Forest Service Alaska Region R10-MB-867b September 2020 
Rulemaking for Alaska Roadless Areas

Final Environmental Impact Statement

September 2020

Lead Agency: USDA Forest Service

Cooperating Agencies: Angoon Community Association; Central Council Tlingit and Haida Indian 

Tribes of Alaska; Hoonah Indian Association; Hydaburg Cooperative 

Association; Organized Village of Kasaan; and State of Alaska.

Responsible Official: Sonny Perdue

U.S. Secretary of Agriculture

For Further Information: Visit the Forest Web site at: 

https://www.fs.usda.gov/project/?project=54511

or Contact:

Ken Tu

Alaska Roadless Interdisciplinary Team Lead

Abstract

Following receipt of a petition from the State of Alaska, submitted pursuant to the Administrative 

Procedure Act, the Secretary of Agriculture directed the Forest Service to develop an Alaska-specific 

roadless rule in June 2018.The proposed state-specific roadless rule would replace the 2001 Roadless 

Rule and, along with existing statutory and land management plan direction, guide roadless area 

management on the Tongass National Forest.

This Final Environmental Impact Statement (FEIS) responds to the Secretary’s direction by analyzing six 

alternatives including the No Action Alternative. Three key issues are identified: 1) conservation of roadless 

area characteristics; 2) support of local and regional socioeconomic well-being including community 

stability, Alaska Native culture, rural subsistence activities, and economic opportunity across multiple 

economic sectors; and 3) conservation of terrestrial habitat, aquatic habitat, and biological diversity. The 

six alternatives provide a range of options for addressing the key issues. Five Alaska Roadless Area

management categories were developed that prohibit timber harvest, road construction, and road 

reconstruction with a range of exceptions, and are applied differentially across four of the alternatives. 

Other than expanding the suitable timber land base, none of the action alternatives propose to change the 

Tongass Land and Resource Management Plan, including the projected harvest level. Direct, indirect, and 

cumulative effects of the alternatives are compared and disclosed in Chapters 2 and 3.

The Secretary for the U.S. Department of Agriculture has identified Alternative 6 as the preferred 

alternative. 
The U.S. Department of Agriculture (USDA) prohibits discrimination in all its programs and activities on the 

basis of race, color, national origin, sex, religion, age, disability, sexual orientation, marital status, family 

status, status as a parent (in education and training programs and activities), because all or part of an 

individual’s income is derived from any public assistance program, or retaliation. (Not all prohibited bases 

apply to all programs or activities.) If you require this information in alternative format (Braille, large print, 

audiotape, etc.), contact the USDA’s TARGET Center at (202) 720-2600 (Voice or TDD). 

If you require information about this program, activity, or facility in a language other than English, contact 

the agency office responsible for the program or activity, or any USDA office. 

To file a complaint alleging discrimination, write USDA, Director, Office of Civil Rights, 1400 Independence 

Avenue, S.W., Washington, D.C. 20250-9410, or call toll free, (866) 632-9992 (Voice). TDD users can 

contact USDA through local relay or the Federal relay at (800) 877-8339 (TDD) or (800) 845-6136 (in 

Spanish). USDA is an equal opportunity provider, employer, and lender.

Federal Recycling Program

Printed on Recycled Paper
Contents

Final EIS iii Contents

CONTENTS

CHAPTER 1 PURPOSE OF AND NEED FOR ACTION........................................................................1-1

Background ...........................................................................................................................1-1

Analysis Area ........................................................................................................................1-3

Purpose and Need ................................................................................................................1-5

Proposed Action ....................................................................................................................1-5

Decision Framework..............................................................................................................1-5

Public Participation................................................................................................................1-5

Tribal and Native Corporation Participation ..................................................................1-6

Cooperating Agencies...................................................................................................1-6

Changes between the DEIS and FEIS..................................................................................1-7

Key Issues.............................................................................................................................1-8

Key Issue 1 – Roadless Area Conservation .................................................................1-9

Key Issue 2 – Support local and regional socioeconomic well-being, Alaska Native 

culture, rural subsistence activities, and economic opportunity across multiple economic 

sectors...........................................................................................................................1-9

Key Issue 3 – Conserve terrestrial habitat, aquatic habitat, and biological diversity ..1-10

Issues Eliminated from Detailed Analysis ...........................................................................1-11

Geology and Geologic Features .................................................................................1-11

Soil Characteristics and Composition .........................................................................1-11

Water Quantity and Quality .........................................................................................1-12

Air Quality....................................................................................................................1-12

General Vegetation .....................................................................................................1-12

General Wildlife Species/Habitat ................................................................................1-12

General Aquatics Species/Habitat ..............................................................................1-12

Essential Fish Habitat .................................................................................................1-13

Invasive Aquatic Species ............................................................................................1-13

Wetlands .....................................................................................................................1-13

Floodplains..................................................................................................................1-13

National Historic Preservation Act ..............................................................................1-14

Specific Location Impacts ...........................................................................................1-14

Changes in Timber Markets........................................................................................1-14

Tongass Timber Reform Act .......................................................................................1-14

Below-cost Timber Sales ............................................................................................1-14

Changes to the General Mining Act of 1872...............................................................1-15

Irreversible or Irretrievable Commitment of Resources ..............................................1-15

Incorporation by Reference.................................................................................................1-15

Scope and Applicability .......................................................................................................1-15

Scope of the FEIS.......................................................................................................1-15

Applicability .................................................................................................................1-16

CHAPTER 2 ALTERNATIVES INCLUDING THE PROPOSED ACTION .............................................2-1

Features Common to Multiple Alternatives ...........................................................................2-1

Tongass Land and Resource Management Plan .........................................................2-1

Timber Suitability...........................................................................................................2-2

Project-Specific Activities ..............................................................................................2-2

Ongoing Projects...........................................................................................................2-2

Existing Land Use Authorizations .................................................................................2-2

Proposed Definitions .....................................................................................................2-2

Proposed Alaska Roadless Boundary Correction and Modification Provisions............2-3

Alaska Roadless Area Land Management Designations..............................................2-4

Alternatives Considered in Detail ..........................................................................................2-9

Alternative 1 – No Action...............................................................................................2-9

Alternative 2 ................................................................................................................2-11
Contents

Final EIS iv Contents

Alternative 3 ................................................................................................................2-12

Alternative 4 ................................................................................................................2-14

Alternative 5 ................................................................................................................2-15

Alternative 6 (Preferred Alternative)............................................................................2-16

Maps............................................................................................................................2-17

Alternatives Considered but Eliminated from Detailed Analysis .........................................2-17

Comparison of the Alternatives ...........................................................................................2-17

Key Issue 1 – Roadless area conservation.................................................................2-18

Key Issue 2 – Support local and regional socioeconomic well-being, Alaska Native 

culture, rural subsistence activities, and economic opportunity across multiple economic 

sectors.........................................................................................................................2-20

Forest Products Industry ......................................................................................2-20

Recreation and Tourism .......................................................................................2-21

Commercial Salmon Harvesting and Processing.................................................2-21

Mining and Mineral Development.........................................................................2-21

Infrastructure Development ..................................................................................2-22

Tree Harvest for Alaska Native Cultural Purposes...............................................2-22

Rural Subsistence Activities .................................................................................2-22

Community Effects................................................................................................2-23

Key Issue 3 – Conserve terrestrial habitat, aquatic habitat, and biological diversity ..2-23

Old-Growth Habitat...............................................................................................2-23

Young Growth in Special Habitats........................................................................2-24

Road Density ........................................................................................................2-24

Fish Habitat...........................................................................................................2-24

Species-Specific Effects .......................................................................................2-24

CHAPTER 3 ENVIRONMENT AND EFFECTS......................................................................................3-1

Introduction............................................................................................................................3-1

Analyzing Effects...........................................................................................................3-1

Cumulative Effects..................................................................................................3-2

Geographic Information System Database and Quantification for this EIS ...........3-3

Current Forest Plan (2016 Amendment) ................................................................3-3

Suitable Timber Land Assumptions........................................................................3-4

Assumptions for Future Harvest.............................................................................3-4

Assumptions for Future Road Construction and Reconstruction ...........................3-5

Land Use Designation Groupings .................................................................................3-6

Land Divisions ........................................................................................................3-6

Maps..............................................................................................................................3-8

Organization of Chapter 3.............................................................................................3-8

Key Issue 1 – Roadless Area Conservation..........................................................................3-9

Affected Environment....................................................................................................3-9

Roadless Area Characteristics ...............................................................................3-9

Environmental Consequences ....................................................................................3-13

Comparison of Effects on Roadless Characteristics by Alternative .....................3-13

Ecosystem Services .............................................................................................3-26

Cumulative Effects................................................................................................3-27

Key Issue 2 – Support Local and Regional Socioeconomic Well-being, Alaska Native 

Culture, Rural Subsistence Activities, and Economic Opportunity Across Multiple Economic 

Sectors ................................................................................................................................3-29

Affected Environment..................................................................................................3-29

Regional Demographic Overview.........................................................................3-29

Regional Economic Overview...............................................................................3-31
Contents

Final EIS v Contents

Natural Resource-Based Industries......................................................................3-32

Nonresident and Seasonal Employment ..............................................................3-33

Subsistence Economy ..........................................................................................3-33

Industry-Specific Descriptions ..............................................................................3-34

Payments to the State ..........................................................................................3-49

Environmental Consequences ....................................................................................3-50

Forest Products ....................................................................................................3-50

Recreation and Tourism (Visitor Industry)............................................................3-56

Salmon Harvesting and Processing .....................................................................3-57

Mining and Mineral Development.........................................................................3-57

Infrastructure Development ..................................................................................3-58

Tree Harvest for Alaska Native Cultural Purposes...............................................3-58

Rural Subsistence Activities .................................................................................3-60

Payments to the State ..........................................................................................3-60

Key Issue 3 – Conserve Terrestrial Habitat, Aquatic Habitat, and Biological Diversity ......3-61

Biological Diversity ......................................................................................................3-61

Affected Environment ...........................................................................................3-61

Environmental Consequences..............................................................................3-73

Wildlife.........................................................................................................................3-89

Affected Environment ...........................................................................................3-89

Environmental Consequences............................................................................3-109

Fish............................................................................................................................3-129

Affected Environment .........................................................................................3-129

Environmental Consequences............................................................................3-134

Other Important Issues......................................................................................................3-143

Climate and Carbon ..................................................................................................3-143

Affected Environment .........................................................................................3-143

Environmental Consequences............................................................................3-148

Karst Lands ...............................................................................................................3-151

Affected Environment .........................................................................................3-151

Environmental Consequences............................................................................3-152

Sensitive and Invasive Plants ...................................................................................3-155

Affected Environment .........................................................................................3-155

Environmental Consequences............................................................................3-158

Transportation, Energy, Communications, and Infrastructure ..................................3-163

Affected Environment .........................................................................................3-163

Environmental Consequences............................................................................3-165

Timber Resources.....................................................................................................3-171

Affected Environment .........................................................................................3-171

Environmental Consequences............................................................................3-174

Minerals.....................................................................................................................3-177

Affected Environment .........................................................................................3-177

Environmental Consequences............................................................................3-178

Recreation and Tourism............................................................................................3-181

Affected Environment .........................................................................................3-181

Environmental Consequences............................................................................3-188

Scenery .....................................................................................................................3-221

Affected Environment .........................................................................................3-221

Environmental Consequences............................................................................3-223

Subsistence...............................................................................................................3-239
Contents

Final EIS vi Contents

Affected Environment ......................................................................................... 3-239

Environmental Consequences............................................................................ 3-246

Environmental Justice ............................................................................................... 3-253

Affected Environment ......................................................................................... 3-253

Environmental Consequences............................................................................ 3-254

CHAPTER 4 PREPARERS AND CONTRIBUTORS ............................................................................. 4-1

Forest Service ....................................................................................................................... 4-1

Interdisciplinary Team ................................................................................................... 4-1

Tetra Tech Team................................................................................................................... 4-2

CHAPTER 5 LIST OF DOCUMENT RECIPIENTS AND THOSE NOTIFIED OR CONSULTED .......... 5-1

Federal Agencies and Tribal Governments........................................................................... 5-1

Federal Congressional Representatives ............................................................................... 5-2

Alaska Native Tribes and Corporations................................................................................. 5-2

Individuals ............................................................................................................................. 5-2

Consultation .......................................................................................................................... 5-2

CHAPTER 6 REFERENCES .................................................................................................................. 6-1

CHAPTER 7 GLOSSARY....................................................................................................................... 7-1

CHAPTER 8 INDEX................................................................................................................................ 8-1

APPENDIX A STATE OF ALASKA’S PETITION FOR RULEMAKING

APPENDIX B CUMULATIVE EFFECTS

APPENDIX C OUTFITTER/GUIDE USE AREA DATA TABLES

APPENDIX D SUITABLE TIMBER BY COMMUNITY

APPENDIX E COMMUNITIES

APPENDIX F TRADITIONAL TERRITORIES

APPENDIX G ROADLESS RULE REGULATORY LANGUAGE BY ALTERNATIVE 

APPENDIX H RESPONSES TO COMMENTS
Contents

Final EIS vii Contents

LIST OF TABLES

Table 2-1 Alaska Roadless Areas (ARA) by Alternative and Management Designations 2-5

Table 2-2 Rule Language Associated with Alaska Roadless Areas and for the Alaska 

Roadless Area Management Designations (see Appendix G for complete 

language) 2-6

Table 2-3 Roadless Rule Language Associated with the 2001 Roadless Rule 

(Alternative 1) 2-10

Table 2-4 Key Element Summary for Alternative 1 2-11

Table 2-5 Key Element Summary for Alternative 2 2-12

Table 2-6 Key Element Summary for Alternative 3 2-13

Table 2-7 Key Element Summary for Alternative 4 2-15

Table 2-8 Key Element Summary for Alternative 5 2-15

Table 2-9 Key Element Summary for Alternative 6 2-16

Table 2-10 Roadless Areas by Alternative and Management Designation 2-18

Table 2-11 Roadless Area Characteristics 2-19

Table 2-12 Comparison of Alternatives 2-25

Table 3-1 Land Use Designation Groupings Used to Discuss Effects 3-7

Table 3.1-1 Roadless Area Characteristics - Comparison 3-10

Table 3.1-2 Roadless Area Characteristics 3-12

Table 3.1-3 Roadless Areas by Alternative and Management Designation 3-18

Table 3.1-4 Estimated Old Growth Harvest Acres on Each Ranger District by Stratum and 

Alternative 3-19

Table 3.1-5 Total Acres by 2001 Inventoried Roadless Area and Net Change in Suitable 

Old-Growth Acres by IRA and Action Alternative 3-20

Table 3.1-6 Percentage Increase in Suitable Old Growth Acres on Each Ranger District by 

Alternative 3-22

Table 3.1-7 Summary of Acres Affected Nationally by Modifications of the Roadless Rule 

along with the Acres Affected by the Proposed Alaska Rule Modifications by the 

Alternatives 3-27

Table 3.2-1 Southeast Alaska Employment by Sector, 2018 3-32

Table 3.2-2 Timber Industry Employment in Southeast Alaska, 2002-2017 3-34

Table 3.2-3 Timber Harvest in Southeast Alaska by Ownership, 2002–2018 3-36

Table 3.2-4 Forest Service Mill Survey: Estimated Mill Capacity, Production, and Utilization,

2018 3-40

Table 3.2-5 Additional Sawmills in Southeast Alaska Based on a Review of Business 

Licenses, 2018 3-42

Table 3.2-6 Southeast Alaska Cruise Passengers by Community, 2007-2016 3-45

Table 3.2-7 Federal Secure Rural Schools Payments to Southeast Alaska Boroughs, 2013 

to 2018 3-50

Table 3.2-8 Suitable and High Volume Suitable Old-Growth Acres by Geographic Area and 

Alternative 3-52

Table 3.2-9 Increase in Suitable Old-Growth Acres by Ranger District and Alternative 3-54

Table 3.2-10 Access to Alaska Native Cultural Sites by Management Designation and 

Alternative 3-60

Table 3.3-1 Biogeographic Provinces in Southeast Alaska and the Tongass National Forest 3-62
Contents

Final EIS viii Contents

Table 3.3-2 Major Cover Types on the Tongass National Forest by Biogeographic Province 

(NFS LandsOnly) 3-65

Table 3.3-3 Distribution of Productive Old-Growth Forest on the Tongass National Forest by 

Biogeographic Province (NFS Lands Only) 3-68

Table 3.3-4 Original and Percent Remaining Total POG, High-Volume POG (SD5S, SD5N, 

SD67) Total and Below 800 feet, and Large-Tree POG (SD67) Total and Below 

800 feet by Biogeographic Province (NFS Lands Only) 3-70

Table 3.3-5 Distribution of Existing POG and Young Growth within the Reserve System and 

Matrix Lands (NFS Lands Only) 3-73

Table 3.3-6 Projected Harvest of Young Growth and Old Growth Over 100 Years by 

Biogeographic Province by Alternative 3-76

Table 3.3-7 Estimated Percent of Original POG Remaining (Total and in Reserves1) after

100 Years byBiogeographic Province and Alternative (NFS lands only)

2 3-77

Table 3.3-8 Estimated Percent of Original High-Volume POG Remaining (Total and in

Reserves) after 100 Years by Biogeographic Province and Alternative (NFS

lands only) 3-78

Table 3.3-9 Estimated Percent of Original Large-Tree POG Remaining (Total and in

Reserves) after 100 Years by Biogeographic Province and Alternative (NFS

lands only) 3-79

Table 3.3-10 Cumulative Percent of Original Total POG Remaining on All Land Ownerships 

after 100 Years of Forest Plan Implementation by Biogeographic Province and 

Alternative (NFS and Non-NFS Lands) 3-86

Table 3.3-11 Cumulative Percent of Original High-Volume POG Remaining on All Land 

Ownerships after 100 Years of Forest Plan Implementation by Biogeographic 

Province and Alternative (NFS and Non-NFS Lands) 3-87

Table 3.3-12 Cumulative Percent of Original Large-tree POG Remaining on All Land 

Ownerships after 100 Years of Forest Plan Implementation by Biogeographic 

Province and Alternative (NFS and Non-NFS Lands) 3-88

Table 3.3-13 Federally Listed Threatened and Endangered Species and Candidate Species 

under the ESA, Forest Service Alaska Region Sensitive Bird, Mammal, and 

Reptile Species with Potential for Occurrence on the Tongass National Forest1 3-91

Table 3.3-14 Existing Forest-wide Deer Habitat Capability Using the Interagency Deer Model 

(NFS Lands Only) 3-97

Table 3.3-15 Existing Estimated Average Road Densities and Percentage of WAAs in Road 

Density Categories on NFS Lands and All Lands Combined for All Roads and 

Open Roads Only within the Tongass National Forest Boundary (All Elevations) 3-99

Table 3.3-16 Modeled Deer Habitat Capability Using the Interagency Deer Model for 

Comparison to Forest Plan 18 Deer per Square Mile Standard and Guideline 

(NFS LandsOnly) 3-101

Table 3.3-17 Migratory and Resident Birds Identified as Species of Concern in Southeast 

Alaska 3-104

Table 3.3-18 Endemic Wildlife Species Documented on the Tongass National Forest 3-108

Table 3.3-19 Estimated Harvest (acres) of High-Volume (SD5N, SD5S, and SD67) and 

Large-Tree (SD67) Productive Old-Growth by Elevation Category and 

Alternative after 100 years (NFS lands only) 3-118

Table 3.3-20 Estimated Road Miles and Average Road Density below 1,200 feet in Elevation 

on NFS Lands and All Lands Combined for All Roads and for Open Roads by 

Alternative after 100 Years 3-121

Table 3.3-21 Estimated Road Miles and Percent of 6th Field Subwatersheds in Road Density 

Categories on NFS Lands under Existing Conditions and after 100 Years of Full 

Implementation1 3-135
Contents

Final EIS ix Contents

Table 3.3-22 Acres of Suitable Young Growth and Estimated Harvest within Tongass 77 

Watersheds and TNC/Audubon Conservation Priority Areas 3-137

Table 3.3-23 Estimated Average Total Road Density on Tongass NFS Lands and Non-NFS 

Lands within the Tongass National Forest Boundary by Alternative over 100+ 

years 3-141

Table 3.6-1 Alaska Region Sensitive Plants Known or Suspected to Occur on the Tongass 

National Forest 3-156

Table 3.6-2 Known Occurrences of Sensitive Plant Species within Estimated Old-Growth 

and Young-Growth Harvest Areas over 100 Years by Alternative 3-160

Table 3.7-1 Proposed or Unconstructed Renewable Energy Projects in IRAs 3-165

Table 3.7-2 Alaska Roadless Area Priorities at Proposed or Unconstructed Renewable 

Energy Projects in IRAs 3-169

Table 3.8-1 Mapped Suitable Acreage of Old-Growth and Young-Growth under Each 

Alternative (thousands of acres) 3-175

Table 3.8-2 Maximum Estimated Average Annual Timber Harvest in Southeast Alaska 

during the Next Decade (MMBF) 3-176

Table 3.10-1 Tongass Recreation Facilities, 2015 3-181

Table 3.10-2 Forest-wide Recreation Opportunity Spectrum Acres 3-183

Table 3.10-3 Important Recreation Places by Category and as a Share of Total Recreation 

Places 3-183

Table 3.10-4 Outfitter/Guide Average Annual Use 2013 to 2017 by Ranger District and

Activity 3-186

Table 3.10-5 Total Area, Percent Roadless, and Reported Service Days for Selected 

Outfitter/Guide Use Area 3-196

Table 3.10-6 Change in Roadless Area, Development LUDs without Roadless Designation, 

and Suitable Timber by Alternative for the East Chilkats Outfitter/Guide Use 

Area 3-204

Table 3.10-7 Change in Roadless Area, Development LUDs without Roadless Designation, 

and Suitable Timber by Alternative for the Sitka Area Outfitter/Guide Use Area 3-205

Table 3.10-8 Change in Roadless Area, Development LUDs without Roadless Designation, 

and Suitable Timber by Alternative for the Rodman Bay Outfitter/Guide Use 

Area 3-207

Table 3.10-9 Change in Roadless Area, Development LUDs without Roadless Designation, 

and Suitable Timber by Alternative for the Kelp Bay Outfitter/Guide Use Area 3-208

Table 3.10-10 Change in Roadless Area, Development LUDs without Roadless Designation, 

and Suitable Timber by Alternative for the Port Frederick Outfitter/Guide Use 

Area 3-209

Table 3.10-11 Change in Roadless Area, Development LUDs without Roadless Designation, 

and Suitable Timber by Alternative for the Freshwater Bay Outfitter/Guide Use 

Area 3-210

Table 3.10-12 Change in Roadless Area, Development LUDs without Roadless Designation, 

and Suitable Timber by Alternative for the Tenakee Inlet Outfitter/Guide Use 

Area 3-211

Table 3.10-13 Change in Roadless Area, Development LUDs without Roadless Designation, 

and Suitable Timber by Alternative for the Peril Strait Outfitter/Guide Use Area 3-212

Table 3.10-14 Change in Roadless Area, Development LUDs without Roadless Designation, 

and Suitable Timber by Alternative for the Craig Ranger District Outfitter/Guide 

Use Area 3-213
Contents

Final EIS x Contents

Table 3.10-15 Change in Roadless Area, Development LUDs without Roadless Designation, 

and Suitable Timber by Alternative for the North Revilla Outfitter/Guide Use 

Area 3-214

Table 3.10-16 Change in Roadless Area, Development LUDs without Roadless Designation, 

and Suitable Timber by Alternative for the Mitkof Island Outfitter/Guide Use 

Area 3-215

Table 3.10-17 Change in Roadless Area, Development LUDs without Roadless Designation, 

and Suitable Timber by Alternative for the North Lindenberg Peninsula 

Outfitter/Guide Use Area 3-216

Table 3.10-18 Change in Roadless Area, Development LUDs without Roadless Designation, 

and Suitable Timber by Alternative for the Kuiu Island Road System 

Outfitter/Guide Use Area 3-217

Table 3.10-19 Change in Roadless Area, Development LUDs without Roadless Designation, 

and Suitable Timber by Alternative for the Muddy River Outfitter/Guide Use 

Area 3-218

Table 3.10-20 Change in Roadless Area, Development LUDs without Roadless Designation, 

and Suitable Timber by Alternative for the Thorne Bay Ranger District 

Outfitter/Guide Use Area 3-219

Table 3.11-1 Adopted Scenic Integrity Objectives for the Tongass (percent) 3-223

Table 3.11-2 Scenery Integrity Objectives for Suitable Young Growth by LUD and Alternative 

(percent) 3-224

Table 3.11-3 Suitable/Projected Harvest (in acres) for Young Growth and Old Growth in 

Selected General Viewsheds 3-225

Table 3.12-1 Deer Harvest by Game Management Unit and Transportation Type, 2013 3-249

Table 3.13-1 Race/Ethnicity by Borough/Census Area 3-253

Table 3.13-2 Income and Poverty by Borough/Census Area 3-254
Contents

Final EIS xi Contents

LIST OF FIGURES

Figure 1-1 Areas Protected by Regulation and Administrative Designation within the 

Tongass 1-2

Figure 1-2 Tongass National Forest Vicinity Map 1-4

Figure 3-1 Estimated Maximum Average Annual Harvest under the 2016 Forest Plan 

Amendment 3-4

Figure 3.1-1 Roadless Areas by Alternative and Management Designation 3-18

Figure 3.1-2 Increase in Suitable Old-Growth Acres Available for Harvest by Ranger District 

and Alternative 3-23

Figure 3.2-1 Total Population in Southeast Alaska, 2010 to 2019 3-30

Figure 3.2-2 Total Population by Southeast Alaska Borough, 2019 3-31

Figure 3.2-3 Natural Resource-Based Employment by Sector, 2018 3-33

Figure 3.2-4 Timber Industry Employment in Southeast Alaska, 2002-2018 3-35

Figure 3.2-5 Timber Harvest in Southeast Alaska by Ownership, 2002-2018 3-37

Figure 3.2-6 Timber Harvest Exports from the Tongass National Forest, 2002-2018 3-39

Figure 3.2-7 Estimated Sawmill Production for Surveyed Mills, 2000 to 2018 3-41

Figure 3.2-8 Volume under Contract by Owner, 2019 3-43

Figure 3.2-9 Southeast Alaska Cruise Passengers, 2000-2019 3-44

Figure 3.2-10 Southeast Alaska Small Cruise Vessel Passenger Capacity, 2005-2016 3-45

Figure 3.2-11 Tongass National Forest Outfitter/Guide Use, 2008 to 2017 3-46

Figure 3.2-12 Suitable Old-Growth Acres by Alternative 3-53

Figure 3.3-1 Map of Biogeographic Provinces of Southeast Alaska 3-64

Figure 3.3-2 Tree Size and Density Model used to Describe Forested Conditions across the 

Tongass National Forest 3-67

Figure 3.3-3 Commercial Harvest of Chinook, Sockeye, and Coho Salmon in Southeast 

Alaska 1960-2019 3-130

Figure 3.3-4 Commercial Harvest of Pink, Chum and Total Salmon in Southeast Alaska 

1960-2019 3-131

Figure 3.10-1 Old-Growth Suitable Acres by ROS Setting and Alternative 3-190

Figure 3.10-2 Old-Growth Acres Expected to be Harvested After 100 Years by ROS Setting 

and Alternative 3-190

Figure 3.10-3 Old-Growth Suitable Acres by Recreation Place Category and Alternative 3-191

Figure 3.10-4 Old-Growth Acres Expected to be Harvested After 100 Years by Recreation 

Place Category and Alternative 3-192

Figure 3.10-5 Alternative 1 with 15 Selected Outfitter/Guide Use Areas 3-198

Figure 3.10-6 Alternative 2 with 15 Selected Outfitter/Guide Use Areas 3-199

Figure 3.10-7 Alternative 3 with 15 Selected Outfitter/Guide Use Areas 3-200

Figure 3.10-8 Alternative 4 with 15 Selected Outfitter/Guide Use Areas 3-201

Figure 3.10-9 Alternative 5 with 15 Selected Outfitter/Guide Use Areas 3-202

Figure 3.10-10 Alternative 6 with 15 Selected Outfitter/Guide Use Areas 3-203

Figure 3.11-1 Map of Selected General Viewsheds 3-231

Figure 3.12-1 Native/Non-Native Components of Southeast Communities 3-242

Figure 3.12-2 Per Capita Subsistence Harvest by Community and Resource Type 3-244
Contents

Final EIS xii Acronyms and Abbreviations

ACRONYMS AND ABBREVIATIONS

2001 Roadless Rule Roadless Area Conservation Rule

ADED Alaska Department of Economic Development

ADF&G Alaska Department of Fish and Game

ADNR Alaska Department of Natural Resources

ADOT&PF Alaska Department of Transportation & Public Facilities

AFHA Anadromous Fisheries Habitat Assessment

AKEPIC Alaska Exotic Plants Information Clearinghouse

AKNHP Alaska Natural Heritage Program

ANCSA Alaska Native Claims Settlement Act of 1971

ANILCA Alaska National Interest Lands Conservation Act of 1980

AP&T Alaska Power & Telephone

ARA Alaska Roadless Area

BA Biological Assessment

BBER Bureau of Business and Economic Research

BCR Bird Conservation Region

BE Biological Evaluation

BLM U.S. Department of the Interior, Bureau of Land Management

BMP Best Management Practice

CA Census Area

CDP Census Designated Places 

CEQ Council on Environmental Quality

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act

CFR Code of Federal Regulations

CMAI culmination of mean annual increment

DEIS Draft Environmental Impact Statement

DOL Department of Labor

DPS distinct population segment

EFH essential fish habitat

EIS Environmental Impact Statement

ESA Endangered Species Act

ESI Existing Scenic Integrity

ESU evolutionarily significant unit 

°F degrees Fahrenheit

FCRPA Federal Cave Resources Protection Act

FEIS Final Environmental Impact Statement

FERC Federal Energy Regulatory Commission

FHWA Federal Highway Administration

Forest Plan Tongass National Forest Land and Resource Management Plan

FPA Federal Power Act

FRESH Forest Resource Evaluation System for Habitat

FR Federal Register

FSM Forest Service Manual

GIS geographic information system

GMU Game Management Unit
Contents

Final EIS xiii Acronyms and Abbreviations

GNA Good Neighbor Authority

IDT Interdisciplinary Team

IRA Inventoried Roadless Area

LTF log transfer facility

LUD Land Use Designation

LWD large woody debris

MBF thousand board feet

MBTA Migratory Bird Treaty Act

MIS Management Indicator Species

MMBF million board feet

MMI mass movement index

MMPA Marine Mammal Protection Act 

MOU Memorandum of Understanding

MW megawatt

NEPA National Environmental Policy Act

NFMA National Forest Management Act of 1976

NFS National Forest System

NHPA National Historic Preservation Act

NMFS National Marine Fisheries Service

NOA Notice of Availability

NOI Notice of Intent

NPS National Park Service

NRIS Natural Resource Information System 

NVUM National Visitor Use Monitoring

OGR old-growth reserve

P Primitive

PNW Pacific Northwest

POG productive old growth

PTSQ projected timber sale quantity 

PWSQ projected wood sale quantity

R Rural

RARE Roadless Area Review and Evaluation

RM Roaded Modified

RMA Riparian Management Area 

RN Roaded Natural

Roadless Rule Roadless Area Conservation Rule

ROD Record of Decision

ROS Recreation Opportunity Spectrum

RV Residual Value

SAFETEA-LU Safe, Accountable, Flexible, Efficient Transportation Equity Act - A Legacy for 

Users

SATP Southeast Alaska Transportation Plan

SDM Size-Density Model

SEIS Supplemental Environmental Impact Statement

SIO Scenic Integrity Objective

SMS Scenery Management System
Contents

Final EIS xiv Acronyms and Abbreviations

SNAP Scenarios Network for Alaska & Arctic Planning 

SPM Semi-Primitive Motorized

SPNM Semi-Primitive Non-Motorized

T77 Tongass 77

TNC The Nature Conservancy

TRUCS Tongass Resource Use Cooperative Survey

TTRA Tongass Timber Reform Act of 1990

TWYGS Tongass-wide Young-Growth Studies

U Urban

U.S.C. United States Code

USDA United States Department of Agriculture

USFWS U.S. Fish and Wildlife Service

VCU Value Comparison Unit

VMS Visual Management System 

WAA Wildlife Analysis Area

WCF Watershed Conditions Framework
EXECUTIVE SUMMARY
Executive Summary

Final EIS ES-1 Executive Summary

Chapter 0

Executive Summary

The Forest Service has prepared an environmental impact statement (EIS) in compliance with the 

National Environmental Policy Act (NEPA) and other relevant federal laws and regulations. This Final EIS 

(FEIS) discloses the potential environmental consequences that might result from the proposed actions 

and alternatives.

Background

Inventoried Roadless Areas

Inventoried Roadless Areas (IRAs) on the Tongass National Forest (Tongass) include 9.37 million acres 

(56 percent of the Tongass) across 110 IRAs. When these designated roadless areas are combined with 

Wilderness and National Monument areas, the Tongass is currently more than 90 percent undeveloped 

and unavailable for timber harvest and road building. Developed areas cover about 1.3 million acres, or 

about 8 percent, of the Tongass. Southeast Alaska residents (approximately 73,000) are, for the most 

part, surrounded by largely undeveloped land. 

Several portions of the Tongass constitute contiguous IRAs exceeding 1 million acres, and thus represent 

large, unfragmented wildlife habitats and opportunities for solitude. Many of the Tongass IRAs represent 

wildlife habitats, ecosystems, and visual characteristics, such as coastal islands facing the open Pacific, 

extensive beaches on inland saltwater, old-growth temperate rain forests, ice fields, and glaciers that 

exist nowhere else in the National Forest System (NFS). Many of these areas are remote and difficult to 

access for primitive recreation and contain other important resources, such as timber, minerals, 

renewable energy opportunities, and salmon-producing streams. While IRAs provide a large portion of the 

land base in Southeast Alaska, National Parks, National Monuments, and designated Wildernesses also 

contribute to the undeveloped nature of the region. 

The Roadless Area Conservation Rule (2001 Roadless Rule) was originally codified at Title 36 of the 

Code of Federal Regulations (CFR) Part 294 (36 CFR 294), Subpart B (66 Federal Register [FR] 3244) in 

January 2001. The 2001 Roadless Rule applies nationwide (except Idaho and Colorado where statespecific rules have superseded the 2001 Rule and were completed in 2008 and 2012, respectively). The 

2001 Rule remains applicable to 44.7 million acres of National Forests (approximately 24 percent of total 

NFS lands) and prohibits road construction/reconstruction and timber harvest, sale, or removal, with 

limited exceptions.

Since its promulgation, the 2001 Roadless Rule has been the subject of litigation. In 2001, the State of 

Alaska filed a complaint, challenging the U.S. Department of Agriculture’s (USDA) promulgation of the 

2001 Roadless Rule and its application in Alaska. The USDA and the State of Alaska reached a 

settlement in 2003, and the USDA subsequently issued a rule temporarily exempting the Tongass from 

the 2001 Roadless Rule. In 2011, a federal court (District of Alaska) set aside the Tongass’s exemption 

and reinstated the 2001 Roadless Rule on the Tongass with special instructions. The Alaska District

Court’s ruling was initially reversed by a three-judge panel of the Ninth Circuit, but the District Court’s 

ruling was ultimately upheld in a 6–5 en banc ruling of the Ninth Circuit in 2015. In September 2017, the 

District Court for the District of Columbia rejected all procedural and substantive claims that the 2001 

Roadless Area Conservation Rule was unlawfully promulgated; both nationally and as applied to Alaska. 

Alaska appealed the District Court’s ruling to the Court of Appeals for the District of Columbia Circuit. On 

September 26, 2018, the D.C. Circuit ordered the appeal be held in abeyance following USDA’s 

acceptance of Alaska’s Petition for Rulemaking and directed that status reports be filed with the court 

every 90 days. Consequently, the 2001 Roadless Rule remains in effect in Alaska and the Forest Service 

continues to apply the 2001 Roadless Rule within the Tongass and Chugach National Forests.
Executive Summary

Final EIS ES-2 Executive Summary

State of Alaska Petition

In January 2018, the State of Alaska submitted a petition requesting that the Secretary of Agriculture 

exempt the Tongass from the 2001 Roadless Rule (see Appendix A). In June 2018, the USDA Secretary 

directed the Forest Service to begin working with the State to consider an Alaska state-specific roadless 

rule. In August 2018, the Forest Service granted cooperating agency status to the State of Alaska. The 

Forest Service and the State of Alaska believed that the rulemaking represented a unique opportunity to 

collaboratively address and provide certainty to the roadless issue in the Tongass. The Forest Service 

published a Notice of Intent (NOI) to prepare an EIS and initiated a public rulemaking process to address 

the management of IRAs on the Tongass on August 30, 2018 (83 FR 44252). As stated in the NOI, USDA 

desires a durable and long-lasting solution for the conservation and management of roadless areas on 

the Tongass. The state-specific roadless rule identified in the preferred alternative would discontinue the 

existing regulation’s prohibitions and instead rely upon existing statutory and land management plan 

direction to manage roadless areas on the Tongass. 

Tongass Land and Resource Management Plan

The 16.7-million-acre Tongass was the first forest to complete a Land and Resource Management Plan 

(Forest Plan) under the National Forest Management Act (NFMA) in 1979. That Forest Plan was 

amended in 1986 and 1991 and revised more broadly in 1997. A final Supplemental Environmental 

Impact Statement (SEIS) was completed in 2003, which further evaluated roadless areas for their 

wilderness potential. The Forest Plan was amended in 2008 in response to a Ninth Circuit Court ruling 

and a 5-Year Plan Review completed in 2005. The Forest Plan was subsequently amended in 2016 to 

address the Secretary of Agriculture’s direction to transition to a young growth-based timber program in 

10 to 15 years. The Forest Plan anticipates production of an average of 46 million board feet (MMBF) per 

year while transitioning to predominantly young growth harvest after about 16 years. Additional objectives 

of the 2016 Forest Plan Amendment (Forest Plan) include facilitation of the development of renewable 

energy projects and responding to findings of the 5-Year Review of the 2008 Forest Plan.

All discretionary Forest Service activities authorized on the Tongass must be consistent with the Forest 

Plan as well as existing laws and regulations. In addition, as with other roadless rulemakings, the Alaska 

roadless rulemaking process does not require an amendment or revision of any forest plan, aside from an 

administrative change to the area that is suitable for timber production.

Purpose and Need

In response to the State of Alaska’s petition for rulemaking, a long-term, durable approach to roadless 

area management is desired that accommodates the unique biological, social, and economic situation 

found in and around the Tongass. The Tongass is unique from other national forests with respect to size, 

percentage of IRAs, amount of NFS lands and subsequent dependency of 32 communities on federal 

lands (the Tongass comprises almost 80 percent of Southeast Alaska), and Alaska and Tongass-specific 

statutory considerations (e.g., Alaska National Interest Lands Conservation Act [ANILCA]), Tongass 

Timber Reform Act [TTRA]). In ANILCA, Congress sought to balance national environmental interests 

with “adequate opportunity for satisfaction of the economic and social needs of the State of Alaska and its 

people” (16 U.S.C. §3101(d), Sturgeon v. Frost, 139 S.Ct. 1066, 1075).

The USDA and Forest Service believe the 2001 Roadless Rule prohibitions on timber harvest and road 

construction/reconstruction can be adjusted for the Tongass in a manner that meaningfully addresses 

local economic and development concerns and roadless area conservation needs. 

The State of Alaska believes that roadless conservation interests for the Tongass can be adequately 

protected under the Tongass Forest Plan and that the 2001 Roadless Rule prohibitions are unnecessary. 

In addition, the State believes application of the 2001 Roadless Rule substantially impacts the social and 

economic fabric of Southeast Alaska and violates ANILCA and TTRA. 

In response to the State’s petition, commercial and non-profit organizations have expressed strong 

opinions, for and against, the idea of a regulatory review
Executive Summary

Final EIS ES-3 Executive Summary

Key Issues

In 2001, the USDA determined that the Tongass National Forest deserved “special attention in 

formulating alternatives due to its unique social and economic conditions” (USDA Forest Service 2000). 

More specifically, USDA’s Record of Decision identified:

“the agency has considered the alternatives of exempting and not exempting the Tongass 

National Forest, as well as deferring a decision per the proposed rule. Social and economic 

considerations were key factors in analyzing those alternatives, along with the unique and 

sensitive ecological character of the Tongass National Forest, the abundance of roadless areas 

where road construction and reconstruction are limited, and the high degree of ecological health. 

In developing the proposed action, the agency sought to balance the extraordinary ecological 

values of the Tongass National Forest against the needs of the local forest dependent 

communities in Southeast Alaska.” (66 FR 3254)

Then, as now, USDA’s (and that of the State, cooperators, and interested members of the public) 

assessment of policy preferences regarding roadless management rests primarily on the different 

weights ascribed to the these ecological, social, and economic factors rather than any specific data or 

scientific findings. To be sure, the agency has carefully considered comments submitted that sought 

clarifications or updated information and revised the FEIS accordingly.

With striking similarity to the issues highlighted in 2001, the following three key issues were identified for 

the Alaska state-specific roadless rulemaking effort and will be carried forward throughout the analysis.

Key Issue 1 – Roadless area conservation

The Tongass includes large undeveloped areas, with several portions of the Forest consisting of 

contiguous roadless areas that exceed one million acres and represent large blocks of unfragmented 

wildlife habitats, undeveloped or natural areas, and opportunities for primitive recreation and/or solitude. 

This large scale of roadless area, including wildernesses and national monuments, does not exist 

anywhere else in the NFS outside of Alaska. The Tongass is the largest national forest in the United 

States, and the majority of the Tongass is in a natural condition. It represents one of the largest, relatively 

intact temperate rainforests in the world.

Roadless areas are important because of their wildlife and fish habitat, recreation values, importance to 

multiple economic sectors, traditional properties and sacred sites for indigenous people, inherent passive 

use values, and ecosystem services they provide. Passive use values represent the value that individuals 

assign to a resource independent of their use of that resource and typically include existence, option, and 

bequest values. These values represent the value that individuals obtain from knowing that expansive 

roadless areas exist, knowing that they are available to visit in the future should they choose to do so, 

and knowing that they are available for future generations to inherit. Ecosystem services represent the 

services provided to society by healthy ecosystems. These services and benefits include what some 

consider to be long-term life support benefits to society as a whole. Examples of ecosystem services 

include watershed services, soil stabilization and erosion control, improved air quality, climate regulation, 

carbon sequestration, and biological diversity. 

Key Issue 2 – Support local and regional socioeconomic 

well-being, Alaska Native culture, rural subsistence activities, 

and economic opportunity across multiple economic sectors

The Tongass comprises approximately 80 percent of Southeast Alaska and therefore plays a critical role 

in supporting local and regional economies, promoting economic diversification, and also enhancing rural 

community well-being. The visitor industry, seafood industry, and resource extraction industries contribute 

to local jobs and income alongside public sector employment in federal, state, and local government. 

While the visitor and seafood industries are the largest private-sector employers across Southeast 

Alaska, resource extraction remains important in some rural communities where job opportunities are 

limited and unemployment rates are often high.
Executive Summary

Final EIS ES-4 Executive Summary

The Forest Service manages land for the multiple-use and sustained yield of all renewable surface 

resources. There is, however, disagreement among the State, cooperators, and public regarding the best 

management of federal lands for economic development purposes and the overall economic vitality of 

Tongass communities. Many believe the visitor industry and seafood industries have become the 

mainstay of Southeast Alaska’s economy and, therefore, should have prominence in Forest Service land 

management decision-making. Others note that resource extraction, including forest products and the 

minerals industry, continue to provide jobs and income sources in Southeast Alaskan communities. 

Southeast Alaska residents, communities, and Alaska Native individuals and tribes rely extensively on the 

Tongass for a wide variety of subsistence resources and traditional cultural activities. Many of them also

use the forest for recreational hunting, fishing, and other activities. These activities yield economic value 

as well, and are important to local and regional socioeconomic well-being.

Key Issue 3 – Conserve terrestrial habitat, aquatic habitat, 

and biological diversity

The Tongass includes large, undeveloped, and natural land areas that represent expansive unfragmented 

blocks of wildlife habitat. This scale and size of contiguous habitat is not generally available elsewhere in 

the NFS outside of Alaska. Although wildlife species on the Tongass are associated with more than one 

habitat type, many inhabit old-growth forests or prey on species that inhabit old-growth forests. The 

Tongass Old-growth Habitat Conservation Strategy (2016 Forest Plan Amendment EIS, Appendix D) was 

developed to maintain the integrity of the old-growth forest ecosystem, and thereby conserve biological 

diversity across the Forest by retaining intact, largely undisturbed habitat. In addition, because of its 

predominantly undeveloped nature, a number of wide-ranging species find optimal habitat in the more 

remote areas of the Forest.

Fish and the aquatic resources on the Tongass support subsistence, commercial, and sport fisheries, as 

well as traditional and cultural values. The Tongass includes high-value, intact watersheds that were 

designated to be managed for intact ecological values and aquatic habitat productivity, and many 

commenters believe these areas should be protected so that they can continue to provide the clean water

and fish habitats that are essential to the ecological and economic health of the Southeast Alaska 

communities and residents who rely on them.

Features Common to Multiple Alternatives

Tongass Land and Resource Management Plan (Forest Plan)

Except for the timber land suitability determinations described below, none of the alternatives would make 

any changes to the Forest Plan including the following:

Goals and Objectives;

Land Use Designations or Management Prescriptions;

Forest-wide Standards and Guidelines;

Plan Components developed under the 2012 Planning Rule; and/or

Projected Timber Sale Quantity (PTSQ), Projected Wood Sale Quantity (PWSQ), and the Younggrowth Transition.

None of the alternatives authorize any site-specific projects or other ground-disturbing activities. Specific 

projects that include timber harvest, road construction, and/or road reconstruction must undergo 

appropriate site-specific environmental analysis when they are proposed, to comply with NEPA. None of 

the alternatives considered in this FEIS waive any applicable requirements regarding site-specific 

environmental analysis, public involvement, consultation with Alaska Native tribes, Alaska Native 

corporations, and other agencies, or compliance with other applicable laws.

Activities that are not otherwise prohibited are permissible in roadless areas under all alternatives, 

including the no-action alternative (2001 Roadless Rule).
Executive Summary

Final EIS ES-5 Executive Summary

Timber Suitability

Alternatives 2, 3, 4, 5, and 6 would result in an administrative change to the timber land suitability 

determinations made in the 2016 Forest Plan Amendment. Specifically, lands identified as suitable for 

timber production that were deemed unsuitable solely due to implementation of the 2001 Rule would be 

set aside and redesignated as suitable for timber production. As described in Appendix A to the Forest 

Plan (USDA Forest Service 2016a), old-growth forest located within Phases 2 and 3 of the Tongass 

Timber Sale Program Adaptive Management Strategy, within the Tongass 77 (T77) Watersheds and The 

Nature Conservancy (TNC)/Audubon Conservation Priority Areas, within non-development Land Use 

Designations (LUDs), and in other areas designated by the Forest Plan as not suitable, would continue to 

be not suitable for timber production. This administrative change would apply to lands removed from the 

roadless inventory and to lands identified as “Community Priority” or “Timber Priority” in Alternatives 3 and 

4, respectively. The administrative change to the Tongass suitability determinations would not preclude 

future adjustments to suitability determinations as part of subsequent Forest Plan amendment or revision 

processes for the purpose of addressing other multiple use needs.

Changes Between the DEIS and FEIS

A number of changes, corrections, and clarifications from the Draft Environmental Impact Statement 

(DEIS) have been made based on public comments and internal reviews. The most notable changes are 

summarized below. Minor edits and corrections are not included in this list.

Corrections were made to IRA boundaries (Alternative 1) based on ownership changes and mapping 

corrections. The alternatives for the FEIS are based on these updated IRA boundaries. The corrections 

removed areas misidentified in the 2001 Roadless Rule (i.e., designated Wilderness identified as IRA), 

aligned IRA boundaries with Wilderness area boundaries, added lakes and aligned IRA boundaries with 

current NFS ownership. This resulted in a net increase of about 30,000 acres from the 9.34 million acres 

identified in 2001.

A new “roaded roadless” analysis was conducted between the DEIS and FEIS resulting in additional 

areas identified with existing timber harvest and roads within IRAs. 

Areas identified as logical extensions were adjusted and removed from roadless designation in 

Alternatives 3 and 4 to eliminate small, isolated roadless areas.

Community Priority Areas: The community priority designation was applied for Hydaburg and Kake, 

resulting in increasing the number of Community Priority Areas for Alternative 3. 

Cooperating Agencies noted that T77 Watershed/TNC-Audubon Conservation Priority areas mapped 

for the DEIS did not include several high-priority sockeye salmon watersheds important to Alaska 

Native Tribes. Therefore, areas identified as logical extensions in the DEIS that overlapped with the 

high-priority sockeye salmon watersheds were added back into the roadless inventory for Alternatives

2 and 3 to minimize effects to these watersheds. 

The DEIS assumed that timber harvest was distributed evenly across the suitable timber lands. In 

response to a number of comments and internal discussions, it was decided that old-growth harvest 

acres could be allocated in a more realistic pattern (since only 11 to 19 percent of the suitable old 

growth is harvested over 100 years). Thus, for the FEIS, a model to project more accurately the 

distribution of harvest was developed (see Chapter 3, Introduction, Assumptions for Future Harvest). 

The mileages of new road construction, road reconstruction, and new roads over decommissioned 

road grades were estimated for each alternative; and these were spatially allocated based primarily 

on where harvest occurred (see Chapter 3, Introduction, Assumptions for Future Road Construction 

and Reconstruction). 

In the DEIS, a number of Biodiversity, Wildlife, and Water tables from the 2016 Forest Plan 

Amendment EIS were referenced, especially in the Affected Environment sections, because 

conditions have not changed significantly. The tables from the 2016 Forest Plan Amendment EIS 

were presented in Appendix C. In order to be more precise in the FEIS, the attributes in these tables 

were analyzed specifically for this EIS, and updated information is now presented in new tables in the 

text that is specific to this EIS. Appendix C has, therefore, been eliminated.
Executive Summary

Final EIS ES-6 Executive Summary

The DEIS incorrectly stated that a Biological Assessment would be prepared for the Decision. Since 

there are no anticipated effects that would influence threatened or endangered species, preparing a 

Biological Assessment is not necessary. Biological Assessments may be prepared for site-specific 

actions proposed in the future, as appropriate.

Maps showing lands suitable for old-growth and young-growth timber production were created for 

each community use area by alternative. However, to better approximate where future old-growth 

harvest might occur, some suitable old growth is excluded because it is considered less desirable 

low-volume old growth or for poor economics. These maps are intended to illustrate to the reader the 

potential impacts of timber harvesting resulting from the final rule by community. These maps are 

provided in Appendix D, which is made available electronically in the data storage device 

accompanying this FEIS and on the project website.

In Appendix G, the Roadless Rule for Alternative 2 was corrected by removing the regulatory 

prohibition of commercial old-growth timber harvest in certain high priority watersheds. This is 

consistent with what was analyzed in the DEIS and was only intended to apply to Alternative 3.

In Appendix G, exceptions to the prohibitions on timber harvest and road building in ARAs have been 

revised.

Proposed Alaska Roadless Boundary Correction and 

Modification Provisions

Alternatives 2, 3, 4, and 5 include administrative correction and modification provisions for inclusion in the 

proposed Alaska Roadless Rule to provide for future boundary and classification changes. While the 

proposed rule and DEIS announced an intention to extend this provision to the Chugach National Forest, 

in response to public comment, this provision has been adjusted and would apply only to the Tongass 

National Forest. Administrative corrections would be limited to adjustments that remedy clerical errors, 

typographical errors, mapping errors, or improvements in mapping technology. Administrative 

modifications would be limited to conformance to statutory changes, or incorporation of changes due to 

land adjustments. The Chief may issue administrative corrections after a 30-day public notice and 

opportunity to comment period. The Chief would provide at least a 45-day public notice and opportunity to 

comment period for all modifications.

Alaska Roadless Area Management Designations

Alternatives 2, 3, 4, and 5 provide for a variety of management approaches within roadless areas through ARA 

land management designations which include LUD II Priority, Watershed Priority, Roadless Priority, 

Community Priority, and Timber Priority. The management designations prohibit timber harvest, road 

construction, and road reconstruction with exceptions that are applied differentially across the alternatives. A 

brief description of each management designation follows.

LUD II Priority (Alternatives 2, 4, and 5)

LUD II Priority ARAs would be managed in accordance with applicable statutory direction. Specifically, 

these lands would continue to be managed in a roadless state to retain their wildland character as defined 

in the Tongass Timber Reform Act (TTRA; Title II, Section 201) and the National Defense Authorization 

Act for Fiscal Year 2015 (Public Law 113-291, 128 Stat. 3729, Section 3720(f)).

Approximately 870,000 acres of the Tongass are congressionally designated as LUD II (847,000 acres 

currently designated as IRA under the 2001 Roadless Rule and 22,000 acres currently not designated as 

IRA). Alternatives 2 and 4 propose to designate 854,000 LUD II acres as LUD II Priority ARA. Alternative 

5 proposes to apply the LUD II Priority ARA only to LUD II areas that are currently designated as IRA.

Alternative 3 proposes to remove all LUD II areas from roadless designation rather than designating LUD 

II lands into an ARA. LUD II areas under Alternative 3 would continue to be managed as directed by their 

congressional designations.
Executive Summary

Final EIS ES-7 Executive Summary

Watershed Priority (Alternatives 2 and 3)

The Watershed Priority ARA is more protective than the 2001 Roadless Rule as it offers fewer exceptions for 

timber harvest, road construction/reconstruction. It also provides for activities specific to aquatic habitat 

improvement. Approximately 3,284,000 acres in Alternative 2 and 3,259,000 acres in Alternative 3 would be 

managed under this designation. The Watershed Priority designation is applied to areas identified in the 

Forest Plan as T77 Watersheds and TNC/Audubon Conservation Priority Areas, as well as high-priority 

sockeye salmon watersheds.

Additionally, for Alternative 3, commercial old-growth timber harvest would be prohibited on NFS lands in T77 

Watersheds and TNC/Audubon Conservation Areas that extend beyond ARA boundaries. A prohibition on 

old-growth harvesting currently exists through the Forest Plan. But Alternative 3 examines establishing 

regulatory continuity between these roadless and watershed management systems given how extensively 

they overlap (the listed watersheds comprise over half of the Tongass’ roadless areas, and approximately 

90 percent of the watershed areas are within roadless area boundaries). Thus, the old-growth harvest 

prohibition would be extended beyond the designated roadless area boundaries in order to maintain the 

balance and integrity of the watershed protection system. As with all roadless rule provisions, the new 

prohibition would supersede current and future forest plans, with the plan continuing to provide 

management direction in other regards. In this manner, Alternative 3 affords high-priority watershed areas 

greater regulatory protection than under the 2001 Roadless Rule. Young-growth timber harvest outside of 

ARAs within these high-priority watershed areas is not prohibited.

Roadless Priority (Alternatives 2, 3, 4, and 5)

The Roadless Priority ARA is similar to the 2001 Roadless Rule but is less restrictive and addresses 

Alaska-specific concerns. Specifically, it provides for infrastructure development to connect and support 

local communities, and road construction/reconstruction for access to renewable energy sites and 

leasable minerals. In addition, the Roadless Priority ARA includes specific exceptions that, while they are 

allowed under the 2001 Roadless Rule, are included to improve overall clarity. 

Community Priority (Alternative 3)

The Community Priority ARA allows for small-scale timber harvest1 (less than one MMBF) and associated 

road construction/reconstruction. In addition, it allows for infrastructure development to connect and 

support local communities and traditional Alaska Native cultural uses. In all cases, activities within 

Community Priority ARAs would have to be consistent with the underlying Forest Plan LUD requirements. 

Even if a timber harvest, road building, or other activity would be permissible under the Alaska Roadless 

Rule, it may not be allowable because of Forest Plan requirements specific to the LUD that applies to the 

area, or other suitability criteria as explained in the Forest Plan, Appendix A. This designation applies to 

approximately 370,000 acres and is proposed in Alternative 3 adjacent to seven communities: Hydaburg, 

Juneau, Kake, Ketchikan, Sitka, Wrangell, and Yakutat. 

This ARA was developed to address desires of these seven communities to retain roadless designations 

while allowing for small timber operators in the community, infrastructure development to support the 

communities, and provide for traditional Alaska Native cultural uses. 

Timber Priority (Alternative 4)

The Timber Priority ARA allows timber harvest, road construction, and road reconstruction to facilitate 

timber management and provide economic opportunity. It is only included in Alternative 4 and would 

apply to approximately 757,000 acres. While management of lands in this ARA management designation 

would not be subject to any regulatory prohibitions on timber harvest or road construction, retaining them 

in roadless designation is a means of acknowledging the roadless values of these lands to ensure 

appropriate consideration in future, site-specific project planning and analysis. Table ES-1 displays the 

ARAs by alternative.

1 Timber harvest in Community Priority ARAs would be limited to micro sales, salvage sales, and small commercial sales less than 

one MMBF in size.
Executive Summary

Final EIS ES-8 Executive Summary

Table ES-1

Alaska Roadless Areas (ARA) by Alternative and Management Designation

ARA Management 

Designations

Alternative

1 2 3 4 5 6

No Action

Roaded 

Roadless

Logical 

Extension

Partial 

Dev. LUDs1

All Dev. 

LUDs

Full 

Exemption

LUD II Priority N/A √ √ √ N/A

Watershed Priority N/A √ √ N/A

Roadless Priority N/A √ √ √ √ N/A

Community Priority N/A √ N/A

Timber Priority N/A √ N/A

N/A = not applicable

1 Includes Timber Production and Modified Landscape LUDs, but not Scenic Viewshed.

Alternative 1 (No Action)

Alternative 1 is the no action alternative as required by the Council on Environmental Quality’s NEPA 

regulations and reflects a continuation of current land management pursuant to the 2001 Roadless Rule 

(see Map 1 in map packet or on thumb drive). This alternative does not mean that no activities would 

occur on the Tongass National Forest; rather, it means the activities currently occurring would continue, 

including implementation of the Tongass timber program at levels defined in the Forest Plan. This 

alternative continues general prohibitions on timber harvest (and sale), road construction, and road 

reconstruction within IRAs with limited exceptions (Table 2-3). 

Under Alternative 1, roadless areas consist of 110 IRAs identified in the 2001 Roadless Rule. These IRAs 

were originally mapped in 1996 for the Tongass Forest Plan Revision and the provisions of the 2001 

Roadless Rule (as provided for by the Court’s reinstatement Order) would apply to those IRAs 

(summarized below). As a result of ownership changes and boundary alignment corrections recognized 

during this review, these IRAs actually encompass 9.37 million acres2 of NFS land. Under this alternative, 

the prohibitions of the 2001 Roadless Rule would continue to apply across the 110 IRAs, encompassing 

approximately 56 percent of the Tongass. 

Under Alternative 1, the 2001 Roadless Rule IRA boundary modifications (increases and decreases) 

would continue to require rulemaking except for minor clerical or technical corrections.

Alternative 2

Alternative 2 provides limited additional timber harvest opportunity while maximizing roadless area 

designations. It removes approximately 142,000 acres from roadless designation that have been 

substantially altered by known road construction or timber harvest. These areas are generally known as 

“roaded roadless” areas but include additional areas considered to be substantially altered. Alternative 2 

also adds 110,000 acres as ARAs. 

The 110,000 acres of added roadless areas maximize the geographic scope of roadless area 

designations by including portions of congressionally-designated LUD II areas not included as IRAs under 

the 2001 Roadless Rule, currently unroaded small islands, and unroaded areas greater than 5,000 acres 

as identified by prior forest planning efforts. Adding additional roadless designations to unroaded islands 

provides for long-term, continued recreational and outfitter and guide opportunities on these islands.

After removals and additions, Alternative 2 consists of 9.34 million inventoried roadless acres, or about 

30,000 fewer roadless acres than under Alternative 1. The 9.34 million acres are designated to three ARA 

land management categories including LUD II Priority, Watershed Priority, and Roadless Priority (see 

Map 2 in map packet or on thumb drive). 

2 The original acreage of inventoried roadless areas on the Tongass was approximately 9.34 million acres. As a result of ownership 

changes and boundary alignment corrections, including shoreline mapping adjustments, the actual acreage is 9.37 million acres.
Executive Summary

Final EIS ES-9 Executive Summary

Alternative 2 applies the most protective ARA, Watershed Priority, to 3.28 million acres, primarily 

identified as T77 Watersheds and TNC/Audubon Conservation Priority Areas and high-priority sockeye 

salmon watersheds. The Watershed Priority ARA is considered most protective because it includes fewer 

exceptions than the 2001 Roadless Rule, while still allowing activities needed for fisheries protection, 

maintenance, or improvement.

Under Alternative 2, a net of 20,000 old-growth acres and 11,000 young-growth acres, previously 

identified as unsuitable timber lands, would revert to suitable timber lands, as they were when the 

roadless rule did not apply to the Tongass.

Alternative 3

Alternative 3 provides moderate additional timber harvest opportunities. Alternative 3 establishes roadless 

designations for T77 Watersheds, TNC/Audubon Conservation Priority Areas, and high-priority sockeye 

salmon watersheds inside roadless areas and also prohibits old-growth harvest in T77 Watersheds and 

TNC/Audubon Conservation Priority Areas outside of roadless areas (similar to the Forest Plan). 

Additional timber harvest opportunity is provided by removing substantially-altered roadless areas 

(including roaded roadless, similar to Alternative 2) and extending the bounds of these areas to logical 

end points of existing road and timber harvest systems, generally defined as the nearest watershed 

boundary (i.e., ridgeline of 14th-field hydrologic unit) from an existing road system. Removing these areas 

from the roadless inventory represents the logical extensions of substantially altered acres from existing 

infrastructure and likely encompasses the more economically feasible locations for future timber harvest 

with the least impact to roadless characteristics. Additional small-scale timber harvest opportunities are 

provided by the designation of Community Priority3 ARAs for Hydaburg, Juneau, Kake, Ketchikan, Sitka, 

Wrangell, and Yakutat.

Alternative 3 designates 8.22 million acres as ARAs. It removes approximately 1.25 million acres from 

roadless designation including both development and non-development LUD acres, and adds 107,000 

acres to ARAs including unroaded small islands and unroaded areas greater than 5,000 acres as 

identified by prior forest planning efforts. Adding additional roadless designations to unroaded islands 

provides for continued recreational and outfitter and guide opportunities on these islands. 

Alternative 3 applies the most protective ARA, Watershed Priority, to 3.26 million acres primarily identified 

as T77 Watersheds, TNC/Audubon Conservation Priority Areas, and high-priority sockeye salmon 

watersheds. The Watershed Priority ARA is considered most protective because it includes fewer 

exceptions than the 2001 Roadless Rule, while still allowing activities needed for fisheries protection, 

maintenance, or improvement. The remaining roadless areas include 4.60 million acres in Roadless 

Priority and 0.37 million acres in Community Priority (see Map 3 in map packet or on thumb drive). 

Additionally, for Alternative 3, commercial old-growth timber harvest would be prohibited on NFS lands in T77 

Watersheds, and TNC/Audubon Conservation Priority Areas, including those that extend beyond ARA 

boundaries.

Alternative 3 proposes a net decrease of 1.14 million roadless acres, as compared to the no action 

alternative, and includes both development and non-development LUDs. Roadless area designation 

would be removed from the 847,000 congressionally-designated LUD II acres that are currently within an 

IRA. The removal of roadless designation from congressionally-designated LUD II acres represents the 

majority of the decrease in designated roadless acres proposed under Alternative 3. Removing roadless 

designation from LUD II acres aligns with congressional intent that LUD II areas be managed “in a 

roadless state to retain their wildland character” (USDA Forest Service 2016a).

Alternative 3 would revert a net of 85,000 old-growth acres and 15,000 young-growth acres, previously 

identified as unsuitable timber lands, to suitable timber lands, as they were when the roadless rule did not 

apply to the Tongass.

3 Timber harvest in Community Priority ARAs would be limited to micro sales, salvage sales, and small commercial sales less than 

one MMBF in size.
Executive Summary

Final EIS ES-10 Executive Summary

Alternative 4

Alternative 4 provides additional timber harvest opportunity while maintaining roadless designations for 

Scenic Viewsheds and T77/TNC-Audubon Conservation Priority Areas that are in roadless areas. 

Approximately 401,000 acres are removed from roadless designation, including substantially-altered 

areas and logical extensions of substantially-altered acres (similar to Alternatives 2 and 3), along with 

selected additional locations for economic timber sales. Protection is maintained for Scenic Viewsheds, 

and most T77 Watersheds and TNC/Audubon Conservation Priority Areas by designating them as 

Roadless Priority ARAs. 

Additionally, Alternative 4 adds 7,000 acres as LUD II Priority ARA. These added roadless acres are LUD 

II areas that were not designated as IRA under the 2001 Roadless Rule. No additional lands would be 

added to ARAs.

The net result of removals and additions under Alternative 4 is 8.98 million roadless acres, which are 

designated into three categories of ARAs: LUD II Priority, Roadless Priority, and Timber Priority (see Map 

4 in map packet or on thumb drive). This alternative was developed to provide for a high level of timber 

management opportunities thus, timber management is allowed in the Timber Priority ARA, which 

consists of the Timber Production and Modified Landscape LUDs, as identified in the Forest Plan.

Alternative 4 proposes a net decrease of 394,000 roadless acres as compared to the no action 

alternative. However, the net increase in suitable timber lands is substantially higher than expected based 

on the decrease in roadless acres alone. This is because the Timber Priority ARA acres produce a large 

component of suitable timber. 

Under Alternative 4, a net of 161,000 old-growth acres and 15,000 young-growth acres previously 

identified as unsuitable timber lands would revert to suitable timber lands, as they were when the 

roadless rule did not apply to the Tongass.

Alternative 5 

Alternative 5 provides maximum additional timber harvest opportunity by removing all Timber

Development, Modified Landscape, and Scenic Viewshed LUDs identified by the Forest Plan from 

roadless designation, including T77 Watersheds and TNC/Audubon Conservation Priority Areas within 

aforementioned development LUDs. Areas with mineral potential, as identified by the Forest Plan’s 

minerals overlay, are also removed from roadless designation (see Map 5 in map packet or on thumb 

drive).

Alternative 5 would designate 7.05 million acres as ARAs. About 2.32 million acres would be removed from 

roadless area designation including mineral overlay acres and the majority of development LUDs including 

T77 Watersheds and TNC/Audubon Conservation Priority Areas. The 7.05 million roadless acres are 

designated to two ARAs: LUD II Priority (0.85 million acres) and Roadless Priority (6.20 million acres) (see 

Map 5 in map packet or on thumb drive). Alternative 5 also reverts a net 168,000 old-growth acres and 17,000 

young-growth acres previously identified as unsuitable timber lands to suitable timber lands, as they were 

when the roadless rule did not apply to the Tongass.

Alternative 6 (Preferred Alternative)

Alternative 6 is the preferred alternative and provides maximum additional timber harvest

opportunities as the full exemption alternative, which was requested by the State of Alaska’s petition 

(Appendix A). It removes all 9.37 million inventoried roadless acres on the Tongass from roadless 

designation. Acres removed from roadless designation would continue to be managed in accordance with 

statutory mandates and by the Forest Plan (see Map 6 in map packet or on thumb drive). Existing 

protections to roadless characteristics provided by Forest Plan non-development LUDs (including LUD II, 

Remote Recreation, Semi-remote Recreation, Old-growth Habitat, Special Interest Area, Wild River, 

Scenic River, and others) would remain in place.
Executive Summary

Final EIS ES-11 Executive Summary

Alternative 6 would revert a net total of 168,000 old-growth acres and 20,000 young-growth acres 

previously identified as unsuitable timber lands to suitable timber lands, as they were when the roadless 

rule did not apply to the Tongass. Table 2-8 summarizes the key elements of Alternative 6.

Maps

Large-scale color maps showing roadless areas by IRA or ARA (Map 1 to 6) are included on the thumb 

drive version of the FEIS, in the map packet that accompanies the FEIS paper copy, and on this project’s 

website: https://www.fs.usda.gov/project/?project=54511. Additional maps showing the lands that would 

be suitable for timber production (Maps 7 to 12) and the lands that would be suitable for timber production 

by certain outfitter/guide use areas (Maps 13 to 18) are included on the thumb drive and website. Maps 

showing lands suitable for timber production by community use area for each alternative are included in 

Appendix D on the thumb drive and website.

Comparison of the Alternatives

This section compares the environmental consequences of the six alternatives with respect to the 

significant issues described in Chapter 1. This comparison is based on the effects analyses presented in 

Chapter 3. For reference, Table ES-2 summarizes the acres by ARA, the acres removed or added from 

inventoried roadless, and the total old-growth acres that are suitable for timber production under 

Alternative 1 and the five action alternatives. Figure ES-1 displays the ARAs by alternative and 

management designation.

Table ES-2

Roadless Areas by Alternative and Management Designation

Roadless Designation 

(acres)

Alternative

1 2 3 4 5 6

No Action

Roaded 

Roadless

Logical 

Extension

Partial 

Dev. LUDs1

All Dev. 

LUDs

Full 

Exemption

Total Roadless Area 9,368,000 9,336,000 8,224,000 8,975,000 7,047,000 0

ARA Management Designations

LUD II Priority N/A 854,000 0 854,000 847,000 0

Watershed Priority N/A 3,284,000 3,259,000 0 0 0

Roadless Priority N/A 5,199,000 4,595,000 7,363,000 6,200,000 0

Community Priority N/A 0 370,000 0 0 0

Timber Priority N/A 0 0 757,000 0 0

Change in Roadless Area Acres

Roadless Area Removed 0 142,000 1,252,000 401,000 2,321,000 9,368,000

Roadless Area Added 0 110,000 107,000 7,000 0 0

Net Change 0 -32,000 -1,144,000 -394,000 -2,321,000 -9,368,000

Old-Growth Acres Suitable for Timber Production

Total Acres 227,000 247,000 312,000 388,000 395,000 395,000

Net Change 0 20,000 85,000 161,000 168,000 168,000

T77 & TNC/ Audubon Conservation Priority Areas Outside of Roadless given Long-term Regulatory 

Protection

Total Acres 0 0 507,000 0 0 0

1 Includes Timber Production and Modified Landscape LUDs, but not Scenic Viewshed.

N/A = not applicable

Note: Numbers may not appear to sum correctly due to rounding.
Executive Summary

Final EIS ES-12 Executive Summary

Figure ES-1

Roadless Areas by Alternative and Management Designation

Key Issue 1 – Roadless area conservation

Roadless area conservation is analyzed in terms of both the acres designated as roadless and the 

degree of protection provided by each alternative. In terms of acres designated, Alternatives 1 and 2 

provide the highest degree of regulatory protection with approximately 9.37 million acres designated as 

roadless and Alternative 6 provides the lowest with zero acres of designated roadless areas. Alternative 5 

removes all regulatory roadless designations within development LUDs4 and has the second lowest 

number of acres designated roadless with 7.05 million acres.

Alternatives 3 and 4 are intermediate in terms of the acres designated as roadless. However, the roadless 

designations provided in development LUDs by Alternative 4 are lower than for Alternative 3 because all 

Timber Priority ARA lands under Alternative 4 are in development LUDs and Alternative 3 would 

designate T77 Watersheds, TNC/Audubon Conservation Priority Areas, and high-priority sockeye salmon 

watersheds as Watershed Priority ARAs. In addition, the removal of roadless designation from LUD II

acres accounts for a large share of the reduction in designated roadless area acres under Alternative 3. 

These acres would retain their specific statutory protections and be managed to preserve roadless area 

characteristics (Table 2-10). Therefore, protection of roadless characteristics is much greater under 

Alternative 3 compared with Alternative 4.

The roadless rule language under Alternative 1 would be unchanged from the 2001 Roadless Rule (as 

reinstated by the District Court). Under Alternative 6, the Tongass would be fully exempted from the 2001 

Roadless Rule. The rule language would be modified under Alternatives 2, 3, 4, and 5.

The Roadless Priority and LUD II Priority management categories would be very slightly more permissive 

than Alternative 1 in terms of road construction, salvage timber harvest, and mineral development, and 

would be slightly more permissive in terms of energy and transportation project development. The 

Watershed Priority ARA would be slightly less permissive relative to timber harvest, road construction, 

and other developments and the Community Priority and Timber Priority categories under Alternatives 35

4 Note that, with the exception of the Timber Priority ARA designation, roadless designation on development LUDs provides more

protection for these areas, because development LUDs are areas most likely to be developed if they were not designated roadless. 

Most non-development LUDs have Forest Plan direction which limits their potential for development.

5 Timber harvest in Community Priority ARAs would be limited to micro sales, salvage sales, and small commercial sales less than 

one MMBF in size.

0

1,000

2,000

3,000

4,000

5,000

6,000

7,000

8,000

9,000

10,000

Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

Roadless Acres (1,000)

2001 Roadless Rule Roadless Priority LUD II Priority

Watershed Priority Community Use Priority Timber Priority
Executive Summary

Final EIS ES-13 Executive Summary

and 4, respectively, would be substantially more permissive of development, especially timber harvest 

and road construction.

As a result, Alternatives 1, 2, and 3 would provide the greatest protection of roadless characteristics.

Alternative 1 would protect the most acres and existing management direction would provide the highest 

degree of protection, with the existing general prohibitions remaining in place for all areas. Alternative 2 

would offer similar levels of protection. The roaded roadless and other substantially altered areas that 

would be removed under Alternative 2 have limited roadless characteristics, and increased regulatory 

protection would be added for the Watershed Priority ARA. Alternative 3 would offer the next most 

protection of roadless area characteristics. Roaded roadless and other substantially altered areas along 

with logical extension areas would be removed under Alternative 3 (as well as LUD II areas), and most 

ARAs would be managed as Roadless Priority or Watershed Priority ARAs. Additionally, T77 Watersheds 

and TNC/Audubon areas outside of roadless would be given regulatory protection from old-growth 

harvest. About 3 percent of ARAs under Alternative 3 would be designated as Community Priority, which 

allows limited timber harvest opportunity. Alternatives 4 through 6 would provide the least amount of 

roadless designations, with Alternative 6 removing all acres from regulatory roadless designation.

Key Issue 2 – Support local and regional socioeconomic 

well-being, Alaska Native culture, rural subsistence activities, 

and economic opportunity across multiple economic sectors.

Support for Southeast Alaska resource-based industries and local/regional socioeconomic well-being is 

compared among the alternatives by industry/category in the following subsections.

Forest Products Industry

The Forest Plan, as amended in 2016, established an average annual Projected Timber Sale Quantity 

(PTSQ) of 46 MMBF prior to the young-growth transition. The old-growth contribution to the PTSQ is 

expected to start out high and decrease over time as more young growth becomes economic to harvest. 

During the first decade, an average of about 12 MMBF of young growth and 34 MMBF of old growth was 

expected to be sold annually. From Year 11 through Year 15 an average of about 28 MMBF of young 

growth and 18 MMBF of old growth were expected to be sold annually. Old-growth volume offered was 

projected to decrease until it reaches 5 MMBF per year (expected to occur about Year 16), at which point 

it is to be stabilized at 5 MMBF per year to support small operators and specialty products such as wood 

for musical instruments. Young growth sales are expected to continue to increase at a rapid rate after 

Year 16 and are expected to reach an upper limit of 98 MMBF about Year 18. If less than the average 

annual PTSQ figure of 46 MMBF is sold in the early years of a decade, the Forest Plan allows the 

difference to be added to the sale quantity for the remainder of the decade. During the initial two years of 

implementing the Forest Plan, the total volumes sold were 30.7 MMBF (Fiscal Year 2017) and 9.0 MMBF 

(Fiscal Year 2018). 

None of the action alternatives would result in changes to the PTSQ and the timber objectives of the 

Forest Plan would continue to require transitioning to primarily young-growth harvest. Harvest levels are 

not expected to vary significantly among the alternatives. However, the alternatives do vary in terms of 

the amount and location of acres of land suitable for timber production. Greater total acreage of suitable 

land would provide greater flexibility in the selection of future timber sale areas, as well as the potential 

for more flexibility in sale design, depending on the planning areas selected. This improved flexibility 

could, in turn, improve the Forest Service’s ability to offer economic sales that meet the needs of industry. 

This greater flexibility could be beneficial during the first two decades of the 2016 Forest Plan (the 

transition period), when most old-growth harvest would take place.

Under Alternative 1, about 227,000 acres of old growth and 334,000 acres of young growth are currently 

suitable for timber production. The young-growth suitable acres would increase slightly (3 through 6 

percent) under the action alternatives. For old growth, however, the suitable acreage increase would 

range from 7 percent for Alternative 2 to 74 percent for Alternatives 5 and 6. For Alternatives 3 and 4 the 

increase would be 37 percent and 71 percent, respectively. It should be noted that harvest levels and 
Executive Summary

Final EIS ES-14 Executive Summary

road construction are not expected to change significantly among the alternatives, although harvest and 

road locations would be more widespread as suitable acres increase. 

The additional suitable old-growth acres are comprised of lands fitting into three broad categories or 

areas: roaded roadless and other substantially altered areas (Alternatives 2 through 6); logical extension 

areas and areas adjacent to roads (Alternatives 3 through 6); and areas more distant from existing roads 

(Alternatives 4 through 6). In addition, suitable old-growth acres would be added in Community Priority 

ARAs, which are associated with seven communities (Alternative 3).6 The substantially altered areas 

removed, the areas immediately adjacent (logical extensions), and the Community Priority ARAs are 

assumed to be more economical to harvest due to their proximity to existing infrastructure. The additional 

acres added under Alternatives 4 through 6 are farther from existing infrastructure and thus less likely to 

be economic to harvest.

Recreation and Tourism

Timber harvest and road construction projects within roadless areas have the potential to affect 

outfitter/guide operations which provide recreation opportunities on the Forest and are often dependent 

on high scenic integrity and undisturbed landscapes. Development projects permitted as a result of 

changes in roadless area designations could also affect outfitter/guide use in other adjacent or nearby 

areas as outfitter/guides displaced from one location seek other places to take clients. Some use areas 

are presently at capacity, which could exacerbate potential displacement effects. The Forest’s ability to 

meet outfitter/guide demand, especially for operators seeking more remote areas, could also be affected.

The outfitter/guide analysis prepared for this EIS used changes in suitable old-growth acres in conjunction 

with information about existing outfitter/guide use to focus on potentially affected areas. The resulting 

analysis identified 15 outfitter/guide use areas where potential conflicts between existing outfitter/guide 

use and future management activities could occur. In most of these areas, existing outfitter/guide use 

occurs near areas where development has occurred, either near or along shorelines and/or Forest road 

systems. Similarly, in most cases, timber harvest that could already occur in these areas (under 

Alternative 1) has the potential to conflict with existing outfitter/guide use. Viewed in terms of increases in 

acres suitable for harvest, impacts under Alternatives 2 and 3 would be nonexistent to very minimal in all 

areas, with increases in designated roadless acres and reductions in suitable acres occurring in some 

areas under these alternatives. By expanding the acres available for harvest, Alternatives 4, 5, and 6 

could in some cases add to these potential impacts by increasing the geographic extent of the acres 

affected, which could also result in an increase in road miles.

Commercial Salmon Harvesting and Processing

None of the alternatives are expected to significantly affect the commercial fishing or fish-processing 

industries. Riparian Management standards and guidelines established in the Forest Plan would remain 

in place under all of the alternatives. While there would be some variation in the level of protection, these 

variations are not expected to affect the commercial fishing industry. The future of the commercial fishing 

industry in Southeast Alaska is more likely to depend upon occurrences outside of the Tongass National 

Forest such as hatchery production, offshore harvest levels, and changes in ocean conditions (USDA 

Forest Service 2016b).

Mining and Mineral Development

Locatable minerals development is possible within designated roadless areas under all alternatives. The 

General Mining Act of 1872 authorizes and governs prospecting and mining for locatable minerals on 

NFS lands, including designated roadless areas. Changes in roadless management are, therefore, not 

expected to affect existing or future locatable mineral exploration or mining activities on the Forest.

Under the 2001 Roadless Rule roadbuilding is prohibited for any new leasable mineral projects, including 

geothermal projects, within IRAs. Changes in management under Alternatives 2 to 6 would allow road 

development to differing degrees. Within Timber Priority ARAs, roads would be permissible for leasable 

6 Timber harvest in Community Priority ARAs would be limited to micro sales, salvage sales, and small commercial sales less than 

one MMBF in size.
Executive Summary

Final EIS ES-15 Executive Summary

projects. The Tongass has no recent or current leasable mineral activity and the demand for leasable 

minerals is expected to remain low. As a result, changes in designated roadless management are 

expected to have limited impacts on mineral development. Geothermal energy projects could be allowed 

in Roadless Priority and Community Priority ARAs under exceptions provided for community utility 

projects.

Infrastructure Development

With some exceptions, discretionary federal road development is limited in IRAs. Examples of exceptions 

include roading pursuant to reserved or outstanding rights, roads provided for by statute or treaty, or a 

qualified Federal Aid Highway. Roadless designation would be removed to various degrees under the 

action alternatives with corresponding implications for regional highway development. In most cases, the 

alternative rules would be more permissive with respect to regional road systems.

Tree Harvest for Alaska Native Cultural Purposes

Tree harvest for Alaska Native cultural purposes is allowed under the 2001 Roadless Rule (Alternative 1) 

but road access for the tree harvesting is not. Alternatives 2, 3, 4, and 5 do support Alaska Native culture 

through explicit rule language that allows increased access to cutting, customary trade, and removal of 

trees for the purposes of Alaska Native customary and traditional uses. This increased access is provided 

in the Roadless and Community Priority ARAs. Access for cultural purposes in ARAs has benefits but 

access as a result of removing roadless area designations or designating them as Timber Priority ARAs 

may increase competition with the timber industry for trees to be used for traditional or cultural purposes, 

and this competition is the greater concern of the Tribes. 

Based on this rationale, Alternatives 2 and 1 would appear to be best overall, because of the relatively 

low level of competition with commercial timber harvest they would create. Alternative 2 would rank higher 

than Alternative 1 because they are almost the same in terms of competition and Alternative 2 includes 

over 5 million acres of Roadless Priority, which would improve access relative to the 2001 Roadless Rule. 

Alternatives 4 and 3 would rank in the middle overall. Alternative 4 would rank higher than Alternative 3 

because they are very similar in terms of acres opened up for competition, but Alternative 4 includes over 

7 million acres of Roadless Priority while Alternative 3 includes less than 5 million acres in Roadless and 

Community Priority ARAs, combined. Alternatives 5 and 6 would allow road construction for access to 

Alaska Native cultural sites, but would also allow the most access for commercial timber harvest and 

other competing uses, which would outweigh the benefits. Potential conflicts between competing uses 

under Alternatives 5 and 6 would primarily be limited to areas managed as development LUDs. 

Rural Subsistence Activities 

Potential effects on rural subsistence activities (harvest and use of natural resources for food, shelter, 

clothing, transportation, handicrafts, and trade) are expected to be similar to the current Forest Plan 

under all of the action alternatives, with similar effects anticipated with respect to abundance and 

distribution, access, and competition. Timber harvest levels are expected to remain the same for all 

alternatives, with similar or only slightly different miles of road construction/reconstruction also 

anticipated. While there would be some new road access under all alternatives in the long run, nearly all 

new roads constructed under the alternatives would be closed following harvest based on past harvest

practices. These roads would, therefore, not be available for use by highway vehicles or high-clearance 

vehicles. They may, however, be available for access by other methods and could, as a result, have the 

potential to affect existing subsistence patterns. Although overall road miles would be similar, based on 

the relative distribution of acres suitable for timber production, road miles are expected to be slightly 

higher for Alternatives 4, 5, and 6. The effects on particular groups of subsistence users or resources are 

difficult to predict at the programmatic level, but the slight difference in road miles is expected to result in 

little to no difference to rural subsistence activities between alternatives.

Community Effects 

Relative to Alternative 1, no major community effects would be expected under the action alternatives. 

The largest degree of change would be expected under Alternatives 4, 5, and 6 because these 
Executive Summary

Final EIS ES-16 Executive Summary

alternatives would result in larger increases in suitable timber (and potential harvest) within many 

community use areas, especially in those that are more remote (see Appendices D and E).7 

Communities with economies that benefit from timber harvest or seek increased roaded access could see 

some modest benefits, but communities with economies that are dominated by the visitor industry have 

expressed concerns (see Table E-2 in Appendix E). Based on an evaluation of employment and business 

licenses by community, along with the amount of suitable timber within community areas (which serves as 

an index to potential timber harvest), the following observations can be made:

Alternatives 1 and 2 are expected to generally result in very little to no effect on communities. 

However, because this EIS is programmatic in nature, the direct effects associated with project 

activities on any community cannot be identified until specific projects are proposed.

Alternative 3 is expected to have very minimal potential for community effects, either adverse or 

beneficial. Community Priority ARAs in this alternative may be beneficial to communities by 

increasing flexibility for the communities adjacent to designated roadless areas. 

Alternatives 4, 5, and 6 (especially Alternatives 5 and 6) have an increased potential for effects on 

communities relative to the other alternatives, especially in those communities where the visitor 

industry sector is important. This is primarily because those communities rely on undisturbed 

landscapes, which in turn may affect visitor use. The smaller and less economically diversified 

communities have a greater risk of effects. In addition, communities influenced by the timber industry

may experience minor beneficial effects resulting from flexibility for timber harvest. Because of the 

programmatic nature of this EIS, the effects on any community cannot be identified until specific 

projects are proposed, but it is expected that they would range from no effect to a minimal effect for 

these alternatives.

Key Issue 3 – Conserve terrestrial habitat, aquatic habitat, 

and biological diversity

Old-Growth Habitat

Relative to old-growth habitat conservation, all of the alternatives would have old-growth harvest levels 

similar to the level authorized by the Forest Plan. There may be slightly more high-volume and large-tree 

productive old growth (POG) harvested under the action alternatives than was predicted for the Forest 

Plan because of the increased options for developing economic timber sales. However, this is speculative 

and depends on harvest levels reaching predicted decadal levels, as well as on being able to 

economically access these stands. In addition, the proportion of high-volume and large-tree POG in the 

added suitable acres under the action alternatives is lower than the proportion in the Alternative 1 suitable 

acres. 

The transition to young-growth management would continue to slow the long-term decrease in deer 

habitat capability due to the reduction in POG harvest, under all of the alternatives. Because long-term 

POG harvest and road densities are not expected to differ significantly among alternatives, effects on oldgrowth–dependent wildlife species are expected to be almost identical to those predicted under the 2016 

Forest Plan Amendment EIS.

Young Growth in Special Habitats

Young growth suitable for timber harvest occurs in a number of habitats under the Forest Plan, including 

Riparian Management Areas, Beach and Estuary Fringe, and the Old-growth Habitat LUD. Young growth on 

specific portions of these areas may be harvested using required silvicultural prescriptions following Forest 

Plan direction. The suitable acres of young growth on these special habitats would increase slightly under 

the action alternatives, but only slightly because the majority of existing young-growth stands are not in

designated roadless areas. Therefore, little to no difference in effects among the alternatives is expected.

7 Appendix D presents suitable old-growth and young-growth timber maps for the community use areas identified for the 32 

communities evaluated in this EIS (see Appendix E). These maps are available electronically only. They are included on the thumb 

drive accompanying this document and are also available online at: https://www.fs.usda.gov/project/?project=54511
Executive Summary

Final EIS ES-17 Executive Summary

Road Density

Slightly more road miles would be developed under the action alternatives with more acreage removed from 

roadless. Under current conditions approximately 4,929 miles of road (including decommissioned road) exist 

on the Tongass and the average road density is approximately 0.19 mile per square mile. Under 

Alternatives 1 and 2, total road miles after 100 years would equal about 5,922, while total road miles under 

Alternative 6 would equal about 5,972. The other action alternatives would range from 5,941 to 5,968 miles 

after 100 years. The overall road density on the Tongass would be approximately 0.23 under all of the 

alternatives. At present approximately 68 percent of 6th field subwatersheds on the Tongass have no roads. 

After 100 years, this percentage would drop to 62 percent for Alternative 1, 61 percent for Alternative 2, 60 

percent for Alternative 3, 58 percent for Alternatives 4 and 5, and 56 percent for Alternative 6. This pattern 

would be reversed for watersheds with existing high road densities, although differences would be slight. 

For example, 0.6 percent of the watersheds would have road densities greater than 3 miles per square mile 

under Alternatives 1 and 2, but 0.5 percent of the watersheds would have densities this high under 

Alternatives 3, 4, 5, and 6 (due to roads being more spread out).

Fish Habitat

Overall effects to fish habitat are expected to be negligible under all alternatives, because of the strong 

protections to fish habitats provided by Forest Plan LUDs, Forest-wide standards and guidelines including 

the riparian management strategy, and the lack of old-growth harvest or associated road construction 

allowed in the T77 watersheds and TNC/Audubon Conservation Priority Areas. Alternative 3 provides 

additional long-term regulatory protection for T77 watersheds and TNC/Audubon Conservation Priority 

Areas by prohibiting old-growth harvest by regulation. Localized effects on fish habitat may occur, but these 

are expected to be minimal overall.

Species-Specific Effects

The transition to young-growth management would continue to slow the long-term decrease in deer 

habitat capability due to the reduction in POG harvest, under all of the alternatives. Because long-term 

POG harvest and road densities are expected to be similar to those under the Forest Plan, effects on oldgrowth dependent or associated wildlife species are expected to be almost identical to those predicted by 

the 2016 Forest Plan Amendment EIS.
Executive Summary

Final EIS ES-18 Executive Summary

This page intentionally left blank.
CHAPTER 1

PURPOSE OF AND NEED

FOR ACTION
Purpose of and Need for Action 1

Final EIS 1-1 Purpose of and Need for Action

Chapter 1

Purpose of and Need for 

Action

The Forest Service has prepared this final environmental impact statement (FEIS) in compliance with the 

National Environmental Policy Act (NEPA) and other relevant federal laws and regulations8. This FEIS 

discloses the potential environmental consequences that may result from the alternatives considered for 

the proposed Alaska Roadless Rule.

Background

Inventoried Roadless Areas (IRAs) on the on the 16.7-million acre Tongass National Forest (Tongass) 

include 9.37 million acres (56 percent of the Tongass) across 110 IRAs. When these designated roadless 

areas are combined with Wilderness and National Monument areas, the Tongass is currently more than 

90 percent undeveloped and unavailable for timber harvest and road building. Regardless of Forest Plan 

land use designation, much of the forest is protected by regulation as National Monuments, Wilderness, 

or LUD II lands (Figure 1-1). Developed areas cover about 1.3 million acres, or about 8 percent, of the 

Tongass. Southeast Alaska residents (approximately 73,000) are, for the most part, surrounded by largely 

undeveloped land. 

Several portions of the Tongass constitute contiguous IRAs exceeding 1 million acres, and thus represent 

large, unfragmented wildlife habitats and opportunities for solitude. Many of the Tongass IRAs represent 

wildlife habitats, ecosystems, and visual characteristics, such as coastal islands facing the open Pacific, 

extensive beaches on inland saltwater, old-growth temperate rain forests, ice fields, and glaciers that 

exist nowhere else in the National Forest System (NFS). Many of these areas are remote and difficult to 

access for recreation and contain other resources, such as timber, minerals, renewable energy 

opportunities, and salmon-producing streams. While IRAs provide a large portion of the land base in 

Southeast Alaska, National Parks, National Monuments, and designated Wildernesses also contribute to 

the undeveloped nature of the region.

