amendment to the 

plan. These factors invalidate several of the assumptions and inputs relied upon by experts on 

the mid-90s TLMP wolf science panel (and consequently by Forest Service decision makers). 

Nonetheless, the Forest Service continues to rely on outdated outcomes of the wolf panel to 

justify ecologically destructive projects such as Big Thorne and Logjam. These factors were 

discussed above, but briefly they are: (1) the precipitous declines in the numbers of wolves on 

Prince of Wales, (2) new information regarding the levels of illegal take as compared to legal 

take, (3) lack of an accurate road closure inventory, with reported closures often not effective at 

preventing access, and not providing the actual mitigation and/or protections that the Forest 

Service assumed they would when it adopted TLMP, and (4) the scientific knowledge that the 

OGRs simply are not large enough or adequately composed for a viable wolf population. 

This statement is true and accurate to the best of my scientific expertise and knowledge. 

Dated this 15th day of August, 2013. 

David K. Person, Ph.D 
i 

DOCUMENTS CITED IN THE STATEMENT OF DAVID K. PERSON 

Title PR No. 

Albert, D., and J. Schoen. 2007. A conservation assessment for the coastal 

forests and mountains ecoregion of Southeastern Alaska and the Tongass 

National Forest. In The coastal forests and mountains ecoregion of 

southeastern Alaska and the Tongass National Forest: A conservation 

assessment and resource synthesis, edited by J. Schoen and E. Dovichin, 

chapter 2. Anchorage, AK: Audubon Alaska and The Nature Conservancy 

(Albert and Schoen 2007) 

736_2140 

Albert, D., and J. Schoen. 2013. Use of historical logging patterns to identify 

disproportionately logged ecosystems within temperate rainforests of 

southeastern Alaska. Conservation Biology 27:774-784 

(Albert and Schoen 2013) 

Ballard, W. B., J. S. Whitman, C. L Gardner. 1987. Ecology of an exploited 

wolf population in south-central Alaska. Wildlife Monographs 98:1-54 

(Ballard et al. 1987) 

Bowyer, R. T., D. K. Person, and B. M. Pierce. 2005. Detecting top-down 

versus bottom-up regulation on ungulates by large carnivores: Implications 

for conservation of biodiversity. In Large carnivores and the conservation of 

biodiversity, edited by J. C. Ray, K. H. Redford, R. S. Steneck, and J. Berger, 

342-361. Covelo, CA: Island Press (Bowyer et al. 2005) 

736_2241a 

(Greenpeace 

Ex. 30) 

Brinkman, T. J. 2006. The Prince of Wales Island Deer Hunter Project: 

Preliminary Summary of Hunter Responses to Interview Questions.

Community Report, Department of Biology and Wildlife, University of 

Alaska Fairbanks, Fairbanks, Alaska (Brinkman 2006) 

736_443 

Brinkman, T. J., D. K. Person, F. S. Chapin III, W. Smith, and J. 

Hundertmark. 2011. Estimating abundance of Sitka black-tailed deer using 

DNA from fecal pellets. Journal of Wildlife Management 75(1):232-242 

(Brinkman et al. 2011) 

736_481 

Kohira, M., and E. A. Rexstad. 1997. Diets of wolves, Canis lupus, in logged 

and unlogged forests of southeastern Alaska. Canadian Field-Naturalist

111(3): 429-435. Ottawa ON (Kohira and Rexstad 1997)

Lowell, R. E. 2013. Petersburg Management Area. Presentation before 

January 2013 Board of Game meeting, available at 

http://www.adfg.alaska.gov/staticf/regulations/regprocess/gameboard/pdfs/2012-2013/southeast_1-11-

13/tab_5_section_1_petersburg_overview.pdf (Lowell 2013) (excerpts) 
ii 

Person, D. K., M. D. Kirchhoff, V. Van Ballenberghe, G.C. Iverson, and E. 

Grossman. 1996. The Alexander Archipelago wolf: A Conservation 

Assessment. General Tech. Report PMW-GTR-384. Juneau, AK: USDA 

Forest Service (Person et al. 1996) 

736_302 

Person, D. 1997. Letter to Theresa Woods, U.S. Fish and Wildlife Service, re: 

status review for the Alexander Archipelago wolf (Apr. 2, 1997) 

(Person 1997) 

Person, D. K. and R. T. Bowyer. 1997. Population Viability Analysis of 

Wolves on Prince of Wales and Kosciusko Islands, Alaska. Final Report to the 

U.S. Fish and Wildlife Service (Person and Bowyer 1997) 

736_2241a 

(Greenpeace 

submissions, 

scoping 

comments) 

Person, D., M. Kirchhoff, V. Van Ballenberghe, and R. T. Bowyer. Sept. 19, 

1997 Letter to Beth Pendelton, U.S. Forest Service (Letter to Beth Pendelton 

1997) 

736_367 

Person, D. K. 2001. Alexander Archipelago wolves: Ecology and population 

viability in a disturbed, insular landscape. Ph.D Dissertation, University of 

Alaska Fairbanks (abstract only) (Person 2001) 

736_303 

Person, D. K., R. T. Bowyer, and V. Van Ballenberghe. 2001. Density 

dependence of ungulates and functional responses of wolves: Effects of 

predator-prey ratios. Alces 37(2): 253-273 (Person et al. 2001) 

Person, D. K., and A. L. Russell. 2008. Correlates of mortality in an 

exploited wolf population. Journal of Wildlife Management 72:1540-1549 

(Person and Russell 2008) 

736_300 

Person, D. K. Estimating wolf populations in Southeast Alaska using 

noninvasive DNA sampling. Federal Aid Research Project Statement and 

Annual Progress Reports (Person 2009-2012) 

Person, D. K., and B. D. Logan. 2012. A spatial analysis of wolf harvest and 

harvest risk on Prince of Wales and associated islands, Southeast Alaska. 

Final Wildlife Research Report, ADF&G/DWC/WRR-2012-06 

(Person and Logan 2012) 

736_299 

Person, D. K., and T. J. Brinkman, Succession Debt and Roads: Short- and 

Long-Term Effects of Timber Harvest on a Large-Mammal Predator-Prey 

Community in Southeast Alaska. In North Pacific Temperate Rainforests, 

edited by G. H. Orians, and J. W. Schoen. Seattle, WA: University of 

Washington Press (Person and Brinkman 2013) 
iii 

Person, D. K. and K. Larson. 2013. Developing a Method to Estimate 

Abundance of Wolves in Southeast Alaska, Progress Report: 1 January 2013–

31 May 2013 (Person and Larson 2013) 

Person, D. K., 2011. Email messages and maps re: the Big Thorne Project 

(Person ADF&G emails and maps) 

Powell, B. E. 1998. Tongass Forest Plan Implementation Clarification, 

Tongass National Forest News (Aug. 7, 1998) (Powell 1998) (excerpt) 

Puchlerz, T. Directive re: Project Level Environmental Analysis (Aug. 6, 

2002) (Puchlerz 2002) 

Schoen, J. and M. Kirchhoff. 1990. Seasonal habitat use by Sitka black-tailed 

deer on Admiralty Island, Alaska. Journal of Wildlife Management 54:371-

378 (Schoen and Kirchhoff 1990) 

Wallmo, O. C. and J. Schoen. 1980. Response of deer to secondary forest 

succession in southeast Alaska. Forest Science 26:448-462 

(Wallmo and Schoen 1980) 

736_346 

(abstract only) 

Weckworth, B. V., S. Talbot, G. K. Sage, D. K. Person, and J. Cook. 2005. 

A signal for independent coastal and continental histories among north 

American wolves. Molecular Ecology 14:917-931 (Weckworth et al. 2005) 

736_347 
1 - Declaration of Jonathan J. Rhodes, Hydrologist

I, JONATHAN J. RHODES, declare and state as follows:

Qualifications

1. My name is Jonathan J. Rhodes. I am a hydrologist with more than 30 years of 

experience, with a B.S. in hydrology from University of Arizona, a M.S. in hydrology and 

hydrogeology from University of Nevada-Reno and I finished all required academic work toward 

a Ph.D. in forest hydrology at the University of Washington. Since 2001, I have worked as a 

consulting hydrologist for a variety of clients, including county and tribal governments in 

Oregon, Washington, and Idaho. Prior to that I worked for more than 12.5 years at the Columbia 

River Inter-Tribal Fish Commission (CRITFC), where I served as Senior Scientist-Hydrologist. 

My professional experience includes work for tribal, federal, state, county, and city governments, 

universities, and non-profit groups in eight western states. 

2. During my tenure at CRITFC, our work with the U.S. Forest Service (hereafter

“USFS”) provided the groundwork for most of the substantive watershed protection measures 

ultimately adopted by the USFS and U.S. Bureau of Land Management (hereafter “USBLM”) in 

two combined agency management strategies designed to reduce the decline in habitat for 

anadromous and resident salmonids, including steelhead, chinook salmon, and cutthroat trout, in 

the Columbia River basin: “Implementation of Interim Strategies for Managing Anadromous 

Fish-Producing Watersheds in Eastern Oregon and Washington, Idaho, and Portions of 

California” (USFS and USBLM, 1995).

3. Most of my work has over the past 24 years has focused on the effects of current 

and proposed uses of land and water on water quality, streams and habitats for native trout and 

salmon. For more than 20 years, I have monitored the impacts of the public land management on 

watersheds and aquatic systems. 
2 - Declaration of Jonathan J. Rhodes, Hydrologist

4. I have co-authored numerous papers on the effects of logging (including 

thinning), roads, and related activities on watersheds and aquatic systems published in peerreviewed scholarly journals (e.g., Espinosa et al., 1997; Beschta et al., 2004; Karr et al., 2004; 

Rhodes and Baker, 2008). I am the primary author of (Rhodes et al., 1994), a peer-reviewed 

report developed under contract at the behest of National Marine Fisheries Service. Rhodes et al. 

(1994) includes a comprehensive review of available scientific information on the effects of 

logging and roads on water quality and salmonid habitat. This report has been cited in numerous 

scholarly journals, as well as many U.S. Forest Service scientific assessments. For instance, the 

U.S. Forest Service’s scientific assessment of management impacts on interior Columbia Basin 

national forests authored by USFS research scientists (USFS and USBLM, 1997a) cites Rhodes 

et al. (1994) more than 10 times. Similarly, the USFS’s synthesis of scientific information on 

roads (Gucinski et al., 2001), authored by USFS research scientists, cites Rhodes et al. (1994) six 

times regarding the impacts of roads on soils, watersheds, and aquatic systems. 

5. I am also the primary author of a peer-reviewed paper examining the impacts of 

fine sediment levels, including that contributed by roads, on salmon survival in streams in the 

Blue Mountains of Oregon (Rhodes and Purser, 1998) and co-author of a report providing the 

results of a government-funded study of sediment sources and their impacts on salmon survival 

in the Stillaguamish River in western Washington (Purser, et al. 2009). I have published many 

other reports related to the effects of land and water use on salmon habitat, stream sedimentation, 

and water quality. I have served as a peer-reviewer for the Open Forest Science journal, North 

American Journal of Fisheries, and an international symposium on the effects of forest 

management and streams for papers related to soil erosion and stream sedimentation of salmonid 

habitats. A true and correct copy of my curriculum vitae is included with this declaration.
3 - Declaration of Jonathan J. Rhodes, Hydrologist

Information Reviewed

6. I reviewed the Final Environmental Impact Statement (FEIS) for the Big Thorne 

Project (Project) Thorne Bay Ranger District, Tongass National Forest (TNF), dated June 2013, 

and the Project’s Record of Decision, and its appendices, dated June 2013. 

7. I also reviewed other pertinent scientific literature. The list of this literature is too 

lengthy to list here, so I have listed it separately at the end of this declaration. I also drew on my 

professional judgment and experience in preparing this declaration.

Scope of Review

8. I submit this information to explain how the FEIS failed in many ways to 

reasonably assess the Project’s effects on watershed conditions and aquatic resources, including 

stream conditions, riparian areas, water quality, and salmonid habitats and populations. I 

describe some of the numerous ways that FEIS did not reasonably incorporate and make known 

available scientific information on the nature, intensity, and duration of the likely direct, indirect, 

and cumulative effects of the Project on large woody debris (LWD), water temperature, stream 

sedimentation and channel form, peak flows, salmonid habitats, and water quality. I also discuss 

how the FEIS failed to reasonably describe and assess existing watershed and aquatic impacts 

and aspects of the Project’s action alternatives that are likely to cause significant and persistent 

harm to affected watersheds, riparian areas, salmonid habitats and populations, and streams.

Discussion

The FEIS fails to adequately assess and make known the impacts of existing roads 

and proposed Project road activities on watersheds, riparian areas, streams, and 

fish habitats. 

The FEIS does not properly assess road-stream connectivity and consequent 

impacts on peak flows and sediment delivery from roads.
4 - Declaration of Jonathan J. Rhodes, Hydrologist

9. The FEIS failed to reasonably describe the hydrologic connectivity of the existing 

road network and proposed roads under the Project. This is a severe defect because proper 

assessment of road-stream connectivity is essential to adequately evaluating cumulative peak 

flow and sediment delivery impacts of roads under existing conditions and the action 

alternatives. Notably, having conducted road connectivity surveys (e.g., Rhodes and Huntington, 

2000) over many years in many areas, I can attest that such surveys are straightforward and 

relatively easy to do and analyze.

10. The FEIS’s assessment of existing road crossings and road crossings proposed 

under the action alternatives on Class I through Class III streams is not an adequate surrogate for 

assessing road-stream connectivity, for several reasons. First, although road crossings certainly 

act as points of road-stream connectivity (Kattlemann, 1996; Rhodes and Baker, 2008; Plumas 

National Forest, 2010), roads are also directly connected to streams with considerable frequency 

at other features, including drainage to hillslopes near streams, ditches, and gullies below 

drainage diversions (Wemple et al., 1996; Rhodes and Huntington, 2000; Gucinski et al., 2001; 

Great Lakes Environmental Center (GLEC), 2008). Roadside ditches collect and concentrate 

road runoff and route it considerable distances to discharge points to streams, such as culverts 

that discharge to gullies, increasing the length of road that delivers sediment-laden runoff to 

streams. USFS and USBLM (1995) noted that channelized flows of water and sediment, such as 

those in gullies below road ditch drainage features, can travel several hundred feet downslope.

11. Roads typically contribute water and sediment to streams via hydrologic 

connectivity at points other than stream crossings when they are relatively close to streams. The 

Clearwater National Forest (2003) noted that roads within 300 feet of streams likely contribute 

some runoff and sediment to streams. Sediment detention below road runoff diversions is 
5 - Declaration of Jonathan J. Rhodes, Hydrologist

limited and quickly exhausted, resulting in the delivery of sediment to streams from road runoff 

diversions near streams, particularly in areas with high levels of precipitation, such as the Pacific 

Northwest, (which has a similar precipitation levels to the Project area) as noted in the USEPAcommissioned assessment of road Best Management Practices (BMPs) and the water quality 

impacts of roads (GLEC, 2008), although this is not assessed or divulged in the FEIS. 

12. The number of road crossings on Class I through III streams under existing 

conditions and the action alternatives, as presented in the FEIS (p. 3-291) and ROD (p. 39), does 

not provide an index of road-stream connectivity under existing conditions or the alternatives, 

because it fails to address other points of stream-road connectivity, such as drainage features and 

roads close to streams. The FEIS completely fails to make known the amount of road that is 

relatively proximate (e.g., within 300’) to all streams under existing conditions and the action 

alternatives; such road information could, at least, provide an index of road connectivity at the 

subwatershed and watershed scales. Therefore, the FEIS does not provide an index of roadstream connectivity, which is critical to assessing the direct, indirect, and cumulative effects of 

the existing road network combined with those of the action alternatives.

13. The FEIS’s failure to assess and disclose the amount of roads that are

hydrological connected to streams at locations is a severe defect because it is likely that a 

significant fraction of the existing road network is hydrologically connected to streams and that a 

significant fraction of roads proposed for reconstruction, construction, and elevated use under the 

alternatives will also be hydrologically connected to streams. The magnitude of the average 

annual precipitation in the Project area is high, which serves to increase the amount of 

connectivity between roads and streams, including at areas other than stream crossings. The 

USFS’s own summary of scientific information on roads (Gucinski et al.; 2001) noted, “As 
6 - Declaration of Jonathan J. Rhodes, Hydrologist

storms become larger or soil becomes wetter, more of the road system contributes water directly 

to streams.” MacDonald and Larsen (2009) provide data corroborating that the amount of roads 

contributing sediment and runoff to streams increases with increasing mean annual precipitation. 

It is likely that more than 50% of the existing road network is connected to streams and that a 

similar fraction roads proposed for construction and reconstruction will be connected to streams, 

even if engineered drainage diversions are in place on roads, based on the relationship between 

road-stream connectivity and mean annual precipitation in MacDonald and Larsen (2009)1

together with a mean annual precipitation of 120 inches for Project area. Using the same 

information, it is likely that an even higher fraction of roads without engineered drainage 

structures within the Project area are connected to streams. It is highly likely that a significant 

fraction of this connectivity occurs at locations other than stream crossings, based on surveys in 

areas with lower levels of mean annual precipitation (e.g., Wemple et al., 1996; Rhodes and 

Huntington, 2000).

14. A second reason that the FEIS’s (p. 3-291) estimate of stream crossings on Class I 

through Class III streams fails to provide a reasonable index of road-stream impacts is that it

completely omits the number of road crossings on Class IV streams under existing conditions 

and by roads subject to elevated use, reconstruction, and construction under the action 

alternatives. This is a severe defect because these smaller headwater streams collectively

provide much of the cumulative sediment and water to downstream fish habitats, due to the 

extent and position of these smaller headwater streams (Moyle et al., 1996; USFS and USBLM, 

1997a). Thus, it is necessary to assess cumulative impacts of road connectivity with Class IV 

streams, because streamflow and fine sediment impacts to these streams are readily and rapidly 

 1

 MacDonald and Larsen (2009) explicitly note that “In the absence of local data, the relationship shown in Figure 1 

[in the paper] can be used to estimate the proportion of unpaved roads that are likely to be delivering runoff and 

sediment to the stream channel network.”
7 - Declaration of Jonathan J. Rhodes, Hydrologist

translated downstream, cumulatively affecting downstream fish habitats (Rhodes et al., 1994; 

Moyle et al., 1996; USFS and USBLM, 1997a).

15. Although the TNF’s stream class typing assumes that individual Class IV streams 

have little immediate effect on downstream water quality or fish habitat capability (FEIS, p. 4-

31), the FEIS provides no sound scientific rationale for this assumption. However, this 

assumption regarding Class IV streams fails to reflect the available scientific information 

regarding the cumulative importance of smaller headwater streams, typed as Class IV. For 

instance, the USFS’s own scientific assessment, USFS and USBLM (1997), noted that smaller, 

non-fish bearing perennial and intermittent streams:

a) are more affected by sedimentation from sediment production accelerated by upslope 

activities than larger streams (pp.1365 to1366);

b) are a primary source of sediment supplied to fish bearing streams (p. 1366);

c) typically comprise the majority of the channel network and “...therefore strongly 

influence the input of materials to the rest of the channel system.” (p. 1366);

d) highly vulnerable to the impacts of upslope activities, because the likelihood for 

discernible instream effects increases with slope steepness and the erodibility of sideslopes 

(p. 1367); these smaller headwater streams tend to have steeper and more erodible 

sideslopes (p. 1371). 

Fine sediment supplied to these smaller streams by road impacts is readily transported 

downstream, thereby cumulatively affecting downstream conditions influenced by streamflow 

and sediment. The FEIS completely fails to disclose this scientific information regarding the 

cumulative importance of Class IV streams to downstream conditions, which is a significant 

flaw. Such headwater streams typically comprise the majority of the stream network; however, 
8 - Declaration of Jonathan J. Rhodes, Hydrologist

the FEIS compounds the failure to assess impacts of road crossings on Class IV streams, by 

completely failing to provide any sound information on the extent of such streams and the 

fraction of the stream network comprised by these streams within Project area.2 For these 

reasons, the FEIS’s failure to assess and make known the total number of stream crossings on 

Class IV streams under existing conditions and affected by the action alternatives road activities 

is a fatal defect with respect to peak flows, sediment-related impacts, 3 and consequent effects on 

salmonids and their habitats.

16. The failure to properly assess and make known the level of road-stream 

connectivity in subwatersheds under existing conditions and under the proposed alternatives 

renders the FEIS’s assessment of peak flow impacts highly defective. It is well-documented that 

road-stream connectivity elevates peak flows (e.g. La Marche and Lettenmaier, 2001; Jones and 

Grant, 1996; Grant et al., 2008). Roads vastly elevate runoff to streams due to extremely low 

infiltration rates on roads, generating runoff even from low-intensity precipitation, which is 

delivered to streams at points of hydrologic connectivity, contributing to frequent and enduring 

elevation of runoff and peak flows. Notably, such alterations of runoff by roads persist for even 

longer than roads do: even with obliteration, infiltration rates remain low for several years after 

such treatment (Foltz et al., 2007). 

 2

 The FEIS’s (p. 3-342) inadequate information on the known length of streams of different classes in the Project 

area does not provide an sound estimate of the extent of Class IV streams, because the FEIS (p. 3-342) explicitly 

notes regarding this information that “Class IV streams greatly under represented as streams can only be 

determined by site surveys.” (emphasis added) It is, therefore, apparent that the FEIS has failed to even determine 

the cumulative length and frequency of these streams and, hence, fails to properly assess their cumulative 

importance with respect to effects on downstream water quantity, sedimentation, and water quality.

3

 As is discussed in greater detail in other sections of this declaration, management-induced sediment delivery 

contributes to the degradation of a host of stream conditions, including suspended sediment, turbidity, fine sediment 

levels in stream substrate, width/depth, and pool volume, depth, frequency, and quality (Richards, 1982; USFS et al., 

1993; Rhodes et al., 1994; Spence et al., 1996; USFS and USBLM; 1997). Notably, degradation of these sedimentaffected stream conditions in salmonid habitats reduces the survival and production of all salmonid species 

inhabiting streams in the Project area, including pink, coho, sockeye, chum, and chinook salmon and cutthroat, 

steelhead, and Dolly Varden trout (Krueger, 1981; Everest and Meehan, 1983; Meehan, 1991; USFS et al., 1993; 

Rhodes et al., 1994; Spence et al., 1996; USFS and USBLM; 1997; Suttle, 2004). 
9 - Declaration of Jonathan J. Rhodes, Hydrologist

17. Although the FEIS cites the USFS’s “state-of-science” report on the effects of 

forest practices on peak flows (Grant et al., 2008), the FEIS fails to make known that Grant et al. 

(2008, p. 39), explicitly stated regarding peak flow impact assessment (emphasis added): 

“Determining where the proposed treatment falls within this range requires an 

assessment of the intrinsic basin condition and intensity of proposed management 

action...For example, the existing and proposed road network should be evaluated 

with respect to its degree of connectivity with the stream network...”

Thus, the FEIS’s failure to properly assess road-stream connectivity directly conflicts with the 

USFS’s own guidance regarding the proper assessment of the cumulative impacts of roads on 

peak flows, although this is never made known in the FEIS.

18. The failure of the FEIS to properly assess road-stream connectivity and resulting 

flow impacts is significant because these effects can significantly increase sediment delivery to 

downstream fish habitats. Peak flow alteration by roads tends to be most pronounced in smaller 

subwatersheds, such as those for smaller streams, as the USFS’s own literature and assessments 

have noted (Gucinski et al., 2001; Grant et al., 2008; Drake et al., 2008), resulting in increased 

channel erosion in headwater streams, as USFS research has noted (King, 1989). Even relatively 

small changes in short duration peak flows in headwater streams can significantly increase 

downstream sedimentation because channel erosion and sediment transport are exponentially 

affected by streamflow (King, 1989; Dunne et al., 2001). Increased channel erosion due to 

increased runoff from roads in small headwater subwatersheds also accelerates mass failures 

occurrences (Montgomery, 1994), thereby increasing downstream sedimentation.

19. There are several reasons why the FEIS’s failure to properly assess road-stream 

connectivity under existing conditions and the action alternatives is a terminal defect with 
10 - Declaration of Jonathan J. Rhodes, Hydrologist

respect to assessing sediment-related impacts from roads to aquatic systems under the 

alternatives. It is well-documented that rates of soil erosion from roads are orders of magnitude 

higher than on undamaged soils on a per unit basis, due to bare soils, soil compaction, and the 

greatly elevated surface runoff. Cut and fill slopes associated with roads also typically undergo 

elevated erosion, adding to sediment loads from road surfaces. Concentrated road runoff in 

ditches can elevate sediment levels in runoff from roads still more. This sediment-laden water is 

delivered to streams very efficiently at road-stream connections.

20. Little can be done to effectively reduce runoff and sediment delivery from roads 

at stream crossings (Kattlemann, 1996), as the USFS has repeatedly conceded. For instance, the 

Plumas National Forest Travel Management FEIS (2010) noted: “Road/stream crossings are 

significant sources of sedimentation on [Forest Service] lands. Even well-drained roads and 

trails will likely deliver some amount of surface-generated sediment to stream channels at 

crossings.” Therefore, it is clear that road crossings elevate sediment delivery to the channel 

network. However, the FEIS fails to even provide a reasonable index of these impacts, because 

it does not provide estimates of road crossings on Class IV streams by alternatives at the 

subwatershed scale.

21. Gullies connecting roads to streams not only efficiently deliver sediment to 

streams, but can also increase sediment loads delivered to streams via gully erosion triggered by 

road runoff, which can be a significant source of anthropogenic sediment loads (Reid et al., 

2010), although this is not made known in the FEIS. The FEIS fails to provide a reasonable 

index of these impacts, because it fails to make known the amount of existing road that is 

relatively proximate to streams at the subwatershed scale.

The FEIS does not adequately assess and make known the magnitude, duration, 

and extent of sediment delivery due to the construction, reconstruction, and 
11 - Declaration of Jonathan J. Rhodes, Hydrologist

subsequent decommissioning/storage of some of these roads in the Project area 

under the alternatives. 

22. The FEIS’s (p. 3-270) baseless assertion that road construction under the action 

alternatives only result in short-term increases in sediment supplied to streams is in direct 

conflict with available scientific information regarding the persistence and magnitude of 

sediment impacts due to road construction (e.g., USFS et al., 1993; Rhodes et al., 1994; USFS 

and USBLM, 1997; Beschta et al., 2004). Although it is not adequately made known in the 

FEIS, it is well-documented that the construction of roads, including “temporary” roads, vastly 

and immediately elevates erosion and subsequent sediment delivery, particularly in the first few 

years after construction. However, road erosion remains enormously elevated relative to 

undisturbed areas for many decades, even with decommissioning or obliteration (Beschta et al., 

2004), as USFS assessments and cumulative effects methods acknowledge (Potyondy et al., 

1991; USFS et al., 1993; Menning et al., 1996). Even many decades after obliteration, erosion 

rates on roads remain well above natural rates, as USFS cumulative effects methods indicate 

(Potyondy et al., 1991; Menning et al., 1996).

4

 Reconstruction of unused or previously 

decommissioned roads also greatly elevates road erosion and subsequent sediment delivery in a 

highly persistent fashion (Beschta et al., 2004), although this is also not adequately disclosed in 

the FEIS. For these reasons, the proposed road construction and reconstruction under the action 

alternatives would cause major, enduring increases in sediment delivery to streams due to the 

high level of stream-road connectivity in the Project area, although the FEIS fails to properly 

make known the persistence of these significant impacts. 

 4 USFS and USBLM, 1997b, Chapter 3, Effects of proposed alternatives on aquatic habitats and native fishes, in

Evaluation of EIS Alternatives by the Science Integration Team. Vol. I PNW-GTR-406, USFS and USBLM, 

Portland, OR, notes that the approach in Menning et al. (1996) regarding the road-related cumulative impacts to 

watersheds were consistent with the USFS’s experts’ assessments of the sediment-related risks from these activities.
12 - Declaration of Jonathan J. Rhodes, Hydrologist

23. The FEIS compounds these flaws by failing to provide any information on the 

likely level of the action alternatives’ constructed and reconstructed roads’ connectivity with 

streams, which strongly affects the magnitude of sediment delivery from such roads. The FEIS 

does not even provide a reasonable index of these impacts by alternative because it does not

provide any assessment of the amount of crossings of Class IV streams by constructed and 

reconstructed roads or provide a notion of the amount of roads proposed for construction and 

reconstruction near (<300 feet) streams, and, hence, likely connected to streams, by 

subwatershed under the action alternatives. Due to these defects, the FEIS fails to reasonably 

asses and disclose the cumulative impacts of road construction and reconstruction on sediment 

delivery to streams under the alternatives at the scales of subwatersheds, watersheds, and the 

Project area. The FEIS also fails to reasonably differentiate among the alternatives with respect 

to sediment impacts from road construction and reconstruction due to the same defects.

24. The FEIS fails to adequately assess and disclose that roads that are put into 

storage and/or decommissioned will continue to significantly elevate sediment delivery to 

streams for several decades. Even over many years such roads undergo nominal recovery in the 

key attributes that cause elevated sediment delivery (Beschta et al, 2004): infiltration and 

vegetative cover. Notably, the USFS’s own research indicates that even with obliteration 

treatments, which likely contribute more to road recovery than storage and/or decommissioning, 

infiltration and vegetative recovery is exceedingly minor several years after such treatment (Foltz 

et al., 2007). Further, efforts to disconnect roads from streams on roads that are proximate to 

streams are frequently unsuccessful, especially in area with high levels of precipitation (GLEC, 

2008), such as the Project area. As we noted in Beschta et al. (2004):
13 - Declaration of Jonathan J. Rhodes, Hydrologist

“Accelerated surface erosion from roads is typically greatest within the first years 

following construction although in most situations sediment production remains 

elevated over the life of a road (Furniss et al. 1991; Ketcheson & Megahan 1996). 