The Roadless Area Conservation Rule (2001 Roadless Rule) was promulgated in January 2001 (66 

Federal Register [FR] 3244). Currently, about 9.37 million acres (56 percent) of the Tongass National 

Forest (hereafter Tongass or Forest) are designated as “inventoried roadless areas” (IRAs).9 Maps of 

IRAs, for the Tongass, are available online here.10 IRAs contain generally undeveloped areas that are 

typically 5,000 acres or greater in size. The 2001 Roadless Rule applies nationwide (except Idaho and 

Colorado), and currently provides management direction for IRAs on 44.7 million acres of National 

Forests (approximately 24 percent of total National Forest System [NFS] lands) by prohibiting road 

construction and reconstruction and timber cutting, sale, or removal in those IRAs, with certain 

exceptions.

8 On September 14, 2020, the Council on Environmental Quality’s revised NEPA regulations became effective (see 85 FR 43304). 

Those regulations apply to NEPA processes begun after September 14, 2020 (40 CFR 1506.13). While agencies may apply CEQ’s 

revised regulations to ongoing activities and environmental documents begun before September 14, 2020, the Forest Service has

elected to complete this NEPA process using the prior regulations, recognizing that where existing agency NEPA procedures are 

inconsistent with CEQ’s revised regulations CEQ’s revised regulations govern unless there is a clear and fundamental conflict with 

the requirements of another statute.

9 The original acreage of inventoried roadless areas on the Tongass was approximately 9.34 million acres. As a result of ownership 

changes and boundary alignment corrections noted during this rulemaking, including shoreline mapping adjustments, the actual 

acreage is 9.37 million acres.

10 https://www.fs.usda.gov/detail/roadless/2001roadlessrule/maps/statemaps/?cid=fsm8_037699
Purpose of and Need for Action 1

Final EIS 1-2 Purpose of and Need for Action

Figure 1-1

Areas Protected by Regulation and Administrative Designation within the Tongass
Purpose of and Need for Action 1

Final EIS 1-3 Purpose of and Need for Action

Since its promulgation, the 2001 Roadless Rule has been the subject of litigation. In 2001, the State of 

Alaska filed a complaint, challenging the U.S. Department of Agriculture’s (USDA) promulgation of the 

2001 Roadless Rule and its application in Alaska. The USDA and the State of Alaska reached a 

settlement in 2003, and the USDA subsequently issued a rule temporarily exempting the Tongass from 

the 2001 Roadless Rule. In 2011, a federal court (District of Alaska) set aside the Tongass’s exemption 

and reinstated the 2001 Roadless Rule on the Tongass (with special instructions). The Alaska District 

Court’s ruling was initially reversed by a three-judge panel of the Ninth Circuit, but the District Court’s 

ruling was ultimately upheld in a 6–5 en banc ruling of the Ninth Circuit in 2015. In September 2017, the 

District Court for the District of Columbia rejected all procedural and substantive claims that the 2001 

Roadless Area Conservation Rule was unlawfully promulgated, both nationally and as applied to Alaska. 

Alaska appealed the District Court’s ruling to the Court of Appeals for the District of Columbia Circuit. On 

September 26, 2018, the D.C. Circuit ordered the appeal be held in abeyance following USDA’s 

acceptance of Alaska’s Petition for Rulemaking and directed that status reports be filed with the court 

every 90 days. Consequently, the 2001 Roadless Rule remains in effect in Alaska and the Forest Service 

continues to apply the 2001 Roadless Rule to the Tongass and Chugach National Forests.

In January 2018, the State of Alaska submitted a petition (Appendix A) requesting that the Secretary of 

Agriculture consider exempting the Tongass from the 2001 Roadless Rule, pursuant to the Administrative 

Procedure Act and the USDA’s petition procedures in 7 CFR 1.28. In June 2018, the Secretary of 

Agriculture directed the Forest Service to begin working to develop an Alaska state-specific roadless rule. 

In August 2018, the Forest Service granted cooperating agency status to the State of Alaska. The Forest 

Service and the State of Alaska believed that the rulemaking represented a unique opportunity to 

collaboratively address and provide certainty to the roadless issue in the Tongass. The Forest Service 

published a Notice of Intent (NOI) to prepare an environmental impact statement (EIS) and initiate a 

public rulemaking process to address the management of IRAs on the Tongass on August 30, 2018 (83 

FR 44252). As stated in the NOI, USDA desires a durable and long-lasting solution for the management 

of roadless areas in Alaska on the Tongass. The state-specific roadless rule identified in the preferred 

alternative would discontinue the existing regulation’s prohibitions and instead rely upon existing statutory 

and management plan direction for managing roadless areas on the Tongass.

No alternative examined in this FEIS would authorize any ground-disturbing activities. Before authorizing 

a land-use activity in roadless areas, the Forest Service must complete a site-specific environmental 

analysis, pursuant to the NEPA and its implementing regulations. When a specific project or activity is 

proposed on NFS land, the Forest Service conducts site-specific analyses of the effects associated with 

that project or activity and makes a decision whether or not to authorize implementation of that project or 

activity.

Analysis Area

The 16.7-million-acre Tongass comprises approximately 7 percent of Alaska and 80 percent of percent of 

Southeast Alaska – Alaska’s southeastern panhandle extending from the Dixon Entrance in the south to

Yakutat Bay in the north, and bordered on the east by Canada and on the west by the Gulf of Alaska. The 

Tongass extends approximately 500 miles north to south, and approximately 120 miles east to west at its 

widest point. Figure 1-2 is a vicinity map of the Forest.

The Tongass includes a narrow mainland strip of steep, rugged mountains, and icefields and more than 

1,000 offshore islands known as the Alexander Archipelago. Together, the islands and mainland have 

nearly 11,000 miles of meandering shoreline, with numerous bays and coves. A system of seaways 

separates the many islands and provides a protected waterway called the Inside Passage. Federal public 

lands comprise approximately 95 percent of Southeast Alaska, with about 80 percent in the Tongass and 

the majority of the remaining lands in Glacier Bay National Park and Preserve. The remaining land is held 

by the State government, Alaska Native corporations, and other private ownerships. Most of the area of 

the Tongass is undeveloped. Approximately 73,000 people inhabit Southeast Alaska, primarily in 32 

communities plus 2 seasonal communities located on islands or mainland coastal areas. Eight of the 

communities have populations greater than 1,000 persons. Most of these communities are surrounded 

by, or adjacent to, NFS land. Three communities are connected to other parts of the mainland by road: 

Haines and Skagway in the north and Hyder in the south.
Purpose of and Need for Action 1

Final EIS 1-4 Purpose of and Need for Action

Figure 1-2

Tongass National Forest Vicinity Map
Purpose of and Need for Action 1

Final EIS 1-5 Purpose of and Need for Action

Purpose and Need

In response to the State of Alaska’s petition for rulemaking, a long-term, durable approach to roadless 

area management is desired that accommodates the unique biological, social, and economic situation 

found in and around the Tongass. The Tongass is unique from other national forests with respect to size, 

percentage of IRAs, amount of NFS lands and subsequent dependency of 32 communities on federal 

lands (the Tongass comprises almost 80 percent of Southeast Alaska), and unique Alaska and Tongassspecific statutory considerations (e.g., Alaska National Interest Lands Conservation Act [ANILCA]), 

Tongass Timber Reform Act [TTRA]). In ANILCA, Congress sought to balance national environmental 

interests with “adequate opportunity for satisfaction of the economic and social needs of the State of 

Alaska and its people” (16 U.S.C. §3101(d), Sturgeon v. Frost, 139 S.Ct. 1066, 1075).

The USDA and Forest Service believe the 2001 Roadless Rule prohibitions on timber harvest and road 

construction/reconstruction can be adjusted for the Tongass in a manner that meaningfully addresses 

local economic and development concerns and roadless area conservation needs. 

The State of Alaska believes that roadless conservation interests for the Tongass can be adequately 

protected under the Tongass Forest Plan and that the 2001 Roadless Rule prohibitions are unnecessary. 

In addition, the State believes application of the 2001 Roadless Rule substantially impacts the social and 

economic fabric of Southeast Alaska and violates ANILCA and TTRA.

In response to the State’s petition, commercial and non-profit organizations have expressed strong 

opinions, for and against, the idea of a regulatory review. 

Proposed Action

The NEPA process begins with a proposed action; in this case the State of Alaska’s petition to remove 

the Tongass National Forest from application of the 2001 Roadless Rule. The rule would discontinue the 

existing regulation’s prohibitions and instead rely upon existing statutory and management plan direction 

to manage roadless area characteristics on the Tongass.

Decision Framework

This FEIS examines environmental, social, and economic consequences in order to inform USDA’s 

judgment in deciding whether to promulgate a regulatory exception for the Tongass as proposed by the 

State, or one of the other alternatives, or a combination or variation of the alternatives analyzed by the 

FEIS. Any new final regulation would be issued under 36 CFR Part 294, Subpart E. Appendix G, Drafted 

Roadless Rule Regulatory Language by Alternative, contains draft regulatory language for each 

alternative.

Public Participation

The Forest Service published an NOI to prepare an EIS for the Alaska Roadless Rule in the Federal 

Register (83 FR 44252) on August 30, 2018. The NOI initiated a 45-day scoping period which ended on 

October 15, 2018. During this time period, the Forest Service conducted 17 public meetings including 

meetings in Anchorage, Alaska; Washington, DC; and communities throughout Southeast Alaska –

Angoon, Craig, Gustavus, Hoonah, Kake, Ketchikan, Petersburg, Point Baker, Sitka, Tenakee Springs, 

Thorne Bay, Wrangell, Yakutat, and two meetings in Juneau. During the scoping period, just over 

144,000 comment letters/emails were received. 

On October 17, 2019, the Department published a Notice of Proposed Rulemaking in the Federal 

Register (84 FR 55522) and on October 18, 2019 a Notice of Availability (NOA) for the DEIS was 

published (84 FR 55952). The publication of the NOA initiated a 60-day comment period ending on 

December 17, 2019. During the 60-day comment period, the Forest Service conducted 21 public 

meetings including Anchorage, Alaska; Washington, DC; and Southeast Alaska communities – Angoon, 

Craig, Gustavus, Haines, Hoonah, Hydaburg, Juneau, Kake, Kasaan, Ketchikan, Pelican, Petersburg, 

Point Baker, Sitka, Skagway, Tenakee Springs, Thorne Bay, Wrangell, and Yakutat. Approximately 

267,000 comment letters/emails were received during the 60-day comment period including 11 petitions 

containing about 117,000 signatures.
Purpose of and Need for Action 1

Final EIS 1-6 Purpose of and Need for Action

Tribal and Native Corporation Participation

On July 30, 2018, the Forest Service sent letters to 32 federally-recognized tribes and 27 Alaska Native 

corporations, within Southeast and Southcentral Alaska, initiating government-to-government and 

government-to-corporation consultation on the Alaska Roadless Rule. The following government-togovernment consultations have occurred in association with this rulemaking effort:

May 2, 2018 – Forest Service Government-to-Government consultation with Ketchikan Indian 

Community;

August 24, 2018 – Forest Service Government-to-Corporation consultation with the Chugach Alaska 

Corporation and Cook Inlet Region Incorporated;

September 5, 2018 – Forest Service Government-to-Government consultation with the Hoonah Indian 

Association;

September 12, 2018 – Forest Service Government-to-Government consultation with Ketchikan Indian

Community and Organized Village of Saxman;

September 12, 2018 – Forest Service Government-to-Government consultation with the Central 

Council Tlingit and Haida Indian Tribes of Alaska;

September 24, 2018 – Forest Service Government-to-Government consultation with Wrangell

Cooperative Association;

October 1, 2018 – Forest Service Government-to-Government consultation with Organized Village of 

Saxman;

November 15, 2018 – Forest Service Government-to-Government consultation with Organized Village 

of Kasaan;

December 14, 2018 – Forest Service Government-to-Government consultation with Organized Village 

of Kasaan, Prince of Wales Tribal Conservation District, Craig Tribal Transportation Staff, and 

Hydaburg Community Association;

May 6, 2019 – Forest Service Government-to-Government consultation with Sitka Tribe of Alaska.

November 2, 2019 – USDA Government-to-Government consultation Central Council Tlingit and 

Haida Indian Tribes of Alaska, Hoonah Indian Association, Hydaburg Cooperative Association, 

Ketchikan Indian Community, Klawock Cooperative Association, Organized Village of Kake, 

Organized Village of Kasaan, Organized Village of Saxman, and Skagway Traditional Council; and

April 28, 2020 – USDA Government-to-Government consultation with Central Council Tlingit and 

Haida Indian Tribes of Alaska, Hydaburg Cooperative Association, Organized Village of Kake, 

Organized Village of Kasaan, and Skagway Traditional Council.

Cooperating Agencies

The following are cooperating agencies for the Alaska Rulemaking process:

State of Alaska.

Angoon Community Association;

Central Council Tlingit and Haida Indian Tribes of Alaska;

Hoonah Indian Association;

Hydaburg Cooperative Association;

Organized Village of Kasaan; and 

The State of Alaska requested cooperating agency status for the Alaska rulemaking process on June 19, 

2018, and entered into an Memorandum of Understanding (MOU) on August 2, 2018. The State of Alaska 

is the petitioner for the rulemaking process and has special knowledge and expertise relative to natural 

resources, economic growth and development, resource planning, transportation, and other matters 

which may be affected by Forest Service management.
Purpose of and Need for Action 1

Final EIS 1-7 Purpose of and Need for Action

The State of Alaska’s input as a cooperating agency was informed by the Alaska Roadless Rule Citizens 

Advisory Committee (the Committee). In September 2018, Governor Walker issued Administrative Order 

299 to establish the Committee, which was charged with providing recommendations to assist the State in 

fulfilling its role as a cooperating agency. Thirteen committee members were selected by Governor 

Walker to represent a diversity of perspectives, including Alaska Native corporations and tribes, fishing, 

timber, conservation, tourism, utilities, mining, transportation, local government, and the Alaska Division 

of Forestry. A Forest Service representative served in an ex officio capacity to provide technical expertise 

for the Committee’s deliberations. The Committee met for three in-person meetings in the fall of 2018 

(October 2-3 in Juneau; October 24-26 in Ketchikan; and November 6-8 in Sitka). Meetings were open to 

the public, and each meeting included an opportunity for public comment. A final report was produced 

with options for the State of Alaska to consider and was provided as part of their Cooperating Agency 

comments to the Forest Service. 

On July 30, 2018, the Forest Service invited 19 Southeast Alaska federally-recognized tribes to 

participate as cooperating agencies during the rulemaking process. Six tribes agreed to become 

cooperating agencies and entered into a MOU. Since then, the Organized Village of Kake withdrew as a 

Cooperating Agency in December 2019.The tribes were invited to be cooperating agencies due to their 

specialized knowledge and expertise of land management, subsistence, natural resources, and potential 

impacts to communities within Southeast Alaska.

Changes between the DEIS and FEIS

A number of changes, corrections, and clarifications from the Draft Environmental Impact Statement 

(DEIS) have been made based on public comments and internal reviews. The most notable changes are 

summarized below. Minor edits and corrections are not included in this list. 

The 2001 IRAs geographic information system (GIS) data had not been updated since the rule was 

set in place. Since then, the Tongass National Forest has undergone several administrative changes 

to its ownership including shoreline mapping, Wilderness boundaries were updated, and the Tongass 

was exempted from the roadless rule. Further, previous policy was to exclude lakes from GIS layers. 

This practice has been abandoned since then, but the GIS data for the 2001 roadless rule were never 

updated.

Thus, corrections were made to IRA boundaries (Alternative 1) based on ownership changes and 

mapping corrections. The alternatives for the FEIS are based on these updated IRA boundaries. The 

corrections removed areas misidentified in 2001 (e.g., designated Wilderness identified as IRA), 

added small areas between wilderness and 2001 IRAs, added lakes, and aligned IRA boundaries 

with current NFS ownership, including the updated marine shoreline. This resulted in a net increase 

of about 30,000 acres from the 9.34 million acres identified in 2001. 

The Tongass updates the roads and activities (timber harvest) information often. Since the Tongass 

was exempted from the roadless rule between 2003 and 2011, timber harvest and road construction 

occurred in IRAs—this is described as “roaded roadless.” A new roaded roadless analysis was 

conducted between the DEIS and FEIS resulting in additional areas identified with existing timber 

harvest and roads within IRAs. 

Areas identified as logical extensions were adjusted and removed from roadless designation in 

Alternatives 3 and 4 to eliminate small, isolated roadless areas.

Community Priority Areas: The community priority designation was applied for Hydaburg and Kake, 

resulting in increasing the number of Community Priority ARA acres for Alternative 3. 

Cooperating Agencies noted that Tongass 77 (T77) Watersheds/The Nature Conservancy (TNC)-

Audubon areas mapped for the DEIS did not include several high-priority sockeye salmon watersheds 

important to Alaska Native Tribes. Therefore, areas identified as logical extensions in the DEIS that 

overlapped with the high-priority sockeye salmon watersheds were added back into the roadless 

inventory for Alternatives 2 and 3 to minimize effects to these watersheds. 

The DEIS assumed that timber harvest was distributed evenly across the suitable timber lands. In 

response to a number of comments and internal discussions, it was decided that old-growth harvest 
Purpose of and Need for Action 1

Final EIS 1-8 Purpose of and Need for Action

acres could be allocated in a more realistic pattern (since only 11 to 19 percent of the suitable old 

growth is harvested over 100 years). Thus, for the FEIS, a model to project more accurately the 

distribution of harvest was developed. The three new primary assumptions that changed the 

distribution of harvest were: 1) projected harvest acres were limited to suitable medium- and highvolume old growth only; 2) the proportion of projected harvest in the northern ranger districts was 

reduced; and 3) Value Comparison Units (VCUs) with the lowest estimated total old-growth stumpage 

values were dropped from consideration for the harvest (see Chapter 3, Introduction, Assumptions for 

Future Harvest). 

The mileage of new road construction, road reconstruction, and new roads over decommissioned 

road grades were estimated for each alternative; and these were spatially allocated based primarily 

on where harvest occurred (see Chapter 3, Introduction, Assumptions for Future Road Construction 

and Reconstruction). Assumptions made were similar to those made for the 2016 Forest Plan 

Amendment EIS.

In the DEIS, a number of Biodiversity, Wildlife, and Water tables from the 2016 Forest Plan 

Amendment EIS were referenced, especially in the Affected Environment sections, because 

conditions have not changed significantly. The tables from the 2016 Forest Plan Amendment EIS 

were presented in Appendix C. In order to be more precise in the FEIS, these attributes were 

analyzed specifically for this EIS and updated information is now presented in new tables in the text 

that is specific to this EIS. Appendix C has, therefore, been eliminated.

The DEIS incorrectly stated that a Biological Assessment would be prepared for the Decision. Since 

there are no anticipated effects that would influence threatened or endangered species, preparing a 

Biological Assessment is not necessary. Biological Assessments may be prepared for site-specific 

actions proposed in the future, as appropriate.

Maps showing lands suitable for old-growth and young-growth timber production were created for 

each community use area and alternative. These maps show suitable old-growth and young-growth. 

However, to better approximate where future old-growth harvest might occur, some suitable old 

growth is excluded because it is considered less desirable low-volume old growth or for poor 

economics. These maps are provided in Appendix D, which is made available electronically in the 

data storage device accompanying this EIS or on the project website.

In Appendix G, the Roadless Rule for Alternative 2 was corrected by removing the regulatory 

prohibition of commercial old-growth timber harvest in certain high priority watersheds. This is 

consistent with what was analyzed in the DEIS and was only intended to apply to Alternative 3. 

In Appendix G, exceptions to the prohibitions on timber harvest and road building in ARAs have been 

revised.

Key Issues

In 2001, USDA determined that the Tongass National Forest deserved “special attention in formulating 

alternatives due to its unique social and economic conditions” (USDA Forest Service 2000). More 

specifically, USDA’s Record of Decision identified:

“the agency has considered the alternatives of exempting and not exempting the Tongass 

National Forest, as well as deferring a decision per the proposed rule. Social and economic 

considerations were key factors in analyzing those alternatives, along with the unique and 

sensitive ecological character of the Tongass National Forest, the abundance of roadless areas 

where road construction and reconstruction are limited, and the high degree of ecological health. 

In developing the proposed action, the agency sought to balance the extraordinary ecological 

values of the Tongass National Forest against the needs of the local forest dependent 

communities in Southeast Alaska.” (66 FR 3254)

Then, as now, USDA’s (and that of the State, cooperators, and interested members of the public) 

assessment of policy preferences regarding roadless management rests primarily on the different weights 

ascribed to the these ecological, social and economic factors rather than any specific data or scientific 

findings. To be sure, the agency has carefully considered comments submitted that sought clarifications 

or updated information and revised the FEIS accordingly. 
Purpose of and Need for Action 1

Final EIS 1-9 Purpose of and Need for Action

With striking similarity to the issues highlighted in 2001, the following three key issues were identified for 

the Alaska state-specific roadless rulemaking effort and will be carried forward throughout the analysis.

Key Issue 1 – Roadless Area Conservation

The Tongass includes large undeveloped areas, with several portions of the Forest consisting of 

contiguous roadless areas that exceed 1 million acres and represent large blocks of unfragmented wildlife 

habitats, undeveloped or natural areas, and opportunities for primitive recreation and/or solitude. This 

large scale of roadless areas, including wildernesses and national monuments, does not exist anywhere 

else in the NFS outside of Alaska. The Tongass is the largest national forest in the United States and the 

majority of the Tongass is in a natural condition. It represents one of the largest, relatively intact 

temperate rainforests in the world.

Roadless areas are important because of their wildlife and fish habitat, recreation values, importance to 

multiple economic sectors, inherent passive use values, traditional properties and sacred sites for 

indigenous people, and ecosystem services they provide. Passive use values represent the value that 

individuals assign to a resource independent of their use of that resource and typically include existence, 

option, and bequest values. These values represent the value that individuals obtain from knowing that 

expansive roadless areas exist, knowing that they are available to visit in the future should they choose to 

do so, and knowing that they are available for future generations to inherit.

Ecosystem services represent the services provided to society by healthy ecosystems. These services 

and benefits include what some consider to be long-term life support benefits to society as a whole. 

Examples of ecosystem services include watershed services, soil stabilization and erosion control, 

improved air quality, climate regulation, carbon sequestration, and biological diversity.

The following units of measure are used to evaluate how each alternative responds to this key issue:

Qualitative degree of impacts to roadless area characteristics;

Total acres of designated roadless areas by alternative and by Alaska Roadless Area (ARA); 

Acres of designated roadless area removed and added; and

Acres of designated roadless area in development LUDs.

Key Issue 2 – Support local and regional socioeconomic 

well-being, Alaska Native culture, rural subsistence activities, 

and economic opportunity across multiple economic sectors

The Tongass comprises approximately 80 percent of Southeast Alaska and therefore plays a critical role 

in supporting local and regional economies, promoting economic diversification, and also enhancing rural 

community well-being. The visitor industry, seafood industry, and resource extraction industries contribute 

to local jobs and income alongside public sector employment spanning federal, state, and local 

government. While the visitor and seafood industries are the largest private-sector employers across 

Southeast Alaska, resource extraction remains important in some rural communities where jobs are 

limited and unemployment is often times high.

The Forest Service manages land for the multiple-use and sustained yield of all renewable surface resources. 

There is fragmentation and disagreement among the State, cooperators, and public regarding the best 

management of federal lands for economic development purposes and to support the overall economic 

vitality of Tongass communities. Many believe the visitor industry and seafood industries have become the 

mainstay of Southeast Alaska’s economy and therefore should have prominence in Forest Service land 

management decision-making. Others note that resource extraction, including forest products and the 

minerals industry, continue to provide jobs and income sources in Southeast communities. 

Southeast Alaska residents, communities, and Alaska Native individuals and tribes rely extensively on the 

Tongass for a wide variety of subsistence resources and traditional cultural activities. Many of them also 

use the forest for recreational hunting, fishing, and other activities. These activities yield economic value 

as well, and are important to local and regional socioeconomic well-being.
Purpose of and Need for Action 1

Final EIS 1-10 Purpose of and Need for Action

The following units of measure are used to evaluate how each alternative responds to this key issue:

Qualitative degree of effect to forest products industry;

Qualitative degree of effect to visitor industry;

Qualitative degree of effect to fisheries industry;

Qualitative degree of effect to locatable and leasable minerals development potential;

Qualitative degree of effect to energy project development potential;

Qualitative degree of effect to major transportation projects;

Acres of forest land suitable for timber production (old growth and young growth);

Acres of increase in suitable old growth by substantially altered areas, logical extensions of roaded 

areas, and areas more distant from roads; 

Acres of increase in high-volume suitable old growth by substantially altered areas, logical extensions 

of roaded areas, and areas more distant from roads;

Qualitative degree of support for Alaska Native culture due to improved access to tree harvest for 

cultural purposes;

Qualitative degree of support for subsistence activities; and

Qualitative degree of effects to communities – overall level of potential change for communities.

Key Issue 3 – Conserve terrestrial habitat, aquatic habitat, 

and biological diversity

The Tongass includes large, undeveloped, and natural land areas that represent expansive unfragmented 

blocks of wildlife habitat. This scale and size of contiguous habitat is not generally available elsewhere in 

the NFS outside of Alaska. Although wildlife species on the Tongass are associated with more than one 

habitat type, many inhabit old-growth forests or prey on species that inhabit old-growth forests. The 

Tongass Old-growth Habitat Conservation Strategy (2016 Forest Plan Amendment EIS, Appendix D) was 

developed to maintain the integrity of the old-growth forest ecosystem, and thereby conserve biological 

diversity across the Forest by retaining intact, largely undisturbed habitat. In addition, because of its 

predominantly undeveloped nature, a number of wide-ranging species find optimal habitat in the more 

remote areas of the Forest.

Fish and the aquatic resources on the Tongass support subsistence, commercial, and sport fisheries, as 

well as traditional and cultural values. The Tongass includes high-value, intact watersheds that were 

designated to be managed for intact ecological values and aquatic habitat productivity, and many 

commenters believe these areas should be protected so that they can continue to provide the clean water

and fish habitats that are essential to the ecological and economic health of the Southeast Alaska 

communities and residents who rely on them.

The following units of measure are used to evaluate how each alternative responds to this key issue:

Percent of existing and original productive old growth (POG) harvested over the long term;

Percent of original high-volume POG harvested over the long term;

Percent of original large-tree POG harvested over the long term;

Acres of young-growth harvest in specific habitats;

Average road density over the long term;

Percent of Wildlife Analysis Areas (WAAs) with road density <0.7 miles/square mile; and

Qualitative ratings of species-specific effects.
Purpose of and Need for Action 1

Final EIS 1-11 Purpose of and Need for Action

Issues Eliminated from Detailed Analysis

NEPA regulations require the agency to identify and eliminate from detailed study those issues that are 

not significant or that have been covered by prior environmental review, to narrow the scope of the 

analysis. Reasons for eliminating issues from detailed study include when the issues are related to the 

following:

General opinions or position statements not specific to the proposed action;

Items addressed by other laws, regulations, or policies;

Items not relevant to the potential effects of the proposed action, or otherwise outside the scope of 

this analysis; and/or

Items that have no or negligible effects.

Although changes in management direction could influence the nature of future projects, the timing, 

location, and details of future projects are currently unknown. This proposal does not make site-specific 

decisions or authorize any ground-disturbing activities. Therefore, site-specific impacts of projects are not 

considered in this FEIS and only broad environmental issues commensurate with program-level, 

landscape-scale decision making are considered. Impacts of future projects would need to be assessed 

on a project by project basis as they are proposed.

Many of the issues dismissed are anticipated to have similar resource effects for each of the various 

alternatives as those effects disclosed in the 2016 Forest Plan Amendment EIS. This is because 

implementation of Forest Plan standards and guidelines would be the same for all alternatives and none 

of the alternatives predict a projected timber sale quantity (PTSQ) greater than the amount disclosed in 

the 2016 Forest Plan Amendment EIS (46 million board feet [MMBF] per year). Although road 

construction and/or timber harvest could potentially increase within some designated roadless areas, 

these effects would be evaluated at the project-level.

Eliminated issues are not addressed beyond the rationale provided below:

Geology and Geologic Features

None of the roadless area management alternatives propose alteration of geologic processes or features. 

Impacts to geology or geologic features would be based on site-specific proposals, which are currently 

unknown, and would be addressed in subsequent project environmental analyses. From a broad 

standpoint, the impacts to geology and geologic features from the proposed alternatives would be the 

same as disclosed in the 2016 Forest Plan Amendment EIS. While this is also true for karst and cave

resources, effects to these resources are discussed in the body of Chapter 3 due to their sensitivity to 

timber harvest and road development.

Soil Characteristics and Composition

None of the roadless area management alternatives propose alterations to soil characteristics or 

composition. Impacts to soil characteristics and composition would be based on site-specific proposals, 

which are currently unknown, and would be addressed in subsequent project environmental analyses. 

From a broad standpoint, the impacts to soil characteristics and composition from the proposed 

alternatives would be the same as disclosed in the 2016 Forest Plan Amendment EIS due to similar 

timber harvest levels and adherence to Forest Plan standards and guidelines.

A preliminary review of effects to soils was conducted, looking at the acres of suitable land on soils with a 

mass movement index (MMI) of 3. The Forest Plan removes very high hazard class MMI 4 from suitability 

because of the risk of irreversible damage to the resource. MMI 3 soils are considered high hazard, but 

less so than MMI 4 soils and can be harvested on. As expected, acres of suitable MMI 3 soils increase 

with each of the Alaska Roadless Rule alternatives, ranging from an increase of 6 percent for Alternative 

2, 21 percent for Alternative 3, and 35 to 39 percent for Alternatives 4 through 6. However, because none 

of the alternatives predict an increase in the PTSQ, this does not correlate to an increase in harvest on 

MMI 3 soils. As with other soil characteristics, site-specific conditions would be evaluated at the project-
Purpose of and Need for Action 1

Final EIS 1-12 Purpose of and Need for Action

scale. Similarly, harvest and road building on steep slopes, and associated risk of landslides, would be 

based on site-specific proposals. From a broad standpoint, the associated risk of timber harvest and road 

building on high risk soils and steep slopes from the alternatives would be the same as disclosed in the 

2016 Forest Plan Amendment EIS due to adherence to Forest Plan standards and guidelines.

Water Quantity and Quality

None of the roadless area management alternatives propose specific actions that would alter water

quantity or quality. Impacts to water quantity or quality would be based on site-specific proposals, which 

are currently unknown, and would be addressed in subsequent project environmental analyses. From a 

broad standpoint, the impacts to water quantity or quality from the proposed alternatives would be the 

same as disclosed in the 2016 Forest Plan Amendment EIS due to following Forest Plan standards and 

guidelines and would use the application of best management practices (BMPs) which are consistent with 

the Alaska Forest Resources Practices Act, Clean Water Act, Magnuson–Stevens Fishery Conservation 

and Management Act, and Alaska’s Department of Environmental Conservation Water Quality Standards. 

Overall, effects on water quantity and quality are expected to be lowest under Alternative 1 and slightly 

higher under the action alternatives, with Alternatives 5 and 6 having the highest effects due to slight 

increases in miles of road construction and reconstruction relative to Alternative 1. Differences, however, 

would be localized and insignificant overall.

Air Quality

None of the roadless area management alternatives propose specific actions that would alter air quality. 

Impacts to air quality would be based on site-specific proposals, which are currently unknown, and would 

be addressed in subsequent project environmental analyses. From a broad standpoint, the impacts to air 

quantity from the alternatives would be the same as disclosed in the 2016 Forest Plan Amendment EIS 

due to following Forest Plan standards and guidelines. Air quality effects could be slightly higher under 

the action alternatives, especially Alternatives 5 and 6, due to slightly greater road construction, but the 

differences among the alternatives would be insignificant for air quality.

General Vegetation

None of the roadless area management alternatives propose specific actions that would alter general 

vegetation. Impacts to general vegetation would be based on site-specific proposals, which are currently 

unknown, and would be addressed in subsequent project environmental analyses. From a broad 

standpoint, the impacts to general vegetation from the proposed alternatives would be the same as 

disclosed in the 2016 Forest Plan Amendment EIS due to the application of Forest Plan standards and 

guidelines. Slightly more road construction under the action alternatives would slightly increase 

vegetation clearing; however, these changes would be insignificant. 

General Wildlife Species/Habitat

None of the roadless area management alternatives propose specific actions that would alter general 

wildlife habitat. Impacts to general wildlife habitats would be based on site-specific proposals, which are 

currently unknown, and would be addressed in subsequent project environmental analyses. From a broad 

standpoint, the impacts to general wildlife habitat from the alternatives would be similar to those disclosed 

in the 2016 Forest Plan Amendment EIS due to the application of Forest Plan standards and guidelines. 

Compared to Alternative 1, the action alternatives would result in small increases in road construction (up 

to 50 more miles of new road plus reconstruction, 14 more miles of road construction on decommissioned 

roadbeds, and 19 more miles of reconstruction over 100 years), habitat changes, and increased 

disturbance to wildlife in areas currently identified as roadless. Since the amount of timber harvest

authorized is not increased, the action alternatives may affect the location and distribution of impacts, but 

are not likely to significantly increase impacts relative to Alternative 1. 

General Aquatics Species/Habitat

None of the roadless area management alternatives propose specific actions that would alter general 

aquatic species. Impacts to general aquatic species would be based on site-specific proposals, which are 
Purpose of and Need for Action 1

Final EIS 1-13 Purpose of and Need for Action

currently unknown, and would be addressed in subsequent project environmental analyses. From a broad 

programmatic standpoint, the impacts to general aquatic species and habitat from the action alternatives 

would be the similar to those disclosed in the 2016 Forest Plan Amendment EIS (Alternative 1) due to the 

application of Forest Plan standards and guidelines and the lack of major differences among the 

alternatives. Although the action alternatives would result in slight increases in impacts relative to 

Alternative 1, the differences among alternatives are not expected to be significant.

Essential Fish Habitat

The Magnuson–Stevens Fishery Conservation and Management Act mandates that agencies initiate 

consultation with the National Marine Fisheries Service (NMFS) for any activities that could affect 

essential fish habitat (EFH). This consultation is completed for site-specific projects with ground-disturbing 

activity. The application of Forest-wide standards and guidelines and BMPs developed to meet soil 

protection, water quality standards, and fish habitat protection will help protect EFH on the Tongass and 

adjacent estuarine and marine waters. Adoption of any of the alternatives would not specifically result in 

any actions that could affect EFH, and any action that would be taken following adoption of an Alaska 

Roadless Rule that could affect EFH would undergo consultation.

Invasive Aquatic Species

Executive Order 13112 addresses the prevention of the introduction of invasive species and provides for 

their control and minimization of the economic, ecological, and human health impacts the invasive 

species causes. None of the roadless area management alternatives propose specific actions that would 

introduce invasive aquatic species. Impacts of invasive aquatic species would be based on site-specific

proposals, which are currently unknown, and would be addressed in subsequent project environmental 

analyses. Implementing active management including road building and timber harvest in areas currently 

designated as roadless areas has the potential for increasing the distribution of aquatic invasive species 

to areas where they do not currently exist. Forest Plan standards and guidelines as well as BMPs should 

minimize the potential for this to occur. The potential for this occurrence and any resulting effects from 

aquatic invasive species would be evaluated more closely during any subsequent project-level analysis. 

During a project-level analysis, specific project design recommendations may be developed to further 

reduce the potential impacts.

Wetlands

Executive Order 11990 requires protection of wetlands by mandating federal agencies to avoid, if 

possible and practicable, adverse impacts to wetlands. Identification, assessment, and protection of 

wetlands would be based on site-specific proposals, which are currently unknown, and would be 

addressed in subsequent project environmental analyses. From a broad standpoint, the protection of 

wetlands from the proposed alternatives would be the same as disclosed in the 2016 Forest Plan 

Amendment EIS due to application of Forest Plan standards and guidelines.

A preliminary review of effects to wetlands was conducted. This analysis concluded that the amount of 

timber harvest on wetlands is expected to vary slightly among alternatives; about 5 percent for old growth 

and 8 percent for young growth based on projected timber harvest distributions by alternative. Miles of 

road on wetlands under all alternatives would be minimized, as individual projects would avoid wetlands 

to the extent feasible, as required in the Forest-wide standards and guidelines. It is projected that new 

road miles on wetlands would vary only slightly among alternatives and would be lowest with Alternatives

1 and 2 and highest with Alternatives 4, 5, and 6. Alternative 3 would be intermediate in terms of road 

miles built on wetlands.

Floodplains

Executive Order 11988 requires federal agencies to avoid, to the extent possible, the long- and short-term 

adverse impacts associated with the occupancy and modification of floodplains and to avoid direct and 

indirect support of floodplain development wherever there is a practicable alternative. None of the 

roadless area management alternatives propose specific actions that would have short- or long-term 

adverse impacts to floodplains. Identification and assessment of short- and long-term effects would be 
Purpose of and Need for Action 1

Final EIS 1-14 Purpose of and Need for Action

based on site-specific proposals, which are currently unknown, and would be addressed in subsequent 

project environmental analyses. From a broad programmatic standpoint, short- and long-term effects to 

floodplains from the proposed alternatives would be the same as disclosed in the 2016 Forest Plan 

Amendment EIS due to Forest Plan standards and guidelines.

National Historic Preservation Act

In carrying out the responsibilities under Section 106 of the National Historic Preservation Act (NHPA), 

the Forest Service consulted with the State of Alaska Department of Natural Resources, Division of Parks 

and Outdoor Recreation and the Office of History and Archaeology, resulting in a letter (10/08/2018) from 

the State Historic Preservation Officer concurring with the Forest Service’s determination that changes in 

management direction for designated roadless areas on the Tongass does not meet the definition of an 

undertaking, as defined in 36 CFR 800.16(y). Although road construction and/or timber harvest could 

potentially increase within some designated roadless areas, impacts under the NHPA would be based on 

site-specific proposals, which are currently unknown, and would be addressed in subsequent Section 106 

reviews and project environmental analyses.

Specific Location Impacts

Comments were received requesting detailed analysis of specific timber sales, road densities, and 

impacts to l special use permit areas. None of the roadless area management alternatives propose sitespecific projects or actions. Specific location impacts would be based on site-specific proposals, which 

are currently unknown, and would be addressed in subsequent project environmental analyses.

Changes in Timber Markets

Commenters stated that timber demand has decreased in the United States, causing Alaska timber to be 

shipped to overseas markets; as a result, the timber industry is no longer a driving economic force in 

Alaska. The Pacific Northwest Research Station published planning-cycle demand projections (Daniels et 

al. 2016) that identified three future scenarios representing alternative futures for Southeast Alaska’s 

forest products industry – the transition to young-growth timber harvest, growing wood energy markets, 

and rebound in domestic housing market. The 2016 Forest Plan Amendment EIS’s use of a projected 

timber demand of an annual average of 46 MMBF of Tongass timber as the PTSQ was reasonable, 

conservative, and based on an evaluation of the best available information. The Forest Service has 

considered the current market situation and determined that no change to the PTSQ is needed at this 

time for purposes of this rulemaking.

Tongass Timber Reform Act

The TTRA (Section 101) directs the Forest Service to seek to provide a supply of timber from the 

Tongass that meets annual market demand and the market demand for each planning cycle to the extent 

consistent with providing for the multiple-use and sustained-yield of all renewable resources, and other 

applicable requirements. The Forest Plan provides sufficient timber to meet projected demand for timber 

from the Tongass as described in the 2016 Forest Plan Amendment EIS and Record of Decision (ROD; 

USDA Forest Service 2016b, 2016c) and by a series of annual applications of the Morse methodology. 

The Morse methodology is implemented, on an annual basis, to estimate current timber supply needed to 

meet market demand – satisfying the TTRA’s “seek to meet market demand” provision. This would 

continue under all alternatives.

Below-cost Timber Sales

Financial analyses for the Forest Plan were presented in the 2016 Forest Plan Amendment EIS (pp. 

3-516 to 3-519) based on modeling that involved first maximizing young-growth harvest under a nondeclining even flow and then adding old-growth volume to reach the annual average harvest of 46 MMBF 

and maximizing the net present value. Modeling results for the Forest Plan indicated positive discounted 

net revenues over the 15-, 25-, and 100-year periods. The analyses suggested that individual timber 

sales offered during the first 25 years of the planning period would likely need to include a mix of old 

growth and young growth to appraise positive, and to cover both logging and stumpage costs while 
Purpose of and Need for Action 1

Final EIS 1-15 Purpose of and Need for Action

providing a normal profit and risk. Under the Further Consolidated Appropriations Act, 2020 P.L. 116-94, 

133 Stat. 2751 (Sec. 436), timber sales that do not appraise positive using the current Region 10 RV 

(Residual Value) appraisal cannot be offered. All the action alternatives would increase availability of 

suitable old growth and young growth for harvest. More acres of suitable land would provide greater 

flexibility in the selection of future timber sale areas, as well as the potential for more flexibility in sale 

design, depending on the planning areas selected which are currently unknown. This improved flexibility 

could, in turn, improve the Forest Service’s ability to offer economic sales that meet industry needs. This 

greater flexibility could be beneficial during the first two decades of the 2016 Forest Plan (the transition 

period), which is the period of greater old-growth timber harvest. Potential revenue from future projects 

would be considered in project-specific analysis.

Changes to the General Mining Act of 1872 

Comments received suggested that reforming or changing the 1872 Mining Law, as amended, would 

address potential future environmental impacts. While the Mining Law is fundamentally a law for acquiring 

property rights, rather than an environmental law, presumably the comments were directed at eliminating 

the ability to establish property rights and increasing agency discretion to prevent mining. This is 

dismissed from consideration because making or amending law is an explicit function of Congress and 

not within the authority of the Secretary of Agriculture.

Irreversible or Irretrievable Commitment of Resources

An irreversible or irretrievable commitment of resources will not be made by the rulemaking. None of the 

roadless area management alternatives propose specific actions that would cause irreversible or 

irretrievable commitments of resources. Although road construction and/or timber harvest could 

potentially increase within some designated roadless areas, commitment of resources would be based on 

site-specific proposals, which are currently unknown, and would be addressed in subsequent project 

environmental analyses.

Incorporation by Reference

To focus on the issues and streamline the EIS, the following documents are incorporated by reference:

The Tongass Land and Resource Management Plan, as amended (USDA Forest Service 2016a), 

and accompanying EIS and ROD (USDA Forest Service 2016b and 2016c);

The Tongass Land and Resource Management Plan, as amended (USDA Forest Service 2008a), 

and accompanying EIS and ROD (USDA Forest Service 2008b);

The 2003 Roadless Area Evaluation for Wilderness Final Supplemental Environmental Impact 

Statement (USDA Forest Service 2003a) and accompanying ROD (USDA Forest Service 2003b);

The Tongass Land and Resource Management Plan Revision (USDA Forest Service 1997a), as 

amended, and accompanying FEIS and ROD (USDA Forest Service 1997b); and

Forest Service Roadless Area Conservation Final EIS (USDA Forest Service 2000). 

Scope and Applicability

Scope of the FEIS

The scope of this FEIS consists of the range of actions, alternatives, and impacts that are considered 

relevant to the proposed action. The roadless rule is geographically limited to proposed ARAs and 

existing IRAs established in the 2001 Roadless Rule, or the “analysis area” within the Tongass (see 

Chapter 3 for a further discussion of the analysis area). The rule is focused on the exceptions of the 

prohibitions for timber harvest and road construction/reconstruction within designated roadless areas on 

the Tongass. The final rule would not suspend, revoke, or modify land-use permits, contracts, or other 

legal instruments issued before the effective date of the final rule. Rulemaking establishes regulations 
Purpose of and Need for Action 1

Final EIS 1-16 Purpose of and Need for Action

with which future actions would have to comply, and does not make site-specific decisions or authorize 

any ground-disturbing activities.

This analysis is a generalized review which the Council on Environmental Quality (CEQ) recognizes as 

any broad or high-level NEPA review of proposed policies, plans, programs, or projects.

While environmental impacts should be disclosed as soon as information is reasonably available and at 

the earliest practicable stage, it is not reasonable or efficient to develop numerous timber harvest or other 

project-level scenarios. It is reasonable and efficient to limit detailed site-specific impact analyses to when 

specific proposals are brought before the agency.

The relationship between regulations, land and resource management plans (forest plan), and national 

forest projects is of particular importance to roadless rulemaking. Hierarchically, the Alaska Roadless 

Rule is two steps removed from any Tongass project-specific decision. A regulation is hierarchically 

above a forest plan, which must comply with all applicable laws and regulations. A forest plan provides 

broad guidance for future project activities within a specific national forest.

Roadless rules are narrowly focused prohibitions and exceptions established by the Secretary concerning 

whether and how timber harvest and road construction/ reconstruction may be allowed within specifically 

designated roadless areas. The alternatives evaluated in this FEIS focus on the particular prohibitions 

and exceptions. General guidance considering other discretionary aspects of management of the 

Tongass is better addressed through forest planning. As directed by the National Forest Management 

Act, Forest Plans are periodically revised and provide greater flexibility to adapt as the Forest Service 

gains greater understanding and/or circumstances change on the ground.

Applicability

The lands subject to this rulemaking are NFS lands on the Tongass. Therefore, the detailed descriptions 

and analyses of the affected environment and impacts on resources will be limited to the Tongass. The 

application of the change and modification provision to the Chugach National Forest considered in the 

DEIS has been removed from consideration in the FEIS.
CHAPTER 2

ALTERNATIVES INCLUDING 

THE PROPOSED ACTION

CHAPTER 1

PURPOSE AND NEED
Alternatives Including the Proposed Action 2

Final EIS 2-1 Alternatives Including the 

Proposed Action

Chapter 2

Alternatives Including the 

Proposed Action

This chapter describes the six alternatives considered in detail in this FEIS. It also describes the 

alternatives not analyzed in detail. It concludes by comparing the six alternatives.

The terms central to understanding the alternatives described in this chapter are defined below. These 

terms and others used in the analysis are also defined in the glossary.

Features Common to Multiple Alternatives

Tongass Land and Resource Management Plan

Except for the timber land suitability determinations described below, none of the alternatives would make 

any changes to the Forest Plan including the following:

Goals and Objectives;

Land Use Designations or Management Prescriptions;

Forest-wide Standards and Guidelines;

Plan Components developed under the 2012 Planning Rule; and/or

Projected Timber Sale Quantity (PTSQ), Projected Wood Sale Quantity (PWSQ), and the Younggrowth Transition.

None of the alternatives authorize any site-specific projects or other ground-disturbing activities. Specific 

projects that include timber harvest, road construction, and/or road reconstruction must undergo 

appropriate site-specific environmental analysis when they are proposed to comply with the NEPA. None 

of the alternatives considered in this FEIS waive any applicable requirements regarding site-specific 

environmental analysis, public involvement, consultation with Alaska Native tribes, Alaska Native 

corporations, and other agencies, or compliance with other applicable laws.

Activities that are not otherwise prohibited are permissible in roadless areas under all alternatives, 

including the no-action alternative (2001 Roadless Rule).

Alaska Roadless Areas (ARA) = Areas identified in the set of ARA maps which the 

Alaska Roadless Rule applies to. These represent new roadless designations and are 

tied to new roadless rule language.

ARA Designations = Areas identified with varying degrees of exceptions and prohibitions, 

designed based on land management priority.

Exceptions = Activities that would be allowed in different categories of ARAs.

Prohibitions = Activities that would not be allowed in different categories of ARAs.
Alternatives Including the Proposed Action 2

Final EIS 2-2 Alternatives Including the 

Proposed Action

Timber Suitability

Alternatives 2, 3, 4, 5, and 6 would result in an administrative change to the timber land suitability 

determinations made in the 2016 Forest Plan Amendment. Specifically, lands identified as suitable for 

timber production that were deemed unsuitable solely due to implementation of the 2001 Rule would be 

set aside and redesignated as suitable for timber production. As described in Appendix A to the Forest 

Plan (USDA Forest Service 2016a), old-growth forest located within Phases 2 and 3 of the Tongass 

Timber Sale Program Adaptive Management Strategy, within the Tongass 77 (T77) Watersheds and The 

Nature Conservancy (TNC)/Audubon Conservation Priority Areas, within non-development LUDs, and in 

other areas designated by the Forest Plan as not suitable, would continue to be not suitable for timber 

production. This change to the designation of lands suitable for timber production would be accomplished 

via an administrative change (36 CFR 219.13(c)) and would apply to lands removed from the roadless 

inventory and to lands identified as “Community Priority” or “Timber Priority” in Alternatives 3 and 4, 

respectively. This change does not preclude future suitability determinations for other multiple purposes 

as part of subsequent Forest Plan amendment or revision processes.

Project-Specific Activities

None of the alternatives authorize site-specific projects or ground-disturbing activities. Projects that 

include timber harvest, road construction, and/or road reconstruction would undergo environmental 

analysis when they are proposed to comply with the NEPA. None of the alternatives considered in this 

FEIS waive any applicable requirements regarding environmental analysis, public involvement, 

consultation with tribes and other agencies, or compliance with other applicable laws.

Ongoing Projects

None of the alternatives would revoke, suspend, or modify any project or activity in which a decision was 

made prior to the effective date of an Alaska Roadless Final Rule.

Existing Land Use Authorizations

All of the alternatives allow for the continuation of existing land use authorizations for activities in roadless 

areas. “Authorizations” refer to land uses allowed under a special use authorization, contract, or similar 

legal instrument. “Existing authorizations” are those that are issued before the effective date of the final 

rule.

Proposed Definitions

Alternatives 2, 3, 4, and 5 would include definitions for clarity. The following are select definitions of terms 

that the agency sought specific comments on along with proposed definitions (Appendix G):

Alaska Native. Federally recognized tribes or individuals that are enrolled or eligible to enroll as a 

member of a federally recognized tribe.

Alaska Roadless Areas. Lands within the Tongass National Forest designated pursuant to this 

subpart and identified in a set of maps maintained by the national headquarters office of the Forest 

Service.

Commercial Old Growth Timber Harvest. Trees, portions of trees, and other forest products 

originating from old growth stands on National Forest System lands that may be sold for the purpose 

of achieving the policies set forth in the Multiple-Use Sustained-Yield Act of 1960, as amended, the 

Forest and Rangeland Renewable Resources Planning Act of 1974, as amended, and the Program 

thereunder. (See 36 CFR 223.1).

Public (Community) utility system. A system that provides a community or communities with services 

for public use or consumption such as municipal water and wastewater systems, biomass heating 

and energy systems, transmission lines, and hydroelectric and other renewable energy projects and 

related infrastructure.
Alternatives Including the Proposed Action 2

Final EIS 2-3 Alternatives Including the 

Proposed Action

Responsible official. The Forest Service line officer with the authority to make and implement a 

decision on a proposed action.

Road. As defined at 36 CFR 212.1, the term means a motor vehicle route over 50 inches wide, unless 

identified and managed as a trail.

Road construction and reconstruction. As defined at 36 CFR 212.1, the terms mean supervising, 

inspecting, building, and incurrence of all costs incidental to the construction or reconstruction of a 

road.

Roadless Area Characteristics. Resources or features that are often present in and characterize 

Alaska Roadless Areas, including

(1) Physical Environment. Roadless areas provide high-quality or undisturbed soil, water, and air.

(2) Water. Roadless areas provide a variety of water resources including public drinking water 

sources, fish and aquatic resources, and hatchery aquatic resources. 

(3) Diversity. Roadless areas support a diversity of plant and animal communities including 

stands of old-growth forests. 

(4) Habitat. Roadless areas are expansive areas where high-quality intact habitat exists and 

ecosystems function with all their native species and components. Roadless areas may serve as 

habitat for threatened, endangered, proposed, candidate, and species of conservation concern, 

and for those species dependent on large, undisturbed areas of land. 

(5) Remoteness. Roadless areas provide rich primitive, semi-primitive motorized, and semiprimitive non-motorized classes of dispersed recreation and are a source of ecological, social, 

and economic benefits.

(6) Landscape. Roadless areas provide reference landscapes of relatively undisturbed areas that 

serve as a barometer to measure the effects of development on other parts of the landscape.

(7) Scenery. Roadless areas have natural-appearing landscapes with high-scenic qualities that 

people value.

(8) Cultural. Roadless areas often include traditional cultural properties and sacred sites. In 

Alaska, indigenous peoples have been on national forests for more than 10,000 years and the 

forests have cultural significance.

(9) Locally-unique characteristics. Roadless areas represent geographic areas with additional 

locally-unique characteristics specific to Alaska, including: (a) important source of subsistence 

resources including terrestrial wildlife, waterfowl, mammals, fish, and plant-based resources; (b) 

rich habitat that supports multiple species of fish for personal, subsistence, sport, recreation, and 

commercial harvest; and (c) supports diverse economic opportunity that is especially important 

for rural community well-being.

Timber harvest. The cutting, removal, or sale of trees.

Proposed Alaska Roadless Boundary Correction and 

Modification Provisions

Alternatives 2, 3, 4, and 5 include administrative correction and modification provisions for inclusion in the 

proposed Alaska Roadless Rule to provide for future boundary and classification changes. While the 

proposed rule and Draft Environmental Impact Statement (DEIS) announced an intention to extend this 

provision to the Chugach National Forest, in response to public comment, this provision has been 

adjusted and would apply only to the Tongass National Forest. Administrative corrections would be 

limited to adjustments that remedy clerical errors, typographical errors, mapping errors, or improvements 

in mapping technology. Administrative modifications would be limited to conformance to statutory 

changes, or incorporation of changes due to land adjustments. The proposed rule would have extended 

this process to the Chugach National Forest, but in response to public input, the correction and 

modification provision would apply exclusively to the Tongass National Forest under Alternatives 2, 3, 4, 

and 5. The Chief may issue administrative corrections after a 30-day public notice and opportunity to 
Alternatives Including the Proposed Action 2

Final EIS 2-4 Alternatives Including the 

Proposed Action

comment period. These provisions are not needed for Alternative 6 because the Tongass would be 

exempt from the 2001 Roadless Rule.

Administrative modifications would be limited to conformance to statutory changes or incorporation of 

changes due to land adjustments. The Chief would provide at least a 45-day public notice and opportunity 

to comment period for all modifications.

Alaska Roadless Area Land Management Designations

Alternatives 2, 3, 4, and 5 provide for a variety of management approaches within roadless areas through ARA 

land management designations, which include Land Use Designation (LUD) II Priority, Watershed Priority, 

Roadless Priority, Community Priority, and Timber Priority. The management designations prohibit timber 

harvest, road construction, and road reconstruction with exceptions that are applied differentially across the 

alternatives (Table 2-2). A brief description of each management designation follows.

LUD II Priority (Alternatives 2, 4, and 5)

LUD II Priority ARAs would be managed in a roadless state to retain their wildland character as defined in 

the Tongass Timber Reform Act (TTRA; Title II, Section 201) and the National Defense Authorization Act 

for Fiscal Year 2015 (Public Law 113-291, 128 Stat. 3729, Section 3720(f)).

Approximately 870,000 acres of the Tongass are congressionally designated as LUD II (847,000 acres 

currently designated as IRA under the 2001 Roadless Rule and 22,000 acres currently not designated as 

IRA). Alternatives 2 and 4 propose to designate 854,000 LUD II acres as LUD II Priority ARA. Alternative 

5 proposes to apply the LUD II Priority ARA only to LUD II areas that are currently designated as IRA.

Notably, Alternative 3 proposes to remove all LUD II areas from roadless designation rather than 

designating LUD II lands into an ARA. LUD II areas under Alternative 3 would continue to be managed as 

directed by their congressional designations.

Watershed Priority (Alternatives 2 and 3)

The Watershed Priority ARA is more protective than the 2001 Roadless Rule as it offers fewer exceptions for 

timber harvest, or road construction/reconstruction. It also provides for activities specific to aquatic habitat 

improvement. Approximately 3,284,000 acres in Alternative 2 would be managed under this ARA. The 

Watershed Priority ARA is applied to areas identified in the Forest Plan as Tongass 77 (T77) Watersheds, The 

Nature Conservancy (TNC)/Audubon Conservation Priority Areas, and high-priority sockeye salmon 

watersheds.

Additionally, for Alternative 3, commercial old-growth timber harvest would be prohibited on NFS lands in T77 

and TNC/Audubon Conservation Areas that extend beyond ARA boundaries (an additional 507,000 acres). A 

prohibition on old-growth harvesting currently exists through the Forest Plan. However, Alternative 3 

examines establishing regulatory continuity between these roadless and watershed management 

systems given how extensively they overlap (the listed watersheds comprise over half of the Tongass’ 

roadless areas, and approximately 90 percent of the watershed areas are within roadless area 

boundaries). Thus, the old-growth harvest prohibition would be extended beyond the designated roadless 

area boundaries in order to maintain the balance and integrity of the watershed protection system. As 

with all roadless rule provisions, the new prohibition would supersede current and future forest plans, with 

the plan continuing to provide management direction in other regards. In this manner, Alternative 3 

affords high-priority watershed areas greater regulatory protection than under the 2001 Roadless Rule. 

Young-growth timber harvest outside of ARAs within these high-priority watershed areas is not prohibited.

Roadless Priority (Alternatives 2, 3, 4, and 5)

The Roadless Priority ARA is similar to the 2001 Roadless Rule but is less restrictive and addresses 

Alaska-specific concerns. Specifically, it provides for infrastructure development to connect and support 

local communities, and road construction/reconstruction for access to renewable energy sites and 

leasable minerals. In addition, the Roadless Priority ARA includes specific exceptions that, while they are 

allowed under the 2001 Roadless Rule, are included to improve overall clarity. 
Alternatives Including the Proposed Action 2

Final EIS 2-5 Alternatives Including the 

Proposed Action

Community Priority (Alternative 3)

The Community Priority ARA allows for small-scale timber harvest (less than one MMBF) and associated 

road construction/reconstruction. In addition, it allows for infrastructure development to connect and 

support local communities and traditional Alaska Native cultural uses. In all cases, activities within 

Community Priority ARAs would have to be consistent with the Forest Plan LUD requirements. Even if a 

timber harvest, road building, or other activity would be permissible under the Alaska Roadless Rule, it 

may not be allowable because of Forest Plan direction specific to the LUD that applies to the area, or 

other suitability criteria as explained in the Forest Plan, Appendix A. This ARA applies to approximately 

370,000 acres and is only proposed in Alternative 3 adjacent to seven communities: Hydaburg, Juneau, 

Kake, Ketchikan, Sitka, Wrangell, and Yakutat. 

This ARA was developed to address the desires of these seven communities to retain roadless 

designations while allowing for small timber operators in the community, infrastructure development to 

support the communities, and provide for traditional Alaska Native cultural uses. 

Timber Priority (Alternative 4)

The Timber Priority ARA allows timber harvest, road construction, and road reconstruction to facilitate 

timber management and provide economic opportunity. It is only included in Alternative 4, and would 

apply to approximately 757,000 acres. While management of lands in this ARA management designation 

would not be subject to any regulatory prohibitions on timber harvest or road construction, retaining them 

in roadless designation is a means of acknowledging the roadless values of these lands to ensure 

appropriate consideration in future, site-specific project planning and analysis. Table 2-1 displays the 

ARAs by alternative.

Table 2-1

Alaska Roadless Areas (ARA) by Alternative and Management Designations

ARA Management 

Categories

Alternative

1 2 3 4 5 6

No Action

Roaded 

Roadless

Logical 

Extension

Partial 

Dev. LUDs1

All Dev. 

LUDs

Full 

Exemption

LUD II Priority N/A √ √ √ N/A

Watershed Priority N/A √ √ N/A

Roadless Priority N/A √ √ √ √ N/A

Community Priority N/A √ N/A

Timber Priority N/A √ N/A

N/A = not applicable

1 Includes Timber Production and Modified Landscape LUDs, but not Scenic Viewshed.
Alternatives Including the Pro

Final EIS 2-6 Alte

Table 2-2

Rule Language Associated with Alaska Roadless Areas and for the Alaska Roadless Area Management D

Appendix G for complete language)

Designation

Tree cutting, sale, or removal within Alaska 

Roadless Areas would be prohibited except 

for the following:

Road construction and reconstruction within Alaska Roadle

except for the following:

Alaska 

Roadless 

Areas

(common to 

Alternatives 2 

through 5)

(1) Timber harvest conducted pursuant to reserved or 

outstanding rights or as provided for by statute or 

treaty,

(2) Timber harvest to protect public health and safety in 

cases of an imminent threat of flood, fire, or other 

catastrophic event that, without intervention, would 

cause the loss of life or property, including removal of 

hazard trees; 

(3) Timber harvest for personal or administrative use, 

as provided for in 36 CFR part 223; or

(4) Timber harvest incidental to the implementation of a 

management activity not otherwise prohibited by this 

subpart, including the construction or reconstruction of 

a road pursuant to §294.53 or the construction, 

expansion, or maintenance of authorized fishways, fish

hatcheries, and aquaculture facilities.

(1) A mandatory road authorization pursuant to reserved or outstanding rig

treaty. Examples of mandatory statutory authorizations include but are not 

Alaska National Interest Lands Conservation Act (P.L. 96-487), Section 44

Flexible, Efficient Transportation Equity Act (P.L. 109-59); and General Mi

(2) A road to conduct a response action under the Comprehensive Environ

and Liability Act (CERCLA) or to conduct a natural resource restoration ac

the Clean Water Act, or the Oil Pollution Act;

(3) A Federal Aid Highway project, authorized pursuant to Title 23 of the U

(4) A road realignment to prevent irreparable resource damage that arises 

deterioration of a road and cannot be mitigated by road maintenance;

(5) A road reconstruction safety improvement project on a classified road; 

(6) A road to protect public health and safety in cases of an imminent threa

event that, without intervention, would cause the loss of life or property.

(Alternative 3 

only)

Additionally, except as provided in Watershed Priority

exceptions, commercial old-growth timber harvest is 

prohibited on National Forest System lands as depicted 

in a map maintained by Chief’s Office that identifies 

high priority watersheds that largely coincide with 

Alaska Roadless Areas, but can extend beyond Alaska 

Roadless Area boundaries.

LUD II Priority

(Alternatives 2, 

4, and 5 only)

Timber harvest in an Alaska Roadless Area designated 

as LUD II Priority is allowed if consistent with the 

legislated management restrictions established in 

Section 201 of the Tongass Timber Reform Act.

Road construction or reconstruction in an Alaska Roadless Area designate

consistent with the legislated management restrictions established in Sect

Reform Act.
Alternatives Including the Pro

Final EIS 2-7 Alte

Table 2-2 (continued)

Rule Language Associated with Alaska Roadless Areas and for the Alaska Roadless Area Management D

Category

Tree cutting, sale, or removal within Alaska 

Roadless Areas would be prohibited except 

where the Responsible Official determines:

Road construction and reconstruction within Alaska Roadle

except where the Responsible Official de

Watershed

Priority

(Alternatives 2 

and 3 only)

(1) The cutting, customary trade, and removal of trees 

for the purposes of Alaska Native customary and 

traditional uses that does not degrade water quality, 

fish habitat, fish production, fish passage, aquatic 

diversity, or soil productivity;

(2) Timber harvest for one of the following purposes 

that will maintain, restore, or improve one or more of 

the purposes:

(i) To maintain, restore or improve fish and wildlife 

habitat; or

(ii) To maintain, restore, or improve the characteristics 

of ecosystem composition, structure, and processes; or

(3) Timber harvest is incidental to trail or recreation 

development that does not degrade water quality, fish

habitat, fish production, fish passage, aquatic 

biodiversity, or soil productivity.

With the exception of the authorities provided for all Alaska Roadless Areas

reconstructed in an Alaska Roadless Area designated as Watershed Priorit

Roadless 

Priority

(1) Timber harvest for the cutting, customary trade, and 

removal of trees for the purposes of Alaska Native 

customary and traditional uses;

(2) Timber harvest for one of the following purposes 

that will maintain, restore or improve one or more of the 

following purposes:

(i) To maintain, restore, or improve fish and wildlife 

habitat; or

(ii) To maintain, restore, or improve the characteristics 

of ecosystem composition, structure, and processes;

(3) Timber harvest within a designated experimental 

forest for research or administration; or

(4) Timber harvest for the construction, expansion, use, 

or maintenance of utility systems; or

(5) Timber harvest is incidental to trail or recreation 

development that does not degrade water quality, fish

habitat, fish production, fish passage, aquatic 

biodiversity, or soil productivity.

(1) A road for the construction, expansion, or maintenance of public facilitie

points, and communication equipment; 

(2) A road to provide access to Alaska Native cultural site(s) if requested by 

tribe(s); 

(3) A road for transportation needs identified by the State of Alaska’s South

the connection of communities and development of the regional transportat

(4) A road within a designated experimental forest for research or administr

access to a designated experimental forest;

(5) A road for the construction, expansion, or maintenance of a community 

(6) A road in conjunction with the construction, expansion, or maintenance 

aquaculture facility. 
Alternatives Including the Pro

Final EIS 2-8 Alte

Table 2-2 (continued)

Rule Language Associated with Alaska Roadless Areas and for the Alaska Roadless Area Management D

Category

Tree cutting, sale, or removal within Alaska 

Roadless Areas would be prohibited except 

where the Responsible Official determines:

Road construction and reconstruction within Alaska Roadle

except where the Responsible Official de

Community 

Priority

(Alternative 3 

only)

(d) Community Priority. Notwithstanding the prohibition 

in paragraph (a) of this section, timber harvest may 

occur in an Alaska Roadless Area designated as 

Community Priority shall be authorized if consistent 

with the following:

(1) The cutting, customary trade, and removal of trees 

is for the purpose of Alaska Native customary and 

traditional uses;

(2) Timber harvest for micro sales, salvage sales, or 

commercial sales less than one million board feet of 

timber;

(3) Timber harvest for one of the following purposes 

that will maintain, restore or improve one or more of the 

following purposes:

(i) To maintain, restore, or improve fish and wildlife 

habitat; or

(ii) To maintain, restore, or improve the characteristics 

of ecosystem composition, structure, and processes; or

(4) Timber harvest for the construction, expansion, use, 

or maintenance of a community utility system.

(1) A road to provide access to Alaska Native cultural site(s) if requested by 

tribe(s);

(2) A road for micro sales, salvage sales, and commercial sales less than o

(3) A road for the construction, expansion, or maintenance of facilities such 

and communication equipment;

(4) A road for the construction, expansion, or maintenance of a community 

(5) A road in conjunction with the construction, expansion, or maintenance 

hatchery, or aquaculture facility; or

(6) A road in conjunction with the construction, expansion, or maintenance 

Timber Priority

(Alternative 4 

only)

Timber harvest in an Alaska Roadless Area designated 

as Timber Priority is allowed. 

Permanent or temporary road construction, reconstruction, or maintenance 

designated as Timber Priority is allowed.

Additional rule language applies; see Appendix G. 

Site specific environmental analysis, public involvement, consultation with Tribes and other agencies, or compliance with other applicable laws would still ap
Alternatives Including the Proposed Action 2

Final EIS 2-9 Alternatives Including the 

Proposed Action

Alternatives Considered in Detail

Based on information obtained during scoping, Cooperating Agency input, consultation with Alaska Native 

tribes, and input on the DEIS, the Forest Service has evaluated six alternatives for detailed analysis, 

including the no action and proposed action alternatives. These alternatives respond to the three key 

issues identified in Chapter 1. Large-scale color maps showing roadless areas by IRA or ARA (Map 1 to 

6) are included on the thumb drive version of the FEIS, in the map packet that accompanies the FEIS 

paper copy, and on this project’s website: https://www.fs.usda.gov/project/?project=54511. In addition, 

electronic versions of these maps, showing the lands that would be suitable for timber production (Maps 7 

to 12), are included on the thumb drive and website. 

Alternative 1 – No Action

Alternative 1 is the no action alternative as required by CEQ’s NEPA regulations and reflects a 

continuation of current land management pursuant to the 2001 Roadless Rule (see Map 1 in map packet 

or on thumb drive). This alternative does not mean that no activities would occur on the Tongass National 

Forest; rather, it means the activities currently occurring would continue, including implementation of the 

Tongass timber program at levels defined in the Forest Plan. This alternative continues general 

prohibitions on tree harvest (and sale), road construction, and road reconstruction within IRAs with limited 

exceptions (Table 2-3). 

Under Alternative 1, roadless areas consist of 110 IRAs identified in the 2001 Roadless Rule. These IRAs 

were originally mapped in 1996 for the Tongass Forest Plan Revision and the provisions of the 2001 

Roadless Rule (as provided for by the Court’s reinstatement Order) would apply to those IRAs 

(summarized below). As a result of ownership changes and boundary alignment corrections recognized 

during this rulemaking these IRAs actually encompass 9.37 million acres11 of NFS land. Under this 

alternative, the prohibitions of the 2001 Roadless Rule would continue to apply across the 110 IRAs, 

encompassing approximately 56 percent of the Tongass. 

Under Alternative 1, the 2001 Roadless Rule IRA boundary modifications (increases and decreases) 

would continue to require rulemaking except for minor clerical and technical corrections.

Table 2-4 summarizes the key elements of Alternative 1.

11The original acreage of inventoried roadless areas on the Tongass was approximately 9.34 million acres. As a result of ownership 

changes and boundary alignment corrections, noted during this rulemaking, including shoreline mapping adjustments, the actual 

acreage is 9.37 million acres.
Alternatives Including the P

Preliminary Final EIS 2-10 Alternatives Includ

Table 2-3

Roadless Rule Language Associated with the 2001 Roadless Rule (Alternative 1)

Timber cutting, sale, or removal is prohibited in IRAs except where 

the Responsible Official determines:

Road construction and reconstruction is prohi

the Responsible Official det

2001 

Roadless 

Rule

(1) The cutting, sale, or removal of generally small diameter timber is needed for 

one of the following purposes and will maintain or improve one or more of the 

roadless area characteristics as defined in § 294.11 of the 2001 Roadless Rule.

(i) To improve threatened, endangered, proposed, or sensitive species 

habitat; or

(ii)To maintain or restore the characteristics of ecosystem composition and 

structure, such as to reduce the risk of uncharacteristic wildfire effects, 

within the range of variability that would be expected to occur under 

natural disturbance regimes of the current climatic period;

(1) A road is needed to protect public health and safety 

of flood, fire, or other catastrophic event that, witho

loss of life or property;

(2) The cutting, sale, or removal of timber is incidental to the implementation of a 

management activity not otherwise prohibited by the 2001 Roadless Rule;

(2) A road is needed to conduct a response action und

Environmental Response, Compensation, and Liab

a natural resource restoration action under CERCL

Water Act, or the Oil Pollution Act;

(3) The cutting, sale, or removal of timber is needed and appropriate for personal 

or administrative use, as provided for in 36 CFR part 223; or

(3) A road is needed pursuant to reserved or outstandi

statute or treaty;

(4) Roadless characteristics have been substantially altered in a portion of an IRA

due to the construction of a classified road and subsequent timber harvest.

Both the road construction and subsequent timber harvest must have occurred 

after the area was designated an IRA and prior to January 12, 2001. Timber

may be cut, sold, or removed only in the substantially altered portion of the IRA.

(4) Road realignment is needed to prevent irreparable 

from the design, location, use, or deterioration of a 

be mitigated by road maintenance. Road realignme

paragraph only if the road is deemed essential for p

resource management, or public health and safety;

(5) Road reconstruction is needed to implement a road 

a classified road determined to be hazardous on th

or accident potential on that road;

(6) The Secretary of Agriculture determines that a Fed

authorized pursuant to Title 23 of the United States 

is consistent with the purposes for which the land w

other reasonable and prudent alternative exists; or

(7) A road is needed in conjunction with the continuatio

mineral lease on lands that are under lease by the S

January 12, 2001, or for a new lease issued immed

existing lease. Such road construction or reconstruc

manner that minimizes effects on surface resources

unreasonable surface disturbance, and complies w

requirements, land and resource management plan 

Roads constructed or reconstructed pursuant to this 

when no longer needed for the purposes of the leas

expiration of the lease, whichever is sooner.
Alternatives Including the Proposed Action 2

Final EIS 2-11 Alternatives Including the 

Proposed Action

Table 2-4

Key Element Summary for Alternative 1

Roadless Areas

• Includes inventoried roadless areas identified in the 2001 Roadless Rule, about 9.37 million acres.

Prohibition on Tree Cutting1

• Tree cutting is excepted for generally small-diameter timber that will maintain or improve one or more 

roadless area characteristics, improve sensitive species habitat, or maintain or restore characteristics of 

ecosystem composition and structure.

• Tree cutting excepted if incidental to the implementation of a management activity not otherwise prohibited.

• Tree cutting excepted if needed and appropriate for personal or administrative use.

• Tree cutting excepted if roadless characteristics have been substantially altered in a portion of an IRA due to 

the construction of a classified road and subsequent timber harvest was conducted prior to January 2001.

Prohibition on Road Construction and Reconstruction1

• Road construction/reconstruction excepted if needed to protect public health and safety, to conduct 

Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) response action, 

pursuant to reserved or outstanding rights, to prevent irreparable resource damage, to implement a road 

safety improvement project.

• Road is needed pursuant to reserved or outstanding rights, or as provided for by statute or treaty;

• Road construction/reconstruction is excepted if needed for a Federal Aid Highway project that meets certain 

criteria and is approved by the Secretary of Agriculture.

• Road construction/reconstruction is excepted if needed in conjunction with the continuation, extension, or 

renewal of a mineral lease on lands that are under lease by the Secretary of the Interior as of January 12, 

2001, or for a new lease issued immediately upon expiration of an existing lease.

Tongass Land and Resource Management Plan

• No changes to Goals and Objectives, Land Use Designations, or Management Prescriptions, Forest-wide 

Standards and Guidelines, Plan Components developed under the 2012 Planning Rule, PTSQ, PWSQ, and 

the Young-growth Transition.

• No change to Lands Suitable for Timber Production. 1 See detailed descriptions of prohibitions/exceptions in 2001 Roadless Rule.

Alternative 2

Alternative 2 provides limited additional timber harvest opportunity while maximizing roadless area 

designations. It removes approximately 142,000 acres from roadless designation that have been 

substantially altered by known prior road construction or timber harvest. These areas are generally known 

as “roaded roadless” areas but include additional areas considered to be substantially altered. Alternative 

2 also adds 110,000 acres as ARAs. 

The 110,000 acres of added roadless areas maximize the geographic scope of roadless area 

designations by including portions of congressionally-designated LUD II areas not included as IRAs under 

the 2001 Roadless Rule, currently unroaded small islands, and unroaded areas greater than 5,000 acres 

as identified by prior forest planning efforts. Adding additional roadless designations to unroaded islands 

provides for long-term, continued recreational and outfitter and guide opportunities on these islands.

After removals and additions, Alternative 2 consists of 9.34 million inventoried roadless acres or about 

30,000 fewer roadless acres than under Alternative 1. The 9.34 million acres are designated to three ARA 

land management categories including LUD II Priority, Watershed Priority, and Roadless Priority (see 

Map 2 in map packet or on thumb drive). 

Alternative 2 applies the most protective ARA, Watershed Priority, to 3.28 million acres, primarily 

identified as T77 Watersheds, TNC/Audubon Conservation Priority Areas, and high-priority sockeye 

salmon watersheds. The Watershed Priority ARA is considered most protective because it includes fewer 

exceptions than the 2001 Roadless Rule, while still allowing activities needed for fisheries protection, 

maintenance, or improvement.
Alternatives Including the Proposed Action 2

Final EIS 2-12 Alternatives Including the 

Proposed Action

Under Alternative 2, a net of 20,000 old-growth acres and 11,000 young-growth acres, previously 

identified as unsuitable timber lands, would revert to suitable timber lands, as they were when the 

roadless rule did not apply to the Tongass.

Table 2-5 summarizes the key elements of Alternative 2.

Table 2-5

Key Element Summary for Alternative 2

Roadless Areas

• Establishes 9.34 million acres of ARAs, including 5.20 million acres in Roadless Priority, 3.28 million acres in

Watershed Priority, and 0.85 million acres in LUD II Priority categories.

Prohibition on Timber Harvest1

• Under the Roadless Priority ARA timber harvest exceptions are written slightly broader than under the 2001 

Roadless Rule to address Alaska’s unique economic development needs. 

• Under the Watershed Priority ARA, timber harvest exceptions are slightly narrower than under the 2001 

Roadless Rule and are designed to address aquatic and terrestrial habitat needs that are unique to Alaska’s 

rural economic conditions and subsistence activities.

• Under the LUD II Priority ARA, timber harvest exceptions are slightly broader than under the 2001 Roadless 

Rule and are designed to align the Alaska Roadless Rule with existing congressional instructions.

Prohibition on Road Construction and Reconstruction1

• Under the Roadless Priority ARA road construction/reconstruction exceptions are slightly broader than under 

the 2001 Roadless Rule.

• Under the Watershed Priority ARA road construction/reconstruction exceptions are slightly narrower than 

under the 2001 Roadless Rule.

• Under the LUD II Priority ARA road construction/reconstruction exceptions are slightly broader than under the 

2001 Roadless Rule.

Tongass Land and Resource Management Plan

• No changes to Goals and Objectives, Land Use Designations or Management Prescriptions, Forest-wide 

Standards and Guidelines, Plan Components developed under the 2012 Planning Rule, PTSQ, PWSQ, and 

the Young-growth Transition.

• Change to Timber Land Suitability: A net of 20,000 old-growth acres and 11,000 young-growth acres 

previously identified as unsuitable timber lands would become suitable timber lands. 1 See detailed descriptions of prohibitions/exceptions in Table 2-2.

Alternative 3 

Alternative 3 provides moderate additional timber harvest opportunities. Alternative 3 establishes roadless 

designations for T77 Watersheds, TNC/Audubon Conservation Priority Areas inside roadless areas, and 

high-priority sockeye salmon watersheds and also prohibits old-growth harvest in T77 Watersheds and 

TNC/Audubon Conservation Priority Areas outside of roadless areas (similar to the Forest Plan). 

Additional timber harvest opportunity is provided by removing substantially-altered roadless areas 

(including roaded roadless, similar to Alternative 2) and extending the bounds of these areas to logical 

end points of existing road and timber harvest systems, generally defined as the nearest watershed 

boundary (i.e., ridgeline of 14th-field hydrologic unit) from an existing road system. Removing these areas 

from the roadless inventory represents the logical extensions of substantially altered acres from existing 

infrastructure and likely encompasses the more economically feasible locations for future timber harvest 

with the least impact to roadless characteristics. Additional small-scale timber harvest opportunity is 

provided by the designation of Community Priority12 ARAs for Hydaburg, Juneau, Kake, Ketchikan, Sitka, 

Wrangell, and Yakutat.

12 Timber harvest in Community Priority ARAs would be limited to micro sales, salvage sales, and small commercial sales less than 

one MMBF in size.
Alternatives Including the Proposed Action 2

Final EIS 2-13 Alternatives Including the 

Proposed Action

Alternative 3 designates 8.22 million acres as ARAs. It removes approximately 1.25 million acres from 

roadless designation, including both development and non-development LUD acres, and adds 107,000 

acres to ARAs including unroaded small islands and unroaded areas greater than 5,000 acres as 

identified by prior forest planning efforts. Adding additional roadless designations to unroaded islands 

provides for continued recreational and outfitter and guide opportunities on these islands. 

Alternative 3 applies the most protective ARA, Watershed Priority, to 3.26 million acres primarily identified 

as T77 Watersheds, TNC/Audubon Conservation Priority Areas, and high-priority sockeye salmon 

watersheds. The Watershed Priority ARA is considered most protective because it includes fewer 

exceptions than the 2001 Roadless Rule, while still allowing activities needed for fisheries protection, 

maintenance, or improvement. The remaining roadless areas include 4.60 million acres in Roadless 

Priority and 0.37 million acres in Community Priority (see Map 3 in map packet or on thumb drive). 

Additionally, for Alternative 3, commercial old-growth timber harvest would be prohibited on NFS lands in T77 

Watersheds, and TNC/Audubon Conservation Priority Areas that extend beyond ARA boundaries.

Alternative 3 proposes a net decrease of 1.14 million roadless acres, as compared to the no action 

alternative, and includes both development and non-development LUDs. Roadless area designation 

would be removed from the 847,000 congressionally-designated LUD II acres that are currently within an 

IRA. The removal of roadless designation from congressionally-designated LUD II acres represents the 

majority of the decrease in designated roadless acres proposed under Alternative 3. Removing roadless 

designation from LUD II acres aligns with congressional intent that LUD II areas be managed “in a 

roadless state to retain their wildland character” (USDA Forest Service 2016a).

Alternative 3 would revert a net of 85,000 old-growth acres and 15,000 young-growth acres, previously 

identified as unsuitable timber lands, to suitable timber lands, as they were when the roadless rule did not 

apply to the Tongass.

Table 2-6 summarizes the key elements of Alternative 3.

Table 2-6

Key Element Summary for Alternative 3

Roadless Areas

• Establishes 8.22 million acres of ARAs, including 4.60 million acres in Roadless Priority, 3.26 million acres in

Watershed Priority and 0.37 million acres in Community Priority.

Prohibition on Timber Harvest1

• Under the Roadless Priority ARA timber harvest exceptions are written slightly broader than under the 2001 

Roadless Rule to better address Alaska’s unique economic development needs. 

• Under the Watershed Priority ARA, timber harvest exceptions are slightly narrower than under the 2001 

Roadless Rule and are designed to address aquatic and terrestrial habitat needs that are unique to Alaska’s 

rural economic conditions and subsistence activities.

• Under the Community Priority ARA, timber harvest exceptions are broader than under the 2001 Roadless 

Rule and allow for small-scale timber harvest. 

• Commercial old-growth timber harvest would be prohibited on T77 Watersheds/TNC-Audubon Conservation 

Priority Areas that largely coincide with ARA, but extend beyond ARA boundaries. This includes all T77 

Watersheds, and TNC/Audubon Conservation Priority Areas, both inside and outside of designated roadless 

areas.

Prohibition on Road Construction and Reconstruction1

• Under the Roadless Priority ARA, road construction/reconstruction exceptions are slightly broader than under 

the 2001 Roadless Rule.

• Under the Watershed Priority ARA, road construction/reconstruction exceptions are slightly narrower than 

under the 2001 Roadless Rule.

• Under the Community Priority ARA, road construction/reconstruction exceptions are broader than under the 

2001 Roadless Rule.
Alternatives Including the Proposed Action 2

Final EIS 2-14 Alternatives Including the 

Proposed Action

Table 2-6 (continued)

Key Element Summary for Alternative 3

Tongass Land and Resource Management Plan

• No changes to Goals and Objectives, Land Use Designations or Management Prescriptions, Forest-wide 

Standards and Guidelines, Plan Components developed underthe 2012 Planning Rule, PTSQ, PWSQ, and 

the Young-growth Transition.

• Change to Timber Land Suitability: A net of 85,000 old-growth acres and 15,000 young-growth acres, 

previously identified as unsuitable timber lands, would become suitable timber lands.

1 See detailed descriptions of prohibitions/exceptions in Table 2-2.

Alternative 4 

Alternative 4 provides substantial additional timber harvest opportunity while maintaining roadless 

designations for Scenic Viewsheds and T77/TNC-Audubon Conservation Priority Areas that are in 

roadless areas. Approximately 401,000 acres are removed from roadless designation, including 

substantially-altered areas and logical extensions of substantially-altered acres (similar to Alternatives 2 

and 3), along with selected additional locations for economic timber sales. Protection is maintained for 

Scenic Viewsheds, and most T77 Watersheds and TNC/Audubon Conservation Priority Areas by 

designating them as Roadless Priority ARAs. 

Additionally, Alternative 4 adds 7,000 acres as LUD II Priority ARA. These added roadless acres are LUD 

II areas that were not designated as IRA under the 2001 Roadless Rule. No additional lands would be 

added to ARAs.

The net result of removals and additions under Alternative 4 is 8.98 million roadless acres, which are

designated into three categories of ARAs: LUD II Priority, Roadless Priority, and Timber Priority (see Map 

4 in map packet or on thumb drive). This alternative was developed to provide for a high level of timber 

management opportunities thus, timber management is permitted in the Timber Priority ARA, which 

consists of the Timber Production and Modified Landscape LUDs, as identified in the Forest Plan.

Alternative 4 proposes a net decrease of 394,000 roadless acres as compared to the no action 

alternative. However, the net increase in suitable timber lands is substantially higher than expected based 

on the decrease in roadless acres alone. This is because the Timber Priority ARA acres produce a large 

component of suitable timber. Under Alternative 4, a net of 161,000 old-growth acres and 15,000 younggrowth acres, previously identified as unsuitable timber lands, would revert to suitable timber lands, as 

they were when the roadless rule did not apply to the Tongass.

Table 2-7 summarizes the key elements of Alternative 4.
Alternatives Including the Proposed Action 2

Final EIS 2-15 Alternatives Including the 

Proposed Action

Table 2-7

Key Element Summary for Alternative 4

Roadless Areas

• Converts inventoried roadless areas to 8.98 million acres of ARAs, including 7.36 million acres in Roadless 

Priority, 0.76 million acres in Timber Priority, and 0.85 million acres in LUD II Priority categories.

Prohibition on Timber Harvest1

• Under the Roadless Priority ARA timber harvest exceptions are written slightly broader than under the 2001 

Roadless Rule to better address Alaska’s unique economic development needs. 

• Under the Timber Priority ARA there are no timber harvest prohibitions.

• Under the LUD II Priority ARA, timber harvest exceptions are slightly broader than under the 2001 Roadless 

Rule and are designed to align the Alaska Roadless Rule with congressional instructions. 

Prohibition on Road Construction and Reconstruction

• Under the Roadless Priority ARA road construction/reconstructionexceptions are slightly broader than under 

the 2001 Roadless Rule.

• Under the Timber Priority ARA there are no roadconstruction/reconstruction prohibitions.

• Under the LUD II Priority ARA road construction/reconstruction exceptionsare slightly broader than under the 

2001 Roadless Rule. 

Tongass Land and Resource Management Plan

• No changes to Goals and Objectives, Land Use Designations or Management Prescriptions, Forest-wide 

Standards and Guidelines, Plan Components developed under the 2012 Planning Rule, PTSQ, PWSQ, and 

the Young-growth Transition.

• Change to Timber Land Suitability: A net of 161,000 old-growth acres (mostlyin Timber Priority ARAs) and 

15,000 young-growth acres previously identified as unsuitable timber lands would become suitable timber

lands.

1 See detailed descriptions of prohibitions/exceptions in Table 2-2.

Alternative 5

Alternative 5 provides maximum additional timber harvest opportunity (same as Alternative 6) by 

removing all Timber Development, Modified Landscape, and Scenic Viewshed LUDs identified by the 

Forest Plan from roadless designation, including T77 Watersheds and TNC/Audubon Conservation 

Priority Areas within aforementioned development LUDs. Areas with mineral potential, as identified by the 

Forest Plan’s minerals overlay, are also removed from roadless designation (see Map 5 in map packet or 

on thumb drive).

Alternative 5 would designate 7.05 million acres as ARAs. About 2.32 million acres would be removed from 

roadless area designation including mineral overlay acres and development LUDs including T77 Watersheds 

and TNC/Audubon Conservation Priority Areas. The remaining 7.05 million roadless acres are designated to 

two ARAs: LUD II Priority (0.85 million acres) and Roadless Priority (6.20 million acres) (see Map 5 in map 

packet or on thumb drive). Alternative 5 also reverts a net 168,000 old-growth acres and 17,000 young-growth 

acres previously identified as unsuitable timber lands to suitable timber lands, as they were when the 

roadless rule did not apply to the Tongass.

Table 2-8 summarizes the key elements of Alternative 5.

Table 2-8

Key Element Summary for Alternative 5

Roadless Areas

• Converts inventoried roadless areas to 7.05 million acres of ARAs, including 6.20 million acres in Roadless 

Priority and 0.85 million acres in LUD II Priority categories.
Alternatives Including the Proposed Action 2

Final EIS 2-16 Alternatives Including the 

Proposed Action

Table 2-8 (continued)

Key Element Summary for Alternative 5

Prohibition on Tree Cutting1

• Under the Roadless Priority ARA timber harvest exceptions are written slightly broader than under the 2001 

Roadless Rule to better address Alaska’s unique economic development needs. 

• Under the LUD II Priority ARA timber harvest exceptions are slightlybroader than under the 2001 Roadless

Rule.

Prohibition on Road Construction and Reconstruction1

• Under the Roadless Priority ARA road construction/reconstructionexceptions are slightly broader than under 

the 2001 Roadless Rule.

• Under the LUD II Priority ARA, timber harvest exceptions are slightly broader than under the 2001 Roadless 

Rule and are designed to align the Alaska Roadless Rule with congressional instructions.

Tongass Land and Resource Management Plan

• No changes to Goals and Objectives, Land Use Designations or Management Prescriptions, Forest-wide 

Standards and Guidelines, Plan Components developed under the 2012 Planning Rule, PTSQ, PWSQ, and 

the Young-growth Transition.

• Change to Timber Land Suitability: A net of 168,000 old-growth acres and 17,000 young-growth acres 

previously identified as unsuitable timber lands would become suitable timber lands.

1 See detailed descriptions of prohibitions/exceptions in Table 2-2.

Alternative 6 (Preferred Alternative)

Alternative 6 is the preferred alternative and provides maximum additional timber harvest opportunities 

(same as Alternative 5) as the full exemption alternative, which was requested by the State of Alaska’s 

petition (Appendix A). It removes all 9.37 million inventoried roadless acres on the Tongass from roadless 

designation. Acres removed from roadless designation would continue to be managed by the Forest Plan 

and in accordance with applicable statutory instructions (see Map 6 in map packet or on thumb drive). 

Existing protections to roadless characteristics provided by Forest Plan non-development LUDs (including 

LUD II, Remote Recreation, Semi-remote Recreation, Old-growth Habitat, Special Interest Area, Wild 

River, Scenic River, and others) would remain in place. 

Alternative 6 would exempt the Tongass from the 2001 Roadless Rule. Alternative 6 would revert a net 

total of 168,000 old-growth acres and 20,000 young-growth acres, previously identified as unsuitable 

timber lands, to suitable timber lands, as they were when the roadless rule did not apply to the Tongass. 

Table 2-9 summarizes the key elements of Alternative 6.

Table 2-9

Key Element Summary for Alternative 6

Roadless Areas

• Removes all 9.37 million acres of inventoried roadless acres on the Tongassfrom roadless designation.

Prohibition on Timber Harvest1

• Roadless Rule prohibitions on timber harvest activities would no longer be applicable.

Prohibition on Road Construction and Reconstruction1

• Roadless Rule prohibitions on road construction/reconstruction prohibitions would no longer be applicable.

Tongass Land and Resource Management Plan

• No changes to Goals and Objectives, Land Use Designations or Management Prescriptions, Forest-wide 

Standards and Guidelines, Plan Components developed under the 2012 Planning Rule, PTSQ, PWSQ, and 

the Young-growth Transition.

• Change to Timber Land Suitability: A net of 168,000 old-growth acres and 20,000 young-growth acres 

previously identified as unsuitable timber lands would become suitable timber lands. 1 See detailed descriptions of prohibitions/exceptions in Table 2-2.
Alternatives Including the Proposed Action 2

Final EIS 2-17 Alternatives Including the 

Proposed Action

Maps

Large-scale color maps showing roadless areas by IRA or ARA (Map 1 to 6) are included on the thumb 

drive version of the FEIS, in the map packet that accompanies the FEIS paper copy, and on this project’s 

website: https://www.fs.usda.gov/project/?project=54511. Additional maps showing the lands that would 

be suitable for timber production (Maps 7 to 12) and the lands that would be suitable for timber production 

by certain outfitter/guide use areas (Maps 13 to 18) are included on the thumb drive and website. Maps 

showing suitable lands by community use area are for each alternative are included in Appendix D on the 

thumb drive and website.