Thus, even ‘temporary’ roads can have enduring aquatic impacts. Similarly, major 

reconstruction of unused roads can increase erosion for several years and potentially 

reverse reductions in sediment yields that occurred with non-use (Potyondy et al. 1991). 

Where roads are unpaved or insufficiently surfaced with erosion resistant aggregate, 

sediment production typically increases with increased vehicular usage (Reid & Dunne 

1984)...Furthermore, the assumption that road obliteration or BMPs will offset the 

negative impacts of new road and landing construction and use is unsound since road 

construction has immediate negative impacts and benefits of obliteration [or 

decommissioning] accrue slowly.” 

Therefore, it is clear that roads that are decommissioned, closed, and/or stored will continue to 

contribute elevated sediment to streams for decades, particularly such roads that are proximate to 

streams, although this is not adequately assessed and made known in the FEIS’s assessment of 

the cumulative watershed effects of the action alternatives.

The FEIS did not properly assess and make known the magnitude and extent of 

increased sediment delivery due to the elevated use of roads under the action 

alternatives. 

25. The FEIS’s failure to adequately assess and make known the magnitude, duration, 

and, extent of increased sediment delivery from roads due to increased road use under the action 

alternatives is a severe defect, because the Project will increase road traffic for log haul on many 

roads for many years under the selected alternative. Many of these roads are hydrologically 

connected to streams.
14 - Declaration of Jonathan J. Rhodes, Hydrologist

26. Increased road use elevates sediment production by producing highly mobile fine 

sediment on road surfaces, rutting road surfaces, and the disrupting of gravel or aggregate 

surfaces. The mobile fine sediment on the road surfaces produced by road traffic is easily 

transported to streams by runoff that inevitably occurs on roads in response to even relatively 

minor rain or snowmelt events.

27. Studies have repeatedly documented that increased logging traffic on unpaved 

roads greatly elevates sediment delivery to streams (Reid and Dunne, 1984; Foltz, 1996; Luce 

and Black; 2001; Gucinski et al., 2001; Beschta et al., 2004). In western Washington with a 

climate similar to the Project area, graveled roads used by more than four logging trucks per day 

generated more than 100 times the sediment delivered to streams than roads with light use and 

more than 1,000 times that from abandoned roads (Reid et al., 1981; Reid and Dunne, 1984). 

Even with a road surface of crushed rock aggregate, which is often used with the intent to reduce 

sediment production, Foltz (1996) documented that elevated log haul traffic increased sediment 

production by 2 to 25 times that on unused roads in western Oregon. Foltz (1996) noted that a 

similar range of increases due to road traffic was likely in other regions, because the mechanisms 

causing the effect are similar among regions. Luce and Black (2001) also documented that 

increased sediment production from elevated traffic on roads surfaced with rock aggregate. 

Although it is not disclosed in the FEIS, the USFS’s summary of road impacts (Gucinski et al., 

2001) concluded that “...rates of sediment delivery from unpaved roads are . . . closely 

correlated to traffic volume.” Therefore, increases in road traffic under the action alternatives 

would increase sediment production and delivery, especially from roads that are hydrologically 

connected to streams. 
15 - Declaration of Jonathan J. Rhodes, Hydrologist

28. Road traffic when roads are wet increases sediment delivery from roads still 

more. Reid (1998) estimated the use of graveled roads during wet weather increased the duration 

of higher instream turbidity from elevated road erosion by about 30-40%. 

29. Traffic on wet roads contributes to the development of ruts, which increase 

erosion by concentrating road runoff (Foltz, 1996). Rut development increases sediment 

delivery from surface erosion on roads by about 2-5 times that on unrutted roads (Burroughs, 

1990; Foltz and Burroughs, 1990). 

30. Ruts increase sediment delivery from roads for as long as the ruts persist, even 

after road use declines or ends. Thus, rutting of roads by traffic when roads are wet significantly 

increases sediment loads in runoff from roads in a persistent fashion. This increase in sediment 

delivery from use when roads are wet is over and above the highly elevated levels caused by the 

existence of roads.

31. Vehicular traffic on wet roads can negate or greatly reduce the effectiveness of 

efforts to limit sediment delivered to streams. For instance, the use of wet roads often destroys 

or damages drainage features, such as water bars, and other attempts to reduce road-stream 

connectivity. Wet weather reduces the bearing strength of road surfaces, leading to submerging 

of gravel or aggregate into the native road surface under the weight of vehicles and/or pumping 

finer material below gravel to the road surface (Fu et al., 2010), returning the treadway to a more 

native-surfaced condition. The physical effects of road traffic also result in the lateral 

displacement of gravel or aggregate from the treadway, resulting in a more native-surfaced 

condition, which further elevates sediment delivery from trafficked roads.

32. Significant road traffic, especially on wet roads, can increase the need for more 

frequent road maintenance, which can elevate sediment delivery from roads. Grading and ditch 
16 - Declaration of Jonathan J. Rhodes, Hydrologist

maintenance elevate road erosion and sediment delivery considerably (Luce and Black, 2001; 

Sugden and Woods, 2007). Although the FEIS (pp. 3-272, 3-285) acknowledges that ditchcleaning will occur under the selected alternative, the FEIS does not disclose that it adds to 

Project’s cumulative increase in sediment delivery to streams. 

33. The FEIS is devoid of a quantitative assessment of the duration, location, extent, 

and magnitude of increased sediment delivery due to road traffic and maintenance. The FEIS 

does not even provide any reasonable index of these effects on sediment delivery under the 

alternatives, because the FEIS does not identify the extent of the road network that will be 

subjected to increased road traffic, including during periods when roads are wet. The FEIS also 

fails to make known the amount of roads with high levels of stream connectivity subjected to 

elevated haul, such as those roads near streams or that cross Class I through Class IV streams, at 

the scale of subwatersheds, watersheds, and the Project.

34. The FEIS’s failure to properly assess increased sediment delivery due increased 

road use and maintenance is extremely significant for several reasons. Roads are typically the 

single largest source of surface erosion and fine sediment in managed watersheds. Fine sediment 

is the sediment caliber that is most deleterious to salmonids. The Project will plainly subject 

many roads with a high level of stream connectivity to considerable increases in log haul and 

other road use for several years. For these combined reasons, the FEIS has not reasonably 

assessed the impacts of Project’s action alternatives on sediment delivery to streams and 

consequent impacts on stream conditions, fish habitats, and fish populations.

The FEIS does not properly assess and make known the magnitude and extent of 

elevated sediment delivery due to the construction, reconstruction, and use of 

logging landings under the action alternatives. 
17 - Declaration of Jonathan J. Rhodes, Hydrologist

35. Logging landings have impacts on vegetation, soils, erosion, and subsequent 

sediment deliver that are akin to those of roads in their persistence and severity (Karr et al., 

2004), as a USFS cumulative effects method also indicates (Menning et al., 1996). The FEIS’s 

failure to assess the sediment impacts of landings under the alternatives is a severe defect 

because, on a per unit basis, landings sediment impacts similar to roads (Menning et al., 1997; 

Beschta et al., 2004) and can deliver sediment over considerable distances. In their study of 

sediment travel distance from forest management activities, Ketcheson and Megahan (1996) 

found that the longest travel distance of sediment originated from a landing. As we noted in Karr 

et al. (2004) (emphasis added): 

“Construction and reconstruction of roads and landings damage soils, destroy or alter 

vegetation, and accelerate the runoff and erosion harmful to aquatic systems...Logging, 

landings, and roads in riparian zones degrade aquatic environments by lessening the 

amount of large wood in streams, elevating water temperature, altering near-stream 

hydrology, and increasing sedimentation.” 

Landings essentially “zero-out” soil productivity in an irreversible manner (Geppert et al., 1984), 

although this is not disclosed in the FEIS.

36. Although the action alternatives would require the construction and reconstruction 

of many landings, the FEIS’s section on the cumulative watershed effects (CWE) of the 

alternatives is devoid of any assessment of the effects of landings at any scale. The FEIS 

compounds this major omission by failing to provide the locations, number, and total area of 

existing landings, and those proposed for construction and reconstruction under the action 

alternatives, at the scale of watersheds and relatively proximate (<300’) to streams. Due to the 
18 - Declaration of Jonathan J. Rhodes, Hydrologist

lack of the latter, the FEIS does not provide any reasonable index of landing impacts on sediment 

delivery to affected streams.

37. The FEIS’s failure to assess and divulge the number, total area, and locations of 

landings that will be reconstructed, constructed under the action alternatives is significant due to 

the persistence and intensity of landings effects on sediment delivery. Like roads, once landings 

are constructed, recovery of impacted areas is not rapid, even with remediation efforts, resulting 

in persistent elevation of erosion and sediment delivery. Other USFS assessments (Bitterroot 

National Forest, 2001, Rogue River and Siskiyou National Forests, 2003) have acknowledged 

that, as with roads, the loss soil properties and productivity on landings is irreversible because 

they are unlikely to fully recover even with remediation efforts.

38. Second, the failure to assess and divulge the number, location, and area of 

landings is a significant defect because of the likely number and total area of landings under the 

action alternatives. Typically at least one landing is needed per logging unit. Therefore, the 

action alternatives would involve the reconstruction and construction of a very large number of 

landings. 

39. The total area of these landings is likely to be highly significant. Analyses of 

numerous logging projects indicate that area of landings typically comprises 1.5-2% of the area 

logged. Using the low value in this range (1.5%) together with the area proposed for logging 

under the selected alternative (ROD, p. 4), it is likely that the area of landings for the selected 

alternative would be about 127.3 acres, most of which will be either constructed or significantly 

reconstructed. Because landings have similar impacts as roads on a per-unit-area basis, it is 

likely this level of landings will have soil and watershed impacts that are akin to the 

reconstruction or construction of about 26.3 miles of road with mean width of 40 feet, which is 
19 - Declaration of Jonathan J. Rhodes, Hydrologist

extremely significant, yet undisclosed in the FEIS with respect to its cumulative watershed 

effects, which would certainly be considerable. 

40. The FEIS’s lack of information on the locations of landing is also a major 

problem. Landings are often located in flatter terrain for logistical reasons, which often results in 

their being constructed relatively close to streams, where the potential for connectivity is high. 

For these combined reasons, the FEIS’s failure to properly make known the number, area, and 

location of landings are highly significant defects. These defects are compounded by the failure 

of the FEIS to properly assess and make known erosion and sediment delivery impacts of

landings, which renders its assessment of sediment impacts under the action alternatives 

unsound.

The FEIS does not reasonably evaluate and disclose existing impacts to riparian 

systems, particularly those from landings and roads, combined with action 

alternatives’ landing and road activities in riparian areas.

41. Proper evaluation of riparian conditions and impacts is essential to assessing the 

cumulative effects on streams and salmonid habitats and populations. Riparian conditions 

profoundly affect stream and salmonid habitat conditions, as legions of studies have noted (e.g., 

Meehan et al., 1991; USFS et al., 1993; Rhodes et al., 1994; Erman et al., 1996; Moyle et al., 

1996; USFS and USBLM, 1997a). Roads, logging, and landings in riparian areas persistently 

degrade stream and salmonid habitat conditions in several ways that greatly decrease the survival 

and production of salmonids, including those with habitats in streams draining the Project area. 

However, the FEIS does not adequately evaluate and disclose existing riparian conditions and the 

action alternatives’ impacts on them, due to a few key defects.

42. First, as previously discussed, the FEIS does not provide any data on the riparian 

areas occupied by existing and past roads and landings. This is a key defect because landings 
20 - Declaration of Jonathan J. Rhodes, Hydrologist

and roads degrade numerous riparian functions in an extremely persistent fashion. Such 

functions include the provision large woody debris (LWD), thermal regulation, bank stability, 

and sediment detention (Meehan, 1991; USFS et al., 1993; Rhodes et al., 1994; Erman et al., 

1996; USFS 1997a; b). The recovery of these riparian functions in areas occupied by roads and 

landings is nominal over many decades, even with non-use, due the irreversible loss of soil 

productivity caused by soil compaction and the irretrievable loss of topsoil. The FEIS (p. 3-530) 

acknowledges roads cause irreversible and irretrievable losses of soil productivity. Roads and 

landings in riparian areas are also long-term sources of elevated sediment delivery, as previously 

discussed. Therefore, it is absolutely essential to assess and make known the existing amount of 

riparian area occupied by landings and roads at the scale of watersheds and subwatersheds in 

order to reasonably assess and divulge cumulative effects on aquatic systems. For these same 

reasons, assessment and disclosure of the amount of riparian area that will be permanently 

damaged by road and landing construction under the action alternatives at the scale of 

watersheds and subwatersheds is necessary to evaluate in order to reasonably assess cumulative 

effects and adequately differentiate among the alternatives.

43. However, the FEIS provides no information on the amount of riparian areas 

occupied by landings and roads under existing conditions or that would be constructed or 

reconstructed under the action alternatives. This is a severe defect for several reasons. First, it is 

highly likely that a considerable amount of riparian areas are occupied by roads and landings. 

Major haul routes are typically located in riparian areas near streams. It is also likely landings 

occupy a significant fraction of riparian zones in many subwatersheds which have had an 

extremely high fraction of riparian areas logged, such as following subwatersheds: Cobble Cr. 

(40% of riparian area logged), Deer (65% of riparian area logged), Eagle Cr./Slide Cr. (64% of 
21 - Declaration of Jonathan J. Rhodes, Hydrologist

riparian area logged), Gravelly Cr. (44% of riparian area logged), Little Ratz Cr. (53% of 

riparian area logged), Sal Cr. (56% of riparian area logged), Thorne River Intertidal (62% of 

riparian area logged, Tiny (53% of riparian area logged), and Torrent (56% of riparian area 

logged) (FEIS, p. 3-274). Therefore, the failure to assess existing landings in riparian areas in 

these subwatersheds is a major defect in the assessment of the cumulative effects in these 

subwatersheds. 

44. It is highly likely that selected alternative (Alt. 3) would involve a significant 

amount of road construction and reconstruction in riparian areas because the selected alternative 

involves such activities on numerous stream crossings on Class I through Class III streams 

(FEIS, p. 3-291). However, the FEIS’s estimates of stream crossings do not provide an index of 

the amount of riparian area occupied by landings and roads, because the former likely doesn’t 

correlate with stream crossings. The FEIS’s stream crossing data does not include crossings on 

Class IV streams, which cumulatively affects downstream conditions. Thus, the FEIS does not

provide an index of the total amount of riparian areas occupied by roads and landings. The 

riparian harvest estimates are also unlikely to provide a reliable index of the riparian areas 

occupied by roads and landings, because a considerable amount of riparian roads are not directly 

associated with nearby riparian harvest, but rather, logging throughout the subwatersheds. 

45. Second, the long-term damage to the functionality of riparian systems by roads 

and landings contributes to the degradation of a variety of stream conditions that reduce the 

survival and production of salmonids. Roads and landings within one site-potential tree height 

of streams cause long-term diminishment of stream shading, contributing to elevated water 

temperatures, which are already a problem for salmonids in several streams in the Project area

(FEIS, p. 3-275). Roads and landings within one site-potential tree height of streams cause long 
22 - Declaration of Jonathan J. Rhodes, Hydrologist

term loss of in-stream LWD, which is already a significant problem in several project area 

streams, due to high levels of logged riparian areas (see: ¶ 43 of this declaration), contributing to 

the loss of in-channel sediment detention in headwater streams and in-stream cover and reduced 

pool quality, volume, and frequency (USFS et al., 1993; Rhodes et al., 1994; McIntosh, 2000; 

Buffington et al., 2002). Notably, field research has shown that in SE Alaska, LWD levels are

lower, in a statistically significant fashion, in some stream types draining logged and roaded 

watersheds than in undisturbed watersheds (Bryant et al., 2004),5 indicating that riparian impacts 

have significantly reduced LWD levels, although this important information is not disclosed in 

the FEIS. Temperature and LWD impacts adversely affect salmonid populations and their habitats, 

resulting in reduced survival and production of affected salmonid populations (Meehan, 1991; 

USFS et al., 1993; Rhodes et al., 1994; USFS and USBLM, 1997a; McCullough, 1999).

46. Roads and landings in riparian areas also cause long-term increases in sediment 

delivery, which has numerous adverse impacts on water quality and salmonid habitats. Elevated 

sediment delivery causes the loss of pool volume, depth, quality, and frequency (Lisle and 

Hilton, 1992; USFS et al., 1993; Rhodes et al., 1994; Buffington et al., 2002; McIntosh et al., 

2000). It also impedes pool development (Buffington et al., 2002). The loss of pool depth from 

sedimentation has been shown to be correlated with increased levels of fine sediment in streams 

caused by increased sediment delivery (Kappesser, 2002). USFS et al. (1993) concluded that 

increased sediment delivery from roads was one of the primary causes of the extensive pool loss on 

public lands throughout western Oregon, Washington, and northern California. McIntosh et al. 

(2000) noted that elevated sediment delivery from land management activities was major cause 

 5

 Bryant et al., (2000) found that reductions LWD in some stream types in roaded and logged watersheds relative to 

unmanaged ones are statistically significant at p<0.10. Due to variability and the consequences and probability of 

erroneously assuming there is no effect when there actually is one, a much higher p-value (e.g., p<0.20) and, hence 

lower minimum detectable effect size, is warranted (Peterman, 1990; Rhodes et al., 1994).
23 - Declaration of Jonathan J. Rhodes, Hydrologist

of the loss of large pools in many streams throughout the Columbia River basin. The loss of 

pool volume, frequency, and quality significantly diminishes the productivity of salmonid 

habitats, as USFS researchers have repeatedly noted (Meehan et al., 1991; USFS et al., 1993; 

USFS et al., 1997a; Reeves et al., 1997; McIntosh et al., 2000). Field studies in SE Alaska have 

shown that pool depths and pool frequency are lower, in a statistically significant fashion, in 

some stream types draining logged and roaded watersheds than in undisturbed watersheds 

(Bryant et al., 2004),

6

 which strongly indicates that the loss of LWD and increased sediment 

delivery has degraded pool habitats in the Project area. However, the FEIS completely fails to 

disclose this peer-reviewed information on the impacts of logging, roads, and landings on pool 

conditions.

47. Elevated sediment delivery from roads and landings near streams also causes 

increases in fine sediment levels in stream substrate, as repeatedly documented in both field 

studies and laboratory experiments (Eaglin and Hubert, 1993; Rhodes et al., 1994; Huntington, 

1998; Buffington and Montgomery, 1999; Hassan and Church, 2000; Kappesser, 2002; Cover et 

al., 2008). Increases in fine sediment in streams are particularly likely when the increases in 

sediment delivery are primarily comprised of fine sediment, as is the case with that from surface 

erosion from roads and landings. Notably, field studies in SE Alaska have shown that stream 

substrates are finer, in a statistically significant fashion, in some stream types draining logged 

and roaded watersheds than in undisturbed watersheds (Bryant et al., 2004),7 indicating that 

elevated sediment delivery has degraded fish habitats in the Project area. However, the FEIS not 

 6

 Bryant et al., (2000) found that reductions in pool depths and pool frequency in managed watersheds relative to 

unmanaged ones are statistically significant at p<0.10. As previously discussed, a much higher p-value (e.g., 

p<0.20) for statistical significance, and, hence lower minimum detectable effect size, is warranted (Peterman, 1990; 

Rhodes et al., 1994).

7

 Bryant et al. (2000) documented that differences in stream substrate size between unmanaged watersheds and those 

are roaded and logged watersheds are statistically significant at p<0.10 in some stream types. As previously 

discussed, a much higher p-value (e.g., p<0.20) for statistical significance, and, hence lower minimum detectable 

effect size, is warranted (Peterman, 1990; Rhodes et al., 1994).
24 - Declaration of Jonathan J. Rhodes, Hydrologist

only fails to disclose these important findings, but erroneously cites the findings as providing 

evidence that there is no statistical relationship between logging activities and substrate 

conditions, which is wholly misleading.

48. Increased levels of fine sediments in streams negatively affect salmonid survival 

and production in several ways (Meehan, 1991; Rhodes et al., 1994; Waters, 1995; USFS et al., 

1997a). Increases in fine sediment in streams sharply reduce the survival and production of all 

salmonid species inhabiting streams within the Project area, but cutthroat trout, which inhabit 

streams in the Project area, undergo especially sharp drops in egg-to-emergent survival with 

increased levels of fine sediment (Weaver and Fraley, 1991). Research indicates that any

elevated level of fine sediment significantly impairs the production of steelhead trout (Suttle et 

al., 2004), which inhabit Project area streams. 

49. Increased sediment delivery increases stream width and decreases stream depth in 

depositional reaches (Richards, 1982; Dose and Roper, 1994), which is also associated with 

reduced pool dimensions (Buffington et al., 2002). Dose and Roper (1994) identified increased 

sedimentation from roads and logging as one of the primary causes of the statistically significant 

increase in channel width in watersheds subjected to forest removal and roads in southwestern 

Oregon. Increases in width/depth ratio increase summer water temperatures (Beschta et al., 

1987; Rhodes et al., 1994). Bartholow (2000) estimated that the increases in channel width 

documented by Dose and Roper (1994) significantly increased summer water temperatures, even 

in the absence of any reduction in stream shading. Notably, field studies in SE Alaska have 

shown that stream width/depth is higher, in a statistically significant manner, in some stream 

types draining logged and roaded watersheds than in undisturbed watersheds (Bryant et al., 
25 - Declaration of Jonathan J. Rhodes, Hydrologist

2004),8 indicating increased sediment delivery has degraded channel form and water 

temperatures in the Project area.

50. For these combined reasons, the FEIS’s failure to properly assess and divulge 

roads and landings within a site-potential tree height of all streams in riparian area at the scale of 

subwatersheds and watersheds is a severe defect. Because the FEIS also failed to evaluate and 

make known the amount of landing and road construction in riparian zones, it did not adequately 

differentiate among the alternatives or properly assess cumulative effects of the alternatives on 

aquatic resources.

51. The FEIS’s (p. 3-274) estimates of riparian area logged in subwatersheds in the 

Project area may not fully capture the negative effects of past logging on riparian functions, and, 

hence, cumulative aquatic effects. This is because logging within a site-potential tree height of 

streams or floodplain degrades the riparian functions of LWD provision and maintenance of 

stream temperatures the sediment regime (USFS et al., 1993; Rhodes et al., 1995; Murphy, 1995; 

NRC, 1996; Erman et al., 1996; USFS et al., 1997a). Therefore, it is critical to assess the amount 

of area logged within one site-potential tree height of all streams or floodplains. There is no 

indication that in the FEIS or the Watershed Resources Report (James, 2013) that the logged 

riparian area estimates in the FEIS include all of the area logged within one site-potential tree 

height of all streams within the Project area.

52. The anecdotal information in the unit and road cards regarding riparian conditions 

is not a surrogate for the proper cumulative assessment and disclosure of riparian conditions 

within the Project area. The information in these cards is innately segmented and much is 

 8

 The differences in width/depth between unmanaged watersheds and those are roaded and logged watersheds are 

statistically significant at p<0.10 (Bryant et al., 2004). As previously discussed, given variability and the 

consequences and probability of erroneously assuming there is no effect when there actually is one, a much higher 

p-value (e.g., p<0.15) for statistical significance, and, hence lower minimum detectable effect size, is warranted 

(Peterman, 1990; Rhodes et al., 1994).
26 - Declaration of Jonathan J. Rhodes, Hydrologist

qualitative. At a minimum, a cumulative assessment of the riparian information in these cards 

would require quantitative aggregation of riparian condition at the scale of subwatersheds and 

watersheds, which is what should have been done in the FEIS, but was not. Although such an 

effort would have been tractable during the development of the DEIS and FEIS, it is not tractable 

for the interested public do such a necessary analysis during the time period allotted for review 

and comment on the FEIS.

The EA fails to reasonably evaluate and disclose that available scientific information 

indicates the Project’s “no-cut” buffers on Class I through Class III will not 

eliminate the selected alternative’s significant and persistent impacts to aquatic 

systems, including salmonid populations and habitats.

53. There are four primary reasons why the Project’s proposed no-cut areas along 

streams will not eliminate the selected alternative’s impacts on aquatic resources to levels and/or 

duration that are insignificant. First, as previously discussed, a significant, although undisclosed, 

amount of riparian areas on Class I- III streams will be damaged by road construction and road 

reconstruction, as evidenced by the stream crossing estimates for the selected alternative (FEIS, 

p. 3-291). It is likely that many of the constructed and reconstructed roads will occupy still more 

riparian areas, especially those along Class IV streams, for which no road crossing data are

provided in the FEIS. 

54. Impacts at or near stream crossings are not abated by the Project’s no-cut buffers,

because the roads pierce these buffers. A no-cut buffer does not exist between roads and streams 

at stream crossings. Simply enough, streamside vegetation and protection zones that are 

functionally destroyed by road construction or reconstruction cannot arrest the impacts of such 

activities. Therefore, a no-cut buffer has no significant effect on the persistent impacts caused by 

road construction and reconstruction at or near stream crossings, including the impacts on 

sediment delivery, runoff, LWD, stream shading, and water temperatures. As previously noted, 
27 - Declaration of Jonathan J. Rhodes, Hydrologist

crossings are long-term, major sources of sediment delivery that are not amenable to elimination 

(Kattlemann, 1996), as USFS assessments have acknowledged (Plumas National Forest, 2010; 

Sante Fe National Forest, 2010). Although the FEIS completely fails to disclose it, field studies 

have demonstrated that fine sediment levels in streams are increased by stream crossings in a 

statistically-significant fashion (Eaglin and Hubert, 1993). 

55. Stream crossing construction and reconstruction activities will remove vegetation 

along streams at and near a number of stream crossings, although this is not disclosed or 

analyzed in the FEIS. The vegetation removed at and near stream crossings provides shade and 

microclimate regulation that is vital to water temperature maintenance (Beschta et al., 1987; 

USFS et al., 1993; Rhodes et al., 1994); its removal will increase water temperatures (Beschta et 

al., 1987; McCullough, 1999). The FEIS also fails to include any sort of reasonable examination 

of the effect of constructing and reconstructing stream crossings in the Project area on water 

temperatures, although such crossings typically elevate summer water temperatures. 

56. The negative effects on water temperature from vegetation removal are persistent. 

In the absence of soil damage, about 25-40 years are needed for the full recovery of stream shade 

after vegetation removal (Beschta et al., 1987; Rhodes et al., 1994). However, the soil damage 

caused by roads significantly retards the regrowth of vegetation, increasing the persistence of 

impacts on water temperatures. 

57. Stream crossing construction contributes to increased water temperatures in other 

ways. Although undisclosed in the FEIS, road runoff that is delivered to streams at stream 

crossings and other points that are hydrologically connected to streams elevates stream 

temperatures during summer runoff events (National Research Council (NRC), 2008). This is 

because runoff occurs in response to even small precipitation events and this runoff is heated by 
28 - Declaration of Jonathan J. Rhodes, Hydrologist

warm road surfaces during summer. Notably, this thermal pollution from roads occurs when 

streams are already relatively warm due to seasonal effects, elevating the adverse impacts on 

salmonids (Meehan, 1991; Rhodes et al., 1994; McCullough, 1999). Although undisclosed in the 

FEIS, examinations of the effects of road density and density of stream crossings in multiple 

watersheds have verified that stream temperatures tend to increase with increasing density of 

roads and stream crossings (Nelitz et al., 2005). This is likely due to the combined impacts of 

roads and road crossings on water temperatures, including shade loss, subsurface flow 

disruption, channel widening, and warmed runoff contributions. By completely ignoring this

source of water temperature elevation due to stream crossings, the FEIS failed to reasonably 

make known the inadequacy of stream protection measures. In so doing, the FEIS also failed to 

reasonably examine the total impacts of the action alternatives on water quality, salmonid 

habitat, and salmonid populations. 

58. The construction of roads within one site-potential tree height of streams also 

irreversibly robs streams of LWD. Such impacts are extremely persistent due to the loss of soil 

productivity, causing long-term loss of LWD provision. These are serious impacts because 

many of the area streams already have depressed LWD levels. This situation is likely to 

continue to deteriorate due to high levels of past riparian logging. The survival and production 

of salmonids inhabiting streams affected by the action alternatives are negatively affected by 

LWD loss.

59. Second, a significant amount of riparian areas are already severely damaged by 

existing and past roads, landings, and logging, although the amount of existing and past roads

and landings near streams is not made known in the FEIS. However, the FEIS completely fails 

to reasonably assess or make known the severe long-term degradation of riparian functionality 
29 - Declaration of Jonathan J. Rhodes, Hydrologist

caused by past and existing roads and landings, including the long-term loss of LWD provision 

and water temperature moderation, together with greatly elevated sediment delivery. All of these 

impacts of existing degradation of riparian conditions strongly affect the survival and production 

of salmonids. 

60. The impacts from existing and past landings are extremely persistent. The USFS 

has conceded that soil productivity cannot be rapidly restored on roads and landings (Bitterroot 

National Forest, 2001; Rogue River and Siskiyou National Forests, 2003). The damage to soil 

productivity on constructed, reconstructed, and existing roads and landings within a site-potential 

tree height of streams will preclude or severely stunt the growth of trees that can ultimately 

provide instream LWD. Therefore, LWD levels are likely to continue to deteriorate in affected 

streams. The damage from existing roads and landings near streams also persistently retards the 

re-establishment of vegetation that provides the stream shade and microclimate regulation 

needed for the maintenance and restoration of water temperatures. 