Alternatives Considered but Eliminated from 

Detailed Analysis

Sometimes alternatives are suggested or proposed that on examination do not adequately respond to the 

purpose of and need for the action, are technically or economically cost prohibitive, are not ripe for 

consideration, are remote or speculative, are substantially similar in design to an existing alternative, 

would have substantially similar effects as an existing alternative, or the authority does not exist to 

approve such actions (Forest Service Handbook 1909.15, Section 14.4). Alternatives that were 

considered and eliminated from detailed analysis are described below, along with the rationale for their 

elimination.

Giving management of the Tongass to the State of Alaska. This alternative was eliminated from 

detailed study because it does not comport with existing legal authorities.

Co-management of the Tongass with tribal partners. This alternative was eliminated from detailed 

study because it does not comport with existing legal authorities.

Congressional changes to 2001 Roadless Rule in Alaska. This alternative was eliminated because it 

is outside the authority of the USDA. Legislative proposals to address the 2001 Roadless Rule in 

Alaska have periodically occurred in the past and have not been enacted. In addition, nothing in any 

alternative would prevent future legislation addressing application of either the 2001 Roadless Rule or 

an Alaska state-specific rule.

Use of the 2003 or 2008 roadless inventories as ARAs. Use of alternative inventories was eliminated 

following review of those inventories and the determination that those inventories contain many areas 

with difficult shapes and of insufficient size to effectively manage or identify on the ground. Several of 

the areas identified in the 2003 and 2008 inventory contain roaded roadless lands. Unroaded areas 

greater than 5,000 acres identified in the 2003 and 2008 roadless inventories were incorporated into 

Alternatives 2 and 3. 

Comparison of the Alternatives

This section compares the environmental consequences of the six alternatives with respect to the key 

issues described in Chapter 1. This comparison is based on the effects analyses presented in Chapter 3. 

For reference, Table 2-10 summarizes the acres by ARAs, the acres removed or added from inventoried 

roadless designation, and the total old-growth acres that are suitable for timber production under 

Alternative 1 and the five action alternatives. Table 2-12, at the end of this section, summarizes the 

environmental consequences for each alternative in a comparative format. Nine categories are used for 

the Qualitative ratings in Table 2-12 as follows (from most adverse to most beneficial): 

Substantial Adverse Effect

Moderate Adverse Effect

Small Adverse Effect

Very Small Adverse Effect 

Neutral/No Effect 

Very Small Beneficial Effect 

Small Beneficial Effect 

Moderate Beneficial Effect 

Substantial Beneficial Effect
Alternatives Including the Proposed Action 2

Final EIS 2-18 Alternatives Including the 

Proposed Action

Table 2-10

Roadless Areas by Alternative and Management Designation

Roadless Designation 

(acres)

Alternative

1 2 3 4 5 6

No Action

Roaded 

Roadless

Logical 

Extension

Partial 

Dev. LUDs1

All Dev. 

LUDs

Full 

Exemption

Total Roadless Area 9,368,000 9,336,000 8,224,000 8,975,000 7,047,000 0

ARA Management Designations

LUD II Priority N/A 854,000 0 854,000 847,000 0

Watershed Priority N/A 3,284,000 3,259,000 0 0 0

Roadless Priority N/A 5,199,000 4,595,000 7,363,000 6,200,000 0

Community Priority N/A 0 370,000 0 0 0

Timber Priority N/A 0 0 757,000 0 0

Change in Roadless Area Acres

Roadless Area Removed 0 142,000 1,252,000 401,000 2,321,000 9,368,000

Roadless Area Added 0 110,000 107,000 7,000 0 0

Net Change 0 -32,000 -1,144,000 -394,000 -2,321,000 -9,368,000

Old-Growth Acres Suitable for Timber Production

Total Acres 227,000 247,000 312,000 388,000 395,000 395,000

Net Change 0 20,000 85,000 161,000 168,000 168,000

T77 & TNC/ Audubon Conservation Priority Areas Outside of Roadless given Long-term Regulatory 

Protection

Total Acres 0 0 507,000 0 0 0

N/A = not applicable

1 Includes Timber Production and Modified Landscape LUDs, but not Scenic Viewshed.

Note: Numbers may not appear to sum correctly due to rounding.

Key Issue 1 – Roadless area conservation

Roadless area conservation is analyzed in terms of both the acres designated as roadless and the 

degree of protection provided by each alternative. In terms of acres designated, Alternatives 1 and 2 

provide the highest degree of regulatory protection with approximately 9.37 and 9.34 million acres 

designated as roadless, respectively, and Alternative 6 provides the lowest with zero acres of designated 

roadless areas. Alternative 5 removes all regulatory roadless designations within development LUDs13

and has the second lowest number of acres designated roadless with 7.05 million acres.

Alternatives 3 and 4 are intermediate in terms of the acres designated as roadless with 8.22 and 8.98 

million acres designated, respectively. However, the roadless designations by Alternative 4 include 0.76 

million acres of Timber Priority ARAs, which allow timber harvest and road construction for timber harvest, 

and 0.85 million acres of LUD II Priority ARAs, which provide little additional conservation of roadless 

values over the protection already provided LUD II. In addition, Alternative 3 would designate T77 

Watersheds, TNC/Audubon Conservation Priority Areas, and high-priority sockeye salmon watersheds as 

Watershed Priority ARAs. The removal of roadless designation from LUD II acres accounts for a large 

share of the reduction in designated roadless area acres under Alternative 3. These acres would retain 

their specific statutory protections and be managed to preserve roadless area characteristics without 

roadless designation (Table 2-11). Therefore, protection of roadless characteristics is much greater under 

Alternative 3 compared with Alternative 4.

The roadless rule language under Alternative 1 would be unchanged from the 2001 Roadless Rule (as 

reinstated by the District Court). Under Alternative 6, the Tongass would be fully exempted from the 2001 

Roadless Rule. The rule language would be modified under Alternatives 2, 3, 4, and 5. 

13 Note that, with the exception of the Timber Priority ARA designation, roadless designation on development LUDs provides the 

highest degree of protection, because development LUDs are most likely to be developed if they were not designated roadless. Most 

non-development LUDs have Forest Plan restrictions which limit their potential for development.
Alternatives Including the Proposed Action 2

Final EIS 2-19 Alternatives Including the 

Proposed Action

For alternatives that involve priority areas, the Roadless Priority and LUD II Priority management 

categories would be very slightly more permissive than Alternative 1 in terms of road construction, 

salvage timber harvest, and mineral development, and would be slightly more permissive in terms of 

energy and transportation project development. The Watershed Priority ARA would be slightly less 

permissive relative to timber harvest, road construction, and other developments and the Community 

Priority and Timber Priority categories under Alternatives 314 and 4, respectively, would be substantially 

more permissive of development, especially timber harvest and road construction.

As a result, Alternatives 1, 2, and 3 would provide the greatest protection of roadless characteristics. 

Alternative 1 would protect the most acres and existing management direction would provide the highest 

degree of protection, with the existing general prohibitions remaining in place for all areas. Alternative 2 

would offer similar levels of protection, with a small reduction in total designated roadless acres. The 

roaded roadless and other substantially altered areas that would be removed under Alternative 2 have 

limited roadless characteristics, and increased regulatory protection would be added for the Watershed

Priority ARA. Thus, both Alternatives 1 and 2 would allow timber harvest and road construction almost 

entirely in roaded and altered areas. 

Alternative 3 would offer the next most protection of roadless area characteristics. Roaded roadless and 

other substantially altered areas along with logical extension areas would be removed under Alternative 3 

(as well as LUD II areas), and most ARAs would be managed as Roadless Priority or Watershed Priority

ARAs. Additionally, T77 Watersheds and TNC/Audubon areas outside of roadless would be given 

regulatory protection from old-growth harvest. About 3 percent of ARAs under Alternative 3 would be 

designated as Community Priority, which allows limited timber harvest opportunity. An estimated 8,000 

acres of old-growth harvest would occur within the logical extension areas under Alternative 3 over 100 

years. The remaining 34,500 estimated acres of old-growth harvest would be in roaded and altered areas. 

Alternatives 4 through 6 would provide the least amount of roadless designations, with Alternative 6 

removing all acres from regulatory roadless designation. Under these alternatives, an estimated 8,000 

acres of old-growth harvest would occur over 100 years within the logical extension areas as with 

Alternative 3, and an additional 6,000 to 7,000 acres of estimated old-growth harvest would occur in 

areas more distant from roads that are removed from roadless by these alternatives. The remaining 

27,500 to 28,500 acres of estimated old-growth harvest would occur in roaded and altered areas. 

In general, harvest and road construction that occurs in roaded and altered areas would have relatively 

little impact on conserving roadless characteristics, while harvest and road construction that occurs in 

extension areas and areas more distant from roads would have a greater adverse effect. 

Table 2-11

Roadless Area Characteristics

2001 Roadless Rule Characteristics, Modified for Alaska

Biological Values

• Diversity of plant and animal communities and protection of old-growth forests

• Habitat – Roadless areas are expansive areas where high-quality intact habitat exists and ecosystems 

function with all their native species and components. Roadless areas serve as habitat for threatened, 

endangered, proposed, candidate, and sensitive species and for those species dependent on large, 

undisturbed areas of land. 

Physical Values

• Environment – high-quality or undisturbed soil, water, and air.

• Water – Roadless areas provide a variety of water resources including public drinking water sources, fish and 

aquatic resources, and hatchery aquatic resources.

14 Timber harvest in Community Priority ARAs would be limited to micro sales, salvage sales, and commercial sales less than one 

MMBF in size.
Alternatives Including the Proposed Action 2

Final EIS 2-20 Alternatives Including the 

Proposed Action

Table 2-11 (continued)

Roadless Area Characteristics

2001 Roadless Rule Characteristics, Modified for Alaska

Social Values

• Remoteness – Roadless areas provide economic opportunity due to rich primitive, semi-primitive motorized, 

and semi-primitive non-motorized classes of dispersed recreation.

• Landscape – reference landscapes of relatively undisturbed areas that serve as a barometer to measure the 

effects of development on other parts of the landscape.

• Scenery – natural-appearing landscapes with high-scenic qualities that people value.

• Cultural – rich in traditional cultural properties and sacred sites.

• Locally-unique characteristics – geographic areas with additional locally-unique characteristics specific to 

Alaska including: 1) important sources of subsistence resource; 2) rich habitat that supports multiple species 

of fish for personal, subsistence, sport, recreation, and commercial harvest; and 3) supports diverse 

economic opportunity that is especially important for rural community well-being.

Source: USDA Forest Service 2000, modified to reflect the unique characteristics of Alaska.

Key Issue 2 – Support local and regional socioeconomic 

well-being, Alaska Native culture, rural subsistence activities, 

and economic opportunity across multiple economic sectors

Support for Southeast Alaska resource-based industries and local/regional socioeconomic well-being is 

compared among the alternatives by industry/category in the following subsections.

Forest Products Industry

The Forest Plan, as amended in 2016, established an average annual Projected Timber Sale Quantity 

(PTSQ) of 46 MMBF prior to the young-growth transition. The old-growth contribution to the PTSQ is 

expected to start out high and decrease over time as more young growth becomes economic to harvest. 

During the first decade, an average of about 12 MMBF of young growth and 34 MMBF of old growth was 

expected to be sold annually. From Year 11 through Year 15 an average of about 28 MMBF of young 

growth and 18 MMBF of old growth were expected to be sold annually. Old-growth volume offered was 

projected to decrease until it reaches 5 MMBF per year (expected to occur about Year 16), at which point 

it is to be stabilized at 5 MMBF per year to support small operators and specialty products such as wood 

for musical instruments. Young growth sales are expected to continue to increase at a rapid rate after 

Year 16 and are expected to reach an upper limit of 98 MMBF about Year 18. If less than the average 

annual PTSQ figure of 46 MMBF is sold in the early years of a decade, the Forest Plan allows the 

difference to be added to the sale quantity for the remainder of the decade. During the initial two years of 

implementing the Forest Plan, the total volumes sold were 30.7 MMBF in Fiscal Year 2017 (about 3 

percent of which was old growth) and 9.0 MMBF in Fiscal Year 2018 (all of which was old growth). 

None of the action alternatives would result in changes to the PTSQ and the timber objectives of the 

Forest Plan would continue to require transitioning to primarily young-growth harvest. Therefore, harvest 

levels are not expected to vary significantly among the alternatives. However, the alternatives do vary in 

terms of the amount and location of acres suitable for timber production. Greater total acreage of suitable 

land would provide greater flexibility in the selection of future timber sale areas, as well as the potential 

for more flexibility in sale design, depending on the planning areas selected. This improved flexibility 

could, in turn, improve the Forest Service’s ability to offer economic sales that meet the needs of industry. 

This greater flexibility could be beneficial during the first two decades of the 2016 Forest Plan (the 

transition period), when most old-growth harvest would take place.

Under Alternative 1, about 227,000 acres of old growth and 334,000 acres of young growth are currently 

suitable for timber production. The young-growth suitable acres would increase slightly (3 through 6 

percent) under the action alternatives. For old growth, however, the suitable acreage increase would 

range from 7 percent for Alternative 2 to 74 percent for Alternatives 5 and 6. For Alternatives 3 and 4 the 
Alternatives Including the Proposed Action 2

Final EIS 2-21 Alternatives Including the 

Proposed Action

increase would be 37 percent and 71 percent, respectively. It should be noted, however, that harvest 

levels and road construction are not expected to change significantly among the alternatives, although 

harvest and road locations would be more widespread as suitable acres increase. 

The additional suitable old-growth acres comprise lands fitting into three broad categories or areas: 

roaded roadless and other substantially altered areas (Alternatives 2 through 6); logical extension areas 

and areas adjacent to roads (Alternatives 3 through 6); and areas more distant from existing roads 

(Alternatives 4 through 6). In addition, suitable old-growth acres would be added in Community Priority 

ARAs, which are associated with seven communities (Alternative 3).15 The substantially altered areas 

removed, the areas immediately adjacent (logical extensions), and the Community Priority ARAs are 

assumed to be more economical to harvest due to their proximity to existing infrastructure. The additional 

acres added under Alternatives 4 through 6 are farther from existing infrastructure and thus less likely to 

be economic to harvest.

Recreation and Tourism

Timber harvest and road construction projects within roadless areas have the potential to affect 

outfitter/guide operations which provide commercial recreation opportunities on the Forest and are often 

dependent on high scenic integrity and undisturbed landscapes. Development projects permitted as a 

result of changes in roadless area designations could also affect outfitter/guide use in other adjacent or 

nearby areas as outfitter/guides displaced from one location seek other places to take clients. Some use 

areas are presently at capacity, which could exacerbate potential displacement effects. The Forest’s 

ability to meet outfitter/guide demand, especially for operators seeking more remote areas, could also be 

affected.

The outfitter/guide analysis prepared for this FEIS used changes in suitable old-growth acres in 

conjunction with information about existing outfitter/guide use to focus on potentially affected areas. The 

resulting analysis identified 15 outfitter/guide use areas where potential conflicts between existing 

outfitter/guide use and future management activities could occur. In most of these areas, existing 

outfitter/guide use occurs near areas where development has occurred, either near or along shorelines 

and/or Forest road systems. Similarly, in most cases, timber harvest that could already occur in these 

areas (under Alternative 1) has the potential to conflict with existing outfitter/guide use. 

Viewed in terms of increases in acres suitable for harvest, impacts under Alternatives 2 and 3 would be 

minimal in all areas, with increases in designated roadless acres and reductions in suitable acres 

occurring in some areas under these alternatives. By expanding the acres available for harvest, 

Alternatives 4 to 6 could in some cases add to these potential impacts by increasing the geographic 

extent of the acres affected, which could also result in an increase in road miles needed. 

Commercial Salmon Harvesting and Processing

None of the alternatives are expected to significantly affect the commercial fishing or fish-processing 

industries. Riparian Management standards and guidelines established in the Forest Plan would remain 

in place under all of the alternatives. While there would be some variation in the level of protection, these 

variations are not expected to affect the commercial fishing industry. The future of the commercial fishing 

industry in Southeast Alaska is more likely to depend upon occurrences outside of the Tongass National 

Forest such as hatchery production, offshore harvest levels, and changes in ocean conditions.

Mining and Mineral Development

Locatable minerals development is possible within designated roadless areas under all alternatives. The 

General Mining Act of 1872 authorizes and governs prospecting and mining for locatable minerals on 

NFS lands, including designated roadless areas. Changes in roadless management are, therefore, not 

expected to affect existing or future locatable mineral exploration or mining activities on the Forest.

15 Timber harvest in Community Priority ARAs would be limited to micro sales, salvage sales, and commercial sales less than one 

MMBF in size.
Alternatives Including the Proposed Action 2

Final EIS 2-22 Alternatives Including the 

Proposed Action

Under the 2001 Roadless Rule roadbuilding is prohibited for any new leasable mineral projects, including 

geothermal projects, within IRAs. Changes in management under Alternatives 2 to 6 would allow road 

development to differing degrees. Within Timber Priority ARAs, roads would be permissible for leasable 

projects. The Tongass has no recent or current leasable mineral activity and the demand for leasable 

minerals is expected to remain low. As a result, changes in designated roadless management are 

expected to have limited impacts on mineral development. Geothermal energy projects could be allowed 

in Roadless Priority and Community Priority ARAs under exceptions provided for community utility 

projects.

Infrastructure Development

With some exceptions, discretionary federal road development is limited in IRAs. Examples of exceptions 

include roading pursuant to reserved or outstanding rights, roads provided for by statute or treaty, or a 

qualified Federal Aid Highway. Roadless designation would be removed to various degrees under the 

action alternatives with corresponding implications for regional highway development. In most cases, the 

alternative rules would be more permissive with respect to regional road systems and infrastructure.

Tree Harvest for Alaska Native Cultural Purposes

Tree harvest for Alaska Native cultural purposes is allowed under the 2001 Roadless Rule (Alternative 1) 

but road access for the tree harvesting is not. Alternatives 2, 3, 4, and 5 do support Alaska Native culture 

through explicit rule language that allows increased access to cutting, customary trade, and removal of 

trees for the purposes of Alaska Native customary and traditional uses. This increased access is provided 

in the Roadless and Community Priority ARAs. Access for cultural purposes in ARAs has benefits but 

access as a result of removing roadless area designations or designating them as Timber Priority ARAs 

may increase competition with the timber industry for trees to be used for traditional or cultural purposes, 

and this competition is the greater concern from the Tribes. 

Based on this rationale, Alternatives 2 and 1 would appear to be best overall, because of the relatively 

low level of competition with commercial timber harvest they would create. Alternative 2 would rank higher 

than Alternative 1 because they are almost the same in terms of competition and Alternative 2 includes 

over 5 million acres of Roadless Priority, which would improve access relative to the 2001 Roadless Rule. 

Alternatives 4 and 3 would rank in the middle overall. Alternative 4 would rank higher than Alternative 3 

because they are very similar in terms of acres opened up for competition, but Alternative 4 includes over 

7 million acres of Roadless Priority while Alternative 3 includes less than 5 million acres in Roadless and 

Community Priority ARAs, combined. Alternatives 5 and 6 would allow road construction for access to 

Alaska Native cultural sites, but would also allow the most access for commercial timber harvest and 

other competing uses, which would outweigh the benefits. Potential conflicts between competing uses 

under Alternatives 5 and 6 would primarily be limited to areas managed as development LUDs. 

Rural Subsistence Activities 

Potential effects on rural subsistence activities are expected to be similar to the current Forest Plan under

all of the action alternatives, with similar effects anticipated with respect to abundance and distribution, 

access, and competition. Timber harvest levels are expected to remain the same for all alternatives, with 

similar or only slightly different miles of road construction/reconstruction also anticipated. While there 

would be some new road access under all alternatives in the long run, nearly all new roads constructed 

under the alternatives would be closed following harvest, based on current practices. These roads would, 

therefore, not be available for use by highway vehicles or high-clearance vehicles. They may, however, 

be available for access by other methods and could, as a result, have the potential to affect existing 

subsistence patterns. Although overall road miles would be similar, based on the relative distribution of 

acres suitable for timber production, road miles are expected to be slightly higher for Alternatives 4, 5, 

and 6. The effects on particular groups of subsistence users or resources are difficult to predict at the 

programmatic level, but the slight difference in road miles is expected to result in little to no difference to 

rural subsistence activities between alternatives.
Alternatives Including the Proposed Action 2

Final EIS 2-23 Alternatives Including the 

Proposed Action

Community Effects

Relative to Alternative 1, no major community effects would be expected under the action alternatives. 

The largest degree of change would be expected under Alternatives 4, 5, and 6 because these 

alternatives would result in larger increases in suitable timber (and potential harvest) within many 

community use areas, especially in those that are more remote (see Appendices D and E).16

Communities with economies that benefit from timber harvest or seek increased roaded access could see 

some modest benefits, but communities with economies that are dominated by the visitor industry have 

expressed concerns (see Table E-2 in Appendix E). Based on an evaluation of employment and business 

licenses by community, along with the amount of suitable timber within community areas (which serves as 

an index to potential timber harvest), the following observations can be made: 

Alternatives 1 and 2 are expected to generally result in very little to no effect on communities. 

However, because this EIS is programmatic in nature, the direct effects associated with project 

activities on any community cannot be identified until specific projects are proposed.

Alternative 3 is expected to have very minimal potential for community effects, either adverse or 

beneficial. Community Priority ARAs in this alternative may be beneficial to communities by 

increasing flexibility for the communities adjacent to designated roadless areas. 

Alternatives 4, 5, and 6 (especially Alternatives 5 and 6) have an increased potential for effects on 

communities relative to the other alternatives, especially in those communities where the visitor 

industry sector is important. This is primarily because those communities rely on undisturbed 

landscapes within the community areas, which in turn may affect visitor use. The smaller and less 

diversified communities have a greater risk of effects. In addition, communities influenced by the 

timber industry may experience minor beneficial effects resulting from flexibility for timber harvest. 

Because of the programmatic nature of this EIS, the effects on any community cannot be identified 

until specific projects are proposed, but it is expected that they would range from no effect to a 

minimal effect for these alternatives.

Key Issue 3 – Conserve terrestrial habitat, aquatic habitat, 

and biological diversity

Old-Growth Habitat

Relative to old-growth habitat conservation, all of the alternatives would have old-growth harvest levels 

similar to the level authorized by the Forest Plan. There may be slightly more high-volume and large-tree 

POG harvested under the action alternatives than was predicted for the Forest Plan because of the 

increased options for developing economic timber sales. However, this is speculative and depends on 

harvest levels reaching predicted decadal levels, which depends on economic access to these stands. In 

addition, the proportion of high-volume and large-tree POG in the added suitable acres under the action 

alternatives is lower than the proportion in the Alternative 1 suitable acres. 

The transition to young-growth management would continue to slow the long-term decrease in deer 

habitat capability due to the reduction in POG harvest, under all of the alternatives. Because long-term 

POG harvest and road densities are not expected to differ significantly among alternatives, effects on oldgrowth–dependent wildlife species are expected to be almost identical to those predicted under the 2016 

Forest Plan Amendment EIS.

16 Appendix D presents suitable old-growth and young-growth timber maps for the community use areas identified for the 32 

communities evaluated in this EIS (see Appendix E). These maps are available electronically only. They are included on the thumb 

drive accompanying this document and are also available online at: https://www.fs.usda.gov/project/?project=54511
Alternatives Including the Proposed Action 2

Final EIS 2-24 Alternatives Including the 

Proposed Action

Young Growth in Special Habitats

Young growth suitable for timber harvest occurs in a number of habitats under the Forest Plan, including 

Riparian Management Areas, Beach and Estuary Fringe, and the Old-growth Habitat LUD. Young growth on 

specific portions of these areas may be harvested using required silvicultural prescriptions following Forest 

Plan direction. The suitable acres of young growth on these special habitats would increase slightly under 

the action alternatives, but only slightly because the majority of existing young-growth stands are not in 

designated roadless areas. Therefore, little to no difference in effects among the alternatives is expected.

Road Density

Slightly more road miles would be developed under the action alternatives with more acreage removed 

from roadless. Under current conditions approximately 4,929 miles of road (including decommissioned 

road) exist on the Tongass and the average road density is approximately 0.19 mile per square mile. 

Under Alternatives 1 and 2, total road miles after 100 years would equal about 5,922, while total road 

miles under Alternative 6 would equal about 5,972. The other action alternatives would range from 5,941 

to 5,968 miles after 100 years. The overall road density on the Tongass would be approximately 0.23 

under all of the alternatives. At present approximately 68 percent of 6th field subwatersheds on the 

Tongass have no roads. After 100 years, this percentage would drop to 62 percent for Alternative 1, 61 

percent for Alternative 2, 60 percent for Alternative 3, 58 percent for Alternatives 4 and 5, and 56 percent 

for Alternative 6. This pattern would be reversed for watersheds with existing high road densities, 

although differences would be slight. For example, 0.6 percent of the watersheds would have road 

densities greater than 3 miles per square mile under Alternatives 1 and 2, but 0.5 percent of the 

watersheds would have densities this high under Alternatives 3, 4, 5, and 6 (due to roads being more 

spread out).

Fish Habitat

Overall effects to fish habitat are expected to be negligible under all alternatives, because of the strong 

protections to fish habitats provided by Forest Plan LUDs, Forest-wide standards and guidelines including 

the riparian management strategy, and the lack of old-growth harvest or associated road construction 

allowed in the T77 watersheds and TNC /Audubon Conservation Priority Areas. Alternative 3 provides 

additional long-term regulatory protection for T77 watersheds and TNC/Audubon Conservation Priority 

Areas by prohibiting old-growth harvest by regulation. Localized effects on fish habitat may occur, but these 

are expected to be minimal overall.

Species-Specific Effects

The transition to young-growth management would continue to slow the long-term decrease in deer 

habitat capability due to the reduction in POG harvest, under all of the alternatives. Because long-term 

POG harvest and road densities are expected to be similar to those under the Forest Plan, effects on oldgrowth–dependent or associated wildlife species are expected to be almost identical to those predicted by 

the 2016 Forest Plan Amendment EIS.
Alternatives Including the Prop

Final EIS 2-25 Alternatives Includin

Table 2-12

Comparison of Alternatives

Resource/Category 

Unit of 

Measure

Alternative

1 2 3 4 5 

No Action

Roaded

Roadless 

Logical

Extensions

Partial

Dev LUDs

Full

Dev LUD

Key Issue 1 – Roadless Area Conservation

Overall Protection of Roadless 

Characteristics on the Tongass

Qualitative1 Neutral/No 

Effect

Neutral/No 

Effect

Very Small 

Adverse Effect

Small Adverse 

Effect

Moderate 

Adverse Ef

Total Roadless Area Acres 9,368,000 9,336,000 8,224,000 8,975,000 7,047,00

Roadless Priority Acres N/A 5,199,000 4,595,000 7,363,000 6,200,00

LUD II Priority Acres N/A 854,0002 0 854,0002 847,000

Watershed Priority Acres N/A 3,284,000 3,259,000 0 0 

Community Priority Acres N/A 0 370,000 0 0 

Timber Priority Acres N/A 0 0 757,000 0 

Roadless Area Removed Acres 0 142,000 1,252,000 401,000 2,321,00

Roadless Area Added Acres 0 110,000 107,000 7,000 0 

Roadless Area in Development 

LUDs3

Acres 2,192,000 2,139,000 1,945,000 1,887,0004 33,0005 

Key Issue 2 – Support local and regional socioeconomic well-being, Alaska Native culture, rural subsistence activities, and econo

across multiple economic sectors

Forest Products Industry Qualitative Neutral/No 

Effect

Very Small 

Beneficial Effect

Small Beneficial 

Effect

Small Beneficial 

Effect

Small Benef

Effect

Recreation/Tourism (Visitor) Industry Qualitative Neutral/No 

Effect

Neutral/No 

Effect

Very Small 

Adverse Effect

Small Adverse 

Effect

Small Adve

Effect

Fisheries Industry Qualitative Neutral/No 

Effect

Neutral/No 

Effect

Neutral/No Effect Neutral/No 

Effect

Neutral/N

Effect

Minerals Development Potential

Locatable Qualitative Neutral/No 

Effect

Neutral/No 

Effect

Neutral/No Effect Neutral/No 

Effect

Neutral/N

Effect

Leasable Qualitative Neutral/No 

Effect

Very Small 

Beneficial Effect

Very Small 

Beneficial Effect

Moderate 

Beneficial Effect

Moderate 

Beneficial E

Renewable Energy Project 

Development Potential

Qualitative Neutral/No 

Effect

Small Beneficial 

Effect

Small Beneficial 

Effect

Small Beneficial 

Effect

Small Benef

Effect

Potential for Development of State 

Roads and Other Transportation 

Projects

Qualitative Neutral/No 

Effect

Small Beneficial 

Effect

Small Beneficial 

Effect

Moderate 

Beneficial Effect

Moderate 

Beneficial E
Alternatives Including the Prop

Final EIS 2-26 Alternatives Includin

Table 2-12 (continued)

Comparison of Alternatives

Resource/Category 

Unit of 

Measure

Alternative

1 2 3 4 5 

No Action

Roaded

Roadless 

Logical

Extension

Partial

Dev LUDs

Full

Dev LUDs

Land Suitable for Timber Production

Old Growth Acres 227,000 247,000 312,000 388,000 395,000 

Young Growth Acres 334,000 345,000 349,000 349,000 351,000 

Increase in Suitable Old Growth

In Roaded Roadless Acres 0 20,000 20,000 20,000 20,000 

In Extensions of Roaded Areas Acres 0 0 49,000 49,000 49,000 

In Community Priority Areas Acres 0 0 16,000 0 0 

In Areas More Distant from Roads Acres 0 0 0 92,000 99,000 

TOTAL Acres 0 20,000 85,000 161,000 168,000 

Increase in High-Volume Suitable Old Growth

In Roaded Roadless Acres 0 7,000 7,000 7,000 7,000 

In Extensions of Roaded Areas Acres 0 0 19,000 19,000 19,000 

In Community Priority Areas Acres 0 0 4,000 0 0 

In Areas More Distant from Roads Acres 0 0 0 31,000 34,000 

TOTAL Acres 0 7,000 30,000 57,000 60,000 

Estimated OG Harvest over 100 yrs

In Roaded and Altered Areas6 Acres 42,500 42,500 34,400 28,350 27,500 

In Extensions of Roaded Areas7 Acres 0 0 8,050 8,050 8,050 

In Areas More Distant from Roads Acres 0 0 0 6,050 6,850 

TOTAL Acres 42,500 42,500 42,500 42,500 42,500 

Support for Alaska Native Culture

Improved Access to Cultural Trees Acres Neutral/No 

Effect

Small 

Beneficial 

Effect

Small Beneficial 

Effect

Small Beneficial 

Effect

Small Bene

Effect

Increased Competition with Timber

Industry

Qualitative Neutral/No 

Effect

Neutral/No 

Effect

Very Small 

Adverse Effect

Small Adverse 

Effect

Small Adve

Effect

Support for Subsistence Activities Qualitative Small Adverse 

and Beneficial 

Effects

Small Adverse 

and Beneficial 

Effects

Small Adverse and 

Beneficial Effects

Small Adverse 

and Beneficial 

Effects

Small Adve

and Benefic

Effects

Community Effects - overall level of 

potential change for communities

Qualitative Neutral/No 

Effect

Neutral/No 

Effect

Very Small 

Adverse and 

Beneficial Effects

Small Adverse 

and Beneficial 

Effects

Small Adve

and Benefic

Effects
Alternatives Including the Prop

Final EIS 2-27 Alternatives Includin

Table 2-12 (continued)

Comparison of Alternatives

Resource/Category 

Unit of 

Measure

Alternative

1 2 3 4 5 

No Action

Roaded

Roadless 

Logical

Extension

Partial

Dev LUDs

Full

Dev LUDs

Key Issue 3 – Protection of terrestrial and aquatic wildlife habitat and ecosystem diversity8

Percent of existing productive old 

growth harvested after 100 years

Percent6 1 Similar to Alt.1 Similar to Alt.1 Similar to Alt.1 Similar to A

Percent of original productive old 

growth remaining after 100 years 

(92% in 2015)

Percent 91 Similar to Alt.1 Similar to Alt.1 Similar to Alt.1 Similar to A

Percent of original high volume 

productive old growth remaining 

after 100 years (83% in 2015)

Percent 83 Similar to Alt.1 Similar to Alt.1 Similar to Alt.1 Similar to A

Percent of original large-tree 

productive old growth remaining 

after 100 years (82% in 2015)

Percent 81 Similar to Alt.1 Similar to Alt.1 Similar to Alt.1 Similar to A

YG Harvest in Beach and Estuary 

Fringe after 100 years (all prescript.)

Acres 3,546 Similar to Alt.1 Similar to Alt.1 Similar to Alt.1 Similar to A

YG Harvest in Riparian Management 

Areas after 100 years (all prescript.)

Acres 882 Similar to Alt.1 Similar to Alt.1 Similar to Alt.1 Very Minim

Increase

YG Harvest in Old Growth Habitat 

LUD after 100 years (all prescript.)

Acres 1,796 Similar to Alt.1 Similar to Alt.1 Similar to Alt.1 Similar to A

Average road density on NFS lands 

after 100 years (0.20 mile/square 

mile in 2016)

Miles/Sq. 

Mile

0.23 Similar to Alt.1 Similar to Alt.1 Very Minimal 

Increase

Very Minim

Increase

Average road density on All lands 

within Tongass boundary after 100 

years (0.33 mile/sq.mi.in 2016)

Miles/Sq. 

Mile

0.45 Similar to Alt.1 Similar to Alt.1 Very Minimal 

Increase

Very Minim

Increase

Percent of WAAs with NFS road 

density <0.7 mile/sq. mile after 100 

years (85% in 2016)

Percent 83 Similar to Alt.1 Similar to Alt.1 Similar to Alt.1 Similar to A

% of WAAs with All Lands road 

density <0.7 mile/sq. mile after 100 

years (79% in 2016)

Percent 72 Similar to Alt.1 Similar to Alt.1 Similar to Alt.1 Similar to A

Total area/potentially suitable OG in 

T77 & TNC/Audubon Conservation 

Priority Areas outside of roadless 

given long-term protection

 Acres 0/0 0/0 507,000/49,000 0/0 0/0 
Alternatives Including the Prop

Final EIS 2-28 Alternatives Includin

Table 2-12 (continued)

Comparison of Alternatives

Resource/Category 

Unit of 

Measure

Alternative

1 2 3 4 5 

No Action

Roaded

Roadless 

Logical

Extension

Partial

Dev LUDs

Full

Dev LUDs

Species-Specific Effects

Likelihood of maintaining viable, well-distributed populations after 100 years

Goshawks Rating6 Very High Very High Very High Very High Very High 

Marten Rating Very High Very High Very High Very High Very High 

Wolf Rating Very High Very High Very High Very High Very High 

Brown Bear Rating Very High Very High Very High Very High Very High 

Endemic Mammals Rating Moderate to 

High

Moderate to 

High

Moderate to High Moderate to 

High

Moderate to 

Deer habitat capability on NFS 

Lands after 100 years in Terms of 

Percent of Original (1954) Habitat 

Capability (89% currently)

Percent 88 Similar to Alt.1 Similar to Alt.1 Similar to Alt.1 Similar to A

Notes:

1 Nine categories are used for the Qualitative ratings. See the beginning of the Comparison of Alternatives section for a complete listing. 2 Total acres in LUD II Priority for Alternatives 2 and 4 is actually 870,000. The acres listed for LUD II Priority are based on the 2001 Roadless Rule GIS laye

different shoreline and did not include lakes.

3 Note that, with the exception of the Timber Priority ARA (and the Community Priority ARA to a lesser extent), roadless designation on development LUDs p

degree of protection, because these are areas that are mostly likely to be developed if they were not designated roadless. Most non-development LUDs hav

which limit their potential for development. Development LUDs include Timber Management, Modified Landscape, Scenic Viewshed, and Experimental Fores

4 Note the 1,875,000 acres of designated roadless under Alternative 4 includes 749,000 acres of Timber Priority. If Timber Priority is excluded because it doe

from timber harvest, the designated roadless area in development LUDs is 1,125,000 acres. 5 These roadless development LUD acres in Alternative 5 are mostly in Experimental Forest. 6 Includes the current harvest base outside of the 2001 inventoried roadless areas plus the roaded roadless areas inside the 2001 inventoried roadless areas. 7 Includes the Community Priority ARA areas.

8 Under Key Issue 3, the action alternatives are compared with acres, miles/sq. mile, or percent, from the 2016 Forest Plan Amendment EIS. “Similar to Alter

Alternative 1 with some very slight variation”. It is essentially the same as no difference or very slight difference. 

Under Key Issue 3, the Rating is also from the 2016 Forest Plan Amendment EIS and it relates to the “likelihood of maintaining viable, well-distributed popula

a species or species group. Similar ratings are also given for the action alternatives.

YG=young growth, OG=old growth

Totals may not appear to sum correctly due to rounding.
CHAPTER 3

ENVIRONMENT AND EFFECTS
Environment and Effects 3

Final EIS 3-1 Introduction

Chapter 3

Environment and Effects

Introduction

This chapter combines the affected environment and environmental consequences discussions required 

by the NEPA implementing regulations (40 CFR 1500-1508). The discussions are combined so that the 

environmental consequences (effects) of the alternatives on forest resources and the background 

information needed to understand these consequences are discussed together for each resource. 

Each resource is first described by its current condition, uses, supply, and demand, or expected use, 

along with an explanation of how each resource is measured and evaluated. The descriptions are limited 

to providing the background information necessary for understanding how the Final Environmental Impact 

Statement (FEIS) alternatives may affect the resource. Methodology and scientific accuracy is discussed 

for most resources.

Existing conditions reflect the extensive changes brought about by long-term human occupancy and use 

of the forest and represent the present-day condition resulting from past and present actions. Effects 

include the short- and long-term effects that would result from each of the alternatives considered in this 

FEIS. Cumulative effects may result when the direct and indirect effects associated with the alternatives 

are added to the effects associated with other past, present, or reasonably foreseeable actions; in this 

case there are no direct effects. Cumulative effects analyses are presented in the effects sections for 

each resource. Analysis of long-term cumulative effects extends at least 25 years into the future and to 

100 years in many cases. A list of past, present, and reasonably foreseeable projects considered, is 

provided in Appendix B, Cumulative Effects.

Many of the relationships established and discussed in the 1997 Tongass Land and Resource 

Management Plan (Forest Plan) Revision FEIS, the 2003 Supplemental EIS (SEIS), the 2008 Forest Plan 

Amendment EIS, and the 2016 Forest Plan Amendment EIS are still valid and, therefore, are incorporated 

by reference in this FEIS. However, this FEIS updates some of this information to better reflect current 

conditions and focuses on the potential effects most relevant to the potential changes that could occur 

from this proposed action and the alternatives.

An effort was made to obtain and use the best available information to evaluate and compare the effects 

of alternatives. NEPA implementing regulations (40 CFR 1502.22) state that when “there is incomplete or 

unavailable information, the agency shall always make clear that such information is lacking.” This was 

done where appropriate. The regulation requirement goes on to say that if the incomplete information “is 

essential to a reasoned choice among alternatives” then considerations, such as the cost of obtaining it, 

apply. This FEIS, in conjunction with the analyses presented in the 2016 and 2008 Forest Plan 

Amendments and the 1997 Forest Plan Revision FEIS, along with their planning records, will provide the 

USDA Secretary or Undersecretary of Agriculture with the “essential” information needed to make a 

reasoned choice among alternatives.

Analyzing Effects

Following each resource description is a discussion of the potential effects (environmental consequences) 

to the resource associated with implementation of each alternative. All significant or potentially significant 

effects, including direct, indirect, and cumulative effects, are disclosed. Effects are quantified, where 

possible, although qualitative discussions are also included. Mitigation measures are also described, if 

relevant.
Environment and Effects 3

Final EIS 3-2 Introduction

Environmental consequences are the effects of implementing an alternative on the physical, biological, 

social, and economic environment. Direct environmental effects are defined as those occurring at the 

same time and place as the initial cause or action. Indirect effects are those that occur later in time or are 

spatially removed from the activity but could be significant in the foreseeable future.

Potential adverse environmental effects that cannot be avoided are discussed. Unavoidable adverse 

effects are those resulting from managing the land for one resource, while recognizing impacts on the use 

or condition of other resources. Some adverse effects can be reduced or mitigated by limiting the extent 

or duration of effects.

Short-term uses, and their effects, are those that occur annually or within about 10 years. Long-term 

productivity refers to the capability of the land and resources to continue producing goods and services 

for 50 years and beyond. Long-term and cumulative effects may be projected out 100 years or more, as 

needed, to fully analyze the potential consequences for specific resources.

For estimating the effects of alternatives at the programmatic level, the assumption is made that the kinds 

of resource management activities allowed under the 2016 Forest Plan will in fact occur under each 

alternative. The actual location, design, and extent of such activities are, however, not known at this time 

because that is a project-by-project decision. In many cases, the discussions refer to the potential for 

effects to occur, realizing that in many cases these are only estimates. For example, harvests are 

assumed to occur at the level authorized by the 2016 Forest Plan, even though this level of harvest may 

or may not occur. While the assumption of effects could vary if forest plan direction is changed through 

future amendments or plan revisions, such adjustments are not presently under consideration and 

projections of hypothetical changes are too speculative to warrant evaluation. To the degree that the 

Forest Plan could change in the future, the activities allowed would change accordingly, and the 

estimates presented here do not reflect such changes. The effects of such a change would be attributed 

to and analyzed as part of the decision-making for that action.

The effects analysis is useful in comparing and evaluating alternatives but should not be applied per se to 

any specific location within the Forest. Thus, the effects presented here are comparative in nature. 

Specific effects that can be meaningfully measured and evaluated generally occur at the project and 

activity stage.

Cumulative Effects

Cumulative effects result from the incremental effects of actions, when added to other past, present, and 

reasonably foreseeable future actions, regardless of what agency (federal or non-federal) or person 

undertakes such other actions. For this analysis, the area considered for cumulative effects varies 

according to the resource being assessed. Cumulative effects are discussed in detail for each resource in 

this chapter. Appendix B describes the projects considered for cumulative effects analysis.

For most aquatic or watershed-related resources, the area within the proclaimed Forest boundary 

(approximately 17.9 million acres, including 1.2 million acres of non-National Forest System [NFS] lands) 

was used and analyses were generally conducted at the watershed scale (sixth-level or 12-digit 

hydrologic unit).

For wildlife and other terrestrial resources, all of Southeast Alaska from Yakutat Bay southeast to the 

southeastern end of Alaska (approximately 21.6 million acres, including 4.8 million acres of non-NFS 

lands) is sometimes used for the analysis, although some analyses will be based on the area within the 

Forest boundary, depending on the availability and quality of available information. Often, Wildlife

Analysis Areas (WAAs) will be used to summarize information. In addition, biogeographic provinces will 

be used to summarize cumulative effects information for wildlife and other terrestrial resources.

For social, economic, recreation, and related human uses, all of Southeast Alaska and adjacent areas will 

be given consideration for cumulative effects, especially regarding economic, market, and other factors.
Environment and Effects 3

Final EIS 3-3 Introduction

Geographic Information System Database and Quantification for this EIS

The Forest Service has developed an extensive computerized geographic information system (GIS) 

database that is continually improved and updated and is used for programmatic and project-level 

analyses. However, the use of newer computer mapping and measurement techniques that are more 

accurate than earlier methods, and the use of updated data, affects the numbers. In general, the 

differences between previous documents and the baseline numbers used in this FEIS are small, and do 

not affect the analysis relationships among these documents.

The ongoing management of the Tongass National Forest and updating of data can affect comparability 

of baseline numbers. Examples include changes in land ownership, changes in resource conditions 

resulting from timber harvest and road construction, updating of resource data based on field surveys or 

other analyses, and forest plan amendments. 

It should be noted that in some cases acreages are measured that depend on overlaying of multiple data 

coverages. The acreage measurements for individual categories may need adjustment to account for the 

fact that coverages are not registered precisely due to scale and data quality attributes. (e.g., along 

property boundaries, saltwater shorelines, lake edges). Very slight misalignment of the coverages can 

result in polygon slivers between the coverages, which can produce acreage differences initially. These 

differences can amount to tens or hundreds of acres or more, especially because of the large area (17 

million acres) under analysis. However, on a percentage basis, these necessary adjustments are 

insignificant.

The figures presented are generally rounded to the nearest whole acre, whole mile, or whole percent. 

Sometimes they are rounded to tens, hundreds, or thousands, but when numbers are given to the nearest 

acre or tenth of a mile, it does not necessarily mean that they are accurate to that level. No attempt has 

been made to adjust rounded numbers to force their sums to equal the expected totals. Therefore, the 

sum of rounded individual numbers will often be one digit higher or lower than the expected sum. The 

sums that are presented are the sums of the unrounded numbers.

Current Forest Plan (2016 Amendment)

The 2016 Forest Plan amendment responded to a July 2013 Memorandum (1044-009) that directed the 

Forest Service to transition to a young-growth–based timber management program on the Tongass 

National Forest within 10 to 15 years, with the goal that at the end of this period the vast majority of 

timber sold by the Tongass will be young growth. The Secretary’s memorandum indicated that this 

transition to young growth should be implemented in a manner that would preserve a viable timber 

industry that provides jobs and opportunities for Southeast Alaska residents

Based on the Pacific Northwest Research Station demand projections for 2015 to 2030 (Daniels et al. 

2016), the Record of Decision (ROD) for the 2016 Forest Plan Amendment EIS established an annual 

Projected Timber Sale Quantity (PTSQ) of 46 million board feet (MMBF) prior to the young-growth 

transition. Under the alternative selected in the ROD, harvest volume would consist of old-growth and 

young-growth harvest, with old growth decreasing as a share of total volume (46 MMBF) over time as 

more young growth becomes economic to harvest. Young-growth volume as a share of the total would 

continue to increase until it reaches 41 MMBF per year (full transition). Under the Forest Plan, the Forest 

Service expected to sell an average of about 12 MMBF of young growth and 34 MMBF of old growth per 

year during the first 10 years to reach the estimated quantity of timber expected to be sold during the first 

decade, 460 MMBF. From Year 11 through Year 15, the Forest Service expected to sell an average of 28 

MMBF of young growth and about 18 MMBF of old growth per year. The Forest Plan was expected to 

reach a full transition of 41 MMBF of young growth around Year 16. Young-growth sales were expected 

to continue to increase at a rapid rate after Year 16 and reach an upper limit of 93 MMBF around Year 18 

(Figure 3-1). Following the transition, old-growth timber would continue to be offered at an average rate of 

5 MMBF per year to support small operators and specialty products such as wood for musical instruments 

(USDA Forest Service 2016c)
Environment and Effects 3

Final EIS 3-4 Introduction

Suitable Timber Land Assumptions

Suitable timber lands represent those lands on the Forest that are suitable for timber production based on 

all multiple-use objectives of the Forest. Appendix A of the 2016 Forest Plan (USDA Forest Service 2016) 

defines the process for determining timber suitability. The only way to map these lands Forest-wide is to 

use GIS. Therefore, a GIS model is used that starts with all land on the Forest and, based on many GIS 

layers, drops out lands that are not suitable based on the criteria identified in Forest Plan Appendix A. 

The end result is a map of the lands that are estimated to be suitable for timber production. Based on this 

model, the current Forest Plan (existing conditions) has 227,000 acres of suitable old growth and 334,000 

acres of suitable young growth. These acres are outside of existing roadless areas because roadless 

areas are defined as not suitable for timber production under the current Forest Plan. Under the action 

alternatives, the roadless designations are removed from some lands and, if these lands are in 

development Land Use Designations (LUDs) and are not otherwise unsuitable according to the Forest 

Plan Appendix A, many of these acres become suitable. Therefore, the alternatives with the fewest lands 

designated as roadless have the most suitable acres.

Figure 3-1

Estimated Maximum Average Annual Harvest under the 2016 Forest Plan 

Amendment

Source: USDA Forest Service 2016c

Assumptions for Future Harvest

Lands to be harvested are selected from the suitable timber lands. In this EIS, potential harvest acres are 

the same for all alternatives, even though the suitable acres change. That is because the Forest Plan 

defines the PTSQ (current Forest Plan [2016 amendment] section) and the acres of harvest is not 

proportional to the acres of suitable timber lands. Based on Forest Plan modeling (using the Woodstock 

Model) for the 2016 amendment, the harvest acres allowed by the Forest Plan over the 100-year planning

horizon, with harvest at PTSQ were calculated at 42,500 acres for old growth and 284,144 acres for 

young growth (USDA Forest Service 2016). These are the harvest acres used for assessing effects for 

each alternative. 

Although the acres of harvest do not change, the distribution of that harvest around the Forest is likely to 

change with each alternative because of shifting patterns of suitable timber lands. In the DEIS, we 
Environment and Effects 3

Final EIS 3-5 Introduction

assumed that the harvest was distributed evenly across the suitable timber lands. In response to a 

number of comments and internal discussions, it was decided that we could allocate the old-growth 

harvest acres in a more realistic pattern (since only 11 to 19 percent of the suitable old growth is 

harvested over 100 years). For young growth, the even distribution model still works because 80 to 85 

percent of the suitable young growth is harvested under each alternative. Thus, for the FEIS, we 

developed a model to project more accurately the distribution of harvest. It is important to understand that 

harvest projections are intended to model what might occur in the future over a very long period of time 

(100 years) to better inform the environmental analysis, show differences and/or similarities between 

alternatives, and provide additional information for the public and decision maker to consider. Harvest 

projections are based on assumptions described here and include inherent uncertainties (e.g., unknown 

changes in future domestic and international markets, harvest and manufacturing technology, and 

environmental constraints). Harvest projections do not propose or suggest when or where specific 

activities would occur or identify specific planned or unplanned timber harvests. The lands mapped as 

suitable for timber production show where harvest could occur.

For the FEIS, we revised our assumptions, in order to make the projected distribution of harvest acres 

more accurately reflect past practices and contemporary economic conditions related to markets. We 

developed three assumptions to provide a more realistic allocation of harvest within the suitable lands. 

These assumptions all relate to timber sale economics and they are described below along with their 

rationales.

First, we assigned all projected harvest acres to suitable medium- and high-volume old growth only. 

This means that about 22 percent of the suitable acres, mapped as low volume, were not candidates 

for harvest. This assumption is reasonable as the low-volume old growth has been avoided for years 

and under our current economic situation, it is highly unlikely that economic sales will be developable 

in this timber during the short-term, and probably even for the long-term, future.

Second, we reduced the proportion of projected harvest in the northern districts due to the fact that 

the northern district acres are less desirable to the timber industry because there are no medium-tolarge-size sawmills in the northern districts (requiring logs from most sales to be transported long 

distances by water to reach mills of appropriate size), there is little other industry infrastructure 

remaining in most areas, and the northern districts generally support forests with smaller logs. Based 

on reviewing the distribution of harvest among Tongass ranger districts over the past 12 years, about 

3 percent of the volume came from the northern districts (Sitka, Hoonah, Juneau, Admiralty, and 

Yakutat), while about 97 percent came from the southern ranger districts (Thorne Bay, Craig, 

Ketchikan, Petersburg, and Wrangell). Because the percentage for the north was well below the longterm average, we decided to slightly increase the contribution of the northern districts in the future by 

restricting projected harvest acres to 5 percent in the north and 95 percent in the south.

Third, because economics is the major limiting factor for developing viable timber sales, we used 

generalized economic data to drop those VCUs with the lowest estimated total old-growth stumpage 

values. These data were generated in 2007 using the Spectrum model for the 2008 Tongass Forest 

Plan (Henderson 2007). Estimated total old-growth stumpage values by VCU were examined and to 

focus on the VCUs with the best economic value, we decided to drop all VCUs with estimated total 

old-growth stumpage values less than -$3,000, which represented about 41 percent of all VCUs 

considered in 2008. Note that the VCUs considered in 2008 included those in all three phases of the 

Timber Sale Program Adaptive Management Strategy and only those VCUs in Phase 1 are currently 

considered suitable for old-growth harvest. The majority of this reduction occurred in the northern 

districts, which comprised 64 percent to 79 percent of the total reduction, depending on the 

alternative. The largest contributor to the reduction was the Sitka Ranger District. 

We believe that using this model results in a more accurate distribution of old-growth harvest than the 

even distribution model; however, it too is just an approximation.

Assumptions for Future Road Construction and Reconstruction

Future road construction/reconstruction assumptions were different for old-growth versus young-growth 

harvest. The ratios derived are based on a review of Big Thorne and other timber sale projects. 
Environment and Effects 3

Final EIS 3-6 Introduction

For young growth in Alternatives 1 and 2, it was first assumed that 100 percent of all Maintenance Level 1 

roads (closed roads) would be reconstructed if all young growth on the Forest were to be harvested. Then 

the miles of reconstruction for each alternative was extrapolated from this by using the proportion of 

young-growth to be harvested in that alternative. In addition, it was assumed that in some young-growth 

stands, construction of new roads would have less impact than reconstruction of old roads; thus, based 

on past timber sales, an additional one mile of new road per 400 acres of young-growth harvest and one 

mile of new road over previously decommissioned road per 600 acres of harvest were assumed. 

Similarly, it was also assumed that 10 percent of new roads and new roads over decommissioned road 

grades would remain open, while the remaining 90 percent would be closed. It is recognized that many of 

these roads would be built as temporary roads and some would be fully obliterated after use. However, to 

be conservative, all roads, including decommissioned roads, closed roads, and open roads, are used in 

the calculation of road miles and road densities.

For old-growth harvest in Alternatives 1 and 2, future road construction was estimated based on the ratio 

of one mile of new road construction per 150 acres of harvest plus one mile of new road construction over 

previously decommissioned road grade per 800 acres of harvest. In addition, one mile of road 

reconstruction per 300 acres of harvest was assumed. Further, it was assumed that 10 percent of new 

roads and new roads over decommissioned road grades would remain open, while the remaining 90 

percent would be closed. 

In addition, for young growth and old growth harvest in Alternatives 3, 4, 5, and 6, the ratios given above 

(i.e., miles of road per acres harvested) were modified slightly to produce more roads to be developed in 

alternatives where more of the suitable timber was remote. Consideration was given to the proportion of 

timber in areas not remote for each alternative. But in general, the higher the proportion of acres of 

remote suitable timber relative to roaded suitable timber, the more miles of road would be 

built/reconstructed per hundred acres of harvest.

On non-NFS lands, future increases in road density were projected after examining existing road 

densities and making reasonable assumptions regarding the additional road density that would be 

developed in the future. Estimates were conservatively high, in general. All future non-NFS roads were 

assumed to remain open. 

Land Use Designation Groupings

For many resources, the effects and the differences in effects among the alternatives are best identified 

through the LUD) allocations. While each LUD has a different management prescription, many are similar 

in the kinds of effects they would potentially create. Based on this and to simplify the identification of 

effects, the LUDs have been grouped into four categories: Wilderness, Natural Setting, Moderate 

Development, and Intensive Development. For some analyses, the LUDs are grouped into two 

categories: Wilderness and Natural Setting LUDs make up the non-development LUDs and Moderate and 

Intensive development LUDs make up the development LUD category. Therefore, acreages in this EIS 

generally reflect the underlying LUD acreages. Table 3-1 displays these LUD groupings.

Land Divisions

The land area of the Tongass National Forest has been divided in different ways to describe the different 

resources and how they are affected by the alternatives. These divisions vary by resource because the 

relationship of each resource to geographic conditions and zones also varies. Several of these divisions 

are described briefly here.

Watershed

The 6th-level hydrologic unit code polygons were used for some watershed/fisheries effects. These come 

from the national Watershed Boundary Dataset.
Environment and Effects 3

Final EIS 3-7 Introduction

Geographic Provinces

These are seven large land areas that are distinguished by differences in ecological processes. They are 

defined by a combination of climatic and geographic features. Geographic provinces are used in the 

evaluation of Research Natural Areas and Wild and Scenic Rivers. See the Research Natural Areas 

section of the 1997 Forest Plan Revision FEIS for a description of each province.

Table 3-1

Land Use Designation Groupings Used to Discuss Effects

LUD Group Land Use Designation

Non-development LUDs3

Wilderness LUD Group Wilderness

Wilderness National Monument

Nonwilderness National Monument

Natural Setting LUDs LUD II

Remote Recreation

Semi-Remote Recreation 

Old-Growth Habitat

Municipal Watershed

Research Natural Area1

Special Interest Area1

Wild River1

Scenic River

Recreational River

Development LUDs

Moderate Development Experimental Forest3

Scenic Viewshed

Modified Landscape

Intensive Development Timber Production

Overlay LUD2

Minerals

Notes:

1 These three LUDs function as overlay LUDs (see footnote 2) when they occur within Wilderness, 

Wilderness National Monument, or LUD II areas. 2 The Minerals LUD is an overlay LUD. Areas allocated to this LUD are managed according to the 

underlying LUD until such time that mineral development is approved, if at all. Generally, acreages 

in this EIS do not include the Minerals, but rather the underlying LUD. 3 Sometimes Experimental Forest, which is a minor LUD in terms of acreage, is included with Nondevelopment LUDs. 

Biogeographic Provinces

Biogeographic provinces are areas within which certain kinds of plants and animals tend to occur 

together. They are defined by a combination of similarity in species, patterns of distribution of species, 

and natural characteristics or barriers. Twenty-one biogeographic provinces occur on the Tongass. They 

are used in the Biological Diversity, Wildlife, and Subsistence sections. 

Wildlife Analysis Areas

WAAs are land divisions used by the Alaska Department of Fish and Game. Approximately 190 WAAs 

apply to the Tongass National Forest; they average slightly less than 90,000 acres in size. In general, 

WAA boundaries correspond with Value Comparison Unit (VCU) boundaries, and they typically include 

three to eight VCUs (averaging just under five). They are used in the Subsistence and Wildlife sections.

Game Management Unit

Geographical areas defined by the Alaska Department of Fish and Game (ADF&G) to manage wildlife 

populations. Legal hunting and trapping regulations govern each unit.
Environment and Effects 3

Final EIS 3-8 Introduction

Community Use Area

Community use areas represent the general area commonly used or related to by many of the 

community’s residents in their local day-to-day work, recreational, and subsistence activities. These areas 

do not necessarily define the limits of a community’s use or represent traditional use areas or territories.

Traditional Use Areas

Traditional territories are shown in Appendix F, which presents maps from Goldschmidt and Haas’ 

landmark ethnographic study of Alaska Native land use, occupancy, and possession in Southeast Alaska.

Maps

Large-scale color maps showing roadless areas by IRA or ARA (Map 1 to 6) are included on the thumb 

drive version of the FEIS, in the map packet that accompanies the FEIS paper copy, and on this project’s 

website: https://www.fs.usda.gov/project/?project=54511. Additional maps showing the lands that would 

be suitable for timber production (Maps 7 to 12) and the lands that would be suitable for timber production 

by select outfitter/guide use areas (Maps 13 to 18) are included on the thumb drive and website. Maps 

showing suitable lands by community use area are for each alternative are included in Appendix D on the 

thumb drive and website.

Organization of Chapter 3

The remainder of Chapter 3 is divided into two parts, key issues and other important issues. Key Issues 

addresses the three key issues covered in Chapters 1 and 2 and Other Important Issues covers the other 

10 issues addressed in detail in this EIS.
Environment and Effects 3

Final EIS 3-9 Key Issue 1

Key Issues

Key Issue 1 – Roadless Area Conservation

Affected Environment

Roadless Area Characteristics

In the 2001 Roadless Rule, IRAs were drawn from undeveloped areas typically exceeding 5,000 acres 

that meet the minimum criteria for wilderness consideration under the Wilderness Act and were 

inventoried during the Forest Service’s Roadless Area Review and Evaluation (RARE) II process and 

subsequent updates and forest planning analyses. The IRA boundaries associated with the 2001 

Roadless Rule (USDA Forest Service 2000), are identified in a set of maps, associated with the Forest 

Service Roadless Area Conservation, Final Environmental Impact Statement (FEIS), Volume 2, dated 

November 2000. 

The characteristics of the IRAs within the Tongass are described within Appendix C to the 1997 Tongass 

Land Management Plan Revision, Final Supplemental EIS (SEIS), Roadless Area Evaluation for 

Wilderness Recommendations (USDA Forest Service 2003a).

In their final report, the Alaska Roadless Rule Citizens Advisory Committee recommended Alaska 

roadless characteristics based on the unique landscape, remote character, and Alaskan way of life –

noting subsistence uses, independent lifestyle, and cultural and spiritual ties to the area. They also noted 

hardships shared – high energy costs and social and economic hardships. As a result, communities in 

Alaska often balance between maintaining the characteristics that they value and that make their 

communities unique, and conserving the resources they use and depend on, while also ensuring 

economic development and opportunities for employment, economic activity, healthcare, safety, and 

connections with other communities. They are dependent on the resources that surround them and value 

preserving the multiple-use capability of the Tongass that is critical to sustaining the regional economy, 

the welfare of its residents, and the economies, social needs, cultures, and ways of life of Native 

Alaskans. Table 3.1-1 compares the Alaska roadless characteristics the Committee recommended with 

the characteristics included in Alternatives 2-5 and those of the 2001 Roadless Rule.

Roadless characteristics (i.e., values or features that make the area meet the minimum criteria for 

wilderness consideration under the Wilderness Act) are described in the Roadless Area Conservation 

FEIS (USDA Forest Service 2000, Vol. 1, pp. 3-3 to 3-7). These roadless characteristics have been 

modified for Alaska conditions and are summarized in Table 3.1-2.

The roadless area inventory displays the extent of the roadless resource and provides data for use by 

managers, legislators, and others to formulate land management proposals. Roadless areas may retain 

their roadless character by being managed in a way that emphasizes relatively large undeveloped or 

natural areas, such as areas usually required for old-growth habitat, scenic backdrops, or primitive 

recreation.

Table 3.1-4 (in the Environmental Consequences section below) provides an overview of the IRAs 

identified in the 2001 Roadless Rule. These areas consist of approximately 9.34 million acres spread over 

110 separate IRAs ranging in size from just 592 acres (Fake Pass IRA 532) to 1.2 million acres (JuneauSkagway Icefield IRA 301). All but 5 of the 110 IRAs identified in the 2001 Roadless Rule are larger than 

5,000 acres.

Ecosystem Services

Ecosystem services are the products of functioning ecosystems that often are available without direct 

costs to people who benefit from them (Kline 2006).
Environment and Effects 3

Final EIS 3-10 Key Issue 1

Table 3.1-1

Roadless Area Characteristics - Comparison

2001 Roadless Rule Proposed Alaska 

Roadless Rule

(Alternatives 2-5)

Citizen Advisory Committee Recommendation

High quality or undisturbed soil, water, and 

air. These three key resources are the foundation 

upon which other resource values and outputs 

depend. Healthy watersheds catch, store, and 

safely release water over time, protecting 

downstream

communities from flooding; providing clean water

for domestic, agricultural, and industrial uses; 

helping maintain abundant and healthy fish and 

wildlife populations; and are the basis for many 

forms of outdoor recreation.

Physical Environment. 

Roadless areas provide 

high-quality or 

undisturbed soil, water,

and air.

Sources of public drinking water. National 

Forest System lands contain watersheds that are 

important sources of public drinking water. 

Roadless areas within the National Forest 

System contain all or portions of 354 municipal 

watersheds contributing drinking water to millions 

of citizens. Maintaining these areas in a relatively 

undisturbed condition saves downstream 

communities millions of dollars in water filtration 

costs. Careful management of these watersheds 

is crucial in maintaining the flow and affordability 

of clean water to a growing population.

Water. Roadless areas 

provide a variety of water

resources including 

public drinking water 

sources, fish and aquatic 

resources, and hatchery 

aquatic resources. 

Watersheds that are important sources of public 

drinking water and water sources for fish and 

aquatic resources, including hatcheries. State 

regulations are currently enforced and applied using 

the most restrictive standard for water quality

criterion as listed in 18 AAC 70. Careful management 

of these watersheds is crucial in maintaining the flow 

of clean water to local communities, and to support 

continued production of fisheries and aquatic food 

webs.

Diversity of plant and animal communities.

Roadless areas are more likely than roaded 

areas to support greater ecosystem health, 

including the diversity of native and desired 

nonnative plant and animal communities due to 

the absence of disturbances caused by roads 

and accompanying activities. Inventoried 

roadless areas also conserve native biodiversity 

by serving as a bulwark against the spread of 

nonnative invasive species.

Diversity. Roadless 

areas support a diversity 

of plant and animal 

communities including 

stands of old-growth 

forests. 

Expansive areas where high quality intact habitat 

exist and ecosystems function with all of their 

native species and components; there are no 

listed or endangered species; and invasive 

species are generally not present. These areas 

function as biological strongholds and refuges for 

many species, harbor a diversity of plant and animal 

communities, and serve as a globally significant 

example of a temperate rainforest ecosystem that is 

both utilized and conserved by the people that live 

within and adjacent to it. Species exist in Alaska 

Roadless Areas that are endangered, threatened, or 

reduced in other places on the continent.

Habitat for threatened, endangered, proposed, 

candidate, and sensitive species and for 

those species dependent on large, 

undisturbed areas of land. Roadless areas 

function as Biological strongholds and refuges for 

many species. Of the nation’s species currently 

listed as threatened, endangered, or proposed for 

listing under the Endangered Species Act, 

approximately 25% of animal species and 13% of 

plant species are likely to have habitat within 

inventoried roadless areas on National Forest 

System lands. Roadless areas support a diversity 

of aquatic habitats and communities, providing or 

affecting habitat for more than 280 threatened, 

endangered, proposed, and sensitive species. 

More than 65% of all Forest Service sensitive 

species are directly or indirectly affected by 

inventoried roadless areas. This percentage is 

composed of birds (82%), amphibians (84%), 

mammals (81%), plants (72%), fish (56%), 

reptiles (49%), and invertebrates (36%).

Habitat. Roadless areas 

are expansive areas 

where high-quality intact 

habitat exists and 

ecosystems function with 

all their native species 

and components. 

Roadless areas serve as 

habitat for a diversity of 

plant and animal 

populations and are of 

particular importance to 

wide-ranging species, 

especially predators, 

which benefit from large, 

unmanaged forest areas 

with limited human 

activity.

Expansive areas where high quality intact habitat 

exist and ecosystems function with all of their 

native species and components; there are no 

listed or endangered species; and Invasive 

species are generally not present. These areas 

function as biological strongholds and refuges for 

many species, harbor a diversity of plant and animal 

communities, and serve as a globally significant 

example of a temperate rainforest ecosystem that is 

both utilized and conserved by the people that live 

within and adjacent to it. Species exist in Alaska 

Roadless Areas that are endangered, threatened, or 

reduced in other places on the continent.
Environment and Effects 3

Final EIS 3-11 Key Issue 1

Table 3.1-1 (continued)

Roadless Area Characteristics - Comparison

2001 Roadless Rule Proposed Alaska 

Roadless Rule

(Alternatives 2-5)

Citizen Advisory Committee Recommendation

Primitive, Semi-Primitive Non-Motorized, and 

Semi-Primitive Motorized classes of 

dispersed recreation. Roadless areas often 

provide outstanding dispersed recreation 

opportunities such as hiking, camping, picnicking, 

wildlife viewing, hunting, fishing, cross-country 

skiing, and canoeing. While they may have many 

Wilderness-like attributes, unlike Wilderness the 

use of mountain bikes, and other mechanized 

means of travel is often allowed. These areas can 

also take pressure off heavily used wilderness 

areas by providing solitude and quiet, and 

dispersed recreation opportunities.

Remoteness. Alaska 

roadless areas provide 

rich primitive, semiprimitive motorized, and 

semi-primitive nonmotorized classes of 

dispersed recreation, 

which are a source of 

ecological, social, and 

economic benefits.

Opportunities for economic development of 

visitor industry products, including remotesetting guided nature tours to view wildlife, hunt, 

fish, and hike. Alaska Roadless Areas contribute to 

a regional resource of undeveloped lands that are an 

important resource for a segment of the visitor sector 

– an important component of the matrix of Tongass 

lands that provide opportunity for medium to larger 

groups to go ashore in a wilderness-type setting. The 

intact ecological systems in these areas, with natural 

settings and iconic fish and wildlife, are a draw for 

visitors.

Reference landscapes. The body of knowledge 

about the effects of management activities over 

long periods of time and on large landscapes is 

very limited. Reference landscapes of relatively 

undisturbed areas serve as a barometer to 

measure the effects of development on other 

parts of the landscape.

Landscape. Roadless 

areas provide reference 

landscapes of relatively 

undisturbed areas that 

serve as a barometer to 

measure the effects of 

development on other 

parts of the landscape.

Stands of old growth forests. These old growth 

forests are nationally and globally significant 

because they exist in quantities and extensions in 

Alaska like few other places on the planet. They 

support subsistence and traditional hunting and 

gathering, unique plant and wildlife populations, a 

significant volume of sequestered carbon and 

forest/soil processes that mitigate climate change 

and represent a globally significant reference 

landscape and intact old growth forest ecosystem.

Natural-appearing landscapes with high 

scenic quality. High quality scenery, especially 

scenery with natural-appearing landscapes, is a 

primary reason that people choose to recreate. In 

addition, quality scenery contributes directly to 

real estate values in nearby communities and 

residential areas.

Scenery. Roadless areas 

have natural-appearing 

landscapes with highscenic qualities that 

people value.

High-quality scenery, especially scenery with 

natural-appearing landscapes, is a primary 

quality that people value in Alaska Roadless 

Areas. Quality scenery contributes directly to the 

quality of life and recreation opportunities for 

residents, property owners, and visitors.

Traditional cultural properties and sacred 

sites. Traditional cultural properties are places, 

sites, structures, art, or objects that have played 

an important role in the cultural history of a group. 

Sacred sites are places that have special 

religious significance to a group. Traditional 

cultural properties and sacred sites may be 

eligible for protection under the National Historic 

Preservation Act. However, many of them have 

not yet been inventoried, especially those that 

occur in inventoried roadless areas.

Cultural. Roadless areas 

are rich in traditional 

cultural properties and 

sacred sites. In Alaska 

indigenous peoples have 

been on national forests 

for more than 10,000 

years and the forests 

have cultural significance.

Alaska Native people who have been on this land 

for more than 10,000 years, and for whom this 

place has cultural and spiritual significance. The 

use of places, sites, waters, structures, resources, 

and objects are historically significant in the beliefs, 

customs, practices, and perpetuation of the culture(s) 

of communities and indigenous peoples of the area. 

While the Alaska Native people now share this place 

with other residents, it is critical that they continue to 

have the ability to sustain their cultures and their 

communities through economic, social, and cultural 

opportunities.
Environment and Effects 3

Final EIS 3-12 Key Issue 1

Table 3.1-1 (continued)

Roadless Area Characteristics - Comparison

2001 Roadless Rule Proposed Alaska 

Roadless Rule

(Alternatives 2-5)

Citizen Advisory Committee Recommendation

Other locally identified unique characteristics.

Inventoried roadless areas may offer other locally 

identified unique characteristics and values. 

Examples include uncommon geological 

formations, which are valued for their scientific 

and scenic qualities, or unique wetland 

complexes. Unique social, cultural, or historical 

characteristics may also depend on the roadless 

character of the landscape. Examples include 

ceremonial sites, places for local events, areas 

prized for collection of non-timber forest products, 

or exceptional hunting and fishing opportunities.

Locally-unique 

characteristics.

Roadless areas represent 

geographic areas with 

additional locally-unique 

characteristics specific to 

Alaska including: (a) 

important source of 

subsistence resources 

including terrestrial 

wildlife, waterfowl, 

mammals, fish, and plantbased resources; (b) rich 

habitat that supports 

multiple species of fish 

for personal, subsistence, 

sport, recreation, and 

commercial harvest; and 

(c) supports diverse 

economic opportunity that 

is especially important for 

rural community wellbeing.

An important source of subsistence resources 

for Alaskans. Roadless Areas are rich in important 

subsistence resources, including game, fish, and 

foraging resources for those residents whose use 

and access rights are specifically recognized and 

guaranteed by the Alaska National Interest Lands

Conservation Act (ANILCA).

Multiple species of fish (including salmon) 

harvested for subsistence and personal use, 

commercial fisheries, and tourism and guided 

recreational fishing. Salmon, trout, char, and 

hooligan of the Tongass National Forest are 

harvested in subsistence fisheries and for personal 

use by local residents. Salmon and trout are also the 

basis of tourism and guided fisheries enjoyed by 

thousands of visitors, supporting hundreds of tourism 

and support businesses. The commercial fisheries 

derived from Tongass streams and rivers produce a 

significant proportion of the total Alaska salmon 

harvest, and support fishing and processing jobs for 

thousands of local residents and nonresidents.

A major source of economic activity for 

Southeast Alaskans. The Tongass National Forest 

surrounds 34 communities and approximately 73,000 

year-round residents. These residents heavily rely on 

Roadless Areas for economic activities, including 

mining, visitor products, ocean products, forest 

products, energy production, and other economic 

activities.

Table 3.1-2

Roadless Area Characteristics 

2001 Roadless Rule Characteristics, Modified for Alaska

Biological Values

• Diversity of plant and animal communities and old-growth forests

• Habitat – Roadless areas are expansive areas where high-quality intact habitat exists and ecosystems function 

with all their native species and components. Roadless areas provide habitat for a diversity of plant and animal 

populations and are of particular importance to wide-ranging species, such as bears and wolves, which 

benefit from large unmanaged forest areas with limited human activity.

Physical Values

• Environment – high-quality or undisturbed soil, water, and air.

• Water – roadless areas provide a variety of water resources including public drinking water sources, fish and 

aquatic resources, and hatchery aquatic resources. 

Social Values

• Remoteness – Roadless areas provide economic opportunity due to rich primitive, semi-primitive motorized, 

and semi-primitive non-motorized classes of dispersed recreation.

• Landscape – reference landscapes of relatively undisturbed areas that serve as a barometer to measure the 

effects of development on other parts of the landscape.

• Scenery – natural-appearing landscapes with high-scenic qualities that people value.

• Cultural – rich in traditional cultural properties and sacred sites. 

• Locally-unique characteristics – geographic areas with additional locally-unique characteristics specific to 

Alaska including: 1) important sources of subsistence resource; 2) rich habitat that supports multiple species 

of fish for personal, subsistence, sport, recreation, and commercial harvest; and 3) supports diverse 

economic opportunity that is especially important for rural community well-being.

Source: USDA Forest Service 2000, modified to reflect the unique characteristics of Alaska.
Environment and Effects 3

Final EIS 3-13 Key Issue 1

These services have been described in a number of different ways including the typology developed by 

the Millennium Ecosystem Assessment (2005), which is featured on the Forest Service’s Ecosystem 

Services web site (http://www.fs.fed.us/ecosystemservices/) and identifies four general categories of 

ecosystem services: provisioning, regulating, cultural, and supporting.

Provisioning services include wild food, fresh water, and fiber. Regulating services are the benefits 

obtained from ecosystem impacts on natural processes, such as air quality, climate stabilization, water 

quality, and erosion. Cultural services include recreation, aesthetic, educational, and spiritual and 

religious benefits. Supporting services are the underlying processes that maintain the conditions for life 

on Earth, such as nutrient cycling and soil formation (Smith et al. 2011).

The concept of ecosystem services has emerged as a way of framing and describing the comprehensive 

set of benefits that people receive from nature. The Forest Service has been exploring use of these 

concepts to describe the benefits provided by forests. The Forest Service’s Pacific Northwest Research 

Station issued a technical report that attempts to define an economics research program to describe and 

evaluate ecosystem services (Kline 2006). More recently, the Pacific Northwest Research Station and the

Deschutes National Forest have partnered to develop a place-based application to explore how this type 

of approach might be implemented by a national forest to enhance forest stewardship. Ecosystem 

services are discussed at the forest planning level for the Tongass National Forest in the 2008 Forest 

Plan EIS (USDA Forest Service 2008b, pp. 3-544 to 3-556). The 2008 Forest Plan EIS also discusses 

non-use values, including existence, option, and bequest values (USDA Forest Service 2008b, pp. 3-551 

to 3-552).

Environmental Consequences

The following analysis evaluates roadless area protection in terms of the acres designated as roadless 

and the degree of regulatory protection provided by the specific variations of the roadless rule language. 

Variations in the roadless rule language would generally allow more activities to take place, but all 

management activities on the Forest would remain subject to the 2016 Forest Plan direction that directly 

and indirectly protects roadless area characteristics.

Comparison of Effects on Roadless Characteristics by Alternative

The following sections provide an overview of the potential effects to the roadless area characteristics 

identified in the 2001 Roadless Rule, as modified, and summarized above in Table 3.1-2.

Roadless Characteristics: Biological Values

One major category of roadless area characteristics is biological value. Roadless areas are considered 

high in biological value if they contain a diversity of plant and animal communities, old-growth forests, 

and/or habitat for threatened, endangered, or sensitive species or wide-ranging species that are 

dependent on large, undisturbed tracts of land. These values are of special importance on the Alaska 

national forests and particularly on the Tongass, because it, along with adjacent areas in Canada, 

represents the largest intact tract of coastal temperate rainforest on earth. In addition, the fish and wildlife 

on the Tongass are of exceptionally high importance for subsistence, recreation, and the economic wellbeing of the residents and visitors of Southeast Alaska.

Of primary importance and of highest value in roadless areas on the Tongass are biological diversity, 

especially associated with old-growth habitats, and sensitive species, endemic species, and the wideranging predators of Southeast Alaska. The threatened and endangered fish and wildlife associated with 

the Tongass National Forest are all marine-oriented species and have only minor associations with the 

roadless areas of the Tongass (see Key Issue 3, Fish and Wildlife sections of this FEIS). There are no 

threatened or endangered plant species known to occur on the Tongass National Forest (see Sensitive 

and Invasive Plants section of this FEIS).
Environment and Effects 3

Final EIS 3-14 Key Issue 1

Biological Diversity and Old-Growth Habitat Conservation Strategy

Biological diversity of the Tongass, associated with old-growth forests, is of high importance to residents 

and visitors to the Tongass and from a national and worldwide perspective. Protection of this resource 

has been given high priority by the Tongass National Forest through the Old-growth Habitat Conservation 

Strategy, which was originally developed for the 1997 Forest Plan and has been carried forward through 

the 2008 and 2016 Forest Plan Amendment EISs (USDA Forest Service 2008a, 2016a).

The effects of the alternatives on biological diversity and the Old-growth Habitat Conservation Strategy 

are described in detail in the Biological Diversity section of this FEIS. Effects related to old-growth harvest 

acres, under all the alternatives, are the same as those for Alternative 1 under the 2016 Forest Plan 

Amendment EIS, which prescribes a harvest level much lower than the level originally allowed under the 

Conservation Strategy (see 1997 Forest Plan and 2008 Forest Plan Amendment). However, effects due 

to the distribution of harvest, related to fragmentation and connectivity, would vary. Alternatives 1, 2, and 

3 would have very low effects, while Alternatives 4, 5, and 6 would have greater effects because of entry 

into more remote watersheds and roadless areas.

Habitat in Roadless Areas

Roadless areas provide expansive areas of high-quality intact habitat for the full range of native species 

and ecosystem components. These include threatened, endangered, and sensitive species, endemic

species, and wide-ranging species dependent on large, undisturbed areas.

The Tongass National Forest currently has no threatened or endangered species associated with 

terrestrial habitats. However, it does have 16 plant and 4 bird species designated as sensitive (see Key 

Issue 3, Fish and Wildlife sections and the Sensitive and Invasive Plants section). Of the 16 sensitive 

plant species, only 4 species have known occurrences expected to be within lands suitable for younggrowth or old-growth timber production. For these populations and for previously undocumented 

populations that are located during project surveys, Forest-wide standards and guidelines under all 

alternatives would result in protection to minimize impacts to these species. Among the bird species, 

three are marine or shoreline species and are expected to be protected from almost all adverse effects by 

Forest Plan LUDs and standards and guidelines. However, the Queen Charlotte goshawk (Accipiter 

gentiles laingi) is a wide-ranging species that seems to prefer mature and old-growth forest habitats for 

nesting and foraging. This species would be affected under all alternatives; effects would generally be 

similar among the alternatives but slightly higher for Alternatives 4, 5, and 6 because of more road 

development and associated fragmentation expected under these alternatives relative to Alternatives 1, 2, 

and 3.

Endemic species occur in isolated populations and can have limited mobility or specific habitat 

requirements (see Key Issue 3, Wildlife section). Thus, they are vulnerable to the effects of habitat loss 

and fragmentation, introduced non-natives, pathogens and disease, natural events (i.e., climate change), 

and overharvesting (Dawson et al. 2007). Although timber harvest levels are the same among all 

alternatives, Alternatives 4, 5, and 6 would have the greatest potential for effects on endemics because 

the degree of fragmentation is likely to be higher under these alternatives (landscape connectivity and 

fragmentation are discussed in detail in the Biological Diversity section). Most endemic species would 

benefit from the transition to young-growth harvest permitted under all alternatives due to the reduced 

amount of scheduled productive old-growth harvest over the long term.

Roadless areas may be of greatest value to wide-ranging species that require large, undisturbed areas of 

land. In general, this group consists of predators. Three mammals are included in this category: 

Alexander Archipelago wolf (Canis lupus ligoni), brown bear (Ursus arctos), and American marten (Martes 

americana; see Key Issue 3, Wildlife section). These species are of concern because their numbers are 

relatively low (they are at or near the top of the food chain), they are under harvest pressure (which is 

affected by access), they are sensitive to disturbance, and they range widely so they are often subject to 

many disturbances within their home ranges. Remote roadless areas often represent optimum habitats 

for them and may serve as important refugia for populations under harvest and development pressures. 

Of greatest concern on the Tongass is the Alexander Archipelago wolf, particularly on Prince of Wales 

and surrounding islands. Although the alternatives would be similar in terms of overall harvest levels, 
Environment and Effects 3

Final EIS 3-15 Key Issue 1

Alternatives 4, 5, and 6 would result in the largest adverse effects on these species because of greater 

road lengths, penetration into remote roadless areas, and habitat fragmentation that they would produce 

relative to Alternatives 1, 2, and 3.

Roadless Characteristics: Physical Values

The physical values associated with roadless areas include soils, water, and air. The Tongass roadless 

areas are generally in near pristine condition in terms of soils, water quality, and air quality.

Large acreages of excessive soil erosion, detrimental soil disturbance, or landslides attributed to 

management activities generally do not exist within roadless areas. However, there are localized areas 

within the roaded roadless portion that include past management-related soil impacts. During project-level

analysis, areas sensitive to surface erosion or landslides are identified and appropriate mitigation 

measures including the Forest-wide standards and guidelines for Soil and Water (USDA Forest Service 

2016a) are used to reduce surface erosion and sediment production. Although timber harvest, energy 

project development, mining activities, and other development would be similar under each alternative, 

the potential for adverse impacts on the soil and water resource in roadless areas would differ slightly 

among the alternatives based on different levels of projected road construction. Alternatives 4, 5, and 6 

would have a slightly larger potential for adverse effects, relative to Alternatives 1, 2, and 3, because they 

are expected to result in slightly more road development. However, the differences among alternatives 

would be minor because effects from those projected activities would be mitigated through the use of sitespecific analysis, Forest-wide standards and guidelines, and other best management practices (BMPs), 

including post-project rehabilitation of disturbed soil. In addition, actual impacts on water quality

anticipated from any alternative would be small in magnitude and scattered over a wide geographic area. 

Most of the potential effects would be of short duration, with disturbed soil areas rehabilitated after 

projects are completed in thoseareas.

Effects on air quality would also not substantially differ among alternatives. Based on the projected land 

management activities that differ among alternatives, atmospheric emissions in roadless areas are not 

anticipated to directly, indirectly, or cumulatively increase to a level that would be likely to exceed state or 

federal air quality standards. Air quality impacts from dust emissions would be negligible and would not 

vary significantly by alternative.

Roadless Characteristics: Social Values

The social values considered under roadless characteristics include remoteness, scenic quality, 

traditional cultural areas and sacred sites, reference landscapes, and other locally-unique characteristics. 

The current condition of most roadless areas on the Tongass is nearly pristine relative to these social 

values. Exceptions include the roaded roadless areas, where previous road development and timber 

harvest has taken place and localized areas along the shoreline where historic development has occurred 

or localized areas where mining-related activities have occurred.

Roadless areas provide recreation opportunity due to rich primitive, semi-primitive motorized, and semiprimitive non-motorized Recreation Opportunity Spectrum (ROS) classes of dispersed recreation. 

Approximately 95 percent of the 2001 roadless areas on the Tongass consist of primitive and semiprimitive ROS classes, and almost two-thirds of these are primitive. Under Alternative 2, roaded roadless 

and other substantially altered areas would lose regulatory protection as designated roadless. The net 

change in roadless designations would result in an increase of 20,000 acres of suitable old growth and 

11,000 acres of suitable young growth. The vast majority of the areas removed from roadless would be 

Roaded Modified and Roaded Natural. Under Alternative 2, approximately 95 percent of Tongass 

roadless areas would be maintained as primitive and semi-primitive ROS classes, an increase of 1 

percent (see Recreation and Tourism section for further details).

Under Alternative 3, approximately 96 percent of the roadless areas on the Tongass would be maintained 

as primitive and semi-primitive ROS classes. The net changes in roadless designations would provide 

85,000 more acres of suitable old growth and 15,000 more acres of suitable young growth. Under 

Alternatives 4 and 5, the remaining roadless areas would maintain approximately 96 and 97 percent of 

their areas as primitive and semi-primitive ROS classes, respectively. The net change in roadless 
Environment and Effects 3

Final EIS 3-16 Key Issue 1

designations under these two alternatives would provide 161,000 and 168,000 more acres of suitable old 

growth and 15,000 and 17,000 more acres of suitable young growth, respectively. With Alternative 6, all 

regulatory roadless designations would be removed. The areas removed from roadless designation would 

provide 168,000 additional acres of suitable old growth and 20,000 additional acres of suitable young 

growth. Under Alternatives 1, 2, 3, 4, and 5, the retained roadless areas would remain similar in terms of 

their ROS allocations. The exception would be Alternative 6, which would include no retained roadless 

designations.

Similarly, outfitter-guide use on the Tongass includes activities in more remote areas. The majority of 

these areas would be retained as roadless under Alternatives 1, 2, and 3. Substantially more lands in the 

primitive ROS class would be removed under Alternatives 4, 5, and 6.

Scenic Quality

The Tongass National Forest offers a variety of high-quality scenery to its visitors, from spectacular 

mountain ranges and glaciers to low-lying marine landscapes composed of intricate waterways, bays, and 

island groups. Scenic quality is based on two definable elements, landscape character and scenic 

integrity. Tongass roadless areas have natural appearing landscapes and have very high scenic integrity 

and generally have high value for landscape character as well. The exception for scenic integrity is the 

roaded roadless areas, which have significantly reduced scenic integrity because of past harvest and 

road construction. Roadless areas are viewed from a variety of vantage points, including the communities

of Southeast Alaska, the Alaska Marine Highway ferry route, cruise ship routes, existing road systems, 

popular small boat routes and anchorages, small aircraft, and hiking trails.

Road construction and timber harvest can have varying degrees of adverse effects on the scenic integrity 

of a landscape. In most studied viewsheds, the highest effects on scenery would be associated with 

Alternatives 5 and 6, followed in order by Alternative 4, Alternative 3, Alternative 2, and Alternative 1. In 

addition, Alternatives 4, 5, and 6 would likely result in more road development to reach more remote 

places, which would have a greater adverse effect on scenery than with less road development under 

Alternatives 1, 2, and 3. Road mileage differences, however, would not be large, because all alternatives 

would result in essentially the same level of acres harvested and timber volume removed (estimated 

maximum difference for new road construction of 49 miles among alternatives).

Traditional Cultural Properties and Sacred Sites

All alternatives require compliance with existing laws and regulations; therefore, before any management 

actions take place, the standard process for considering effects would be conducted as required by the 

implementing regulations for the National Historic Preservation Act and other relevant law, policy, and 

guidance provided in agreement documents. In most cases impacts would be avoided or mitigated. Tribal 

consultation is an integral part of the planning process for management actions; as well as consultations 

with the State Historic Preservation Officer and other interested parties.

For cultural resources, including historic and traditional cultural properties and sacred sites, prior to 

management actions taking place on the ground, resource inventories and appropriate mitigation are 

required by law. Some risk to cultural resources is associated with all alternatives, but increased risk 

would occur under Alternatives 4, 5, and 6 because of potentially greater road lengths and potential 

activity in areas currently and previously protected from development associated with harvest activities. 

Reference Landscapes and Locally Identified Unique Characteristics

A range of distinctive characteristics occur within the Tongass roadless areas. Many of these are already 

identified in the Forest Plan and managed as Special Interest Areas. These include Geological Areas, 

Recreation Areas, Zoological Areas, Botanical Areas, Cultural Areas, and Scenic Areas. Special Interest 

Areas cover 186,000 acres within 2001 roadless areas. In addition, a number of Research Natural Areas

occur within the Tongass roadless areas (21,000 acres). The Research Natural Areas, along with some of 

the Special Interest Areas, serve as reference landscapes. Further, a number of river corridors are 

managed under the Forest Plan as wild and scenic rivers. Within 2001 roadless areas, there are 14,000 

acres of Recreational River, 16,000 acres of Scenic River, and 48,000 acres of Wild River. Finally, there 
Environment and Effects 3

Final EIS 3-17 Key Issue 1

are other small areas, not included within these special LUDs, such as areas with unique karst features 

that occur within roadless areas.

Altogether, these special LUDs cover 285,000 acres within 2001 roadless areas (Alternative 1). Under 

Alternative 2, these areas would remain at 285,000 acres, and they would be little changed under 

Alternatives 3, 4, and 5 at 281,000 acres, 279,000 acres, and 283,000 acres, respectively. However, 

under Alternative 6, the roadless acreage within these special LUDs would decrease to zero.

Another reference landscape adjacent to the Tongass National Forest is Glacier Bay National Park and 

Wilderness. Commenters on the DEIS expressed concern about deleting the roadless designations on 

these adjacent lands and the effect on the Park and Wilderness values. The Chilkat Peninsula portion of 

the Tongass borders the eastern portion of the Park and the northern end of Chichagof Island lies across 

from the mouth of Glacier Bay. Alternatives 1, 2, and 4 have no effect on these adjacent lands, Alternative 

3 would remove roadless designations on the lands to the south on Chichagof Island, Alternative 5 would 

remove roadless designations on lands nearby, but not adjacent to the Park, and Alternative 6 would 

remove roadless designations on all adjacent lands. 

However, none of the adjacent lands are development LUDs. They consist of Semi-remote Recreation, 

Old-growth Habitat, and LUD II areas and no timber harvest or related road construction would be 

allowed under any of the alternatives. It is possible that limited road, mineral, or energy development 

could occur, but there are no known specific proposals. If specific proposals are made, they would be 

analyzed through individual site-specific NEPA. 

Alternative 1

Under Alternative 1 there would be no change in the boundaries of the IRAs identified in the 2001 

Roadless Rule and no changes to current management (Table 3.1-3, Figure 3.1-1). This alternative would 

continue the general prohibitions on tree cutting, sale, and removal and road construction/reconstruction 

within IRAs (9.37 million acres), with some of those activities permitted under certain exceptions. There 

would be no impact to existing Forest-wide roadless characteristics under this alternative. Existing IRA

boundaries would not be corrected or modified to address ownership changes and updated mapping.

Viewed relative to the action alternatives, along with Alternative 2, Alternative 1 would protect the most 

acres and existing management direction would provide the highest degree of protection, with the existing 

general prohibitions remaining in place.