61. Third, the FEIS fails to properly assess and divulge that the lack of no-cut riparian 

areas on Class IV streams will contribute to cumulative downstream degradation in a persistent 

fashion. Roads, landings, and logging along these streams elevate sediment delivery and 

streamflows, as previously discussed. The loss of LWD in Class IV streams also cripples 

sediment storage in headwater systems, resulting in elevated routing of sediment to downstream 

reaches. It can also reduce downstream LWD levels (May and Gresswell, 2003), as the FEIS (3-

275) acknowledges. Vegetation removal along headwater streams also cumulatively affects 

downstream water temperatures (Allen and Dietrich, 2005). 

62. The FEIS also does not properly disclose that numerous scientific assessments 

have noted that small headwater streams, such as those typed Class IV by the TNF, should be 
30 - Declaration of Jonathan J. Rhodes, Hydrologist

provided with protected riparian widths that are at least as great as downstream reaches due to 

the sensitivity of these headwater streams and their cumulative importance to downstream habitat 

conditions (Rhodes et al., 1994; Moyle et al., 1996; Erman et al., 1996; USFS and USBLM, 

1997a). The FEIS fails to disclose that USFS’s own assessments have recommended protected 

widths along smaller headwater streams of at least one site-potential tree height (USFS et al., 

1993; USFS and USBLM, 1997a) in order to limit downstream degradation from roads, logging, 

and landings near headwater streams. These evaluations indicate that the protection measures for 

numerous, sensitive, and cumulatively important Class IV streams under the Project are 

inadequate and will result in persistent and significant degradation of an array of fish habitat 

attributes that affect the survival and production of the salmonid populations that inhabit Project 

area streams. 

63. Fourth, the streamside “no-cut” buffers along Class I through Class III streams are 

not wide enough to obviate the impacts of upslope impacts or to fully maintain riparian functions 

essential to the maintenance of unimpaired aquatic habitat conditions. Numerous assessments, 

including those of the USFS (USFS et al., 1993; USFS and USBLM, 1995; 1997a), have 

indicated that at least 300 feet of undisturbed vegetation is needed to prevent sedimentation from 

unchannelized sediment delivery from upslope sources. Roads and landings near streams can 

generate create channelized flows of sediment that are travel many hundreds of feet. Thus, the 

no-cut widths of vegetation along Class I through Class III streams under the Project are not 

adequate to eliminate sediment delivery in channelized flows from roads, landings, and logging. 

For these reasons, the no-cut widths of vegetation along Class I through III streams under the 

Project are not sufficient to prevent significant and persistent increases in cumulative sediment 

delivery from logging, landings, and roads under the selected alternatives. Scientific information 
31 - Declaration of Jonathan J. Rhodes, Hydrologist

amply indicates that there is a high degree of certainty that the lack of adequate riparian 

protection under the Project together with the landing and road activities in riparian areas under 

the selected alternative will appreciably degrade riparian functions and aquatic resources, 

contrary to the cursory statements in the FEIS. 

64. Although it is not disclosed in the FEIS, the retention of all vegetation along 

streams for a distance of at least one site-potential tree height is necessary to maintain nearly 

natural levels of stream temperature moderation and provision of LWD recruitment (USFS et al., 

1993; Rhodes et al., 1994; USFS et al., 1997). There is no indication in the FEIS that the width 

of no-cut areas along streams corresponds to at least the height of a site-potential tree. 

Therefore, the no-cut widths along streams under the Project are unlikely to maintain unimpaired

levels of LWD recruitment and stream temperature moderation.

65. The FEIS fails to make the foregoing information regarding stream protection 

widths known. The FEIS compounds this significant omission by failing to soundly examine the 

ineffectiveness of the Project’s no-cut riparian widths and make known that the are inadequate.

The FEIS fails to adequately assess and make known the cumulative effects of 

existing conditions together with the impacts of the alternatives on fish habitats and 

populations. 

Water temperature

66. The FEIS has numerous defects with respect to the assessment of water 

temperature impacts. It failed to take a hard look at the cumulative impacts of:

• the Project’s permanent and irreversible of removal of stream shading and stream 

microclimate regulation due the construction and reconstruction of stream crossings 

and other road segments with one site-potential tree height of all streams;
32 - Declaration of Jonathan J. Rhodes, Hydrologist

• the Project’s cumulative effects on increasing stream width via the combined impacts 

of elevated peak flows and sediment, which can significantly elevate water 

temperatures, even in the absence of shade removal (Bartholow, 2000);

• stream shade removal on Class IV streams.

67. These defects are compounded by the failure to properly assess existing 

conditions that cumulatively affect water temperatures, including the cumulative loss of riparian 

shading and microclimate regulation due to roads, landings, and logging.9 Although the FEIS 

provides estimates of past riparian logging, the FEIS completely fails to provide any quantitative 

assessment of how much this logging has elevated water temperatures, although this has been 

eminently tractable for decades (Thuerer et al., 1984; Thuerer et al., 1985; Bartholow, 2000). 

68. The lack of data on current water temperatures in the affected subwatersheds and 

watersheds exacerbates the foregoing defects. Many USFS assessments have noted that the 

assessment of existing conditions is essential to evaluating cumulative effects (e.g., Sante Fe 

National Forest, 2010; Plumas National Forest, 2010; Mt. Hood National Forest, 2012). For 

instance, Mt. Hood National Forest (2012) acknowledged:

“...existing conditions reflect the aggregate impact of all prior human actions and 

natural events that have affected the environment and might contribute to cumulative 

effects.” 

 69. The FEIS fails to provide data on existing water temperatures for all affected 

subwatersheds, so the FEIS fails properly assess the effects of existing water temperature 

conditions combined with those from the selected alternative. Less than 40% of the 

 9

 As previously discussed, the FEIS’s estimates of past riparian harvest does not capture the loss of riparian 

vegetation due to landings and roads in riparian zones, which persistently elevate water temperatures.
33 - Declaration of Jonathan J. Rhodes, Hydrologist

subwatersheds and watersheds have any sort of condition surveys (FEIS, p. 3-258).

10 Further, 

the condition surveys appear to have involved only a few reaches in the surveyed subwatersheds

and watersheds. Temperature monitoring does not appear to have been part of any of these 

surveys (FEIS, p. 3-258). Therefore, the FEIS lacks the water temperature data needed to 

reasonably assess the cumulative water temperature impacts on salmonids in all affected 

subwatersheds. This is significant because, for instance, a water temperature increase of 0.5oF 

has far more profound impacts on salmonid survival and productivity when existing temperatures 

are near lethal levels than when water temperatures are well below lethal levels (McCullough, 

1999). 

70. The paucity of water temperature information is a problem compounded by the 

lack of stream surveys in subwatersheds with high levels of past riparian logging and, hence, 

likely significantly elevated water temperatures. Subwatersheds without stream surveys include: 

Cobble Cr. (40% of riparian area logged), Deer (65% of riparian area logged), Little Ratz Cr. 

(53% of riparian area logged), Thorne River Intertidal (62% of riparian area logged), Tiny (53% 

of riparian area logged), and Torrent (56% of riparian area logged) (FEIS, p. 3-274). 

71. The failure to properly assess water temperature is a major flaw in the FEIS’s 

assessment of cumulative effects on salmonid populations, survival, and production. Although 

there is little data available, water temperatures in some streams in the Project area are already a 

problem for salmonids, even under natural conditions (FEIS, p. 3-275), indicating that some 

 10 The FEIS (p. 3-258) indicates that “Proper Functioning Condition” (PFC) assessments were done in a few reaches 

in three (Eagle Creek, North Thorne River, and North Big Salt Lake, which, perplexingly, is both a subwatershed 

and watershed) of the 13 watersheds affected by the Project. PFC surveys in were done in a few reaches in four 

(Sal, Gravelly, Falls, and North Big Salt Lake) of the 13 subwatersheds affected by the Project (FEIS, p. 3-258). 

Tier II surveys were done in a few reaches in four (Eagle Creek , Sal Creek, Big Ratz and North Thorne River) of 

the 13 watersheds affected by the Project (FEIS, 3-258). In aggregate, this information indicates only about 38% of 

affected watersheds and about 31% of affected subwatersheds have had some conditions in few reaches surveyed. 

Therefore, the FEIS lacks reasonable data on existing conditions in affected streams that are crucial to proper 

cumulative effects assessment.
34 - Declaration of Jonathan J. Rhodes, Hydrologist

streams in affected subwatersheds are highly susceptible to temperature elevation due to riparian 

canopy loss from logging, roads, and landings. This information also indicates that additional 

incremental increases in summer high water temperatures are likely to adversely affect the 

salmonid species inhabiting Project streams. These impacts are likely to exacerbated further due 

increases in water temperature caused by global climate change (Beschta et al., 2012).

72. Water temperature elevation negatively affects the production and survival of all 

of the salmonids in the Project area in numerous ways (McCullough, 1999; McCullough, 2010). 

Elevated water temperatures have significant acute and chronic negative impacts on pink, coho, 

chinook, sockeye, and chum salmon that inhabit the Project area streams (FEIS, p. 3-345), 

including loss of suitable habitat, thermal passage barriers, increased competition by species 

tolerant of warmer temperatures, reduced egg survival during incubation, and increased 

susceptibility to disease (McCullough, 1999; 2010). Increased water temperatures have similar 

negative impacts on steelhead, cutthroat, and Dolly Varden trout (McCullough, 1999; 2010) that 

inhabit streams in the Project area (FEIS, p. 3-345). Dolly Varden require quite cold water and 

are particularly unable to tolerate increased water temperatures (McCullough, 1999) Due to the 

foregoing defects related to water temperature impacts and conditions and their importance to the 

production and survival of salmonids, the FEIS fails to reasonably assess and make known the 

cumulative impacts of the selected alternative on the salmonid populations affected by the 

Project.

LWD

73. The FEIS did not adequately assess the cumulative impacts of the following on 

LWD in streams:
35 - Declaration of Jonathan J. Rhodes, Hydrologist

• the magnitude of the Project’s irreversible elimination of LWD recruitment from 

areas affected by the construction and reconstruction of stream crossings and other 

road segments with one site-potential tree height of streams;

• the magnitude of irretrievable loss of LWD recruitment from past logging within one 

site-potential tree heights of streams;

• the magnitude of the irreversible loss of LWD recruitment due existing and past roads 

and landings that are within one site-potential tree heights of streams.

11 

 74. These defects are exacerbated by FEIS lack of systematic information on LWD 

levels in streams in all affected subwatersheds. Less than 40% of the subwatersheds and 

watersheds affected by the Project have any sort of condition surveys (See footnote 10). Based 

on the limited information in the FEIS, the condition surveys only involved a few reaches in 

surveyed subwatersheds and watersheds. 

75. The paucity of LWD information is a problem compounded by the lack of stream 

surveys in subwatersheds and watersheds with high levels of past riparian logging and, hence, 

likely significantly depressed LWD levels. Subwatersheds without stream surveys include: 

Cobble Cr. (40% of riparian area logged), Deer (65% of riparian area logged), Little Ratz Cr. 

(53% of riparian area logged), Thorne River Intertidal (62% of riparian area logged), Tiny (53% 

of riparian area logged), and Torrent (56% of riparian area logged) (FEIS, p. 3-274). Notably, a 

couple of these unsurveyed subwatersheds and watersheds would have LWD levels depressed 

further in an enduring fashion via road construction at stream crossings under the selected 

alternative, including Deer Cr. and Little Ratz Cr.(FEIS, p. 3-291). Due to lack of information 

 11 As previously discussed, the FEIS’s estimates of past riparian harvest do not capture the loss of riparian 

vegetation due to landings and roads in riparian zones, which persistently eliminate the provision of LWD from such 

areas.
36 - Declaration of Jonathan J. Rhodes, Hydrologist

on LWD conditions, the FEIS fails properly assess the effects of existing LWD conditions

combined with those from the selected alternative. 

76. The FEIS is devoid of any estimate of existing LWD loss due to past and existing 

riparian impacts although such estimates are eminently tractable (Gregory et al., 1991; Rhodes et 

al., 1994). The FEIS could have roughly estimated existing LWD loss by simply using mean 

level of trees per acre in riparian zones, combined with the riparian area logged in a 

subwatershed, together with the reasonable assumption that about 50% of trees within one sitepotential tree height would ultimately become instream LWD. For instance, in Deer Creek about 

294 acres of riparian area has been logged (FEIS, p. 3-274). Using a conservative assumed 

stocking rate of 120 trees per acre and an instream LWD recruitment fraction of 50%, yields an 

estimated loss of about 17,640 pieces of LWD due to past impacts in the Deer Creek 

subwatershed. This very rough estimate indicates that LWD loss has been significant and that 

more refined estimates are tractable and should have been included in the FEIS.

77. The failure to properly assess LWD impacts is a major flaw in the FEIS’s 

assessment of cumulative effects on salmonid populations, survival, and production. Studies 

have consistently documented that LWD serves irreplaceable functions in streams that are 

essential to maintenance of salmonid habitat quality and the survival and production of 

salmonids (e.g., Gregory et al., 1991; Meehan, 1991; USFS et al., 1993, Rhodes et al., 1994; 

McIntosh et al., 2000; Buffington, 2002). As we noted in Karr et al., (2004): 

“...large trees ...provide habitat for many species, reduce soil erosion, aid soil 

formation, and nourish streams as their leaves fall or their trunks decay (Henjum et 

al.1994)....there is no debate about the key role that large trees play in aquatic 

systems and many ecological processes...” (emphasis added). 
37 - Declaration of Jonathan J. Rhodes, Hydrologist

78. LWD is critically important to pool formation and maintenance of stream 

complexity (Gregory et al., 1991; Meehan, 1991; USFS et al., 1993, Rhodes et al., 1994; 

McIntosh et al., 2000; Buffington, 2002; Karr et al., 2004). Pools and channel complexity are 

vital to salmonid survival and production (Gregory et al., 1991; Meehan, 1991; USFS et al., 

1993, Rhodes et al., 1994; USFS and USBLM, 1995; 1997a; McIntosh et al., 2000). LWD also 

provides instream cover which is important for salmonids (Meehan, 1991; USFS et al., 1993; 

Rhodes et al., 1994). Reductions in LWD contribute to reductions in populations and production 

of coho, sockeye, chum, pink, and chinook salmon (Meehan et al., 1991; USFS et al., 1993; 

Rhodes et al., 1994; USFS and USBLM, 1997a) that inhabit affected streams in the Project area 

(FEIS, p. 3-345). Loss of LWD also has negative impacts on steelhead, cutthroat, and Dolly 

Varden trout (Krueger, 1981; Meehan et al., 1991; USFS et al., 1993; USFS and USBLM, 

1997a; Reeves et al., 1997) that inhabit streams in the Project area (FEIS, p. 3-345).

79. Although there is little data in the FEIS on LWD levels, the limited available 

information, together with information on riparian conditions, indicates that many streams have 

significant deficiencies of LWD, hampering salmonid production. Due to the defects in the 

FEIS’s analysis of LWD impacts, together with riparian conditions and the importance of LWD

to the production and survival of salmonids, the FEIS fails to reasonably assess and make known 

the cumulative impacts of the selected alternative on the salmonid populations affected by the 

Project.

Sediment delivery

80. As previously discussed, the FEIS did not adequately assess the cumulative 

impacts the following on sediment delivery to streams:
38 - Declaration of Jonathan J. Rhodes, Hydrologist

• the Project’s long-term elevation of sediment delivery to road and landing 

construction and reconstruction, particularly at all stream crossings and within a few 

hundred feet of all streams;

• the elevation of sediment delivery due to increased road use and maintenance, 

particularly at all stream crossings and on roads within a few hundred feet of all 

streams;

• the long-term loss of elevation of sediment delivery from existing and past roads and 

landings, especially at all stream crossings and from roads and landings within a few 

hundred feet of all streams. 

81. The lack of data on existing sediment-related conditions in affected 

subwatersheds compounds the foregoing defects in the FEIS related to sediment delivery. As 

previously discussed, these conditions include channel width/depth, fine sediment levels in 

substrate, turbidity, and the volume, frequency, depth, and quality of pools. Less than 40% of the 

subwatersheds and watersheds have any sort of condition surveys and the condition surveys only 

involved a few reaches in subwatersheds and watersheds. There is no indication in the FEIS that 

these surveys reasonably and consistently assessed all sediment-related conditions. 

82. The lack of information on sediment-related conditions is a problem compounded 

by the paucity of stream surveys in subwatersheds and watersheds with high levels of road 

density and/or past riparian logging and, hence, likely significantly elevated sediment delivery. 

Subwatersheds without stream surveys include: Cobble Cr. (40% of riparian area logged), Deer 

(65% of riparian area logged), Little Ratz Cr. (53% of riparian area logged), Pin (2.1% of area in 

roads); Thorne River Intertidal (62% of riparian area logged), Salamander (2.9% of area in 

roads), Tiny (53% of riparian area logged), and Torrent (56% of riparian area logged) (FEIS, p. 
39 - Declaration of Jonathan J. Rhodes, Hydrologist

3-274). Notably, several of these unsurveyed subwatersheds and watersheds would have 

sediment delivery elevated further, in enduring fashion due to road construction including at 

stream crossings under the selected alternative, including Deer Cr, Salamander, Pin, and Little 

Ratz Cr. (FEIS, pp. 3-287, 3-291). Therefore, the FEIS does not include the information needed 

to reasonably assess and disclose the cumulative impacts of the Project on sediment delivery and 

sediment-related conditions in affected subwatersheds. Such surveys are tractable, using 

accepted methods, but were not done.

83. Studies have consistently documented that elevated sediment delivery degrades 

several sediment-related conditions in salmonid habitat quality, reducing the survival and 

production of salmonids. Elevated sediment delivery contributes to loss of pool volume, depth, 

and frequency (Lisle and Hilton, 1992; USFS et al., 1993; Rhodes et al., 1994; McIntosh et al., 

2000; Buffington et al., 2002) which adversely affects all of the salmon and trout species 

inhabiting streams affected by the Project (Meehan, 1991; USFS et al., 1993, Rhodes et al., 

1994; USFS and USBLM, 1997a;b; Reeves et al., 1997). The persistence of the reduction in the 

quality, frequency, and volume of pools due to wood loss and elevated sediment delivery may be 

one of the reasons that coastal cutthroat trout do not rebound from watershed disturbance from 

timber harvest and related activities (Reeves et al., 1997). The loss of pool depth due to

elevated sediment delivery also contributes to the loss of thermal refugia for salmonids in deep 

pools (McCullough, 1999), although this impact is not assessed in the FEIS.

84. Field studies and laboratory experiments have consistently shown that elevated

sediment delivery increases fine sediment levels in stream substrate (Eaglin and Hubert, 1993; 

Rhodes et al., 1994; Buffington and Montgomery, 1999; Hassan and Church, 2000; Kappesser, 

2002; Cover et al., 2008). Increases in fine sediment in streams sharply reduce the survival and 
40 - Declaration of Jonathan J. Rhodes, Hydrologist

production of all salmon and trout species inhabiting streams affected by the Project (Meehan, 

1991; USFS et al., 1993; Rhodes et al., 1994; USFS and USBLM, 1997a). Suttle (2004) 

demonstrated that any incremental increase in fine sediment levels contribute to reduced 

production of steelhead.

85. Increased sediment delivery also contributes to increases in width/depth of 

streams (Richards, 1982; Rhodes et al., 1994). Such increases inexorably contribute to elevated 

summer water temperatures (Bartholow, 2000), although this impact on water temperatures is not 

examined in the FEIS. Due to the defects in the FEIS’s analysis of sediment delivery impacts 

and sediment-related conditions, together with effects of elevated sediment delivery on the 

production and survival of salmonids, the FEIS fails to reasonably assess and make known the 

cumulative impacts of the selected alternative on the salmonid populations affected by the 

Project. 

The FEIS fails to adequately assess and make known the cumulative effects of 

existing conditions together with the impacts of the selected alternative will have 

measurable, ecologically-significant, and persistent impacts on salmonid habitats 

and populations. 

86. The FEIS’s repeated assertions that the aquatic impacts caused by Project would 

not be measurable and persistent are without a sound basis. A sound determination of the 

measurability of impacts requires all of the three following steps: 1) Determine a scientificallysound threshold for the measurability and significance of the in-stream impact (such as fine 

sediment, pools, or LWD); 2) Develop a thorough and complete quantitative estimate of the instream impact; 3) Compare the sound estimate of the magnitude of the instream impact to the 

threshold of significance. Notably, the FEIS lacks all three of these steps with respect to the 

analysis of sediment, LWD, pool, peak flow, and water temperature impacts. 
41 - Declaration of Jonathan J. Rhodes, Hydrologist

87. The FEIS’s assertion of measurability conflicts with available scientific 

information, including that of the USFS. Studies have consistently documented measurable and 

persistent degradation of sediment-related stream conditions, including increased fine sediment 

(Eaglin and Hubert, 1993; USFS and USBLM, 1993; Rhodes et al., 1994; Espinosa et al., 1997; 

Huntington, 1998; Kappesser, 2002; Bryant et al., 2006; Cover et al., 2008) and the loss of pool 

depth, frequency, and volume (Lisle and Hilton, 1991; USFS et al., 1993; Rhodes et al., 1994; 

McIntosh et al., 2000) in response to elevated sediment delivery from the cumulative effects of 

roads, landings, and logging. While this scientific information is never examined or properly 

disclosed in the FEIS, it indicates that the action alternatives will persistently and measurably 

degrade sediment-related conditions in fish habitat, contrary to the cursory assessments in the 

FEIS.

88. Studies have repeatedly documented that logging and roads near streams elevate 

water temperatures in a measurable, persistent, and ecologically-significant manner, as the 

USFS’s own large-scale assessments have acknowledged and described (USFS et al., 1993; 

USFS and USBLM, 1997a), although this information is not examined or made known in the 

FEIS. Stream crossings and riparian roads have been shown to elevate water temperatures 

significantly (Nelitz et al., 2007). Although the FEIS does not examine or make this information 

known, together with information on the effects of activities on water temperatures (e.g., Rhodes 

et al., 2004; Beschta et al., 1987; McCullough et al., 1999; 2010) and the nature of the selected 

alternative’s riparian activities, this alternative will significantly elevate water temperatures in a 

persistent and ecologically significant manner. 

89. Losses of LWD due to riparian damage from roads are easy to estimate and 

measure. These losses are also extremely persistent (USFS et al., 1993; Rhodes et al., 1994; 
42 - Declaration of Jonathan J. Rhodes, Hydrologist

USFS and USBLM, 1997a); the loss of LWD recruitment from such damaged areas is 

irreversible. For these reasons, the nature of the selected alternative’s riparian activities will 

measurably reduce LWD levels in an enduring manner that will contribute to long-term 

reductions in salmonid production. 

The FEIS does not properly examine and make known that available scientific 

information indicates that increases in road density harms salmonid populations.

90. The USFS’s own assessments have repeatedly found that increases in road density 

lead to increased degradation of salmonid habitats and reductions in salmonid populations. The 

USFS’s own synthesis of road impacts (Gucinski et al., 2001) noted that there is robust largescale evidence that increasing road densities and their attendant effects are correlated with 

declines in the status of some salmonid species. USFS and USBLM (1997a) documented that 

increases in road density, even at low levels of road density, resulted in reductions in the strength 

of several populations of resident salmonids. USFS and USBLM (1997) noted that this 

relationship between road density and salmonid population status was “...consistent and 

unmistakable...”

91. USFS and USBLM (1997a) found that areas with estimated road densities of <0.1 

miles per square mile were most associated with areas of low levels of stream degradation, while

areas with estimated road densities of >0.7 miles per square mile were associated with high

levels of habitat degradation. Frequency of pools in lower-gradient streams, which are essential 

aspects of salmonid habitats, declined with increasing road density (USFS and USBLM, 1997a). 

92. Extensive habitat and salmonid population surveys done for the Clearwater 

National Forest, Idaho, found that with few exceptions, native salmonid abundance was higher

and fine sediment levels lower in unroaded versus managed landscapes (Huntington, 1998). 

These differences were largest and most consistent in the lower-gradient channel types, which 
43 - Declaration of Jonathan J. Rhodes, Hydrologist

are most sensitive to sediment-related road and logging impacts. Other information indicates that 

increases in stream crossings and riparian road density contribute to elevated water temperatures 

(Nelitz et al., 2007). In aggregate, this information, which is not made known in the FEIS, 

indicates that the significant increases road mileage in many subwatersheds under the selected 

alternative are likely to cause serious and persistent harm to affected salmonid populations. 

93. Importantly, the foregoing also indicates that notion that there is not significant 

harm from sediment-related impacts below a road density threshold of 2.5% of subwatershed 

area is not valid. Significant harm is likely to occur at far lower levels of road density. 

The FEIS did not analyze impacts at ecologically meaningful scales that are 

adequate for assessing impacts on streamflows, sediment delivery, and fish habitats. 

94. There are several reasons why the scale of subwatersheds used for analysis in 

the FEIS are inadequate to reasonably analyze and disclose impacts on peak flows, sediment 

delivery and their effects on important aquatic conditions. First, the subwatershed scales 

used in the FEIS are not based on any sort of stated ecological considerations. The FEIS’s 

subwatershed scales do not appear to correspond to fish production units, stream order, 

watershed field order,

12 or watershed size. For instance, at least one subwatershed described 

in the FEIS, North Big Salt Lake, occupies the entire watershed, so it is not really a 

“subwatershed.” The scales of subwatersheds assessed in the FEIS vary widely: the largest 

“subwatershed,” North Big Salt Lake, is more than 38 times larger than the smallest 

subwatershed analyzed. This vast difference in scales is problematic, especially because 

significant impacts that are manifest at smaller scales are obscured by analysis of conditions 

at larger scales. For instance, peak flows in smaller watersheds are more prone to elevation 

by logging and roads, as previously discussed. Studies have consistently demonstrated that 

 12 Subwatershed/watershed scales are commonly delineated in terms of field order on the basis of hydrologic unit 

codes.
44 - Declaration of Jonathan J. Rhodes, Hydrologist

logging activities elevate peak flows in smaller watersheds (MacDonald and Ritland, 1989; 

Drake et al., 2008). 

95. Second, smaller watersheds often have a greater percentage of their watershed 

area that has been logged and road. This higher percentage of watershed disturbance causes 

proportionately greater peak flow increases in these smaller watersheds. Due to the patchiness in 

the distribution of logged areas and roaded areas, analysis at larger scales does not capture the 

more intensive disturbance levels existing in smaller watershed systems that significantly elevate 

peak flows. As a team of USFS scientists noted in a review of proposed land management 

(Drake et al., 2008):

“Streams are most susceptible to change in peak flows at scales smaller than sixth-field 

subwatersheds (10,000-40,000 ac) (Grant et al. in press). Because headwater catchments 

(on the order of 25-250 ac) can experience peak flow changes due to management...it is 

feasible that individual logged catchments within a sixth-field watershed could have 

peak flow increases that are masked by uncut catchments sharing the same 6th field 

subwatershed.” 

The foregoing indicates that peak flow alteration analysis should be done at scales less than 

10,000 acres in order to reasonably assess the Project’s impacts on peak flows. Notably, six

of the 37 subwatersheds assessed in the FEIS have areas greater than 10,000 acres, including 

Big Ratz, Control Lake, Goose Creek, North Big Salt Lake, North Kasaan Bay Frontage, 

and Thorne Lake (FEIS, p. 3-262). Thus, the FEIS’s scale of analysis obscures, rather than 

discloses, the effects of logging on peak flows in headwater systems in smaller portions of 

large scale subwatersheds analyzed in the FEIS.
45 - Declaration of Jonathan J. Rhodes, Hydrologist

96. Due to the patchiness in the distribution of logging and roads, it is likely that 

significant sediment impacts at smaller scales is also obscured in the larger subwatersheds (e.g., 

>10,000 ac). This scale issue undermines the soundness of the analysis of the percentage of 

roads occupying subwatersheds in the FEIS. 

97. Third, increases in peak flows in smaller subwatersheds have significant impacts. 

Some channel types in headwaters are highly vulnerable to increased channel erosion caused by 

peak flow elevation (Rosgen, 1996). Once degraded, many headwater streams in have very poor 

prospects for recovery, even after the causes of degradation have been eliminated (Rosgen, 1996). 

Due to their position in the channel network, elevated erosion in headwater channels increases 

downstream sediment transport and sedimentation in downstream fish habitats (Montgomery and 

Buffington, 1998). 

98. For these reasons, the FEIS’s analysis of peak flows and percentage of area 

occupied by roads at the scale of quite large subwatersheds is inadequate for assessing and 

disclosing the impacts on peak flows and sediment delivery under existing conditions and the 

action alternatives. 

The FEIS fails to properly assess the limited effectiveness of the Project’s BMP and 

resulting negative impacts on aquatic systems under the selected alternative.

99. The FEIS compound the defects in the analysis of cumulative effects on aquatic 

resources by failing to reasonably disclose that Best Management Practices (BMPs) for roads

and landings, especially those constructed within a few hundred feet of streams, have very 

limited effectiveness. Although it is undisclosed in the FEIS, there are no reliable data indicating 

that BMPs consistently reduce the adverse effects of roads on aquatic resources to ecologically 

negligible levels, especially within the context of currently pervasive watershed and aquatic 
46 - Declaration of Jonathan J. Rhodes, Hydrologist

degradation (Ziemer and Lisle, 1993; Espinosa et al., 1997; USFS and USBLM, 1997; Beschta et 

al., 2004; GLEC, 2008). 

100. The nationwide assessment of BMP effectiveness commissioned by the USEPA 

(GLEC, 2008) specifically noted that BMPs aimed at reducing road impacts are not 100% 

effective, and, in particular, that efforts to prevent road drainage to streams have considerable 

potential for failure, especially in the Pacific Northwest. However, the FEIS does not provide 

any discussion of the known limited effectiveness of road BMPs. GLEC (2008) also notes that 

in the Pacific Northwest that “conventional BMPs for road construction may not be sufficient to 

prevent adverse effects on stream channels and fish habitat.” 