Alternative 2

Under Alternative 2, there would be a slight decrease in roadless area acres, with 9.34 million acres 

managed as ARAs (Table 3.1-3, Figure 3.1-1). In addition to gains and losses from ownership changes 

and updated mapping, gains would include the addition of LUD II acres not designated as roadless in 

2001, while losses would include the removal of approximately 142,000 acres from roadless designation 

that have been substantially altered as identified by prior road construction or timber harvest. These 

areas are generally known as “roaded roadless” areas and include additional areas considered to be 

substantially altered. Because roaded roadless areas have been substantially altered, the roadless area 

characteristics they once had have been greatly diminished.

The removal of roaded roadless acres from roadless designation and other removals and additions would 

revert a net of about 20,000 acres of previously unsuitable lands to suitable old-growth lands that would 

be available for harvest. The projected harvest on suitable acres is not expected to change because of 

Forest Plan limitations, but would be spread over a wider pool of lands. Harvest in the areas converted 

from roadless would further reduce the limited roadless characteristics that remain in these roaded 

roadless areas. Estimated old-growth harvest in these roaded roadless areas over 100 years would be 

approximately 3,750 acres (Table 3.1-4).
Environment and Effects 3

Final EIS 3-18 Key Issue 1

Table 3.1-3

Roadless Areas by Alternative and Management Designation

Roadless Designation 

(acres)

Alternative

1 2 3 4 5 6

No Action

Roaded 

Roadless

Logical 

Extension

Partial 

Dev. LUDs1

All Dev. 

LUDs

Full 

Exemption

Total Roadless Area 9,368,000 9,336,000 8,224,000 8,975,000 7,047,000 0

ARA Management Designations

LUD II Priority N/A 854,000 0 854,000 847,000 0

Watershed Priority N/A 3,284,000 3,259,000 0 0 0

Roadless Priority N/A 5,199,000 4,595,000 7,363,000 6,200,000 0

Community Priority N/A 0 370,000 0 0 0

Timber Priority N/A 0 0 757,000 0 0

Change in Roadless Area Acres

Roadless Area Removed 0 142,000 1,252,000 401,000 2,321,000 9,368,000

Roadless Area Added 0 110,000 107,000 7,000 0 0

Net Change 0 -32,000 -1,144,000 -394,000 -2,321,000 -9,368,000

Old-Growth Acres Suitable for Harvest

Total Acres 227,000 247,000 312,000 388,000 395,000 395,000

Net Change 0 20,000 85,000 161,000 168,000 168,000

T77 & TNC/ Audubon Conservation Priority Areas Outside of Roadless given Long-term Regulatory 

Protection

Total Acres 0 0 507,000 0 0 0

1 Includes Timber Production and Modified Landscape LUDs, but not Scenic Viewshed.

N/A = not applicable; T77 = Tongass 77; TNC = The Nature Conservancy

Note: Numbers may not sum correctly due to rounding.

Figure 3.1-1

Roadless Areas by Alternative and Management Designation 

0

1,000

2,000

3,000

4,000

5,000

6,000

7,000

8,000

9,000

10,000

Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

Roadless Acres (1,000)

2001 Roadless Rule Roadless Priority LUD II Priority Watershed Priority

Community Use Priority T77 & TNC/Audubon Timber Priority
Environment and Effects 3

Final EIS 3-19 Key Issue 1

Table 3.1-4

Estimated Old Growth Harvest Acres on Each Ranger District by Stratum and Alternative1

Ranger 

District

Stratum

Estimated Old-Growth Harvest Acres 

Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

Craig Existing Roaded 3,100 2,850 2,150 1,600 1,550 1,550 

Roaded Roadless 0 800 800 800 800 800 

Logical Extensions 0 0 950 950 950 950 

Distant from Roads 0 0 0 500 650 650 

Subtotal 3,100 3,650 3,900 3,850 3,950 3,950 

Hoonah Existing Roaded 800 800 700 450 400 400 

Roaded Roadless 0 0 0 0 0 0 

Logical Extensions 0 0 150 150 150 150 

Distant from Roads 0 0 300 300 300 

Subtotal 42,500 42,500 42,500 42,500 42,500 42,500 

Juneau Existing Roaded 300 300 250 150 150 150 

Roaded Roadless 0 0 0 0 0 0 

Logical Extensions 0 0 0 0 0 0 

Distant from Roads 0 0 0 0 50 50 

Subtotal 800 800 850 900 850 850 

Ketchikan Existing Roaded 6,350 5,750 4,500 3,550 3,400 3,400 

Misty Fjords Roaded Roadless 0 900 900 900 900 900 

Logical Extensions 0 0 1,550 1,550 1,550 1,550 

Distant from Roads 0 0 0 1,300 1,450 1,450 

Subtotal 6,350 6,650 6,950 7,300 7,300 7,300 

Petersburg Existing Roaded 12,000 10,900 8,650 6,950 6,700 6,700 

Roaded Roadless 0 1,000 1,000 1,000 1,000 1,000 

Logical Extensions 0 0 2,950 2,950 2,950 2,950 

Distant from Roads 0 0 0 2,000 2,100 2,100 

Subtotal 12,000 11,900 12,600 12,900 12,750 12,750 

Sitka Existing Roaded 1,000 1,000 850 550 500 500 

Roaded Roadless 0 0 0 0 0 0 

Logical Extensions 0 0 200 200 200 200 

Distant from Roads 0 0 0 250 300 300 

Subtotal 1,000 1,000 1,050 1,000 1,000 1,000 

Thorne Bay Existing Roaded 13,450 12,200 9,800 8,200 8,000 8,000 

Roaded Roadless 0 500 500 500 500 500 

Logical Extensions 0 0 1,300 1,300 1,300 1,300 

Distant from Roads 0 0 0 800 900 900 

Subtotal 13,450 12,700 11,600 10,800 10,700 10,700 

Wrangell Existing Roaded 5,400 4,900 3,850 3,150 3,000 3,000 

Roaded Roadless 0 550 550 550 550 550 

Logical Extensions 0 0 950 950 950 950 

Distant from Roads 0 0 0 900 1,100 1,100 

Subtotal 5,400 5,450 5,350 5,550 5,600 5,600 

Total 

Acres1

Existing Roaded 42,500 38,700 30,750 24,600 23,750 23,750 

Roaded Roadless 0 3,750 3,750 3,750 3,750 3,750 

Logical Extensions 0 0 8,050 8,050 8,050 8,050 

Distant from Roads 0 0 0 6,050 6,850 6,850 

Subtotal 42,500 42,500 42,500 42,500 42,500 42,500 1 These estimates are very approximate and based on many assumptions. They are intended to provide a realistic, but rough indication 

of the distribution of harvest.

Although most roadless areas would decrease in size, 15 IRAs would increase more than 100 acres, with 

increases ranging up to 15,000 acres. Almost two-thirds of the suitable old-growth lands in roaded 

roadless are located on existing road systems in six 2001 IRAs: North Kupreanof (IRA 211), North Revilla 

(IRA 526), Twelvemile (IRA 534), Lindenberg (216), South Zarembo (IRA 237), and West Wrangell (IRA 

288) (Table 3.1-5). The entire increase in suitable acres would be in the five ranger districts on the south 

part of the Forest (Craig, Ketchikan Misty Fjords, Petersburg, Thorne Bay, and Wrangell; Table 3.1-6, 

Figure 3.1-2).
Environment and Effects 3

Final EIS 3-20 Key Issue 1

Table 3.1-5

Total Acres by 2001 Inventoried Roadless Area and Net Change in Suitable Old-Growth 

Acres by IRA and Action Alternative

Ranger 

District1

Roadless 

Area

Number

Roadless Area

Name

Total IRA

Acres2

Increase in Suitable Old-Growth Acres3

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

PRD 201 Fanshaw 48,317 0 0 0 0 0 

PRD 202 Spires 538,901 115 3,180 6,764 6,772 6,772 

WRD 204 Madan 69,608 0 0 0 5 5 

WRD 205 Aaron 79,731 0 0 0 0 0

WRD 206 Cone 127,963 0 0 0 0 0

WRD 207 Harding 175,432 0 0 0 0 0 

WRD 208 Bradfield 198,115 0 0 0 0 0 

WRD 209 Anan 37,876 0 0 0 0 0 

WRD 210 Frosty 38,658 122 363 1,710 1,710 1,710 

PRD 211 North Kupreanof 114,608 2,903 9,936 10,638 10,640 10,640 

PRD 212 Missionary 16,741 815 1,857 2,468 2,553 2,553 

PRD 213 Five Mile 19,078 1 1,136 1,279 1,287 1,287 

PRD 214 South Kupreanof 217,292 2 1,001 1,001 1,003 1,003 

PRD 215 Castle 49,997 0 0 0 0 0 

PRD 216 Lindenberg 25,841 2,018 4,265 6,399 6,763 6,763 

PRD 217 Green Rocks 10,726 236 259 329 343 343 

PRD 218 Woewodski 10,284 0 0 0 1 1 

PRD 220 East Mitkof 8,012 1 1 551 551 551 

PRD 223 Manzanita 8,394 2 964 966 966 966 

PRD 224 Crystal 18,648 6 466 1,868 2,055 2,055 

WRD 225 Kadin 2,020 0 0 0 0 0 

WRD 227 North Wrangell 7,943 681 2,706 2,706 2,706 2,706 

WRD 229 South Wrangell 14,133 0 2,368 2,368 2,369 2,369 

WRD 231 Woronkofski 11,101 0 0 0 0 0 

WRD 232 North Etolin 41,244 20 1,191 1,337 2,402 2,402 

WRD 233 Mosman 53,904 4 168 168 224 224 

WRD 234 South Etolin 26,665 11 245 1,496 1,496 1,496 

WRD 235 West Zarembo 6,787 11 11 264 264 264 

WRD 236 East Zarembo 10,928 237 237 3,030 3,126 3,126 

WRD 237 South Zarembo 36,334 1,624 2,577 5,138 5,138 5,138 

WRD 238 Kashevarof Islands 4,773 0 0 0 0 0 

PRD 239 Keku 9,274 0 5 5 5 5 

PRD 240 Security 31,663 34 587 1,418 1,418 1,418 

PRD 241 North Kuiu 6,352 -1,433 -1,433 512 513 513 

PRD 242 Camden 36,848 26 1,886 1,886 1,886 1,886 

PRD 243 Rocky Pass 77,057 11 106 254 254 254 

PRD 244 Bay of Pillars 27,408 0 0 0 0 0 

PRD 245 East Kuiu 27,050 13 13 608 608 608 

PRD 246 South Kuiu 62,268 0 0 0 0 0 

WRD 247 East Wrangell 7,263 11 369 369 369 369 

WRD 288 West Wrangell 8,823 1,125 1,299 1,299 1,299 1,299 

WRD 289 Central Wrangell 13,149 34 2,147 2,147 2,147 2,147 

WRD 290 SE Wrangell 18,480 17 822 822 822 822 

JRD 301 Juneau-Skagway

Icefield

1,204,175 19 19 40 40 40 

JRD 302 Taku-Snettisham 696,487 0 0 0 0 0 

JRD 303 Sullivan 67,229 0 0 0 0 0 

JRD 304 Chilkat-West Lynn 

Canal

195,334 291 291 3,421 4,350 4,350 

JRD 305 Juneau Urban 101,896 0 0 0 29 29 

JRD 306 Mansfield 

Peninsula

53,016 0 0 0 0 0 
Environment and Effects 3

Final EIS 3-21 Key Issue 1

Table 3.1-5 (continued)

Total Acres by 2001 Inventoried Roadless Area and Net Change in Suitable Old-Growth 

Acres by IRA and Action Alternative

Ranger 

District1

Roadless 

Area

Number

Roadless Area

Name

Total IRA

Acres2

Increase in Suitable Old-Growth Acres3

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

JRD 307 Greens Creek 27,412 0 0 0 0 0 

JRD 308 Windham-Port 

Houghton

159,986 0 0 123 125 126 

JRD 310 Douglas Island 24,682 0 0 0 0 0 

HRD/SRD 311 Chichagof 556,866 -1,920 201 8,376 8,894 8,895 

HRD/SRD 312 Trap Bay 13,296 15 977 977 977 977 

JRD 313 Rhine 22,735 0 0 0 13 13 

SRD 314 Point Craven 10,742 2 2 2 490 490 

HRD 317 Point Augusta 15,483 72 1,411 2,532 2,532 2,532 

HRD 318 Whitestone 5,882 0 0 725 876 876 

HRD 319 Pavlof-East Point 4,912 47 348 348 414 414 

SRD 321 Tenakee Ridge 20,699 68 1,312 3,577 3,577 3,577 

HRD/SRD 323 Game Creek 49,842 841 1,128 7,181 7,181 7,181 

HRD 325 Freshwater Bay 44,135 105 105 5,367 5,367 5,367 

SRD 326 North Kruzof 31,778 0 0 55 55 55 

SRD 327 Middle Kruzof 14,766 19 19 2,360 2,360 2,360 

SRD 328 Hoonah Sound 79,284 0 0 0 0 0 

SRD 329 South Kruzof 54,511 0 0 4 4 4 

SRD 330 North Baranof 314,304 127 127 6,608 6,609 6,609 

SRD 331 Sitka Urban 113,015 0 0 110 110 110 

SRD 332 Sitka Sound

13,185

0 0 0 0 0 

SRD 333 Redoubt 68,559 8 8 12 12 12 

SRD 334 Port Alexander 125,004 0 0 0 0 0 

YRD 338 Brabazon Addition 499,945 0 0 0 0 0 

YRD 339 Yakutat Forelands 325,755 0 0 0 0 0 

YRD 341 Upper Situk 17,479 2 2 2 2 2 

HRD 342 Neka Mountain 6,119 0 0 0 0 0 

HRD 343 Neka Bay 6,953 0 0 0 0 0 

CRD 501 Dall Island 108,002 0 0 0 0 0 

CRD 502 Suemez Island 20,177 -1 -1 1,504 1,505 1,505 

CRD 503 Outer Islands 99,051 0 0 0 13 13 

CRD 504 Sukkwan 44,551 0 0 0 0 4 

CRD 505 Soda Bay 64,067 461 2,719 2,716 2,723 2,723 

CRD 507 Eudora 197,359 21 95 1,144 1,152 1,152 

TRD 508 Christoval 9,113 150 150 320 320 320 

TRD 509 Kogish 64,010 1,003 7,026 7,075 7,075 7,075 

CRD 510 Karta 51,976 830 3,506 5,457 6,413 6,413 

TRD 511 Thorne River 74,080 533 2,070 2,319 2,666 2,666 

TRD 512 Ratz 5,402 47 47 210 210 210 

TRD 514 Sarkar 54,005 91 477 513 513 513 

TRD 515 Kosciusko 64,560 363 1,566 1,567 1,567 1,567 

TRD 516 Calder 8,868 0 0 0 0 0 

TRD 517 El Capitan 26,609 137 238 4,430 5,029 5,029 

TRD 518 Salmon Bay 24,115 213 449 1,179 1,179 1,179 

CRD 519 McKenzie 77,645 642 1,706 2,448 2,450 2,450 

TRD 520 Kasaan 7,648 0 0 0 0 0 

KRD 521 Duke 45,086 0 0 0 0 0 

KRD 522 Gravina 38,265 94 1,032 1,030 1,045 1,045 

KRD 523 South Revilla 52,826 227 3,688 3,697 3,710 3,710 

KRD 524 Revilla 30,869 8 1,349 1,349 1,349 1,349 

KRD 525 Behm Islands 4,351 0 0 0 0 0 

KRD 526 North Revilla 217,829 2,637 7,386 14,549 15,232 15,233 

KRD 528 Cleveland 187,974 0 0 0 116 116 

KRD 529 North Cleveland 109,379 0 0 0 270 270 
Environment and Effects 3

Final EIS 3-22 Key Issue 1

Table 3.1-5 (continued)

Total Acres by 2001 Inventoried Roadless Area and Net Change in Suitable Old-Growth 

Acres by IRA and Action Alternative

Ranger 

District1

Roadless 

Area

Number

Roadless Area

Name

Total IRA

Acres2

Increase in Suitable Old-Growth Acres3

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

KRD 530 Hyder 122,130 0 0 0 21 21 

CRD 531 Nutkwa 42,560 0 0 66 74 74 

TRD 532 Fake Pass 592 0 0 0 0 0 

CRD 533 Hydaburg 11,130 0 0 0 0 0 

CRD 534 Twelvemile 38,275 2,155 3,376 3,376 3,376 3,376 

KRD 535 Carroll 11,879 783 2,252 3,145 3,145 3,145 

TRD 536 Kasaan Bay 6,244 781 882 882 882 882 

KRD 577 Quartz 146,675 0 0 0 0 0 

Total 9,368,434 19,519 84,692 160,596 167,749 167,749 

Notes:

IRA = Inventoried Roadless Area 1 CRD = Craig Ranger District; HRD = Hoonah Ranger District; JRD = Juneau Ranger District; KRD = Ketchikan Misty Fjords 

Ranger District; PRD = Petersburg Ranger District; SRD = Sitka Ranger District; TRD = Thorne Bay Ranger District; WRD = 

Wrangell Ranger District; YRD = Yakutat Ranger District 2 Note that IRA boundaries have been edited to match the shoreline and ownership changes. 3 Increases in suitable old-growth acres would occur in areas removed from roadless area designation under all five action 

alternatives. 

Table 3.1-6

Percentage Increase in Suitable Old Growth Acres on Each Ranger District 

by Alternative 

Ranger District

Total IRA

Acres

Percentage Increase in Suitable Old-Growth Acres2

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

Admiralty NM 15,800 0% 0% 0% 0% 0%

Craig 735,200 22% 12% 9% 9% 9%

Hoonah 416,000 3% 4% 10% 10% 10%

Juneau 2,537,100 2% 0% 2% 3% 3%

Ketchikan Misty Fjords 967,300 19% 19% 15% 15% 15%

Petersburg 1,364,700 24% 29% 23% 22% 22%

Sitka 1,133,300 -6% 2% 14% 14% 14%

Thorne Bay 364,800 16% 17% 13% 13% 13%

Wrangell 990,900 20% 17% 14% 14% 14%

Yakutat 843,200 0% 0% 0% 0% 0%

Total Acres1 9,368,400 19,500 84,700 160,600 167,800 165,800

Notes:

IRA = 2001 Inventoried Roadless Area; NM = National Monument 1 Total IRA acres represent the total IRA acres for the Forest. Total acres presented by alternative are the 

estimated increase in suitable old-growth acres that would be available for harvest under each alternative. 2 Percent of total increase identifies the share of the total Forest-wide increase in suitable old-growth acres by 

Ranger District.
Environment and Effects 3

Final EIS 3-23 Key Issue 1

Figure 3.1-2

Increase in Suitable Old-Growth Acres Available for Harvest by Ranger District 

and Alternative

Notes:

CRD – Craig Ranger District; HRD – Hoonah Ranger District; JRD – Juneau Ranger District; KRD – Ketchikan

Misty Fjords Ranger District; PRD – Petersburg Ranger District; SRD – Sitka Ranger District; TRD – Thorne Bay

Ranger District; WRD – Wrangell Ranger District. 1 There are no suitable old-growth acres on the Admiralty National Monument, and the increase in suitable old-growth

acres available for harvest on the Yakutat Ranger District is 63 acres or less under Alternatives 2 through 6.

Three ARA categories would be designated: LUD II (9 percent), Watershed Priority (35 percent), and 

Roadless Priority (55 percent) (Table 3.1-3). None of these categories would allow commercial timber 

harvest or associated road building. The Watershed Priority ARA is more restrictive than the 2001 

Roadless Rule. Areas identified as Tongass 77 (T77) Watersheds or The Nature Conservancy 

(TNC)/Audubon Conservation Priority Areas in the 2016 Forest Plan (USDA Forest Service 2016a) would 

be designated as Watershed Priority ARAs. Forest-wide, the majority of the ARA acres would allow some 

forms of infrastructure development and mineral-related road construction, as is the case under 

Alternative 1, but they would be more explicitly allowed under Alternative 2. The impacts of these types of 

development are expected to be limited in terms of acreage covered, especially when viewed as a share 

of total protected acres. 

Alternative 3

Under Alternative 3, there would be an overall reduction in roadless area acres, with an estimated total of 

1.25 million acres removed from roadless designation, for a net loss of approximately 1.14 million acres 

due to roadless area additions. A total of 8.22 million acres would be managed as ARAs under this 

alternative (Table 3.1-3). Like Alternative 2, this alternative would remove “roaded roadless” areas. In 

addition, areas adjacent to existing road and harvest systems would be removed from roadless 

designation. These adjacent areas, considered “logical extensions” of the existing road and harvest 

systems within the same watersheds, would revert acres of previously unsuitable lands to suitable oldgrowth lands that would be available for harvest. Altogether, the removal of roaded roadless and logical 

extension acres from roadless designation, along with the gains and losses from ownership changes and 

updated mapping, would result in a net increase of about 85,000 acres of suitable old-growth lands that

0 20,000 40,000 60,000 80,000 100,000 120,000 140,000 160,000 180,000

Alt 6

Alt 5

Alt 4

Alt 3

Alt 2

Suitable Old-growth (acres)

CRD HRD JRD KRD PRD SRD TRD WRD
Environment and Effects 3

Final EIS 3-24 Key Issue 1

would be available for harvest. The projected harvest on suitable acres is not expected to change

because of Forest Plan limitations, but would be spread over a wider pool of lands. Harvest in the areas 

converted from roadless would reduce the roadless characteristics that are presently protected under 

Alternative 1.

Table 3.1-4 summarizes the estimated old-growth harvest over 100 years by Ranger District according to 

the various removal strata. Larger effects on roadless characteristics are generally expected to occur the 

farther out from existing roads that harvest occurs. Under Alternative 3, approximately 30,750 acres 

would be harvested in the existing roaded land base, 3,750 acres in the roaded roadless areas, and 

8,050 acres in the logical extension areas.

Although most roadless areas would decrease in size, nine IRAs would increase more than 100 acres, 

with increases ranging up to 10,000 acres. Half of the suitable old-growth lands that would be made 

available for harvest under this alternative are located in eight IRAs. The largest increases (more than 

4,000 acres each) would be in areas that are presently part of the Kogish (IRA 509), North Revilla (IRA 

526), North Kupreanof (IRA 211), and Lindenberg (IRA 216) IRAs (Table 3.1-5). Most of the increase in 

suitable old-growth acres would be in the five ranger districts on the south part of the Forest (91 percent) 

with these five districts ranging from 12 percent (Craig) to 29 percent (Petersburg) of the total increase 

(Table 3.1-6).

Roadless designation would also be removed from the 843,000 LUD II acres that are currently within an 

IRA. This change in management accounts for a large share of the decrease in roadless area acres that 

would occur under this alternative. Alternative 3 proposes to remove all statutorily designated LUD II 

areas from the current overlapping administrative roadless classification system as a means of eliminating 

confusion over governing standards and ensuring management consistent with congressional 

instructions. As a result, LUD II areas under Alternative 3 would retain their congressional protections and 

would continue to be managed “in a roadless state to retain their wildland character” as directed by the 

Tongass Timber Reform Act or other statute (USDA Forest Service 2016b).

ARAs would be designated according to three ARA categories under this alternative. Roadless Priority

ARA would receive 4.6 million roadless acres, Watershed Priority would receive 3.3 million roadless 

acres, and Community Priority would receive 0. 4 million acres. The Roadless Priority ARA is similar to 

the 2001 Roadless Rule, but less restrictive with respect to some forms of infrastructure development and 

mineral-related road construction. The Watershed Priority ARA is more restrictive than the 2001 Roadless 

Rule and the Community Priority, which covers lands around seven communities, is less restrictive. The 

impacts of developments within this latter designation are expected to be limited in acreage covered and 

affect a relatively small number of acres. In addition, Alternative 3 would provide long-term regulatory 

protection from old-growth harvest in all T77 Watersheds and TNC/Audubon Conservation Priority Areas 

outside of roadless under the Alaska Roadless Rule (507,000 acres). Although these would not be 

categorized as roadless areas, they would receive some degree of regulatory protection because the 

Alaska Roadless Rule would designate them as off-limits to old-growth harvesting (with a few exceptions) 

on a permanent basis. 

Alternative 4

Under Alternative 4, there would be an overall reduction in roadless area acres, with an estimated total of 

401,000 acres removed from roadless designation, 7,000 acres added, and a net loss of approximately 

394,000 acres. A total of 9.0 million acres would be managed as ARAs under this alternative (Table 3.1-

3). Altogether, the additions to and deletions from roadless would produce a net increase of about 

161,000 acres of suitable old-growth lands that would be available for harvest. In addition, the Timber

Priority ARA (see below) would result in the conversion of about 43,000 acres of previously unsuitable 

lands to suitable old-growth lands that would be available for harvest, resulting in an increase of 161,000 

acres of suitable old growth. Additions to roadless designation under this alternative include the LUD II

acres not previously designated as roadless in 2001.

Three ARA categories would be designated: LUD II Priority (10 percent), Roadless Priority (82 percent), 

and Timber Priority (8 percent) (Table 3.1-3). The LUD II Priority and Roadless Priority ARAs, which 

account for the majority of ARA acres (92 percent) under this alternative, do not allow commercial timber 
Environment and Effects 3

Final EIS 3-25 Key Issue 1

harvest or associated road building. Forest-wide, most of the ARA acres would allow some forms of 

infrastructure development and mineral-related road construction, but the impacts of these types of 

development are expected to be limited in terms of acreage, especially when viewed as a share of total 

protected acres.

As noted above, the Timber Priority ARA (8 percent of ARA acres) would allow timber harvest and road 

construction, resulting in the conversion of about 43,000 acres of previously unsuitable lands to suitable 

old-growth lands that would be available for harvest. The ARA acres that would be managed as Timber 

Priority are allocated to Timber Development and Modified Landscape LUDs in the 2016 Forest Plan. The 

Timber Priority ARA often include areas farther from existing road systems, making them more expensive 

and less likely to be accessed for timber production under the current Forest Plan. If harvest were to 

occur in these areas, impacts to roadless characteristics would likely be more noticeable than in logical 

extension areas, which are, by definition, in watersheds where road development and harvest has 

occurred in the past.

Reductions in roadless areas (roaded roadless and logical extensions) and the allocation of ARA acres to 

Timber Priority management would result in the total conversion of 161,000 acres of previously unsuitable 

lands to suitable old growth. The projected harvest on suitable acres is not expected to change because 

of current Forest Plan limitations, but would be spread over a wider pool of lands. Harvest in the areas 

converted from roadless would reduce the roadless characteristics that are presently protected under 

Alternative 1. As a result, Alternative 4 would more likely result in more degradation of roadless area 

characteristics than Alternatives 1, 2, and 3, but less than under Alternatives 5 and 6.

Table 3.1-4 summarizes the estimated old-growth harvest over 100 years by Ranger District according to 

the various removal strata. Larger effects on roadless characteristics are generally expected to occur the 

further out from existing roads that harvest occurs. Under Alternative 4, approximately 24,600 acres 

would be harvested in the existing roaded land base, 3,750 acres in the roaded roadless areas, 8,050 

acres in the logical extension areas, and approximately 6,050 acres in the areas more distant from roads.

Most roadless areas would decrease in size; none would increase. The largest gain in suitable old-growth 

acres would be in the North Revilla (IRA 526) IRA, followed by the North Kupreanof (IRA 211), Chichagof 

(IRA 311), Game Creek (IRA 323), and Kogish (IRA 509) IRAs (Table 3.1-5).

About 83 percent of the increase in suitable acres would be from the five south ranger districts (Craig, 

Ketchikan Misty Fjords, Petersburg, Thorne Bay, and Wrangell), with shares ranging from 9 percent 

(Craig) to 23 percent (Petersburg) of the total (Table 3.1-6).

Alternative 5

Under Alternative 5, there would be an overall reduction in roadless area acres, with an estimated net 

loss of approximately 2.3 million acres. A total of 7.0 million acres would be managed as ARAs under this 

alternative (Table 3.1-3). In addition to roaded roadless and logical extension areas, this alternative would 

remove all other Timber Production, Modified Landscape, and Scenic Viewshed LUDs identified in the 

2016 Forest Plan from roadless designation, including T77 Watersheds and TNC/Audubon Conservation 

Priority Areas within those development LUDs. Areas with mineral potential as defined by the “minerals 

overlay” in the Tongass Forest Plan would also be removed.

As with Alternative 6, this alternative would result in the conversion of about 168,000 acres of previously 

unsuitable old growth to suitable old-growth that would be available for harvest. The projected harvest on 

suitable acres is not expected to change because of Forest Plan limitations, but would be spread over a 

wider pool of lands. Harvest in the areas converted from roadless would reduce the roadless 

characteristics that are presently protected under Alternative 1. As a result, Alternative 5 would more 

likely result in more degradation of roadless area characteristics than all alternatives except Alternative 6. 

Suitable old-growth acres would be distributed across the same IRAs and ranger districts as they would 

be under Alternative 6, as summarized below (see also Tables 3.1-5 and 3.1-6).

Alternative 5 is estimated to have slightly less harvest in the roaded land base compared with Alternative 

4, about the same harvest in roaded roadless and logical extension areas, and more harvest in areas 

more distant from roads (about 800 more acres) than Alternative 4 (Table 3.1-4). Therefore, as noted 
Environment and Effects 3

Final EIS 3-26 Key Issue 1

above, Alternative 5 is likely to have a greater effect on roadless characteristics compared with 

Alternative 4. Under Alternative 5, approximately 23,750 acres would be harvested in the existing roaded 

land base, 3,750 acres in the roaded roadless areas, 8,050 acres in the logical extension areas, and 

approximately 6,850 acres in the areas more distant from roads.

Two ARA categories would be designated: LUD II Priority (12 percent) and Roadless Priority (88 percent) 

(Table 3.1-3). The LUD II Priority and Roadless Priority categories do not allow commercial timber harvest

or associated road building. Forest-wide, most of the ARA acres (88 percent) would allow some forms of 

infrastructure development and mineral-related road construction, but the impacts of these types of 

development are expected to be limited, especially when viewed as a share of total protected acres. 

Alternative 6

Alternative 6 is the full exemption alternative, as requested in the State of Alaska’s petition. Under this 

alternative, regulatory roadless designation would be removed from all designated roadless areas on the 

Tongass, resulting in a net reduction of 9.4 million acres of designated roadless areas (Table 3.1-3). 

Former roadless areas would be managed in accordance with the 2016 Forest Plan. Existing protections 

to roadless characteristics provided by Forest Plan non-development LUDs (including LUD II, Remote 

Recreation, Semi-remote Recreation, Old-growth Habitat, Special Interest Area, Wild River, Scenic River, 

and others) would remain in place.

Alternative 6 would have the same distribution of harvest acres among the distance strata as Alternative 

5, because they both would remove roadless designations on all development LUDs. Therefore, 

Alternatives 5 and 6 would have the largest effect on roadless characteristics; although the effects would 

be only slightly greater than with Alternative 4 (800 more harvest acres in areas more distant from roads) 

(Table 3.1-4). Under Alternative 6, approximately 23,750 acres would be harvested in the existing roaded 

land base, 3,750 acres in the roaded roadless areas, 8,050 acres in the logical extension areas, and 

approximately 6,850 acres in the areas more distant from roads.

Viewed in terms of suitable acres, the removal of regulatory roadless area prohibitions would result in the 

conversion of about 168,000 acres of previously unsuitable old growth to suitable old growth that would be 

available for harvest. This is similar to the additional old-growth acres that would be suitable under 

Alternative 4 (161,000 acres). The projected harvest on suitable acres is not expected to change because of 

Forest Plan limitations, but would be spread over a wider pool of lands. Harvest in the areas converted from 

roadless would reduce the roadless characteristics that are presently protected under Alternative 1. As a 

result, Alternative 6 would more likely result in more degradation of roadless area characteristics than any 

of the other alternatives. Overall increases in suitable old-growth larger than 100 acres would occur within 

63 IRAs, with increases ranging up to 15,025 acres. Gains of 5,000 acres or more in suitable old-growth 

would occur in 12 IRAs. The largest increase would be in in North Revilla (IRA 526), followed by North 

Kupreanof (IRA 211), Chichagof (IRA 311), Game Creek (IRA 323), and Kogish (IRA 509) IRAs (Table 3.1-

5). Slightly less than three-quarters of the increase (73 percent) in suitable acres would be in the five south 

ranger districts (Craig, Ketchikan Misty Fjords, Petersburg, Thorne Bay, and Wrangell). Increases in suitable 

old-growth in these five districts would range from 9 percent (Craig) to 22 percent (Petersburg) of the total 

(Table 3.1-6).

Ecosystem Services

Under the 2016 Forest Plan, timber management activities are governed by a number of rules and 

regulations designed to protect or mitigate adverse impacts to natural resources that provide ecosystem 

services. This is discussed further in the 2008 Forest Plan EIS (USDA Forest Service 2008b, pp. 3-553 to 

3-556). These rules and regulations would remain in place under all of the alternatives evaluated in this 

FEIS. The effects of the alternatives on these types of services are assessed in the sections of this FEIS 

that address fisheries, wildlife and subsistence use, and timber and vegetation, among others. Monetary 

values are not assigned to these services, but this does not lessen their importance in the decisionmaking process. Decision-makers will consider the economic values discussed in the Key Issue 2 section 

within the context of the information presented elsewhere in this document, much of which cannot readily 

be translated into economic terms.”
Environment and Effects 3

Final EIS 3-27 Key Issue 1

Cumulative Effects

Cumulative actions affecting the Roadless Rule have included modifications to the Roadless Rule as it 

applies to Idaho and Colorado. In addition to modifying the Roadless Rule, Colorado roadless lands were 

removed from having a roadless designation. In addition, Utah is seeking a state-specific modification to 

the Roadless Rule.

Table 3.1-7 summarizes the acres affected by modifications of the Roadless Rule, including past projects 

(Idaho and Colorado) and the alternatives being evaluated in this EIS for the AlaskaRule.

Under Alternative 1, 23 percent of the national roadless acres were modified as a result of the Idaho and 

Colorado Rule modifications; no modifications would result from the Tongass. The total acres of roadless 

areas nationally remains at almost 100 percent. Under Alternatives 2, 3, 4, and 5, the percent of national 

roadless acres modified would be 35 to 39 percent, while about 23 percent would be modified under 

Alternative 6. The total acres remaining in roadless areas nationally, under Alternatives 1, 2, 3, 4, and 5, 

would be 96 to almost 100 percent; however, this percentage would decrease to 84 percent under 

Alternative 6 due to the full elimination of roadless on the Tongass. 

Table 3.1-7

Summary of Acres Affected Nationally by Modifications of the Roadless Rule along with 

the Acres Affected by the Proposed Alaska Rule Modifications by the Alternatives

Modifications Proposed by Alaska Rule

Category Alt. 1 Alt. 2 Alt. 3 Alt. 4 Alt. 5 Alt. 6

Modifications by Idaho Rule 9,306,000 9,306,000 9,306,000 9,306,000 9,306,000 9,306,000

Modifications by Colorado 

Rule

4,186,000 4,186,000 4,186,000 4,186,000 4,186,000 4,186,000

Colorado Removals from 

Roadless (Net)

58,000 58,000 58,000 58,000 58,000 58,000

Proposed Alaska Rule 

Modifications

0 9,336,000 8,224,000 8,975,000 7,047,000 0

Proposed Alaska Removals 

from Roadless (Net)

0 32,000 1,144,000 394,000 2,321,000 9,368,000

Total Acres Modified 13,492,000 22,828,000 21,716,000 22,467,000 20,539,000 13,492,000

Total Acres Removed 58,000 90,000 1,202,000 452,000 2,379,000 9,426,000

Total Original Acres in 

Roadless Nationally1

58,292,000 58,292,000 58,292,000 58,292,000 58,292,000 58,292,000

Percent of Original National 

Acres Modified

23.1% 39.2% 37.3% 38.5% 35.2% 23.1%

Percent of Original National 

Acres Removed

0.1% 0.2% 2.1% 0.8% 4.1% 16.2%

Percent of Original National 

Acres Remaining in 

Roadless

99.9% 99.8% 97.9% 99.2% 95.9% 83.8%

Source: National Datasets and Tongass GIS

1 These acres are adjusted for administrative corrections to account for ownership changes, boundary alignment corrections 

(shorelines in Alaska), clerical errors, mapping errors, and changes in mapping technologies for Colorado and Alaska. Original 

acres were 58,453,000 and these adjustments amounted to a net of 161,000 acres.
Environment and Effects 3

Final EIS 3-28 Key Issue 1

This page intentionally left blank.
Environment and Effects 3

Final EIS 3-29 Key Issue 2

Key Issue 2 – Support Local and Regional 

Socioeconomic Well-being, Alaska Native 

Culture, Rural Subsistence Activities, and 

Economic Opportunity Across Multiple 

Economic Sectors

Affected Environment

The Tongass National Forest stretches roughly 500 miles northwest from Ketchikan to Yakutat and 

includes approximately 80 percent of the land area in Southeast Alaska. The region is sparsely settled 

with an estimated 72,915 people living in more than 30 towns and villages located in and around the 

Forest in 2017, most of which are located on islands or along the narrow coastal strip (Alaska Department 

of Labor [DOL] 2018). The communities of Southeast Alaska depend on the Tongass National Forest in 

various ways, including employment in the wood products, commercial fishing and fish processing, 

recreation, visitor, and mining and mineral development sectors. Many residents depend heavily on 

subsistence hunting and fishing to meet their basic needs. In addition, natural amenities and recreation 

activities associated with the Tongass National Forest form an important part of the quality of life for many

residents of Southeast Alaska. Since there is very little private land in the region to provide these 

resources and opportunities, appropriate management of the Tongass National Forest is important to 

communities and the overall regional economy.

The Tongass National Forest is also an important national and international resource. An estimated 1.2 

million people visited Southeast Alaska in 2016, with most of these visitors (86 percent) arriving by cruise 

ship (McDowell Group 2017). For many, a visit to the Tongass is an once-in-a-lifetime experience and 

spending by these visitors helps drive the recreation and tourism sector. The Tongass National Forest 

contains large areas of essentially undisturbed forest lands, which represent increasingly scarce and, 

therefore, increasingly valuable ecosystems. These lands have value for many people who may never 

visit Southeast Alaska, but benefit from knowing that the Tongass National Forest is there. This type of 

value, often referred to as non-use value, includes existence, option, and bequest values. These values 

represent the value that individuals obtain from knowing that the Forest exists, knowing that it would be 

available to visit in the future should they choose to do so, and knowing that it will be left for future 

generations to inherit.

Regional Demographic Overview

Southeast Alaska is divided into eight boroughs and two census areas (CAs). The eight boroughs –

Haines, Juneau, Ketchikan Gateway, Petersburg, Sitka, Skagway, Wrangell, and Yakutat – correspond 

with the county governments found elsewhere in the United States. The remaining areas that are not part 

of a borough are allocated to two CAs: the Hoonah-Angoon CA and Prince of Wales-Hyder CA. CAs are 

statistical units that are widely recognized from a data reporting standpoint by federal agencies and most 

state agencies as county equivalents. Boroughs and CAs are collectively referred to as “boroughs” in the 

remainder of this section.

Total regional population in Southeast Alaska peaked in 2014 and has since decreased five years in a 

row, by a combined total of 2,145 people (Figure 3.2-1). Population losses have been most dramatic in 

Juneau, with recent cuts in state sector employment contributing to a net reduction of 900 residents in 

2016 and 2017. Much of these losses appear to be the result of young families moving away, with Juneau 

losing more than 300 children and 400 age 30 to 40 demographic. These reductions have been matched 

by a further decrease in K-12 enrollment in Southeast Alaska. Since 1997, annual enrollment has 

decreased by more than 3,500 students, a 24 percent decline (Southeast Conference 2019). This loss of 

young families has exacerbated the most pronounced regional demographic shift since 2010: the aging of 
Environment and Effects 3

Final EIS 3-30 Key Issue 2

the population, with the 60-plus population increasing by more than 40 percent over this period due to 

aging in place (Southeast Conference 2019).

Figure 3.2-1

Total Population in Southeast Alaska, 2010 to 2019

Note:

1 Data for 2010 are from the 2010 Census (April). Data for 2011 to 2019 are annual estimates.

Source: Alaska DOL 2019

The three largest communities – Juneau, Ketchikan, and Sitka – together accounted for 75 percent of 

total regional population in 2019 (Figure 3.2-2). Juneau, which is the state capital and a regional trade 

center, accounted for 44 percent of Southeast Alaska’s total population in 2019 (Figure 3.2-2). Ketchikan 

Gateway Borough, the second largest borough in Southeast Alaska, accounted for about 19 percent of 

the region’s population. Ketchikan is a smaller regional trade center that serves Prince of Wales Island 

and the surrounding area.

Population is discussed in more detail in the Subregional Overview and Communities section of the 2016 

Forest Plan Amendment EIS (USDA Forest Service 2016b, pp. 3-525 to 3-535).

71,664

73,582

74,168 74,297

74,518 74,371

73,827

72,915

72,657

72,373

70,000

70,500

71,000

71,500

72,000

72,500

73,000

73,500

74,000

74,500

75,000

2010 2011 2012 2013 2014 2015 2016 2017 2018 2019
Environment and Effects 3

Final EIS 3-31 Key Issue 2

Figure 3.2-2

Total Population by Southeast Alaska Borough, 2019

Notes:

Total = 72,373 residents 

Boroughs and CAs are collectively referred to as “boroughs” in this figure. Hoonah-Angoon and Prince of WalesHyder are CAs.

Source: Alaska DOL 2019

The remote nature of the region is reflected in a population density of approximately two persons per 

square mile, which is much lower than the United States’ average of 92 persons per square mile. Many 

locations are accessible only by boat or plane, and landing strips or seaplane facilities are located in 

virtually all communities. The Alaska State ferry system transports people and vehicles between several 

ports in Southeast Alaska, and Prince Rupert, British Columbia, and Bellingham, Washington. Haines and 

Skagway, at the northern end of the Forest, and Hyder at the southern end, offer access to interior and 

Southcentral Alaska via the Alaska Highway, and Canada via the Cassiar Highway.

Regional Economic Overview

The following section is based on the latest data available. These data were compiled prior to the

coronavirus pandemic, which is ongoing at the time of writing. The coronavirus is expected to have 

significant economic impacts throughout the region that are not captured in the following sections. A 

preliminary analysis of virus-related economic impacts prepared and just released by the Alaska DOL 

(2020) found that Southeast Alaska will experience significant impacts from the likely cancellation of the 

2020 summer cruise ship season. Businesses throughout the region would normally have started hiring in 

March and April in preparation of the upcoming season. Based on a preliminary analysis of businesses 

directly tied to summer tourism, they estimate that there will be about 18,000 fewer jobs statewide during 

the July peak, if there is little or no tourism. The seafood processing sector in April and May is also 

expected to be impacted because of reduced worker supply (approximately 74 percent of workers in this 

sector are nonresident), with secondary concerns related to reductions in market demand, and 

implications for commercial fishermen if seafood processors are unable to operate (Alaska DOL 2020).

Southeast Alaska employment in 2018 is summarized by sector in Table 3.2-1. Government and the 

visitor sector were the largest employers’ accounting for 29 percent and 18 percent of total employment, 

respectively. The government sector is the main source of year-round employment in all the communities
Environment and Effects 3

Final EIS 3-32 Key Issue 2

in Southeast Alaska. In addition to direct employment in government, many of the area’s private sector 

jobs are also dependent on government funding and contracts. Private sector activities dependent on 

government funding include road construction and health care services.

State government employment has decreased significantly since 2012, with a loss of 850 state jobs in 

Southeast Alaska from 2012 through July 2018. Three-quarters of these losses occurred in Juneau. 

These losses have accompanied declining oil production and prices, with state revenues falling by 70 

percent from Fiscal Year 2013 to Fiscal Year 2018, and the state budget decreasing by 40 percent. 

Federal government employment has also declined in Southeast Alaska over the past decade, with the 

loss of 600 jobs since 2005 (Southeast Conference 2018).

Table 3.2-1

Southeast Alaska Employment by Sector, 2018 

Economic Sector1

Total Employment 

(Jobs)

Total Earnings 

($M)2

Percent of Total

Employment Earnings

Government (includes Coast Guard) 13,148 776.9 29% 34%

Visitor 8,004 249.3 18% 11%

Seafood 3,711 237.4 8% 10%

Retail and Wholesale Trade 4,490 145.1 10% 6%

Health Care (private only) 2,852 168.6 6% 7%

Construction 1,909 121.6 4% 5%

Financial 1,830 122.2 4% 5%

Professional and Business Services 2,910 123.0 6% 5%

Social Services 1,476 46.4 3% 2%

Mining 889 93.0 2% 4%

Information3 541 23.5 1% 1%

Timber 337 18.8 1% 1%

Warehousing, Utilities, Transportation4 943 61.8 2% 3%

Other 2,602 94.5 6% 4%

Total 45,642 2,282.0 100% 100%

Notes:

1 These data were compiled on behalf of Southeast Conference based on data collected by the Alaska DOL and the U.S. 

Census Bureau. The Alaska DOL data are for 2018 for non-agricultural wage and salary employment. These data do not 

include proprietors or self-employed workers, and are, therefore, supplemented using data from the 2017 US Census 

Nonemployer Statistics, which specifically count proprietors and the self-employed. 2 Total earnings are expressed in millions of dollars.

3 The Information sector, as defined here, includes publishing, broadcasting, and telecommunications. 4 Includes non-visitor-related transportation only. Visitor-related transportation is included in the visitor sector.

Source: Southeast Conference 2019

Natural Resource-Based Industries

Direct employment in natural resource-based industries – timber, visitor, seafood, and mining – together 

accounted for an estimated 12,941 jobs in 2018, more than one-quarter (28 percent) of total employment 

in Southeast Alaska (Table 3.2-1). The estimated distribution of resource-dependent employment is 

shown by industry in Figure 3.2-3. The visitor industry accounted for more than half (62 percent) of this 

total, followed by the seafood sector, which accounted for almost one-third (29 percent). Mining 

accounted for 7 percent and wood products made up 3 percent (Figure 3.2-3).
Environment and Effects 3

Final EIS 3-33 Key Issue 2

Figure 3.2-3

Natural Resource-Based Employment by Sector, 2018

Notes:

Total = 12,941 Employees

Source: Southeast Conference 2019

Nonresident and Seasonal Employment

Nonresident and seasonal employment are two important and related aspects of resource-dependent 

employment in Southeast Alaska. Many nonresidents work a relatively short time in Alaska, often for just 

two or three months, generally spend the bulk of their earnings elsewhere, and, as a result, contribute 

less to the regional economy than resident workers.

Nonresidents accounted for more than one-quarter (27 percent) of total estimated employment in 

Southeast Alaska in 2018 (Krieger et al. 2020). Viewed by borough, the estimated nonresident share of 

total employment ranged from about 17 percent in Wrangell to 71 percent in Skagway. Seafood 

processing had the highest percentage of nonresident workers, with 67 percent of the labor force 

composed of nonresidents. The Arts, Entertainment, and Recreation sector and the Accommodation and 

Food Services sector in Southeast Alaska also had relatively high nonresident shares, 54 percent and 55 

percent, respectively, as did the Mining sector (51 percent) (Krieger et al. 2020).

Southeast Alaska’s economy is highly seasonal. This is particularly the case with the salmon-harvesting and 

seafood-processing sectors. Seasonal variation in the leisure and hospitality sector (used here as a proxy for 

the visitor industry) is substantially lower than the salmon harvesting and seafood processing sectors, but more 

than twice the Southeast Alaska average. Annual seasonal variation for mining and logging are lower than the 

Southeast Alaska average. Nonresident and seasonal employment are discussed in more detail in the 2016 

Forest Plan Amendment EIS (USDA Forest Service 2016b, pp. 3-482 to 3-484).

Subsistence Economy

Subsistence use of fish, wildlife, and other natural resources is an important component of the economies 

of Southeast Alaska communities. Cash income in most Southeast Alaska rural communities is limited 

and intermittent, and subsistence harvests have been found to fill essential food needs in all rural 

communities in the region. These harvests are also customarily shared among community residents and 

between members of different communities. Although some subsistence products are traded and 

bartered, subsistence harvest is not geared toward market sale or commercial profit. A mixed 

Timber, 3%

Visitor, 62%

Seafood, 29%

Mining, 7%
Environment and Effects 3

Final EIS 3-34 Key Issue 2

subsistence-market economy in which subsistence harvests and cash income are complementary 

characterizes the economies of most of the region’s rural communities and provides the economic basis 

for a way of life that is highly valued in these communities (Wolfe 2004; Wolfe and Walker 1987). 

Elements of the subsistence economy are discussed in more detail in the separate Subsistence section in 

this document, see below.

Industry-Specific Descriptions

Forest Products

Employment

Southeast Alaska timber is primarily purchased and harvested from Tongass National Forest lands 

managed by the USDA Forest Service, from the State of Alaska (Division of Forestry, Alaska Mental 

Health Trust Land Authority, and University of Alaska Trust Land Office), and Alaska Native Village and 

Regional corporations (Alaska Native corporations). Sawmill employment has historically been supported 

by Forest Service timber sales, with state timber harvest also contributing. Logging employment is 

generated from all ownerships, including Alaska Native corporation lands.

Timber industry employment in Southeast Alaska peaked at the end of the 1980s, before decreasing 

sharply in the 1990s. Much of this job loss was associated with closure of the large pulp mills in Sitka

(1993) and Ketchikan (1997). Timber employment has continued to decline since the 1990s, falling from a 

recent high of 561 jobs in 2003 to 193 jobs in 2018 (Table 3.2-2; Figure 3.2-4). Tongass National Forestrelated employment in logging and sawmilling declined from 199 jobs in 2003 to a low of 62 jobs in 2017 

and 2018. Non-Tongass timber employment also declined over this period, falling from a high of 362 jobs 

in 2003 to 131 jobs in 2018, a decrease of 64 percent (Table 3.2-2). From 2002 to 2018 harvest activities 

on the Tongass supported about 41 percent of timber jobs in Southeast Alaska, on average. Harvest 

activities supporting employment have included pre-commercial thinning, generally defined as a 

silvicultural treatment to reduce stand density, to improve understory habitat (deer), improve the growth 

characteristics of trees, shorten rotation times, and improve forest health.

Table 3.2-2

Timber Industry Employment in Southeast Alaska, 2002-2017

Year1

Tongass 

Logging

Tongass 

Sawmill

Total TongassRelated 

Employment

Other 

Logging

Other 

Sawmill

Total Other 

Timber

Employment

Total Timber

Industry

Employment

2002 63 110 173 299 40 339 512

2003 108 91 199 298 64 362 561

2004 82 95 177 220 53 273 450

2005 88 96 184 263 52 315 499

2006 81 77 158 217 46 263 421

2007 44 70 114 225 54 279 393

2008 52 70 122 118 24 142 264

2009 48 39 87 110 19 129 216

2010 61 43 104 133 7 140 244

2011 62 47 109 150 3 153 262

2012 42 47 89 144 11 155 244

2013 75 48 123 106 14 120 243

2014 86 60 146 96 7 104 249

2015 104 58 162 63 12 75 237

2016 81 70 151 76 1 77 228

2017 25 37 62 108 32 141 202

2018 25 37 62 94 37 131 193

Note:

1 Data are presented by calendar year. Source: USDA Forest Service 2018a, 2020
Environment and Effects 3

Final EIS 3-35 Key Issue 2

Figure 3.2-4

Timber Industry Employment in Southeast Alaska, 2002-2018

Source: USDA Forest Service 2018a, 2020

Harvest

Timber harvest in Southeast Alaska also peaked in the late 1980s, with harvest levels slightly below 1 

billion board feet. Total harvest in 2018 was 96.0 MMBF, about 10 percent of peak levels. Harvest on the 

Tongass accounted for about 21 percent (20.0 MMBF) of this total, with almost two-thirds (61 percent, 

58.4 MMBF) of the overall total provided by Alaska Native corporation lands and 18 percent (17.6 MMBF) 

provided by the State of Alaska (Table 3.2-3; Figure 3.2-5).

0

100

200

300

400

500

600

Jobs

Year

Tongass Logging Tongass Sawmill Other Logging Other Sawmill
Environment and Effects 3

Final EIS 3-36 Key Issue 2

Table 3.2-3

Timber Harvest in Southeast Alaska by Ownership, 2002–2018

Year1 Tongass National Forest State of Alaska2

Alaska Native 

Corporation Total

2002 31.9 57.3 101.7 190.9

2003 48.1 34.8 105.7 188.6

2004 49.2 24.2 98.9 172.3

20053 46.6 42.9 103.9 193.4

20063 40.0 44.6 71.2 155.8

20073 4 22.5 44.6 50.0 117.1

2008 30.0 11.9 52.3 94.2

2009 28.3 13.5 51.8 93.6

2010 35.7 10.5 66.4 112.6

2011 31.6 16.3 63.1 111.0

2012 17.5 10.8 56.1 84.4

2013 41.2 11.2 47.4 99.8

2014 36.7 12.0 29.3 78.0

2015 59.5 6.2 32.4 98.1

2016 43.5 27.5 34.6 105.6

2017 16.0 11.9 46.4 74.2

2018 20.0 17.6 58.4 96.0

Notes:

1 Timber harvest volume is reported by calendar year in million board feet (MMBF), and includes both sawlog and utility 

logs. Sawlogs are logs that come from that portion of the tree that is of suitable size and quality to be cut into dimension 

lumber. Utility logs are logs that cannot be used to produce lumber but are suitable for chips. Note that timber sold in a 

year is not necessarily harvested in the same year and sales may be harvested over several years. 2 State of Alaska includes Division of Forestry, Mental Health Trust, and University of Alaska Trust Lands. 3 The relative increase in State harvest was an effort to provide additional timber to make up for a shortfall in supply from 

the Tongass.

4 The relative decrease in Tongass harvest in 2007 was the result of an injunction that stopped Tongass logging over 

most of the operating season.

Source: USDA Forest Service 2018a, 2020
Environment and Effects 3

Final EIS 3-37 Key Issue 2

Figure 3.2-5

Timber Harvest in Southeast Alaska by Ownership, 2002-2018

Source: USDA Forest Service 2018a, 2020

2016 Forest Plan and the Tongass Timber Program

Annual Market Demand

The Tongass National Forest, in compliance with the Tongass Timber Reform Act (1990), seeks to 

provide an annual (and planning cycle) supply of timber to meet market demand to the extent consistent 

with providing for multiple use and sustained use of all renewable forest resources and other applicable 

laws. The formulas and procedures used to forecast annual market demand are described in a Forest 

Service report titled Responding to the Market Demand for Tongass Timber: Using Adaptive Management

to Implement Section 101 of the 1990 Tongass Timber Reform Act (Morse 2000). These procedures, 

known as the “Morse Methodology,” are based on the following premises:

Forest product markets are volatile, especially in the short-term.

Timber purchasers in Southeast Alaska have few alternative suppliers of timber if they cannot obtain 

it from the Tongass National Forest. The only adverse economic effects of oversupplying the market

are Forest Service expenses to prepare timber sales with no bidders; undersupplying it can have 

much greater negative consequences.

It takes years to prepare NFS timber for sale, including completion of EISs. 

It is difficult to estimate demand for timber from the Tongass National Forest, even a year or two in

advance.

Industry must be able to respond to rapidly changing market conditions in order to remain

competitive.

Following the 2016 Forest Plan Amendment EIS, the derived demand projections from Daniels et al. 

(2016) were incorporated into the Morse Methodology and used to develop subsequent annual estimates 

of the Tongass National Forest timber sale offerings required to meet market demand (Grewe 2017). The 

resulting estimates for Fiscal Years 2017, 2018, and 2019 were 53 MMBF, 58 MMBF, and 52 MMBF, 

respectively (USDA Forest Service 2017a, 2018b, 2019a). These estimates are not intended to represent 

actual timber purchases. Rather, these annual estimates reflect the estimated volume of timber the Forest 

Service needs to offer to replace the volume expected to be harvested and to help build a 3-year supply 

0

20

40

60

80

100

120

140

160

180

200

MMBF

Year

Tongass National Forest State of Alaska Native Corporation
Environment and Effects 3

Final EIS 3-38 Key Issue 2

of timber under contract. This 3-year supply allows the industry to respond to market fluctuations. In 

practice, the actual amount of timber that is offered and sold may be substantially less than the predicted 

timber purchases in the annual demand calculations. This is because the actual volume of timber offered 

in any year reflects a combination of factors, including final budget appropriations, completing the NEPA 

process, and volume affected by litigation. The planned annual timber volume could include a 

combination of new, previously offered, and reconfigured timber sales. Both old-growth and young-growth 

green timber and salvage sales are components of this program.

Timber Supply

The Tongass National Forest uses a five-year timber sale schedule for planning and scheduling purposes 

that is consistent with Forest Service Manual 2430. This five-year plan is based on completed and 

ongoing environmental analyses and can be adjusted in response to changing market conditions and the 

NEPA public involvement process on projects. Volumes for future timber sales are estimates that may be 

adjusted over time. The Tongass National Forest posts the five-year schedule on the public website at: 

www.fs.usda.gov/tongass/. 

For Fiscal Year 2017, the annual demand goal for volume of timber to be offered from the Tongass 

National Forest was 53 MMBF (USDA Forest Service 2017a). A total of 30.7 MMBF was sold on the 

Tongass in Fiscal Year 2017, with the Good Neighbor Authority (GNA) Kosciusko Young Growth sale 

purchased by Alcan Forest Products accounting for 30 MMBF (98 percent) of the total (USDA Forest 

Service 2017b). The GNA Kosciusko Young Growth sale was the first timber sale awarded under a GNA 

agreement between the State of Alaska and USDA Forest Service. Under this agreement, the State 

Division of Forestry and its partners and contractors were authorized to prepare, award, harvest, and 

administer the sale. The sale area consisted of 1,500 acres of young-growth timber stands composed of 

approximately 75 percent Sitka spruce and 25 percent western hemlock, with stands to be harvested 

using a variety of methods (USDA Forest Service 2017c). The remaining volume sold in Fiscal Year 2017 

consisted of 9 microsales and two other small sales, which together included less than 1 MMBF of old 

growth in volume (USDA Forest Service 2017b).

For Fiscal Year 2018, the annual demand goal for volume of timber to be offered from the Tongass National 

Forest was 58 MMBF (USDA Forest Service 2018b). This was not matched by the proposed sales identified 

for 2018 in the five-year timber sale plan for 2018, which estimated that a total volume of 32.4 MMBF would 

be made available for sale (USDA Forest Service 2018c). A total of 9.0 MMBF was sold on the Tongass in 

Fiscal Year 2018, with the Rough Luck sale purchased by Viking Lumber accounting for 7.6 MMBF (84 

percent) of the total. The remaining 15 sales purchased that year consisted together of about 1.4 MMBF 

(USDA Forest Service 2018d). The FY 2018 sales consisted entirely of old growth.

The Final EIS for the Prince of Wales Landscape Level Analysis Project noted that there has been a lack 

of economic timber volume available for the Forest Service to offer across the Tongass National Forest 

(USDA Forest Service 2018e). Under the Further Consolidated Appropriations Act, 2020, timber sales 

that do not appraise positive using the current Region 10 RV (Residual Value) appraisal cannot be 

offered (USDA Forest Service 2018e).

Three other sales that were offered in Fiscal Year 2018 did not receive any bids. Combined these sales 

consisted of an estimated 23.6 MMBF that went unpurchased. The three sales were North Kuiu 2 (13.4 

MMBF), Wrangell Island (7.4 MMBF), and GNA Vallenar Young-Growth (2.8 MMBF).

North Kuiu 2 was the largest of the no-bid sales offered in 2018. A timber sale on Kuiu Island was 

originally authorized by the Forest Supervisor in 2008 and consisted of an estimated 31 MMBF from 

1,200 acres of old-growth forest. A version of the sale was first offered in September 2016. This sale 

consisted of approximately 30 MMBF from 866 acres and did not receive any bids at that time. Following 

the decision for the 2016 Forest Plan Amendment, the proposed sale area was reduced, and the sale 

was reoffered in 2018, this time consisting of 13.4 MMBF from 523 acres (Gullufsen 2018). No bids were 

received in 2018.

The Wrangell Island timber sale consisted of 7.4 MMBF of old-growth timber intended to provide a supply 

of “bridge” timber that would support local jobs and facilitate the young-growth transition. The project area 

consisted of approximately 428 acres on Wrangell Island (USDA Forest Service 2017d).
Environment and Effects 3

Final EIS 3-39 Key Issue 2

The Vallenar Young-growth Project, which consisted of approximately 2.8 MMBF of young-growth on 

Gravina Island near the Ketchikan airport, was subsequently sold in 2019 along with 13.2 MMBF of stateowned old-growth. Approximately 2.9 MMBF of old-growth timber was also sold in FY 2019.

For Fiscal Year 2019, the annual demand goal for volume of timber to be offered from the Tongass National 

Forest was 52 MMBF (USDA Forest Service 2019a). The five-year timber sale plan for 2019 estimated that a 

total volume of 56.5 MMBF would be made available for sale, with most of this volume (50 MMBF, 88 percent 

of the total) to be provided by the Prince of Wales Landscape Level Analysis Project (USDA Forest Service 

2019b). A total of 5.3 MMBF was sold on the Tongass in Fiscal Year 2019. No volume was offered from the 

Prince of Wales Landscape Level Analysis (USDA Forest Service 2019c), which is currently under courtimposed injunction preventing harvest.

R10 Limited Export Shipment Policy

Initially established in 2007, the Limited Export Policy is intended to boost appraised timber values and 

provide economic sale opportunities and additional processing options for purchasers. The policy has 

continued since 2007 with modifications designed to provide additional opportunities. The limited export 

policy is reviewed on an annual basis. The Regional Forester noted in a 2015 review that, while 

improvements had occurred nationally over the preceding three years, challenges continued for 

purchasers seeking domestic markets for Alaska timber. The current policy allows the limited export of 

unprocessed western hemlock and Sitka spruce logs up to 50 percent of the total sale sawtimber volume 

upon Regional Office approval. In 2012, the Regional Forester agreed to begin reviewing requests to 

allow increased export of these species on a case-by-case basis, in exchange for purchasers providing 

an equivalent amount of Alaska yellow-cedar to small business operators who would process the timber 

locally. The Limited Export Policy is discussed in detail in Appendix H to the 2016 Forest Plan 

Amendment EIS (USDA Forest Service 2016b).

The share of total harvest on the Tongass exported as logs has varied over time, as shown in Figure 3.2-

6. The export amount includes both international exports as well as domestic exports to the lower 48. 

With the exception of 2016, the majority of timber harvested from the Tongass has remained in-state for 

processing. In 2018, 9.2 MMBF (46 percent) of the total harvested (20.0 MMBF) was exported, with the 

majority (95 percent) exported to the Pacific Rim, rather than the lower 48 (USDA Forest Service 2018g).

Figure 3.2-6

Timber Harvest Exports from the Tongass National Forest, 2002-2018

Note: These data represent actual volume cut and processed by year, not volumes sold for the same year.

Source: USDA Forest Service 2019d

0

10

20

30

40

50

60

MMBF

Year

Processed In-State Exported Unprocessed
Environment and Effects 3

Final EIS 3-40 Key Issue 2

Timber Industry

Annual Mill Survey

The wood products industry in Southeast Alaska in its current form consists of individual- and familyowned sawmills and independent logging businesses. The Forest Service has conducted an annual onsite survey of sawmills in the region since 2000. To maintain consistency, the survey includes only those 

mills assessed in previous survey years. The original list of mills to be surveyed, initially identified in 2000, 

consisted of 20 sawmills that regularly operated and met established criteria for medium- to large-size 

classification. This total was subsequently increased to 22 in 2007. The annual survey for 2018 found that 

seven of these sawmills (32 percent) were still active; two (9 percent) remained installed with significant 

equipment on site, but were idle during 2018; and the remaining 13 (59 percent) were no longer in 

production, either decommissioned or uninstalled (Parrent et al. 2019). The seven active and two idle 

mills included in the survey are identified in Table 3.2-4, from largest to smallest capacity within the two 

groups.

Estimated total production for the mills included in the annual mill survey fell by more than 50 percent 

from 2000 to 2002, decreasing from 87.1 MMBF to 39.7 MMBF. Production has varied from year-to-year 

since then, but has generally trended downward (Figure 3.2-7). Total estimated production from the 

remaining active saw mills was 15.3 MMBF in 2018, approximately 14 percent of total active and idle 

capacity (Table 3.2-3). The capacity utilization rate of the last operating medium-sized sawmill in 

Southeast Alaska (Viking Lumber) in 2018 was estimated at about 18 percent (Table 3.2-4). By 

comparison, sawmills in Idaho, Oregon, California, and Montana generally utilize more than 80 percent of 

their capacity, unless there is a severe economic downturn (USDA Forest Service 2011a).

Table 3.2-4

Forest Service Mill Survey: Estimated Mill Capacity, Production, and Utilization, 2018

Mill Name1 Location

Estimated 

Capacity (MBF)2

Estimated 

Production (MBF)3

Percent 

Utilization

Viking Lumber Co. Craig 80,000 14,000 18%

Western Gold Cedar Products Thorne Bay 6,500 700 11%

The Mill Petersburg 6,000 2.5 <1%

Icy Straits Lumber & Milling Co.4 Hoonah 3,000 500 17%

Falls Creek Forest Products5 Petersburg 3,000 15 1%

D&L Woodworks Hoonah 1,000 1.5 <1%

Thuja Plicata Lumber Thorne Bay 1,000 31 3%

Total Active Southeast Alaska 100,500 15,250 15%

Thorne Bay Wood Products Thorne Bay 6,250 NA NA

St. Nick Forest Products6 Craig 1,150 NA NA

Total Idle Southeast Alaska 7,400 NA NA

Overall Total7 Southeast Alaska 107,900 15,250 14%

Notes:

MBF = thousand board feet; NA = not applicable

1 Data are presented for those mills included in the Forest Service’s annual on-site survey only. 2 Estimated mill capacity is an estimate of the processing capability of the mill based on the amount of net sawlog volume 

(Scribner log scale) that could be utilized by the mill as currently configured, during a standard 250-day per year, two shifts per 

day, annual operating schedule, not limited by availability of employment, raw materials or market.

3 Estimated Mill Production is the estimated net sawlog volume used during the year to manufacture sawn products. 4 Estimated capacity for the Icy Straits mill was reduced from 21 MMBF as a result of a major mill fire in July 2010. Mill production 

occurred prior to the fire.

5 Formerly Southeast Alaska Wood Products. 6 Formerly W.R. Jones & Son Lumber Co.

7 Totals may not sum due to rounding.

Source: Parrent et al. 2019
Environment and Effects 3

Final EIS 3-41 Key Issue 2

Figure 3.2-7

Estimated Sawmill Production for Surveyed Mills, 2000 to 2018

Note: The annual survey was not conducted during 2001. 

Source: Parrent et al. 2019

The Tongass National Forest supplied about 7.7 MMBF or 50 percent of the total volume (15.3 MMBF) 

processed by the mills identified in Table 3.2-4 in 2018, with State lands responsible for most of the 

remaining volume (Parrent et al. 2019). The Tongass share of timber processed locally (8.4 MMBF) was 

equivalent to about 52 percent of the total (16.0 MMBF) harvested on the Tongass in 2017 (Table 3.2-3). 

Viking Lumber processed 14 MMBF, approximately 92 percent of the total (15.3 MMBF) processed in 

2018 (Table 3.2-4).

Other Mills

As noted above, the annual Forest Service mill survey is not a comprehensive inventory of all sawmills in 

Southeast Alaska. While no new sawmills of sufficient size classification to be added to the annual mill 

survey have been established since 2007, many other smaller sawmills operate across the region, 

including facilities that operate on a seasonal, part-time, or contingent basis. The number of active mills 

and timber operators in Southeast Alaska varies at any given time. A review of business licenses in 

December 2018, for example, identified 22 additional sawmills in Southeast Alaska that are not included 

in the Forest Service survey (Table 3.2-5). The University of Montana’s Bureau of Business and 

Economic Research (BBER), in conjunction with the PNW Inventory and Analysis Program of the Forest 

Service, conducted a census of timber processors in Alaska in 2011 and identified 27 sawmills in 

Southeast Alaska, with almost half this total (12 facilities) located on Prince of Wales Island (Berg et al. 

2014). A point-in-time analysis of business license data in 2012 identified a total of 105 forest products 

businesses including wood products manufacturing businesses (32 percent), timber tract operations (32 

percent), forestry support activities (19 percent), and sawmills (17 percent) (Alaska DCCED 2012). A 

comparable review in December 2018 identified a total of 152 active forest projects business licenses in 

Southeast Alaska communities (Alaska DCCED 2018).

0

10

20

30

40

50

60

70

80

90

MMBF

Year

Estimated Production
Environment and Effects 3

Final EIS 3-42 Key Issue 2

Table 3.2-5

Additional Sawmills in Southeast Alaska Based on a Review of Business 

Licenses, 2018

Mill Name1 Location

Cedar Street Enterprises Port Alexander

Chilkat Valley Sawmill Haines

Crew Lumber Edna Bay

CSL Farm & Services Edna Bay

Cutting Edge Wood Products Ketchikan

D and L Woodworks Hoonah

Dale R. Bakula Construction Ketchikan

Dark Horse Lumber Haines

Fair & Square Milling Coffman Cove

Falls Creek Forest Products Petersburg

Glacier Bay Woodcraft Gustavus

K & D Lumber Thorne Bay

Mud Bay Lumber Company, LLC Haines

Peavey Log Thorne Bay

Pitch Enterprises Thorne Bay

Seakwood.com Petersburg

Spruce Point Mill Petersburg

Tenakee Logging Company Tenakee Springs

Windy Point Sawmill and Bobcat Service Craig

Wood Marine Klawock

The Woodshed Petersburg

Yakutat Supply Yakutat

Note:

1 These businesses were identified through a review of business licenses in December 2018 and include 

businesses listed as sawmills (North American Industrial Classification System [NAICS] Code 321113 –

Sawmills). This table identifies additional sawmills that are not included in the Forest Service’s mill survey 

(see Table 3.2-4), but is not intended to be a comprehensive list of all sawmills in Southeast Alaska.

Source: Alaska DCCED 2018

Volume Under Contract

Volume under contract refers to the volume included in Forest Service timber sales that have been 

purchased, but not yet logged or only partially logged. Volume under contract is, therefore, essentially a 

measure of inventory that changes on a regular basis, increasing as timber is sold and added to the total 

and decreasing when sale volumes are harvested.

Various purchasers had an estimated total of 60.1 MMBF of uncut timber under contract with the Forest 

Service at the end of December 2019 (USDA Forest Service 2019c). Alcan Forest Products LLP/Timber

Inc. had more than half of this total (61 percent; 36.6 MMBF) under contract, followed by Viking Lumber 

with 21 percent (12.6 MMBF), Micheal B. Allen Jr with 9 percent (5.2 MMBF), and Western Gold Cedar 

Products with 3 percent (1.8 MMBF) (Figure 3.2-8). Eighteen other purchasers had a combined total of 

3.9 MMBF in uncut volume under contract, with less than 1 MMBF under contract in each case (USDA 

Forest Service 2019c). Alcan Forest Products, based in Ketchikan, does not operate a processing facility 

in Southeast Alaska, and under the Limited Export Shipment Policy, must sell logs that are not approved 

for export to a processing facility in the state. The GNA Kosciusko Young Growth sale, which makes up 

much of the volume Alcan Forest Products has under contract, about 82 percent, was approved for 100 

percent export. 
Environment and Effects 3

Final EIS 3-43 Key Issue 2

Figure 3.2-8

Volume under Contract by Owner, 2019

Source: USDA Forest Service 2019c

Recreation and Tourism (Visitor Industry)

Recreation and Tourism in Southeast Alaska

Trends in Visitation

As noted above, an estimated 1.2 million people visited Southeast Alaska in 2016, with most of these 

visitors (86 percent) arriving by cruise ship (McDowell Group 2017).

Southeast Alaska Cruise Ship Visitor Volume

From 2000 to 2019, Southeast Alaska’s total cruise passenger volume has averaged approximately 

950,000 each year, with cruise ships visiting during the summer season (May to September). Cruise 

visitation to Southeast Alaska initially peaked with more than 1 million visitors per year from 2007 to 2009 

before decreasing in 2010, as a result of the national economic recession. Volumes have gradually 

increased since then peaking with an all-time high of 1,165,000 cruise visitors in 2018, followed by 

another record year in 2019, with 1,361,400 cruise visitors (Figure 3.2-9). Prior to the coronavirus 

pandemic, the number of cruise passengers visiting Southeast Alaska was forecast to continue to grow 

with an estimated 1,441,000 cruise passengers anticipated for 2020 (Southeast Conference 2019). On 

July 16, 2020 (85 FR 44085) the Center for Disease Control extended its No Sail Order and Suspension 

of Further Embarkation for cruise ships with the capacity to carry 250 or more individuals until one of the 

following occurs:

• The expiration of the Secretary of Health and Human Services’ declaration that COVID-19 

constitutes a public health emergency,

• The CDC Director rescinds or modifies the order based on specific public health or other 

considerations, or

• September 30, 2020.

Alcan Forest 

Products/Timber, 

61%

Viking Lumber 

Company, 21%

Micheal B Allen Jr, 9%

Western Gold Cedar 

Products, 3%

Other (18 Purchasers), 7%
Environment and Effects 3

Final EIS 3-44 Key Issue 2

Figure 3.2-9

Southeast Alaska Cruise Passengers, 2000-2019

Source: Southeast Conference 2019, USDA Forest Service 2016b

Almost all Southeast Alaska cruise passengers, 98 percent of the total, visited Juneau in 2016. A large 

share of total Southeast Alaska cruise passengers also visited Ketchikan (92 percent of the total) and 

Skagway (80 percent) (Table 3.2-6). Hoonah and Sitka each received more than 120,000 cruise visitors 

in 2016 each (159,132 and 122,944, respectively), with Haines and Wrangell visited by 41,685 and 7,926 

cruise passengers, respectively (Table 3.2-6). Trends in cruise visitation in the three communities with the 

largest number of visitors (Juneau, Ketchikan, and Skagway) mirrored regional trends over time, peaking 

in the years prior to the national recession, with visitation decreasing sharply in 2010. From lows in 2010 

and 2011, visitation has gradually increased in all three communities and was similar to pre-recession 

levels by 2016 (Table 3.2-6).

500,000

600,000

700,000

800,000

900,000

1,000,000

1,100,000

1,200,000

1,300,000

1,400,000

Number of Passengers

Year
Environment and Effects 3

Final EIS 3-45 Key Issue 2

Table 3.2-6

Southeast Alaska Cruise Passengers by Community, 2007-2016

Year Haines Hoonah Juneau Ketchikan Sitka Skagway Wrangell

2007 27,659 161,920 1,017,341 901,595 233,936 820,829 5,192

2008 50,121 126,381 1,032,274 941,910 289,753 781,676 4,002

2009 43,550 134,575 1,019,507 936,220 224,335 785,034 3,842

2010 32,259 122,974 879,310 828,929 144,383 697,060 3,869

2011 27,176 127,866 875,947 844,412 129,380 708,981 4,719

2012 31,007 120,786 927,941 894,320 110,714 755,681 678

2013 32,378 124,320 978,559 948,685 99,920 821,874 6,417

2014 29,133 142,416 953,055 884,503 90,182 819,239 5,171

2015 42,515 150,434 976,367 944,525 117,546 815,541 7,471

2016 41,685 159,132 1,004,774 947,972 122,944 817,308 7,926

Source: Alaska DCCED 2017

Small Cruise Market

Alongside the international cruise lines, several small- and mid-size cruise operators are active in the 

region, often taking their customers to smaller places such as Metlakatla and Petersburg in addition to the 

larger communities. Reliable data regarding the small cruise vessel industry is limited, but the Alaska 

Department of Economic Development (ADED) (2016) found that small cruise ships accounted for about 

1.5 percent of Alaska’s cruise passengers in 2015.

Although accounting for a small share of the overall market, this segment of the cruise market is important 

for smaller communities that do not have the infrastructure to accommodate larger vessels. Overall, small 

cruise vessel passenger capacity declined from a high of 22,100 passengers in 2005, but capacity has 

gradually increased since a low of 8,800 estimated passengers in 2011. Capacity remained below 2005 

levels in 2016 (Figure 3.2-10). In 2015, Alaska’s small cruise vessel fleet included 27 vessels (including 

vessels carrying fewer than 20 passengers), with a total of 344 scheduled sailings (ADED 2016).

Figure 3.2-10

Southeast Alaska Small Cruise Vessel Passenger Capacity, 2005-2016

Note:

1 Small cruise vessels are defined for the purposes of data collection as small, overnight commercial passenger vessels 

that carry less than 250 passengers. Estimates exclude vessels with capacity for less than 20 passengers. 2 Data for 2016 was projected. Source: ADED 2016

22,100

21,400 20,800

19,200

14,500

11,500

8,800

12,800

14,200

16,100 16,900 16,700

5,000

7,000

9,000

11,000

13,000

15,000

17,000

19,000

21,000

23,000

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016

Number of Passengers

Year
Environment and Effects 3

Final EIS 3-46 Key Issue 2

Outfitter/Guide Use

A total of 242 authorized outfitter/guides provided services to Forest visitors during 2013 to 2017. More 

than half of these operators (132) uses the Forest consistently (at least four out of the five years). 

Outfitter/guides reported an annual average of 632,000 clients or service days over this period, with a 

total of 641,149 clients or service days reported in 2017. A service day is defined as a day or any part of a 

day for which an outfitter or guide provides service to a client on NFS lands. Figure 3.2-11 shows 

reported outfitter/guide use on the Forest from 2008 to 2017. Outfitter/guide use is discussed in more 

detail in the separate Recreation and Tourism section of this EIS (see below).17

Figure 3.2-11

Tongass National Forest Outfitter/Guide Use, 2008 to 2017

Note:

1 A service day is defined as a day or any part of a day for which an outfitter or guide provides service to a client on 

NFS lands.

Source: USDA Forest Service 2017e, 2018g

Employment and Contribution to the Regional Economy. Recreation and tourism-related employment 

is difficult to accurately quantify because visitors spend their money throughout the local economy. 

Recreation and tourism is not classified or measured as a standard industrial category. Components of 

travel and tourism activities are instead partially captured in other economic sectors, such as retail trade 

(e.g., grocery stores and gift shops), transportation, hotels and other lodging places, and amusement and 

recreation services. Information presented above for the visitor sector is considered generally 

representative of recreation and tourism-related employment in Southeast Alaska (see Table 3.2-1 and 

Figure 3.2-3).

According to the Alaska DOL (Bell 2015), visitor-related jobs in Southeast Alaska are concentrated in 

Juneau, Ketchikan, and Skagway, which together accounted for more than three-quarters of the regional 

total in 2014. Transportation is the largest visitor-related economic sector in Southeast Alaska making up 

about one-third of visitor-related employment, with jobs ranging from whale watching boats, to tour buses, 

to airlines. The highest paying visitor-related occupations are also in the transportation sector, including 

captains and mates of water vessels (Bell 2015).

17 This subsection addresses recreation and tourism in the context of the visitor industry as an economic sector. Recreation and 

tourism activities and potential impacts are addressed more broadly in a separate section in the Other Important Issues part of this 

chapter. See the separate Recreation and Tourism section, below.

400,000

450,000

500,000

550,000

600,000

650,000

2008 2009 2010 2011 2012 2013 2014 2015 2016 2017

Number of Clients/Service Days

Year
Environment and Effects 3

Final EIS 3-47 Key Issue 2

A separate study prepared on behalf of the Alaska DCCED found that the visitor industry supported 

11,925 jobs and $445 million in labor income in Southeast Alaska from October 2016 through September 

2017 based on direct visitor spending of $705 million (McDowell Group 2018a). These estimates are for 

total employment and labor income, meaning that they include workers employed directly by the visitor 

industry (direct jobs and income), as well as jobs and income supported elsewhere in the economy 

(indirect and induced jobs and income).18 A separate estimate of direct employment developed from 

Alaska DOL and U.S. Census data identified a total of 8,004 direct jobs supported by the visitor industry 

in 2018 (Table 3.2-1).

Nature-Based Tourism. A study prepared by the Institute of Social and Economic Research at the 

University of Alaska Anchorage provides insight into the contribution of nature-based tourism to the 

regional economy. This study, which involved field research conducted in the summers of 2005, 2006, 

and 2007, focused on a limited number of communities and sought to provide insight into revenues 

generated, the types of nature-based activities attracting tourists, and the resulting flows of money 

through the economy (Dugan et al. 2009). The findings of the study indicate that nature-based tourism 

generates substantial revenues in the region, with an estimated $277 million generated in annual direct 

business revenues for the companies surveyed in Sitka, Juneau, Chichagof Island, Prince of Wales 

Island, Petersburg, and Wrangell (Dugan et al. 2009).

Dugan et al. (2009) also found that nature-based tourism takes a number of different forms and the ratio 

of cruise ship passengers to independent travelers varies by location. Most nature-based activities that 

originate in Ketchikan, for example, fell into four general categories: flightseeing, marine charters, 

adventure experiences, and general sightseeing. In all cases, the majority of clients participating in these 

activities were cruise ship passengers. Cruise lines contract with other visitor service businesses 

operating in the Ketchikan area to provide these nature-based activities. Nature-based tourism on 

Chichagof Island, on the other hand, included a mix of cruise ship passengers and independent travelers, 

depending on the location and activity involved (Dugan et al. 2009).

Another study, conducted on behalf of ADF&G, estimated that residents and visitors to Southeast Alaska 

spent $363 million hunting and viewing wildlife in 2011, with visitors viewing wildlife accounting for an 

estimated 59 percent of this total (ECONorthwest 2014). Based on these estimated expenditures, the 

study estimated that hunting and wildlife viewing, respectively, supported 390 and 1,390 direct jobs and a 

combined total of $107 million in labor income in Southeast Alaska in 2011, with additional indirect and 

induced jobs and income supported elsewhere in the economy (ECONorthwest 2014).

Recreation on the Tongass National Forest

While it is reasonable to assume that the majority of visitor recreation and tourism activity in the region is 

related to the natural environment, not all of the activity generating this employment can be directly linked 

to the Tongass National Forest. Many visitors experience the Tongass from the deck of a cruise ship 

without directly using the forest for recreation purposes. In addition, while the Tongass includes 

approximately 80 percent of the land area in Southeast Alaska, there are other lands that offer wildland 

recreation opportunities in the region, including 3.3 million acres of National Park Service (NPS) lands, 

and recreation lands managed by the State of Alaska. Further, other popular recreation and tourism 

activities, such as saltwater fishing, sea kayaking, and shopping, do not take place on the Tongass, 

although the forest may provide a backdrop for these activities.

The Alaska Region of the Forest Service (Region 10) has been participating in the Forest Service’s 

National Visitor Use Monitoring (NVUM) program since 2000. Based on the results of the NVUM program 

for 2010 to 2014 and coefficients developed by White and Stynes (2010), the Forest Service (2017f) 

calculated a visitation estimate of 2,874,000 annual visits to the Tongass National Forest. The results of 

earlier surveys indicated that half of Alaska residents surveyed who live in Southeast Alaska reported 

using a boat or plane to access the national forest (White and Stynes 2010). Almost half (49.7 percent) of 

non-resident visits to the Tongass National Forest involved the use of a guide or outfitter at some point, 

with local cruises, wildlife viewing, and flightseeing reported most frequently. Alaska residents in contrast 

18 Economic activity in one sector generates activity in others as firms purchase services and materials as inputs (termed “indirect” 

effects) and employees spend their earnings within the local economy (“induced” effects).
Environment and Effects 3

Final EIS 3-48 Key Issue 2

were found to very rarely use outfitters or guides (White and Stynes 2010). More detailed information on 

recreation use on the Tongass is presented in the separate Recreation and Tourism section of this EIS 

(see below).

Spending profiles were estimated for residents and non-residents visiting the Forest based on data 

compiled during the NVUM surveys. Using coefficients developed by White and Stynes (2010), the Forest 

Service (2017f) estimated that 2,874,000 annual visits generated about $382 million in spending and 

supported 3,947 direct jobs and an additional 1,110 jobs elsewhere in the regional economy. This overall 

estimate is equivalent to about 42 percent of the regional visitor estimate developed for Alaska DCCED in 

2017 (McDowell Group 2018a), and the direct component is about 51 percent of the direct visitor jobs 

estimated by Southeast Conference (2018).

Commercial Fishing and Seafood Processing

In 2018, an estimated 185 million pounds of seafood was harvested in Southeast Alaska with an exvessel value of $247 million, which was significantly below the 10-year average, with poor pink salmon 

and herring returns primarily to blame due to warm sea temperatures between 2013 and 2016 (Southeast 

Conference 2019). Viewed in terms of value, salmon accounted for more than half (55 percent) of the 

total commercial catch in Southeast Alaska in 2018, with the remainder divided among black cod (16 

percent), halibut (13 percent), crab (7 percent), herring (2 percent), and other (8 percent) (Southeast 

Conference 2019). Based on data from 2007 to 2018, a recent study found that wild Pacific salmon 

originating from streams and lakes within the Tongass accounted for a major share of the overall number 

and value of commercially caught Pacific salmon in Southeast Alaska (Johnson et al. 2019). Additional 

detail on commercial harvest is provided in the Fish section, which is part of Key Issue 3 below.

Employment in the seafood harvesting and processing sectors varies from year-to-year, but remains 

relatively stable compared to the fluctuations in the volumes and value of salmon harvested each year. 

Salmon harvesting employed an estimated 864 people in Southeast Alaska in 2018, with an additional 

1,281 people employed harvesting other fish (Alaska DOL 2019b). A further total of 1,300 people were 

employed in fish processing in 2018 for a combined total of 3,445 jobs (Alaska DOL 2019c). Seafood 

harvesting and fish processing employment trends are shown for 2000 to 2013 in the 2016 Forest Plan 

Amendment EIS (USDA Forest Service 2016b, pp. 3-501 to 3-503).

Unlike other basic sectors of Southeast Alaska’s economy, components of the seafood industry are 

spread throughout the region with an important presence in virtually every community. Seafood 

processing workers, for example, were employed in all of the boroughs in 2017, ranging from 15 workers 

in Skagway to 1,024 workers in Sitka (Alaska DOL 2019d).

The seafood processing sector is generally characterized by high seasonality and low resident hire, as 

well as low hourly wages, with a median annual wage of $24,689 in 2013 (Strong 2014). The vast majority 

of workers, 91 percent, worked two or fewer quarters (Strong 2014) suggesting they may earn additional 

income elsewhere in the other half of the year. The industry does, however, have a number of higher paid 

occupations, including ship engineers, captains, mates, boat pilots, and general and operations mangers, 

which accounted for just 1.2 percent total employment, but 6 percent of wages, with a median annual 

wage of $66,720 (Strong 2014). 

Mining and Mineral Development

Mineral exploration and mining have been a part of life in Southeast Alaska for more than a century. 

Estimates developed using Alaska DOL data found that a total of 889 workers were employed in the 

mining sector in Southeast Alaska in 2018 (Table 3.2-1). According to a recent economic impact study 

prepared for Alaska’s mining industry, the Greens Creek and Kensington mines employed 420 workers 

and 387 workers in 2018, respectively, with the Kensington Mine employing an additional 90 contractors 

(McDowell Group 2019). Mining jobs are the highest-paying jobs in the region, with average annual 

wages of $104,650 in 2018 (Southeast Conference 2019). The high wages in this sector reflect the skilled 

nature of the job, as well as the demands of working in remote locations (Abrahamson 2013). The 

region’s two large mines (Greens Creek and Kensington) accounted for the majority of the mining 

employment in Southeast Alaska in 2018 (Southeast Conference 2019).
Environment and Effects 3

Final EIS 3-49 Key Issue 2

Both the Greens Creek and Kensington mines are located in the City and Borough of Juneau, mostly on 

Tongass NFS lands. Greens Creek Mine is a silver, lead, and zinc mine located on Admiralty Island; 

Kensington Mine is a gold mine located on the mainland approximately 45 miles north of Juneau. Alaska 

residents make up about two-thirds of the total labor force at each mine, 66 percent at Greens Creek and 

67 percent at Kensington. Alaska resident employees of both mines live throughout the region. More than 

two-thirds of Greens Creek’s Alaska resident employees live in Juneau. The other third live in other 

Southeast Alaska communities or elsewhere in the region (McDowell Group 2018b).

Two proposed underground mine projects on NFS lands on Prince of Wales Island received approval for 

financial assistance through the Alaska Industrial Development and Export Authority in June 2014 

(Bradner 2014). Alaska Senate Bill 99 authorized $145 million and $125 million in infrastructure and 

construction financing, respectively, for the proposed Bokan Mountain and Niblack projects. The Bokan 

Mountain project is a rare earth mine that would include on-site ore processing facilities. The McDowell 

Group (2013) in a study prepared for the Bokan Mountain project estimated that construction of the 

project would last 2 years and employ an average construction workforce of 200, with peak employment 

potentially reaching 300 workers. Operation would be expected to employ 190 workers with 

approximately $18 million in annual payroll (McDowell Group 2013). The governor of Alaska asked that 

the White House CEQ designate the Bokan Mountain project as a high-priority infrastructure project in 

August 2019 (Southeast Conference 2019). The Niblack project is a proposed underground copper-goldzinc-silver mine. The project owners estimate that the construction and operation phases of the project 

would both employ approximately 200 workers (Niblack Project LLC 2015). No exploration activity was 

reported for either project in 2016 and 2017 (McDowell Group 2018b).

Payments to the State

Prior to 2000, in states with national forests, 25 percent of the returns to the U.S. Treasury from revenue 

producing Forest Service activities such as timber sales, were returned to each state for distribution back 

to counties (or in Alaska, boroughs) having acreage within a national forest. Those payments were called 

the “25 percent fund payments” and were dedicated by law to be used for roads and schools. In October 

2000, the Secure Rural Schools and Community Self Determination Act of 2000 was enacted to stabilize 

federal payments to states in response to declining federal receipts.

The legislation was authorized for implementation for Fiscal Years 2001 through 2007 and allowed 

counties and/or boroughs to choose between 25 percent of current receipts or a full payment amount 

based on the average of the highest three payments made to the state during the 14-year period between 

1986 and 1999. Alaska boroughs and communities have elected to receive a full payment amount rather 

than 25 percent of receipts since enactment of this legislation.

Those annual full payment amounts are primarily dedicated to roads and schools, with provisions for 

special project funding under certain conditions. Under the full payment approach, Forest Service 

payments to the State of Alaska have been based on the high 3-year historic average, rather than linked 

to annual Forest Service revenue.

The Secure Rural Schools Act has been reauthorized since 2008, most recently in March 2018. The 

program was not reauthorized for Fiscal Year 2016, resulting in a substantial decrease in payments. 

Tongass-related secure rural schools payments to Southeast Alaska by borough for 2013 through 2018 

are presented in Table 3.2-7.
Environment and Effects 3

Final EIS 3-50 Key Issue 2

Table 3.2-7

Federal Secure Rural Schools Payments to Southeast Alaska Boroughs, 2013 to 20181

Borough/Area 2013 2014 2015 2016 2017 2018

Haines $131,581 $124,386 $145,551 $30,166 $376,567 $277,344

Juneau $670,595 $637,211 $624,947 $43,275 $555,618 $517,412

Ketchikan Gateway $1,045,870 $1,059,007 $993,053 $91,316 $905,127 $882,032

Petersburg $1,255,586 $1,204,494 $577,743 $41,876 $544,597 $546,414

Sitka $800,509 $752,083 $544,967 $49,389 $567,243 $529,232

Skagway $22,105 $21,595 $17,122 $2,664 $18,625 $19,845

Wrangell $1,117,867 $1,052,610 $922,953 $47,826 $845,691 $986,580

Yakutat $560,798 $539,527 $623,842 $36,682 $473,738 $513,767

Unorganized2 $3,253,421 $3,125,381 $2,674,447 $110,116 $2,476,673 $2,474,268

Total $8,858,332 $8,516,294 $7,124,625 $453,310 $6,763,879 $6,746,894

Note:

1 Payments are in nominal values

2 Unorganized represents payments to the Hoonah-Angoon and Prince of Wales-Hyder CAs. 

Sources: USDA Forest Service 2015a, 2015b, 2016d, 2018g, 2018h, 2019e

Environmental Consequences

Forest Products

This FEIS provides an assessment of the potential impacts that may result from the alternatives 

considered for a proposed Alaska Roadless Rule. This analysis is programmatic, meaning that it examines 

potential effects of alternative forms of management direction for broad land areas, rather than specific 

activities scheduled for specific locations. Specific timber sales would be developed over time in accordance 

with established Forest Service procedures, with site-specific impacts evaluated through project-level 

environmental analysis, as appropriate. Overall timber harvest levels and general composition (old-growth 

versus young-growth) are expected to remain unaffected by the final rule. Timber program output levels 

are expected to remain constant and involve a similar number of acres under all alternatives, varying only 

by the location of timber harvest.