101. BMPs do not eliminate the adverse impacts of roads on sediment delivery. For 

instance, BMPs cannot eliminate sediment delivery from roads to streams at stream crossings 

(Kattlemann et al., 1996; Beschta et al., 2004; Rhodes and Baker, 2008). USFS and USBLM 

(1997b) noted that it is not possible to log areas without increasing erosion and sediment delivery

to streams, regardless of BMPs involved or care in implementation, especially when roads are 

involved. Based on review of available data, MacDonald and Ritland (1989) concluded that 

roads typically double suspended sediment yield even with state-of-the-art construction and 

erosion control and that suspended sediment contributions from surface erosion, alone, from 

roads in the absence of mass failure, are typically in the range of 5 to 20 percent above 

background and remain at elevated levels for as long as roads are in use. Notably, this would, in 

many cases, violate water quality standards for turbidity.

102. There are many impacts that conventional BMPs cannot do much to reduce or 

arrest, such as the severe adverse effects from high-intensity impacts (e.g. road construction) in 

sensitive areas, such as stream crossings. As GLEC (2008) noted with respect to road impacts, 
47 - Declaration of Jonathan J. Rhodes, Hydrologist

“in some cases, however, control of the problem may not be feasible: location ‘trumps’ 

management practice.” BMPs cannot obviate or significantly reduce the long-term loss of LWD 

recruitment to streams from roads and landings constructed near streams, which will occur under 

the selected alternative. Similarly, BMPs cannot eliminate or rapidly arrest increases in water 

temperature caused by the loss of shade and microclimatic functions in riparian areas affected by 

road and landings.

103. Activities implemented with somewhat effective BMPs still often contribute to 

negative cumulative effects on aquatic systems (Ziemer et al., 1991; Rhodes et al., 1994; 

Espinosa et al. 1997; Beschta et al., 2004; GLEC, 2008). Espinosa et al. (1997) documented that 

aquatic habitats were severely damaged by roads and logging in several watersheds despite BMP 

application. Espinosa et al. (1997) noted that blind reliance on BMPs in lieu of limiting or 

avoiding activities that cause aquatic damage serves to increase aquatic damage. 

104. Importantly, the selected alternative fails to include the most effective BMPs, 

which are:

• avoidance of implementing damaging logging, landing, and road activities in high 

hazard, sensitive, or degraded areas, such as stream crossings, riparian areas, and 

unstable terrain, such as earthflows (Rhodes, 1994; Kauffman et al., 1997; Beschta et 

al., 2004; Karr et al., 2004; GLEC, 2008);

• full protection of an adequate width of riparian areas on all streams to prevent or 

reduce the transmission of upslope impacts to streams (USFS, 1993; Rhodes et al., 

1994; Moyle et al., 1996; Erman et al., 1996; USFS and USBLM, 1997a; Beschta et 

al., 2004; Karr et al., 2004).
48 - Declaration of Jonathan J. Rhodes, Hydrologist

The avoidance of high impact activities in sensitive terrain has long been recognized as far more 

effective than attempting to reduce such impacts via BMPs, which have very limited 

effectiveness. Avoidance of sensitive areas is critical, due to the effects that impacts in such 

locations promulgate (USFS et al., 1993; Rhodes et al., 1994; Beschta et al., 2004; GLEC, 2008). 

105. It has long been recognized that full protection of the area of vegetation within 

200 to >300 ft of the edge of all stream types is one of the most important and effective ways to 

limit the impacts from upslope logging-related disturbances, as numerous independent 

assessments have repeatedly concluded, including, to but not limited to, USFS et al. (1993), 

Henjum et al. (1994), Rhodes et al. (1994), NRC (1996), Erman et al. (1996), Moyle et al., 1996; 

USFS and USBLM (1997a; b), Beschta et al. (2004), and Karr et al. (2004). However, despite 

this information, the selected alternative fails to incorporate these effective BMPs.

106. For these reasons, the FEIS fails to reasonably examine the Project’s likely 

cumulative impacts on aquatic systems, because the FEIS fails to reasonably assess the limited 

effectiveness of the Project’s BMPs. 

The FEIS does not identify several irretrievable and irreversible impacts of the 

selected alternative. 

107. The FEIS does not make known that the loss of topsoil exported to streams as a 

result of road and landing construction is both irretrievable and irreversible (Beschta et al., 

2004). In a similar vein, the FEIS fails to properly divulge that the loss of soil productivity on 

constructed landings is irreversible. 

108. The FEIS does not make known that the loss of key riparian functions, including 

LWD provision and moderation of water temperatures is an irreversible and irretrievable loss

from riparian areas subjected to landing and road construction. The FEIS also fails to make 
49 - Declaration of Jonathan J. Rhodes, Hydrologist

known that the loss of the production of salmonids due to the cumulative adverse impacts of the 

selected alternative on salmonid habitats is irretrievable.

Summary and Conclusions

109. The FEIS did not properly assess peak flow and sediment impacts because it 

failed to properly assess the connectivity of streams and roads. It also failed to assess these 

impacts due to improper analytical scales. 

110. The FEIS did not properly assess water temperature and LWD impacts because it 

failed to properly assess duration and magnitude of the impacts of past logging, existing and past 

landings and roads in riparian areas on water temperatures and LWD levels. The lack of 

information on existing instream LWD and water temperature conditions also precludes 

reasonable assessment of the Project’s cumulative impact on LWD and water temperature.

111. Due to the importance of LWD, sediment-related conditions, and water 

temperature to the survival and production of salmonids, the FEIS did not reasonably assess and 

make known the cumulative effects of the action alternatives on salmonid survival and 

production.

112. The FEIS failed to incorporate and make known a wide variety of scientific 

information which indicates that existing conditions together with the cumulative impacts of the 

selected alternative will cumulatively contribute to long-term aquatic degradation and losses in 

the survival and production of salmonid species inhabiting affected streams within the Project 

area.

113. The FEIS does not adequately divulge that the selected alternative will result in 

several types of irreversible and/or irretrievable commitments of important resources, including 
50 - Declaration of Jonathan J. Rhodes, Hydrologist

losses of: salmonid habitat quality, salmonid production, topsoil, LWD, and riparian 

functionality. 

I declare under penalty of perjury that the foregoing is true and correct to the best of my 

knowledge.

Executed this 12th day of August 2013 in Portland, Oregon.

____________________________

JONATHAN J. RHODES

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UNITED STATES OF AMERICA

DEPARTMENT OF AGRICULTURE

UNITED STATES FOREST SERVICE

Before the Chief

USDA Forest Service

In re Appeal of the Big Thorne Project

Final Environmental Impact Statement and

Record of Decision.

GREATER SOUTHEAST ALASKA

CONSERVATION COMMUNITY,

Appellant.

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Appeal No. ___________

DECLARATION OF JOSEPH R. MEHRKENS

I, Joseph R. Mehrkens, declare as follows:

1. I am a retired resource economist residing at 15450 Glacier Highway, Juneau, 

Alaska 99801. I periodically consult on natural resource issues in Alaska.

2. I received a B.S. in Forestry from the University of Minnesota in 1970 and a 

Masters of Science in Forest Economics from Michigan State University in 1975. 
2

3. Since 1979 I have worked as an economist for the Forest Service, The Wilderness 

Society, the Alaska Department of Commerce and Economic Development, and Environmental 

Economics – Alaska (my former consulting business).

4. From 1979 to 1987 I was the Regional Economist for the USDA-Forest Service, 

Alaska Region. My duties included economic assessments of the Tongass NF timber program –

including the timber trade between Alaska and the Pacific Rim countries. I also prepared 

congressional reports on the annual supply and demand for Southeast Alaska timber.

5. From 1987 to 1991 I worked for The Wilderness Society as an economist and 

lobbyist to help gain passage of the Tongass Timber Reform Act of 1990. I testified before 

various congressional committees on the economic tradeoffs of the Tongass NF timber program 

– including taxpayer subsidies. I also analyzed the annual President’s budget for the Tongass NF 

and made recommendations for change to the House and Senate Appropriations committees.

6. From 1991 to 2000 I was a part-time consultant on various projects including an 

expert witness on the Alaska Pulp of America consolidated income statements. During this time 

I also commercial fished and worked full time for the Alaska Department of Law (1995-1998).

7. From 2000 to 2004, I worked for the Alaska Department of Commerce, 

Community and Economic Development. I developed the framework for the Alaska Economic 

Information System – a web based system to access federal, state and local economic data. I also 

reinitiated the Alaska Annual Economic Performance Report.

8. I worked as a part-time consultant from 2004 until I retired in May 2008. My

work included the determination of public subsidies for the Tongass NF timber program. The 

subsidy work was initially completed under two contracts to the Southeast Alaska Conservation 

Council (SEACC), but the final products were also shared with the Natural Resources Defense 

Council, The Wilderness Society, EarthJustice and other environmental organizations.
3

9. I have maintained a series of Excel spreadsheets and charts since 1987 and have 

included various versions and updates of these spreadsheets for clients such as SEACC. Under 

two contracts with SEACC in 2004 and 2007, I provided an up-to-date analysis of the cost of the 

Tongass Timber Program in terms of timber sale planning, preparation, administration and road 

construction, including the cost of purchaser road credits and purchaser-elect roads. 

10. Prior to my contractual work, SEACC published a report titled, “Taxpayer Losses 

and Missed Opportunities.” The report documented the public subsidies from 1998 to 2002 in 

terms of total dollars lost and the cost per Tongass timber dependent job. The SEACC report 

evolved from a Freedom of Information Act (FOIA) request prepared by another former Alaska 

Regional Economist, Dr. Guy Robertson. Dr. Robertson provided Forest Service information on 

timber receipts and expenditures, including the costs of road building. The SEACC report 

simply subtracted timber and road expenditures from timber revenues to calculate the net dollar 

loss to taxpayers. The SEACC loss calculations excluded road maintenance costs, and the 

estimated loss per timber job for 2002 was based on partial information – only two quarters of 

employment data.

11. My first contract in 2004 was designed to revise the 2002 information concerning 

timber employment and update the subsidy information for FY2003 and FY2004. My update 

followed the same approach as economist Robertson and SEACC. In addition, I included the 

prior analyses of two General Accounting Office reports released in 1989 and 1997, and the 

work of forest economist Randle O’Toole, “$64 million Dollar Question: How the Taxpayers

Paid the Pulp Mills to Clearcut the Tongass National Forest” ( Table 17, page 28) (1993). This 

supplemental information gave me consistent expenditure and revenue data from 1982 to 2002. 

12. Subsequent FOIA requests were made by SEACC to gain the same type of 

information as provided by Dr. Robertson for my analyses for FY 2003 and FY2004. Line item 
4

expenditures for the timber and road programs were taken from Forest Service budget and 

accounting documents. These expenditures were subtracted from timber receipts that are 

regularly published on the Forest Service web site. This yielded the public subsidy or net loss in 

total dollars. Tongass timber dependent employment numbers for 2002, 2003 and 2004 were 

taken from two draft Forest Service reports: the ANILCA Section 706(a) timber supply and 

demand report for fiscal years 2001 & 2002, and the same report for fiscal years 2001-2005. 

Based on my past experience, the employment numbers in these reports were reasonable and 

accurate. 

13. Using the total dollar loss and the Forest Service job employment numbers, I 

estimated net loss per Tongass timber dependent job for fiscal years 2003 and 2004, by following 

the same methodology/conventions from 1998 to 2002. Simply, the net loss in total dollars is 

divided by the Tongass timber dependent job numbers reported by the Forest Service. The only 

exception is that I used road maintenance costs in my estimates. I also corrected the FY2002 net 

loss per job calculated by SEACC by using the more complete Forest Service employment 

information – an entire year versus just two quarters. 

14. The subsidy analysis under my second contract with SEACC in 2007 was similar. 

A SEACC FOIA provided the same type of information on timber and roads expenditures for 

FY2005, FY2006 and FY2007. Again timber receipts were taken from the Forest Service web 

site. Tongass timber dependent employment was taken from another Forest Service draft Section 

706(a) report for 2006. The subsidy in total dollars lost and the net losses per job for FY2005 

and 2006 were calculated as before. 

15. The estimated subsidy for FY2007 and FY2008 had to go a couple of steps 

further. While the expenditures for 2007 were actual expenditures, the FY2008 program costs 

were the approved budget authorities for the timber and road programs, i.e., the maximum 
5

amount that can be expended. Simply stated, actual expenditures for FY2008 were not yet 

available. Also, the Tongass timber dependent job numbers for FY2007 and FY2008 were my 

independent estimates and are based on reduced logging in 2007 and the recent closure of the 

Ketchikan veneer mill in 2008. Nonetheless, my methodology was similar to the Forest Service 

methodology in the agency’s 706(a) reports and similar to what I used as Regional Economist in 

the mid-1980s. The employment estimates made by the Forest Service and me very closely 

tracked similar information reported by the Alaska Department of Labor and Work Force 

Development (ADOLWD). I have used to ADOLWD information to validate my employment 

estimates as well as the Forest Service estimates.

16. To make the dollar losses consistent over time, I had to fill in missing information 

about overhead costs in support of the timber and road programs. The overheads costs are 

expenditures for shared utilities, equipment, facilities, accounting, procurement, personnel,

supervision, etc. The overhead costs (now known as cost pools) were once an explicit line item

in the budgeting and accounting documents – that is until FY2004. From FY2004 to FY 2007 

the timber and roads construction cost pools were lumped together with all other programs,

making a timber and roads estimate more difficult. However, the FOIA information for FY2004 

did reveal the cost pool allocations for the roads program in the budget documents. 

Consequently, I used this explicit budget information to estimate the total road expenditures

(including overheads) for 2004. However, I could not do the same for the timber program. For 

the timber program I had to use an independent estimate for the overhead costs. This estimate 

was based on the ratio of actual overhead costs to direct timber program costs during FY2002 

and FY2003. This ratio ranged from 49% to 51% and I used the lower percentage to be 

conservative. It turns out this percentage is pretty consistent over time.
6

17. Again, for FY2006 and FY2007 there was no explicit information on overhead 

costs. However, the FOIA information for this period revealed the Regional Office and Tongass 

NF assessments for the cost pools (overheads) as a percentage of direct program costs. The

percentage applied to all resource programs – timber and non-timber alike. I assumed these

percentages have been applied to timber and road programs and they were the basis for the 

overhead costs for my FY2006 and FY2007 analysis. I also used these percentages to revise the 

FY2005 timber overheads since it is based on real information and not an assumption about 

historic rates. 

18. I used this information to produce Exhibit A to my declaration attached as Exhibit 

D to The Wilderness Society’s administrative appeal of the Record of Decision and Final 

Environmental Impact Statement for the 2008 Amendment to the Tongass Land Management 

Plan (appeal number 08-13-00-0028). Exhibit A was based entirely on publically available 

information, including numerous Forest Service documents that are available as hard copy or 

online documents. All information sources were documented in the spreadsheet, which was part 

of an Excel Workbook file I created entitled, “Final Tongass Budget Analysis 91-07.” The 

FOIA documents are available in hard copy from the Forest Service or SEACC. In my opinion, 

Exhibit A presented an accurate picture of Tongass costs, revenues, and jobs through 2007, and

represents the best data available.