Factors Affecting the Economics of Timber Offers

In practice, many factors can influence the cost of timber harvest, adding economic risks for potential 

purchasers and affecting the ability of the Forest Service to offer timber sales. Road construction, 

helicopter yarding, complex silvicultural prescriptions, setting size, and other factors may increase costs, 

which then decrease the value of the offering. The value of the timber offered must be sufficient to cover 

costs and include profit for the purchaser. Under the Further Consolidated Appropriations Act, 2020, 

timber sales that do not appraise positive using the current Region 10 RV (Residual Value) appraisal 

cannot be offered (USDA Forest Service 2018d). Estimated costs per thousand board feet vary 

substantially across the Forest. Transportation infrastructure costs and haul distances are typically higher 

in more remote areas, i.e., those areas that are further from existing infrastructure and markets. In this 

context, a market may include a mill or export yard.

None of the action alternatives would result in changes to the PTSQ, and the timber objectives of the 

Forest Plan would continue to involve the transition to primarily young-growth harvest. While harvest 

levels are not expected to vary significantly among the alternatives, the alternatives do vary in terms of 

the amount and location of acres suitable for timber production. Young-growth suitable acres would 

increase only slightly (3 to 6 percent) under the action alternatives (Table 3.2-8) and, as a result, the 

following assessment focuses on changes in old-growth suitable acres. Summary information is, however, 

also provided for changes in young-growth suitable acres by alternative.

The Record of Decision for the 2016 Forest Plan estimated that a total of approximately 24,000 oldgrowth acres would be harvested Forest-wide after 25 years, with a total of 42,500 old-growth acres 

harvested after 100 years (USDA Forest Service 2016c). These estimates represent an approximate 
Environment and Effects 3

Final EIS 3-51 Key Issue 2

upper ceiling of the number of roadless acres that could be potentially harvested under any of the 

alternatives. The 2016 Forest Plan Amendment EIS estimated that approximately 5 MMBF of small and 

micro-sales of old-growth timber is required each year to meet the needs of existing small old-growth mills 

that produce high value products such as appearance grade lumber and cedar shingles. This annual 

small and micro-sale demand (5 MMBF) is anticipated to be met for the duration of the planning period 

under all of the alternatives, including Alternative 1 – No Action.

For larger sales, more acres of suitable old-growth land would allow the Forest Service greater flexibility 

in the selection of future timber sale areas, as well as the potential for more flexibility in sale design, 

depending on the project areas selected. This improved flexibility could, in turn, potentially improve the 

Forest Service’s ability to offer economic sales that meet the needs of industry. This greater flexibility 

could be especially beneficial during the first two decades of the 2016 Forest Plan (the transition period), 

when most old-growth harvest would take place. While many factors can influence the cost of timber 

harvest, as noted above, areas along existing roads are typically more economically efficient, followed by 

areas where existing roads can be easily extended. Transportation infrastructure costs can include road 

construction, reconditioning, reconstruction, and maintenance, as well as log transfer facility (LTF) 

development. Road construction, reconditioning, reconstruction, and maintenance involve substantial 

costs and have the potential to strongly influence timber sale economics.

Areas closer to markets, either a mill or export facility, are also more likely to offer more economic timber 

sale options. Existing old-growth mills in Southeast Alaska are primarily located in the south part of the 

region, with a concentration of mills, including the last remaining medium-sized mill (Viking Lumber), on 

Prince of Wales Island. Sales on the south part of the Forest are, therefore, more likely to appraise 

positive. In cases where the Regional Forester allows 100 percent export, which is permissible on a caseby-case basis (as discussed above), proximity to an export facility may also result in sales being more 

likely to appraise positive.

Areas not covered by existing NEPA decisions require additional NEPA analysis, adding cost, as well as 

several years planning time. The projects identified in the most recent 5-year timber sale plan for the 

Tongass (2019 to 2023) are assumed to be made available to meet short-term (4- to 5-year) demand 

under all alternatives (USDA Forest Service 2019b).

Factors Common to the Action Alternatives

Additional timber harvest opportunities under the action alternatives would primarily be provided by 

removing regulatory roadless prohibitions for areas that are currently designated under the 2001 

Roadless Rule (i.e., the removal of acres from roadless in the transition from 2001 Inventoried Roadless 

Areas [IRAs] to Alaska Roadless Areas [ARAs]).19 Timber harvest would also be allowed in Timber 

Priority and Community Priority ARAs.20 With the removal of prohibitions for either of these priorities

areas of previously identified unsuitable lands would revert to suitable lands that would be available for 

harvest.

Suitable old-growth lands would be incrementally added by alternative, with total net increases ranging 

from about 20,000 acres (Alternative 2) to 168,000 acres (Alternatives 5 and 6) (Table 3.2-8, Figure 3.2-

12). Viewed as a share of existing suitable old growth, these increases would range from 9 percent 

(Alternative 2) to 74 percent (Alternatives 5 and 6). Suitable old-growth acres would be added in three 

broad categories or areas: roaded roadless (Alternatives 2 to 6); logical extension areas (Alternatives 3 to 

6); and areas more distant from roads (Alternatives 4 to 6). In addition, suitable old-growth acres would 

be added in Community Priority ARAs (Alternative 3). For the locations of suitable areas, refer to the 

Timber Suitability maps (see Maps 7 through 12 on thumb drive or website).

19 Alternative 6 would remove all regulatory roadless prohibitions on the Tongass, which would be exempt from the 2001 Roadless 

Rule under this alternative.

20 Timber harvest in Community Priority ARAs would be limited to micro sales, salvage sales, and small commercial sales less than 1 

MMBF in size.
Environment and Effects 3

Final EIS 3-52 Key Issue 2

Roaded Roadless. All action alternatives would remove roadless designations for 142,000 acres that 

currently have roads (i.e., “roaded roadless”). These areas are considered likely locations for future timber 

harvest. The removal of roaded roadless acres from roadless designation would revert about 20,000 

acres of previously identified unsuitable lands to suitable old-growth lands that would be available for 

harvest, including an estimated 7,000 acres of high-volume old growth (Table 3.2-8). High volume oldgrowth acres are based on the size-density model (SDM), as described in the Timber Resources section, 

below. In addition, an estimated 11,000 acres of previously unsuitable lands would revert to suitable 

young-growth lands that would be available for harvest.

Logical Extensions. Alternatives 3 to 6 would also remove roadless designations for “logical extension 

areas.” These are areas that are considered the logical extension of existing road and harvest systems, 

and typically include areas within the same watershed (7th field or 14-digit hydrologic unit) as an existing 

road system. These areas were identified by forest staff as the most likely locations for future timber 

harvest, following roaded roadless. The removal of logical extension acres from roadless designation 

would revert an estimated 49,000 acres of previously identified unsuitable lands to suitable old-growth 

lands, including an estimated 19,000 acres of high-volume old growth (Table 3.2-8). In addition, an 

estimated 2,000 acres of previously unsuitable lands would be revert to suitable young-growth lands.

More Distant Areas. Alternatives 4 to 6 would also remove roadless areas considered more distant from 

existing road systems (i.e., roadless areas outside the “roaded roadless” and “logical extension” areas). 

These acres are added in different ways, as discussed below, by alternative. However, when viewed in 

terms of changes in suitable old-growth acres that would be available for harvest, the alternatives are 

very similar. This is especially true for Alternatives 5 and 6, which would result in the same increase in 

areas more distant from roads, about 99,000 acres, including 33,000 acres of high-volume old growth 

(Table 3.2-8). Changes in suitable young-growth acres in areas more distant from roads would range 

from approximately 3,000 acres (Alternative 4) to 8,000 acres (Alternative 6). 

In addition, 16,000 suitable old-growth acres, including 4,000 acres of high-volume old growth, and 2,000 

suitable young-growth acres would be added in Community Priority ARAs (Alternative 3) (Table 3.2-8).

Table 3.2-8

Suitable and High Volume Suitable Old-Growth Acres by Geographic Area and 

Alternative

Forest Land Suitable for 

Timber Production

Alternative

1 2 3 4 5 6

No 

Action

Roaded 

Roadless

Logical 

Extension

Partial Dev 

LUDs1

All Dev 

LUDs

Full 

Exemption

Old Growth 227,000 247,000 312,000 388,000 395,000 395,000

Young Growth 334,000 345,000 349,000 349,000 351,000 354,000

Increase in Suitable Old Growth

In Roaded Roadless Areas 0 20,000 20,000 20,000 20,000 20,000

In Logical Extension Areas 0 0 49,000 49,000 49,000 49,000

In Community Priority Areas 0 0 16,000 0 0 0

In More Distant Areas 0 0 0 92,000 99,000 99,000

Total2 0 20,000 85,000 161,000 168,000 168,000

Increase in High-Volume Suitable Old Growth

In Roaded Roadless Areas 0 7,000 7,000 7,000 7,000 7,000

In Logical Extension Areas 0 0 19,000 19,000 19,000 19,000

In Community Priority Areas 0 0 4,000 0 0 0

In More Distant Areas 0 0 0 30,000 33,000 33,000

Total2 0 7,000 28,000 56,000 59,000 59,000

1 Includes Timber Production and Modified Landscape LUDs, but not Scenic Viewshed. 2 Totals may not sum due to rounding.
Environment and Effects 3

Final EIS 3-53 Key Issue 2

Figure 3.2-12

Suitable Old-Growth Acres by Alternative

Note:

1 Harvest levels for 25 years and 100 years represent the total estimated old-growth acres that would be harvested to 

meet the PTSQ established for the 2016 Forest Plan.

Alternative 1 – No Action

Under Alternative 1 there would be no change in the boundaries of the IRAs identified in 2001 Roadless 

Rule and no changes in the availability of suitable old-growth acres for harvest. Under the current Forest 

Plan, there are an estimated 227,000 acres of suitable old growth available for harvest, almost 10 times 

the area expected to be harvested over the next 25 years (Table 3.2-8, Figure 3.2-12).

Alternative 2

Under Alternative 2, additional timber harvest opportunities would be provided in roaded roadless areas, 

with an estimated net gain of about 20,000 acres of suitable old-growth, including 7,000 acres of highvolume suitable old-growth (Table 3.2-8, Figure 3.2-12). This estimated gain (20,000 acres) is equivalent 

to about 9 percent of the acres available under Alternative 1 and 83 percent of old-growth acres expected 

to be harvested over the next 25 years (24,000 acres). The added suitable acres would be in areas where 

roads already exist and are, therefore, generally considered relatively economic to harvest. Further, the 

majority of the added acres would be located on the south part of the Forest, with more than one-third (38 

percent) on Prince of Wales Island (Craig and Thorne Bay Ranger Districts) (Table 3.2-9). 

Alternative 2 would also result in an estimated net gain of about 11,000 acres of suitable young-growth, 

the majority of which (87 percent) would be located on the south part of the Forest. These acres would 

also be in areas where roads already exist.

0

50,000

100,000

150,000

200,000

250,000

300,000

350,000

400,000

Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

Suitable Old-Growth (acres)

Existing Forest Plan Roaded Roadless Logical Extensions

Community Priority Areas More Distant 25 Years Harvest

100 Years Harvest
Environment and Effects 3

Final EIS 3-54 Key Issue 2

Table 3.2-9

Increase in Suitable Old-Growth Acres by Ranger District and Alternative

Ranger District Alternative

2 3 4 5 6

South

Craig 4,300 9,900 14,800 15,800 15,800

Ketchikan Misty Fjords 3,700 15,700 23,800 24,900 24,900

Petersburg 4,800 24,200 36,900 37,600 37,600

Thorne Bay 3,100 14,400 20,400 21,300 21,300

Wrangell 3,900 14,500 22,900 24,100 24,100

Subtotal1 19,800 78,700 118,800 123,700 123,700

North

Hoonah 500 3,700 15,900 16,100 16,100

Juneau 300 300 3,600 4,600 4,600

Sitka2 -1,200 1,900 22,300 23,400 23,400

Yakutat 0 0 0 0 0

Subtotal1 -400 5,900 41,800 44,100 44,100

Overall Total1 19,400 84,600 160,600 167,800 167,800

Note:

1 Totals may not sum due to rounding.

2 Alternative 2 provides limited additional timber harvest opportunity while maximizing roadless area designations by adding 

110,000 acres as ARAs. In the Sitka Ranger District, more suitable old growth acres would be removed than added under this 

alternative.

Alternative 3

Under Alternative 3, additional timber harvest opportunities would be provided in roaded roadless and 

logical extension areas, with an estimated net gain of about 85,000 acres of suitable old-growth, including 

28,000 acres of high volume suitable old-growth (Table 3.2-8, Figure 3.2-12). This estimated gain (85,000 

acres) is equivalent to about 37 percent of the acres available under Alternative 1 and more than three 

and a half times the old-growth acres expected to be harvested over the next 25 years (24,000 acres). 

The added suitable acres would be in areas where roads already exist or could be logically extended and 

are, therefore, generally considered relatively economic to harvest. Alternative 3 also includes a net 

increase of approximately 16,000 acres in Community Priority ARAs. Similar to Alternative 2, the majority 

(93 percent) of the added acres would be located on the south part of the Forest, with almost one-third 

(29 percent) on Prince of Wales Island (Table 3.2-9).

Alternative 3 would also result in an estimated net gain of about 15,000 acres of suitable young-growth, 

the majority of which (76 percent) would be located on the south part of the Forest. These acres would 

also be in areas where roads already exist or could be logically extended.

Alternative 4

Alternative 4 would provide additional timber harvest opportunities in roaded roadless and logical 

extension areas, as well as areas more distant from roads, with an estimated net gain of about 161,000 

acres of suitable old growth, including 56,000 acres of high-volume suitable old growth (Table 3.2-8, 

Figure 3.2-12). This estimated gain (161,000 acres) is equivalent to about 71 percent of the acres 

available under Alternative 1 and almost seven times the old-growth acres expected to be harvested over 

the next 25 years (24,000 acres). Although the increase in the high-volume suitable old growth relative to 

Alternative 1 is not expected to change as to either the number of acres harvested or the volume of 

timber harvested, it would allow increased flexibility in where harvest could occur.

This alternative makes available all Timber Production and Modified Landscape LUDs that were in 

roadless, outside of T77 Watersheds and TNC/Audubon Conservation Priority Areas. On average, these 

areas are more distant from roads compared with Alternative 3 and would include extensive areas 

designated as Timber Priority ARA. Approximately 92,000 acres of the previously identified unsuitable 
Environment and Effects 3

Final EIS 3-55 Key Issue 2

lands that would revert to suitable old-growth lands are located in more distant areas. Because these 

areas are more distant from existing road systems, on average, they are likely to be relatively expensive 

to harvest and less likely to be accessed for timber production under the current Forest Plan. Almost 

three-quarters (74 percent) of the acres added under this alternative would be located on the south part of 

the Forest, with 22 percent on Prince of Wales Island (Table 3.2-9).

Alternative 4 would also result in an estimated net gain of about 15,000 acres of suitable young-growth, 

including 3,000 acres more distant from roads. The majority of the total added young-growth suitable 

acres (77 percent) would be located on the south part of the Forest. 

Alternative 5

Alternative 5 would provide additional timber harvest opportunities in roaded roadless and logical 

extension areas, as well as areas more distant from roads (Table 3.2-8, Figure 3.2-12). In addition to 

roaded roadless and logical extension areas, this alternative would remove all Timber Production, 

Modified Landscape, and Scenic Viewshed LUDs identified in the 2016 Forest Plan from roadless 

designation, along with T77 Watersheds and TNC/Audubon Conservation Priority Areas within those 

development LUDs. In addition, areas with mineral potential as defined by the “minerals overlay” defined 

in the Tongass Forest Plan would be removed from roadless designation. Viewed in terms of suitable oldgrowth acres, this alternative would have the same effect as removing regulatory roadless designation 

from all lands (Alternative 6).

Alternative 5 would also result in an estimated net gain of about 17,000 acres of suitable young-growth, 

including 5,000 acres more distant from roads. Because these areas are more distant from existing road 

systems, on average, they are likely to be relatively expensive to harvest and less likely to be accessed 

for timber production under the current Forest Plan. The majority of the total added young-growth suitable 

acres (78 percent) would be located on the south part of the Forest. 

Alternative 6

Under Alternative 6, the full exemption alternative, regulatory roadless designations would be removed 

from all inventoried roadless areas on the Tongass, resulting in a net reduction of 9.34 million acres of 

designated roadless (Table 3.2-8, Figure 3.2-12). Former inventoried roadless areas would be managed 

in accordance with the 2016 Forest Plan, with an estimated net gain of about 168,000 acres of suitable 

old growth, including 59,000 acres of high-volume suitable old growth (Table 3.2-8, Figure 3.2-12). This 

estimated gain (168,000 acres) is equivalent to about 74 percent of the acres available under Alternative 

1 and seven times the old-growth acres expected to be harvested over the next 25 years (24,000 acres). 

As with Alternative 4, much of the gain in suitable old-growth acres relative to Alternative 3 would be in 

areas more distant from roads (approximately 99,000 acres) and would provide additional opportunities 

for harvest. These more distant areas would be relatively expensive to harvest and less likely to be 

accessed under the current Forest Plan. Almost three-quarters (74 percent) of the acres added under this 

alternative would be located on the south part of the Forest, with 22 percent on Prince of Wales Island 

(Table 3.2-9).

Alternative 6 would also result in an estimated net gain of about 20,000 acres of suitable young-growth, 

including 8,000 acres more distant from roads. Because these areas are more distant from existing road 

systems, on average, they are likely to be relatively expensive to harvest and less likely to be accessed 

for timber production under the current Forest Plan. The majority of the total added young-growth suitable 

acres (71 percent) would be located on the south part of the Forest. 

Employment and Income

Timber program output levels are expected to remain constant and involve a similar number of acres 

under all alternatives, varying only by the location of timber harvest. The proportion of cutting activity 

occurring within versus outside of roadless areas would vary by alternative, but overall regional economic 

impacts are assumed to remain constant. These impacts were estimated for the first decade following 

implementation in the 2016 Forest Plan Amendment EIS (USDA Forest Service 2016b), with all six 

alternatives based on an annual average harvest of 46 MMBF. In the 2016 Forest Plan Amendment EIS, 
Environment and Effects 3

Final EIS 3-56 Key Issue 2

the ratio of young growth to old growth varied by alternative and over time in the years prior to the 

transition to young growth (defined as the time that the young-growth supply reaches 41 MMBF).

Alternative 1 within this FEIS and all alternatives are assumed to support a similar range of direct jobs and 

income. Based on the 2016 Forest Plan Amendment EIS assessment, all of the alternatives would support an 

estimated 92 jobs in logging, 49 to 100 jobs in sawmilling, and 29 to 46 jobs related to transportation and other 

services, with direct income ranging from $9.8 million to $10.4 million. 

The local sawmilling and transportation-related employment estimates presented in the 2016 Forest Plan 

Amendment EIS were based on a range, from maximum possible shipment out of state (export of all 

Alaska yellow-cedar and western redcedar plus hemlock and Sitka spruce export equal to 50 percent of 

total sale net sawlog volume), to no shipment of western redcedar, hemlock, or Sitka spruce, and export 

of 100 percent Alaska yellow cedar. Transportation and other services include water transportation, 

independent trucking, stevedoring (e.g., process of loading/offloading of a ship or cargo), scaling, and 

export marking and sort yard employment for export volume, and water transportation, scaling, and 

independent trucking for locally sawn volume. Export employs more workers in transportation and other 

services per million board feet harvested than domestic production, which is reflected in the range of 

values estimated for transportation and related services.

Actual employment and income in Southeast Alaska would depend on choices made by purchasers that 

exist outside the context of roadless restrictions; those choices may change as markets and prices shift. 

Under current market conditions, purchasers are likely to export as much as they can while processing 

enough material locally to keep manufacturing facilities open and take advantage of opportunities to 

produce high-value sawn material in Southeast Alaska. In addition, the Regional Forester has allowed 

increased export on a case-by-case basis, as discussed above and explained in Appendix H of the 2016 

Forest Plan (USDA Forest Service 2016a). If purchasers were allowed on a case-by-case basis to export 

a larger share of a particular sale in unprocessed form, there would be a commensurate reduction in 

sawmilling jobs and an increase in transportation-related jobs.

Recreation and Tourism (Visitor Industry)

Potential impacts to recreation and tourism are assessed in the separate Recreation and Tourism section 

of this EIS (see below). Potential impacts are evaluated with respect to ROS settings, recreation places, 

and recreation use. The Recreation and Tourism section also assesses impacts to outfitter/guide 

businesses and clients.

Under Alternative 1, most projected harvest is expected to occur in ROS settings where some 

modification of the natural environment is expected. Less than 1 percent of the acres currently allocated 

to Primitive (P), Semi-Primitive Non-Motorized (SPNM), and Semi-Primitive Motorized (SPM) ROS 

settings would be harvested after 100 years, assuming the maximum allowable levels of harvest were to 

occur. Assuming that the estimated total number of acres harvested would be the same for each 

alternative, harvest projections by alternative indicate that Roaded Modified (RM) as a share of the 

estimated total would decrease relative to Alternative 1 under all alternatives, decreasing from 91 percent 

under Alternative 1 to 72 percent under Alternatives 4 to 6. Much of this decrease would be made up by 

an increase in SPNM acres. SPNM as a share of the estimated total would range from about 4 to 5 

percent under Alternatives 1 and 2 to 18 percent under Alternatives 4 to 6. This analysis is discussed 

further in the Recreation and Tourism section of this EIS.

Changes in land management have the potential to affect outfitter/guide operations that provide 

commercial recreation opportunities on the Forest. Impacts to existing outfitter/guide use are likely to be 

greatest where changes in roadless designations allow development in remote areas that are used for 

outfitter/guide activities dependent on high scenic integrity and undisturbed landscapes. Changes in 

roadless area designations could also affect outfitter/guide use in other adjacent or nearby areas as 

outfitter/guides displaced from one location seek other places to take clients. Some use areas are 

presently at capacity, which could serve to exacerbate potential displacement effects. Long-term changes 

in roadless area management could affect the Forest’s ability to meet future outfitter/guide demand, 

especially for operators seeking more remote areas.
Environment and Effects 3

Final EIS 3-57 Key Issue 2

The outfitter/guide analysis prepared for this EIS used changes in suitable old-growth acres in conjunction 

with information on existing outfitter/guide use to help focus on potentially affected areas. The resulting 

analysis identified 15 outfitter/guide use areas where potential conflicts between existing outfitter/guide 

use and future management could occur. In most of these areas, existing outfitter/guide use occurs near 

areas where management activities have occurred in the past, either near or along shorelines and/or 

Forest road systems. Similarly, in most cases, harvest that could already occur in these areas (under 

Alternative 1) has the potential to conflict with existing outfitter/guide use. Viewed in terms of increases in 

acres suitable for timber production, impacts under Alternatives 2 and 3 would be minimal in all areas, 

with increases in roadless acres and reductions in suitable acres occurring in some areas under these 

alternatives. By expanding the acres available for harvest, Alternatives 4 to 6 could add to these potential 

impacts by increasing the number and geographic extent of the acres affected. The analysis also 

considered the projected distribution of old-growth and young-growth harvest acres over 100 years of 

implementation. Old-growth harvest is not expected to occur in 8 of the 15 outfitter/guide use areas 

considered, specifically those located on the north part of the Forest where old-growth harvest has 

historically accounted for less than 5 percent of the total Forest-wide harvest. Allowing road construction 

could create new opportunities for operators who use Forest roads for access. However, nearly all new 

roads constructed would be closed following harvest. These potential impacts are discussed in more 

detail in the Recreation and Tourism section.

Salmon Harvesting and Processing

None of the alternatives are expected to have a significant change to the commercial fishing or fishprocessing industries over the planning period. Riparian Management standards and guidelines 

established in the 2016 Forest Plan would remain in place under all of the alternatives. While there would 

be some variation in the level of protection, these variations are not expected to affect the fishing industry. 

The future of the fishing industry in Southeast Alaska is more likely to depend upon occurrences outside 

of the Tongass National Forest such as hatchery production, offshore harvest levels, and changes in 

ocean conditions (USDA Forest Service 2016b).

The 1997 FEIS (USDA Forest Service 1997a) noted that the amount of acreage of timber harvest was at 

most less than 20,000 acres per year, representing approximately 0.5 percent of the total remaining 

productive old growth (or 5 percent over the next decade) and less than 0.02 percent of the entire Forest. 

That EIS concluded that this was not expected to result in a significant change to commercial fishing 

employment. All of the alternatives that are presently being evaluated in this EIS would allow considerably 

less timber harvest and new road construction than the alternatives evaluated in the 1997 FEIS. Total 

annual old-growth harvest allowed over the 100-year planning period would be approximately 42,500 

acres, substantially lower than the maximum proposed in the 1997 FEIS. Impacts to fish are discussed in 

detail in the Key Issue 3 section of this EIS. 

Mining and Mineral Development

The Forest Service divides minerals resources into three groups: locatable minerals, leasable minerals, 

and salable minerals. Locatable minerals are those minerals that may be located and removed from 

Federal lands under the authority of the General Mining Law of 1872, as amended. Examples of locatable 

minerals on the Tongass include gold, silver, copper, molybdenum, iron, nickel, lead, and zinc. The 

General Mining Law of 1872, as amended, grants every United States citizen the right to prospect and 

explore public domain lands open to mineral entry. The right of reasonable access is guaranteed and is 

not at the discretion of the Forest Service. Exploration, mining, and mineral processing activities, 

including road construction and reconstruction, are presently allowed to the extent provided by statute in 

IRAs and would continue to be allowed under all alternatives. Changes in roadless management are, 

therefore, not expected to affect existing or future locatable mineral exploration or mining activities on the 

Forest.

Leasable minerals are certain types of minerals, primarily energy resources (e.g., oil, gas, coal, and 

geothermal resources) that are not subject to mining claim location but are available for exploration and 

development under provisions of the Mineral Leasing Act of 1920 and other mineral leasing laws.

Roadbuilding is currently prohibited for any new leasable projects, including geothermal projects, within 
Environment and Effects 3

Final EIS 3-58 Key Issue 2

IRAs. For Alternatives 2, 3, 4, and 5, this prohibition would continue in Watershed Priority (Alternative 2), 

Roadless Priority, and LUD II Priority ARAs. Following project-specific analyses, roads could be approved 

for leasable projects within Timber Priority (Alternative 4) ARAs. Geothermal energy projects could be 

allowed in Roadless Priority and Community Priority ARAs under exceptions provided for community 

utility systems. The Tongass has three current geothermal leases; however, no development has 

occurred, and the probability of development is low. No other current leases exist. The anticipated 

demand for leasable minerals is expected to remain low. As a result, changes in roadless management 

are expected to have limited impacts on related economic activity.

Salable minerals on the Forest are mainly used to construct NFS roads. Since road construction is not 

expected to vary much between alternatives, there would be little difference in salable mineral 

development between the alternatives.

Infrastructure Development

With some exceptions, Federal and state road development is presently limitedin IRAs. Exceptions 

include roads with reserved or outstanding rights, roads provided for by statute or treaty, or road 

development related to a Federal Aid Highway. Roadless designation would be removed to various 

degrees under the action alternatives with corresponding implications for regional highway development. 

In most cases, changes in roadless management, as well as changes in the number of acres managed as 

roadless, would be more permissive with respect to regional road systems. In addition to those roads 

presently excepted, Roadless Priority ARAs would also allow roads needed for the connection of 

communities and development of the regional transportation system as identified in the State of Alaska’s 

Southeast Alaska Transportation Plan. Timber Priority ARAs and areas removed from roadless 

designation would not have roadless rule-related prohibitions on road building. More areas would be 

available for additional types of regional road development under Alternatives 4 to 6. Future road projects 

would be subject to funding constraints and evaluated in detail on a project-by-project basis. Potential 

transportation effects are discussed in more detail in the Transportation, Energy, Communications, and 

Infrastructure section of this EIS.

None of the alternatives are expected to substantially affect the development of energy projects or related 

infrastructure. Removing roadless designations in areas under Alternatives 2 through 6 would simplify the 

process for projects but would not necessarily result in an increase in the number of projects developed. 

In areas where new roadless areas are added or expanded, the permitting process could be more 

complex, but projects would not be prohibited. An exception for utility systems in Roadless Priority ARAs 

under Alternatives 2, 3, 4, and 5 and Community Priority ARAs (Alternative 3) would allow for timber 

harvest and road construction. Under Alternative 4, Roadless Areas with timber priority would not prohibit 

timber harvest or road construction at all. Where restrictions are removed, or exceptions added, the 

greatest effect may be in making the permitting process for developers less burdensome, resulting in a 

more efficient permitting process rather than an increase in the number of sites developed.

Tree Harvest for Alaska Native Cultural Purposes

Timber cutting, sale, or removal is prohibited in IRAs (Alternative 1), with some exceptions if the Regional 

Forester or designated Forest Officer determines that one of a limited number of circumstances exists (as 

specified in 66 FR 3244 § 294.13). These circumstances include the provision of trees, portions of trees, 

or forest products to Indian tribes free of charge for traditional and cultural purposes (36 CFR part 223.15; 

FSH 2409.18, chapter 80, section 82.5). However, roads may not be constructed or reconstructed in IRAs 

and, while there are some exceptions, they do not include access for timber cutting, sale, or removal (66 

FR 3244 § 294.12). 

Alternatives 2, 3, 4, and 5 provide for a variety of management approaches within roadless areas through 

ARA land management designations, which include LUD II Priority, Watershed Priority, Roadless Priority, 

Community Priority, and Timber Priority. In areas where roadless designation is removed, there would be 

no roadless-related limitations and only Forest Plan-defined limitations would exist (in addition to other 

existing statutory requirements). The timber cutting, sale, or removal exception for the provision of trees 
Environment and Effects 3

Final EIS 3-59 Key Issue 2

to Indian tribes for traditional and cultural purposes would remain in place under all ARAs, as well as 

under Alternative 6.

As with IRAs, roads may not be constructed or reconstructed in an ARA, with some exceptions which vary 

by type of ARA. Exceptions related to access for Indian tribes for tree harvest for traditional and cultural 

purposes may be summarized by ARA as follows:

The Roadless Priority and Community Priority ARAs include specific exceptions for roads “to provide 

access to Alaska Native cultural site(s) if requested by an affected federally-recognized tribe(s).” 

LUD II Priority and Watershed Priority ARAs do not provide the above exception or other timberrelated exceptions to the restriction on road construction and reconstruction. 

The Timber Priority ARA allows road construction for timber harvest and other uses, with no specific 

exception required for access to Alaska Native cultural sites. Road construction in the Timber Priority 

ARA would be managed in accordance with the Forest Plan.

Alternatives 2, 3, and 4 would remove roadless designations on a portion of current roadless lands. 

Alternative 5 would remove the roadless designation from all development LUDs in all current roadless 

areas, thereby allowing the maximum level of road construction for timber harvest and related uses. 

Alternative 6 would remove regulatory roadless designation from all designated roadless areas on the 

Tongass and would allow the maximum level of road construction for timber harvest and all other uses. 

As with the Timber Priority ARA, no specific exception would be required for access to Alaska Native 

cultural sites or trees important for cultural purposes, and areas removed from roadless protection would 

be managed under the Forest Plan. 

Management designations (including removal of regulatory roadless designation) that would allow road 

access to Alaska Native cultural sites are summarized by alternative in Table 3.2-10. Management 

designations are divided into two categories: 1) the Roadless Priority and Community Priority ARAs, which 

each provide a specific exception for access to Alaska Native cultural sites; and 2) the Timber Priority

ARA and full exemption, which both allow roads, with no specific exception required for Alaska Native 

cultural sites. Management under the Roadless Priority and Community Priority ARAs is generally assumed 

to be more beneficial in this context than management under the Timber Priority ARA or full exemption 

because it potentially allows access for Alaska Native cultural purposes without also allowing access for 

commercial timber harvest and other competing uses. Under the Timber Priority ARA and full exemption, 

timber harvest and other development activities would be managed in accordance with the Forest Plan, 

with old-growth harvest limited to areas in development LUDs. 

With the above assumptions in mind, the alternatives can be ranked for access and competition. For 

access, Alternatives 5 and 6 would rank highest, but Alternative 4 would be close behind. Alternatives 2, 

3, and 1 would rank lowest, in that order. For competition, the best alternative would be Alternative 1, 

followed closely by Alternative 2, and then 3, 4, 5, and 6, in that order. Access for cultural purposes has 

benefits but may increase competition with the timber industry for trees to be used for traditional or 

cultural purposes, and competition is the greater concern from the Tribes. As noted above, the type of 

access created by the Roadless Priority and Community Priority ARAs is preferable to the access created 

by the Timber Priority ARA or full exemption. 

Based on this rationale, Alternatives 2 and 1 would appear to be best overall, because of the relatively 

low level of competition with commercial timber harvest they would create. Alternative 2 would rank higher 

than Alternative 1 because they are almost the same in terms of competition and Alternative 2 includes 

over 5 million acres of Roadless Priority, which would improve access relative to the 2001 Roadless Rule. 

Alternatives 4 and 3 would rank in the middle overall. Alternative 4 would rank higher than Alternative 3 

because they are very similar in terms of acres opened up for competition, but Alternative 4 includes over 

7 million acres of Roadless Priority while Alternative 3 includes less than 5 million acres in Roadless and 

Community Priority ARAs, combined. Alternatives 5 and 6 would allow road construction for access to 

Alaska Native cultural sites, but would also allow the most access for commercial timber harvest and 

other competing uses, which could outweigh the benefits. Potential conflicts between competing uses 

under Alternatives 5 and 6 would primarily be limited to areas managed as development LUDs. 
Environment and Effects 3

Final EIS 3-60 Key Issue 2

Table 3.2-10

Access to Alaska Native Cultural Sites by Management Designation and Alternative 

Management Designation

Alternative

1 2 3 4 5 6

Alaska Native Cultural Exceptions1

Roadless Priority ARA 0 5,199,000 4,595,000 7,363,000 6,200,000 0

Community Priority ARA 0 0 370,000 0 0 0

Subtotal 0 5,199,000 4,965,000 7,363,000 6,200,000 0

Removal of Roadless Requirements2

Timber Priority ARA 0 0 0 757,000 0 0

Full Exemption (net change) 0 32,000 1,144,000 394,000 2,321,000 9,368,000

Subtotal 0 32,000 1,144,000 1,151,000 2,321,000 9,368,000

No Change in Access3

LUD II Priority 0 854,000 0 854,000 847,000 0

Watershed Priority 0 3,284,000 3,259,000 0 0 0

2001 Roadless Rule 9,368,000 0 0 0 0 0

Subtotal 9,368,000 4,138,000 3,259,000 854,000 847,000 0

Grand Total4 9,368,000 9,368,000 9,368,000 9,368,000 9,368,000 9,368,000 1 The Watershed Priority and Community Priority ARAs include specific exceptions for roads “to provide access to Alaska Native cultural 

site(s) if requested by an affected federally-recognized tribe(s).” 2 Timber Priority ARA and full exemption allow all roads, with no specific exception required for Alaska Native cultural sites. Timber 

harvest and other development activities would be managed in accordance with the 2016 Forest Plan.

3 The LUD II Priority and Watershed Priority ARAs and the 2001 Roadless Rule allow cultural trees to be taken by Alaska Native tribes, free 

of charge, but do not allow roads to be constructed or reconstructed for accessing them.

4 Totals may not sum due to rounding.

Rural Subsistence Activities

Potential effects on rural subsistence activities are expected to be similar to the current Forest Plan under 

all of the action alternatives, with similar effects anticipated with respect to abundance and distribution, 

access, and competition. Impacts to subsistence are discussed in more detail in the separate 

Subsistence section, below. Subsistence impacts are also assessed by community and alternative in 

Appendix E.

Payments to the State

As noted in the Affected Environment discussion, the Secure Rural Schools Act has been reauthorized 

since 2008, most recently in March 2018. The amount of these payments would not be affected by any of 

the alternatives considered in this EIS.
Environment and Effects 3

Final EIS 3-61 Key Issue 3

Key Issue 3 – Conserve Terrestrial Habitat, 

Aquatic Habitat, and Biological Diversity

Biological Diversity

Affected Environment

This section provides a summary of the Old-growth Habitat Conservation Strategy, ecosystem-based 

landscape delineations or biogeographic provinces on the Tongass, and past timber harvest. Landscape 

connectivity and fragmentation and invasive species are also discussed. Additional information on the 

background of the Old-growth Habitat Conservation Strategy and its components can be found in the 

2016 Forest Plan Amendment EIS (USDA Forest Service 2016b, Appendix D).

Ecosystem Classification

Southeast Alaska is divided into 23 biogeographic provinces (21 of which coincide with the Tongass) and 

characterized by 1) similarities in terrestrial wildlife species composition, 2) similarities in distributional 

patterns for many of these species, 3) geologic and water barriers stemming from past events, such as 

glaciation, and 4) generally similar climatic conditions and physiographic characteristics (USDA Forest 

Service 2003a). Biogeographic provinces provide an appropriate scale for the analysis of impacts to 

biological diversity because they are ecosystem-based and vary in the level of resource development that 

has taken place and is allowed within them (see the Suitable Land maps in the Map Packet for the 

distribution of suitable old growth and young growth across the Planning Area). Biogeographic provinces 

in Southeast Alaska are described in Table 3.3-1 and shown on Figure 3.3-1. 

Cover Types

The vegetation of Southeast Alaska and the Tongass is dominated by temperate coastal rain forests at 

lower elevations (less than about 2,000 feet). Interspersed within the forest are muskegs, other wetlands, 

and other non-forest types. At higher elevations, alpine vegetation, rock, glaciers, and snowfields 

dominate. Table 3.3-2 summarizes the breakdown of cover types by biogeographic province. Each of 

these cover types is described below.

Approximately 60 percent of the Tongass consists of forest land (including harvested areas). 

Approximately 5.6 million acres of the forest land is considered “productive forest land,” defined as land 

capable of producing at least 20 cubic feet of wood fiber per acre per year or having greater than 8,000 

board feet per acre of standing volume (see the Timber section for additional discussion). The remaining 

4.4 million acres of forest lands are considered unproductive forest because they do not meet the above 

criteria.

Productive forest land is divided into POG and young growth. Young growth includes those stands 

resulting from past timber harvest, as well as natural young growth (e.g., created by wind, fire, or glacial 

retreat).
Environment and Effects 3

Final EIS 3-62 Key Issue 3

Table 3.3-1

Biogeographic Provinces in Southeast Alaska and the Tongass National Forest

No. Province Description

1. Yakutat

Forelands

A very young, nearly flat landscape with extensive flooding and active isostatic rebound (uplifting of the 

ground after glaciers recede). Most surfaces vary from 200 to 1,500 years old. Dune formation and 

succession are ongoing processes due to glacial rebound and wave action. Plant community patterns 

reflect a diverse mosaic of naturally occurring older and young forests, shrublands, bogs, and meadows. 

Sitka spruce, alder, and cottonwood are abundant on well drained, recently deglaciated, and active 

fluvial surfaces. Most of the province is inside the Tongass Forest boundary, but the southern lobe that 

extends into Glacier Bay National Park is not.

2.

Yakutat/

Glacier Bay 

Upland

The climate varies from very wet hyper-maritime along the coast to very wet maritime inland. Mountains 

abruptly rising more than 10,000 feet from sea level, extensive active glaciers, and fiords dominate this 

landscape. Sitka spruce, alder, and cottonwood are abundant at lower elevations; alpine and lichen over 

rock plant communities dominate the land from 2,000 to over 10,000 feet elevation.

3.

East 

Chichagof 

Island

This province is drier and colder than the outer coast of Chichagof Island; the winter snow pack is 

generally greater. Chichagof Island is deeply dissected into three peninsulas, which may be functioning 

biologically more like separate islands. Vegetation in this province represents a modal condition similar 

to the Admiralty Island Province.

4.

West 

Chichagof 

Island

This province is dominated by a very wet hyper-maritime climate and exposure to outer coastal storms. 

Hundreds of small islands dot the coast. Topography is gentle when compared to the mountains of 

Baranof Island and the coastline is highly irregular. The Sitka spruce/Pacific reedgrass plant association 

is abundant along the outermost coastal fringe; otherwise, vegetation is similar to the other northern 

islands.

5. East Baranof 

Island

This province is colder than West Baranof or East Chichagof Island. Mountain glaciers occur along the 

divide between east and west Baranof. Topography is rugged and steep to saltwater, with little flat land. 

Plant associations on East Baranof are similar to much of the mainland due to the steep topography and 

cold environment. Spruce, devil’s club, salmonberry forest associations are common on avalanche and 

steep erosional slopes; alpine and rock/lichen plant communities are abundant.

6. West Baranof 

Island

This province is similar to the West Chichagof Island Province with the exception of southern Baranof, 

where precipitation exceeds 250 inches per year. Topographically, Baranof Island is the most rugged of 

all the islands in Southeast Alaska. The southern half of this province is highly dissected by steep-sided 

fiords; the outer coast is dotted with hundreds of small islands. All forest plant associations except those 

in the Western red-cedar series and those found around large mainland rivers occur in this province. 

Kruzof Island has some unique vegetation communities, which have not been classified.

7. Admiralty 

Island

This province is represented by relatively gentle topography and moderate rainfall. Winter conditions are 

moderated by the surrounding marine environment. Winds from Chatham and Icy Straits, Lynn Canal, 

and off the mainland are often severe. All forest plant associations but those in the Western red-cedar 

series, those found around large mainland rivers, and those occurring only on outer coastal areas occur 

in this province. Forest productivity is high. Fresh and saltwater marshes in the numerous bays and 

inlets, and alpine and bog communities, are abundant.

8. Lynn Canal

Rain shadows and the dominating influence of the continental climate make this the driest and 

seasonally warmest province in Southeast Alaska. Precipitation is generally less than 60 inches per 

year. The topography is rugged and glaciated. The southern portion of the Chilkat Peninsula is more 

similar to the East Chichagof Island Province. Western and mountain hemlock and Sitka spruce plant 

associations are common. Alpine tundra and extensive rock/lichen communities dominate much of the 

land from 2,000 to over 8,000 feet elevation.

9. Northern 

Coast Range

This province has little maritime influence. Topography is rugged and glaciated. The Taku and Whiting 

Rivers extend into Canada. All forest plant associations except those in the Western red-cedar series 

and those occurring only on outer coastal areas occur in this province.

10. Kupreanof/

Mitkof Islands

The climate is cooler and the winter snow pack greater than on the islands to the south. The eastern 

edge of this province is strongly influenced by wind-born loess (silt) coming from the Stikine River and 

the mainland. All forest plant associations except those in the Western red-cedar series and those 

occurring only on outer coastal areas occur in this province. This province contains the highest 

percentage of muskeg wetlands within the Tongass.

11. Kuiu Island

Kuiu Island is deeply dissected, creating several prominent peninsulas. The topography is gentle 

compared to neighboring Baranof Island or the mainland. The climate is cooler and winter snow pack 

greater than on islands to the south, yet milder than the mainland or islands nearer the mainland. The 

western portion of Kuiu Island is subject to severe windstorms from both the ocean and Chatham Strait. 

Most forested plant associations occur here, but those found in outer coastal environments dominate.
Environment and Effects 3

Final EIS 3-63 Key Issue 3

Table 3.3-1 (continued)

Biogeographic Provinces in Southeast Alaska and the Tongass National Forest

No. Province Description

12. Central Coast 

Range

This province is warmer than the Northern Coast Range Province. The topography is similar, but overall 

less precipitous. The Stikine River system is located in the center of this province and has a major 

continental influence, providing a migration corridor for plant and animal species. Plant associations 

found along saltwater are similar to those occurring elsewhere in northern Southeast Alaska except for 

those near the mouth of the Stikine River. Here, unique plant associations subject to high 

loess-carrying winds can be found.

13. Etolin Island 

and Vicinity

Similar to the Kupreanof/Mitkof Islands Province, this province is also subject to continental influence 

from the mainland and the Stikine River. Glacial flour (very finely ground particles of rock, silt, or clay 

created by a glacier when its rock-filled ice scrapes over bedrock and which flow out from beneath a 

glacier in the meltwater) is present in the marine environment in the northern part of this province 

nearly year-round. All forest plant associations except those occurring only on outer coast areas are 

present.

14.

North Central 

Prince of Wales 

Island

Topography is relatively gentle, limestone is common, and precipitation is relatively low due to 

interception by lands to the south and southwest. All forest plant associations except those found 

around the mainland river systems occur in this province. Overall forest productivity is high. Karst 

topography and numerous caves are present.

15.

Revilla Island/

Cleveland 

Peninsula

Climate is variable with warm and wet conditions predominating on land nearest the outer coast; much 

colder conditions occur near the mainland. Revilla, Gravina, and Annette Islands are influenced by 

human activities and populations, whereas the Cleveland Peninsula and Duke Island are generally in a 

natural condition. Revilla Island has many exceptional estuaries. Muskeg ponds are common on Duke 

Island, attracting many wintering and migratory birds.

16. Southern Outer 

Islands

These islands are isolated and are subject to strong oceanic influences. Temperatures are moderate 

year-round. The topography is low-lying and gentle. These islands are relatively rich in endemic

vertebrate species, including dusky shrew, long-tailed vole, and ermine. Major coastal seabird colonies 

are present.

17. Dall Island and 

Vicinity

These islands are subject to strong oceanic influences. Temperatures are moderate year-around. The 

topography is rugged and dissected, with abundant limestone outcrops. Dall Island appears to be a 

glacial refugia but inventories of plants and animals are limited. Major coastal seabird colonies are 

present on Dall Island.

18. South Prince of 

Wales Island

The climate is warm and wet, and deep snow is rare or highly transient. The topography is steep and 

rugged and the coastline is highly dissected. The vegetation in this province is strongly influenced by 

southeasterly storms; mixed conifer and western hemlock-red-cedar plant associations dominate.

19. North Misty 

Fiords

Compared to South Misty Fiords, this province has considerable topographic relief and characterized 

as having a colder, mainland-type climate with many glaciers. Vegetation occurs in long, narrow strips 

along the valleys and lower slopes of fiords. Much of the vegetation is muskeg, with cottonwoods in 

some of the river bottoms and subalpine fir along the Canadian border.

20. South Misty 

Fiords

South Misty Fiords is typical of the other mainland provinces and is the warmest. Topographic relief is 

lower in comparison with North Misty. Forest plant associations are more diverse than the other coastal 

provinces, and the vegetation is less fragmented by rock and ice than in North Misty Fiords. The 

southwestern portion of this province is rolling, nearly continuous muskeg with conifer forests in the 

bottoms and flats. This province is the northern limit of Pacific silver fir, yew, and honeysuckle.

21. Ice Fields Permanent ice fields, active glaciers (some advancing and some receding), and nunataks (mountain 

peaks between glaciers) dominate this province.

22. Chilkat River 

Complex

The Chilkat River Complex lies at the northern end of the Inside Passage and is outside the Tongass 

Forest boundary. It consists of tall ridge systems, large glacial rivers, and includes glaciers and 

snowfields. Many of the rivers and drainage basins extend across the international boundary into 

Canada. Because of the overlap of coastal and interior floras and faunas, the province contains 

Alaska’s highest vascular plant species richness and the highest mammalian diversity in Southeast 

Alaska (Carstensen et al. 2007). 

23.

Glacier Bay/ 

Fairweather 

Range

This is the largest province in Southeast Alaska (2.5 million acres) and is located outside the Tongass 

Forest boundary. The vast majority is high mountains and glaciers and the majority is non-vegetated. 

The highest peaks are in the Fairweather Range along the western edge of the province, with Mt. 

Fairweather at over 15,000 feet. A large flat, foreland, the Gustavus Foreland, occurs in the area 

around Gustavus and to the north in the Bartlett River valley. Lowlands are also fairly extensive along 

the Dundee River and other smaller drainages on the southwest side of Glacier Bay. Glacier Bay 

National Park protects virtually the entire province (97 percent), except for about 75,000 acres in the 

vicinity of Gustavus. 
Environment and Effects 3

Final EIS 3-64 Key Issue 3

Figure 3.3-1

Map of Biogeographic Provinces of Southeast Alaska 
Environme

Final EIS 3-65 

Table 3.3-2

Major Cover Types on the Tongass National Forest by Biogeographic Province (NFS LandsOnly)

Biogeographic Province

Productive Forest (acres) Unproductive Forest (acres) Non-Fores

POG3

Younggrowth1,3

Total 

Productive 

Forest

Forested 

Muskeg3

Other 

Unproductive 

Forest3

Total 

Unproductive 

Forest Land2,3 Wate

1 Yakutat Forelands 94,847 40,356 135,203 101,775 25,807 127,583 29,549 5,

2 Yakutat Uplands 43,838 13,212 57,049 5,244 14,752 19,995 814,444 23,

3 East Chichagof 

Island

399,152 47,332 446,484 108,731 203,783 312,514 275,325 6,

4 West Chichagof 

Island

72,614 329 72,943 45,206 82,655 127,861 72,496 8,

5 East Baranof Island 88,669 14,341 103,010 12,204 90,074 102,278 177,553 6,

6 West Baranof Island 214,429 17,715 232,143 70,538 193,739 264,277 241,642 19,

7 Admiralty Island 595,616 25,860 621,475 85,114 190,246 275,361 147,866 13,

8 Lynn Canal 158,009 8,322 166,331 20,617 100,250 120,868 347,557 2,

9 North Coast Range 322,663 5,960 328,623 19,694 159,364 179,058 477,154 15,

10 Kupreanof/Mitkof 

Island

308,046 39,157 347,203 176,597 212,250 388,847 14,252 3,

11 Kuiu Island 292,304 30,967 323,271 44,128 88,421 132,549 18,504 2,

12 Central Coast Range 246,229 9,309 255,538 27,232 152,657 179,890 267,080 10,

13 Etolin Island 220,998 42,103 263,101 71,848 130,203 202,051 20,948 4,

14 North Central Prince 

of Wales

485,142 171,051 656,193 152,229 270,990 423,219 44,291 21,

15 Revilla Island/ 

Cleveland Peninsula

503,404 48,322 551,726 174,203 307,539 481,742 87,069 35,

16 Southern Outer 

Islands

112,109 18,184 130,293 27,176 44,396 71,573 4,654 

17 Dall Island and 

Vicinity

66,880 1,298 68,179 6,467 26,547 33,014 9,585 2,

18 South Prince of 

Wales

150,860 4,256 155,116 45,275 105,831 151,106 27,156 10,

19 North Misty Fjords 198,187 6,554 204,741 21,227 264,633 285,860 458,713 14,

20 South Misty Fjords 309,058 2,405 311,463 80,097 292,245 372,342 2,222 14,

21 Ice Fields 116,895 10,004 126,899 8,628 171,811 180,439 2,535,268 10,

Forest-wide 4,999,950 557,036 5,556,986 1,304,231 3,128,192 4,432,423 6,273,330 235,

1 Includes 83,000 acres of natural young growth, 430,000 acres of even-aged harvested stands, and about 45,000 acres of partial harvested stands. 2 Non-forest land classes primarily include alder brush, brush, alpine, ice and snow fields, muskeg meadow, recurrent slide, and rock. 3 Totals may not sum or match exactly to other tables in this section due to rounding.

Source: Data are from USDA Forest Service 2018 GIS.
Environment and Effects 3

Final EIS 3-66 Key Issue 3

The remaining 40 percent of the Tongass National Forest (about 6.7 million acres) is classified as nonforest land and includes shrub and herbaceous habitats (e.g., muskeg, alpine, estuaries), sparsely 

vegetated and non-vegetated areas (e.g., snow, rock, ice), and aquatic habitats (e.g., streams, ponds, 

and lakes).

Productive Old-Growth Forest

Old-growth forests support biological diversity due to their structural and ecological complexity. In 

Southeast Alaska, old-growth forests are greater than 150 years old, and are characterized by multiple

canopy layers; an interspersion of trees of multiple age classes; the presence of snags, decadent trees, 

and fallen trees; presence of forbs; and variation in the amounts and distribution of live trees (USDA-FS 

R10-TP-28). These features create intricate habitat niches that support many plant and animal species 

(Spies 2004). In Southeast Alaska, old-growth forests have been the focus of past timber harvest making 

them the most susceptible ecosystem to changes caused by forest management activities.

The Size-Density Model (SDM), which uses a combination of tree sizes and tree densities to classify 

forest structure (Caouette and DeGayner 2005) into Size Density classes (SD classes), is used by the 

Tongass to map POG and assess impacts to old-growth habitat. This classification system builds on the 

timber volume-based classification system (volume strata) for POG used developed prior to the 2008 

Land and Resource Management Plan (Forest Plan) (low-, medium-, and high-volume strata), which used 

hydric soils and steep slopes as measures of productivity and growth. While timber volume may be a 

good indicator of the overall productivity of a forested stand, volume fails to recognize key differences in 

forest structures. Forest structure is important because it reflects the complex spatial and temporal 

interactions between plant growth (e.g., dispersal and competition), environmental gradients (e.g., 

geology, soils, slope, aspect, elevation, and climate), and disturbance (e.g., wind and logging) (Caouette 

and DeGayner 2005). To move beyond the limitations of timber volume, the SDM was developed as a 

means to produce a classification system based on forest structure. By modeling forest structure patterns 

using two measurable forest attributes: tree sizes and densities, the SDM is more applicable in assessing 

biodiversity, estimating timber values, and describing wildlife habitat than using timber volume alone 

(Caouette and DeGayner 2005). Seven POG types have been defined, which were used to develop a 

hierarchical mapping model for predicting tree sizes and densities on the Tongass National Forest. Figure 

3.3-2 presents a description of each of the categories and illustrates the most probable forest type on the 

Tongass National Forest based on land form and forest condition.

From a biological diversity standpoint, high-volume POG and large tree POG are thought to have the 

highest importance for diversity. High-volume POG is defined as the grouping of the three tree size and 

density classes that represent the highest volume strata—SD5S, SD5N, and SD67 types. Large-tree 

POG is defined as the SD67 class, representing the most productive of the POG types, and typically 

containing the highest density of large trees.

There are approximately 5 million acres of POG forest on the Tongass. Of this amount, approximately 16 

percent is low-volume POG (SD4H type), 42 percent is medium volume POG (SD4N, 4S, and 5H types), 

and 42 percent is high-volume POG (SD5S, 5N, and 67 types). Large-tree POG (SD67 type) makes up 

almost 11 percent of all POG. Table 3.3-3 provides the distribution of existing POG forest by 

biogeographic province and POG type.

Elevation is considered a landscape variable influencing the distribution and availability of POG forest. 

Lower elevation stands (at or below 800 feet) hold the highest value for many wildlife species because 

they remain relatively accessible during winter (see the Wildlife section for additional discussion). Forestwide, only approximately 60 percent of POG forest occurs at low elevations, but 64 percent of highvolume POG and 74 percent of large-tree POG occurs at low elevations, respectively (see Table 3.3-4). 
Environment and Effects 3

Final EIS 3-67 Key Issue 3

Figure 3.3-2

Tree Size and Density Model used to Describe Forested Conditions across the Tongass 

National Forest

SD 

Class

Land and Forest Condition

Most Probable Forest Type

Tree Sizes and Densities

Most Probable Forest Type 1

Illustration

Most Probable Forest Type

4H

Low productive older forests associated 

with wet, poorly drained land types 

(e.g., muskegs, fens, rolling hills, 

broken mountain slopes, plateaus, 

glacial outwash zones). Canopy closure 

is variable. Trees are small, old, and 

defective. Stand volume is low.

Low densities (SDI < 280) of smalldiameter trees (QMD < 17 inches). Tree 

size distribution and spacing is variable 

and patchy. Tree diameters greater than 

40 inches are generally not present.

4N

Low to moderately productive older 

upland forests. Canopy characteristics 

are variable and patchy, with moderate 

canopy closure and relatively coarse 

canopy texture. Stand volume is low to 

moderate.

Low densities (SDI < 280) of medium 

diameter trees (17 < QMD < 21 inches). 

Tree size distribution and spacing is 

variable and patchy. Tree diameters 

greater than 40 inches are rare.

4S

Highly productive younger upland 

forests. Stand volume is moderate, but 

increasing rapidly. Crown competition is 

high. Canopy characteristics tend to be 

uniform, with high canopy closure and 

fine canopy texture.

High densities (SDI > 280) of mediumdiameter trees (17 < QMD < 21 inches). 

Tree size distribution and spacing tends 

to be more uniform. Tree diameters 

greater than 40 inches are rare.

5H

Moderately productive older forests 

associated with wet, somewhat poorly 

drained land types. Canopy closure, 

texture, and structure tend to be 

variable and patchy. Stand volume and 

annual growth is also variable and 

patchy.

Low densities (SDI < 280) of mediumdiameter trees (17 < QMD < 21 inches). 

Tree diameters greater than 40 inches 

are somewhat common, but not uniformly 

distributed throughout the stand.

5N

Moderately productive older upland 

forests. Stand volume is moderate to 

high. Canopy characteristics tend to be 

variable, with moderate canopy closure 

and coarse canopy texture.

Low densities (SDI < 280) of medium-tolarge diameter trees (17< QMD < 21 

inches). Tree size distribution and 

spacing is variable and patchy. Tree 

diameters greater than 40 inches are 

common, but not uniformly distributed 

throughout the stand.

5S

Highly productive upland forests. Stand 

volume is high. Canopy characteristics 

tend to be uniform, with moderate to 

high canopy closures.

High densities (SDI > 280) of mediumdiameter trees (17 < QMD < 21 inches). 

Tree size distribution and spacing tends 

to be uniform. Tree diameters greater 

than 40 inches are somewhat common, 

but not uniformly distributed throughout 

the stand.

67

Highly productive forests associated 

with riparian areas, alluvial fans, 

colluvial toe slopes, karst geology, and 

wind-protected uplands. Stand volume 

is high. Stand age can vary. Canopy 

closure is low to moderate and canopy 

texture is coarse.

Low densities (SDI < 280) of largediameter trees (QMD > 21 inches). Tree 

diameters greater than 40 inches are 

common and uniformly distributed 

throughout the stand.
Environment and Effects 3

Final EIS 3-68 Key Issue 3

Table 3.3-3

Distribution of Productive Old-Growth Forest on the Tongass National Forest by 

Biogeographic Province (NFS Lands Only) 

Biogeographic 

Province

POG Type

Total 

POG1

Low Vol. Medium Vol. High Vol.

SD4H SD4N SD4S SD5H SD5N SD5S

SD67 

(Largetree)

1 Yakutat

Forelands 

7,236 9,426 17,639 2,025 4,791 9,755 43,976 94,847 

2 Yakutat Uplands 2,777 6,323 19,523 939 2,926 7,933 3,417 43,838 

3 East Chichagof 

Island

62,546 53,412 102,313 22,106 45,281 79,254 34,241 399,152 

4 West Chichagof 

Island

14,421 12,837 24,938 1,950 6,245 10,202 2,021 72,614 

5 East Baranof 

Island

10,256 15,069 28,722 4,566 12,150 15,938 1,969 88,669 

6 West Baranof 

Island

32,282 38,895 80,394 7,187 19,566 32,011 4,093 214,429 

7 Admiralty Island 86,695 53,062 110,613 43,383 64,515 139,688 97,659 595,616

8 Lynn Canal 21,199 20,586 46,128 

9,058 

 

13,010 

36,075 11,953 158,009 

9 North Coast 

Range

35,540 38,172 88,216 23,435 42,808 72,153 22,340 322,663 

10 Kupreanof/

Mitkof Island

84,024 32,116 63,684 21,824 30,168 56,625 19,606 308,046 

11 Kuiu Island 42,763 19,535 41,776 24,865 44,668 84,106 34,591 292,304 

12 Central Coast 

Range

30,454 27,195 66,024 12,945 27,070 62,504 20,037 246,229 

13 Etolin Island 49,879 24,836 53,972 11,856 25,057 42,970 12,428 220,998 

14 North Central 

Prince of Wales

103,164 27,783 64,535 64,216 43,537 80,281 101,626 485,142 

15 Revilla Island/ 

Cleveland 

Peninsula

78,575 43,712 94,155 54,564 70,041 130,895 31,463 503,404 

16 Southern Outer 

Islands

17,373 10,276 26,714 9,305 15,631 20,355 12,454 112,109 

17 Dall Island and 

Vicinity

7,440 5,716 16,801 3,455 10,987 14,578 7,904 66,880 

18 South Prince of 

Wales

25,374 11,132 32,206 10,301 11,023 22,011 38,813 150,860 

19 North Misty 

Fiords

13,545 35,207 78,978 3,861 18,998 34,874 12,724 198,187 

20 South Misty 

Fiords

52,833 40,463 104,900 11,392 29,513 55,869 14,088 309,058 

21 Ice Fields 4,940 21,671 50,564 1,479 10,427 21,940 5,875 116,895 

Forest-wide 783,314 547,425 1,212,796 344,711 548,412 1,030,016 533,276 4,999,950

1 Totals may not sum or match exactly to other tables in this section due to rounding.

Source: Data are from USDA Forest Service 2018 GIS.
Environment and Effects 3

Final EIS 3-69 Key Issue 3

Young-Growth Forest

There are approximately 557,000 acres of young-growth forest on the Tongass, of which approximately 

84 percent is a result of past timber harvest and approximately 15 percent a result of natural processes 

(e.g., wind, fire, glacial retreat). Over 90 percent of the harvested young growth is from even-age harvest. 

Approximately 20 percent of young growth from even-age harvest is 25 years old or younger, in the stand 

initiation stage. Of this age class, stands up to about 10 years tend to have high species diversity, in 

particular their shrub layer, which expands as a result of the open canopy after harvest. The remaining 

approximately 80 percent of young growth is older and mostly in the stem exclusion stage. This type of 

stand condition has very low species diversity.

Some of these older young-growth stands are considered suitable for timber harvest, and could help 

support the Tongass transition to young-growth harvest (see the Timber section for additional discussion 

of young-growth harvest and suitability). Approximately 90,000 acres of young-growth (harvested and 

natural) occur in Riparian Management Areas (RMAs) and an additional 68,000 acres occur in Beach and 

Estuary Fringe outside of RMAs. In addition, approximately 32,000 acres of young growth (harvested and 

natural) occur within the Old-growth Habitat LUD and outside of RMAs and Beach and Estuary Fringe.

Unproductive Forest and Non-Forested Lands

Approximately 26 percent of the Tongass is classified as unproductive forest (Table 3.3-2). Many 

unproductive forest stands meet the definition of old growth, but the trees are typically small and stunted 

(under 40 feet in height) and the canopy is open (10 to 40 percent canopy closure). Hemlock, cedar, and 

lodge pole pine are the most common trees; blueberry and rusty menzesia are the most common shrubs. 

Past disturbance to this habitat type has occurred primarily as a result of road construction, which has 

resulted in some permanent reduction in total acres of these unproductive forest types.

Non-forest ecosystems provide valuable habitat types that include wetland and other areas of shrub and 

herbaceous types (e.g., muskegs, alder and willow brush, alpine, estuaries), non-vegetated areas (e.g., 

snow, rock, ice), and aquatic sites (e.g., streams, ponds, and lakes) and contribute greatly to the species 

diversity on the Tongass National Forest by providing unique microsites and openings that contain shrub 

and herbaceous vegetation within forested stands.

Approximately 39 percent of the Tongass National Forest consists of non-forest lands (Table 3.3-2).

Overview of Existing Levels of POG Forest on NFS Lands

This section provides a brief summary of past timber harvest as provided in the 2016 Forest Plan 

Amendment EIS (USDA Forest Service 2016b) and focuses on the amount of POG forest compared to 

the amount present in 1954 prior to large-scale commercial timber harvest because management 

activities are most likely to affect productive forest. Other habitat types are expected to be maintained and 

will contribute toward overall biological diversity.

Approximately 91 percent of the estimated original (prior to 1954) 5.5 million acres of POG that occurred 

on Tongass remains today (Table 3.3-4). Forest-wide, 86 percent of the original high-volume POG and 79 

percent of the original large-tree POG remains (Table 3.3-4). The greatest amount of timber harvest has 

occurred in the North Central Prince of Wales biogeographic province (74 percent of the total original 

POG forest remaining), followed by Etolin Island, Southern Outer Islands, East Baranof, Kupreanof/Mitkof 

Islands, and East Chichagof Island biogeographic provinces (85, 86, 87, 89, and 90 percent of the original 

total POG forest remaining, respectively; Table 3.3-4).

These biogeographic provinces, in addition to West Baranof Island biogeographic province, have also 

had the most harvest of high-volume and large-tree POG forest harvested. The Revilla Island/Cleveland 

Peninsula province also ranks among the highest when considering large-tree POG harvest. For 

additional discussion of past harvest on the Tongass, see the Timber section in this EIS and Appendix C 

in USDA Forest Service (2016b).
Environme

Preliminary Final EIS 3-70 

Table 3.3-4

Original and Percent Remaining Total POG, High-Volume POG (SD5S, SD5N, SD67) Total and Below 800 

Tree POG (SD67) Total and Below 800 feet by Biogeographic Province (NFS Lands Only)

Biogeographic Province

Acres Original POG1, 2 % Original POG rem

Total POG

HighVolume 

POG

High-Vol. 

POG 

<800 ft

Largetree POG

Large-tree 

POG 

<800 ft Total POG

High-Vol. 

POG

High-Vol. 

POG 

<800 ft

1 Yakutat Forelands 98,443 61,218 61,071 45,054 44,965 96% 96% 96% 

2 Yakutat Uplands 45,211 15,306 14,810 3,829 3,597 97% 93% 93% 

3 East Chichagof Island 443,189 191,803 125,424 47,452 36,951 90% 83% 78% 

4 West Chichagof Island 72,614 18,467 14,902 2,021 1,927 100% 100% 100% 

5 East Baranof Island 102,142 40,161 31,750 6,010 5,508 87% 75% 71% 

6 West Baranof Island 231,279 68,308 53,701 9,149 8,591 93% 81% 77% 

7 Admiralty Island 616,194 317,296 192,198 103,833 70,389 97% 95% 93% 

8 Lynn Canal 163,380 65,066 39,236 13,564 9,563 97% 94% 91% 

9 North Coast Range 323,340 137,808 67,237 22,543 13,831 100% 100% 99% 

10 Kupreanof/Mitkof 

Island

345,548 134,526 84,572 30,856 23,147 89% 79% 74% 

11 Kuiu Island 319,805 183,991 131,810 42,841 28,611 91% 89% 86% 

12 Central Coast Range 252,770 114,517 70,929 21,999 16,925 97% 96% 93% 

13 Etolin Island 259,670 109,459 68,920 24,030 16,417 85% 74% 69% 

14 North Central Prince of 

Wales

656,064 353,636 239,489 152,903 113,309 74% 64% 58% 

15 Revilla Island/ 

Cleveland Peninsula

551,164 268,219 141,142 45,791 27,447 91% 87% 82% 

16 Southern Outer Islands 130,013 61,869 45,797 17,825 13,458 86% 78% 75% 

17 Dall Island and Vicinity 68,179 34,442 24,210 8,293 6,197 98% 97% 96% 

18 South Prince of Wales 155,116 75,039 53,004 40,090 31,356 97% 96% 95% 

19 North Misty Fjords 204,462 71,302 42,097 14,606 10,880 97% 93% 91% 

20 South Misty Fjords 311,463 101,274 63,891 14,810 11,597 99% 98% 98% 

21 Ice Fields 123,567 43,245 21,269 7,876 5,523 95% 88% 81% 

Forest-wide 5,473,634 2,466,951 1,587,454 675,375 500,192 91% 86% 82% 

1 To determine amount of high-volume POG, assumed 75% of total past harvest consisted of high-volume POG. To determine amount of large-tree POG 

percent of total past harvest consisted of large-tree POG.

Source: Data are from USDA Forest Service 2018 GIS.
Environment and Effects 3

Final EIS 3-71 Key Issue 3

Of the 922 VCUs, or large watersheds, with POG forest on the Tongass, 71.5 percent are considered 

intact (for NFS lands only) and are thus likely to maintain a high degree of biological diversity. Although 

landscapes with higher amounts of past harvest likely remain functional, this index represents areas that 

are in relatively pristine conditions and thus have the highest ecological integrity. Intact watersheds are 

defined here as those large watersheds that have less than 5 percent of their POG forest harvested.

Landscape Connectivity and Fragmentation

The Tongass is characterized by an inherent level of fragmentation due to its island geography. The 

natural distribution of POG forest is also patchy and linear in many areas, as a result of the mosaic 

condition of the landscape created by muskeg, forested wetlands, alpine areas, other unproductive forest, 

and other non-forested habitats. This section provides an overview of the concepts of landscape 

connectivity and fragmentation and existing conditions on the Tongass.

Landscape connectivity has been defined as the degree to which the structure of a landscape helps or 

hinders the movement of wildlife species (Taylor et al. 1993). A landscape with a high degree of 

connectivity is one in which wildlife and other species can move readily between habitat patches over the 

long term (USDA Forest Service 2008a). On the Tongass, connectivity between areas of similar habitats 

(for example, between two patches of old-growth forest) or between high and low elevation habitats is 

important to maintaining well-distributed, viable wildlife populations and thus contributing to the ecological 

integrity of the landscape. Empirical studies to date suggest that habitat loss has large, consistently 

negative effects on overall biological diversity. Fragmentation, both natural (e.g., windthrow, landslides, 

insects and diseases, and avalanches) and human-caused (e.g., timber harvest, road building, and 

powerline development), reduces landscape connectivity by breaking apart larger contiguous blocks of 

habitat into smaller patches. The degree to which impacts to some species habitat requisites depends on 

species-specific dispersal capabilities, the distance between habitat patches, and conditions within the 

matrix between habitat patches.

When fragmentation occurs, there is an increase in the amount of forest edge habitat and a decrease in 

the amount of interior old-growth forest habitat with which many wildlife species are associated (see the 

Wildlife section).

Fragmentation is often accompanied by a decline in native species diversity because habitat conditions 

along the edge (edge effects) may favor some species over others. Edge effects may include changes to 

vegetation structure, species composition (both plants and animals), predation rates, and disturbance 

(Murcia 1995; Nilon et al. 1995; As 1999). Although the number of species may be higher along edges 

(often favoring invasive species), the number of habitat specialists (such as those associated with interior 

old growth forest conditions and those that tend to be more sensitive or at‐risk) decreases (As 1999; Nilon 

et al. 1995; Kissling and Garton 2008).

Past analysis has looked at biological diversity at the large watershed scale. Intact, undeveloped 

landscapes, even at this scale, are assumed to function in a way that maintains plant communities, 

unique habitat, and other supporting ecological processes for increased biological diversity. Intact 

watersheds are defined as those having less than 5 percent of their POG harvested, which is consistent 

with a similar analysis conducted by Audubon Alaska and The Nature Conservancy (Albert and Schoen 

2007). Based on this definition, a VCU, roughly equivalent to a large watershed, with at least 95 percent 

of the original POG remaining would be considered to be intact.

Forested corridors along streams and between old-growth habitats at different elevations have been 

reduced in size by past harvest in many areas of the Tongass. Remaining patches of old-growth forest

may serve as the only habitat in a landscape for many lichens, fungi, bryophytes, plants, and smallbodied animals, all of which contribute to the biological diversity and productivity of the old-growth forest 

ecosystem. These patches may be critical for species that are locally endemic, occur only in very specific 

conditions of forest structure or soil type, or have limited dispersal capabilities. Biogeographic provinces 

with the greatest levels of past timber harvest (Table 3.3-2) are at a higher risk of not maintaining a full 

range of natural biological diversity (ecological integrity) and have the greatest reductions in overall 

landscape connectivity. Other biogeographic provinces are naturally fragmented by unproductive forest 

and non-forest habitats. Detailed analyses of landscape connectivity and fragmentation are typically 
Environment and Effects 3

Final EIS 3-72 Key Issue 3

conducted at the project level where individual patches of contiguous old-growth forest habitat and 

movement corridors can be identified. For this FEIS, landscape connectivity and fragmentation are 

discussed qualitatively at the biogeographic province scale.

Tongass Forest Plan Old-growth Habitat Conservation Strategy

The Tongass Forest Plan Old-growth Habitat Conservation Strategy was developed to maintain the 

integrity of the old-growth forest ecosystem, and thereby conserve biological diversity across the Forest, 

by retaining intact, largely undisturbed habitat. This strategy, initially incorporated into the 1997 Forest 

Plan, was reviewed and amended for incorporation into the 2008 and 2016 Forest Plans. The Old-growth 

Habitat Conservation Strategy includes two major components: (1) a forest-wide network of variably sized 

old-growth reserves (OGRs) allocated to the Old-growth Habitat LUD plus other non-development LUDs 

and all small islands less than 1,000 acres, and (2) a series of standards and guidelines applicable to 

lands where timber harvest is permitted, also known as the matrix (USDA Forest Service 2008a, 2008b).

The reserve network was designed to maintain habitats of the species that have the highest viability 

concerns (USDA Forest Service 2008b), particularly those associated or dependent upon old-growth 

forest characteristics. The reserve network includes other non-development LUDs such as Wilderness, 

LUD II, Remote, and Semi-Remote Recreation. These non-development LUDs contribute to maintaining a 

variety of habitats important for species not necessarily dependent on old growth ecosystems. The intent 

of the reserve system is to help ensure the maintenance of well-distributed viable populations of all oldgrowth associated wildlife species across the Tongass, with focus on those species that are most 

sensitive to habitat loss and fragmentation. For a complete review of the Old-growth Habitat Conservation 

Strategy, including assumptions underlying the design of the OGR system, refer to Appendix D of the 

2008 Forest Plan Amendment EIS (USDA Forest Service 2008b).

Within the matrix areas outside of reserves, components of the old-growth ecosystem are maintained 

through standards and guidelines designed to provide for important ecological functions such as dispersal 

of organisms, movement between forest stands, and maintenance of ecologically valuable structural 

components such as down logs, snags, and large trees. Matrix lands where commercial timber harvest

occurs include Modified Landscape, Scenic Viewshed, and Timber Production LUDs.

Matrix management complements the reserve system by providing habitat at smaller spatial scales, 

increasing the effectiveness of reserves, and maintaining landscape connectivity (USDA Forest Service 

2008b). Standards and guidelines applicable to these lands include maintenance of the 1,000-foot beach 

and estuary buffer, variable-width stream buffers, project-level legacy forest structure retention 

requirements, high-hazard soils, steep slopes, karst terrain, and visually sensitive travel routes and use 

areas, and requirements for connectivity. These are all considered contributing elements of the Oldgrowth Habitat Conservation Strategy. Finally, a number of species-specific standards and guidelines, 

such as raptor nest and wolf den buffers, set aside old growth buffers, are implemented to avoid impacts 

to these species. These standards and guidelines are also addressed in the Wildlife section of this FEIS. 

Table 3.3-5 shows the distribution of POG and young-growth forest within the reserve system and matrix 

lands. 
Environment and Effects 3

Final EIS 3-73 Key Issue 3

Table 3.3-5

Distribution of Existing POG and Young Growth within the Reserve System and Matrix 

Lands1 (NFS Lands Only) Biogeographic Province

Within Reserves (Non-Development LUDs; 

acres) Within Matrix (Development LUDs; acres)

Productive Old-growth

Younggrowth2

Productive Old-growth

Younggrowth1 TotalHigh-volume 

(SD 5N, 5S, 67)

Largetree 

(SD 67) Total

High-volume 

(SD 5N, 5S, 67)

Largetree

(SD 67)

1 74,204 42,760 30,850 24 20,643 15,761 13,125 3,571 

2 43,017 13,821 3,181 254 821 455 236 1,119 

3 230,168 94,749 23,190 10,340 168,985 64,027 11,051 33,696 

4 72,609 18,467 2,021 0 5 0 0 00

5 53,760 16,450 1,213 1,783 34,909 13,606 755 11,690 

6 181,286 47,505 3,555 6,327 33,143 8,165 539 10,524 

7 595,616 301,862 97,659 20,579 0 0 0 0

8 109,436 41,085 7,817 1,094 48,599 19,953 4,135 4,277 

9 215,993 90,833 14,542 354 106,670 46,468 7,798 323 

10 136,464 50,115 9,571 6,105 171,582 56,285 10,035 31,396 

11 201,938 108,144 18,382 5,538 90,366 55,222 16,210 21,962 

12 172,244 76,832 13,096 768 73,985 32,780 6,940 5,773 

13 102,925 37,721 6,124 4,277 118,073 42,733 6,304 34,395 

14 268,394 130,333 61,538 30,595 216,748 95,110 40,088 140,327 

15 342,848 160,788 20,990 9,353 160,556 71,612 10,473 38,407 

16 89,520 36,698 8,473 4,089 22,589 11,742 3,981 13,815 

17 57,605 29,747 7,541 1,268 9,275 3,722 363 30 

18 105,909 50,135 27,764 1,665 44,952 21,712 11,049 2,591 

19 184,642 61,321 11,524 5,271 13,545 5,275 1,200 1,003 

20 309,058 99,470 14,088 2,405 0 0 0 0

21 97,621 32,693 5,390 4,474 19,274 5,549 485 2,197 

Forest

-wide

3,645,258 1,541,530 388,508 116,565 1,354,718 570,176 144,768 357,097 

1 Matrix includes all Development LUDs including Timber Production, Modified Landscape, and Scenic Viewshed; Experimental 

Forest is also included. Reserves include all other LUDs, which are considered Non-Development LUDs. 2 Previously harvested young growth, which could help contribute to the transition to young-growth harvest.

Source: Data are from USDA Forest Service 2018 GIS.

Environmental Consequences

Effects Common to All Alternatives

Effects on the Old-Growth Forest Ecosystem

A functional and interconnected old-growth ecosystem is essential to maintaining ecological integrity of 

several biological diversity components, including: structural complexity (within-stand and landscape 

level); connectivity (unfragmented contiguous blocks of old growth, as well as functional connectivity 

within the matrix); stand age and species composition; and various ecological functions (tree 

establishment, disturbance, and nitrogen fixation [USDA Forest Service 2008b]). Timber harvest in POG 

may reduce biological diversity by shifting the age-structure of the forest by replacing old growth trees 

with younger trees (Franklin et al. 1997); changing the composition of understory vegetation (Deal and 

Tappeiner 2002); and removing key habitat features such as large decadent trees, snags, and downed 

logs.
Environment and Effects 3

Final EIS 3-74 Key Issue 3

Although many other cover types contribute to the overall biological diversity on the Tongass, the 

emphasis throughout this section is placed on old-growth forest because this is the focus of the Oldgrowth Habitat Conservation Strategy, and the cover type that has been most affected by timber 

management activities on the Tongass. The amount of POG remaining and its distribution across the 

landscape provides a method to estimate the effects of the alternatives on biological diversity and was 

analyzed in detail in the 2016 Forest Plan Amendment EIS (USDA Forest Service 2016b).

Within matrix lands, there may be slightly more high-volume and large-tree POG harvested under the 

action alternatives than was predicted for the Forest Plan because of the increased options for creating 

positive timber sales. However, this is speculative and depends also on harvest levels reaching predicted 

decadal levels. In addition, the proportion of high-volume and large-tree POG in the added suitable acres 

under the action alternatives is lower than in the Alternative 1 suitable acres (see Effects Specific to Each 

Alternative). Regardless, potential impacts would be analyzed at the project level and under a separate 

NEPA process.

Young-growth harvest, depending on treatment type and rotation, may reduce the range of habitats that 

support diverse plant and animal communities and alter the ecological functions supported by the oldgrowth ecosystem. However, treatments such as pre-commercial and commercial thinning can result in 

benefits to biological diversity by increasing understory growth over the short term, and by promoting the 

development of old-growth stands over the long term when stands are allowed to mature. The effects of 

young-growth harvest discussed throughout this section, as well as in the Wildlife section, represent the 

trade-off associated with the proposed transition to predominantly young-growth harvest.

Young growth suitable for timber harvest occurs in a number of special habitats under the Forest Plan, 

including RMAs, beach and estuary fringe, and the Old-growth Habitat LUD. Young growth on specific 

portions of these areas may be harvested under required prescriptions and following specific guidelines. 

The suitable acres of young growth on these special areas will increase slightly under the action 

alternatives, but only slightly because the vast majority of existing young-growth stands are not in 

roadless areas. Therefore, little to no difference among the alternatives is expected.

Effects on the Old-growth Habitat Conservation Strategy

Under all of the alternatives, long-term protection of POG would continue to occur under the Old-growth 

Habitat Conservation Strategy. The system of OGRs and other non-development LUDs is intended to 

maintain the ecological integrity of the old-growth ecosystem; all non-development LUDs would remain 

intact across all alternatives. Within the matrix, old-growth between reserves is maintained through 

Forest-wide standards and guidelines for stream buffers, the beach and estuary fringe, legacy forest 

structure, and other features that preclude or limit POG timber harvest under all alternatives (USDA 

Forest Service 2016b).

Collectively, these measures would facilitate organism dispersal and maintain the functionality and 

interconnectedness of the old-growth ecosystem (USDA Forest Service 2008b). In addition, the 

substantial reduction in old-growth harvest relative to the 1997 Forest Plan (under which the Old-growth 

Habitat Conservation Strategy was developed) through the transition to predominantly young-growth 

harvest would enhance biological diversity and the functioning of the Old-growth Habitat Conservation 

Strategy over the long-term. No changes to these Forest Plan features are proposed under any of the 

alternatives.

Effects Specific to Each Alternative

Alternative 1 (No Action)

Alternative 1 represents continued implementation of the Forest Plan under the 2001 Roadless Rule. 

Under Alternative 1, there would be no effects related to additional or modified Forest Plan components 

because none are proposed.

Alternative 1 would maintain the current Forest Plan harvest levels consisting of about 42,500 acres of old 

growth and 284,000 acres of young growth over 100 years. The total suitable acres of young growth 
Environment and Effects 3

Final EIS 3-75 Key Issue 3

would be about 334,000 acres and suitable old-growth acres would be about 227,000 acres. Suitable 

high-volume POG and suitable large-tree POG would be about 96,000 acres and 31,000 acres, 

respectively. 

Harvest of young growth in RMAs, beach fringe, and Old-growth Habitat LUD would remain restricted to 

the first 15 years and under restrictive harvest prescriptions. Suitable young growth in RMAs consist of 

about 27,000 acres; in beach fringe about 29,000 acres; and in Old-growth Habitat LUDs about 26,000 

acres. Harvest is limited to a maximum of 10-acre openings or commercial thinning. RMA harvest is only 

allowed outside of TTRA buffers, and beach fringe harvest is only allowed outside of a 200-foot buffer 

along the shoreline. A one-time entry stipulation is also implemented. Because of the restrictive 

prescriptions required in these areas, they are harvested at a lower rate than other young-growth areas. 

Forest Plan modeling projected harvest levels of 1,089 acres in RMAs, 3,903 acres in beach fringe, and 

1,811 acres in Old-growth Habitat LUDs after 100 years (USDA Forest Service 2016b, Table 2-18).

Table 3.3-6 shows the projected harvest by biogeographic province over the next 100 years of Forest 

Plan implementation. Assuming full implementation of the Forest Plan after 100 years, approximately 91 

percent of the original total POG, 85 percent of the original high-volume POG, and 78 percent of the 

original large-tree POG would be maintained on the Tongass (Tables 3.3-7, 3.3-8, and 3.3-9). By 

biogeographic province, approximately 72 to 100 percent of the original total, 61 to 100 percent of the 

original high-volume, and 33 to 100 percent of the original large-tree POG would be maintained. The 

reduction of biological diversity associated with old-growth forest and fragmentation would be greatest in 

the Kupreanof/Mitkof Island, Etolin Island & Vicinity, and North Central Prince of Wales biogeographic 

provinces, where the amount of POG remaining is estimated to be reduced by 2 percent over 100 years. 

As noted previously, fragmentation can be caused by timber harvest, road building, and powerline and 

facility development. Under Alternative 1, overall impacts due to fragmentation and on the Old-growth 

Habitat Conservation Strategy are expected to be minor and consistent with the existing Forest Plan. 

Under the current Forest Plan, there would be a slight reduction in the number of intact watersheds, and 

acreage within intact watersheds, over the planning horizon. After 100+ years of Alternative 1 

implementation, there would be two fewer intact watersheds considering NFS lands only. This means 

71.3 percent of the 922 large watersheds containing POG forest would remain intact.
Environme

Final EIS 3-76 

Table 3.3-6 

Projected Harvest of Young Growth1 and Old Growth Over 100 Years by Biogeographic Province by Alte

No.

Biogeographic 

Province

Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 

Young 

Growth

Old 

Growth

Young 

Growth

Old 

Growth

Young 

Growth

Old 

Growth

Young 

Growth

Old 

Growth

Young 

Growth

O

Gro

1 Yakutat Forelands 4,320 7 4,477 7 5,744 6 5,522 4 5,462 

2 Yakutat Uplands 949 0 918 0 1,158 0 1,157 0 1,050 

3 East Chichagof Island 30,597 1,717 29,898 1,714 29,599 1 ,777 29,718 1,716 29,649 1

4 West Chichagof 

Island

0 0 0 0 0 0 0 0 0 

5 East Baranof Island 9,622 109 9,271 110 9,172 93 9,205 204 9,158 

6 West Baranof Island 8,983 0 8,724 0 8,638 0 8,634 6 8,590 

7 Admiralty Island 0 0 0 0 0 0 0 0 0 

8 Lynn Canal 3,778 292 4,222 293 4,177 248 4,217 194 4,521 

9 North Coast Range 137 0 138 0 136 0 155 1 248 

10 Kupreanof/Mitkof 

Island

23,075 7,294 24,782 7,947 24,593 8,409 24,571 8,058 24,581 8

11 Kuiu Island 17,810 4,107 17,238 3,361 17,067 3,190 17,154 3,393 17,096 3

12 Central Coast Range 4,102 605 3,968 579 3,926 884 3,924 1,320 3,956 1

13 Etolin Island & Vicinity 26,839 5,128 27,417 5,196 27,265 5,134 27,321 5,170 27,546 5

14 North Central Prince 

of Wales

109,286 14,491 108,932 14,383 108,639 13,861 108,609 12,835 108,122 12

15 Revilla Island/ 

Cleveland Pen.

27,520 6,613 27,389 6,923 27,438 7,190 27,312 7,656 27,525 7

16 Southern Outer 

Islands

11,374 1,367 11,034 1,279 10,917 1,041 10,923 1,164 10,872 1

17 Dall Island and 

Vicinity

0 0 0 0 0 0 0 0 20 

18 South Prince of 

Wales

1,904 735 2,014 675 1,993 557 2,017 656 2,041 

19 North Misty Fjords 847 1 819 1 811 1 810 1 830 

20 South Misty Fjords 0 0 0 0 0 0 0 0 0 

21 Ice Fields 3,002 12 2,904 11 2,873 89 2,892 102 2,878 

Totals1 Forest-wide 284,144 42,479 284,144 42,479 284,144 42,479 284,144 42,479 284,144 42

1 Numbers may not appear to sum correctly due to rounding.
Environment and Effects 3

Final EIS 3-77 Key Issue 3

Table 3.3-7

Estimated Percent of Original POG Remaining (Total and in Reserves1) after 100 Years by

Biogeographic Province and Alternative (NFS lands only)

2

No.

Biogeographic 

Province

% Original POG Remaining after 100+ Years 

(Total / In Reserves) by Alternative

Original POG

Acres

% Remaining

in 2018 Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

1 Yakutat Forelands 98,443 96% 96 / 75 96 / 75 96 / 75 96 / 75 96 / 75 96 / 75

2 Yakutat Uplands 45,211 97% 97 / 95 97 / 95 97 / 95 97 / 95 97 / 95 97 / 95

3 East Chichagof 

Island

443,189 90% 90 / 52 90 / 52 90 / 52 90 / 52 90 / 52 90 / 52

4 West Chichagof 

Island

72,614 100% 100 / 100 100 / 100 100 / 100 100 / 100 100 / 100 100 / 100

5 East Baranof Island 102,142 87% 87 / 53 87 / 53 87 / 53 87 / 53 87 / 53 87 / 53

6 West Baranof Island 231,279 93% 93 / 78 93 / 78 93 / 78 93 / 78 93 / 78 93 / 78

7 Admiralty Island 616,194 97% 97 / 97 97 / 97 97 / 97 97 / 97 97 / 97 97 / 97

8 Lynn Canal 163,380 97% 97 / 67 97 / 67 97 / 67 97 / 67 97 / 67 97 / 67

9 North Coast Range 323,340 100% 100 / 67 100 / 67 100 / 67 100 / 67 100 / 67 100 / 67

10 Kupreanof/Mitkof 

Island

345,548 89% 87 / 39 87 / 39 87 / 39 87 / 39 87 / 39 87 / 39

11 Kuiu Island 319,805 91% 90 / 63 90 / 63 90 / 63 90 / 63 90 / 63 90 / 63

12 Central Coast 

Range

252,770 97% 97 / 68 97 / 68 97 / 68 97 / 68 97 / 68 97 / 68

13 Etolin Island &

Vicinity

259,670 85% 83 / 40 83 / 40 83 / 40 83 / 40 83 / 40 83 / 40

14 North Central Prince

of Wales

656,064 74% 72 / 41 72 / 41 72 / 41 72 / 41 72 / 41 72 / 41

15 Revilla Island/

Cleveland Pen.

551,164 91% 90 / 62 90 / 62 90 / 62 90 / 62 90 / 62 90 / 62

16 Southern Outer 

Islands

130,013 86% 85 / 69 85 / 69 85 / 69 85 / 69 85 / 69 85 / 69

17 Dall Island and 

Vicinity

68,179 98% 98 / 84 98 / 84 98 / 84 98 / 84 98 / 84 98 / 84

18 South Prince of 

Wales

155,116 97% 97 / 68 97 / 68 97 / 68 97 / 68 97 / 68 97 / 68

19 North Misty Fiords 204,462 97% 97 / 90 97 / 90 97 / 90 97 / 90 97 / 90 97 / 90

20 South Misty Fiords 311,463 99% 99 / 99 99 / 99 99 / 99 99 / 99 99 / 99 99 / 99

21 Ice Fields 123,567 95% 95 / 79 95 / 79 95 / 79 95 / 79 95 / 79 95 / 79

Forest-wide 5,473,612 91% 91 / 67 91 / 67 91 / 67 91 / 67 91 / 67 91 / 67 1 Reserves include all Non-Development LUDs, which are considered all LUDs other than Timber Production, Modified Landscape, 

Scenic Viewshed, and Experimental Forest. 

2 Numbers may not appear to sum correctly due to rounding.

Source: Data are from USDA Forest Service 2018 GIS and modeled projected harvest.
Environment and Effects 3

Final EIS 3-78 Key Issue 3

Table 3.3-8

Estimated Percent of Original High-Volume POG Remaining (Total and in Reserves1) after 100 

Years by Biogeographic Province and Alternative (NFS lands only)

2

% Original High-Volume POG Remaining after 100+ Years

(Total / In Reserves) by Alternative

No.

Biogeographic

Province

Original HighVol. POG

Acres

% Remaining

in 2018 Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

1 Yakutat Forelands 61,218 96% 96 / 70 96 / 70 96 / 70 96 / 70 96 / 70 96 / 70

2 Yakutat Uplands 15,306 93% 93 / 90 93 / 90 93 / 90 93 / 90 93 / 90 93 / 90

3 East Chichagof 

Island 191,803 83% 82 / 49 82 / 49 82 / 49 82 / 49 82 / 49 82 / 49

4 West Chichagof 

Island 18,467 100% 100 / 100 100 / 100 100 / 100 100 / 100 100 / 100 100 / 100

5 East Baranof Island 40,161 75% 75 / 41 75 / 41 75/ 41 75/ 41 75/ 41 75/ 41

6 West Baranof Island 68,308 81% 81 / 70 81 / 70 81 / 70 81 / 70 81 / 70 81 / 70

7 Admiralty Island 317,296 95% 95 / 95 95 / 95 95 / 95 95 / 95 95 / 95 95 / 95

8 Lynn Canal 65,066 94% 94 / 63 94 / 63 94 / 63 94 / 63 94 / 63 94 / 63

9 North Coast Range 137,808 100% 100 / 66 100 / 66 100 / 66 100 / 66 100 / 66 100 / 66

10 Kupreanof/Mitkof 

Island 134,526 79% 76 / 37 76 / 37 76 / 37 76 / 37 76 / 37 76 / 37

11 Kuiu Island 183,991 89% 88 / 59 88 / 59 88 / 59 88 / 59 88 / 59 88 / 59

12 Central Coast 

Range 114,517 96% 95 / 67 95/ 67 95 / 67 95 / 67 95 / 67 95 / 67

13 Etolin Island &

Vicinity 109,459 74% 71 / 34 71 / 34 71 / 34 71 / 34 71 / 34 71 / 34

14 North Central Prince

of Wales 353,636 64% 61 / 37 61 / 37 62 / 37 62 / 37 62 / 37 62 / 37

15 Revilla Island/

Cleveland Pen. 268,219 87% 85 / 60 85 / 60 85 / 60 85 / 60 85 / 60 85 / 60

16 Southern Outer 

Islands 61,869 78% 77 / 59 77 / 59 77 / 59 77 / 59 77 / 59 77 / 59

17 Dall Island and 

Vicinity 34,442 97% 97 / 86 97 / 86 97 / 86 97 / 86 97 / 86 97 / 86

18 South Prince of 

Wales 75,039 96% 95 / 67 95 / 67 95 / 67 95 / 67 95 / 67 95 / 67

19 North Misty Fiords 71,302 93% 93 / 86 93 / 86 93 / 86 93 / 86 93 / 86 93 / 86

20 South Misty Fiords 101,274 98% 98 / 98 98 / 98 98 / 98 98 / 98 98 / 98 98 / 98

21 Ice Fields 43,245 88% 88 / 76 88 / 76 88 / 76 88 / 76 88 / 76 88 / 76

Forest-wide 2,466,951 86% 85 / 62 85 / 62 85 / 62 85/ 62 85 / 62 85 / 62 1 Reserves include all Non-Development LUDs, which are considered all LUDs other than Timber Production, Modified Landscape, 

Scenic Viewshed, and Experimental Forest. 

2 Numbers may not appear to sum correctly due to rounding.

Source: Data are from USDA Forest Service 2018 GIS and modeled projected harvest.
Environment and Effects 3

Final EIS 3-79 Key Issue 3

Table 3.3-9

Estimated Percent of Original Large-Tree POG Remaining (Total and in Reserves1) after 100 

Years by Biogeographic Province and Alternative (NFS lands only)

2

No.

Biogeographic

Province

% Original Large-Tree POG Remaining after 100+ Years

(Total / In Reserves) by Alternative

Original LargeTree POG 

Acres

% Remaining

in 2018 Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

1 Yakutat Forelands 45,054 98% 98 / 68 98 / 68 98 / 68 98 / 68 98 / 68 98 / 68

2 Yakutat Uplands 3,829 89% 89 / 83 89 / 83 89 / 83 89 / 83 89 / 83 89 / 83

3 East Chichagof 

Island

47,452 72% 72 / 49 72 / 49 72 / 49 72 / 49 72 / 49 72 / 49

4 West Chichagof 

Island

2,021 100% 100 / 100 100 / 100 100 / 100 100 / 100 100 / 100 100 / 100

5 East Baranof Island 6,010 33% 33 / 20 33 / 20 33 / 20 33 / 20 33 / 20 33 / 20

6 West Baranof Island 9,149 45% 45 / 39 45 / 39 45 / 39 45 / 39 45 / 39 45 / 39

7 Admiralty Island 103,833 94% 94 / 94 94 / 94 94 / 94 94 / 94 94 / 94 94 / 94

8 Lynn Canal 13,564 88% 88 / 58 88 / 58 88 / 58 88 / 58 88 / 58 88 / 58

9 North Coast Range 22,543 99% 99 / 65 99 / 65 99 / 65 99 / 65 99 / 65 99 / 65

10 Kupreanof/Mitkof 

Island

30,856 64% 59 / 31 58 / 31 58 / 31 59 / 31 59 / 31 59 / 31

11 Kuiu Island 42,841 81% 79 / 43 79 / 43 79 / 43 79 / 43 79 / 43 79 / 43

12 Central Coast 

Range

21,999 91% 90 / 60 91 / 60 90 / 60 90 / 60 90 / 60 90 / 60

13 Etolin Island &

Vicinity

24,030 52% 47 / 25 47 / 25 48 / 25 48 / 25 48 / 25 48 / 25

14 North Central Prince

of Wales

152,903 66% 64 / 40 65 / 40 65 / 40 65 / 40 65 / 40 65 / 40

15 Revilla Island/ 

Cleveland Pen.

45,791 69% 66 / 46 66 / 46 66 / 46 66 / 46 66 / 46 66 / 46

16 Southern Outer 

Islands

17,825 70% 68 / 48 68 / 48 69 / 48 69 / 48 69 / 48 69 / 48

17 Dall Island and 

Vicinity

8,293 95% 95 / 91 95 / 91 95 / 91 95 / 91 95 / 91 95 / 91

18 South Prince of 

Wales

40,090 97% 96 / 69 96 / 69 97 / 69 97 / 69 97 / 69 97 / 69

19 North Misty Fiords 14,606 87% 87 / 79 87 / 79 87 / 79 87 / 79 87 / 79 87 / 79

20 South Misty Fiords 14,810 95% 95 / 95 95 / 95 95 / 95 95 / 95 95 / 95 95 / 95

21 Ice Fields 7,876 75% 75 / 68 74 / 68 74 / 68 74 / 68 74 / 68 74 / 68

Forest-wide 675,375 79% 78 / 58 78 / 58 78 / 58 78 / 58 78 / 58 78 / 58

1 Reserves include all Non-Development LUDs, which are considered all LUDs other than Timber Production, Modified Landscape, 

Scenic Viewshed, and Experimental Forest. 

2 Numbers may not appear to sum correctly due to rounding.

Source: Data are from USDA Forest Service 2018 GIS and modeled projected harvest.

Alternative 2

This alternative would remove roadless designation from areas identified as roaded roadless, which 

would allow access to areas that already have a road system for harvest of old growth and existing young 

growth. In addition, although 142,000 acres would have the roadless designation removed, about 110,000 

acres would have the roadless designation added, resulting in a net decrease in roadless area of 32,000 

acres.

Suitable high-volume POG and suitable large-tree POG base would increase by about 7,000 acres (8 

percent) and 900 acres (3 percent), respectively (relative to Alternative 1). However, the proportion of 

high-volume and large-tree POG in the added suitable acres under Alternative 2 is lower than in the 

Alternative 1 suitable acres.
Environment and Effects 3

Final EIS 3-80 Key Issue 3

Implementation of the Forest Plan under Alternative 2 would have harvest levels similar to the level 

projected under Alternative 1, the current Forest Plan, about 42,500 acres of old growth and 284,000 

acres of young growth over 100 years. The total suitable acres of young growth would increase by about 

11,000 acres or about 3 percent relative to Alternative 1 and medium-to-high-volume old-growth suitable 

acres would increase by about 14,000 acres or about 9 percent.

Harvest of young growth in RMAs, beach fringe, and Old-growth Habitat LUD would remain restricted to 

the first 15 years and under restrictive harvest prescriptions. The suitable young-growth acres in these 

three special areas would change by 1 to 3 percent, relative to Alternative 1. Because of the restrictive 

prescriptions required in these areas, they are harvested at a lower rate than other young-growth areas. 

Therefore, there would be little to no difference in the amount of young-growth harvest in RMAs, beach 

fringe, or Old-growth Habitat LUDs under Alternative 2. 

Table 3.3-6 shows the projected harvest by biogeographic province over the next 100 years of Forest 

Plan implementation. Assuming full implementation of the Forest Plan after 100 years, approximately 91 

percent of the original total POG, 85 percent of the original high-volume POG, and 78 percent of the 

original large-tree POG would be maintained on the Tongass National Forest (Tables 3.3-7, 3.3-8, and 

3.3-9). By biogeographic province, 72 to 100 percent of the original total, 61 to 100 percent of the original 

high-volume, and 33 to 100 percent of the original large-tree POG would be maintained. The reduction of 

biological diversity associated with old-growth forest and fragmentation would be greatest in the 

Kupreanof/Mitkof Island, Etolin Island & Vicinity, and North Central Prince of Wales biogeographic 

provinces, where the amount of POG remaining is estimated to be reduced by 2 percent over 100 years. 

Under Alternative 2, the overall harvest level would be maintained, but the distribution of harvest could be 

slightly different. Based on our projected harvest for Alternative 2, the provinces where old-growth harvest 

is likely to increase by 200 acres or more over 100 years (relative to Alternative 1) are Kupreanof/Mitkof 

Island and Revilla Island/Cleveland Peninsula. Harvest in seven provinces is expected to decline. 

Because the projected increases in harvest over 100 years are less than 700 acres in each province, 

overall effects are not expected to be significantly different from Alternative 1. 

As noted previously, fragmentation can be caused by timber harvest, road building, and powerline and 

facility development. Under Alternative 2, there would be little change in the distribution of timber harvest, 

roads, and other facilities relative to Alternative 1. After 100+ years of Alternative 2 implementation, there 

would be two fewer intact watersheds considering NFS lands only. This means 71.3 percent of the 922 

large watersheds containing POG forest would remain intact or the same percentage as under Alternative 1. 

Therefore, overall, impacts due to fragmentation and the Old-growth Habitat Conservation Strategy are 

expected to be minor and are not expected to be noticeably different from Alternative 1 (existing Forest 

Plan).

Alternative 3

This alternative would remove roadless designation from areas identified as roaded roadless and include 

areas identified as logical extensions of existing roads. Alternative 3 would be less protective because it 

would result in a net reduction of approximately 1.1 million total acres of roadless designations but would 

still rank relatively high overall because it would maintain substantial roadless designations within 

development LUDs. Approximately 3.3 million acres would be managed under a Watershed Priority ARA, 

4.6 million acres would be managed under a Roadless Priority designation, and 0.4 million acres would 

be managed under a Community Priority ARA. In addition, Alternative 3 would designate 0.5 million acres 

of T77 and TNC/Audubon Conservation Priority Areas outside of roadless to have long-term protection 

from old-growth harvest under the ARA. The majority of lands removed from roadless designation are 

managed as LUD II lands, which are intended to be managed in a roadless state to retain their wildland 

character (see current Forest Plan, Land Use Designation II goal description). Therefore, the roadless 

designation on LUD II lands provides little additional protection of roadless characteristics. 

Implementation of the Forest Plan under Alternative 3 would have harvest levels similar to the levels 

projected under Alternative 1, the current Forest Plan; about 42,500 acres of old growth and 284,000 

acres of young growth over 100 years. The total suitable acres of young growth would increase by about 
Environment and Effects 3

Final EIS 3-81 Key Issue 3

15,000 acres or about 4 percent relative to Alternative 1, and suitable old-growth acres would increase by 

about 85,000 acres or about 34 percent relative to Alternative 1.

Suitable high-volume POG and suitable large-tree POG would increase by about 30,000 acres (31 

percent) and 5,000 acres (15 percent) relative to Alternative 1, respectively. There could be a very slight 

increase in high-volume and large-tree POG harvested under Alternative 3 than was predicted for the 

Forest Plan because of increased options for creating positive timber sales. However, this is speculative 

and also depends on harvest levels reaching predicted decadal levels, as well as on being able to 

economically access these stands. In addition, the proportion of high-volume and large-tree POG in the 

added suitable acres under Alternative 3, is lower than the proportion in the Alternative 1 suitable acres.

Harvest of young growth in RMAs, beach fringe, and Old-growth Habitat LUD would remain restricted to 

the first 15 years and under restrictive harvest prescriptions. The suitable young growth acres in these 

three special areas would increase by 1 to 5 percent, relative to Alternative 1. Because of the restrictive 

prescriptions required in these areas, they are harvested at a lower rate than other young-growth areas. 

Therefore, there would be little to no difference in the amount of young-growth harvest in RMAs, beach 

fringe, or Old-growth Habitat LUDs under Alternative 3.

Table 3.3-6 shows the projected harvest by biogeographic province over the next 100 years of Forest 

Plan implementation. Assuming full implementation of the Forest Plan for 100 years, approximately 91 

percent of the original total POG, 85 percent of the original high-volume POG, and 78 percent of the original 

large-tree POG would be maintained on the Tongass National Forest under Alternative 3 (Tables 3.3-7, 3.3-

8, and 3.3-9). By biogeographic province, 72 to 100 percent of the original total POG, 62 to 100 percent of 

the original high-volume POG, and 33 to 100 percent of the original large-tree POG would be maintained. 

The reduction of biological diversity associated with old-growth forest and fragmentation would be 

greatest in the Kupreanof/Mitkof Island, Etolin Island & Vicinity, and North Central Prince of Wales 

biogeographic provinces, where the amount of POG remaining is estimated to be reduced by 2 percent 

over 100 years. Under Alternative 3, the overall harvest level would be maintained, but the distribution of 

harvest could be different. The provinces where harvest is likely to increase more than 200 acres over 100 

years relative to Alternative 1 include Kupreanof/Mitkof Island, Central Coast Range, and Revilla 

Island/Cleveland Peninsula. Harvest in eight provinces is expected to decline. The projected increases in 

harvest acres over 100 years relative to Alternative 1 are less than 600 acres in every province except for 

Kupreanof/Mitkof Islands, which would have an increase of 1,100 acres. Therefore, overall effects are 

expected to be relatively minor, with greater effects in the Kupreanof/Mitkof Islands province. 

As noted previously, fragmentation can be caused by timber harvest, road building, and powerline and 

facility development. Under Alternative 3, there would be little change in the distribution of timber harvest, 

roads, and other facilities relative to Alternative 1. After 100+ years of Alternative 3 implementation, there 

would be three fewer intact watersheds considering NFS lands only. This means 71.1 percent of the 922 

large watersheds containing POG forest would remain intact; one less watershed than under Alternative 

1. Therefore, overall, impacts due to fragmentation and on the Old-growth Habitat Conservation Strategy 

are expected to be relatively minor and are not expected to be noticeably different from Alternative 1 

(existing Forest Plan).

Alternative 4

This alternative would remove the roadless designation on areas identified as roaded roadless, on areas 

identified as logical extensions of existing roads, and on some additional acres of development LUDs. 

Alternative 4 would be substantially less protective than Alternative 3 but would still include a high number 

of roadless acres within development LUDs. However, 757,000 of these roadless acres are designated as 

Timber Priority, which provides little or no protection of roadless characteristics; timber harvest and road 

construction and reconstruction to facilitate timber management and provide economic opportunity are 

allowed with few additional constraints.

Implementation of the Forest Plan under Alternative 4 would have harvest levels similar to the level 

projected under Alternative 1, the current Forest Plan, about 42,500 acres of old growth and 284,000 

acres of young growth over 100 years. The total acres of suitable young growth would increase by about 
Environment and Effects 3

Final EIS 3-82 Key Issue 3

15,000 acres or about 5 percent relative to Alternative 1 and suitable old-growth acres would increase by 

about 161,000 acres or about 71 percent.

Suitable high-volume POG and suitable large-tree POG base would increase by about 57,000 acres (49 

percent) and 9,000 acres (30 percent) relative to Alternative 1, respectively,. There could be a slight 

increase in high-volume and large-tree POG harvested under Alternative 4 than was predicted for the 

Forest Plan because of increased options for creating positive timber sales. However, this is speculative

and also depends on harvest levels reaching predicted decadal levels, as well as on being able to 

economically access these stands. In addition, the proportion of high-volume and large-tree POG in the 

added suitable acres under Alternative 4, is lower than the proportion in the Alternative 1 suitable acres.

Harvest of young growth in RMAs, beach fringe, and Old-growth Habitat LUD would remain restricted to 

the first 15 years and under restrictive harvest prescriptions. The suitable young growth acres in these 

three special areas would change by 1 percent to 4 percent, relative to Alternative 1. Because of the 

restrictive prescriptions required in these areas, they are harvested at a lower rate than other younggrowth areas. Therefore, there would be little to no difference in the amount of young-growth harvest in 

RMAs, beach fringe, or Old-growth Habitat LUDs under Alternative 4.

Table 3.3-6 shows the projected harvest by biogeographic province over the next 100 years of Forest 

Plan implementation. Assuming full implementation of the Forest Plan for 100 years, approximately 91 

percent of the original total POG, 85 percent of the original high-volume POG, and 78 percent of the 

original large-tree POG would be maintained on the Tongass National Forest under Alternative 4 (Tables 

3.3-7, 3.3-8, and 3.3-9). By biogeographic province, 72 to 100 percent of the original total, 62 to 100 

percent of the original high-volume, and 33 to 100 percent of the original large-tree POG would be 

maintained. The reduction of biological diversity associated with old-growth forest and fragmentation

would be greatest in the Kupreanof/Mitkof Island, Etolin Island & Vicinity, and North Central Prince of 

Wales biogeographic provinces, where the amount of POG remaining is estimated to be reduced by 2 to 

over 100 years. Under Alternative 4, the overall harvest level would be maintained, but the distribution of 

harvest could be different. The provinces where harvest is likely to increase more than 200 acres over 

100 years relative to Alternative 1 include Kupreanof/Mitkof Islands, Central Coast Range, and Revilla 

Island/Cleveland Peninsula. Harvest in the other provinces would remain at the same level or decline. 

The projected increases in old-growth harvest acres relative to Alternative 1 are 1,000 acres or less in 

each province.

As noted previously, fragmentation can be caused by timber harvest, road building, and powerline and 

facility development. Under Alternative 4, there would be some change in the distribution of timber 

harvest, roads, and other facilities relative to Alternative 1. Under this alternative, roads and timber 

harvest are likely to penetrate further into currently roadless areas than under Alternatives 1, 2, or 3, 

resulting in a greater degree of fragmentation. After 100+ years of Alternative 4 implementation, there 

would be five fewer intact watersheds considering NFS lands only. This means 70.9 percent of the 922 

large watersheds containing POG forest would remain intact, three fewer watersheds than under 

Alternative 1. Nevertheless, because overall harvest levels would not change relative to Alternative 1, the 

effects due to fragmentation and on the Old-growth Habitat Conservation Strategy are expected to be 

relatively low and slightly greater than expected under Alternative 1 (existing Forest Plan).

Alternative 5

Under Alternative 5, approximately 7.0 million acres would be maintained and managed as Roadless 

Priority or LUD II Priority. Roadless designations would be removed on all development LUDs and mineral 

overlay areas and, as a result, it would rank the second lowest in terms of roadless designations. 

However, it would still be moderate in terms of overall protection due to the degree of protections 

provided by the underlying Forest Plan LUDs and Forest Plan standards and guidelines, which would not 

change.

Implementation of the Forest Plan under Alternative 5 would have harvest levels similar to the level 

projected under Alternative 1, the current Forest Plan, about 42,500 acres of old growth and 284,000 

acres of young growth over 100 years. The total suitable acres of young growth would increase by about 
Environment and Effects 3

Final EIS 3-83 Key Issue 3

17,000 acres or about 5 percent relative to Alternative 1 and suitable old-growth acres would increase by 

about 96,000 acres or about 62 percent.

Suitable high-volume POG and suitable large-tree POG would increase by about 60,000 acres (62 

percent) and 10,000 acres (32 percent), respectively, relative to Alternative 1. There could be a slight 

increase in high-volume and large-tree POG harvested under Alternative 5 than was predicted for the 

Forest Plan because of increased options for creating positive timber sales. However, this is speculative 

and also depends on harvest levels reaching predicted decadal levels, as well as on being able to 

economically access these stands. In addition, the proportion of high-volume and large-tree POG in the 

added suitable acres under Alternative 5 is lower than the proportion in the Alternative 1 suitable acres.

Harvest of young growth in RMAs, beach fringe, and Old-growth Habitat LUD would remain restricted to 

the first 15 years and under restrictive harvest prescriptions. The suitable young-growth acres in these 

three special areas would increase by 3 to 5 percent, relative to Alternative 1. Because of the restrictive 

prescriptions required in these areas, they are harvested at a lower rate than other young-growth areas. 

Therefore, there would be little to no differences in the amount of young-growth harvest relative to 

Alternative 1 in RMAs, beach fringe, or Old Growth Habitat LUDs under Alternative 5.

Table 3.3-6 shows the projected harvest by biogeographic province over the next 100 years of Forest 

Plan implementation. Assuming full implementation of the Forest Plan for 100 years, approximately 91 

percent of the original total POG, 85 percent of the original high-volume POG, and 78 percent of the 

original large-tree POG would be maintained on the Tongass under Alternative 1 (Tables 3.3-7, 3.3-8, 

and 3.3-9). By biogeographic province, 72 to 100 percent of the original total, 62 to 100 percent of the 

original high-volume, and 33 to 100 percent of the original large-tree POG would be maintained. The 

reduction of biological diversity associated with old-growth forest and fragmentation would be greatest in 

the Kupreanof/Mitkof Island, Etolin Island & Vicinity, and North Central Prince of Wales biogeographic 

provinces, where the amount of POG remaining is estimated to be reduced by 2 percent over 100 years. 

Under Alternative 5, the overall harvest level would be maintained, but the distribution of harvest could be 

different. Assuming harvest patterns follow the distribution of suitable old growth, the provinces where 

harvest is likely to increase more than 200 acres over 100 years include Kupreanof/Mitkof Islands, 

Central Coast Range, and Revilla Island/Cleveland Peninsula. The projected increases in old-growth 

harvest acres relative to Alternative 1 are 1,000 acres or less in each province. As noted previously, 

fragmentation can be caused by timber harvest, road building, and powerline and facility development. 

Under Alternative 5, there would be some change in the distribution of timber harvest, roads, and other 

facilities relative to Alternative 1. Under this alternative, roads and timber harvest are likely to penetrate 

much farther into currently roadless areas than under Alternatives 1, 2, or 3, resulting in a greater degree 

of fragmentation. After 100+ years of Alternative 5 implementation, there would be five fewer intact 

watersheds considering NFS lands only. This means 70.9 percent of the 922 large watersheds containing 

POG forest would remain intact, three fewer watersheds than under Alternative 1. Nevertheless, because 

overall harvest levels would not change relative to Alternative 1 and because the broader Old-growth 

Habitat Conservation Strategy for the Tongass was developed prior to the roadless rule and would be 

maintained under the Forest Plan, the effects due to fragmentation and on the Old-growth Habitat 

Conservation Strategy are expected to be relatively low and slightly greater than projected under 

Alternative 1 (existing Forest Plan).

Alternative 6

Whereas the roadless rule language under Alternatives 2, 3, 4, and 5 would be modified, all regulatory 

roadless designations would be removed from the Tongass under Alternative 6 and, therefore, it would 

rank the lowest in terms of roadless designations and any additional protections due to roadless. 

However, it would still be moderate in terms of overall protection due to the underlying Forest Plan LUDs 

and Forest Plan standards and guidelines, which would not change.

Implementation of the Forest Plan under Alternative 6 would have harvest levels similar to the level 

projected under Alternative 1, the current Forest Plan, about 42,500 acres of old growth and 284,000 

acres of young growth over 100 years. The total suitable acres of young growth would increase by about 
Environment and Effects 3

Final EIS 3-84 Key Issue 3

20,000 acres or about 6 percent relative to Alternative 1 and suitable old-growth acres would increase by 

about 168,000 acres or about 74 percent.

Suitable high-volume POG and suitable large-tree POG would increase by about 60,000 acres (62 

percent) and 10,000 acres (32 percent), respectively, relative to Alternative 1. There could be a slight 

increase in high-volume and large-tree POG harvested under Alternative 6 than was predicted for the 

Forest Plan because of increased options for creating positive timber sales. However, this is speculative 

and also depends on harvest levels reaching predicted decadal levels, as well as on being able to 

economically access these stands. In addition, the proportion of high-volume and large-tree POG in the 

added suitable acres under Alternative 6 is lower than the proportion in the Alternative 1 suitable acres.

Harvest of young growth in RMAs, beach fringe, and Old-growth Habitat LUD would remain restricted to 

the first 15 years and under restrictive harvest prescriptions. The suitable young-growth acres in these 

three special areas would increase by 6 percent in RMAs and beach fringe relative to Alternative 1, but by 

12 percent in Old-growth Habitat LUDs, which is the largest increase among the action alternatives. 

Because of the restrictive prescriptions required in these areas, they are harvested at a lower rate than 

other young-growth areas. Therefore, there would be minor differences in the amount of young-growth 

harvest relative to Alternative 1 in RMAs, beach fringe, or Old-growth Habitat LUDs under Alternative 6.

Table 3.3-6 shows the projected harvest by biogeographic province over the next 100 years of Forest 

Plan implementation. Assuming full implementation of the Forest Plan for 100 years, approximately 91 

percent of the original total POG, 85 percent of the original high-volume POG, and 78 percent of the 

original large-tree POG would be maintained on the Tongass under Alternative 1 (Tables 3.3-7, 3.3-8, 

and 3.3-9). By biogeographic province, 72 to 100 percent of the original total, 62 to 100 percent of the 

original high-volume, and 33 to 100 percent of the original large-tree POG would be maintained. The 

reduction of biological diversity associated with old-growth forest and fragmentation would be greatest in 

the Kupreanof/Mitkof Island, Etolin Island & Vicinity, and North Central Prince of Wales biogeographic 

provinces, where the amount of POG remaining is estimated to be reduced by 2 percent over 100 years. 

Under Alternative 6, the overall harvest level would be maintained, but the distribution of harvest could be 

different. The provinces where harvest is likely to increase more than 200 acres over 100 years include 

Kupreanof/Mitkof Islands, Central Coast Range, and Revilla Island/Cleveland Peninsula. The projected 

increases in old-growth harvest acres relative to Alternative 1 are 1,000 acres or less in each province.

As noted previously, fragmentation can be caused by timber harvest, road building, and powerline and 

facility development. Under Alternative 6, there would be some change in the distribution of timber 

harvest, roads, and other facilities relative to Alternative 1. Under this alternative, roads and timber 

harvest are likely to penetrate much farther into currently roadless areas than under Alternatives 1, 2, or 

3, resulting in a greater degree of fragmentation. After 100+ years of Alternative 6 implementation, there 

would be five fewer intact watersheds considering NFS lands only. This means 70.9 percent of the 922 

large watersheds containing POG forest would remain intact; three fewer watersheds than under 

Alternative 1. Nevertheless, because overall harvest levels would not change relative to Alternative 1 and 

because the broader Old-growth Habitat Conservation Strategy for the Tongass was developed prior to 

the roadless rule and would be maintained under the Forest Plan, the effects due to fragmentation and on 

the Old-growth Habitat Conservation Strategy are expected to be relatively low and slightly greater than 

projected under Alternative 1 (existing Forest Plan).

Cumulative Effects

The cumulative effects analysis for old-growth ecosystem biological diversity takes into account all of 

Southeast Alaska, including all lands within the Tongass boundary from the Yakutat area to the south of 

Ketchikan, the area of Glacier Bay National Park, and the areas around Haines and Skagway, as well as 

non-NFS lands. A list of all projects considered in the cumulative effects analysis is provided in Appendix 

B of this FEIS.

Approximately 874,000 acres of POG have been harvested across the Tongass, including both NFS 

lands and non-NFS lands, resulting in a reduction to 86, 78, and 67 percent of the original total, highvolume, and large-tree POG in Southeast Alaska, respectively (Tables 3.3-10, 3.3-11, and 3.3-12). 

Approximately 82 percent of the original POG would remain on the Tongass after full implementation of 
Environment and Effects 3

Final EIS 3-85 Key Issue 3

the 2016 Forest Plan (Alternative 1) and future non-NFS harvest in 100+ years. Future representation of 

high-volume POG and large-tree POG would be expected to be approximately 75 and 62 percent of the 

original amount, respectively, after 100+ years under the 2016 Forest Plan. These same percentages of 

original POG, high-volume POG, and large-tree POG would result under all of the other actions 

alternatives as well (Tables 3.3-10, 3.3-11, and 3.3-12).

Harvest associated with all action alternatives would contribute to the cumulative reduction in POG and 

associated increase in fragmentation and loss of connectivity, which has the potential to reduce biological 

diversity. Timber harvest on non-NFS lands would result in similar effects; however, it would not 

contribute above what was analyzed for the current Forest Plan. Collectively, the implementation of the 

Forest Plan under all of the alternatives in combination with ongoing and foreseeable projects would 

increase the number of smaller patches on the landscape, reducing the amount of interior forest and 

increasing the occurrence of forest edge habitat. Edge effects such as shifts in species composition may 

reduce natural biological diversity over time by favoring some species over others; however, effects would 

be lessened by the Forest Plan, including the action alternatives, which continue to propose a transition to 

predominantly young-growth harvest. This would reduce the long-term cumulative effects to old-growth 

ecosystem diversity by reducing the total amount of POG harvest and associated fragmentation. Note 

that the actual amount of timber harvest that has occurred on the Tongass since the 2016 Forest Plan 

was adopted is less than that projected under the Forest Plan Amendment EIS, and may continue to be 

less under all of the alternatives (see the Timber section of this FEIS for additional discussion).

Overall, biological diversity on the Tongass and in Southeast Alaska remains in good condition and the 

landscape continues to be dominated by old-growth forest ecosystems. As development continues 

through timber harvest and associated activities such as road building, mining activities, energy 

development, and community expansion, particularly in areas where extensive development has already 

occurred (i.e., Prince of Wales Island), maintaining connectivity and roadless refugia will become 

increasingly important, particularly for wide-ranging species whose distribution depends on some level of 

connectivity across the landscape. In addition, the management of human resources will continue to play 

a role in maintaining biological diversity across the Tongass. Within the Tongass boundary, the Oldgrowth Habitat Conservation Strategy was designed to address the more extensive harvest on non-NFS 

lands through the OGR system and Forest-wide standards and guidelines, both of which were intended to 

maintain ecological components needed to maintain the ecological integrity important to a variety of 

organisms and maintain connectivity across the landscape, with or without much contribution from nonNFS lands. The overall Old-growth Habitat Conservation Strategy approach was developed prior to 

roadless designations and would be maintained regardless of the alternative selected.
Environment and Effects 3

Final EIS 3-86 Key Issue 3

Table 3.3-10

Cumulative Percent of Original Total POG Remaining on All Land Ownerships after

100 Years of Forest Plan Implementation by Biogeographic Province and Alternative 

(NFS and Non-NFS Lands)

No. Biogeographic Province

Estimated 

Original 

Total POG 

(Acres)

% Original 

Total POG 

Remaining 

Percent Total POG Remaining after 100+ Years1,2

Alternative

1 2 3 4 5 6

1 Yakutat Forelands 123,462 85% 80% 80% 80% 80% 80% 80%

2 Yakutat Uplands 45,250 97% 97% 97% 97% 97% 97% 97%

3 East Chichagof Island 507,906 84% 81% 81% 81% 81% 81% 81%

4 West Chichagof Island 72,949 100% 100% 100% 100% 100% 100% 100%

5 East Baranof Island 103,105 87% 86% 86% 86% 86% 86% 86%

6 West Baranof Island 247,391 92% 89% 89% 89% 89% 89% 89%

7 Admiralty Island 646,813 94% 93% 93% 93% 93% 93% 93%

8 Lynn Canal 180,194 97% 91% 91% 91% 91% 91% 91%

9 North Coast Range 382,563 94% 88% 88% 88% 88% 88% 88%

10 Kupreanof/Mitkof Island 407,318 82% 76% 76% 76% 76% 76% 76%

11 Kuiu Island 328,197 91% 89% 89% 89% 89% 89% 89%

12 Central Coast Range 259,656 97% 95% 95% 95% 95% 95% 95%

13 Etolin Island 276,170 85% 80% 80% 80% 80% 80% 80%

14 North Central Prince of 

Wales

905,793 63% 56% 56% 56% 56% 56% 56%

15 Revilla Island/ Cleveland 

Peninsula

646,595 88% 81% 81% 81% 81% 81% 81%

16 Southern Outer Islands 141,253 83% 80% 80% 80% 80% 80% 80%

17 Dall Island and Vicinity 135,694 68% 57% 57% 57% 57% 57% 57%

18 South Prince of Wales 192,225 88% 82% 82% 82% 82% 82% 82%

19 North Misty Fiords 207,639 96% 96% 96% 96% 96% 96% 96%

20 South Misty Fiords 311,749 99% 99% 99% 99% 99% 99% 99%

21 Ice Fields 123,674 95% 95% 95% 94% 94% 94% 94%

Total for Southeast 

Alaska3

6,245,598 86% 82% 82% 82% 82% 82% 82%

1 The estimate assumes all scheduled suitable POG is harvested; does not account for Model Implementation Reduction Factor 

(MIRF).

2 Based on an inventory of existing harvest on non-NFS lands and the estimation of future harvest by major landowner 

category. To estimate the future harvest of POG on non-NFS lands, it was assumed that 60 percent of the remaining POG 

would be harvested on non-NFS lands over the life of the Forest Plan (100 years). 3 Does not include land area in biogeographic provinces 22 and 23 which are almost exclusively non-NFS land.
Environment and Effects 3

Final EIS 3-87 Key Issue 3

Table 3.3-11

Cumulative Percent of Original High-Volume POG Remaining on All Land Ownerships 

after 100 Years of Forest Plan Implementation by Biogeographic Province and 

Alternative (NFS and Non-NFS Lands)

No. Biogeographic Province

Estimated 

Original 

High-Volume 

POG (Acres)

% Original 

High-Volume 

POG 

Remaining 

Percent Total POG Remaining after 100+ 

Years1,2

Alternative

1 2 3 4 5 6

1 Yakutat Forelands 74,593 83% 80% 80% 80% 80% 80% 80%

2 Yakutat Uplands 15,320 93% 93% 93% 93% 93% 93% 93%

3 East Chichagof Island 225,206 75% 72% 72% 72% 72% 72% 72%

4 West Chichagof Island 18,585 100% 100% 100% 100% 100% 100% 100%

5 East Baranof Island 40,498 75% 74% 74% 74% 74% 74% 74%

6 West Baranof Island 74,713 81% 77% 77% 77% 77% 77% 77%

7 Admiralty Island 334,413 91% 91% 91% 91% 91% 91% 91%

8 Lynn Canal 71,131 94% 89% 89% 89% 89% 89% 89%

9 North Coast Range 165,333 91% 86% 86% 86% 86% 86% 86%

10 Kupreanof/Mitkof Island 167,093 69% 63% 63% 63% 63% 63% 63%

11 Kuiu Island 187,270 89% 87% 87% 87% 87% 87% 87%

12 Central Coast Range 117,401 95% 94% 94% 94% 93% 93% 93%

13 Etolin Island 116,474 73% 68% 68% 68% 68% 68% 68%

14 North Central Prince of 

Wales

489,790 52% 47% 47% 47% 47% 47% 47%

15 Revilla Island/ Cleveland 

Peninsula

309,870 83% 77% 77% 77% 77% 77% 77%

16 Southern Outer Islands 67,840 74% 71% 71% 71% 71% 71% 71%

17 Dall Island and Vicinity 70,526 60% 53% 53% 53% 53% 53% 53%

18 South Prince of Wales 93,825 83% 79% 79% 79% 79% 79% 79%

19 North Misty Fiords 72,749 93% 92% 92% 92% 92% 92% 92%

20 South Misty Fiords 101,374 98% 98% 98% 98% 98% 98% 98%

21 Ice Fields 43,283 88% 88% 88% 88% 88% 88% 88%

Total for Southeast 

Alaska3

2,857,286 78% 75% 75% 75% 75% 75% 75%

1 The estimate assumes all scheduled suitable POG is harvested; does not account for Model Implementation Reduction 

Factor (MIRF).

2 Based on an inventory of existing harvest on non-NFS lands and the estimation of future harvest by major landowner 

category. To estimate the future harvest of POG on non-NFS lands, it was assumed that 60 percent of the remaining HighVolume POG would be harvested on non-NFS lands over the life of the Forest Plan (100 years). 

3 Does not include land area in biogeographic provinces 22 and 23 which are almost exclusively non-NFS land.
Environment and Effects 3

Final EIS 3-88 Key Issue 3

Table 3.3-12

Cumulative Percent of Original Large-tree POG Remaining on All Land Ownerships 

after 100 Years of Forest Plan Implementation by Biogeographic Province and 

Alternative (NFS and Non-NFS Lands)

No. Biogeographic Province

Estimated 

Original 

SD67 POG 

(Acres)

% Original 

SD67 POG 

Remaining 

Percent SD67 POG Remaining after 100+ 

Years1,2

Alternative

1 2 3 4 5 6

1 Yakutat Forelands 52,435 87% 85% 85% 85% 85% 85% 85%

2 Yakutat Uplands 3,836 89% 89% 89% 89% 89% 89% 89%

3 East Chichagof Island 65,766 60% 55% 55% 55% 55% 55% 55%

4 West Chichagof Island 2,079 100% 98% 98% 98% 98% 98% 98%

5 East Baranof Island 6,179 35% 33% 33% 33% 33% 33% 33%

6 West Baranof Island 12,466 52% 40% 40% 40% 40% 40% 40%

7 Admiralty Island 113,351 88% 87% 87% 87% 87% 87% 87%

8 Lynn Canal 16,624 89% 79% 79% 79% 79% 79% 79%

9 North Coast Range 37,325 77% 67% 67% 67% 67% 67% 67%

10 Kupreanof/Mitkof Island 48,782 49% 41% 41% 40% 41% 41% 41%

11 Kuiu Island 44,532 81% 77% 77% 77% 77% 77% 77%

12 Central Coast Range 23,512 89% 86% 86% 86% 86% 86% 86%

13 Etolin Island 27,723 53% 44% 44% 44% 44% 44% 44%

14 North Central Prince of 

Wales

228,293 51% 46% 46% 46% 46% 46% 46%

15 Revilla Island/ Cleveland 

Peninsula

67,855 64% 51% 51% 51% 51% 51% 51%

16 Southern Outer Islands 21,117 63% 59% 59% 59% 59% 59% 59%

17 Dall Island and Vicinity 28,203 44% 34% 34% 34% 34% 34% 34%

18 South Prince of Wales 50,353 83% 79% 79% 79% 79% 79% 79%

19 North Misty Fiords 15,380 85% 84% 84% 84% 84% 84% 84%

20 South Misty Fiords 14,860 95% 95% 95% 95% 95% 95% 95%

21 Ice Fields 7,895 75% 74% 74% 74% 74% 74% 74%

Total for Southeast 

Alaska3

888,563 67% 62% 62% 62% 62% 62% 62%

1 The estimate assumes all scheduled suitable POG is harvested; does not account for Model Implementation Reduction Factor 

(MIRF).

2 Based on an inventory of existing harvest on non-NFS lands and the estimation of future harvest by major landowner 

category. To estimate the future harvest of SD67 POG on non-NFS lands, it was assumed that 60 percent of the remaining 

SD67 POG would be harvested on non-NFS lands over the life of the Forest Plan (100 years). 3 Does not include land area in biogeographic provinces 22 and 23 which are almost exclusively non-NFS land.
Environment and Effects 3

Final EIS 3-89 Wildlife

Wildlife

Affected Environment

Wildlife species and their habitat on the Tongass were described in the 2016 Forest Plan Amendment EIS 

(USDA Forest Service 2016b). This section summarizes the wildlife resources, but updates that 

information to characterize the current affected environment and refers the reader to that document 

where relevant. The following subsections summarize the old-growth conservation strategy; threatened, 

endangered, and candidate species; Management Indicator Species (MIS); Alaska Region Sensitive 

Species; migratory birds; endemic species; and invasive species. Consumptive uses of wildlife on the 

Tongass are discussed in the Subsistence section.

Old-Growth Habitat and the Old-growth Habitat Conservation Strategy

Typical of Southeast Alaska, vegetation on the Tongass is dominated by temperate coastal rain forests at 

lower elevations (less than 2,000 feet elevation), with interspersed muskegs, other wetlands, and other 

non-forest types. At higher elevations, alpine vegetation, rock, glaciers, and snowfields dominate. 

Although many wildlife species on the Tongass are associated with more than one habitat type, most 

inhabit old-growth forests or prey on species that inhabit old-growth forests. Therefore, this analysis 

focuses on the old-growth forest ecosystem.

The reserve system of the Tongass Old-growth Habitat Conservation Strategy was first designed and 

implemented for the 1997 Forest Plan to maintain habitats of the old-growth associated and dependent 

species in a well-distributed and viable manner across the Tongass (see USDA Forest Service 2016b,

Appendix D). This strategy is described in greater detail, along with the Forest Plan standards and 

guidelines and the management of the matrix lands outside of reserves, in the Biological Diversity section 

of this FEIS.

There are currently approximately 5.0 million acres of POG forest on the Tongass, of which 2.1 million 

acres are high-volume POG including 0.53 million acres of large-tree POG. These existing acreages 

represent 91, 86, and 79 percent, respectively, of these forest types that existed in 1954, prior to the 

beginning of industrial-scale timber harvest (see Biological Diversity section; Table 3.3-4). There are 

approximately 0.56 million acres of young-growth forest on the Tongass, of which about 85 percent are a 

result of past harvest and 15 percent are natural young-growth. The Biological Diversity section briefly 

describes POG and other cover types and provides a discussion of past timber harvest on the Tongass 

(see also the Timber section).

Landscape Connectivity and Fragmentation

The concepts of landscape connectivity and fragmentation are described in the Biological Diversity

section but are summarized here as they relate to wildlife and their habitat requirements. On the Tongass, 

connectivity between areas of similar habitats (i.e., old-growth forest) or between high- and low-elevation 

habitats is important to maintaining well-distributed, viable wildlife populations of some species.

Fragmentation of suitable habitats across the landscape through both natural and human-caused actions 

reduces larger contiguous blocks of habitat into smaller patches, which may cause some species 

populations to become isolated, and therefore may pose a greater risk of local extirpation.

Wildlife Species

The following sections summarize information on threatened and endangered species, candidates for 

listing, MIS (1982 planning rule), Alaska Region sensitive species, and other species of interest that were 

analyzed in detail for the 2016 Forest Plan (USDA Forest Service 2016a). Table 3.3-13 provides a 

comprehensive list of the threatened, endangered, candidate, and sensitive bird, mammal and reptile 

species and identifies any updates of species listing status or occurrences since the completion of the 

2016 Forest Plan Amendment EIS. Threatened and endangered fish species are identified in the fish 

section of this analysis. Some species are grouped based on habitat similarities where possible or 
Environment and Effects 3

Final EIS 3-90 Wildlife

referenced back to the 2016 Forest Plan Amendment EIS, and corresponding Biological Assessment 

(BA), or Biological Evaluation (BE) for Wildlife and Fish as appropriate.

Threatened, Endangered, and Candidate Species

Federally listed threatened and endangered species are those plant and animal species formally listed by 

the U.S. Fish and Wildlife Service (USFWS) or National Marine Fisheries Service (NMFS) under authority 

of the Endangered Species Act of 1973 (ESA), as amended. Some federally-listed species in the table 

are not addressed further because the Tongass is outside of their known range or suitable habitat is not 

present (Table 3.3-13). Informal programmatic consultation was completed for the 2016 Tongass Plan 

Amendment. The NMFS reviewed the biological assessment for threatened and endangered species 

under their regulatory jurisdiction and concluded that the 2016 Forest Plan Amendment EIS was “not 

likely to adversely affect” threatened or endangered species occurring on the Tongass (NMFS 2016).

Also listed in the table are listed fish species that are addressed in the Fish section of this EIS. Currently, 

no candidates for federal listing occur within the boundary of the Tongass (Table 3.3-13).

Short-tailed Albatross

The short-tailed albatross is a pelagic seabird species that forages offshore and in shelf-break waters 

throughout the North Pacific Ocean and Bering Sea and is listed under the ESA as Endangered. The 

short-tailed albatross primarily breeds in Japan, but single nest sites have been documented on Midway 

Island, Hawaii.

Previously, the waters adjacent to the Tongass were thought to be outside of the range of this species; 

however, more recent satellite tracking indicates that albatrosses, particularly juveniles and sub-adult 

birds, travel to the west coast, including the outer coast of Southeast Alaska (USFWS 2014). This species 

may forage in nearshore waters adjacent to the outer coastal islands of the Tongass, particularly where 

the continental shelf break is close to shore. Changes to the roadless rule for Alaska are not the source of 

causation for any potential effects and will have no effect to the short-tailed albatross.

Threatened and Endangered Marine Mammals

The federally listed marine mammals that may occur in the waters adjacent to the Tongass National 

Forest include the sei whale (E), fin whale (E), humpback whale (T), sperm whale (E), and the Western 

DPS of the Stellar sea lion (E). The sei, fin, and sperm whales more typically occur in offshore marine 

waters of the Bering Sea, Chukchi Sea, North Pacific Ocean and/or Gulf of Alaska (NMFS 2009a) and are 

rare visitors to the waters surrounding the Tongass (Dahlheim et al. 2009).

The ESA for the State of Alaska authorizes the Commissioner of ADF&G to list Alaska endangered 

species. Species listed as endangered by the State of Alaska include humpback whale, right whale, and 

blue whale. With the exception of the humpback whale, none of these species occur in Southeast Alaska 

and therefore are not considered further here. Pursuant to Section 7 of the ESA, a BA was prepared to 

assess the effects of the 1997, 2008, and 2016 Forest Plans on endangered or threatened species and 

ensure that proposed actions would not jeopardize the continued existence of listed species (specifically, 

humpback whale and the Steller sea lion). Only the humpback whale and Steller sea lion will be 

addressed further in this document.
Environment and Effects 3

Final EIS 3-91 Wildlife

Table 3.3-13

Federally Listed Threatened and Endangered Species and Candidate Species under the 

ESA, Forest Service Alaska Region Sensitive Bird, Mammal, and Reptile Species with 

Potential for Occurrence on the Tongass National Forest1

Common 

Name Scientific Name Habitat Association

Potential for 

Occurrence in the 

Analysis Area Status2

ESA Species Under USFWS Jurisdiction

Eskimo curlew Numenius borealis Arctic tundra. No, outside of 

species’ range.

E

Short-tailed 

albatross

Phoebastria albatrus Winters in waters of the Bering 

Sea, Aleutian Islands, and Gulf of 

Alaska; breeds in Japan (USFWS 

2012a).

Yes, may occur in 

nearshore waters near 

islands and mainland 

coastlines of 

Southeast Alaska.

E

Spectacled 

eider

Somateria fischeri Coastal waters in northern and 

western Alaska (USFWS 2012b).

No, outside of 

species’ range.

T

Steller’s eider Polysticta stelleri Occurs in northern and western 

Alaska (USFWS 2012c).

No, outside of 

species’ range.

T

Polar bear Ursus maritimus Sea ice and coastlines of western 

Alaska and along the North 

Slope.

No, outside of 

species’ range.

T

ESA Species Under NMFS Jurisdiction

Blue whale Balaenoptera 

musculus

Off-shore (pelagic) marine waters 

of the Bering Sea, Chukchi Sea, 

North Pacific Ocean and/or Gulf 

of Alaska (NMFS 2009a). Critical 

habitat designated for North 

Pacific right whales in the Bering 

Sea and the Gulf of Alaska 

(NMFS 2009a).

No, very rarely 

observed in Southeast 

Alaska.

E

Beluga whale Delphinaperus leucas

Bowhead whale Balaena mysticetus

Northern Pacific 

right whale

Eubalaena japonica

Sei whale Balaenoptera borealis

Humpback 

Whale

Megaptera 

novaeangliae

Common in the inside waters of 

the Alexander Archipelago and 

are regularly sighted in the Inside 

Passage and coastal waters of 

the Southeast Alaska panhandle 

(NMFS 1991; Muto et al. 2018).

Yes, likely to occupy 

marine waters 

surrounding the 

Tongass. May occur 

in shallow coastal 

areas.

E

Fin whale Balaenoptera physalus Typically, off-shore (pelagic) 

marine waters of the Bering Sea, 

Chukchi Sea, North Pacific 

Ocean and/or Gulf of Alaska 

(NMFS 2009a); two more recent 

sightings in lower Clarence Strait 

(Dahlheim et al. 2009).

Yes, may occur 

seasonally in marine 

waters surrounding 

the Tongass, but in 

proximity to the open 

ocean.

E

Sperm whale Physeter 

macrocephalus

Typically, off-shore marine waters 

of the Bering Sea, Gulf of AK, 

Southeast AK and Aleutian 

Islands (Allen and Angliss 2014).

Yes, may occur 

seasonally in marine 

waters around 

Tongass, but in 

proximity to the open 

ocean.

E
Environment and Effects 3

Final EIS 3-92 Wildlife

Table 3.3-13 (continued)

Federally Listed Threatened and Endangered Species and Candidate Species under the 

ESA, Forest Service Alaska Region Sensitive Bird, Mammal, and Reptile Species with 

Potential for Occurrence on the Tongass National Forest1

Common 

Name Scientific Name Habitat Association

Potential for 

Occurrence in the 

Analysis Area Status2

Threatened or Endangered Species

Bearded seal Erignathus barbatus Sea-ice habitats in Bering Sea, 

Chukchi Sea, Beaufort seas (77 

FR 76740-76768, 77 FR 76706-

76738).

No, outside of species’ 

range.

T – bearded 

seal; T –

ringed seal Ringed Seal Phoca hispida

Northern sea 

otter, SW Alaska 

population

Enhydra lutris kenyoni Coastal marine habitats. No, outside of species 

range.

T

Steller sea lion 

– Western AK 

DPS3

Eumetopias jubatus Marine and terrestrial areas from 

Prince William Sound westward 

(west of 144° west longitude).

Yes, DPS occurs in 

waters surrounding 

the Tongass. Critical 

habitat has also been 

designated.

E

Green sea turtle Chelonia mydas Occur in the Gulf of Alaska and 

some species are found as far 

west as the Aleutian Islands. 

Adults are highly migratory, but 

the details and locations of 

migrations are largely unknown 

(NMFS 2009b).

No, only rarely 

observed in Southeast 

Alaska.

T

Loggerhead sea 

turtle

Caretta T

Olive Ridley sea 

turtle

Lepidochelys olivacea T

Leatherback 

sea turtle

Dermochelys coriacea E

Forest Service Alaska Region Sensitive Species4

Steller sea lion 

– Eastern AK 

DPS3

Eumetopias jubatus Marine and terrestrial areas in 

Southeast Alaska (east of 144° 

west longitude).

Yes, occurs in waters 

surrounding the 

Tongass.

S

Queen 

Charlotte 

goshawk

Accipiter gentiles laingi Mature/old-growth forests. Yes, known to occur 

on the Tongass.

S

Aleutian Tern Sterna aleutica Nests on islands, shrub-tundra, 

grass or sedge meadows and 

freshwater and coastal marshes.

Yes, known to occur 

on the Tongass.

S

Black 

oystercatcher

Haematopus bachmani Rocky shorelines along the 

coast; forages in sheltered areas 

where low-sloping gravel or rock 

beaches with abundant prey 

occur.

Yes, known to occur 

on the Tongass.

S

Kittlitz’s 

murrelet

Brachyramphus 

brevirostris

Breeds in the vicinity of glaciers 

and cirques in high elevation 

alpine areas with little or no 

vegetative cover; northern Gulf 

of Alaska and Bering Sea coast 

(Day et al. 1999).

Yes, known to occur 

on the Tongass.

S

1

Special status fish species are identified in the fisheries section of the analysis.

2

T = Federally threatened; E = Federally endangered; C = candidate for Federal listing; S = Alaska Region Sensitive Species 3 DPS = Distinct Population Segment.

4 Regional Forester’s Sensitive Species List (February 2009). The Steller sea lion Eastern DPS was added as a sensitive species 

after federal ESA delisting. The Western DPS remains federally endangered.

Humpback whales are currently listed as endangered under the ESA and have been protected since 

1965. Humpback whales generally migrate between temperate and tropical waters in the winter and 

spring where they mate and calve, and cooler northern coastal waters where they feed. Feeding occurs 

near the highly productive fjords of the Southeastern Alaskan panhandle and Prince William Sound, from 
Environment and Effects 3

Final EIS 3-93 Wildlife

approximately May through December, although some individuals can be seen every month of the year 

(Calkins 1986). Peak numbers of whales are usually found in nearshore waters during late August and 

September, but substantial numbers usually remain until early winter.

Humpbacks summering in Southeast Alaska have been linked to three wintering areas: the coastal 

waters along Baja California and mainland Mexico, the main islands of Hawaii, and the islands south of 

Japan (NMFS 1991). Those whales that feed in Southeast Alaska and migrate to Hawaii are referred to 

as the central North Pacific stock (Muto et al. 2018). The local distribution of humpbacks in Southeast 

Alaska appears to be correlated with the density and seasonal availability of prey, particularly herring 

(Clupea harengus) and euphausiids (small shrimp-like crustaceans such as krill), and adults consume up 

to 3,000 pounds a day outside the breeding season. Important feeding areas include Glacier Bay and 

adjacent portions of Icy Strait, Stephens Passage/Frederick Sound, Seymour Canal, and Sitka Sound.

Glacier Bay and Icy Strait appear to be an important feeding area early in the season, when whales prey 

heavily on herring and other small, schooling fishes. Frederick Sound is important later in summer, when 

whales feed on swarming euphausiids. During autumn and early winter, humpbacks move out of the 

Sound to areas where herring are abundant, particularly Seymour Canal. Other areas of Southeastern 

Alaska may also be important for humpbacks and need to be evaluated. These include Cape 

Fairweather, Lynn Canal, Sumner Strait, Dixon Entrance, the west coast of Prince of Wales Island, and 

offshore banks such as the Fairweather Grounds.

Recent estimates of the Central North Pacific stock of humpback whales found 1,115 unique 

identifications in Southeast Alaska and 583 in northern British Columbia, for a total of 1,669 individual 

whales (Calambokidis et al. 2008 [referred to as the SPLASH study]; Muto et al. 2018). From the 

SPLASH study, the estimates of abundance for Southeast Alaska/northern British Columbia ranged from 

2,883 to 6,414. The estimates from SPLASH are considerably larger than previous estimates. The 

population rate of increase was estimated at 7 percent for Pacific humpback whales (Muto et al. 2018).

Although the final rule for humpback whale ESA listing (81 FR 62259, 8 September 2016) established 14 

Distinct Population Segments (DPSs) with different listing statuses, the DPSs that occur in waters under 

the jurisdiction of the United States do not equate to the existing Marine Mammal Protection Act (MMPA) 

stocks. Some of the listed DPSs partially coincide with the currently defined Central North Pacific stock. 

Because NMFS cannot manage one portion of an MMPA stock as ESA-listed and another portion of a 

stock as not ESA-listed, until such time as the MMPA stock delineations are reviewed in light of the DPS 

designations and Bettridge et al. (2015), NMFS will continue to use the existing MMPA stock structure 

and considers this stock to be endangered and depleted for MMPA management purposes. As a result, 

the Central North Pacific stock continues to be classified as a strategic stock.

Humpback whales are regularly sighted in the Inside Passage and coastal waters of the Southeastern 

Alaska panhandle from Yakutat Bay south to Queen Charlotte Sound (USDA Forest Service 1997a). 

Because the humpback inhabits shallow coastal areas, it is increasingly exposed to human activity. 

Consequently, these whales may be more susceptible to confrontational disturbance, displacement, and 

loss of habitat from environmental degradation than some other whale species. Specifically, the greatest 

threats to humpback whales today are entanglements in fishing gear, ship strikes, and coastal habitat 

pollution.

Marine mammals are protected under the MMPA as well as the Forest Plan standards and guidelines that 

ensure protection and maintenance of whale habitats and that permitted or approved activities are 

conducted in a manner consistent with the MMPA, ESA, and NMFS regulations for approaching whales, 

dolphins, and porpoise. Changes to the roadless rule for Alaska are not the source of causation for any 

potential effects and will have no effect to the humpback whale.

Steller Sea Lion, Western and Eastern DPS

The Steller sea lion (Eumetopias jubatus) was emergency-listed as threatened under the ESA in April 

1990 by NMFS due to rapid population declines in the western portion of its range (55 FR 12645). In 

1997, the NMFS designated two DPSs, occurring west and east of 144 degrees west longitude, 

respectively. The western DPS includes Steller sea lions that originate from rookeries west of 144° west 

longitude (Cape Suckling): those in the Gulf of Alaska, the Aleutian Islands, the Bering Sea, and Asia. 
Environment and Effects 3

Final EIS 3-94 Wildlife

The eastern DPS includes sea lions originating from rookeries in Southeast Alaska, British Columbia, 

Washington, Oregon, and California. Due to persistent decline, the western DPS was reclassified as 

endangered, while the increasing eastern DPS was delisted in November 2013. On November 4, 2013, 

NMFS issued a final rule (78 FR 66140) to remove the eastern DPS of Steller sea lion from the List of 

Endangered and Threatened Wildlife. A speciesremoved from listing under the ESA because recovery 

criteria have been met will be automatically added to the Alaska Region Sensitive Species list for at least 

5 years (FSM 2672.11, R-10 2600-2005-1). Until the Alaska Region Sensitive Species list is updated, the 

Steller sea lion will continue to be analyzed as a sensitive species. The western DPS is analyzed as an 

endangered species. 

Steller sea lions are widely distributed over the continental shelf and throughout the coastal waters of the 

Gulf of Alaska. The Eastern DPS is known to occur in the waters surrounding the Tongass, although 

inter-migration between the eastern and western populations has been documented, particularly north of 

Frederick Sound.

Critical habitat was designated for the Steller sea lion (western DPS) by NMFS in 1993 and represents 

areas considered essential for the continued survival and recovery of this species (50 CFR 226.202). 

None of this critical habitat occurs in Southeast Alaska. Adult Steller sea lions congregate at rookeries for 

breeding and pupping which are generally located on relatively remote islands, often in exposed areas 

that are not easily accessed by humans or mammalian predators. These rookeries, as well as haulouts, 

have been officially designated as critical habitat in Southeast Alaska (50 CFR 226.202).

To date, 3 major rookeries and 11 major haulouts have been identified as critical habitat on or adjacent to 

the Tongass. Two additional haulouts have been identified in Southeast Alaska (Cape Fairweather and 

Graves Rock) but these locations are within Glacier Bay National Park. In light of the delisting of the 

Eastern DPS and listing of the Western DPS as endangered, as well as availability of new science, NMFS 

is currently conducting a review of critical habitat for this species.

Steller sea lions are sensitive to disturbance and harassment or displacement from haulouts and 

rookeries. Human activities such as boating, recreation, aircraft, log transfer facilities (LTFs), and log raft 

towing are concerns related to the long-term conservation of the sea lion in Southeast Alaska (Muto et al. 

2018). Forest Plan standards and guidelines for Steller sea lions provide protection to sea lion habitats 

and regulate activities in proximity to this species (USDA Forest Service 2016a; WILD 1-Section X and 

WILD 4-Section A). Steller sea lions are also protected by the MMPA.

Changes to the roadless rule for Alaska are not the source of causation for any potential effects and will 

have no effect to the western DPS of the Steller sea lion or designated critical habitat.

Alaska Region Sensitive Species

The Alaska Region Sensitive Species list was updated in 2009 and supersedes previous lists (USDA 

Forest Service 2009a). The current Alaska Region Sensitive Species list for animal species that occur on 

the Tongass includes the Queen Charlotte goshawk, Kittlitz’s murrelet, black oystercatcher, Aleutian tern, 

and Steller sea lion (Eastern DPS), which was discussed above.

Although not on the 2009 list, the Steller sea lion (Eastern DPS) is now an Alaska Region Sensitive 

Species. On November 4, 2013, NMFS issued a final rule (78 FR 66140) to remove the Eastern DPS of 

Steller sea lion from the List of Endangered and Threatened Wildlife and, therefore, it continues to be 

analyzed as a sensitive species.

Queen Charlotte Goshawk

The Queen Charlotte goshawk (Accipiter gentilis laingi) is recognized as a distinct subspecies of the 

northern goshawk (Accipiter gentilis) that occurs only in coastal areas of British Columbia and in 

Southeast Alaska. The British Columbia DPS of the Queen Charlotte goshawk was listed as threatened 

under the ESA (FR 45870-45893) in August 2012; however, the Alaska DPS was not listed in part due to 

the protections provided by the Old-growth Habitat Conservation Strategy.

The goshawk is a year-round resident in Southeast Alaska and may occupy different or overlapping 

breeding and winter territories. Goshawk breeding territories can be described hierarchically in terms of 
Environment and Effects 3

Final EIS 3-95 Wildlife

the nest site, the nest area, post-fledging area, and foraging area (see Reynolds et al. 1992 and USDA 

Forest Service 2008b). Goshawks in Southeast Alaska typically nest in large patches of tall, mature, and 

old trees with dense canopies. When mature and old-growth habitats are not available, they will nest in 

maturing young growth with sufficient structure (Reynolds et al. 2006; Boyce et al. 2006). Nesting in 

mature young growth is less common, and occurs in proportion to the amount of this habitat available on 

the landscape, suggesting goshawks neither prefer nor avoid its use (USFWS 2007).

Goshawk foraging areas typically consist of mature and old-growth forest stands, though they will also 

forage in young forest as well as along edges and in openings as long as suitable perches from which to 

observe and attack prey are present (Iverson et al. 1996; Bosakowski et al. 1999; McClaren 2004; Boyce 

et al. 2006; Reynolds et al. 2006). Prey species vary geographically, and include blue grouse, red 

squirrels, and a variety of forest-dwelling birds (spruce grouse, Steller’s jay, and ptarmigan; Lewis 2001). 

High-volume POG represents optimal nesting and foraging habitat for goshawks due to the presence of 

large trees and snags. Existing amounts of this forest type on the Tongass are discussed in the Biological 

Diversity section. Approximately 86 percent of the original high-volume POG existing in 1954 remains on 

the Tongass (see Table 3.3-4).

Kittlitz’s Murrelet

The Kittlitz’s murrelet (Brachyramphus brevirostris) was retained as a 2009 sensitive species because it 

was a USFWS candidate for ESA listing. On October 3, 2013, the USFWS issued a 12-month finding (78 

FR 61763) that listing the Kittlitz’s murrelet was not warranted. However, until the Alaska Region 

Sensitive Species list is updated, the Kittlitz’s murrelet will continue to be analyzed as a sensitive species 

(USDA Forest Service 2016b).

More than 95 percent of the global population is estimated to breed in Alaska, with the remainder 

occurring in the Russian Far East. The largest breeding populations are believed to be in Glacier Bay 

National Park and Preserve, Prince William Sound, Kenai Fjords, and Icy Bay (Kendall and Agler 1998 as 

cited in Day et al. 2000). Breeding season core population centers adjacent to the Tongass include Icy 

Bay, Malaspina Forelands, and Yakutat Bay where the species is closely associated with glacial habitats 

(Kissling et al. 2011). The Forest Plan contains direction to “provide for the protection and maintenance of 

known Kittlitz’s murrelet nesting habitat.”

Black Oystercatcher

The black oystercatcher (Haematopus bachmani) was added to the Alaska Region Sensitive Species list 

in 2009. The Alaska Shorebird Conservation Plan also notes it as a species of high concern due to

concerns with population size, breeding and nonbreeding threats, and nonbreeding distribution (Alaska 

Shorebird Group 2008). It is also a Bird of Conservation Concern, and is on the Audubon Society’s Watch 

List (Tessler et al. 2007).

The black oystercatcher occurs along the North American Pacific coast from the Aleutian Islands to Baja 

California (Andres and Falxa 1995), with over half of the global population residing in Alaska primarily in 

Prince William Sound and the Kodiak Archipelago (Tessler et al. 2007). Historically, they have been 

documented in Sitka Sound/Necker Islands, the Myriad Islands, the outer coast of Baranof Island, and the 

Forrester Island group but breeding birds are generally sparsely distributed (Tessler et al. 2007). They 

favor rocky shorelines and forage exclusively on intertidal macroinvertebrates (e.g., limpets and mussels).

Breeding oystercatchers are highly territorial and breeding pairs tend to be widely distributed but Kodiak 

Island is currently the only documented area in Alaska that supports large concentrations of black 

oystercatchers (Tessler et al. 2007). Limited surveys specifically targeting black oystercatchers in Alaska 

have occurred, but they have been observed and are known to nest in low densities along shorelines and 

intertidal areas adjacent to the Tongass. After breeding, black oystercatchers aggregate into winter flocks 

ranging from tens to hundreds of individuals. Winter flocks typically concentrate on protected, ice-free 

tidal flats or rocky islets with dense mussel beds. Because black oystercatchers solely use the intertidal 

zone, where they may congregate in large numbers, they are especially vulnerable to disturbance from 

marine industrial pollution and human disturbance from tourism and fishing. Threats include predation, 

recreational disturbances, flooding, vessel wakes, and shoreline contamination (Tessler et al. 2007).
Environment and Effects 3

Final EIS 3-96 Wildlife

Aleutian Tern

The Aleutian tern (Sterna aleutica) is a migratory seabird that breeds exclusively in Alaska and eastern 

Siberia. It is a USFWS Bird of Conservation Concern and is protected under the Migratory Bird Treaty Act 

(MBTA) and is listed as an Alaska Region sensitive species by the Forest Service. In Alaska, Aleutian 

tern colonies are located throughout the Aleutian Islands, north to the southeastern Chukchi Sea and east 

to the Alaska Peninsula, Yakutat, and Glacier Bay (USFWS 2012d).

Aleutian terns are ground nesters that breed in loose colonies, often in association with Arctic terns, in 

coastal sites located at the heads of bays, reefs, island, estuaries, and river mouths (USFWS 2012d). 

One of the largest breeding colonies of Aleutian terns occurs on Black Sand Spit in the Yakutat

Forelands, which supports approximately one third of Alaska’s population. Due to its importance as a 

breeding colony, Black Sand Spit has been identified as an Audubon Important Bird Area and is included 

in conservation priority areas identified by TNC and Audubon Alaska (Audubon Alaska and The Nature 

Conservancy 2007).

Management Indicator Species

The 1982 Planning Rule directed the use of MIS in forest planning to help display the effects of forest 

management. The 1997 Forest Plan selected 13 wildlife MIS which carried through to the 2008 Forest 

Plan Amendment. Because the 2016 Forest Plan Amendment EIS analyzed an amendment to the 2008 

Forest Plan done under the 1982 Planning Rule, these species were carried forward and analyzed even 

though the 2012 Planning Rule does not use MIS for evaluating effects. MIS are also addressed in this 

EIS, which summarizes, where appropriate, the detailed analysis completed for the 2016 Forest Plan 

Amendment EIS (USDA Forest Service 2016b). Most of these species are associated with POG forests of 

Southeast Alaska either directly or rely on prey species associated with these habitats.

Sitka Black-Tailed Deer

Sitka black-tailed deer (Odocoileus hemionus sitkensis) are indigenous to the coastal regions of 

Southeast Alaska and northwest British Columbia. They are an important big game hunting and 

subsistence species. They are also an important prey species for the Alexander Archipelago wolf 

(discussed below).

Sitka black-tailed deer use lower elevation (below 800 feet elevation) POG forest habitats during the 

winter period. The quantity, quality, distribution and arrangement of winter habitat are considered the 

most important limiting factors for Sitka black-tailed deer in Southeast Alaska. However, spring, summer, 

and fall habitats (non-winter) are also important for deer reproduction and population recovery following 

severe winters, and for building up pre-winter body reserves. During these seasons, and during mild 

winters, deer will forage in young-growth stands less than about 25 years old and other open nonforested habitats. High-volume POG below 800 feet elevation is generally considered to be the habitat of 

highest importance for deer during the winter period, especially during severe winters, because of forage 

availability and snow interception capability. The Tongass currently provides 1.3 million acres of highvolume POG below 800 feet. This represents 82 percent of the original amount of high-volume POG 

below 800 feet on the Tongass (see Table 3.3-4).

However, spring, summer, and fall habitats (non-winter) are also important for deer reproduction and 

population recovery following severe winters, and for building up pre-winter body reserves. During these 

seasons, and during mild winters, deer will forage in young-growth stands less than about 25 years old 

and other open non-forested habitats.

As part of the 2016 Forest Plan Amendment EIS, the interagency deer habitat capability model was used 

to assess existing habitat capability within the planning area (see USDA Forest Service 2016b; Wildlife

section). Table 3.3-14 summarizes the modeled deer habitat capability by biogeographic provinces. 

Forest-wide, approximately 89 percent of the original (1954) habitat capability remains, ranging from 72 to 

100 percent depending on the biogeographic province. The greatest reductions in deer habitat capability 

have occurred in provinces where timber harvest has been concentrated (the North Central Prince of 

Wales, East Baranof, and Etolin Island and vicinity biogeographic provinces).
Environment and Effects 3

Final EIS 3-97 Wildlife

In addition to the interagency deer model, the Forage Resource Evaluation System for Habitat (FRESH) 

model developed by the USDA Forest Service Pacific Northwest Research Station (Hanley et al. 2012; 

http://cervid.uaa.alaska.edu/deer/Home.aspx) was also used to quantify the relative value of available 

deer forage under different alternatives (described in detail in the 2016 Forest Plan Amendment EIS). The 

output of the model provides a “snapshot” of habitat conditions based on estimated food availability and 

quality at one point in time, which was used to make a relative comparison of conditions within a habitat 

patch or landscape under different conditions (i.e., before and after implementation of a management 

activity). More detailed information on the FRESH model inputs and results can be found in the 2016 

Forest Plan Amendment EIS, Wildlife section, and the model is not discussed further here.

Table 3.3-14

Existing Forest-wide Deer Habitat Capability Using the Interagency Deer Model (NFS 

Lands Only)1

Biological Province2

Existing 

Habitat 

Capability 2015 

(Deer per 

Square Mile)

Original (1954) 

Habitat Capability 

(Deer per Square 

Mile)

% Original 

Habitat 

Capability 

Remaining

No. WAAs with 

Modeled Deer Density 

of at least 18 Deer per 

Square Mile3

1 Yakutat Forelands 13.3 13.7 97% 2

2 Yakutat Uplands 2.3 2.4 98% 0

3 East Chichagof Island 11.7 13.7 86% 1

4 West Chichagof Island 14.5 14.5 100% 1

5 East Baranof Island 7.0 8.5 82% 0

6 West Baranof Island 12.2 13.7 89% 4

7 Admiralty Island 17.6 17.9 98% 10

8 Lynn Canal 5.5 5.8 95% 1

9 North Coast Range 6.2 6.2 100% 0

10 Kupreanof/Mitkof Island 16.9 19.2 88% 7

11 Kuiu Island 25.5 28.1 91% 7

12 Central Coast Range 9.0 9.5 96% 1

13 Etolin Island 15.7 18.9 83% 3

14 North Central Prince of 

Wales

17.7 24.5 72% 11

15 Revilla Island/Cleveland 

Peninsula

13.5 15.0 90% 7

16 Southern Outer Islands 28.1 32.1 88% 9

17 Dall Island and Vicinity 30.4 30.6 99% 3

18 South Prince of Wales 21.8 22.2 98% 5

19 North Misty Fjords 3.7 3.8 99% 2

20 South Misty Fjords 8.4 8.4 100% 0

21 Ice Fields 0.7 0.8 94% 0

Forest-wide 10.1 11.3 89% 57

1 Note that the model treats harvested stands in the stem exclusion stage (25 years old or older) the same value regardless of 

thinning treatments that are implemented.

2 Note that wolves very rarely occur on Admiralty, Baranof, and Chichagof Islands.

3 For WAAs that overlap a biological province boundary only the overlapping portion counted toward the total.

Source: USDA Forest Service 2016

Mountain Goat

Mountain goats (Oreamnos americanus) inhabit alpine and subalpine areas and adjacent POG forests on 

the mainland portions of the Tongass and have been introduced to several islands. Steep glacial valleys 

and peaks provide escape terrain from predation by wolves and bears. Adjacent meadows provide forage 

and, at lower elevations, POG forests provide cover as well as evergreen shrubs and forbs for winter 

forage (Porter 2010).
Environment and Effects 3

Final EIS 3-98 Wildlife

Mountain goats are sensitive to human disturbance, which can cause the temporary or permanent 

abandonment of habitat, increased stress, altered behaviors, and potentially excess energy expenditure 

(Goldstein et al. 2005; Olliff et al.1999). Industrial activities such as timber harvest, mining, road 

construction, and hydroelectric development have the potential to have adverse effects on mountain goat 

populations through disturbance or removal of habitat. However, this species spends much of its time 

outside of areas where timber harvest has occurred or are likely to occur in the future. Existing Forest 

Plan standards and guidelines were developed to reduce the impacts of other activities (e.g., helicopter 

over-flights for recreation) and impacts associated with facilities.

Black Bear

Black bears are an important species for hunting, recreation, and tourism. In Southeast Alaska, black 

bears are present throughout the mainland and on the islands south of Frederick Sound. Black bears in 

Southeast Alaska are part of a population (Alexander Archipelago black bears) endemic to coastal British 

Columbia and Southeast Alaska, except Admiralty, Baranof, and Chichagof islands (Stone and Cook 2000; 

Peacock et al. 2007). Black bears will use habitats from sea level to the alpine but appear to prefer 

estuarine, riparian, and forested coastal habitats (USDA Forest Service 2008b). Black bears use small 

openings and areas such as wetlands, clearcuts, and subalpine meadows for foraging.

Past timber harvest, especially in areas adjacent to salmon streams, has decreased black bear habitat 

suitability through the removal of POG forest. While early successional habitats may provide abundant 

food (berries), over the long term dense young-growth stands provide poor habitat for black bears due to 

the lack of forage and large hollow trees for denning. Also, over the long term, reduction of den sites may 

result from a lack of availability of large tree root structures (Davis etal. 2012). Approximately 90,000 acres 

of young-growth (harvested and natural) occur in RMAs and an additional 68,000 acres occur in Beach 

and Estuary Fringe outside of RMAs. Small OGRs and other Non-development LUDs provide some 

connectivity on a local scale to shoreline and riparian habitats preferred by black bears.

Timber harvest may also impact black bears through increased human access on roads. This can result 

in increased harvest-related mortality; however, it should be noted that black bear harvest risk has not 

been linked to a particular road density level.

River Otter

River otter (Lutra canadensis) are associated with coastal and freshwater aquatic environments and the 

immediately adjacent (within 100 to 500 feet) upland habitats. River otters are distributed throughout 

Southeast Alaska, and across the Tongass, along coastal and inland waters (MacDonald and Cook 2007).

Old-growth forests have the highest habitat value for river otters, providing canopy cover, large-diameter 

trees and snags, and burrow and den sites. River otters rest in cavities or beneath the roots of large 

conifers or snags in POG forests with open understories (high-volume POG forest; Ben-David et al. 1996; 

Bowyer et al. 2003). Young-growth forests provide lower quality habitat. There are approximately 2.1 

million acres of high-volume POG forest on the Tongass. Approximately 90,000 acres of young-growth 

(harvested and natural) occur in Riparian Management Areas (RMAs) and an additional 68,000 acres 

occur in Beach and Estuary Fringe outside of RMAs. Protection under the Forest Plan is provided through 

standards and guidelines for beaches, estuaries, and riparian areas (USDA Forest Service 2016a).

American Marten

The American marten (Martes americana) is an important furbearer that is associated with old-growth 

forests. Coastal habitats (beach fringe) and riparian areas have the highest habitat value for marten, followed 

by upland forested habitats below 1,500 feet in elevation (USDA Forest Service 2008a). Marten favor largeand medium-sized old-growth forests because they intercept snow, provide cover and denning sites, and 

provide habitat for marten prey species (Flynn and Schumacher 2001; Flynn et al. 2004). The quantity and 

quality of winter habitat is a limiting factor for marten in Southeast Alaska. Therefore, the availability of deepsnow marten habitat, defined as high-volume POG below 800 feet in elevation, provides a measure of habitat 

quality for marten. There are approximately 1.3 million acres of high-volume POG forest below 800 feet 

elevation on the Tongass and 82 percent of the original POG in this category remains on the Tongass (see 

Table 3.3-4).
Environment and Effects 3

Final EIS 3-99 Wildlife

Old-growth timber harvest reduces habitat quality for marten through the removal of forest cover, 

fragmentation of old-growth habitat (reductions in travel corridors and/or functional connectivity between 

spatially isolated populations), and reductions in habitat for some prey species. Increased human access 

associated with new roads may result in increased marten harvest-related mortality.

Although closed roads still facilitate access (e.g., off-highway vehicle, pedestrian), open roads that 

receive the highest and most consistent use are likely to have the greatest effect on martens by 

facilitating access for trappers. Existing road densities (all elevations included) on the Tongass are listed 

in Table 3.3-15.

Table 3.3-15

Existing Estimated Average Road Densities and Percentage of WAAs in Road 

Density Categories on NFS Lands and All Lands Combined for All Roads and 

Open Roads Only within the Tongass National Forest Boundary (All Elevations) 

Road Density Category

(miles per square mile)

Existing Road Densities (percentage of WAAs)

NFS Lands All Lands1

All Roads

0 55.0% 50.8%

0 to 0.7 31.9% 30.9%

0.7 to 1.0 6.3% 5.8%

1.0 to 2.0 6.3% 9.9%

2.0 to 3.0 0.5% 2.6%

>3.0 0.0% 0.0%

Total 100% 100%

Average Total Road Density – All WAAs 0.19 0.32

Open Roads2

0 60.2% 56.0%

0 to 0.7 37.7% 34.6%

0.7 to 1.0 1.6% 4.2%

1.0 to 2.0 0.5% 5.2%

2.0 to 3.0 0.0% 0.0%

>3.0 0.0% 0.0%

Total 100% 100%

Average Open Road Density – All WAAs 0.08 0.21 1 Percentages are based on all 191 Wildlife Analysis Areas (WAAs) inside the Forest boundary. 2 Open roads on NFS land were calculated using Maintenance Levels 2, 3, 4, and 5 (see Transportation section for 

maintenance level description).

Source: Tongass National Forest GIS layer, 2018, and modeling of alternatives.

Roadless areas and OGRs and other non-development LUDs provide refugia for marten from trapping 

pressure. However, marten home ranges are well-distributed across the landscape and include areas 

with timber harvest and roads, emphasizing the importance of habitat within matrix lands. Legacy Forest 

Structure standards and guidelines, in combination with the beach fringe and riparian buffers, aid in 

providing habitat and connectivity for marten on NFS lands.

Brown Bear

Southeast Alaska is home to one of the highest concentrations of brown bears (Ursus arctos) in the world 

(ADF&G 2000). Brown bears are present on the mainland and on most the islands north of Frederick 

Sound. They are occasionally reported on Mitkof, Etolin, Revillagigedo, and Wrangell Islands south of 

Frederick Sound, but are not found on any of the other islands in Southeast Alaska. Admiralty, Baranof, 

Chichagof, Kruzof, Yakobi, and neighboring islands consistently support the highest densities of brown 

bears on the Tongass (Game Management Unit [GMU] 4).

Brown bears are important both for hunting (including both outfitter guided and non-guided hunting) and 

to the recreation and tourism industry of Southeast Alaska. On the Tongass, ADF&G permits harvest of 
Environment and Effects 3

Final EIS 3-100 Wildlife

brown bears in GMUs 1, 3, 4, and 5. As tourism grows in Southeast Alaska, there is increasing demand 

for more bear viewing opportunities such as those provided by Pack Creek and Anan Creek.

Brown bears use areas from sea level to the alpine and are habitat generalists. The late-summer season 

has been identified as the most critical or limiting period for brown bears when they must build up energy 

reserves that are adequate to survive the winter and successfully reproduce (Hilderbrand et al. 1999). 

During this season, many brown bears concentrate along low elevation valley bottoms and salmon 

streams, with most use occurring within 500 feet of streams (Schoen and Beier 1990; Titus and Beier 

1999), where their efforts focus on consuming large quantities of fish in order rebuild their body condition 

and lay on essential fat reserves. These are often the same areas of highest human use and most 

intense resource development activities (Flynn et al. 2007).

Roads and other human developments can also be detrimental to bears because they increase the 

opportunity for human-induced mortality of bears through legal hunting, defense of life or property kills, 

and illegal killing. Additionally, poorly maintained or constructed roads can affect water quality and 

productivity of salmon streams.

Alexander Archipelago Wolf

The Alexander Archipelago wolf (Canis lupus ligoni) is thought to be a subspecies of gray wolf endemic to 

Southeast Alaska and British Columbia. It inhabits the mainland of Southeast Alaska and coastal British 

Columbia west of the Coast Mountain Range, and larger islands (those south of Frederick Sound) except 

Admiralty, Baranof, Chichagof islands, and all of the Haida Gwaii or the Queen Charlotte Islands (USFWS 

2015). Approximately 38 percent of the range-wide population of Alexander Archipelago wolves inhabits 

Southeast Alaska, where population trends are largely unknown, except for the population on Prince of 

Wales Island and the surrounding islands (collectively GMU 2), which appears to have declined in 

abundance over the past 20 years. A portion of Prince of Wales Island was sampled, and estimates 

expanded to the entire GMU 2 suggesting an apparent decline of potentially 75 percent. However, 

because GMU 2 constitutes approximately 4 percent of the range of the Alexander Archipelago wolf and 

6 percent of the range-wide population, negativepopulation impacts in GMU 2 likely do not affect the 

range-wide population significantly (USFWS 2015). The majority (62 percent) of the Alexander 

Archipelago wolf population occurs in coastal British Columbia and is thought to be stable (USFWS 

2015). Although some research suggests that wolves inhabiting Prince of Wales Island may be 

genetically isolated from other populations in Southeast Alaska (Person 2001; Weckworth et al. 2005, 

2010, 2011), there remains uncertainty about the degree of isolation (see the Alexander Archipelago Wolf

Species Status Assessment [USFWS 2015] for more information).

In August 2011 and more recently in July 2020, the USFWS received petitions to list the subspecies as 

threatened or endangered, and to recognize Prince of Wales Island as a significant portion ofits range 

(Center for Biological Diversity and Greenpeace 2011). The 2011 petition also requested that the USFWS 

consider those wolves found on Prince of Wales Island and adjacent islands (including Kosciusko, Tuxekan, 

Heceta, Suemez, Dall, and others proximate to Prince of Wales) as a DPS based on unique genetic, 

physical, and ecological characteristics. In March 2014, the USFWS issued a 90-day finding that the petition 

to list the subspecies presented substantial information indicating that listing may be warranted (79 FR 

17993). A status review of the Alexander Archipelago wolf to determine if listing is warranted was published 

in November 2015. In January 2016, the USFWS published a 12-Month finding that listing of the subspecies 

was not warranted. The 2016 amended Forest Plan facilitates a transition from harvesting old-growth forest

to predominantly harvesting young-growth forest. After the USFWS decision in 2016 that listing was not 

warranted, and based on continued GMU 2 wolf population concerns, Forest Service leadership within the 

Tongass and Alaska Region directed staff to proceed with developing the Wolf Habitat Management 

Program and wolf management recommendations for GMU 2 (see Wolf Technical Committee2017).

Wolves feed primarily on deer in certain areas (especially in GMUs 1, 2, 3, and 4), though waterfowl, 

beaver, spawning salmon, sea otter, squirrels, mountain goat, and black bear represent important prey 

when available (Lafferty et al. 2014; Darimont and Reimchen 2002; Szepanski et al. 1999; ADF&G 2017). 

Wolves in Southeast Alaska also prey on moose and elk where available. Suitable habitats for wolves are 

those capable of supporting this prey base. Therefore, wolves in Southeast Alaska use a wide variety of 

prey habitats but spend most of their time in productive and unproductive old-growth forests at low 

elevations (below 270 feet); young-growth forests and clearcuts are typically avoided (Person 2001). 
Environment and Effects 3

Final EIS 3-101 Wildlife

Dens on Prince of Wales Island are located in root wads of large living or dead trees within old-growth 

forest stands less than 495 feet (150 meters) from freshwater (Person and Russell 2009). Roffler and 

Gregovich (2018) monitored 13 radio-collared wolves between 2012 and 2016 and documented 11 den 

sites. Although the mean minimum and maximum distance from the core area edge to the active den site 

(0.73 mile – 3.93 miles) varied widely, it was smaller for breeding wolves (0.46 mile – 1.43 miles), and all 

distances exceeded the existing recommended den buffer distance (1,200 feet or 0.23 mile).

Deer winter habitat was considered by Person et al. (1996) and Person (2001) to be a good measure of 

habitat quality for wolves in southern Southeast Alaska. Black-tailed deer are present in all Southeast 

Alaska GMUs where wolves occur. Forest Plan standards and guidelines state that, where possible, 

sufficient deer habitat capability should first be maintained to sustain wolf populations, and then to consider 

meeting estimated human deer harvest demands. This is generally considered to equate to the habitat 

capability to support a minimum of 18 deer per square mile (using interagency deer habitat capability model 

outputs; USDA Forest Service 2008a). However, other factors (e.g., local knowledge of habitat conditions, 

inherent capability of the landscape, spatial extent of the analysis) are to be considered by the biologist, as 

well, rather than solely relying upon model outputs (USDA Forest Service 1997b, Appendix N; 2016a).

The interagency deer habitat capability model was used to evaluate wolf habitat capability based on 

modeled deer habitat capabilities (see the 2016 Forest Plan Amendment EIS for discussion of model 

limitations and assumptions). Table 3.3-16 summarizes existing conditions by biogeographic province. 

Forest-wide approximately 89 percent of the original (1954) habitat capability remains, ranging from 72 to 

100 percent by biogeographic province.

Table 3.3-16

Modeled Deer Habitat Capability Using the Interagency Deer Model for Comparison to 

Forest Plan 18 Deer per Square Mile Standard and Guideline (NFS LandsOnly) 

Biological Province

Existing 

Habitat 

Capability 2015 

(Deer per 

Square Mile)

Original 

(1954) Habitat 

Capability 

(Deer per 

Square Mile)

% Original 

Habitat 

Capability 

Remaining

No. WAAs with 

Modeled Deer 

Density of at 

least 18 Deer 

per Square Mile1

No. WAAs 

with >100 

acres in 

Province4

1 Yakutat Forelands 13.3 13.7 97% 2 5

2 Yakutat Uplands 2.3 2.4 98% 0 5

3 East Chichagof Island 11.7 13.7 86% 1 22

4 West Chichagof Island 14.5 14.5 100% 1 7

5 East Baranof Island 7.0 8.5 82% 0 6

6 West Baranof Island 12.2 13.7 89% 4 11

7 Admiralty Island 17.6 17.9 98% 10 18

8 Lynn Canal 5.5 5.8 95% 1 17

9 North Coast Range 6.2 6.2 100% 0 10

10 Kupreanof/Mitkof Island 16.9 19.2 88% 7 10

11 Kuiu Island 25.5 28.1 91% 7 6

12 Central Coast Range 9.0 9.5 96% 1 14

13 Etolin Island 15.7 18.9 83% 3 7

14 N. Central Prince of Wales 17.7 24.5 72% 11 22

15 Revilla Island/Cleveland 

Peninsula

13.5 15.0 90% 7 22

16 Southern Outer Islands 28.1 32.1 88% 9 9

17 Dall Island and Vicinity 30.4 30.6 99% 3 3

18 South Prince of Wales 21.8 22.2 98% 5 6

19 North Misty Fjords 3.7 3.8 99% 2 12

20 South Misty Fjords 8.4 8.4 100% 0 6

21 Ice Fields 0.7 0.8 94% 0 33

Forest-wide 10.1 11.3 89% 57 250 1 For WAAs that overlap a biological province boundary only the overlapping portion counted toward the total.

2 Note that the model treats harvested stands in the stem exclusion stage (25 years old or older) the same value regardless of 

thinning treatments that are implemented.

3 Note that wolves very rarely occur on Admiralty, Baranof, and Chichagof Islands.

4 Note that deer abundance varies naturally, with much lower abundance in the northern portion of the Forest and in higher 

elevation WAAs. Also note that many WAAs in this column occur in more than one province.

Source: Data from 2016 Tongass GIS.
Environment and Effects 3

Final EIS 3-102 Wildlife

Wolves are also a furbearer in Southeast Alaska. Harvesting of wolves is regulated by the Federal 

Subsistence Board and the State of Alaska Board of Game. Harvest regulations, both subsistence and 

sport, are intended to help ensure sustainable wolf populations. The ADF&G works cooperatively with the 

Alaska Board of Game and with federal land managers, including the Forest Service, to identify and 

address conservation concerns and propose regulation changes as needed for all wildlife in Southeast 

Alaska, including wolves.

Although wolves are often harvested by hunters and trappers working from boats (approximately 59 

percent of harvest in GMU 2), harvest-related wolf mortality (both legal and illegal) is correlated with roads 

and other habitat features, which influence their vulnerability to harvest (Person and Russell 2008; Person 

and Logan 2012).

A road density of 0.7 to 1.0 mile per square mile or less may be necessary to reduce harvest-related 

mortality risk where locally unsustainable wolf mortality has been identified through interagency analysis 

(USDA Forest Service 2008a, p. 4-95; Person et al. 1996). Existing road densities are presented in Table 

3.3-15. For NFS lands, approximately 13 percent of WAAs exceed the 0.7 mile per square mile guideline; 

however, approximately 18 percent exceed the guideline when all lands are considered, including nonNFS lands. When only open roads are considered, these percentages drop to 2 and 9 percent, 

respectively. Approximately 7 percent of WAAs exceed 1.0 mile per square mile for NFS lands only and 

13.5 percent exceed this density for all lands (Table 3.3-15). Current Standards and Guidelines provide 

protection for active den sites through the establishment of a 1,200-foot forested buffer and avoid road 

construction within established buffer where feasible (USDA Forest Service 2016a).

Bald Eagle

The bald eagle (Haliaeetus leucocephalus) is associated with beach, estuary fringe, and riparian habitats. 

Bald eagles typically nest in large trees in spruce-hemlock forest, and over 90 percent of the nests are 

within 500 feet of a saltwater beach. Nests are located within beach, estuary fringe, and riparian habitats. 

Since 1967, the USFWS has monitored, via aerial surveys, bald eagle populations along the north Pacific 

coast from southern British Columbia to the Alaska Peninsula (Hodges 2011). In Southeast Alaska, the 

population increased until the 1980s, but since then has remained stable, with an adult population of 

approximately 13,000 to 26,000 birds (Hodges 2011).

Bald eagles are especially sensitive to disturbance early in the breeding season. Activities associated 

with timber harvest can result in reproductive failure or cause bald eagles to abandon their nests 

completely (Fraser et al. 1985 as cited in Isaacs et al. 2005). They are also susceptible to water quality

impacts that adversely impact their prey populations (e.g., herring, flounder, pollock, and salmon). Under 

the 2016 Forest Plan, the availability of nesting habitat is not seen as a significant limiting factor, in part 

due to the current protection of the 1,000-foot shoreline beach buffer on the Tongass (Hodges 2011). 