19. After I retired in 2008 I continued to be involved in issues related to timber 

economics. In 2011 I helped to incorporate an Alaska non-profit corporation, the Greater 

Southeast Alaska Conservation Community (GSACC) and conduct extensive research work as a 

board member and volunteer on behalf of GSACC.

20. On June 11, 2012, I submitted a FOIA request on behalf of GSACC and requested 

information for fiscal years 2008, 2009, 2010 and 2011 showing expenditures and activity 
7

outputs for timber-program related budget codes and work plan documents. I also requested 

final fiscal year 2012 budget advice for the Alaska Region for timber-program related budget 

codes. The requested information was similar to the information requested on behalf of SEACC 

in 2007 and 2008.

21. After reviewing the information provided pursuant to the FOIA request, I updated 

the Excel Workbook file I created for the 2008 TLMP Amendment Appeal, “Final Tongass 

Budget Analysis 91-07” to include budget information for fiscal years 2008 – 2012. GSACC 

submitted the updated Excel Workbook file, now entitled “GSACC-EEA Tongass Budget 

Analysis 91-12” as Exhibit 202b to its comments on the Big Thorne Project Draft Environmental 

Impact Statement.

22. My methodology for calculating timber program costs for Exhibit 202b was 

similar to the methodology described in paragraphs 13 – 17. I updated the 2008 program costs 

which were previously based on approved budget authorities with costs based on actual 

expenditures provided in the 2011 FOIA request. As explained in paragraph 15, the cost figures 

for fiscal year 2012 are based on approved budget authorities rather than actual expenditures 

because the expenditure information was not yet available. All other program costs displayed in 

the spreadsheets reflect actual expenditures.

23. I again added missing information about overhead costs in support of the timber 

and road programs. From FY2010 to FY2012 overhead costs are based on constant percentages 

applied to timber and road related costs but with different percentages applied to the Regional 

Office (39%) and the Tongass National Forests (31%). These percentages were derived from 

separate analyses of past actual cost pool expenditures for all programs reported by the Forest 

Service each fiscal years from 2006 to 2012.
8

24. On September 25, 2012, I submitted an additional FOIA request seeking reports 

related to the administrative costs of NEPA preparation, sale preparation, sale administration and 

engineering support and any other documents or reports regarding average administrative cost 

reports, budget monitoring and cost monitoring. The materials provided by the Forest Service 

did not include any budget preparation documents or reviews that support the agency’s 

administrative cost estimates for the Tongass timber sale program.

25. On January 15, 2013, I submitted a FOIA request on behalf of GSACC and 

requested information for fiscal years 2012 and 2013. For FY 2012 I requested actual 

expenditure information for timber-and road construction budget codes. For FY2013 I requested 

the final budget allocations for Alaska Region for the same budget codes as is FY2012. Again, 

the final budget advice is used as a proxy for actual expenditures until the actual expenditure 

information for FY2013 is finalized and publically available.

26. Using the information described in paragraph 25 I once again updated the series 

of Excel spreadsheets described in paragraph 9 and replaced the final budget advice for FY2012 

with actual timber related expenditures for FY2012. My methodology for calculating timber 

program costs was consistent with to the methodology used in prior updates as described in 

paragraphs 13 – 17. This most recent Excel spreadsheet update is the basis for specific findings 

about the economic and financial analysis found in the Big Thorne Project (BTP) planning 

record. 

27. More specifically I have reviewed the updated analysis of timber sale program 

costs based on a “snapshot” review of fiscal years 2010, 2011 and 2012. The one page document 

does not provide any underlying data to support the cost assumptions, and omits substantial 

timber program costs, including, but not limited to overhead costs, transportation system costs, 
9

post-project habitat treatment costs and numerous other public expenditures that would not be 

incurred but for the Tongass timber sale program. 

28. The single most important failing of the BTP economic analysis is the lack 

credible information on the total costs to conduct the Tongass timber sale program. The total 

unit cost to produce a thousand board feet of timber averaged $1,335/mbf from FY2010 to FY 

2012 (the base period used in the BTP financial analysis).

29. In comparison, the total unit costs of $1,335/mbf is 13 times greater than the 

purported agency unit costs of $101/mbf for the BTP economic/financial analysis (which has 

been recently amended to $103/mbf).

30. The much higher total unit cost of $1,335/mbf is based on actual U.S. Forest 

Service expenditures rather than agency estimates to prepare future Tongass budget requests. 

The latter is supposedly the basis for the unit costs of $101/$103/mbf used in the BTP financial 

analysis. Again, the lower unit costs are not explicitly documented

31. In contrast, the $1,335/mbf is explicitly documented and is calculated from 

readily available agency information. The $1,335/mbf includes costs for timber management 

and logging roads and includes estimated overhead costs. It is also based on actual Tongass 

timber consumption.

32. With the exception of engineering support (the design and location of logging 

roads), the Forest Service also routinely ignores the total costs of road construction, 

reconstruction and maintenance in the BTP economic analysis. Logging road related costs are 

substantial and create a financial liability that stems both past and new timber sales.

33. While there are many differing and valid arguments on how to account for road 

costs, the simple fact is if you ignore all Tongass road construction, reconstruction and 

maintenance cost over the period FY2010 to 2012, the average total unit cost is still $938/mbf 
10

for Tongass timber — again about 9.5 times greater the purported agency costs of $101-103/mbf 

and used in the BTP economic/financial analysis.

34. While it is uncertain to the public just how the $101/$103/mbf unit costs are 

derived, it is very certain that they are inconsistent with real data reported by the Forest Service 

in the past. Forest Supervisor Cole explained in a 2004 deposition that the unit costs were 

$101/mbf and pretty constant. The BTP planning record states the $101/mbf is derived from 

information used to build annual budget requests. 

35. In any case, Supervisor Cole’s unit cost have not changed over a long period of 

time and the BTP planning records simply reiterated the same unit costs as $29/mbf for timber 

preparation, $9/mbf for timber sale administration and $28/mbf for engineering support. In 2012

these values have been revised slightly upwards by Robert Vermillion to $20.78/mbf for timber 

preparation, $12.28/mbf for timber sale administration and $22.67/mbf for engineering support.

36. The first issue is how either set of unit costs (Cole or Vermillion) can remain so 

static after years of inflation – albeit relatively low inflation. 

37. Past unit costs are indeed available from budget documents covering FY1981 to 

FY1990 (the last time period that unit costs were reported in public budget documents). Simply 

inflating the historic past unit costs to reflect 2012 dollars indicates that BTP unit costs are 

substantially underestimated.

38. Comparing Vermillion’s revised unit costs to the inflated historic unit costs shows

$20.78/mbf versus $38.41/mbf for timber preparation, $12.28mbf versus $25.89/mbf for timber 

administration and $22.87/mbf versus $60.87/mbf for engineering support.

39. While the forestry and engineering technology has no doubt improved over time 

there is nothing to suggest improved efficiencies of 46%-63% -- the gains needed to account for 

the lower unit costs used in the BTP financial analysis. Moreover, if such technological 
11

efficiencies are indeed real they have not been carried over into recent annual Tongass budget 

requests from Congress. Simply stated, total program budget requests remain high. Actual 

program expenditures are the best and most informative measures for disclosing economic 

impacts.

40. In the BTP, the Forest Service ignores overhead costs which are a substantial

component in day to day operations. Two past GAO audits of the timber program included 

overhead costs (now called cost pools). To be consistent with the GAO methodology my 

subsequent spreadsheet analyses have always included estimates of overhead costs.

41. Again, using the budget data from 1981-1990, the proportion of overhead costs 

for timber preparation, timber administration and engineering support ranged from 16% to 63%. 

More recently, from FY2010 to 2012 the estimated overhead costs are 39% for the Regional 

Office related expenditures and 31% for Tongass National Forest expenditures. These overhead 

percentages were applied to Timber Management (NFTM budget line item) and the Construction 

Maintenance Roads (CMRD budget line item). In any case, overhead costs have always been a 

substantial cost of doing the business in the offering and selling of Tongass timber.

42. To ignore overheads in the BTP financial analysis is like rationalizing the cost of 

home ownership to only the costs for heat, utilities and maintenance, while ignoring major cost 

components such as the mortgage, insurance and taxes.

43. Timber related employment is overestimated in the BTP economic analysis. 

While the Forest Service correctly estimates the direct timber industry jobs, they inappropriately 

then add estimates for indirect and induced jobs.

44. Conventional economic impact assessments recognize the relationship between 

direct jobs and the additional indirect and induced jobs supported by the existence of the direct 

jobs in a local economy. Indirect jobs are from local firms that are not part of the sawmill 
12

industry but who supply the mills with goods and services used by mill operators, e.g., a fuel oil 

delivery jobs. Induced jobs are the jobs created to support direct and indirect jobs, such as 

school teachers, retailers and local government employees. However, the relationships between 

direct, indirect and induced jobs have been found to be invalid by Forest Service economists Dr. 

Guy Robertson and Dr. Lisa Crone – especially for small communities similar to those affected 

by BTP.

45. While the findings by Robertson and Crone are cited in the BTP planning records,

their cautions and recommendations are ignored. Thus, for the BTP, the Forest Service is using a 

sawmilling multiplier of 2.68 jobs/mmbf/sawn composed of 1.68 direct jobs and 1.0 jobs for 

indirect and induced – a 60% overestimation.

46. Estimating Tongass timber dependent employment has become increasingly 

difficult because of structural changes in the Southeast timber industry and changes in federal 

timber export policies.

47. The decline of the timber industry is now sufficient to withhold employment 

information that was previously available from traditional sources such as the Alaska 

Department of Labor and Workforce Development. This is due to disclosure policies which are 

designed to prevent the identification of an individual firm’s employment and payroll 

information.

48. Good regional information is still publically available for direct Southeast logging 

and sawmilling for the years prior to 2011. However, starting in 2011 region-wide logging jobs 

are combined with sawmilling and mining in order to not violate disclosure policies. However, I 

was able to get timber industry employment information for logging and sawmills combined for 

FY2011 via a special request to the Alaska Department of Labor and Workforce Development.
13

49. Using Alaska Department of Labor and Workforce Development employment 

information for years 1991-2001, I have been able to validate the employment data collected by 

the Forest Service in their periodic sawmill surveys and the implied multipliers for sawmill 

production.

50. To the agency’s credit, starting in 2002 the Forest Service had to adjust their 

employment estimates by taking into account the amount of timber supplied to sawmills from 

sources other than the Tongass NF.

51. As cited in the BTP planning record, prior to 2002 nearly all the saw timber was 

supplied from the Tongass National Forest, but during 2002-2012 the Tongass share ranged from 

59% to 87%.

52. Now, timber sale operators can elect to export up to 50% of the saw-log volume 

in a timber sale as round logs. These exports were originally required to undergo primary 

processing in Alaska mills and supported local sawmill jobs.

53. To obtain better sawmill employment information and to compensate for the 

factors described in paragraphs 49, 51 and 52, the Forest Service conducts periodic mill surveys.

More specifically, these surveys monitor saw-log consumption, export volumes and employment 

information. 

54. Using the Forest Service sawmill surveys, an implied the number for direct jobs in 

sawmills averaged 1.68 jobs/mmbf of timber sawn from all sources from 2002 to 2010 (BTP 

planning record). This multiplier is very consistent with previous multipliers derived from past 

Forest Service and ADOLWD information. In contrast, a higher 2.68 jobs/mmbf multiplier is 

used in the BTP economic analysis and overestimates supported employment by 60%. The 

overestimate is because it supposedly includes indirect and induced jobs, which again is contrary 

to the findings of their own agency economists.
14

55. Likewise, the Forest Service is erroneously using a logging multiplier of 2.26 

jobs/mmbf in the BTP analysis. A multiplier without the indirect/induced jobs components

should be about 1.80 logging jobs/mmbf. The lower multiplier is also consistent with previous 

multipliers derived from past Forest Service and ADOLWD information prior to 2012. 

56. Other anecdotal evidence supports the exclusion of the indirect and induced jobs 

from the BTP analyses. The timber industry has repeatedly claimed that the prolonged industry 

contraction has resulted in the loss of more and more local vendors that once catered to the 

timber industry and the closure of rural schools, i.e., the indirect and induced jobs.

57. The whole premise for additional timber sales like the BTP is based on flawed 

methodologies which forecast how much Tongass timber sawmills will need, the volume of new 

timber sales to prepare for sale and the longer term future demand for Tongass timber.

58. The first wrong-headed methodology is commonly known as the Morse 

methodology and is named after former Forest Service economist. It has been used since 2000 

and has consistently overestimated the need for additional Tongass timber sales as well as the 

amount of Tongass timber the industry is willing to buy.

59. The fundamental flaw in the Morse methodology is demonstrated by the trends in 

actual Tongass timber purchases and the utilization rates of mills sawing Tongass timber.

60. There has been a huge disparity (called a fall-down), between Tongass timber 

offered and the amount actually sold. This disparity is part due to the Morse methodology. 

From 1997 to 2007, 948 mmbf of timber was offered for sale. Of this amount nearly 45% of this 

timber volume did not receive a single bid from the industry. Moreover, 23% of the timber sold 

ended up in cancelled sales.
15

61. The fall-down between volume offered and sold has abated somewhat since 2007 

but is primarily due to the chronic low level of mill activity and not any new policies to better 

bring timber offers like BTP more in line with actual demand.

62. In fact, the Forest Service now wants to offer and sell 600 mmbf in timber sales 

over the next few years. In stark contrast, the Forest Service sawmill surveys show a persistent 

long term decline in installed and operable mill capacity and very low utilization rates

63. Installed and operable mill capacity has decreased from 453 mmbf in 2002 to 155 

mmbf in 2010. If the Forest Service succeeds in selling the 600 mmbf of timber over the next 

few years, the backlog uncut timber under contract will be near or exceed a four year timber 

supply. Such a backlog will even exceed the industry norms for big timber operations in the 

Pacific Northwest. This backlog will certainly exceed the historic norms for Tongass timber 

industry.

64. Also important is the utilization rate for Southeast Alaska mills in terms of 

installed capacity. Since 2002 this rate has been less than 11 percent This is further evidence 

that BTP contribution of 131-148 mmbf towards the Forest Service goal of 600 mmbf of 

Tongass timber sold over the next few years is excessive and well beyond the industry needs.

65. Periodically the Morse methodology is reinforced by longer-term timber demand 

projections by Forest Service Research. Five separate Tongass timber demand projections have 

been conducted covering various periods covering 1980 to 2025. Similar to the Morse 

Methodology, each of these five demand projections has resulted in unrealistic future timber 

demands. More importantly, each projection failed to materialize and is totally inconsistent with 

actual Tongass timber demands.

66. In each of the five timber demand projections, the Forest Service simply assumed

that Tongass timber producers will remain competitive and maintain historic market shares.