Further protection to bald eagles is afforded by Forest-wide standards and guidelines that require the 

maintenance of estuarine and riparian buffers, raptor nest protection standards and guidelines (USDA 

Forest Service 2016a). Bald eagles are managed by the USFWS under the National Bald and Golden 

Eagle Protection Act and through the Bald Eagle Take Permit Program (74 [175] FR 46836).

Red Squirrel

The red squirrel is abundant on many of the islands and mainland and are an important prey species for 

American marten and goshawk. It is an MIS because of its preference for cone-producing trees and tree 

cavities and snags, which they use for denning and nesting (USDA Forest Service 2016b). Red squirrels 

are abundant on many of the islands in the Alexander Archipelago and the mainland.

Red squirrels use POG forests, but may also use young-growth stands once cone production begins 

about 40 years after timber harvest (USDA Forest Service 2016b). There are approximately 10 million 

acres of forested land, including all age classes and types of conifer forests (5.6 million acres of 

productive forest land and 4.4 million acres of unproductive forest land) on the Tongass that provide 

potential habitat for red squirrels (see Biological Diversity section; Table 3.3-2).

Old-growth timber harvest reduces habitat quality for red squirrels through the removal of forest cover and 

fragmentation of forest habitats. However, recovery of habitat capability after timber harvest is much 

faster for red squirrels than other species because although post-harvest formation of structures favored 
Environment and Effects 3

Final EIS 3-103 Wildlife

for nesting and food storage (cavities) takes longer, the majority of habitat capability (food availability) is 

restored quickly as cone production typically begins 40 years after harvest. Commercial even-aged 

young-growth harvest returns stands to an early seral condition so would also delay development of 

habitat capability for red squirrels. Forest Plan Reserve Tree/Cavity-Nesting Habitat and Legacy Forest 

Structure standards and guidelines maintain habitat for this species.

Red-breasted Sapsucker, Hairy Woodpecker, and Brown Creeper

The red-breasted sapsucker (Sphyrapicus ruber), hairy woodpecker (Leuconotopicus villosus), and brown 

creeper (Certhia americana) are old-growth associated and snag-dependent species. Hairy woodpeckers 

and red-breasted sapsuckers are primary cavity excavators that require snags and dying trees for 

foraging and nesting. Although they may be found in a variety of forested habitats, the brown creeper 

prefers large diameter old-growth trees (Hejl et al. 2002). Although no historic population estimates exist, 

it is likely that timber harvest and associated activities have reduced populations from historic levels (Hejl 

et al. 2002). North American Breeding Bird Survey data collected between 2003 and 2013 suggest 

populations of all three species are increasing within the Northern Pacific Rainforest region, though none 

of the trends were statistically significant (Sauer et al. 2014).

All three species are associated with interior old-growth forest conditions (Kissling and Garton 2008). Oldgrowth timber harvest activities that remove large, live trees and dead or dying trees reduce nesting and 

foraging habitat for these species and may reduce local habitat quality by creating fragmented forest 

patches and thereby reducing the amount of interior old-growth forest habitat with which these species 

are associated.

Past timber harvest has reduced and altered the habitat used by the red-breasted sapsucker, hairy 

woodpecker, and brown creeper. Of the 5.0 million acres of POG forest on the Tongass, approximately 

2.1 million acres are high-volume POG, and 780,000 acres are low-volume POG that provide potential 

habitat for these species (see Biological Diversity section; Table 3.3-3). Maintenance of habitat for these 

species under the Forest Plan is provided through the reserve tree and legacy standards and guidelines, 

beach and riparian buffers, and the Old-growth Habitat Conservation Strategy (USDA Forest Service 

2016a).

Vancouver Canada Goose

The Vancouver Canada goose (Branta canadensis fulva) is associated with wetlands (both forested and 

non-forested) in the estuary, riparian, and upland areas of the Forest (USDA Forest Service 2016a). The 

Vancouver Canada goose is primarily a non-migratory subspecies of Canada goose that occurs yearround throughout Southeast Alaska, with an estimated resident population of 25,000 birds (Hupp et al. 

2010). This species nests in forested habitats associated with beach and estuary buffers, and riparian 

habitats. Hupp et al. (2010) documented nests in forests adjacent to muskegs. During winter, marine 

grasses and salt marsh plants commonly found in intertidal areas are important forage resources, and 

Vancouver Canada geese exhibit strong fidelity, returning repeatedly to such winter sites.

Timber harvest activities may result in disturbance to geese, particularly if they occur in the vicinity of nest 

sites or brood rearing areas, and habitat removal. However, timber harvest in these areas has generally 

been minimal because these sites are fairly unproductive. Modifications to shoreline and riparian habitats 

can occur in association with young-growth harvest and roads and utility corridors if these habitats are 

crossed. Protection from direct impact to habitat is provided by Forest Plan Standards and Guidelines for 

waterfowl and shorebird, wetland, and riparian standards and guidelines; overall goose habitat is provided 

by the Old-growth Habitat Conservation Strategy (USDA Forest Service 2016a).

Other Species

Migratory Birds

Executive Order 13186 provides for the conservation of migratory birds and their habitats and requires 

the evaluation of the effects of Federal actions on migratory birds, with an emphasis on species of 

concern. The Executive Order directs agencies to take certain actions to further comply with the migratory 

bird conventions, the MBTA, the Bald and Golden Eagle Protection Act, and other pertinent statutes. 

Agencies are required to support the conservation and intent of the migratory bird conventions by 
Environment and Effects 3

Final EIS 3-104 Wildlife

integrating bird conservation principles, measures, and practices into agency activities and by avoiding or 

minimizing, to the extent practicable, adverse impacts on migratory bird resources when conducting 

agency actions.

Birds protected under the MBTA include all common songbirds, waterfowl, shorebirds, hawks, owls, 

eagles, ravens, crows, native doves and pigeons, swifts, martins, swallows, and others, including their 

body parts (e.g., feathers, plumes), nests, and eggs. The Tongass is located in the Northern Pacific 

Rainforest Bird Conservation Region (BCR 5). The Northern Pacific Rainforest BCR is one of five BCRs 

designated in Alaska to provide a framework to facilitate coordinated conservation efforts (U.S. NABCI 

Committee, September 2000; Rich et al. 2004).

Priority migratory bird species identified in the Landbird Conservation Plan (BPIF 1999; Rich et al. 2004; 

Rosenberg 2016) for Southeast Alaska with the potential to occur on the Tongass are listed in Table 3.3-17 

and discussed in detail in the 2016 Forest Plan Amendment EIS (USDA Forest Service 2016b, Wildlife

section). Migratory birds are likely to be present in upland forest, riparian, and coastal habitat. There are 5.0 

million acres of POG on the Tongass that provide primary or secondary habitats for these species (note that 

many of these species are also shrub nesters and may use young-growth as well as unproductive forest 

types).

The main management issue for migratory birds in BCR 5 is the harvest of old-growth coniferous forests. 

Timber harvest directly removes perching, foraging, and nesting habitat and results in habitat 

fragmentation, which may reduce the suitability of remaining forest stands for species associated with oldgrowth interior forest conditions. Fragmentation may increase the exposure of birds to edge-related 

predators and parasites. As the landscape becomes more fragmented, forest buffers become increasingly 

important for migratory birds to mitigate the effects of habitat loss (Kissling 2003). There is already an 

existing level of fragmentation on the Tongass, both natural in association with the distribution of forested 

and non-forested cover types, and in association with past timber harvest and other development 

activities. Timber harvest and related activities may also directly impact migratory birds through 

disturbances of adults or young through the removal of active bird nests or by causing nest abandonment. 

Protection under the Forest Plan is provided by beach fringe and riparian buffers and standards and 

guidelines for waterfowl, shorebirds, raptors, legacy forest structure, and the Old-growth Habitat 

Conservation Strategy.

Table 3.3-17

Migratory and Resident Birds Identified as Species of Concern in Southeast Alaska1

Common 

Name

Scientific 

Name General Habitat

Preferred 

Habitat2

Abundance 

and 

Occurrence

Sooty Grouse Dendragapus 

fuliginosus

Habitat affinities vary by season and region. 

Coastal birds tend to remain in old-growth or 

recently logged forests all year. Inland birds 

prefer forest edges in summer, coniferous 

forests in winter (Kaufman 1996). Found in 

coniferous and mixed forests in Southeastern 

Alaska; also in dwarf conifer forests at treeline.

2, 3 Rare; 

breeding, 

winter
Environment and Effects 3

Final EIS 3-105 Wildlife

Table 3.3-17 (continued)

Migratory and Resident Birds Identified as Species of Concern in Southeast Alaska1

Common 

Name

Scientific 

Name General Habitat

Preferred 

Habitat2

Abundance 

and 

Occurrence

Western 

Screech-Owl

Megascops 

kennicottii 

Open coniferous and deciduous forests and 

along rivers, creeks, ponds and bogs. Also 

forest edges and in suburban areas in parks, 

orchards and gardens. Often nest near water

(Campbell et al. 1990). In southern part of 

range in mesquite groves and saguaros 

(Kaufman 1996). Probably non-migratory in 

Alaska due to sufficient habitat to meet yearround requirements (P. Schempf, pers. 

comm.). In Yakutat, appears to favor riparian 

spruce (B. Andres, pers. comm.). 

2 Uncommon; 

breeding, 

winter

Black Swift Cypseloides 

niger (borealis) 

Appear to be restricted to river valleys with 

steep unvegetated cliffs. Although nesting 

has not been confirmed in Southeastern 

Alaska, summer sightings in adequate habitat 

suggest Black Swifts are a probable breeder. 

5 Rare; 

breeding

Vaux’s Swift Chaetura vauxi Nests in coniferous and mixed forests, 

especially old growth. Often observed 

foraging over lakes, rivers, open country and 

clearcuts. Many records from Southeastern 

Alaska are along rivers and estuaries. 

2 Uncommon; 

migration, 

breeding

Rufous 

Hummingbird

Selasphorus 

rufus

Found in a variety of habitats throughout 

breeding range including old growth, young 

growth, thickets, and shrubby hillsides 

2 Common; 

migration, 

breeding

Red-Breasted 

Sapsucker

Sphyrapicus 

ruber

Often associated with mature stands, 

especially hemlock and/or spruce in Pacific 

Northwest and Southeastern Alaska, but may 

not be an obligate old-growth species.

2 Abundant; 

breeding

Olive-sided 

Flycatcher

Contopus 

cooperi

In Central Alaska, most often found in open 

conifer forest. Usually associated with 

openings (muskegs, meadows, burns, and 

logged areas) and water (streams, beaver 

ponds, bogs, and lakes). Apparently requires 

an uneven canopy or openings for aerial 

hawking, and wet areas productive of insect 

prey.

3 Uncommon; 

breeding

Western WoodPeweeContopus 

sordidulus

In Southeastern Alaska, occurs along large 

mainland rivers, much less common on 

islands.

3 Uncommon; 

breeding

Hammond’s 

Flycatcher

Empidonax 

hammondii

In Southeastern Alaska, found in riparian 

deciduous forests. 

2, 3 Uncommon; 

breeding

Pacific-slope 

Flycatcher

Empidonax 

difficilis

Prefers old-growth coniferous forests, 

especially near streams. 

2, 3 Common; 

breeding

Steller’s Jay Cyanocitta 

stelleri

In Alaska, found predominately in coniferous 

forests.

2 Abundant; 

breeding, 

winter

Northwestern 

Crow

Corvus 

caurinus

Coastal beaches, rocky shores, estuaries, 

coastal ponds and inshore islands.

2, 6, 7, 8 Abundant; 

breeding, 

winter

Chestnutbacked 

Chickadee

Poecile 

rufescens

In Southeastern Alaska, common in mature 

hemlock/spruce forests and also in pole and 

sawtimber stages of successional forests.

2 Abundant; 

breeding, 

winter

American 

Dipper

Cinclus 

mexicanus 

Dippers are a riparian-obligate species and 

are totally dependent on the productivity of 

streams and rivers. 

4, 5 Fairly 

common; 

breeding

Varied Thrush Ixoreus naevius Found mostly in thick, wet, coniferous forests 

of the coast.

1, 2, 3 Abundant; 

migration, 
Environment and Effects 3

Final EIS 3-106 Wildlife

Table 3.3-17 (continued)

Migratory and Resident Birds Identified as Species of Concern in Southeast Alaska1

Common 

Name

Scientific 

Name General Habitat

Preferred 

Habitat2

Abundance 

and 

Occurrence

breeding, 

winter

Townsend’s 

Warbler

Dendroica 

townsendi

Largely restricted to mature forests with tall 

coniferous trees throughout its breeding 

range. Most abundant in large undisturbed 

tracts of contiguous forest, but will also use 

forests in late successional stages.

2, 3 Common; 

breeding

Blackpoll 

Warbler

Dendroica 

striata

Habitat preference variable, but usually found 

in tall shrubs (riparian woodland) or in 

coniferous or deciduous forest or woodland

2 Rare; 

migration

MacGillivray’s 

Warbler

Oporornis 

tolmiei

In southeastern Alaska, it is found in shrubs 

along hemlock/spruce edges, deciduous 

woodlands with shrubs, clearcuts, and 

riparian shrubs.

1 Uncommon; 

breeding

Goldencrowned 

Sparrow

Regulus 

satrapa

Prefers low to tall alder and willow scrub on 

hillsides and near tundra. Commonly found in 

proximity to lakes, streams, and bogs. In 

winter prefers uninterrupted brushland, 

streamside thickets, and chaparral.

1 Fairly 

common; 

breeding, 

winter

Goldencrowned kingletZonotrichia 

atricapilla

Found in coniferous forests (spruce, fir, and 

hemlock) all times of year; also in mixed 

forests in south coastal and central Alaska. In 

winter and migration, can be found in other 

trees and shrubs. 

1, 3 Common; 

breeding, 

winter

1 Source: BPIF 1999; Rich et al. 2004; Rosenberg 2016 2 1=shrub thicket; 2=hemlock/Sitka spruce/cedar forest; 3=mixed deciduous/spruce woodland; 4=fluvial waters; 5=cliffs, bluffs, 

and screes; 6=moraines, alluvia, and barrier islands; 7=beaches and tidal flats; 8=rocky shores and reefs.

Bats

There are seven species of bats that are known to occur in Alaska (Parker et al. 1996; Olson et al. 2014). 

Of the bat species that occur in Southeast Alaska, the little brown bat (Myotis lucifugus) is the most 

common and wide spread. Others include the silver-haired bat (Lasionycteris noctivagans), Keen’s myotis 

(M. keenii), California myotis (M. californicus), the long-legged myotis (M. californicus), Yuma myotis (M. 

yumanensis), and the big brown bat (Eptesicus fuscus). All species are associated with mature forested 

habitats which provide roosting, breeding, and foraging sites, and bat activity appears rare, for most 

species, in second-growth forest (Tessler et al. 2014; Walton et al. 2013a-e; Parker et al. 1996). Treeroosting species, such as the Keen’s myotis and silver-haired bat, often roost in mature forest patches 

with large numbers of suitable cavity trees. Other species, such as the little brown bat, roost in caves 

associated with the karsts systems. Foraging activities vary depending on vegetation density, and studies 

have found higher foraging activity from bats in intact forest patches and along the patch edges, with less 

activity in clear-cut areas (Patriquin and Barclay 2003). Throughout its range, the little brown bat has 

undergone dramatic declines due to white-nose syndrome (a fungal infection that affects bats while in 

hibernation) and is of particular management interest as white-nose syndrome has not yet been detected 

in Alaska. Bats are relatively uncommon in Alaska and reproductive rates for bats in higher latitudes are 

generally lower than farther south. These factors may make these species more susceptible to habitat 

loss and other factors; however, further research is needed to better understand current bat populations 

and how they respond to habitat loss and other factors (Boland et al. 2009). Timber harvest, particularly 

even-aged harvest, has the potential to remove roosting and foraging habitat for bats.

Marbled Murrelet

In March 2006, a status review for the marbled murrelet was initiated by the USFWS for the northern part 

of the species range to support ESA deliberations over the listing of the species as threatened in the 

southern part of its range (California, Oregon, and Washington; Piatt et al. 2007). Genetic analysis 

conducted as part of the review identified three distinct population segments: one in the central and 
Environment and Effects 3

Final EIS 3-107 Wildlife

western Aleutian Islands; one ranging from the eastern Aleutians to northern California; and one in central 

California.

Marbled murrelets are widely distributed across marine waters in Southeast Alaska. They spend the 

majority of their lives at sea, but travel inland up to 50 miles to nest in old-growth forest stands (Piatt et al. 

2007). Marbled murrelets typically nest on mossy-limbed branches of large, mature coniferous trees 

within stands of structurally complex, coastal high-volume old-growth forest (DeGange 1996; Kuletz et al. 

1995; Ralph and Miller 1995). However, on some treeless islands in Southeast Alaska marbled murrelets 

lay eggs on bare talus slopes in mountainous areas (Piatt et al. 2007).

Timber harvest, through the removal of POG forest, can directly remove nest trees, and also increases 

habitat fragmentation and associated edge effects, such as increased rates of nest predation (Andren 

1994; Chalfoun et al. 2002). Some avian predators of murrelets, especially corvids (i.e., ravens, crows, 

jays), are known to increase with both forest fragmentation and proximity to human activity (Burger 2002). 

In a study of the edge effects and nest predation risk on marbled murrelets, Malt and Lank (2007) found 

that disturbances by avian predators at nests were significantly more frequent at hard edges (clearcuts) 

relative to interiors, but less frequent at soft edges (regenerating forest); there were no edge effects at 

natural-edged (riparian) sites. Thus, edge-associated predation risk may subside with the progression of

forest succession. Forest Plan standards and guidelines pertaining to marbled murrelets include 

maintaining a 600-foot radius no-cut buffer zone around identified murrelet nests; however, habitat 

protection is also provided through beach and estuary fringe buffers and riparian standards and guidelines 

(USDA Forest Service 2016a), as well as the overall system of OGRs and other non-development LUDs.

Amphibians

There are eight species of amphibians known to occur in Southeast Alaska, two of which, the Pacific 

chorus frog (Pseudacris regilla) and the red-legged frog (Rana Aurora), are introduced (MacDonald and 

Cook 2007). Native species include the western toad (Bufo boreas), wood frog (Rana sylvatica), 

Columbia spotted frog (Rana luteiventris), rough-skinned newt (Taricha granulosa), long-toed salamander 

(Ambystoma macrodactylum), and northwestern salamander (Ambystoma gracile). Within Alaska, most of 

these species are confined to the southeast, with the exception of the western toad which ranges as far 

north as Prince William Sound (MacDonald and Cook 2007), and the wood frog, which is widespread 

throughout Alaska, and persists north of the arctic circle (Lee-Yaw et al. 2008). Amphibians have specific 

requirements for both aquatic and terrestrial habitats in order to complete their life-cycle. This makes 

them useful indicator taxa of forest change and effects on habitat elements such as canopy shade, soil 

moisture, and coarse woody material. Clearing of trees can result in increased solar radiation to the forest 

floor, resulting in changes in moisture and soil temperatures; these effects can be reduced using selective 

thinning (Verschuyl et al. 2011). Amphibians are often vulnerable to road construction and increased road 

traffic as many species migrate from streams and other waterbodies to upland habitats.

Endemism

The USFWS defines endemic as “a species native and confined to a certain region; having comparatively 

restricted distribution” (http://www.fws.gov/endangered/about/glossary.html). The 2016 Forest Plan 

standards and guidelines for endemic mammals direct the Forest to “maintain habitat to support viable 

populations and improve knowledge of habitat relationships of rare or endemic terrestrial mammals that 

may represent unique populations with restricted ranges.” Likewise, the National Forest Management Act 

(NFMA) directs that management prescriptions “provide for diversity of plant and animal communities.”

Centers of endemism (areas with the presence of a high number of endemic species) have been 

identified in Southeast Alaska which are thought to have been refugia during the last glacial event (Cook 

et al. 2001, 2006). Some of these locations coincide with areas that have also experienced high levels of 

timber harvest and which may be ready for young-growth harvest.

Due to their restricted ranges, specific habitat requirements, and sensitivity to human activity, insular 

endemic species (i.e., those restricted to islands or groups of islands) are highly susceptible to extirpation 

and eventually extinction (Reid and Miller 1989; Burkey 1995). Species tied to island archipelagos are 

more sensitive to the effects of introduced non-natives, including pathogens and disease, and natural 

events, such as climate change, than other managed landscapes due to their limited mobility and 
Environment and Effects 3

Final EIS 3-108 Wildlife

isolation from other subpopulations (Cook et al. 2006). The 2016 Forest Plan Amendment EIS (USDA 

Forest Service 2016b) provides a detailed discussion on endemism and its implications on the Tongass.

There are 24 known endemic wildlife species (mammals and birds) on the Tongass (Table 3.3-18) (also 

see USDA Forest Service 2016b, Wildlife section; ISLES 2013). The Alaska Natural Heritage Program 

(AKNHP) has established a working web-based interactive range map and list of endemic species for 

Alaska. Two of the more well-studied species, the Prince of Wales flying squirrel and Prince of Wales 

spruce grouse, are endemic to portions of the Tongass where much of the past timber harvest has been 

concentrated and are described in more detail below. Other species include the Coronation Island longtailed vole, Admiralty Island ermine and vole, and the Warren Island red-backed vole, which occur where 

little to no past harvest has occurred. The Alexander Archipelago wolf and Alexander Archipelago black 

bear are also thought to be endemic taxa and are described above.

Old-growth timber harvest has the potential to remove habitat used by some endemic species, such as 

snags and hollow trees used by the Keen’s myotis and the Prince of Wales flying squirrel, but may also 

create habitat for some species e.g., regenerating forest stands for spruce grouse. Fragmentation of 

habitat patches could limit the ability of some species, e.g., flying squirrels, to disperse between areas of 

suitable habitat. In addition, for those species that are hunted, roads have the potential to increase hunter 

access and thus may increase harvest rates along the road system and the areas that these roads 

access (note that there are no known road thresholds relative to road density for these species).

Prince of Wales Flying Squirrel

The Prince of Wales flying squirrel is endemic to the Prince of Wales Island complex (Demboski et al. 

1998; Smith 2005). Due to its close association with old-growth forest structure and processes and 

because of its specific habitat requirements for efficient movement, some authors have expressed 

concern about the long-term viability of this species because much of its range overlaps areas that have 

been affected by old-growth timber harvest (Carey 2000; Scheibe et al. 2006; Pyare et al. 2010).

Prince of Wales flying squirrels are associated with POG forest and den sites are typically located in 

areas with lower levels of fragmentation than elsewhere on the landscape (Pyare et al. 2010). Thus, 

successful dispersal of the species depends on the functional connectivity of the landscape (Smith et al. 

2005).

Table 3.3-18

Endemic Wildlife Species Documented on the Tongass National Forest

Species Known Distribution

Prince of Wales spruce grouse (Falcipennis 

canadensis isleibi)

Prince of Wales Island and nearby island including Heceta, 

Suemez, Warren, Kosciusko, Zarembo, and Mitkof

Admiralty Island beaver (Castor canadensis phaeus) Admiralty Island

Prince of Wales flying squirrel (Glaucomys sabrinus 

griseifrons)

Prince of Wales Archipelago

Pacific marten (Martes caurina) In Southeast Alaska, restricted to Admiralty and Kuiu 

islands

Coronation Island long-tailed vole (Microtus 

longicaudus coronarius)

Coronation, Warren, and Forrester islands

Sitka root vole (Microtus oeconomus sitkensis) Baranof and Chichagof islands complex

Admiralty Island meadow vole (Microtus 

pennsylvanicus admiraltiae)

Admiralty Island

Baranof Island ermine (Mustela ermine initis) Baranof and Chichagof islands

Admiralty Island ermine (Mustela erminea salva) Admiralty Island

Revillagigedo Island red-backed vole (Myodes 

gapperi solus)

Revillagigedo Island

Warren Island red-backed vole (Myodes gapperi 

wrangeli)

Wrangell and Sergief islands

Keen’s myotis (Myotis keenii) Records from Juneau south

Alexander Archipelago mink (Neovison vison 

nesolestes)

Admiralty Island

Forrester Island deermouse (Peromyscus keeni 

oceanicus)

Forrester Island
Environment and Effects 3

Final EIS 3-109 Wildlife

Table 3.3-18 (continued)

Endemic Wildlife Species Documented on the Tongass National Forest

Species Known Distribution

Sitka deermouse (Peromyscus keeni sitkensis) Baranof, Chichagof, Warren, Coronation, and Duke islands

Insular dusky shrew (Sorex monticolus elassodon) Alexander Archipelago and Haida Gwaii

Warren Island dusky shrew (Sorex monticolus 

malitiosus)

Warren Island

Alexander Archipelago black bear (Ursus 

americanus pugnax)

Throughout Southeast Alaska, except Admiralty, Baranof, 

and Chichagof islands

“Glacier bear” (Ursus americanus emmonsii) Yakutat/Glacier Bay region

Yakutat brown bear (Ursus arctos dallli) North mainland from Yakutat to Glacier Bay

Sitka brown bear (Ursus arctos sitkensis) Alexander Archipelago and northern mainland

Source: ISLES 2013

Under the Old-growth Habitat Conservation Strategy, the system of small OGRs was designed to provide 

for the distribution of flying squirrels in every major watershed and facilitate functional connectivity

between larger reserves (USDA Forest Service 1997a). However, some biologists suggest that many 

reserves on Prince of Wales Island may be too small or spaced too far apart to support populations of 

Prince of Wales flying squirrels over the long term or maintain functional connectivity to support a backand-forth exchange between flying squirrel populations (Pyare and Smith 2005; Smith et al. 2011). In 

addition to the system of OGRs, connectivity between reserves for flying squirrels is also provided by the 

legacy forest structure, stream, lake, and beach and estuary buffer standards and guidelines. These 

features represent significant structural elements providing functional connectivity among landscape 

elements.

Prince of Wales Spruce Grouse

The Prince of Wales spruce grouse (spruce grouse) is a subspecies endemic to Prince of Wales and 

nearby islands in southern Southeast Alaska. The spruce grouse is associated with muskegs, highvolume POG, and mixed conifer (scrub) habitats but will also use young-growth forest (15-30 years 

following timber harvest) with a well-developed middle story; they avoid clearcuts (Russell 1999). Though 

they are closely associated with conifer forests, the highest densities of spruce grouse are supported by 

areas with a mosaic of older coniferous habitats interspersed with regenerating patches of dense trees. 

Spruce grouse are poor long-distance flyers and are generally sedentary, with some limited migratory 

movement (typically less than a mile; Dickerman and Gustafson 1996) between summer and winter 

habitats (Boag and Schroeder 1992; Williamson et al. 2008).

Spruce grouse are an important prey species for goshawks and marten. Forest birds, including spruce 

grouse, comprised a larger proportion of goshawk diets during the breeding season on Prince of Wales 

Island than elsewhere in Southeast Alaska (Lewis et al. 2006). Thus, impacts to spruce grouse could also 

impact goshawk and marten populations. Spruce grouse are managed as a game species by ADF&G.

Timber harvest and associated fragmentation may lead to population declines if open areas are too large 

or forested patches are spread too far apart to enable spruce grouse to move between them (greater than 

1 mile). Clearcuts may also present a dispersal barrier to this species due to the thick logging debris often 

present which could inhibit walking, this species’ preferred method of movement (Russell 1999).

Spruce grouse are a small game species that are particularly vulnerable to hunting along road systems, 

and thus are susceptible to overexploitation near roads and human populations (Williamson et al. 2008; 

Rabe 2009). Existing total road densities are provided in Table 3.3-15. The current season for grouse is 

August 1 through May 15 with a bag limit of five per day in GMU 2 (ADF&G 2018a). The Old-growth 

Habitat Conservation Strategy maintains connectivity within matrix lands that will help facilitate dispersal 

and interchange between spruce grouse populations.

Environmental Consequences

This section describes effects on wildlife resources in the analysis area.
Environment and Effects 3

Final EIS 3-110 Wildlife

The Tongass Forest Plan Old-growth Habitat Conservation Strategy provides the platform to manage 

wildlife habitat across the planning area to maintain viable and well distributed populations. For this 

analysis, the evaluation of viability includes considerations of the island archipelago environment as well 

as the best available science related to each species.

This section begins with an analysis of effects on the overall Old-growth Habitat Conservation Strategy, 

which is addressed in detail in the 2016 Forest Plan Amendment EIS Appendix D and discussed in the 

Biological Diversity section of this FEIS. The use of the word “wildlife” occurs frequently in this discussion 

without referencing a particular species because the intent is to consider each of the contributing 

elements of the conservation strategy and their ability to function as intended with respect to old-growth 

associated species under the alternatives. Modifications to various Forest Plan standards and guidelines 

occurred through interagency technical workgroups, workshops, and advisory groups during revisions to 

the 1997, 2008, and 2016 Forest Plans. Monitoring on the Tongass has helped to inform the 

management actions taken under the standards and guidelines to protect wildlife resources in the 

Tongass. The current Forest Plan considered the past actions related to timber harvest and other 

activities that have affected wildlife and their habitat. This Alaska Roadless Rule EIS evaluates how the 

alternatives would affect wildlife and their habitat under the current 2016 Forest Plan.

Following this discussion, impacts to individual species are addressed. 

Indirect Effects

Old-growth Habitat Conservation Strategy

The Tongass Old-growth Habitat Conservation Strategy was designed to maintain well-distributed, viable 

wildlife populations across the Forest in the context of past and anticipated old-growth timber harvest. 

Since 1997, timber harvest rates have been far below those assumed in the 1997 Forest Plan Final EIS, 

the 2008 Forest Plan EIS, and the 2016 Forest Plan Amendment EIS (USDA Forest Service 1997a, 

2008a, 2016b). Under all of the alternatives, long-term protection of POG would continue to occur under 

the Conservation Strategy. The system of OGRs and other non-development LUDs is intended to 

maintain the ecological integrity of the old-growth ecosystem; all non-development LUDs would remain 

intact across all alternatives. Within the matrix, old-growth between reserves is maintained through 

Forest-wide standards and guidelines for stream buffers, the beach and estuary fringe, legacy forest 

structure, and others that preclude or limit POG timber harvest for other resources under all alternatives 

(USDA Forest Service 2016a). Collectively, these measures would facilitate and maintain connectivity and 

functionality of the old-growth ecosystem (USDA Forest Service 2016a).

Common to all alternatives, young-growth harvest within the reserve system, beach and estuary fringe, or 

RMAs has the potential to affect the integrity of the Old-growth Habitat Conservation Strategy under the 

Forest Plan. Effects can include reduced functionality of these areas, reduced or fragmented buffers, and 

increased edge effects. However, the Forest Plan only allows RMA harvest outside of TTRA buffers, and 

beach fringe harvest is only allowed outside of a 200-foot buffer along the shoreline. Additional Forest 

Plan restrictions on harvest of young growth apply within these areas (created openings must be less 

than 10 acres and less than 35 percent of stand can be removed) and harvest is limited to a one-time 

entry within the first 15 years of Forest Plan implementation. Because of these strong limitations on 

harvest, modeling results for the Forest Plan presented in the 2016 Forest Plan Amendment EIS (USDA 

Forest Service 2016b) estimated that only approximately 3,900 acres of young-growth within the beach 

and estuary fringe, 1,100 acres in riparian management areas, and 1,800 acres in Old-growth Habitat 

LUD would be harvested over 100 years. The analysis assumed application of the 2001 Roadless Rule 

and is represented by Alternative 1 in this EIS. For the action alternatives, the acres of suitable young 

growth in these special areas would not increase that much because most young growth occurs outside 

of roadless areas and is already captured under Alternative 1. The maximum increase in suitable young 

growth in these special areas under the action alternatives would occur under Alternative 6 and is 6 

percent for RMA and beach fringe suitable and 12 percent for Old-growth Habitat LUD suitable. It is likely 

that any increase in harvest in these areas under the action alternatives, if any, would be a lower 

percentage than the percent increase in suitable. In addition, the effects of harvest in these areas would 

be localized. Ultimately, the substantial reduction in old-growth harvest through the transition to younggrowth harvest under the Forest Plan would enhance biological diversity and further support the overall 
Environment and Effects 3

Final EIS 3-111 Wildlife

function of the Conservation Strategy over the long-term, and would not change under any of the 

alternatives.

General Effects – POG and Roads

Relative to old-growth habitat conservation, all of the alternatives would allow old-growth harvest at levels 

similar to the level predicted in the Forest Plan Amendment EIS (USDA Forest Service 2016b) though 

more areas would be available to choose from. For Alternative 1 with maximum timber harvest over the 

planning horizon (100 years), approximately 91 percent of the original total POG, 85 percent of the 

original high-volume POG, and 78 percent of the original large-tree POG would be maintained (see 

Tables 3.3-7, 3.3-8, and 3.3-9). By biogeographic province, 72 to 100 percent of the original total, 61 to 

100 percent of the original high-volume, and 33 to 100 percent of the original large-tree POG would be 

maintained. Overall, under the action alternatives, effects on wildlife resulting from these POG reductions 

are not expected to be substantially different from Alternative 1 (implementation of the Forest Plan under 

the 2001 Roadless Rule) (see Tables 3.3-7, 3.3-8, and 3.3-9). By biogeographic province, 72 to 100 

percent of the original total, 61 or 62 to 100 percent of the original high-volume, and 33 to 100 percent of 

the original large-tree POG would be maintained. 

Timber harvest in newly opened areas and associated road construction or reconstruction has the 

potential to decrease the value of these roadless areas to wildlife through increased habitat fragmentation

and reduced landscape connectivity. Additionally, species that are vulnerable to overharvest (e.g., wolf, 

marten, and spruce grouse) would be affected by potential increased hunter and trapper access along 

new or reconstructed roads, whether for young-growth or old-growth harvest or renewable energy 

projects. Regulated/coordinated game harvest management would help improve flexibility for land 

management. These indirect human effects can be a primary driver of population sizes over land 

management. As with all alternatives, the specific magnitude of effects and where these would occur 

would be evaluated at the project level through a separate NEPA process. Total road miles to be 

constructed under each alternative are expected to be similar because the harvest levels are the same 

(see Table 3.3-21). However, Alternatives 3, 4, 5, and 6 are expected to result in more roads being built 

because these alternatives result in suitable timber in progressively more remote areas than under 

Alternatives 1 and 2. New road construction under all alternatives is expected to range from 994 miles 

under Alternative 1 to 1,043 miles under Alternative 6. Likewise, road construction over decommissioned 

roadbeds would range from an estimated 527 miles to 541 miles, and road reconstruction would range 

from an estimated 1,104 miles to 1,123 miles, respectively (see Table 3.3-21). 

Comparison of Action Alternatives

Although IRAs were not part of the original 1997 Old-growth Habitat Conservation Strategy, they add value 

by providing larger expanses of roadless refugia, which are important to wide-ranging wildlife species such 

as wolves, brown bears, marten, and less mobile species such as flying squirrels and amphibians. 

Alternative 2, would remove roadless designation from areas identified as roaded roadless (e.g., roaded or 

altered before the 2001 Roadless Rule or during the 2001 Roadless Rule exemption period) which would 

allow slightly more access to harvest forest stands than under the current Forest Plan (Alternative 1), but 

would be limited to areas that already have a road system. Young-growth harvest within the Old-growth 

Habitat LUD, Beach Fringe, and RMAs would remain restricted to the first 15 years and under the additional 

harvest restrictions addressed earlier. There would be no difference in the amount of harvest under 

Alternative 2 relative to Alternative 1.

Similar to Alternative 2, Alternative 3 would open up areas identified as roaded-roadless but would also 

include areas identified as logical extensions of existing roads. Alternative 3 would be less protective 

because it would result in a net reduction of approximately 1.1 million total acres of roadless designations; 

however, 0.8 million of these acres are LUD II areas, which already have statutorily protection. Alternative 

3 would still rank relatively high overall because it would maintain substantial roadless designations within 

development LUDs and 4.6 million total acres would be managed under a Roadless Priority designation, 

3.3 million acres would be managed under a Watershed Priority ARA, and 0.4 million acres would be 

managed under a Community Priority ARA. Although suitable acres would increase for old growth and 

young growth, there would be no difference in the overall amount of harvest under this alternative relative 

to Alternative 1. An additional benefit of Alternative 3 is that T77 and TNC/Audubon Conservation Priority 
Environment and Effects 3

Final EIS 3-112 Wildlife

Areas outside of roadless (507,000 acres) would be given permanent protection from old-growth harvest; 

this would be designated in the Alaska Roadless Rule. 

Alternative 4 would remove the roadless designation on areas identified as roaded roadless and on areas 

identified as logical extensions of existing roads. Alternative 4 would be less protective than Alternative 3 

but would still include a high number of roadless acres within development LUDs. However, 757,000 

roadless acres are designated as Timber Priority, which provides little or no protection of roadless 

characteristics and essentially eliminates the roadless protections provided in these development LUDs. 

Although suitable acres would increase for old growth and young growth, there would be no difference in 

the overall amount of harvest under this alternative relative to Alternative 1.

Under Alternative 5, approximately 7.0 million acres would be maintained and managed as Roadless 

Priority or LUD II Priority. Roadless designations would be removed on all development LUDs and mineral 

overlay areas and, as a result, it would rank the second lowest in terms of roadless designations. 

However, it would still be moderate in terms of overall protection due to the degree of protections 

provided by the underlying Forest Plan LUDs and Forest Plan standards and guidelines, which would not 

change. Because overall harvest levels would not change relative to Alternative 1 and because the 

broader Old-growth Habitat Conservation Strategy for the Tongass was developed prior to the roadless 

rule and would be maintained under the Forest Plan, the general effects of Alternative 5 on wildlife and 

the Conservation Strategy are expected to be relatively low but slightly greater than projected under the 

other alternatives, with the exception of Alternative 6. 

Whereas the roadless rule language under Alternatives 2, 3, 4, and 5 would be modified, all regulatory 

roadless designations would be removed from the Tongass under Alternative 6 and, therefore, it would 

rank the lowest in terms of roadless designations and habitat protections. However, it would still be 

moderate in terms of overall protection due to the degree of protections provided by the underlying Forest 

Plan LUDs and Forest Plan standards and guidelines, which would not change. Because overall harvest 

levels would not change relative to Alternative 1 and because the broader Old-growth Habitat 

Conservation Strategy for the Tongass was developed prior to the roadless rule and would be maintained 

under the Forest Plan, the general effects of Alternative 6 on wildlife and the Conservation Strategy are 

expected to be relatively low but greater than projected for the other alternatives.

Species-specific Effects

The following sections describe impacts to threatened and endangered species, MIS, Alaska Region 

sensitive species, migratory birds, and endemic species that could occur by implementing the Forest Plan 

under the Alaska Roadless Area alternatives.

Threatened, Endangered, and Candidate Species

On the Tongass National Forest all ESA listed species are associated with the off-shore marine environment 

adjacent to the National Forest. There are no ESA listed threatened or endangered species that occupy the 

terrestrial or aquatic ecosystems systems managed by the Tongass National Forest with the exception of a 

few isolated haul-out locations for the Stellar sea lions associated with the western DPS.

The review of ESA listed species and habitats for the action alternatives associated with this analysis 

were found to have ‘no effect’ to any threatened or endangered species or designated critical habitat and 

therefore there is no need for consultation with either the USFWS or NMFS.

Under Section 7(a)(2) of the ESA, Federal agencies must ensure that actions they authorize, fund, or 

carry out are “not likely to jeopardize the continued existence” of any Federally listed threatened or 

endangered species or result in the destruction or adverse modification of the designated critical habitat 

of these species (16 U.S.C. § 1536(a)(2)). In general, if a Federal agency determines that an agency 

action may affect a listed species or designated critical habitat, it must initiate consultation. If the action 

agency determines that its action will have no effect on a listed species or designated critical habitat, the 

ESA section 7(a)(2) consultation obligations are not triggered. The Federal agency taking action 

evaluates the possible effects of its action and determines whether to initiate consultation (50 CFR §§ 

402.14(a), 402.17(c)). 
Environment and Effects 3

Final EIS 3-113 Wildlife

The ESA regulations define “effects of the action” to include “all consequences to listed species or critical 

habitat that are caused by the proposed action, including the consequences of other activities that are 

caused by the proposed action. A consequence is caused by the proposed action if it would not occur but 

for the proposed action and it is reasonably certain to occur” (50 CFR § 402.02). In this context, “‘but for” 

causation means that the consequence in question would not occur if the proposed action did not go 

forward. In other words, if the agency does not implement an action alternative associated with an 

analysis and the activity would still occur, there is no ‘but for’ causation. In that event, the activity would 

not be considered an effect of the action under consultation (84 FR 44976, 44977 (Aug. 27, 2019); 50 

CFR§ 402.17(b)). 

In regards to the action alternatives associated with this environmental impact statement, the alternatives 

described in this Environmental Impact Statement are not the source of causation for potential adverse 

effects to threatened or endangered species, rather ‘but for’ causation stems from the 2016 Forest Plan 

decision and not as a result of any changes to the roadless rule as described in this EIS.

All of the alternatives considered in this Roadless Rule EIS maintain the current 2016 Forest Plan LUDs, 

standards and guidelines, and predicted harvest amounts.

Threatened and Endangered Marine Mammals

Adherence to the ESA, MMPA, and NMFS guidelines for approaching sea lions and other marine 

mammals, as currently required under the Forest Plan, would continue under any alternative. The amount 

of human activity in the marine environment associated with Forest management activities is only a 

fraction of the total amount of human activity occurring in the marine environment. Land use designations 

and forest-wide standards and guidelines that have been developed for application on all Forest Service 

permitted or approved activities minimize or eliminate adverse impacts on marine species. Any Alaska 

Roadless Rule decision would not result in on-the-ground effects. Any future Forest Service actions or 

authorizations will be subject to additional Section 7 consultation under the ESA, as well as consultation 

required at the project level.

The proposed federal action and the adoption of any of the action alternatives resulting in changes to the 

roadless rule for Alaska are not the source of causation for any potential effects to threatened or 

endangered species or designated critical habitat and will have no-effect to listed species or designated 

critical habitat. When specific timber or other projects are proposed, site-specific NEPA analysis would be 

conducted at that time. 

Short-tailed Albatross

Short-tailed albatross may occasionally occur in nearshore areas along the outer coast. Changes to the 

roadless rule for Alaska are not the source of causation for any potential effects and will have no-effect to 

the short-tailed albatross.

Alaska Region Sensitive Species

Queen Charlotte Goshawk

Timber harvest in both old-growth and mature young-growth forest may locally limit goshawk population 

capacity and affect prey populations through the modification of forest stands and reduction in contiguous 

mature forest. Nest trees optimally should be surrounded by contiguous stands of mature or old-growth 

forest large enough to include several alternate nests and provide post-fledging habitat. Timber harvest 

may also decrease foraging habitat quality through reductions in prey abundance and availability. Dense 

young-growth stands are difficult for goshawks to hunt, reducing availability of prey, even where prey 

populations may otherwise be adequate. The availability of adequate prey resources has been linked to 

goshawk territory occupancy and breeding success (Doyle and Smith 1994; Salafsky et al. 2005; Keane 

et al. 2006; Salafsky et al. 2007).

Forest Plan Standards and Guidelines for this species include project-level survey requirements for 

nesting goshawks, retention of confirmed or probable nest stands, designing and maintaining a buffer 

area of not less than 100 acres of POG forest if it exists centered on or adjacent to the nest tree or nest 

site, timing restrictions during active nesting, and retention of legacy old-growth forest structure in oldgrowth harvest units larger than 20 acres, where logging has been most intensive (USDA Forest Service 
Environment and Effects 3

Final EIS 3-114 Wildlife

2016a). The system of OGRs and other non-development LUDs also maintains habitat for this species, 

although a recent study suggests that some uncertainty remains with respect to the ability of Forest Plan 

conservation measures to contribute sufficient habitat to sustain well-distributed, viable populations of 

northern goshawks throughout Southeast Alaska (Smith 2013). Continued project-level required protocollevel surveys, inventories and monitoring of established nest protection buffers will help to inform future

decisions.

Impacts to goshawks are assessed in terms of the reduction in total and high-volume POG, which 

provides potential high-quality nesting and foraging habitat. High-volume POG represents optimal nesting 

habitat due to the presence of large trees and snags. Reductions in forest cover, and the subsequent 

progression of forest succession in young-growth stands, also have the potential to affect the abundance 

and availability of prey. At a landscape level, reductions in the amount of POG and mature young-growth 

forest may result in portions of the landscape becoming marginal or unsuitable for goshawks. Under all 

alternatives, the projected harvest level would be about 42,500 acres of old growth and 284,000 acres of 

young growth over 100 years. Approximately 86 percent of the original high-volume POG existing in 

1954, the time at which industrial scale logging began on the Tongass, remains (see Table 3.3-8 in the 

Biological Diversity section). After 100 years of implementation under Alternative 1 or any of the action 

alternatives, approximately 85 percent of the original high-volume POG is expected to remain (see Table 

3.3-8). None of the action alternatives would increase harvest rates of POG above the level of Alternative 

1 (refer to the Biological Diversity section for a discussion of effects on POG by biogeographic province).

Young-growth forest provides marginal goshawk habitat, but over the long term, if unharvested or thinned 

with an objective of accelerating old-growth conditions, would return to old-growth conditions. Younggrowth stands ready for commercial harvest may be reaching an age to provide some benefits to 

goshawk (foraging, occasional nesting, post-fledging areas) if adequate structure is developed (typically 

50 to 100 years following harvest, depending on site productivity).

Under all alternatives, impacts to goshawks would still be greatest in the North Central Prince of Wales, 

Kupreanof/Mitkof Island, East Chichagof Island, and Revilla Island/Cleveland Peninsula biogeographic 

provinces where the most suitable young-growth forest is located; these provinces have been harvested 

relatively heavily in the past and considerable additional old-growth harvest would occur in the future. The 

beach and estuary fringe and RMAs provide connectivity for goshawks between reserve areas, and oldgrowth forest near beach, estuary, and riparian habitats generally support greater prey diversity and net 

prey productivity for goshawk foraging. Thus, young-growth stands in these areas have the potential to 

develop into productive habitats for goshawks. Pre-commercial and commercial thinning of young-growth 

stands, which would occur under all of the alternatives, would promote the development of stand 

conditions that improve foraging habitat for goshawks. However, even-aged harvest or group-selection of 

young-growth in these areas, as well as in the Old-growth Habitat LUD, would set back the stand 

development process (returning harvest units to the stand initiation stage). The creation of gaps several 

acres in size or more could result in localized reductions in goshawk foraging habitat quality and would 

delay the development of old-growth habitat capable of providing higher quality foraging, nesting, and 

post-fledging habitat. Effects to connectivity for goshawks are lessened through implementation of Forest 

Plan standards and guidelines (Beach and Estuary Fringe, RMAs, Legacy tree, goshawk habitat, and 

protection measures).

Despite these localized and project-level implementation effects, the transition to young growth guided by 

the 2016 Forest Plan, unchanged by the Alaska Roadless Rule alternatives, is likely to benefit goshawks 

by reducing the amount of POG harvest that would occur over the planning horizon, thereby maintaining 

more old-growth forest that provides potential foraging, nesting, and post-fledging habitat.

Individual projects would be required to conduct goshawk surveys and implement the goshawk standards 

and guidelines which would minimize impacts to this species at the project level. For the reasons 

articulated in this section, including the maintenance of the Old-growth Habitat Conservation Strategy, all 

the alternatives considered would not result in a loss of viability of this species or trend toward federal 

listing.
Environment and Effects 3

Final EIS 3-115 Wildlife

Kittlitz’s Murrelet

The Kittlitz’s murrelet is associated with glacial habitat and occupies areas outside of where timber 

harvest and associated activities and other development have occurred or are likely to occur. 

Consequently, implementation of any of the alternatives, guided by the 2016 Forest Plan restrictions 

would have no impact on the Kittlitz’s murrelet. The 2016 Forest Plan standard and guideline to “provide 

for the protection and maintenance of known Kittlitz’s murrelet nesting habitats” would be unchanged. 

Project-level analysis would occur should any future development be proposed near tidewater glaciers.

Black Oystercatcher

The black oystercatcher is associated with rocky shorelines and tidal mudflats along the coast. They 

could be affected by oil or fuel spills associated with vessels in the vicinity of the LTFs and the transport 

of logs from harvested areas under all of the alternatives. They could also be affected by disturbance 

associated with management activities within the beach fringe.

However, black oystercatchers occur at low densities across the Tongass and the habitats it uses 

(intertidal areas) do not typically coincide with management activities, although there is the potential for 

ongoing effects associated with recreation and tourism activities on the Tongass, disturbance associated 

with young-growth harvest in the beach fringe, and energy development or other activities under all 

alternatives. The Forest Plan requires a minimum 330-foot buffer from human activities around 

concentration or nesting areas that would apply to future projects regardless of roadless status. For these 

reasons, all the alternatives considered would not result in a loss of viability of this species or trend 

toward federal listing.

Aleutian Tern

Threats to this species include human disturbance at nest sites, marine oil spills, and change in forage 

fish populations (USFWS 2012d). Common to all alternatives, timber harvest associated activities (i.e., 

log transport, use of LTFs, and helicopter activity) could have the potential to affect this species through 

disturbance to nesting colonies or through water quality impacts to prey species. Although most known 

colonies are in remote sites in areas surrounded by non-development LUDs, some do exist in areas 

where Forest Service permitting may have the potential to cause disturbance. There is no specific Forest 

Plan direction for this species but the standards and guidelines for Seabird Colonies apply (USDA Forest 

Service 2016a).

None of the alternatives would increase the potential of any young-growth or old-growth harvest or other 

management activities in the vicinity of Black Sand Spit, in the Yakutat Ranger District, where the largest 

known breeding colony occurs. Only Alternatives 5 and 6 would remove this area from roadless 

designation; however, harvest in the vicinity would not occur because it is in a non-development LUD, as 

well as a conservation priority area as identified by The Nature Conservancy (TNC) and Audubon Alaska 

(2007). Therefore, all the alternatives considered would not result in a loss of viability of this species or 

trend toward federal listing.

Steller Sea Lion (Eastern DPS)

Steller sea lions may occur in the nearshore and pelagic waters throughout the Tongass. Common to all 

alternatives, Steller sea lions have the potential to be exposed to disturbance and noise associated with 

LTF activity, potential collisions with vessels, and fuel or oil spills associated with vessel traffic particularly 

if these activities occur in the vicinity of major haul-outs or rookeries. All identified rookery sites occur in 

the outside waters of the Tongass far from expected activities. One site, Forrester Island, is a designated 

National Wildlife Refuge and is under the jurisdiction of the USFWS. Most of the known haulouts (Biali 

Rock, Cape Cross, Biorka Island, Cape Ommaney, Coronation Island, Timbered Island, and Cape 

Addington) occur in the outside waters of the Tongass and would not likely be impacted by any future 

activities permissible under any of the alternatives. Of the known haulout sites, only Gran Point, Benjamin 

Island, Sunset Island, and Lull Point occur in the inside waters of the Tongass. Gran Point is an area in 

Chilkoot Inlet near Haines; Benjamin Island is a small island in Lynn Canal north of Juneau; Sunset Island 

is a small island located in Stephens Passage between Hobart and Windham Bay; and Lull Point located 

on the south end of Catherine Island on the east side of Baranof Island. It is unlikely that any of the areas 

identified as critical habitat would be impacted by activities that would be newly permissible under the 
Environment and Effects 3

Final EIS 3-116 Wildlife

alternatives; if impacts do occur that create noise and disturbance (e.g., boating), the potential resulting 

disturbance would likely be minor and temporary and would be addressed at the project level.

The amount of human activity in the marine environment associated with Forest management activities is 

only a fraction of the total amount of human activity occurring in the marine environment. Some of the 

other activities include commercial fishing, sport fishing, hunting, subsistence, tourism, and mariculture. 

Most of these activities are not regulated by the Forest Service. Adherence to the MMPA, ESA, and

NMFS guidelines for approaching sea lions, as currently required under the Forest Plan, would continue 

under all alternatives. Young-growth timber harvest within the beach fringe or other developments in 

these areas have the potential to result in very localized, minor, temporary reductions in water quality to 

which Steller sea lions could be exposed. Therefore, all the alternatives considered would not result in a 

loss of viability of this species or trend toward federal listing.

Sitka Black-Tailed Deer

Extensive analysis on deer was done for the 1997 Forest Plan and subsequent 2008 and 2016 Forest 

Plan Amendment EIS. Analyses conducted during the 2016 Forest Plan Amendment EIS also included 

information on summer and winter forage and effects of roadbuilding, noting that the expected ecological 

response of deer to old-growth and mature young-growth timber harvest, road building, and vegetation 

succession would be similar to those predicted previously, but the extent of future impacts would be 

expected to be reduced from earlier analyses because lower levels of old-growth harvest were proposed 

in all action alternatives in the 2016 Forest Plan Amendment EIS (USDA Forest Service 2016b).

As part of the 2016 Forest Plan Amendment EIS, the interagency deer habitat capability model was used 

to assess existing habitat capability within the planning area, and describes model limitations, and results 

(see USDA Forest Service 2016b, Wildlife section). Table 3.3-14 summarizes the modeled deer habitat 

capability by biogeographic province. Forest-wide, approximately 89 percent of the original (1954) habitat 

capability remains, ranging from 72 to 100 percent depending on the biogeographic province. The 

greatest reductions in deer habitat capability have occurred, and will continue to occur, in provinces 

where timber harvest has been concentrated (the North Central Prince of Wales, East Baranof, and Etolin 

Island biogeographic provinces). 

Due to the continued harvest of POG forest and mature young-growth, deer habitat capability would 

continue to be reduced, but only slightly. Immediately following young-growth and old-growth timber 

harvest, there is an increase in the amount of forage available to deer during the summer and mild winter 

months in response to increased understory growth responding to sunlight associated with opening the 

forest canopy, although it may be of lesser quality compared to the same species of plants grown in the 

shade (Person and Brinkman 2013; Happe et al. 1990). Therefore, reductions in deer habitat capability in 

summer and mild winters are not expected to be realized immediately after timber harvest due to the 

short-term increase in forage but are expected to be greatest in heavy snow winters during years 

immediately following harvest and after about 25 years, as forest succession progresses and harvested 

stands reach the stem exclusion stage. Over the long term, reductions in habitat capability are expected 

to reduce carrying capacity, or the numbers of deer an area is capable of supporting given the available 

resources. This could lead to a decline in the deer population, particularly following severe winters, if the 

demand for resources (e.g., food or habitat) exceeds that which is available. Potential declines in the deer 

population resulting from reduced habitat capability may decrease the availability of deer to wolves 

(Person 2001; Farmer et al. 2007; Brinkman 2009). Likewise, reductions in deer habitat capability over 

the long term may reduce the access to and availability of deer to wolves and subsistence hunters.

At the forest scale, the current Forest Plan maintains 89 percent of the existing deer habitat capability over 

the long term and this would not vary among Alaska Roadless Rule alternatives. Stand treatments (precommercial and commercial thinning) in young-growth forest are not reflected in the deer habitat 

capability, but would result in increased understory growth which improves forage resources for deer over 

the first 15-25 years following harvest.

Other developments, such as energy projects and transmission lines, and transportation projects, can 

affect deer during construction through disturbance and through habitat removal or alteration. Operational 

impacts due to disturbance would be expected to be minimal. Forest Plan standards and guidelines, 

which are unchanged by any Alaska Roadless Rule alternative, include consideration of the most current 
Environment and Effects 3

Final EIS 3-117 Wildlife

science, guidance, and methodologies related to avoiding and minimizing wildlife impacts and minimize 

impacts to deer and/or areas of important deer habitat during construction and operation.

Mountain Goat

Mountain goats inhabit alpine and subalpine areas and adjacent POG forests on the mainland portions of 

the Tongass and have been introduced to several islands. Mountain goats are susceptible to over-hunting 

if road access is increased or improved, though most roads are located a long distance (both vertically 

and horizontally) from mountain goat habitat.

The amount of road access quantified in terms of the amount of road construction and reconstruction, common to 

all alternatives, is representative of the potential for over-hunting. The projection over the next 100 years was 

modeled to include 994 to 1,043 miles of new road construction, 527 to 541 miles of road construction over 

decommissioned roadbeds, and 1,104 to 1,123 miles of road reconstruction for Alternative 1 and the action 

alternatives. Alternatives 1 and 2 represent the lowest estimated road miles, while Alternative 6 is at the highest 

end of the range. Existing road miles on NFS lands are estimated at 4,929 miles, including open roads, closed 

roads, and decommissioned roads. After 100 years of implementation, NFS lands are estimated to have 5,922 to 

5,972 miles of existing roads, with Alternatives 1 and 2 at the low end and Alternative 6 at the high end and 

Alternatives 3, 4, and 5 in between. This would be an increase of 20 to 21 percent over existing conditions. While 

there would be acres potentially available for harvest with each of the action alternatives, there would be no 

change in the projected harvest amount. Most of the roads, particularly those accessing young-growth units, 

would be below 1,500 feet in elevation and outside of mountain goat habitat. Additionally, many new or 

reconstructed roads would be closed or decommissioned after use, further reducing effects on mountain goats. 

Risk of over-harvest due to human access along roads is mitigated to some extent by Transportation Forest-wide 

standards and guidelines that require travel access road objectives to be developed for all roads and mountain 

goat standards and guidelines, which would not be affected by any Alaska Roadless Rule alternative.

Energy, transportation, or other projects that may become permissible in new areas could affect mountain 

goats through direct disturbance or through removal or modification of habitats. These effects would be 

evaluated at the project level. The Forest-wide standards and guidelines would minimize impacts to 

mountain goats and their habitat during project construction and operation.

Black Bear

Preferred habitats for black bears, which include coastal, estuarine, and riparian areas, are protected by 

the Old-growth Habitat Conservation Strategy. None of the alternatives would remove these measures. 

Common to all alternatives, harvest of mature young-growth and old-growth timber (both even aged as 

well as thinning) would increase forage availability (berries) for black bears over the short term in the 

resulting early-successional plant communities. However, this food source typically lasts only about 25 

years post-logging and decreases over time in association with canopy closure. Over the long term, oldgrowth harvest would decrease habitat suitability for black bears, due to the reduced understory forage in 

young-growth stands and loss of denning habitat in upland areas (e.g., large woody structures such as 

hollow logs and hollow living trees; Davis et al. 2012). The transition to young-growth harvest under the 

current Forest Plan, which is not changed by any of the alternatives, is expected to increase forage 

availability over the long term by reverting young-growth stand in the stem exclusion stage back to the 

stand initiation stage but, development of old-growth stand characteristics used by bears for denning 

would be delayed in those stands. Effects to the contributing elements of the Old-growth Habitat 

Conservation Strategy would be localized and common to all alternatives, with the maximum expected 

young-growth harvest affecting 0.4 percent of forest land in the beach and estuary fringe, 0.3 percent of 

the forest land within RMAs, and approximately 0.2 percent of the forest land (young-growth, POG, and 

unproductive forest) within the Old-growth Habitat LUD. (See USDA Forest Service 2016b, Appendix D 

for additional discussion of the Old-growth Habitat Conservation Strategy). Therefore, these areas would 

continue to function as habitat for black bears.

Timber harvest may also indirectly increase the susceptibility of black bears to over-harvest if road access 

is increased or improved. An increase in open roads, particularly in open habitats such as clearcuts and 

muskegs, where bears forage and are easier to see, can increase the potential for human-bear 

interactions. The amount of road access, quantified in terms of the amount of road construction and 

reconstruction anticipated under the current Forest Plan, is representative of the potential for over-hunting 
Environment and Effects 3

Final EIS 3-118 Wildlife

(see discussion above under Mountain Goat for a comparison of the alternatives). Average total road 

density on NFS lands (across all WAAs) in 100 years would increase to approximately 0.23 mile per 

square mile for Alternative 1 and all action alternatives. This is in comparison to an existing road density 

of 0.19 mile per square mile.

Therefore, any potential increase in hunter access and risk of over harvest would be localized, and no 

measurable increase would be expected at the forest scale under any of the alternatives.

Energy, transportation, or other projects that may become permissible in new areas could affect black 

bears through direct disturbance or through removal or modification of habitats. These effects would be 

evaluated at the project level. The Forest-wide standards and guidelines would minimize impacts to black 

bears and their habitats during project construction and operation.

River Otter

River otters prefer habitats, especially POG forest, immediately adjacent to coastal and fresh water

aquatic environments, with most use occurring within 500 feet of these areas. These old-growth habitats 

are protected by Forest Plan standards and guidelines for the beach and estuary fringe, riparian areas, 

and lakes which would be implemented under all alternatives.

Energy, transportation, or other projects that may become permissible in new areas could affect river 

otters through direct disturbance or through removal or modification of habitats, particularly if activities 

affect waterbodies. These effects would be evaluated at the project level. Forest-wide standards and 

guidelines would minimize impacts to river otters and their habitats during project construction and 

operation.

American Marten

Through the removal of forest cover and old-growth ecosystem features such as decadent live trees and 

snags, timber harvest (POG harvest and young-growth harvest) under that could occur under all 

alternatives would reduce the vertical and horizontal structural complexity important to marten in relation 

to prey access, denning and resting sites, escape from predation, and thermoregulation (Buskirk and 

Zielinski 1997; Hargis et al. 1999; Flynn and Schumacher 2001). Forest fragmentation resulting from 

timber harvest may also alter patterns of occupancy by marten (Bissonette et al. 1997; Chapin et al. 

1998). Although more recent research indicates that marten use all forested stands relative to their ability, 

including young-growth stands mixed conifer and deciduous stands less than 40 years of age (Goldstein 

et al. 2013), harvests that result in the greatest reduction in deep snow marten habitat (high-volume POG 

at or below 800 feet elevation) are expected to have the greatest adverse effects to marten.

Reductions in deep snow marten habitat may result in localized reductions in the capability of the 

remaining habitat to support marten. Under Alternative 1, about 13,900 acres of deep snow marten 

habitat is projected to be harvested over the next 100 years; under the action alternatives, about 11,000 

to 13,400 acres are projected for harvest during this timeframe (Table 3.3-19).

Table 3.3-19

Estimated Harvest (acres) of High-Volume (SD5N, SD5S, and SD67) and LargeTree (SD67) Productive Old-Growth by Elevation Category and Alternative after 

100 years (NFS lands only)

Elevation 

Category

Alternative

1 2 3 4 5 6

High-Volume POG

< 800 feet 13,890 13,405 11,809 10,989 10,969 10,969

> 800 feet 10,227 10,340 11,902 12,671 12,681 12,681

Total 24,117 23,745 23,711 23,660 23,650 23,650

Large-Tree POG

< 800 feet 5,516 5,213 4,466 4,032 3,992 3,992

> 800 feet 3,183 2,925 3,513 3,794 3,826 3,826

Total 8,699 8,138 7,979 7,825 7,818 7,818
Environment and Effects 3

Final EIS 3-119 Wildlife

Increased human access associated with new roads may result in increased marten vulnerability to 

harvest, particularly along open roads (Flynn et al. 2004). Harvest under the Forest Plan, under all 

alternatives, would result in minor increased average total road densities; however, the proportion of 

WAAs within various road density categories would not likely change under any of the alternatives (see 

the discussion under Black Bear). Increased road densities have the potential to indirectly increase hunter 

access and associated trapping pressure; however, these effects would be minor and would not 

significantly differ among alternatives as no increased harvest and only slight increases in roading 

(Alternatives 3, 4, 5, and 6) are anticipated.

Under the current Forest Plan, marten populations are supported by the Old-growth Habitat Conservation 

Strategy which works to maintain old-growth forest cover and coarse woody debris to provide structure 

important to marten for resting, denning, escape from predators, trapping refugia, and facilitate marten 

dispersal. The beach and estuary fringe and RMAs provide travel corridors for marten, and old-growth 

reserves (OGR) and other non-development LUDs provide refugia from trapping. Pre-commercial and 

commercial thinning of young-growth stands in these areas, which would occur under all of the 

alternatives, would promote the development of stand conditions that provide habitat structure for marten.

However, even-aged harvest or group-selection of young-growth in the beach and estuary fringe, RMAs, 

and non-development LUDs would setback the stand development process (returning harvest units to the 

stand initiation stage). The creation of gaps several acres in size or more could result in localized 

reductions in marten movement, local reductions in prey availability, and would delay the development of 

old-growth habitat conditions in harvested stands. However, overall connectivity for marten would be 

provided through application of the Forest Plan requirement of maintaining the 1,000-foot buffer 

immediately inland of young-growth harvest units in the beach and estuary fringe and a 200-foot buffer 

along the shoreline.

Energy, transportation, or other projects that may become permissible in new areas could affect marten

through direct disturbance or through removal or modification of habitats. These effects would be 

evaluated at the project level. Forest-wide standards and guidelines would minimize impacts to marten 

and their habitats during project construction and operation.

Brown Bear

Brown bears are associated with low-elevation POG forests, particularly along Class I salmon streams. 

These habitats are protected to some extent by Forest-wide standards and guidelines for beach and 

estuary fringe and RMAs. However, young-growth harvest under the Forest Plan would occur in these 

areas under all alternatives. Young-growth harvest within beach and estuary fringe and RMAs are 

discussed above under Black Bear.

Road densities are another measure of the potential impact on brown bears. Primary concerns include 

increased hunting or poaching, and disturbance during critical life stages (e.g., late-summer feeding 

periods for bear). Habitat fragmentation, as well as habitat loss secondary to activities that are facilitated 

by vehicular access (e.g., timber harvest, mining, residential development, and renewable energy 

development) are other potential impacts. Open roads, which receive the highest and most consistent 

use, are likely to have the greatest effect on brown bears, although closed roads still facilitate access 

(e.g., off-highway vehicle, pedestrian) to roadless areas. There is no road density guideline for brown 

bears; however, it can be assumed that increased road density elevates the potential for human-bear 

interactions. Implementation of the Forest Plan under all alternatives would result in minor changes in 

total road density (see the discussion under Black Bear). Increased road densities have the potential to 

indirectly increase human-bear interactions; however, these effects would be minor. Alternatives 1 and 2 

would be similar in their effects, Alternative 3 would be slightly greater, and Alternatives 4, 5, and 6 would 

be slightly greater than Alternative 3. Overall, there is little difference between the alternatives because 

predicted harvests levels are not changed (see Table 3.3-21).

Energy, transportation, or other projects that may become permissible in new areas could affect brown 

bears through direct disturbance or through removal or modification of habitat, particularly if 

developments affect Class I salmon streams. These effects would be evaluated at the project level. The 

Forest-wide standards and guidelines would minimize impacts to brown bears and their habitats during 

project construction and operation.
Environment and Effects 3

Final EIS 3-120 Wildlife

Alexander Archipelago Wolf

The 1997, 2008, and 2016 Forest Plan analyses contain extensive information on wolf ecology, building 

on the wolf assessment (Person et al. 1996). As outlined in the above Forest Plans and associated 

documents, scheduled harvest of POG forest has the potential to result in a small reduction of the wolf 

prey base (deer through decreased deer habitat capability) and increased human access along project 

roads, which could reduce the wolf population through increased legal and illegal hunting and trapping. It 

is assumed that a decline in the deer population would likely result in a decline in the wolf population 

(USDA Forest Service 2008b). Resonating effects could include reductions in opportunities to hunt or trap 

wolves (see USDA Forest Service 2016b, Subsistence section).

These effects are of particular concern on Prince of Wales Island where the population has apparently 

undergone substantial declines over the last several decades; however, this population represents a 

small portion (approximately 4 percent) of the overall Alexander Archipelago wolf population and this 

decline is not anticipated to affect the status of the population at large (USFWS 2015).

Evaluation employing the Interagency Deer Carrying Capacity Model as well as the FRESH Deer Model 

suggests that harvest of POG forest will decrease carrying capacity for deer over the long term because 

of reductions in the amount of available winter habitat due to the ultimate development of forest in stemexclusion. However, this long-term decline in carrying capacity is lessened now due to the current 

Tongass Forest Plan’s transition to young growth, which would not change under any alternative. Current 

deer habitat capability based on the interagency habitat capability model is below the Forest Plan 

guideline of 18 deer per square mile in many WAAs.

This results from several factors and varies among landscapes. Contributing factors include lower 

inherent capability of some landscapes and habitats, reduced habitat capability from past timber harvest

and associated succession, and the static nature of how the model expresses habitat capability during 

succession (e.g., one value for young growth from 25 to 150 years of age). Model results suggested that 

continued harvest of POG forest in some areas would result in higher risk that there will be insufficient 

deer to sustain predation by wolves and human deer harvest over the long term (see existing modeled 

deer densities in Table 3.3-14 and 3.3-16). That concern exists despite the availability of alternative prey 

and current abundance of deer in some parts of the forest.

Projections based on the 2016 Forest Plan indicate a reduction in the existing percentage of WAAs with 

deer habitat capability of at least 18 deer per square mile by 11 percent after approximately 25 years (at 

stem exclusion) (see Table 3.10-14 in USDA Forest Service 2016). After 100 years of Forest Plan 

implementation the reduction in the percentage of WAAs with at least 18 deer per square mile would be 

14 percent. WAAs with the greatest potential impacts are located in South Prince of Wales, North Central 

Prince of Wales, Kupreanof/Mitkof Islands, Revillagigedo Island, and Chichagof Island biogeographic 

provinces (see Table 3.10-14 in USDA Forest Service 2016). Reductions in habitat capability are due to 

both timber harvest as well as natural succession of stands harvested in the past. None of the 

alternatives would be expected to change the model results as there would be no increase in the overall 

harvest relative to the 2016 Forest Plan.

The transition to young-growth harvest under the current Forest Plan is not fully reflected in the 

interagency deer model results because the model does not assign different values to stands that have 

been pre-commercially or commercially thinned (i.e., it still treats them as stands in the stem exclusion 

phase with limited value for deer), or young-growth stands beyond the stem exclusion phase which 

become more suitable for deer. Harvest of young-growth stands would increase summer and low-snow 

winter forage availability for deer over the short term, providing temporary increases in habitat capability 

during most years, but reduced winter habitat capability in high-snow years. Over the long term as younggrowth stands re-enter the stem exclusion phase, habitat capability for deer (and thus potential prey 

availability for wolves) would be expected to decrease (due to reduced forage availability) until the next 

stand treatment. Ultimately, the continued harvest of old-growth and young-growth forest that would be 

permissible under all the alternatives has the potential to result in localized reductions in deer habitat 

capability which may reduce prey availability for wolves in portions of the Tongass where deer are their 

primary prey (e.g., Prince of Wales Island and surrounding islands [GMU 2]). ADF&G recently updated its 

wolf management by game management area. All updated management reports and plans were 

reviewed but the discussion below focuses on GMU 2 (Porter 2018). The harvest data through 2014 was 
Environment and Effects 3

Final EIS 3-121 Wildlife

used for the 2016 Forest Plan. ADF&G plans for the next period (2015-2020) include the development of 

a more formal management plan for Unit 2 wolves (Porter 2018). Other recently updated management 

reports and plans for various GMUs note that changes to seasons and bag limits for wolves are currently 

not needed at this time.

All action alternatives would allow the construction or reconstruction of roads in some areas previously 

prohibited by the 2001 Roadless Rule, but the amount of roads would be similar. Roads associated with 

timber harvest may also increase the risk of both legal and illegal hunting and trapping related wolf 

mortality by increasing human access. Estimated total road densities and open road densities below 

1,200 feet (representative of low elevation habitats used by wolves and deer) would increase by 0.07 and 

0.01 mile per square mile (NFS lands only) for all roads and for NFS roads only under the current Forest 

Plan (Table 3.3-20). Therefore, at most, localized increases in hunter access would be expected under 

the action alternatives with no substantial increase across the Tongass. Alternative 2 would be the same 

as Alternative 1, Alternative 3 would result in slightly more roads than Alternative 2, and Alternatives 4, 5, 

and 6 would result in slightly more roads than Alternative 3. These effects would be lessened through 

road closures after use, through storage or decommissioning. The effectiveness of closure and storage, 

or decommissioning and ultimately the extent of mitigation will depend on both enforcement and the 

approach to closure. These decisions are made at the island, district, and project level through Access 

Travel Management Plans based on an evaluation of all resources.

Table 3.3-20

Estimated Road Miles and Average Road Density below 1,200 feet in Elevation on NFS 

Lands and All Lands Combined for All Roads and for Open Roads by Alternative after 100 

Years

Category

Existing Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

NFS 

Lands

Only

All 

Lands

NFS 

Lands

Only

All 

Lands

NFS 

Lands

Only

All 

Lands

NFS 

Lands

Only

All 

Lands

NFS 

Lands

Only

All 

Lands

NFS 

Lands

Only

All 

Lands

NFS 

Lands

Only

All 

Lands

Road Miles

All Roads 4,698 8,539 5,633 11,373 5,633 11,373 5,650 11,390 5,665 11,405 5,675 11,415 5,679 11,419

Open Roads 2,029 5,479 2,173 5,797 2,173 5,797 2,175 5,799 2,177 5,801 2,178 5,802 2,179 5,802

Road Density (mi/mi2)

All Roads 0.38 061 0.45 0.82 0.45 0.82 0.46 0.82 0.46 0.82 0.46 0.82 0.46 0.82

Open Roads 0.16 0.39 0.18 0.42 0.18 0.42 0.18 0.42 0.18 0.42 0.18 0.42 0.18 0.42

Source: Tongass National Forest GIS layer, 2018, and modeling of alternatives.

Energy, transportation, or other projects that may become permissible in new areas could affect wolves 

directly during construction through disturbance at den and rendezvous sites and indirectly through 

effects to deer habitat and increased vulnerability to harvest. These effects would be evaluated at the 

project level.

The Forest-wide standards and guidelines would minimize impacts to wolves, their habitats, and their 

prey base during project construction and operation, and through cooperation and coordination with 

ADF&G and the Wolf Technical Committee to meet the management intent to secure and support 

sustainable wolf population levels, particularly in GMU 2.

Bald Eagle

Common to all alternatives, timber harvest and associated activities, which create noise and disturbance 

(e.g., blasting and helicopter logging), have the potential to result in minor, temporary disturbance to 

individual bald eagles. As required by the Forest Plan, all activities would be conducted in accordance 

with the Bald and Golden Eagle Protection Act, including maintaining appropriate distances from active 

bald eagle nests. Riparian and beach and estuary standards and guidelines, as well as OGRs and other 

non-development LUDs, protect bald eagle habitat on the Tongass. Management activities in these areas 

could disturb eagles and reduce the protection afforded to suitable bald eagle habitat. Under all 

alternatives, commercial management of young growth (up to 10-acre openings) in the beach and estuary 

fringe and RMAs for the first 15 years after plan approval would continue. Harvest of young-growth in 

these areas would delay development of future trees/snags suitable for eagle nesting, perching, and 
Environment and Effects 3

Final EIS 3-122 Wildlife

roosting; however, it includes a minimum 200-foot forested buffer along the shore (beach) that would 

continue to protect some eagle perching or roosting trees during that time.

Many young growth trees harvested would be of insufficient size to be suitable for nesting or preferable

for roosting. Harvest of young growth has potential to disturb eagles, especially if helicopter harvest 

methods are used. Timing restrictions would apply near active eagle nests in the vicinity of harvest 

activities to minimize disturbance to eagles or the abandonment of nests.

Energy, transportation, or other projects that may become permissible in new areas could affect bald 

eagles directly during construction through disturbance and through habitat removal or alteration. During 

operation, electrocution with powerlines and/or collisions with project structures are a potential risk. These 

effects would be evaluated at the project level. The Forest-wide standards and guidelines would minimize 

impacts to bald eagles, their habitats, and their prey base during project construction and operation. They 

would include adherence to the MBTA, Bald and Golden Eagle Protection Act, and guidelines such as 

APLIC standards for transmission lines (APLIC 2006).

Red Squirrel, Red-breasted Sapsucker, Hairy Woodpecker, and Brown Creeper

These species are associated with old-growth forest and extensive quality habitat is protected through the 

conservation system, particularly OGRs and non-development LUDs. In the matrix, these species rely on 

legacy components (e.g., large diameter trees, snags) of the old-growth forest ecosystem for nesting and 

foraging. Harvests that could occur under all alternatives would result in the removal of POG forest 

nesting and foraging habitat (Tables 3.3-7, 3.3-8, and 3.3-9). Red-breasted sapsuckers are most closely 

associated with low-volume old growth, whereas hairy woodpeckers and brown creepers are associated 

with high-volume and large-tree stands, respectively. Red squirrels are more versatile and will use younggrowth stands as young as 40 years of age. Indirect effects to these species would be associated with 

fragmentation and the reduction in POG patch sizes. Fragmentation reduces the amount and 

effectiveness of interior old-growth forest habitat by creating habitat edges along which may increase 

rates of nest predation by avian predators (Kissling and Garton 2008). Harvest of young-growth stands 

would have minimal fragmentation-related effects to these species because old-growth interior forest 

conditions preferred by these species would not be affected. However, connectivity for red squirrels could 

be locally reduced because this species may use mature young-growth stands that are suitable for 

commercial harvest.

Legacy Forest Structure standards and guidelines which are intended to maintain old-growth structure in 

areas that are already highly developed, as well as areas that will experience increased harvest levels 

over the life of the Forest Plan would continue to be implemented under all alternatives. These 

components (large trees and snags) may provide nesting and foraging habitat for the red squirrels, redbreasted sapsuckers, hairy woodpeckers, and brown creepers.

Energy, transportation, or other projects that may become permissible in new areas could affect red 

squirrels, red-breasted sapsuckers, hairy woodpeckers, and brown creepers during construction through 

direct disturbance or through removal or modification of habitats. During operation, the potential for 

collision with project structures is a risk. These effects would be evaluated at the project level. The Forestwide standards and guidelines would minimize impacts to these species and their habitats during project 

construction and operation.

Vancouver Canada Goose

Vancouver Canada geese use wetlands (forested and non-forested) in the estuary, riparian, and uplands 

areas of the forest. Habitat needs for this subspecies are specifically provided for under the waterfowl 

standards and guidelines, which apply to specific sites, and a 100-foot buffer around lakes and streams. 

The beach, estuary, and riparian Forest-wide standards and guidelines provide additional protection to 

habitats used by Vancouver Canada geese.

Harvest of young-growth within the beach and estuary fringe and RMAs under the Forest Plan could 

affect this species. However, because of Forest Plan measures, effects on the Vancouver Canada goose

should be minimal and would be similar under all alternatives.
Environment and Effects 3

Final EIS 3-123 Wildlife

Energy, transportation, or other projects that may become permissible in new areas could affect the 

Vancouver Canada goose during construction through direct disturbance or through removal or 

modification of habitats. During operation, collision with project structures is a risk. These effects would be 

evaluated at the project level. The Forest-wide standards and guidelines would minimize impacts to 

Vancouver Canada geese and their habitats during project construction and operation.

Other Species

Migratory Birds

Under all alternatives, harvest implemented under the Forest Plan would result in a reduction of perching, 

foraging, and potential nesting habitat and the increase in fragmentation associated with timber harvest

and road building. After timber harvest, there would be a short-term increase in the habitat for species 

associated with early successional habitats and forest edges, which may result in short-term population 

growth for these species. However, extended local reductions in available habitat would be expected as 

forest succession progresses. Habitat removal would reduce the effectiveness of interior forest habitat, 

and increase the potential for nest predation and nest parasitism for some species, which can ultimately 

reduce reproductive success (Robinson et al. 1995). Migratory birds would be most susceptible to 

impacts from harvest activities occurring in suitable nesting habitat during the nesting/fledging period, 

which generally begins in mid-April and ends about mid-July, when young birds have fledged.

The migratory bird species most likely to be adversely affected by the harvest of POG forest under all of 

the alternatives are those that primarily nest in POG forests, including the Western screech-owl, rufous 

hummingbird, red-breasted sapsucker, Pacific-slope flycatcher, Steller’s jay, northwestern crow, chestnutbacked chickadee, golden-crowned kinglet, varied thrush, Townsend’s warbler, blackpoll warbler, 

northern goshawk, and marbled murrelet. However, species associated with early successional or scrub 

habitats such as the MacGillivray’s warbler, golden-crowned sparrow, and golden-crowned kinglet would 

benefit through increases in suitable habitat over the short- to mid-term from timber harvest. All migratory 

bird species would benefit from the transition to young-growth harvest continued under all alternatives 

due to the reduced long-term scheduling of POG harvest. Differences among alternatives would be very 

slight because of the fact that harvest levels would remain the same.

Under all alternatives, the Old-growth Habitat Conservation Strategy would continue to provide for 

extensive areas in reserves of migratory bird habitat and distributed across the Forest. Legacy Forest 

Structure standards and guidelines that protect habitat features important for migratory birds on a stand 

level would be applied, as appropriate, under all alternatives.

Energy, transportation, or other projects that may become permissible in new areas could affect migratory 

during construction through direct disturbance or through removal or modification of nesting habitats. 

During operation, collision with project structures is a risk. These effects would be evaluated at the project 

level. The Forest-wide standards and guidelines would minimize impacts to migratory birds and their 

habitats during project construction and operation.

Bats

All bat species known to occur in Southeast Alaska are associated with mature forested habitats which 

provide roosting, breeding, and foraging sites, and bat activity appears rare in young-growth forest. Oldgrowth timber harvest would remove POG, thereby reducing the number of potential day-roosts available 

to tree-roosting bats and foraging habitat. Indirectly, timber harvest may also reduce the suitability of 

remaining roosting habitat through increased fragmentation (and decreased patch sizes) as day-roosts 

are more likely to be selected by some species (e.g., Keen’s myotis and silver-haired bat) if they are 

located in stands with a higher number of trees in early to late decay stages (Boland et al. 2009).

Under all alternatives, harvest of POG that could occur under the Forest Plan would be expected to have 

some level of impact, but differences among alternatives would be very limited due to the uniform harvest 

level. It should be noted tree-roosting species may choose a large-diameter tree for roosting regardless of 

whether or not it is located in an area with past timber harvest (Boland et al. 2009). Habitat and landscape 

connectivity would be provided for these species by the Forest Plan conservation strategy.
Environment and Effects 3

Final EIS 3-124 Wildlife

Marbled Murrelets

Marbled murrelets nest in structurally complex old-growth forest stands (Piatt et al. 2007). As a result, 

timber harvesting and road construction within POG forest stands (especially high-volume POG) can 

remove nest trees or disturb nesting birds. Indirectly, timber harvest and road building increase 

fragmentation, reducing the effectiveness of interior forest habitat and creating habitat edges, which may 

result in increased rates of nest predation by avian predators. Under all alternatives, marbled murrelet

nesting habitat would be protected by the Forest Plan conservation strategy.

The ongoing transition to young-growth harvest would benefit this species through the retention of a 

greater amount of POG forest on the landscape over the planning horizon. Moreover, many of younggrowth trees harvested would be of insufficient size to be suitable for nesting. Additionally, harvest of 

young-growth stands that could occur under all alternatives would have minimal fragmentation-related 

effects to this species because old-growth interior forest conditions preferred by this species for nesting 

would not be affected. 

Legacy Forest Structure standards and guidelines are intended to maintain old-growth structure in areas 

that are already highly developed, as well as areas that will experience increased harvest levels over the 

life of the Forest Plan. These components (large trees and snags) may provide nesting habitat for 

marbled murrelets. Differences in effects among the alternatives would be very slight because of the lack 

of differences in harvest volumes.

Energy, transportation, or other projects that may become permissible in new areas could affect marbled 

murrelets during construction through direct disturbance or through removal or modification of habitat. 

During operation, the potential for collision with project structures is a risk. The Forest-wide standards and 

guidelines would minimize impacts to marbled murrelets and their habitats during project construction and 

operation. Forest Plan standards and guidelines pertaining to marbled murrelets include maintaining a 

600-foot radius no-cut buffer zone around identified murrelet nests; however, habitat protection is also 

provided through beach and estuary fringe and riparian standards and guidelines (USDA Forest Service 

2016a), as well as the overall system of OGRs and other non-development LUDs.

Amphibians

Amphibians require both aquatic and terrestrial habitats in order to complete their life-cycle. Ponds, 

streams, and wetlands used by amphibians for breeding are protected by Forest Plan Riparian and 

Wetland standards and guidelines.

However, increased sedimentation and the entry of contaminated run-off from roads resulting from timber 

harvest can reduce the quality of these habitats. Under all alternatives, standard best management 

practices (BMPs) for water quality would be implemented to minimize these effects (see the Fisheries 

section for additional discussion).

Timber harvest has the potential to result in the loss and/or degradation of terrestrial habitats through 

changes in microclimates, soil compaction, and leaf litter disturbance. Tree canopy removal increases 

solar radiation to the forest floor, resulting in changes in moisture and soil temperatures which can make 

terrestrial habitats unsuitable for amphibians. Thinning or uneven-aged harvest techniques may reduce 

these effects.

The effects of specific harvest treatments on amphibians is complex. Some amphibians in the aquatic 

stage may be affected positively by even-aged harvest techniques (clearcutting), whereas effects of these 

treatments on juvenile and adult terrestrial stages are mostly negative (Semlitsch et al. 2009). In addition, 

renewable energy, mining, and transportation projects could affect amphibians through direct disturbance 

or through removal or modification of habitats, particularly if activities affect water bodies. The Forest-wide 

standards and guidelines would minimize impacts to amphibians and their habitats during project 

construction and operation.

Endemism

By definition, endemic species occur in isolated populations and many have limited mobility or specific 

habitat requirements. Thus, they are vulnerable to the effects of habitat loss and fragmentation, 

introduced non-natives, pathogens and disease, natural events (i.e., climate change), and overharvesting 
Environment and Effects 3

Final EIS 3-125 Wildlife

(Dawson et al. 2007). Therefore, the ability to disperse and recolonize is an important factor in how 

endemic species are able to respond to environmental changes.

Under all alternatives, harvest and road construction/reconstruction implemented under the Forest Plan 

would affect endemic species through habitat loss (POG) and fragmentation (reduced patch size), and by 

altering the distribution of habitats across the landscape. This may inhibit the ability of individuals to move 

between patches of suitable habitat, and therefore may further limit the distribution of a population or 

reduce genetic interchange between subpopulations. These effects would occur to a less extent in 

association with young-growth harvest as these stands provide lower quality habitat to most endemic 

species. Although timber harvest levels are the same among all alternatives, Alternatives 4, 5, and 6 

would have the greatest potential for effects on endemics because of the degree of fragmentation is likely 

to be higher under these alternatives (landscape connectivity and fragmentation are discussed in detail in 

the Biological Diversity section). Most endemic species would benefit from the transition to young-growth 

harvest continued under all alternatives due to the reduced amount of scheduled POG harvest over the 

long term.

Prince of Wales Flying Squirrel

A thorough analysis of this species occurred during the 1997, 2008 and 2016 Forest Plan efforts and 

results documented that the conservation strategy was functioning adequately to maintain the viability of 

this species in the planning area (USDA Forest Service 1997b, Appendix N; 2008b, Appendix D; 2016b). 

Prince of Wales flying squirrels are closely associated with old-growth structural characteristics and are 

limited by their dispersal capabilities. This subspecies has a limited gliding range (approximately 250 

feet), a distance substantially less than the average clearcut width (Flaherty et al. 2008). Fragmentation

resulting from old-growth timber harvest has the potential to reduce the value of residual patches of old 

growth in the matrix if they become isolated from adjacent patches either by distance or habitat type 

(young growth). Under all alternatives, old-growth timber harvest implemented under the Forest Plan 

could reduce the quality and quantity of flying squirrel nesting, foraging, and denning habitat.

However, the Old-growth Habitat Conservation Strategy would continue to maintain suitable old-growth 

habitat and provide landscape connectivity for flying squirrels.

Young-growth management (particularly commercial thinning) could benefit flying squirrels over the short 

term by increasing canopy height and creating more open space in the midstory conditions that facilitate 

efficient gliding (Scheibe et al. 2006). Over the long term, commercial thinning would promote stand 

development toward conditions capable of supporting breeding flying squirrels and improve the functional 

connectivity between old-growth reserves (Smith et al. 2011).

Prince of Wales Spruce Grouse

Prince of Wales spruce grouse are associated with muskegs, high-volume POG, and mixed conifer (scrub) 

habitats but will also use young-growth forest (15-30 years following timber harvest) with a well-developed 

middle story. Because they are associated with microhabitats within POG forests, old-growth timber 

harvest would alter habitat availability for this species, though effects would change over time. Harvest of 

old-growth timber under all alternatives would have a short-term benefit to grouse due to increased forage 

availability, followed by an extended period in which habitat conditions in harvested units would not be 

suitable. Young-growth harvest would provide similar short-term benefits to this species in the years 

following stand treatments. However, even-aged harvest of both old-growth and young-growth forest would 

initially (i.e., within the first 5 years after harvest) result in habitat patches unsuitable for spruce grouse, 

which may result in local impediments to movement. Due to their generally sedentary nature and 

preference for walking rather than flying, fragmentation due to even-aged timber harvest can result in the 

isolation of local spruce grouse populations (i.e., if open areas are too large or forested patches are spread 

too far apart to enable spruce grouse to move between them). However, thinning and group selection 

treatments can promote the development of structural and horizontal diversity beneficial to grouse 

(Russell 1999).

Increased road densities associated with timber harvest could also adversely affect spruce grouse by 

increasing hunter access (USFWS 2010). None of the alternatives would result in significant increases in 

average WAA road densities and therefore would not be expected to result in significantly increased 

harvest risk at the forest level. Localized increases in road densities would be managed through road 
Environment and Effects 3

Final EIS 3-126 Wildlife

closures and storage or decommissioning which would likely minimize the potential for increased harvest 

risk for spruce grouse over the long term.

Overall effects of the alternatives would be very similar due to the constant level of harvest among them. 

The Old-growth Habitat Conservation Strategy would continue to provide suitable habitat and landscape 

connectivity for spruce grouse.

Cumulative Effects

Activities that occur on other land ownerships within and adjacent to the Tongass have the potential to 

affect the overall context within which effects to wildlife are considered. Appendix B provides a full list of 

all the activities considered in the cumulative effects analysis. Such reasonably foreseeable activities 

include, but are not limited to, timber harvest, community development, mining, recreation and tourism, 

and road construction. Typically, these activities have the potential to adversely impact wildlife 

populations through habitat conversion, fragmentation, and disturbance associated with road building, 

though some activities can have short-term or long-term beneficial impacts, depending on the species. 

Prediction of the future extent and intensity of such activities has a high degree of uncertainty associated 

with it on a Forest-wide basis over a broad time scale. The 2016 Forest Plan FEIS also summarizes a 

review of the overall wildlife viability analysis (see USDA Forest Service 2016b, cumulative effects 

discussion in the Wildlife section).

Many private lands in Southeast Alaska are already highly developed in terms of roading and timber 

harvest and are likely to experience a continuing decline in old-growth forest in the future. Therefore, the 

cumulative long-term trend within the Forest boundary under all alternatives is likely to be a decline in 

optimum habitat for most old-growth associated species, with non-NFS land contributing to this trend. 

Additionally, land exchanges and conveyances (e.g., Mental Health Trust) have the potential to remove 

some lands from protection under the Old-growth Habitat Conservation Strategy. The Forest Service 

would continue to evaluate opportunities to compensate for these losses by evaluating additional OGR

modifications when land adjustments are implemented.

The transition to young-growth harvest on the Tongass would benefit wildlife species by reducing the 

overall amount of POG forest harvested over the planning horizon. Activities such as pre-commercial and 

commercial thinning would have both short-term (increased forage availability) and long-term (promotion 

of the development of old-growth forest stand characteristics) benefits to wildlife species that use POG 

forests on the Tongass.

When combined with other management activities occurring on non-NFS lands, implementation of the 

Forest Plan under any Alaska Roadless Rule alternative would produce additional impacts (noted above) 

associated with continued old-growth harvest to species for which this forest type is optimal habitat, such 

as goshawks, marten, mountain goats, red squirrel, red-breasted sapsucker, hairy woodpecker, brown 

creeper, marbled murrelets, and bat species. However, these declines in habitat (and associated effects 

such as fragmentation) would be lessened to some extent through the transition to young-growth harvest

on NFS lands.

Approximately 875,700 acres of POG have been harvested across the Tongass, including both NFS 

lands and non-NFS lands, resulting in a reduction to 86, 78, and 67 percent of the original total, highvolume, and large-tree POG in Southeast Alaska, respectively (see Tables 3.3-10, 3.3-11, and 3.3-12). 

Approximately 82 percent of the original POG would remain on the Tongass after full implementation of 

the Alternative 1 or any of the action alternatives, along with future non-NFS harvest in 100+ years (Table 

3.3-10). Future representation of high-volume POG and large-tree POG would be expected to be 

approximately 75 and 62 percent of the original amount, respectively, after 100+ years under the any of 

the alternatives. There would be no changes among the alternatives because harvest levels would be the 

same as Alternative 1.

Harvest associated with all alternatives would contribute to the cumulative reduction in POG and 

associated increase in fragmentation and loss of connectivity, which has the potential to reduce biological 

diversity. Timber harvest on NFS lands, as well as on non-NFS lands would result in similar effects; 

however, would not contribute above what was analyzed in the current Forest Plan.
Environment and Effects 3

Final EIS 3-127 Wildlife

Collectively, the implementation of the Forest Plan under all of the alternatives in combination with 

ongoing and foreseeable projects would increase the number of smaller patches on the landscape, 

reducing the amount of interior forest and increasing the occurrence of forest edge habitat. Edge effects 

such as shifts in species composition may reduce natural biological diversity over time by favoring some 

species over others; however, effects would be lessened by the transition to predominantly young-growth 

harvest, which would reduce the long-term cumulative effects to old-growth biological diversity by 

reducing the total amount of POG harvest and associated fragmentation. Note that the actual amount of 

harvest that has occurred to date on the Tongass is far less than that projected under all previous Forest 

Plan EISs and would likely continue to be less under all of the alternatives (see Timber section of this EIS 

for additional discussion).

Cumulative effects to modeled deer habitat capability would maintain 78 percent of the original level in 25 

years and at 100 years. WAAs with the greatest impacts under the alternatives are located in GMU 2 

(Prince of Wales and surrounding island) where concentrated past timber harvest has occurred. The 

USFWS Alexander Archipelago wolf species status assessment concluded that assuming continuation of 

current land use trends, the GMU 2 wolf population is anticipated to decline by another roughly 8 to 14 

percent of current levels over the next 30 years (USFWS 2015). Although this could result in gaps in wolf 

distribution within GMU 2, given that it comprises just 6 percent of the population range wide, impacts to 

the overall distribution in Southeast Alaska or to species viability are not expected (USFWS 2015). The 

Forest Service will continue to coordinate with ADF&G and the Wolf Technical Committee to address 

future issues, especially within GMU 2.

Overall, biological diversity on the Tongass and in Southeast Alaska remains in good condition and the 

landscape continues to be dominated by old-growth forest ecosystems. As development continues 

through timber harvest and associated activities such as road building, and community expansion, 

particularly in areas where extensive development has already occurred (e.g., Prince of Wales Island), 

maintaining connectivity and roadless refugia will become increasingly important, particularly for wideranging species whose distribution depends on some level of connectivity across the landscape. In 

addition, the management of human resources will continue to play a role in maintaining biological 

diversity across the Tongass. Within the Tongass boundary, the Old-growth Habitat Conservation 

Strategy was designed to address the more extensive harvest on non-NFS lands through the OGR

system and Forest-wide standards and guidelines, both of which were intended to maintain ecological 

components needed to maintain the ecological integrity important to a variety of organisms and maintain 

connectivity across the landscape, with or without much contribution from non-NFS lands. Note that the 

system of OGRs and overall Old-growth Habitat Conservation Strategy approach was developed prior to 

roadless and would be maintained regardless of the alternative selected.

There are portions of the Tongass where cumulative effects become more important due to the level of 

past harvest that has occurred. Specifically, the North Central Prince of Wales and Kupreanof/Mitkof 

Islands biogeographic provinces have experienced some of the highest reductions in original (1954) POG 

forest on the Tongass and are also where much of the young-growth suitable for commercial timber 

production is located. Additional timber harvest, particularly when located adjacent to previously 

harvested areas, has a greater potential to result in localized reductions in landscape connectivity and 

gaps in species distributions in these more heavily harvested areas compared to portions of the Tongass 

that have less cumulative past timber harvest. These cumulative effects would be most likely to occur for 

species with very limited ranges (endemic species limited to individual islands or island groups, e.g., 

Prince of Wales flying squirrel, Prince of Wales spruce grouse) or with limited dispersal capabilities or 

capabilities that are dependent on certain mature forest structural characteristics (e.g., goshawks, 

amphibians, flying squirrels, spruce grouse).

Species with limited dispersal capabilities (i.e., flying squirrels and spruce grouse, which are also endemic

species) are likely to be more sensitive to habitat loss and fragmentation than species with greater 

dispersal capabilities (i.e., goshawks, wolves, and brown bears; D’eon et al. 2002). Natural fragmentation 

of habitats can also affect the level of additional fragmentation that can be supported. The Old-growth 

Habitat Conservation Strategy would continue to provide for extensive areas in reserves distributed 

across the Forest. The Legacy Forest Structure and other standards and guidelines that retain POG 

forest in harvested areas (e.g., beach and estuary fringe, RMAs, and Scenic Integrity Objectives) would 

also ensure the maintenance of a functional and interconnected old-growth ecosystem on the Tongass. 
Environment and Effects 3

Final EIS 3-128 Wildlife

These features are important for species associated with shoreline and riparian habitats such as river 

otters, black bears, brown bears, bald eagles, and Vancouver Canada geese. These measures, 

particularly when implemented in areas that have experienced concentrated past harvest increase the 

likelihood that the landscapes will continue to provide the full range of matrix functions that support viable 

and well-distributed populations of wildlife species.

Under all alternatives, activities implemented under the Forest Plan would result in vessel traffic and 

marine activity associated with LTF use and log transport, which would occur irregularly over the life of 

the Forest Plan (in association with individual old-growth and young-growth timber harvest projects as 

they are proposed). Therefore, all of the alternatives would make a minor contribution to the existing 

potential for oil or fuel spills associated with existing vessel activity and bark accumulations near the LTFs 

to which marine and shoreline-associated species such as black oystercatchers, Aleutian terns, shorttailed albatrosses, humpback whales, and Steller’s sea lions would be exposed. However, levels of 

marine activity are expected to remain within levels anticipated for the current Forest Plan (Alternative 1) 

under all of the action alternatives. Furthermore, all activities at the project level would be conducted in 

accordance with Alaska Water Quality Standards under Section 401 of the Clean Water Act for LTFs.

These standards place restrictions on the types, quantities, and extent of discharges (including bark) to 

the marine environment and would limit the effects of the project on water quality. Therefore, very minor 

contributions to cumulative effects in the marine environment are anticipated under all of the alternatives 

and these would be the same among the alternatives.

Climate change may also contribute to cumulative effects. Warmer temperatures and increased 

precipitation are anticipated to result in changes to vegetation and thus, the suitability of wildlife habitat, 

among other impacts (Haufler et al. 2010, Shanley et al. 2015; see the Climate and Carbon section). 

Although many species may benefit (e.g., greater overwinter survival of deer, and thus a greater prey 

base for wolves, resulting from warmer winter temperatures during normal years), habitat changes 

resulting from a longer growing season, wind, fires, insect infestations, and disease would have variable 

effects on others. The greatest concerns for wildlife populations in relation to climate change, however, 

are the weather extremes that can be expected to occur periodically (Haufler et al. 2010).

Periodic severe winter snowfalls, which may seem counterintuitive given the general warming trend, are 

anticipated (SNAP 2013). These stochastic events would be of greatest concern for populations that are 

limited in number or distribution. The Forest Plan Old-growth Habitat Conservation Strategy was designed

to maintain a resilient old-growth forest ecosystem in the face of this uncertainty. The potential for 

contributions to climate change from continued old-growth timber harvest on the Tongass, which could 

indirectly affect wildlife species such as the Kittlitz’s murrelet, is described in detail in the Climate and 

Carbon section.
Environment and Effects 3

Final EIS 3-129 Fish

Fish

Affected Environment

The important fish and aquatic habitat details of the Tongass were provided in the recently developed 

2016 Forest Plan Amendment EIS (USDA Forest Service 2016b). This section relies extensively on that 

information to characterize the current affected environment and refers the reader to that document for 

further details. The abundant aquatic systems of the Tongass provide spawning and rearing habitats for 

most fish produced in Southeast Alaska. Maintenance of this habitat and associated high-quality water is 

a focal point of public, state, and federal natural resource agencies, as well as user groups, Native 

organizations, and individuals.

Several watersheds and VCUs in the Tongass have been evaluated for relative importance for several 

metrics relating to fish and wildlife. Included among these are conservation priority areas identified by The 

Nature Conservancy (TNC) and Audubon Alaska (Audubon Alaska and The Nature Conservancy 2007), 

and the “Tongass 77” (T77) 21 watersheds identified by Trout Unlimited. Audubon Alaska and TNC 

identified conservation priority watersheds that include high-value intact watersheds in primarily intact 

conditions and generally encompass the highest current ecological values within each province; these 

areas were recommended to be managed for intact ecological values and habitat productivity.

About 46,000 stream miles and 213,000 acres of lakes and ponds are present on Tongass lands. Of 

these, approximately 14,900 stream miles and 3,300 lakes and ponds are mapped as anadromous or 

high-value resident fish habitat. Another 9,500 stream miles and 1,000 lakes and ponds are mapped as 

resident fish habitat. Many estuarine and marine, fish and shellfish resources are affected by actions on 

the Tongass that affect marine shorelines and stream runoff (USDA Forest Service 2016b).

Subsistence, commercial, and sport fisheries are all important to the way of life for Southeast Alaskan 

residents and some forms occur in both marine and freshwater systems (USDA Forest Service 2016b). 

Major species include all five salmon species [pink salmon (Oncorhynchus gorbuscha), chum salmon (O. 

keta), coho salmon (O. kisutch), Chinook salmon (O. tshawytscha), and sockeye salmon (O. nerka)] for all 

activities, while various primarily trout species [e.g., rainbow trout/steelhead (O. mykiss) and cutthroat 

trout (O. clarki), Dolly Varden char (Salvelinus malma)] are important for sport, commercial, and 

subsistence fishing, while a variety of other marine species are also of importance. Hatcheries, and the 

enhancement of wild fish, among other aquaculture projects, contribute to resource availability and 

abundance.

Details of quantity and changes in harvest of salmon species in Southeast Alaska are summarized here, 

including current updates on harvest and values. Commercial fish harvest in the waters of Southeast 

Alaska (includes Yakutat area harvest) can fluctuate widely from year to year but has remained typically in 

the tens of millions of fish for all five species (Figures 3.3-3 and 3.3-4). The annual average has ranged 

from a low of about 6 million in 1975 to a high of 112 million in 2013. Pink salmon have had a sharp 

decline since the 2013 peak with a low for odd-year returns of about 21 million in 2019. Pink salmon 

make up the bulk of the harvest, averaging 75 percent of all salmon from 1960 to 2019 (Conrad and Gray 

2019; USDA Forest Service 2016b). Coho salmon also had below average harvests in 2018 and 2019. 

Fish production from the Tongass is a primary source of fish for commercial, sport, and subsistence harvest. 

Based on recent period data (2007-2016), an estimated 75 percent of all salmon commercially harvested 

began their life in streams and lakes within the Forest boundaries (Johnson et al. 2019). Pink salmon 

have the highest portion of the commercial harvest originating in the Tongass at 91 percent. The 

estimated annual average commercial salmon harvest (2007-2016) produced from streams originating in 

the Tongass was over 41 million fish, with a wholesale value (ex-vessel value) over $69 million (adjusted 

21 The Tongass 77 (T77) refers to VCUs, which approximate major watersheds located on National Forest System lands that Trout 

Unlimited, Alaska Program, identified as priority salmon watersheds. Four watersheds were removed from the T77 in 2014 as a result 

of the Sealaska Land Entitlement Finalization in the Carl Levin and Howard P. “Buck” McKeon National Defense Authorization Act for

Fiscal Year 2015 (Public Law 113-291).
Environment and Effects 3

Final EIS 3-130 Fish

to 2017 dollars (Johnson et al. 2019). Approximately 85 percent of Southeast Alaska’s sport fishing 

occurs in the vicinity of the Tongass. Sport fishing for salmon has been substantial over the recent two 

decades (averaging about 940,000 catch and 450,000 harvested salmon per year; see 

https://www.adfg.alaska.gov/sf/sportfishingsurvey/index.cfm?ADFG=region.results). Hatchery production 

has also contributed substantially to overall fish production regionally. Hatchery production statewide has 

greatly increased since 1977 with releases of more than 1.5 billion fish occurring annually since 1995, 

peaking in 2014 with about 1.8 billion juvenile fish released statewide (Vercessi 2015). State subsistence 

and personal use salmon fisheries averaged about 46,000 fish annually from 2005 to 2018 for Southeast 

Alaska and Yakutat, down from peak period average of 62,000 fish during (1994–2004 period) (Conrad 

and Gray 2019).

Figure 3.3-3

Commercial Harvest of Chinook, Sockeye, and Coho Salmon in Southeast Alaska 1960-

2019

0

1

2

3

4

5

1960 1965 1970 1975 1980 1985 1990 1995 2000 2005 2010 2015 2020

Harvest Numbers (millions)

Year

Chinook Sockeye

Coho

Data Sources: Bachman et al. 2005, Conrad and Gray 2019
Environment and Effects 3

Final EIS 3-131 Fish

Figure 3.3-4

Commercial Harvest of Pink, Chum and Total Salmon in Southeast Alaska 1960-2019

Data Sources: Bachman et al. 2005, Conrad and Gray 2019

Fish Habitat

Important Components of Fish Habitat

With more than 46,600 miles of streams and 212,000 acres of ponds and lakes, the Forest provides 

abundant fish habitat. Generally, salmon and trout require cool stream temperature to thrive in streams 

with stream temperature affecting fish rearing, migration and spawning success (Bjornn and Reiser 

1991). The relative composition of stream substrate and sediment affects many factors in stream 

production, including spawning areas and spawning success for salmon and trout, and benthic organism 

composition and abundance, an important food resource for fish.

The amount of coarse sediment affects available spawning habitat and influences pool filling and bank 

stability (Spence et al. 1996). High levels of fines affect pool filling and survival of eggs and fry in 

spawning nests of salmon and (Chapman and McLeod 1987; Chapman 1988; Iwamoto et al. 1978; 

Gregory and Bisson 1997; McNeil 1964). Increased fines in streams also reduce interstitial spaces in 

large substrate that are important habitat for many common cool water mountain stream aquatic insects. 

Large woody debris (LWD) is an important component of good trout and salmon habitat, especially in 

heavily wooded regions (Swanson et al. 1976; Bisson et al. 1987; Naiman et al. 1992; Beechie and Sibley 

1997; Spence et al. 1996; Murphy et al. 1986), that provides channel complexity and cover, and is 

especially important in the formation of pools (Bisson et al. 1987; Sullivan et al. 1987; Benda et al. 2003). 

The primary timber-related actions that may affect LWD supply to streams include buffer width along 

streams, stream class and channel characteristics that buffers are placed on, size of trees remaining in 

0

10

20

30

40

50

60

70

80

90

100

110

120

1960 1965 1970 1975 1980 1985 1990 1995 2000 2005 2010 2015 2020

Harvest Numbers (Millions)

Year

Pink

Chum

Total
Environment and Effects 3

Final EIS 3-132 Fish

the buffer area, and effects on windthrow from adjacent harvest. Additional information on LWD in 

Tongass streams and timber harvest practices of the past is presented in the 2016 Forest Plan 

Amendment EIS (USDA Forest Service 2016b).

Fish passage and access to suitable habitat in streams and lakes is critical to fish stocks. Natural falls 

and barriers in systems have been found in some areas to prevent the use of suitable fish habitat, 

especially for anadromous stocks in some natural systems. Man-made barriers in the form of dams, 

diversion, and road-crossing structures have been common partial or complete barriers to fish movement 

in much of the developed areas where fish are present. Road crossings (e.g., culverts) over much of the 

range of salmonids in the Pacific Northwest have often reduced or eliminated access to substantial 

portions of habitat to migratory fish use.

Effects of Past Forest Management Practices

Effects of past timber harvest practices on fish populations and habitat in the Tongass were addressed in 

the 2016 Forest Plan Amendment EIS (USDA Forest Service 2016b). Older forest practices (mostly prior 

to 1980) in the Tongass have had adverse effects to anadromous fish habitat conditions, including 

spawning and rearing habitat, and migration conditions (Murphy and Milner 1997). Timber harvest during 

this timeframe accounts for about 60 percent of all timber harvest on the Forest. Generally, studies found 

that older harvested watersheds (mostly prior to 1980), which generally included clearcutting of riparian 

trees, had mostly lower fish production (Stillwater Sciences 2012).

Modern forest practices under the Forest Plan are intended to prevent the habitat degradation in riparian 

areas and headwater streams that have contributed to adverse effects on fish and habitat. Monitoring of 

stream habitat, fish, and riparian conditions has not found marked problems with water quality, fish 

resources, or habitat with the implementation of current forest practices (USDA Forest Service 2004, 

2007, 2014, 2015c). The results of the latest monitoring report, while indicating that some issues need 

further monitoring and analysis to fully assess effects, have not resulted in any recommendations to 

change the current standards and guidelines of the Forest Plan (USDA Forest Service 2015c).

Fish Habitat Enhancement and Restoration

Recent enhancements have included varied activities such as fishways, falls improvements, and lake and 

stream stocking, while restorations have been primarily culvert removal or repair and LWD management. 

Other watershed improvement activities include riparian and upland vegetation improvement, road 

storage and decommissioning, and improved road drainage structures to reduce sediment entry to 

streams and improve fish passage.

Special Status Species

Fish Management Indicator Species

The 1982 Planning Rule directed the use of MIS in forest planning to help display the effects of forest 

management. For the 1997 Forest Plan, pink salmon, coho salmon, Dolly Varden char, and cutthroat trout 

were selected as MIS. Pink salmon were selected to represent anadromous fish that are limited in their 

freshwater life period by spawning gravel quality and quantity; coho salmon to represent anadromous fish 

that are generally limited in their freshwater life period by stream and lake rearing area; Dolly Varden char 

because of their ubiquitous distribution in freshwater habitats; and cutthroat trout because of their 

dependency on small freshwater stream systems, which are most susceptible to effects from 

management activities. These MIS, and their habitats, are described in the 1997 Forest Plan Revision 

FEIS (USDA Forest Service 1997a) where carried through to the 2008 Forest Plan Amendment. Because 

the 2016 Forest Plan Amendment EIS analyzed an amendment to the 2008 Forest Plan done under the 

1982 Planning Rule, these species were carried forward and analyzed even though the 2012 Planning 

Rule does not use MIS for evaluating effects.
Environment and Effects 3

Final EIS 3-133 Fish

Sensitive Fish Species

Sensitive species are those plant and animal species identified by the Regional Forester for which 

population viability is a concern on NFS lands within the region. The goal of the Forest Service Sensitive 

Species Program (Forest Service Manual 2670) is to ensure that species numbers and population 

distribution are adequate so that no federal listing will be required, and no extirpation will occur on NFS 

lands.

The Alaska Region Sensitive Species List was updated in 2009 (USDA Forest Service 2009a). There 

currently are no fish species designated as sensitive species in the Alaska Region.

Threatened and Endangered Fish Species

Federally listed threatened and endangered species are those plant and animal species formally listed by 

the U.S. Fish and Wildlife Service (USFWS) or National Marine Fisheries Service (NMFS), under authority 

of the Endangered Species Act of 1973 (ESA), as amended. An endangered species is defined as one 

that is in danger of extinction throughout all or a significant portion of its range. A threatened species is 

defined as one that is likely to become an endangered species within the foreseeable future throughout 

all or a significant portion of its range.

No federally listed fish species or stocks originate from Alaska streams. However, some federally listed 

fish stocks may occur in marine waters within the boundary of the Tongass National Forest (NMFS 2020). 

These fish include the following:

Endangered species:

Snake River sockeye salmon

Upper Columbia River spring-run Chinook salmon 

Threatened species: 

Upper Columbia River steelhead

Snake River spring/summer Chinook salmon

Snake River fall Chinook salmon

Puget Sound Chinook salmon

Lower Columbia River Chinook salmon

Upper Willamette River Chinook salmon

Hood Canal summer chum salmon

Lower Columbia River coho salmon 

Snake River Basin steelhead

Lower Columbia River steelhead

Upper Willamette River steelhead

Middle Columbia River steelhead

Green Sturgeon (Acipenser medirostris) – Southern distinct population segment (DPS) 

Columbia River Chum Salmon

Lake Ozette Sockeye Salmon

Upper Columbia River DPS Steelhead Trout

Puget Sound DPS Steelhead Trout

These listed stocks of salmon and steelhead do not spawn in Alaska but are known to seasonally inhabit 

marine waters on the outside coast to the west and occasionally in inside waters of the Tongass (McNeil
Environment and Effects 3

Final EIS 3-134 Fish

and Himsworth 1980; Trudel et al. 2004; Trudel et al. 2009; Burgner 1991; Haggerty 2009; Groot and 

Margolis 1991; Tucker et al. 2011). They may feed on fish that are dependent on coastal marine waters of 

the Tongass at some stages of their lives. The southern DPS of the green sturgeon is an anadromous 

species that spawns in the Sacramento River in California (NMFS 2015b). Green sturgeon also do not 

rear or spawn in fresh waters of Southeast Alaska but have been rarely found to be present in marine 

waters of Southeast Alaska and may feed on benthic organisms found in these waters, likely in waters 

less than 100 meters deep (Lindley et al. 2008; Huff 2012; Colway and Stevenson 2007).

Green sturgeon could be present in the inside waters of Southeast Alaska, particularly during the winter.

Environmental Consequences

Indirect Effects

The current standards and guidelines in the 2016 Forest Plan were developed substantially through work 

that was done initially by the Anadromous Fisheries Habitat Assessment (AFHA) (USDA Forest Service 

1995). Follow-up work in the Tongass after 1995 and other studies have contributed to modifications of 

these standards and guidelines in the 1997, 2008, and 2016 Forest Plans. Monitoring in the Tongass has 

helped confirm that the actions taken under the standards and guidelines have protected fisheries 

resources in the Tongass. The Alaska Roadless Rule alternatives will be evaluated on how these 

alternative associated actions would affect fish resources relative to implementation of the 2016 Forest 

Plan under the 2001 Roadless Rule (Alternative 1).

Fish Habitat

Roads pose the greatest risk to fish resources on the Tongass (Dunlap 1996), partly because they pose 

the largest risk of management-caused sediment input to streams (Reid and Dunne 1984; Furniss et al. 

1991; Gomi et al. 2005; Hassan et al. 2005). Road construction, road drainage, level of road use, number 

of road stream crossings, watershed road density, and related actions in forested areas may all influence 

the amount of sediment to streams (Gomi et al. 2005; Furniss et al. 1991; Swanson et al. 1987; 

Chamberlin et al. 1991; Reid and Dunne 1984). Road effects to aquatic systems and fish are likely to vary 

little among the alternatives.

Roads

Roads have been found to contribute more sediment to streams than any other land management activity 

(Gucinski et al. 2001). Roads can contribute towards increases in peak flow to streams (Grant et al. 2008) 

that can result in stream channel erosion and bed scour (Tonina et al. 2008), affecting stream bed and 

bank stability, and adverse effects on fisheries resources. Roads can also potentially create areas of 

hillslope instability resulting in landslide generation, contribute fine sediment from surface erosion, and 

alter surface and subsurface water flow patterns. Long-term sediment introduction from roads is 

influenced by the type of structure at the road–stream crossing, proximity of the drainage structures to 

streams, road slope, age, maintenance condition, time since last graded, seasonal timing of maintenance 

activities, amount of traffic, rock quality, weather, hillslope length, soil depth, and cutbank depth (Croke 

and Hairsine 2006; Wemple and Jones 2003; Kahklen and Hartsog 1999; Reid and Dunne 1984). 

Although standards and guidelines are in place to help moderate these effects, some adverse effects, or 

increase in risk of adverse effects, would occur with these road parameters.

Density of roads is also a major factor in considering watershed condition as indicated by the Forest 

Service Watershed Conditions Framework (WCF) (USDA Forest Service 2011b). Road density is one of 

12 factors considered when rating the status of watershed on national forest. The WCF concluded as part 

of their assessment that watersheds with fewer roads generally have healthier overall resources (USDA 

Forest Service 2011c). Specifically, the Forest Service (2011c) noted the following: 1) a watershed with 

road density of less than 1 mile per square mile would be considered “good” or “properly functioning,” 2) 

watersheds with road density of 1 to 2.4 miles per square mile were “fair’ or “functioning at risk,” and 3) 

watersheds with road density greater than 2.4 miles per square mile were rated as “poor” or “impaired 

function.” 
Environment and Effects 3

Final EIS 3-135 Fish

New road construction and road density would be similar under all alternatives because roads on the 

Tongass are largely developed in support of timber harvesting, and the PTSQ under the 2016 Forest Plan 

does not vary between the alternatives. The updated estimates of existing road conditions included almost

5,000 miles of existing roads on NFS lands (Table 3.3-21). The projection over the next hundred years was 

modeled to include an additional 1,000 miles of new roads, totaling about 5,900 miles of roads after 100 

years. This would be an increase of about 20 percent over existing conditions. In addition to new roads, 

roads would be constructed over decommissioned roadbeds or reconstructed. Reconstruction involves the 

rehabilitation of the original roadbed, and can include cleaning ditches, replacing drainage structures, reinstalling bridges, and grading and shaping. More ground disturbance would occur for reconstruction over 

decommissioned roads than for closed roads and may include some major roadbed restoration similar to 

new road construction. By the same rationale, the estimated 500 miles of roads constructed over 

decommissioned roadbeds and 1,100 miles of road reconstruction over 100 years for the No Action 

alternative would be similar among all alternatives (Table 3.3-21).

The number of new road miles estimated beyond the current forest plan (Alternative 1) would range from 

0 to 49 miles total. Alternatives 1 and 2 would have about the same amount of road miles as indicated in 

the current Forest Plan evaluation, with Alternative 3 a slight increase over 1 and 2, and Alternatives 4, 5 

and 6 similar with slightly more road miles than Alternative 3 (see Transportation section). Alternative 1 

would result in a 20 percent increase in new roads over existing conditions; none of the other alternatives 

would increase this value more than 1 percent (i.e., 21 percent). 

Road density also would change little among the alternatives. Given the young growth transition, the 

acres and level of old-growth harvest vary little across the alternatives, including the majority of sales 

which would be most economic, leading to the very small differences in roads built. Based on this 

information, the frequency of occurrence of road densities exceeding the “properly functioning” value of 1 

mile of road per square mile was used as a general index of relative effects of roads on water quantity

and quality and relative effect to fisheries resources. Under existing conditions, average road density is 

about 0.19 mile per mile square mile. Under all alternatives, the average road density on NFS lands is 

increased to about 0.23 mile per square mile (see Table 3.3-21). While there are slight differences among 

alternatives, this would translate into about 90 percent of all subwatersheds with road densities in the 

“properly functioning” range (less than 1 mile of road per square mile) for NFS lands for all alternatives. 

The number of subwatersheds that have no roads on NFS lands is currently about 68 percent; this is 

projected to be about 62 percent under the current Forest Plan Alternative 1. The other alternatives would 

decrease to between 56 and 61 percent. While there would be slight increases in number of watersheds 

with roads, most of that increase would result in additional watersheds with road density less than 1 mile 

per square mile with these watershed remaining in the “properly functioning” range. Alternative 2 would 

have the least increase and Alternative 6 the most increase in number of watersheds with roads. The 

overall number of watersheds with road density less than 1 mile per square mile would be least with 

Alterative 6 as slightly more development would occur in watersheds without roads, with fewer new roads 

built in watersheds that have existing roads. Overall, there are only slight differences among the 

alternatives over the projected 100-year period in number of estimated changes in road density among 

watersheds. 

Overall, the potential effects to fish from road construction, reconstruction, and maintenance under 

projects that could be approved in the future would be similar among all alternatives and would be 

evaluated at the project-scale.

Table 3.3-21

Estimated Road Miles and Percent of 6th Field Subwatersheds in Road Density 

Categories on NFS Lands under Existing Conditions and after 100 Years of Full 

Implementation1 

Road Type

Alternative

Existing 1 2 3 4 5 6

Existing Roads 2 (miles) 4,929 4,929 4,929 4,929 4,929 4,929 4,929

New Road Construction (miles) – 994 994 1,012 1,029 1,039 1,043
Environment and Effects 3

Final EIS 3-136 Fish

Table 3.3-21 (continued)

Estimated Road Miles and Percent of 6th Field Subwatersheds in Road Density 

Categories on NFS Lands under Existing Conditions and after 100 Years of Full 

Implementation1 

Road Type

Alternative

Existing 1 2 3 4 5 6

Road Construction over 

Decommissioned Roadbeds (miles)

– 527 527 532 535 539 541

Road Reconstruction3 (miles) – 1,104 1,104 1,111 1,119 1,123 1,123

Total Roads (miles) 4,929 5,922 5,922 5,941 5,958 5,968 5,972 

Percent New Road Increase - 20% 20% 21% 21% 21% 21%

Road Density Categories (Mi/Sq. Mi.)4

 0.0 67.8% 61.5% 60.8% 59.6% 58.4% 57.7% 56.4%

>0.0 – 1.0 23.8% 28.3% 28.9% 29.8% 31.1% 31.8% 33.0%

>1.0 – 2.4 7.8% 8.2% 8.3% 8.7% 8.6% 8.6% 8.8%

>2.4 – 3.0 0.4% 1.4% 1.4% 1.4% 1.5% 1.5% 1.4%

 >3.0 0.2% 0.6% 0.6% 0.5% 0.5% 0.5% 0.5%

Percent of watersheds with Average 

Road Density less than 1.0 mile/sq. mi. 

91.6% 89.8% 89.7% 89.5% 89.5% 89.5% 89.4%

Average Road Density (miles/sq. mi.) 

for all NFS Lands

0.19 0.23 0.23 0.23 0.23 0.23 0.23

1 Assumes full implementation of Forest Plan at PTSQ levels. Includes adjusted road miles estimated to be needed to harvest 

all scheduled timber in each alternative.

2 Note that the 4,929 miles of existing roads consists of 43% open roads, 31% closed roads (i.e., in storage), and 26% 

decommissioned roads.

3 Estimated existing road miles that would need to be reconstructed.

4 Percentages are based on 959 6th field subwatersheds that contain at least 100 acres of NFS lands. 

Source: Tongass National Forest GIS layer, 2018, and modeling of alternatives.

Fish Passage

Roads may also increase risk to fish movement due to improper construction affecting fish passage 

(Gibson et al. 2005) and blocked culverts. Stream-rearing fish, particularly cutthroat trout and Dolly 

Varden, which occupy the smaller headwater streams during some parts of their lives, are at the greatest 

risk. Fish passage guidelines (Forest Service Handbook 2090.21 Aquatic Habitat Management Handbook 

[USDA Forest Service 2001]) for culvert design greatly reduces the risk of new culvert installation 

impeding fish passage, but some risks remain.

As discussed above, road construction would be similar under all alternatives; thus, the number road 

crossings that could impede fish passage would also be similar. While the alternatives with the most 

potentially new road miles (Alternatives 4 through 6) would appear to have the largest potential for 

increase in stream crossings, the lack of increase in actual predicted harvest would greatly limit additional 

construction of new roads, and respective increase in stream crossings, relative to implementation of the 

current Forest Plan under the 2001 Roadless Rule. Therefore, the total change in stream crossings, 

including fish streams with their associated impacts to fish and their habitat, would be highest for 

Alternatives 4 to 6, but would be unlikely to vary substantially among the alternatives.

Timber Harvest

Timber harvest activities can increase risk to fish resources. Protection of riparian areas, including 

floodplains, areas of riparian vegetation, and certain wetlands associated with riparian systems, is of 

concern. Riparian vegetation serves many important functions for stream fish habitat, including supplying 

LWD, food input, and stream shade to name a few. The 2016 Forest Plan includes areas designated as 

RMAs that encompass the stream, mandatory no-harvest zones required by the 1990 TTRA, adjacent sitepotential tree-height distances, landscape features such as floodplains, alluvial fans, and v-notches, and 

associated wetlands (Forest Plan, Appendix D; Paustian 2004). The RMAs are ecologically tailored to 

ensure the integrity of the stream channel, maintain the supply of large wood, and protect other functions 

critical to soil, water, fish, and wildlife in Southeast Alaska (USDA Forest Service 2015c). Greatest 
Environment and Effects 3

Final EIS 3-137 Fish

protection is provided to riparian areas associated with alluvial soils and fish streams; fishless headwater 

streams are also protected as important conduits of clean water, large wood, stream substrate, and food 

for aquatic organisms. In addition, reasonable assurance of windfirmness (RAW) must be provided for 

buffers, which may or may not include additional buffer width depending on site conditions. While some 

blowdown has occurred in monitored buffers this has generally been low, averaging 6.8 percent of the 

buffer area in monitored RMAs with blowdown occurrence decreasing with time (USDA Forest Service 

2019f). These Forest Plan standards and guidelines associated with riparian areas, wetlands, and beach 

and estuary fringe are expected to protect fish resources from significant impacts associated with timber 

harvest, but there is still some level of risk. These ecologically based RMA buffers are also likely an 

important component to mitigate potential effects of climate change on hydrologic regimes and fish 

(EcoAdapt 2014).

All alternatives would have the same PTSQ as the current Forest Plan. Timber harvest activities projected 

under the current plan could potentially affect over 320,000 acres after full implementation of the Forest 

Plan over 100 years. The acres of harvest would not be substantially different from the current plan or 

among the alternatives. Therefore, effects on fish and fish habitat would be similar among the 

alternatives.

The Tongass 77 Watersheds and TNC/Audubon Conservation Priority Areas

The 2016 Forest Plan prohibits old-growth timber harvest in T77 Watersheds and TNC/Audubon 

Conservation Priority Areas, and this carries through for all the alternatives in this EIS. Within ARAs, 

harvests would generally be prohibited in Watershed Priority, LUD II Priority, and Roadless Priority ARAs, 

with exceptions. The exceptions for timber harvest and road building are presented in Chapter 2 (Table 2-

2). However, there would be no prohibition on young-growth harvests within the Timber Priority ARA 

(Alternative 4). Under Alternative 4, young-growth harvest could occur within Timber Priority ARAs if other 

suitability requirements were met (such as occurring within a development LUD). Community Priority 

ARAs (Alternative 3) do not include T77 Watersheds and TNC/Audubon Conservation Priority Areas.

While the size and location of future harvests are unknown, Table 3.3-22 presents the acres of suitable 

young growth and the projected harvest over 100 years within T77 Watersheds and TNC/Audubon 

Conservation Priority Areas. Suitable acres within these areas, as well as projected harvest, would occur 

outside of roadless areas.

Table 3.3-22

Acres of Suitable Young Growth and Estimated Harvest within Tongass 77 Watersheds 

and TNC/Audubon Conservation Priority Areas

Harvest Type

Alternative

1 2 3 41 5 6

Suitable YG 55,500 58,800 59,000 59,200 60,100 61,300

Increase in Suitable YG 

Relative to Alt. 1

0 3,300 2,700 3,700 4,600 5,700

Estimated YG Harvest 

over 100 years

47,300 48,400 48,100 48,200 48,700 49,200

Increase in YG Harvest 

over 100 years

0 1,100 800 900 1,400 1,900

1 Includes Timber Priority areas within Alternative 4 ARAs.

Suitable young growth in T77 watersheds and TNC/Audubon Conservation Priority Areas would not 

increase much between the alternatives, with increases relative to Alternative 1 ranging from about 2,700 

acres (5 percent) under Alternative 3 to about 5,700 acres (10 percent) under Alternative 6 (Table 3.3-

22). Increases in estimated harvest over 100 years range between 800 and 1,100 acres (about 2 percent) 

under Alternatives 2 through 4 and between 1,400 and 1,900 acres (3 to 4 percent) under Alternatives 5 

and 6. 
Environment and Effects 3

Final EIS 3-138 Fish

All action alternatives would allow young-growth harvest in T77 watersheds and TNC/Audubon 

Conservation Priority Areas outside of designated roadless areas. Relative changes from current plans 

for all alternatives are slight and spread over a 100-year period resulting in no substantial change or 

differences among alternatives to fish resources. Further, the Record of Decision on the 2016 Forest Plan 

calls for a 5-year internal scientific review in collaboration with stakeholders to assess impacts resulting 

from young-growth harvest in these high-value areas.

Alternative Summary

While more suitable harvest acres would be open among the action alternatives than are currently 

available, none of the alternatives propose to increase harvest over the existing Forest Plan. While some 

of the metrics that have potential to cause adverse effect to fish and their habitat (e.g. road miles, road 

crossing of streams, total harvest acres) may slightly increase, their quantity is not expected to change 

substantially among any of the alternatives. Additionally, while there are minor differences among the 

alternatives, the overall risk to fish resources and watersheds is unlikely to be large or differ from current 

Forest Plan projected conditions. None of the alternatives would change Forest Plan LUDs or Forest Plan 

standards and guidelines developed to protect fish and their habitat. 

Overall effects to fish habitat are expected to be minimal under all alternatives, because of the strong 

protections to fish habitats provided by Forest Plan LUDs, Forest-wide standards and guidelines including 

the riparian management strategy, and the lack of old-growth harvest or associated road construction 

allowed in the T77 watersheds and TNC/Audubon Conservation Priority Areas. Localized effects on fish 

habitat may occur, but these are expected to be minimal overall with low long-term risk. Any potential sitespecific effects will be addressed under separate site-specific NEPA analysis, as this assessment will not 

authorize any site-specific actions.

Alternative 1: This alternative would have the lowest potential harvestable acres, the lowest number of 

new and rebuilt roads constructed, and likely the lowest number of new and reconstructed stream 

crossings of any alternative. However, these numbers are not substantially different than the other 

alternatives. All stream crossings increase risks to fish passage, and new crossings have a greater risk of 

sediment effects. Given that the expected number of new and reconstructed stream crossings under this 

alternative would be similar to other alternatives, there would be an overall similar risk of sediment 

addition and passage issues to other alternatives.

Alternative 2: The opening of roaded roadless areas would allow access to more acres of second-growth 

forest areas than under current conditions in areas that already have roaded systems. However, there 

would not be a substantial difference in harvest volume, road building or road reconstruction compared to 

Alternative 1. While young-growth harvest could potentially increase in key TNC/Audubon Conservation 

Priority Areas and T77 watersheds in formerly roaded roadless areas, the amount of overall potential 

harvest area added would not be substantial. Overall, the risk of adverse effects to fish or their habitat 

relative through future actions would be similar to that under the current Forest Plan (Alternative 1). 

Compared to the Alternatives 4 through 6, Alternative 2 would be more protective to fish resources within 

T77 watersheds and TNC/Audubon Conservation Priority Areas, and some additional sockeye 

watersheds, because it is the most restrictive on timber harvest and road building by designating nearly all 

of these lands within ARAs as Watershed Priority (about 3.25 million acres) with the remaining areas 

designated LUD II Priority (about 856,000 acres) or Roadless Priority (8,700 acres).

Alternative 3: This alternative would open more areas to harvest and slightly increase road miles compared 

to Alternatives 1 and 2. The number of new road miles and road crossings would increase slightly (see 

Transportation section) relative to Alternatives 1 and 2 but overall harvest would not. While different areas 

may have harvest occurring and some additional roads may be constructed compared to the current Forest 

Plan, the change would be minor, and effects would be similar for fish, fish habitat, and watershed 

conditions as under Alternative 1. Like Alternative 2, Alternative 3 would be protective to fish resources 

within T77 watersheds and TNC/Audubon Conservation Priority Areas, and some additional sockeye 

watersheds, because it is the most restrictive on timber harvest and road building by designating nearly all 

of these lands within ARAs as Watershed Priority (3.21 million acres) with the remaining acres designated 

as Roadless Priority (24,000 acres).
Environment and Effects 3

Final EIS 3-139 Fish

In addition to designating T77 watersheds and TNC/Audubon Conservation Priority Areas within ARAs as 

Watershed Priority, Alternative 3 would also add protection to these areas outside of ARAs through the 

roadless regulation. Specifically, old-growth timber harvest would be prohibited, subject to exceptions

(Table 2-2) within T77 watersheds and TNC/Audubon Conservation Priority Areas outside of ARAs. Thus, 

the old-growth harvest prohibition would be extended beyond the designated` roadless area boundaries 

in order to maintain the balance and integrity of the watershed protection system. A prohibition on oldgrowth harvesting already exists through the Forest Plan, but Alternative 3 would include this prohibition 

in regulation. Young-growth timber harvest outside of ARAs within these areas would be allowable, as it is 

currently. This would apply to about 507,000 acres outside of roadless areas.

Alternative 4: This alternative has the potential to add more roads in roadless areas beyond roaded 

roadless logical extensions into old-growth areas and has a slight increase in overall new road miles 

constructed than Alternative 3 but similar to Alternatives 5 and 6. While a potential slight increase in roads 

and potential harvest areas with associated effects to streams could occur, with the current project 

harvest remaining unchanged, harvest and road building in these areas would only occur, with minor 

exceptions, with an associated reduction in roads and harvest in other areas. Thus, there would be similar 

effects to fish and their habitat, though possibly in different areas, as under Alternative 1.

Alternative 4 would be slightly less protective to fish resources within T77 watersheds and TNC/Audubon 

Conservation Priority Areas than Alternatives 2 and 3, designating most roadless areas within these lands 

Roadless Priority (about 3.2 million acres) or LUD II Priority (about 140,000 acres) ARAs. Forest Plan 

requirements would still apply, including the prohibition on old-growth harvests within these areas. 

However, there would still only be a slight potential increase in roads and essentially no change in harvest 

amount, so effects to fish and their habitat would be similar to current plan conditions over the Tongass.

Alternative 5: This alternative removed all regulatory roadless designation, and related restrictions, in 

development LUDs. This alternative has the potential to add more roads in currently roadless areas 

beyond the roaded roadless and logical extensions into old-growth areas accessible and has a slight 

increase in overall new road miles compared to Alternative 3 but similar to Alternatives 4 and 6. While a 

potential slight increase in roads and potential harvest areas with associated effects to streams could 

occur, with the current project harvest remaining unchanged, harvest and road building in these areas 

would only occur, with minor exceptions, with an associated reduction in roads and harvest in other 

areas. Thus, there would be similar effects to fish and their habitat, though possibly in different areas, as 

under Alternative 1.

Alternative 5 would be less protective to fish resources within T77 Watersheds and TNC/Audubon 

Conservation Priority Areas than Alternatives 2 and 3 because it is moderately restrictive on timber 

harvest and road building in these areas, designating these lands as LUD II Priority (about 136,000 acres) 

and Roadless Priority (about 2.1 million acres) ARAs.

Alternative 6: This alternative removes all designations of roadless areas on the Tongass. This 

alternative has the potential to add more roads in currently roadless areas beyond the roaded roadless 

and logical extensions into old-growth areas accessible and has a slight increase in overall new road 

miles compared to Alternative 3 but similar to Alternatives 4 and 5. While a potential slight increase in 

roads and potential harvest areas with associated effects to streams could occur, with the current project 

harvest remaining unchanged, harvest and road building in these areas would only occur, with minor 

exceptions, with an associated reduction in roads and harvest in other areas. Thus, there would be similar 

effects to fish and their habitat, though possibly in different areas, as under Alternative 1.

Alternative 6 would be less protective to fish resources within T77 watersheds and TNC/Audubon 

Conservation Priority Areas than Alternatives 2, 3, and 4 because it is not restrictive on timber harvest

and road building in these areas, removing all regulatory roadless designations. Forest Plan requirements 

would still apply, including the prohibition on old-growth harvests within these areas. However, there 

would still only be a slight potential increase in roads and essentially no change in harvest amount, so 

effects to fish and their habitat would be nearly identical to current plan conditions over the Tongass.
Environment and Effects 3

Final EIS 3-140 Fish

Special Status Species Assessments

Threatened and Endangered Species

As stated in the Affected Environment section, there are six Chinook salmon, two sockeye salmon, one 

coho salmon, two chum, six steelhead, and one green sturgeon evolutionarily significant units/DPSs that 

are federally ESA listed that may be present in waters potentially affected by project alternatives.

No ESA-listed stocks of salmon or steelhead originate (spawn) in Alaska streams. Listed species and 

stocks originate in freshwater habitats in Washington, Idaho, and Oregon. Some of these listed species 

migrate into marine waters off the coast of Alaska. While distribution of these stocks is primarily in outer 

coastal waters, some are occasionally present in the inner waters of Southeast Alaska and they may feed 

on prey resources originating within marine and estuarine waters of the Tongass.

The southern DPS of the green sturgeon is rarely present in Southeast Alaska waters. Most are believed 

to stay south, but some could be present in the inside waters of Southeast Alaska, particularly during the 

fall and winter. They migrate south again in spring (Lindley et al. 2008). The adults live in nearshore 

waters typically less than 100 meters deep (Lindley et al. 2008). Based on their regional and seasonal 

distribution, they would be uncommon in nearshore areas where potential project actions may have some 

effect.

The concern for ESA fish species would be those activities that affect the nearshore marine and marine 

environments. Beach and estuarine fringe timber harvests under the 2016 Forest Plan have a chance of 

affecting nearshore habitat that may supply prey resources to listed salmon, steelhead, or green 

sturgeon. Currently, there are about 17,000 miles of shoreline in the Tongass lands, and about 500 miles 

have past harvest. A small subset of these areas would be harvested over a 100+-year period under all 

alternatives. The Roadless Rule alternatives would not substantially or measurably change the quantity of 

these areas potentially affected. Nearshore marine bottom disturbance to intertidal and subtidal habitats 

could be caused by nearshore log yarding, vehicle travel on beaches, log rafting, and log loading and 

yarding vessel anchorage and associated activities. Sediment runoff to streams from land-based activities 

could have some effects to nearshore marine habitat where these species may be present. Site-specific 

nearshore marine habitat-disturbing actions, or any other ground-disturbing action, are not authorized 

under the considered alternatives of the Roadless Rule alternatives. Thus, the considered actions of the 

Roadless Rule alternatives would not have adverse effects to any of the listed species addressed in this 

section from potential nearshore marine disturbance or upslope activity.

These actions’ effects to listed fish were considered in the 2016 Forest Plan Amendment EIS which 

included informal consultation and NMFS concurrence with effects determinations. Biological 

Assessments prepared for the 2016 Forest Plan, and their determinations, represent the baseline 

condition (no action). There would be no change from the baseline condition under any of the Alaska 

Roadless Rule alternatives because, while there would be more acres potentially available for harvest 

with each of the Alaska Roadless Rule action alternatives the Alaska Roadless Rule would not cause 

changes in projected harvest amounts or otherwise result in effects to ESA listed species. Thus, there 

would be no effect (no change from baseline) under any Alaska Roadless Rule alternative. Further, future 

projects that could be implemented would still be required to adhere to Forest Plan requirements and 

would be subject to ESA consultation if there would be effects to listed species and/or critical habitat. 

Any proposed actions indirectly resulting from the considered alternatives will be evaluated on a casespecific basis as to their effects to listed species. This may include formal or informal consultation with 

NMFS at the time of project-specific evaluations.

The proposed federal action and the adoption of any of the action alternatives resulting in changes to the 

roadless rule for Alaska are not the source of causation for any potential effects to threatened or 

endangered fish species or designated critical habitat and will have no effect to listed species or 

designated critical habitat.

Sensitive Species

There are no aquatic sensitive species on the Tongass.
Environment and Effects 3

Final EIS 3-141 Fish

Cumulative Effects

General

The effects of the alternatives on fish resources may be influenced by other actions occurring in the 

project area. Appendix B provides a list of past, present, and reasonably foreseeable actions considered 

for cumulative effects and indicates which of these interact with aquatic resources affected by the Forest 

Plan alternatives.

The main factors affecting fish are related to land development actions that occur regionally. This 

primarily includes other timber harvest-related actions on non-NFS lands, especially associated roads. 

The total lands within the Tongass boundary, which includes all NFS lands and other non-NFS lands, is 

about 17.8 million acres. Of this, only about 6 percent (1.1 million acres) are non-NFS lands. However, 

development actions on these non-NFS lands, which include most cities and towns in Southeast Alaska, 

are moderately intense.

Cumulative effects to fish resources include those actions that affect water and watershed resources, 

such as the development of roads. Generally, overall average road density, which is an indicator of 

potential adverse sediment effects to streams, is expected to increase markedly on non-NFS lands, but 

across the region would only increase slightly over 100 years (see USDA Forest Service 2016b, Water

section) under the current Forest Plan and would not change from this estimate among the alternatives 

(Table 3.3-23).

Table 3.3-23

Estimated Average Total Road Density on Tongass NFS Lands and Non-NFS Lands 

within the Tongass National Forest Boundary by Alternative over 100+ years1 

Alternative

Road Density as Miles/Square Mile

Road Density on NFS 

Lands

Road Density on Non-NFS 

Lands2

Total Road Density All 

Lands

Existing 0.19 2.30 0.32

Alternative 1 0.23 3.60 0.44

Alternative 2 0.23 3.60 0.44

Alternative 3 0.23 3.60 0.44

Alternative 4 0.23 3.60 0.44

Alternative 5 0.23 3.60 0.44

Alternative 6 0.23 3.60 0.44

1 Assumes full implementation of Forest Plan at PTSQ levels plus future non-NFS harvest. Includes adjusted roads miles 

estimated to be needed to harvest all scheduled timber in the alternative. 

2 Assumes an estimated increase in non-NFS road miles within the Forest boundary from 4,054 miles at present to 6,346 

miles after 100 years.

Source: Tongass National Forest GIS layer, 2018, and modeling of alternatives.

Effects on fish resources are less directly tied to the amount of timber harvest than to roads, but harvest 

may affect fish through effects to water quality, riparian condition, and where the harvest occurs, as 

discussed under Effects. Existing conditions include retention of 86 percent of the original productive oldgrowth forest inside the Forest boundary and 95 percent of the land area remaining undisturbed from 

direct timber harvest (USDA Forest Service 2016b, Water section Table 3.4-10). Overall, the cumulative 

effects to fish relating directly to quantity of timber harvest would be about 82 percent of the original 

productive old growth on all lands within the Forest boundary under the current Forest Plan in the future 

and would be unchanged by any Alaska Roadless Rule alternative.

While some local regions may have fish resources affected where watershed harvest levels and road 

density are high under the current Forest Plan, additional affects from any Roadless Rule alternative 

would not occur. Protections on non-NFS lands for stream buffers would be less but roadless alternative 

actions would not likely change cumulative effects to fish resources in these. There would be no 
Environment and Effects 3

Final EIS 3-142 Fish

difference in cumulative effects among the Alaska Roadless Rule alternatives and these cumulative 

effects would be unchanged from those disclosed in the 2016 Forest Plan Amendment EIS. Again, effects 

of harvest activities on fish resources would ultimately be considered at the project-specific levels, 

ensuring minimal adverse cumulative effects.

Climate Change

Climate change is one factor that has some unquantifiable potential to affect fishery resources on the 

Tongass. In general, climate changes could affect stream temperature, snow accumulation and 

precipitation, stream flow and peak stream flow, and ocean water levels. The effects to fish resources in 

the Tongass from these changes would be both positive and negative and would vary by species, life 

stage, and location. Higher temperatures are expected in the winter months, with greater precipitation 

increases expected in winter and fall (EcoAdapt 2014). With warmer temperatures, much of the 

precipitation that currently is snow would fall as rain. The result would be higher peak flows in the winter 

and fall in most streams, and, even with increased precipitation, lower summer flows primarily in 

snowmelt- and rain-fed dominated basins, which would include most major fish-producing systems in 

Southeast Alaska (Shanley and Albert 2014; Shanley et al. 2015).

Higher stream temperatures would result in faster egg development and emergence of fry. This may 

affect when fish out-migrate to the ocean, which may have negative consequences (Heard 1991; Salo 

1991). Elevated temperatures, however, may result in faster fish growth in these typical cool water

streams of Southeast Alaska, which could be positive. If temperatures increase too much, fish may suffer 

indirect effect such as insufficient food supply to maintain growth even for temperatures well below 

physiological stress. Elevated temperatures may also increase the rate of predation on juvenile fish by 

other fish species (e.g., cutthroat trout and Dolly Varden char). Elevated temperatures in late summer or 

fall could also affect adult salmon survival and reproductive success (Bryant 2009). Changes in

temperature could also affect life stage development possibly affecting whether fish out migrate or remain 

as resident fish (Kendall et al. 2015; Pearce et al. 2009).

Changes in flow could also have positive and negative effects. Higher flows in the winter may increase 

overwintering habitat for fish such as juvenile coho salmon, while high flows at this time could also scour streams 

beds affecting fish redds and habitat (Shanley and Albert 2014; Bryant 2009). Increasing precipitation in the 

winter likely increases the risk of landslides and debris flows that may enter streams (Bryant 2009). Areas that 

historically received precipitation as snow may get more as rain as estimated for climate change. Many species of 

Pacific salmon have adapted to high flows by selecting coarser spawning substrate (depending on species size) 

and locations away from the channel center (May et al. 2009). Sloat et al. (2016) modeled the likely effects of 

future flow changes from climate change on spawning conditions in Southeast Alaska. They noted that median 

annual average flood flows would increase by 28 percent by 2080. The estimated effects on habitat varied by 

watershed and stream morphology–specific conditions.

Climate change could also result in sea-level change. This sea-level rise could inundate estuarine rearing areas 

for fish. Stream mouth areas of some low-gradient small streams, which are used by some rearing fish including 

coho salmon, could also be inundated with salt water if sea-level rises were substantial. Pink and chum salmon in 

some areas spawn in intertidal regions, which could be affected with sea-level rise. Current predictions are for a 

sea-level rise of 1.3 to 2.1 feet by 2081-2100 (Shanley et al. 2014). However, the Southeast Alaska land mass is 

rising in many areas; due to isostatic rebound from past glaciers, sea level in Southeast Alaska is decreasing by 

as much as about 3 centimeters/year (1.2 inches/year) (Larsen et al. 2005). Some areas, particularly in northern 

Southeast Alaska, may rise 1 to 4 feet over the next century (Kelly et al. 2007). This rate of land rebound increase 

would likely offset sea-level rises over most of the Tongass shorelines. Thus, overall effects on estuarine areas, 

coastal stream mouths, and fish stocks would vary considerably, and changes are difficult to predict and may 

even be difficult to detect.

In summary, there is general agreement that the climate is warming, precipitation will increase, and flows 

will increase in the fall and winter but decrease in summer in snow- and rain-dominated watersheds. 

However, there is uncertainty surrounding specific predictions and even more uncertainty regarding the 

effect of these changes on resources including fish. The cumulative effects of climate change are not 

clear but some of the changes could be detrimental to fish resources.
Environment and Effects 3

Final EIS 3-143 Climate and Carbon

Other Important Issues

Climate and Carbon

Affected Environment

Climate

The Tongass National Forest occupies an archipelago and a narrow strip of the mainland between the 

Pacific Ocean and the crest of the coastal mountains. The configuration of the coastline, the warm 

Japanese ocean current, and the high coastal mountains combine to produce a cool, wet environment. 

Precipitation at sea level in Southeast Alaska ranges from 30 inches per year at Skagway to 220 inches 

per year at Little Port Walter, with precipitation rates increasing with elevation. Average annual 

precipitation can be as high as 400 inches on the mountains of southern Baranof Island and about 260 

inches over the Juneau Icefield. Southeast Alaska has complete cloud cover approximately 85 percent of 

the year. Snowfall varies according to elevation and distance inland from the coast. October is generally 

the wettest month. May through July are on average the drier months. The Pacific maritime influence 

holds the daily and seasonal temperatures within a narrow range. Temperatures average 28 degrees 

Fahrenheit (°F) in the winter and 52°F in the summer. During the warmer months, temperatures are 

highest inland and lowest along the coasts, while in the colder months, the reverse is true. Storms and 

moderate to heavy precipitation occur year-round, but occurs most commonly in early fall. The abundant 

moisture supports an extensive temperate rain forest and feeds numerous streams, rivers, and lakes, 

which in turn provide valuable fish habitat.

Climate Change

Southeast Alaska experiences considerable year-to-year and decade-to-decade variability in its weather, 

associated with large-scale shifts in ocean temperatures, salinity levels, and ice conditions (as described 

in the 2016 Forest Plan Amendment EIS [USDA Forest Service 2016a]). However, Southeast Alaska’s 

climate has shown a strong warming trend since the middle of the 19th century (i.e., the end of the Little 

Ice Age), as has much of the Northern Hemisphere (Parson et al. 2001; Sullivan et al. 2015; Markon et al. 

2018). A portion of this change in Southeast Alaska’s average temperature is likely the result of the 

natural changes in the earth’s climate, which are caused in part by “wobbles” in the earth’s rotation 

around the sun resulting in changes to earth’s position within its elliptical path (i.e., the precession of 

equinoxes) as well as the Pacific Decadal Oscillation (as described in the 2016 Forest Plan Amendment 

EIS [USDA Forest Service 2016a]). However, recently (in geological terms) humans have contributed to 

the acceleration of natural climate change on a global level through multiple activities such as the burning 

of fossil fuels, which have released greenhouse gases (GHGs) into the environment, as well as reducing 

natural carbon sinks (Intergovernmental Panel on Climate Change [IPCC] 2014; USDA Forest Service 

2015d; Markon et al. 2018). The potential impacts of accelerated global climate change on the 

ecosystems of Southeast Alaska may include acidification of ocean waters; increasing the temperatures 

of ocean and streams; altering water input sources; changing precipitation rates and patterns; increasing 

the rate of glacier retreat; increasing storm intensities; altering ecosystem composition and structure; 

altering species distributions; and altering fire regimes (Wolken et al. 2011; EcoAdapt 2014; Shanley et al. 

2015; Markon et al. 2018).

The impacts of climate change have been, and will likely continue to be, more pronounced in the most 

northern and southern regions of the globe. Alaska, which is located farther north than any other U.S. 

territory or state, has experienced an increase in annual temperatures at twice the rate of the rest of U.S. 

(Haufler et al. 2010; Chapin et al. 2014; Markon et al. 2018). Alaska’s annual average temperatures have 

increased by 3.4°F over the last 50 years, with an increase of 6.3°F in average winter temperatures 

(Haufler et al. 2010; Chapin et al 2014; U.S. Environmental Protection Agency [EPA] 2014a). The 

average number of snow-free days has also increased in Alaska by about 10 days (Chapin et al. 2014). 

The observed changes to the climate in Southeast Alaska have resulted in modifications to ecosystem 

processes and ecosystem services on the Tongass. For example, the warmer summers have led to 
Environment and Effects 3

Final EIS 3-144 Climate and Carbon

longer growing seasons for trees and other vegetation, while warmer winters have resulted in more insect 

outbreaks, plant diseases, and population declines for some plant species.22 The warming trend has also 

reduced snowpack in low-elevation areas, which may be contributing to ongoing yellow-cedar decline.23

Drier summers may have also contributed to the number and duration of low stream-flow episodes, which 

can have adverse effects on salmon while warming of some watersheds may increase productivity for 

some fish populations (EcoAdapt 2014). The increase in the amount of precipitation falling as rain instead 

of snow since the 1970s has reduced the frequency of low- and moderate-elevation avalanches, which 

has allowed mountain hemlock to colonize some alpine areas (EcoAdapt 2014; Shanley and Albert 2014). 

Furthermore, although Alaska has not yet experienced the same extensive rate of establishment by 

invasive plant species that has historically occurred in the rest of the U.S., the current and predicted 

milder winter temperatures and the longer growing season in Southeast Alaska have created 

opportunities for the spread and establishment of invasive plant species within this region (Bauder and 

Heys 2004; McKee 2006; Wolken et al.2011).

The ongoing changes to Alaska’s climate, as well as to the temperate forests in this region, can have 

global consequences. For example, recent data show that the melting of glaciers and ice sheets in Alaska 

has contributed more to the global increase in sea levels over the past 50 years than any other glaciated 

region that has been measured, with the exception of the Greenland and Antarctic ice sheets (Wolken et 

al. 2011; Chapin et al. 2014). The coastal-temperate forests in Southeast Alaska comprise approximately 

10 percent of Alaska’s total forests and 19 percent of the world’s coastal-temperate forests (Wolken et al. 

2011). Although these coastal forest types are confined to a relatively small footprint globally (covering 

less than 0.5 percent of the earth’s total forested area), they play a critical role in the delivery of dissolved 

organic carbon to coastal oceans (Wolken et al. 2011). In addition, these forests currently take up and 

store large quantities of carbon relative to most forest types in higher latitudes (DellaSala 2014; DellaSala 

2016; Law 2014). As a result, Southeast Alaska plays a role in the global climate and carbon cycle; 

however, the recorded and projected increases in temperature and precipitation in the region can have 

both positive and negative effects on these forests ability to sequester carbon (Parks 2013; Markon et al. 

2018; see further discussion in the “Carbon Sequestration” subsection below). 

Climate Models

There are several models that examine the potential future climate conditions and/or trends in Alaska’s 

climate. Most models suggest warmer, wetter conditions for Alaska. They generally project that rainfall 

may increase and snowfall may decrease at lower elevations in Southeast Alaska over the next 50 to 100 

years (Bonsal and Prowse 2006; SNAP 2013; Markon et al. 2018). The Scenarios Network for Alaska & 

Arctic Planning (SNAP) developed a model for climate projections in Southeast Alaska (SNAP 2013 as 

cited in EcoAdapt 2014). SNAP’s projections suggest that mean winter temperatures in Southeast Alaska 

may increase by an additional 1.8 to 6.3°F (or 1 to 3.5 degrees Celsius) by the year 2050 (SNAP 2013 as 

cited in EcoAdapt 2014). Their model also suggests that precipitation levels may increase in all seasons, 

with winter precipitation potentially increasing by 5 to 15 percent by 2050. The most recent synthesis for 

the National Climate Assessment (by the NCA4 Alaska Chapter team), presented annual average 

temperature increases for Southeast Alaska for the end of the 21st century ranging from 4 to 6°F under a 

lower GHG emission scenario to 6 to 10°F under a higher scenario (Markon et al. 2018).

The effects that these changes in temperature and precipitation levels would have on local conditions 

would vary, with the increased precipitation potentially resulting in increased snow occurring at higher 

elevations where temperatures remain below freezing. Lower elevations could experience a shift from 

snow to rain and a decrease in snowpack as the lower elevations warm and the number of days with 

below freezing temperatures decrease (SNAP 2013 as cited in EcoAdapt 2014; Markon et al. 2018).

22 In 2014, Alaska Region Forest Health Protection surveyed 4.5 million acres of the Tongass National Forest and mapped 51,000 

acres of insect and disease damage. The most widespread damage type was recorded for yellow-cedar (which had a decline of about 

19,600 acres), followed by 12,000 acres of spruce defoliation. Seventeen other infestation/damages were mapped, most notably 

cottonwood defoliation, hemlock sawfly, and general conifer defoliation (Heutte, pers. comm. 2015).

23 Almost 585,000 acres of yellow-cedar decline have been mapped in Alaska through aerial detection surveys since the surveys 

began in the late 1980s, with extensive mortality occurring in a wide band from the Ketchikan area to western Chichagof and Baranof 

Islands (USDA Forest Service 2015d).
Environment and Effects 3

Final EIS 3-145 Climate and Carbon

Carbon Sequestration

Forests both take up carbon dioxide and release it into the atmosphere. Forests are dynamic systems 

that naturally undergo ebbs and flows in carbon storage and emissions as trees establish and grow, die 

with age or disturbances, and re-establish and regrow. Management activities, such as timber harvests, 

tend to approximate and promote natural processes that would also release carbon to the atmosphere. 

Many management activities initially remove carbon from the forest ecosystem, but they can also result in 

long-term maintenance or increases in forest carbon uptake and storage by improving forest health and 

resilience to various types of stressors. Carbon can also be transferred and stored outside of the forest 

system in the form of wood products, further influencing the amount of carbon entering the atmosphere. 

Wood fiber can substitute for products that generate more GHG emissions to produce, such as concrete 

and steel, and it may be used as a renewable energy source (“substitution effect”). Substitution of wood 

for fossil fuel–intensive materials and energy can lower net carbon emissions.

Carbon, primarily in the form of carbon dioxide, is one of the major GHGs released into the atmosphere 

through both natural and anthropogenic (i.e., human-driven) influences (McPherson and Simpson 1999; 

IPCC 2014). Recent changes to the global carbon cycle, driven in large part by human activities, have 

been cited as the leading cause of global climate change and the general global warming trend that has 

been detected (IPCC 2014, 2018). Forests worldwide contribute greatly to the global carbon cycle by 

taking up and storing about 1.4 billion metric tonnes of carbon every year (McKinley et al. 2011), and 

forests already store over one trillion metric tonnes of carbon24 in plants and soil (Domke 2018). Forest 

management can play an important role in moderating the amount of carbon dioxide that enters and 

leaves the atmosphere (Ryan et al. 2010; McKinley et al. 2011; Skog et al. 2014).

The Tongass contains almost 10 million acres of forest land. About 5.5 million of these acres are 

considered to be productive forest land. The Tongass stores more forest carbon than any other national 

forest in the United States (Barrett 2014), due to its very large size and high density of carbon. As such, 

an important ecosystem service sustained by this forest is carbon uptake and storage (i.e., the removal of 

carbon dioxide from the atmosphere and storage of it in live or dead biomass as well as organic soil 

matter). This makes the Tongass, along with forests worldwide, an important component in the global 

carbon cycle (DellaSala 2014; Law 2014).

Carbon Storage in Soils

Generally, the capacity of a forest system to take up and store carbon depends on the location (climate, 

disturbance), stand age, and species composition of the forest (Birdsey et al. 1993; McKinley et al. 2011). 

In some forests found in warmer climates, the accumulation of carbon can decrease overtime as the 

carbon stored in soils and dead vegetative materials are released through the process of organic decay, 

which includes biomass breakdown/decay and carbon release. A portion of the dead or decaying plant 

matter is eventually incorporated into the soil’s organic and mineral layers within the Tongass where it 

accumulates and has varying degrees of recalcitrance (i.e., resistance to breaking down), decaying 

quickly or over centuries. The cool conditions on the Tongass produce a slower rate of decomposition 

compared with forests in warmer climates. Mature forests within the Tongass generally store considerable 

amounts of carbon in the soils. Although the soils of the Tongass currently store considerable amounts of 

carbon, D’Amore and Lynn (2002) note that numerous studies have shown that carbon stored in soils 

may be released to the atmosphere in the form of carbon dioxide or methane as the climate warms, and 

climate warming is expected to be relatively high in Southeast Alaska (see above). Harvest activities can 

modify this effect by increasing the amount of solar energy that is allowed to reach the ground while the 

forest regenerates following a harvest. In contrast, forest clearing can have a slight local cooling effect

due to surface albedo (replacing the darker forest with more reflective open land, especially in winter 

when the ground is covered by snow). Davidson and Janssens (2006) noted that many factors can affect 

the sensitivity of soil decomposition rates to increased temperatures (e.g., the relative mix of organic to 

mineral substrates, soil moisture levels, as well as other biotic and abiotic conditions) and that not all soil 

types would be equally sensitive to increased temperature; however, D’Amore has indicated that the 

24 Carbon mass is used here, not carbon dioxide mass, because carbon is a standard unit and can easily be converted to any other 

unit. To convert carbon mass to carbon dioxide mass, multiply by 3.67 to account for the mass of the oxygen.
Environment and Effects 3

Final EIS 3-146 Climate and Carbon

organic layers in the soil profile on the Tongass may experience increased decomposition rates if average 

temperatures were to increase (D’Amore et al. 2015; D’Amore 2016). Based on a synthesis of information 

from a wide range of recent studies, Conant et al. (2011) state that the impacts of climate warming on 

decomposition dynamics have not been resolved due to apparently contradictory results from field and 

lab experiments, most of which has focused on labile carbon with short turnover times. But the majority of 

total soil carbon stocks are composed of organic carbon with turnover times of decades to centuries. 

They conclude that important advances in understanding the temperature response of the processes that 

control substrate availability, depolymerization, microbial efficiency, and enzyme production will be 

needed to predict the fate of soil carbon stocks in a warmer world.

Carbon Storage Aboveground

Previous studies have been conducted to determine how much carbon is stored on the Tongass. Barrett 

(2014) examined the storage and flux of carbon in live trees, snags, and logs in the Tongass.25 On the 

Tongass, growth and recruitment of live trees removed an estimated 760 pounds of carbon per acre per 

year on average from the atmosphere, but net change in live (aboveground) carbon mass was not 

significantly different from zero, with mortality and harvest estimated at 670 pounds of carbon per acre 

per year on average (Barrett 2014). Estimates were based on plot data measured in 1999-2003 

compared with plots measured in 2004-2010. Including wilderness areas, aboveground live and snag 

carbon on the Tongass is estimated to be 601 (± 21) million U.S. tons26 on an estimated 9.7 million acres 

of forest.27 Some 233 million U.S. tons of this carbon are on lands that are legally excluded from timber 

harvesting, such as formally designated wilderness areas (Barrett 2014). Total carbon densities on 

unmanaged forests were estimated as 72 U.S. tons per acre, which comprised 7 percent logs, 13 percent 

snags, and 80 percent live trees. Carbon densities on managed forests were estimated as 45 U.S. tons 

per acre, which comprised 38 percent logs, 8 percent snags, and 54 percent live trees (Barrett 2014). On 

a per-acre basis, the Western hemlock and Sitka spruce forest types were found to have the highest 

amount of carbon (Barrett 2014). Using the per-acre values by forest types, and extrapolating to include 

wilderness areas, provides a rough estimate of about 650 million U.S. tons in aboveground tree carbon 

on the Tongass, equivalent to 2.4 billion U.S. tons of carbon dioxide (Barrett 2014). 

To put this in perspective, an estimated 83,500,000 billion metric tons of carbon are stored worldwide, 

primarily in the oceans and marine sediment, based on United Nations estimates. In 2005, Heath et al.

(2011) estimated that the carbon stored in the Tongass in all carbon pools (above- and below-ground live 

tree biomass, understory vegetation, standing dead trees, down dead wood, forest floor, and soil organic 

carbon to the depth of one meter) makes up about 11 percent of the carbon stored in the national forests of 

the United States. More recently, Smith et al. (2019) estimated that the Tongass portion of all stored carbon (all 

pools) in 2017 made up about 9 percent of the carbon stored in United States national forests. Leighty et al. 

(2006) estimate that between 6.4 and 17.2 million metric tons (0.2 to 0.6 percent) of stored carbon in 

aboveground carbon pools, net of subsequent regrowth, has been lost on the Tongass since timber harvest

began in 1900 through 1995. For comparison, approximately 2,039 million metric tons of carbon dioxide 

(converts to approximately 556 million metric tons of carbon) were released to produce electric power in the 

United States in 2012 (U.S. Energy Information Administration [EIA] 2013). The total U.S. carbon dioxide

emissions in 2017 (which includes the electric sector discussed above, as well as other sections such as 

industry, transportation, agriculture, and commercial/residential) were approximately 5,280 million metric tons of 

carbon dioxide (converts to approximately 1,439 million metric tons of carbon) (EPA 2019).

Mature forests on the Tongass National Forest likely store considerably more carbon compared to 

younger forests (within the individual trees themselves as well as within the organic soil layer found in 

mature forests). At the stand level, the rate of carbon uptake may decline and level off as forests reach 

older ages due to increases in mortality and subsequent respiration, although total carbon storage may 

25 A number of carbon pools and fluxes were not included in Barrett’s report, including (1) carbon in non-forested lands, which includes 

alpine environments, wetlands, grasslands, and shrublands; (2) below-ground carbon, including roots, soils, and organic materials; 

(3) carbon in non-tree vegetation and litter within forest; (4) carbon in a few pools currently not measured by FIA, which includes 

stumps below 4.5 feet and dead saplings; and (5) carbon in forest lands in inaccessible wilderness.

26 Conversions: 1 U.S. ton = 0.907 metric ton, 1 metric ton = 1.102 U.S. tons

27 Note that this does not represent a complete accounting of stored carbon, as it does not take into consideration carbon stored in 

the soil, nor does it take into consideration the stored carbon present in the final products of the harvested timber.
Environment and Effects 3

Final EIS 3-147 Climate and Carbon

continue to increase over time (Ryan et al. 1997; Pregitzer and Euskirchen 2004). However, this decline 

in the rate of carbon uptake may be slower and less pronounced than in other regions, given that 

decomposition rates in the Tongass are relatively lower. Furthermore, some studies have indicated that 

individual live trees can continue to accumulate carbon at increasing rates as they mature, thereby 

resulting in large amounts of carbon stored annually within mature trees (Stephenson et al. 2014).

Land Conversion

Important to the maintenance of this ecosystem service performed by the Tongass is the maintenance of 

its land base in forest. The largest source of GHG emissions in the forestry sector globally and within the 

United States is deforestation, defined as the removal of all trees on forested land to convert it to other 

land uses. Converting forest land to a non-forest use not only removes carbon from the forest, it inhibits 

future carbon uptake and storage indefinitely, because there is no regrowth. Since the mid-1950s, 

changes in land use have been minor in the Tongass. Development pressure for land use conversion in 

Southeast Alaska has been slight. This is true for the non-NFS lands as well. 

Timber Harvesting

Timber harvesting and active forest management can affect a forest’s ability to take up and store carbon. 

After a forest is harvested, it will eventually regrow and recover the carbon removed from the ecosystem 

in the harvest. In some cases, removing carbon from forests for human use can result in lower net 

contributions of GHGs to the atmosphere than if the forest was not managed, when accounting for the 

carbon stored in wood products, substitution effects, and forest regrowth (Skog et al. 2014; Bergman et 

al. 2014; McKinley et al. 2011), Skog et al. (2014) noted that harvesting forests with high biomass and 

replanting with new forests would reduce carbon stocks more in the near term than if the high biomass 

forest were retained. They also note that increasing harvest intervals for forests harvested prior to peak 

growth rates begin to decline (culmination of mean annual increment [CMAI]) would maintain higher 

carbon stocks over time. Several authors (DellaSala 2016; Janish and Harmon 2002) suggest that the 

amount of carbon lost initially due to harvesting might take 50 to 200 years to fully recover in the 

ecosystem. However, these estimates do not include consideration of harvested wood products and 

substitution effects, which would effectively reduce the initial impacts more quickly. The net effect of a 

timber harvest and active forest management action (i.e., amount of carbon released versus the amount 

stored) would depend on how the harvested timber was used (e.g., if it was used for durable timber 

products, paper, pulp, or biomass fuels), what substitute materials are available for construction purposes 

(i.e., non-wood materials), the amount of carbon emitted during harvesting activities, the amount of 

carbon emitted via decomposition of on-site wood and organic soil matter losses, and the influence of the 

harvested wood on timber markets elsewhere (McKinley et al. 2011; Jonsson et al. 2012). 

Timber harvesting in Southeast Alaska peaked in the 1970s and 1980s, and harvest on the Tongass 

declined after that, especially after closure of two large pulp mills in the 1990s. Beginning in the 1980s 

logging increased on Alaska Native corporation and state lands. Approximately 474,000 acres of 

productive old growth have been harvested on the Tongass, almost entirely from the 1950s and more 

recent. This represents about 9 percent of the original amount of productive old growth and about 5 

percent of all forest land on the Tongass. About 76 percent of these acres were harvested prior to 1990. 

Current harvest rates (since about 2006) were around 1,200 acres or less each year. The USDA Forest 

Service (Birdsey et al. 2019) estimated that the 2011 carbon storage on the Tongass was reduced by less 

than 0.3 percent by all disturbances (including harvest, insects, wind, and fire) during the period from 

1990 to 2011. During this period, the harvest rate was approximately 5,100 acres of old growth per year. 

This result includes all non-soil ecosystem pools.

Forest carbon stocks on the Forest, including above- and below-ground, appear to be steady or 

increasing, even after the impacts of disturbances, increasing about 1.4 percent between 1990 and 2013 

(USDA Forest Service 2015d). In the Alaska Region’s baseline forest carbon assessment, the USDA 

Forest Service (2015d) concluded that, based on forest inventory data, total forest ecosystem carbon (in 

all seven ecosystem carbon pools) stored on the Tongass steadily increased from 2005 to 2013, adding 

about 4.6 million metric tons of carbon during this 8-year period. For context, another complementary 

report found that about 1.9 million metric tons of carbon were removed by timber harvests on the Tongass 
Environment and Effects 3

Final EIS 3-148 Climate and Carbon

over a recent and longer period (21 years) from 1990-2011 (Birdsey et al. 2019). Thus, when comparing 

these recent periods, carbon stocks were being added at a much greater annual rate (by more than 6 

times) than what was removed from harvesting. 

Other Disturbance Factors

Aside from timber harvesting, the only other disturbance factors of major importance on the Tongass 

have been windthrow and, to a lesser extent, insects; large windthrow events have occurred sporadically, 

but small windthrow disturbances are a common occurrence in Southeast Alaska forests. Land 

exchanges could be considered a disturbance factor as well. However, the lands involved are generally 

maintained as forests, possibly undergoing forest management.

Environmental Consequences

Indirect Effects

Climate Change / Carbon Sequestration

Implementation of any of the alternatives would be similar to how the Forest is managed today and would 

not convert additional forest land to non-forest uses. The largest source of GHG emissions in forest 

ecosystems globally and within the United States is deforestation, defined as the permanent removal of 

all trees on forested land to convert it to other land uses such as agriculture and residential development. 

Maintaining forest land is necessary to ensure carbon storage over time and to realize potential carbon 

benefits from management activities through regrowth. Forests would not be converted to other land uses 

but rather would be retained and managed to maintain a vigorous and healthy condition with a decreasing 

reliance on old-growth harvest and increased harvest of regenerated forest (young growth) over the next 

15 years. Consequently, the alternatives would not result in major sources of GHG emissions relative to 

local, national and global emissions and can be important in maintaining forest carbon uptake and 

storage and other ecosystem services in the region.

The effects of implementing the Forest Plan under the nationwide Roadless Rule (i.e., the No Action 

Alternative) and the action alternatives on GHG emissions and climate change would likely be small 

although there is considerable uncertainty regarding these effects. For instance, there is uncertainty 

regarding long-term carbon release particularly because of the importance of how the wood is used 

(durable or nondurable products), the regrowth of young forests, and market dynamics related to 

substitution. Considering the alternatives in a global atmospheric carbon dioxide context, treatment levels 

would have a small contribution to GHG emissions and therefore would have a negligible effect on 

climate change. Because local GHG emissions mix readily into the global pool of GHGs, it is difficult and 

highly uncertain to ascertain the indirect effects of emissions resulting from these alternatives on global 

climate. There would be only negligible differences among the alternatives because the harvest levels 

and the mix of old growth and young growth to be harvested are expected to be very similar, and thus 

unaffected by implementation of the Alaska Roadless Rule. As a result, the alternatives would not differ in 

regard to their contributions to GHG emissions, changes in forest carbon stocks, carbon sequestration, or 

global climate change. Given the level of uncertainty in parameters related to the net contribution of 

GHGs, an attempt to quantify the evaluation would not provide a clearer understanding of potential 

effects.

This scope and degree of harvest effects would be similar and minor for all the alternatives, affecting an 

estimated 3.5 percent of the 9.7 million acres of forested land, 6 percent of all productive forest land, and 

less than 1 percent of productive old growth forests on the Tongass over 100 years (based on the 

assumption that harvest occurs at the Projected Timber Sale Quantity rate over the next 100 years). The 

average harvest rate over the next 100 years would be about 425 acres per year for old growth and 2,842 

acres per year for young growth (with more old growth and less young growth in the early years and the 

opposite in later years), which is substantially lower than the harvest rate analyzed in the USDA Forest 

Service (Birdsey et al. 2018) disturbance report (discussed previously). In addition, timber harvests mostly 

affect aboveground carbon stocks (live woody vegetation), while carbon stored in the soils represents a 

relatively stable and long-lived carbon pool (McKinley et al. 2011; Domke et al. 2017), However, there is 
Environment and Effects 3

Final EIS 3-149 Climate and Carbon

growing evidence that carbon stored in soil is sensitive to global change effects, particularly land use 

histories, resource management, and climate (Domke et al. 2017).

Based on the fact that all of the alternatives would result in the same harvest volumes, effects are 

expected to be similar. Given the fact that the average harvest rate expected over the next 100 years is 

low by historical standards it is logical to assume that the rate of carbon loss due to disturbances would 

also be lower, because timber harvesting has been the dominant disturbance type (Birdsey et al. 2019). 

Further, given the maintenance of live tree carbon estimated on the Tongass by Barrett (2014) and the 

growth of total ecosystem carbon on the Tongass estimated by the USDA Forest Service (2015d) (both 

discussed previously) under the more intensive historical harvests, it is logical to assume that ecosystem 

carbon will continue to accumulate at the forest level, outpacing carbon removed due to the expected 

amount of harvesting under all alternatives.

Some assessments suggest that the effects of climate change in some U.S. forests may cause shifts in 

forest composition and productivity or prevent forests from fully recovering after severe disturbance 

(Anderson-Teixeira et al. 2013), thus impeding their ability to take up and store carbon and retain other 

ecosystem functions and services. An evaluation of the relative stability of biomes and the climate niche 

of dominant tree species on neighboring Chugach National Forest suggests that the Chugach Kenai 

Peninsula of Alaska are exceptionally resilient to expected changes in climate over the next 30 to 50 

years (Hayward et al. 2017). However, there are considerable differences between the Tongass and the 

Chugach/Kenai assessment area and a comparable assessment has not yet been completed for the 

Tongass. 

On the Tongass, yellow-cedar is one species that is already demonstrating effects of climate change on 

its distribution (Hennon et al. 2016). Based on plot data, Parks and Barrett (2013) noted that live-tree 

biomass in higher elevation ecoregions of the Alaska temperate rain forest increased by 7 to 8 percent 

between 1995 and 2008, western redcedar showed a 4.2 percent increase in live-tree biomass, and 

shore pine showed a 4.6 percent decrease. They concluded that continued warming in Alaska’s 

temperate rain forest could lead to further biomass increases at higher elevations via faster growth, more 

trees, and uphill migration of tree species. However, there is considerable uncertainty in the long-term 

response of Tongass forests in terms of forest composition, especially because the forest trees of 

Southeast Alaska are so long-lived. Despite long-term changes in climate, there is no direct evidence to 

suggest that that regenerating rainforest on the Tongass will have a reduced capacity for carbon storage 

under future climate conditions.

Cumulative Effects

Climate Change / Carbon Sequestration

This section will address two issues: 1) the cumulative effects of the alternatives and other past, present, 

and reasonably foreseeable actions on climate change and carbon sequestration; and 2) the cumulative 

effects of climate change on the Forest Service’s future management of the Tongass.

The extent and scope of cumulative effects on climate change and carbon sequestration depends on the 

amount and condition of total forest land harvested (worldwide, as well as locally within Southeast Alaska) 

and the use to which harvested wood is put, as well as the use of the land post-harvest and how the nonNFS lands are managed (including private and state-managed lands within the U.S., as well as forests in 

other countries). In addition, it depends on the amount of carbon released during harvest, processing, and 

transporting wood products and the decomposition rates of organic materials. Furthermore, it depends on 

factors such as the amount of new hydroelectric or other renewable energy power projects that are built 

(e.g., those that might replace diesel-generated power), future community expansion and development, 

and emissions from ongoing and future activities in the region. It is likely that most of the state and private 

commercial forest land in Southeast Alaska, except for state parks and some other state lands, would be 

managed for the production of forest products under any of the alternatives considered in this analysis. A 

noteworthy exception to this is the recent decision by Sealaska to set aside 165,000 acres of forested 

land in Southeast Alaska for 110 years to store, or bank, carbon (Sealaska 2018).
Environment and Effects 3

Final EIS 3-150 Climate and Carbon

Potential initial negative effects on the Tongass may be ameliorated and may be completely reversed with 

time, reducing or eliminating potential negative cumulative effects on carbon and climate. Carbon emitted 

during the initial implementation of the management actions (e.g., harvest) would have a temporary 

influence on atmospheric carbon concentrations, because carbon would be removed from the 

atmosphere over time following management as the forest regrows. These net outcomes would be the 

cumulative result of forest regrowth, enhanced productivity of young stands, growth of older stands, 

growth releases from light thinning, carbon storage off-site in products (Tongass produces mainly saw 

logs for long-lived products), and substitution benefits of wood products and wood-based energy (IPCC 

2007; McKinley et al. 2011; Keyser and Zarnoch 2012; Bergman et al. 2014; Skog et al. 2014). Also, over 

the longer term, the lower anticipated harvest levels associated with the Forest Plan are likely to result in 

the continued increase in forest carbon stocks and reduced carbon emissions to the atmosphere when 

considering the whole Forest, independent of which alternative is selected. The management 

mechanisms applied in all alternatives are consistent with internationally recognized climate change 

adaptation and mitigation practices identified by the IPCC. The IPCC recognizes a broader definition of 

the forest system (which includes the fate of carbon once it leaves the forest and use by society) and 

where various types of timber harvesting are among a suite of tactics to achieve short- and long-term 

carbon benefits (IPCC 2000, 2007).

Climate change could impact the resources currently managed by the Forest Service as well as how the 

Forest Service manages the Tongass in the future. While there is general agreement among scientists 

that the climate of Southeast Alaska is warming, there is considerable uncertainty concerning the exact 

scope of the effects of climate change on the forests of Southeast Alaska and how best to deal with 

possible changes to the many resources managed on the Tongass. A summary of the effects of climate 

change on Tongass resources is presented in the Climate and Air section of the 2016 Forest Plan 

Amendment EIS (USDA Forest Service 2016b). Because the effects of the alternatives on climate change 

are the same, this discussion is not repeated here.

The Forest Service will continue to work with local stakeholders and scientists to develop measures to 

alert the Forest Service to trends that may affect the health of the Forest and the species that depend on 

it, as well as measures that could be implemented to minimize or adapt to the effects of climate change 

on managed resources.
Environment and Effects 3

Final EIS 3-151 Karst Lands

Karst Lands

Affected Environment

The geology and climate of Southeast Alaska are particularly favorable for karst development. Karst is a 

comprehensive term that applies to the unique topography, surface and subsurface drainage systems, 

and landforms that develop by the action of water on soluble rock in Southeast Alaska. The dissolution of 

the rock results in the development of internal drainage, producing sinking streams (streams that sink into 

the stream bed or karst features), closed depressions, sinkholes, collapsed channels, and caves.

Karst lands add a vertical, underground dimension to land use planning. Karst subsurface drainage 

networks generally operate independently of, and with more complexity than, the surface drainage 

systems above. On karst lands, the many solution-widened fissures at the surface become entry points 

into the subsurface drainage system, where water and sediment from surface sources move vertically 

downward into the underground lateral systems. Sediment and water from disturbed lands or roads may 

enter this system at a single point and emerge unexpectedly at one or more distant springs, sometimes 

crossing surface watershed boundaries.

Karst resources must be evaluated according to their vulnerability to land uses. Vulnerability mapping 

recognizes that some parts of the karst landscape are more sensitive than others to surface activities and 

groundwater contamination. These differences in vulnerability may be a function of the extent of karst 

development, the openness of the karst systems, and the sensitivity of other resources that benefit from 

karst groundwater systems. The vulnerability categories and their criteria are defined in the 2016 Forest 

Plan, Appendix H (USDA Forest Service 2016a). For projects that could affect karst, a four-step Karst 

Vulnerability Assessment is conducted that includes identifying potential karst lands, inventorying and 

characterizing karst resources in the project area, delineating karst hydrologic systems and recharge 

areas, and assessing the vulnerability of the karst terrain to management activities.

Applicable federal, state, and municipal laws, regulations, and policies that govern the management of 

karst include the Federal Cave Resources Protection Act (FCRPA) of 1988 (16 United States Code 4301-

4309; 102 Stat. 4546), 36 CFR Part 290, 36 CFR part 261, Forest Service Manuals 2356 and 2880, and 

the Forest Plan (Karst and Cave Resources, Forest-wide Standards and Guidelines pp. 4-23 to 4-25, 

Plan Components for young-growth harvests on karsts pp. 5-5 to 5-6, and Appendix H).

Approximately 431,000 acres of karst underlies NFS lands inside the Tongass. Of these acres of NFS 

karst lands, approximately 278,000 acres were originally POG. Based on geographic information system 

(GIS) queries conducted for the 2016 Forest Plan Amendment EIS, about 82,000 of these POG acres (29 

percent) have been harvested. Much of the karst land within development LUDs has been designated as 

high vulnerability karst land and is protected by standards and guidelines or included within geologic 

Special Interest Areas.

On the low to moderate vulnerability karst lands, where mineral or glacially derived soils fully or partially 

cover the epikarst, forest regeneration is exceptional. In these areas, even the complete loss of soil and 

litter from the surface of the limestone will not prohibit the re-establishment of a forest because the 

displaced surface materials are retained within the epikarst channels (Harding and Ford 1993).

Recent monitoring has shown that the karst and cave standards and guidelines outlined in Forest Plan 

ensure a high level of protection for significant caves and karst resources overall (USDA Forest Service 

2015a). However, the Forest Service identified a need to amend the 2016 Forest Plan on lands identified 

as moderate vulnerability to provide greater flexibility in managing harvest to protect the karst resources 

based on site-specific conditions. The standards and guidelines for young-growth harvest on karst was 

amended in August 2020 to reduce the limitation on harvest.

Recent monitoring has shown that the karst and cave standards and guidelines outlined in Forest Plan 

were implemented to the fullest extent practicable, and through effectiveness monitoring have shown that 

they ensure a high level of protection for significant caves and karst resources overall (USDA Forest 
Environment and Effects 3

Final EIS 3-152 Karst Lands

Service 2015a). The standards and guidelines for young-growth harvest on karst was amended in August 

2020 to reduce the limitation on harvest.

For additional information on the importance and sensitivity of karst, and the effects of past and current 

forest management practices on karst, see the 2016 Forest Plan Amendment EIS (USDA Forest Service 

2016b, pp. 3-28 to 3-36).

Environmental Consequences

Indirect Effects

Potential effects from harvest that could occur under any of the alternatives could initially increase flow 

through karst systems after initial harvest in low and moderate vulnerability karst areas and subsequently 

(approximately 15 years post-harvest) decrease flow through these karst systems due to dense forest 

regeneration (Aley et al. 1993). Increase to turbidity and changes in water chemistry through the karst 

system could also occur due to these changes in flow (Aley et al. 1993). However, with implementation of 

the Forest Plan standards and guidelines, and site-specific mitigation measures (designed and 

implemented at the project level), the Forest Service expects to mitigate the effects of these activities.

None of the alternatives predict a PTSQ greater than the amount disclosed in the 2016 Forest Plan 

Amendment EIS (46 MMBF per year) nor would they result in a considerable difference in suitable acres 

on mapped low or medium vulnerability karst lands (estimated to range from 64,000 acres for Alternatives

1, 2, 3, and 4 to 65,000 acres for Alternative 5 and 6). Impacts to karst and cave resources would be 

based on site-specific proposals, which are currently unknown, and would be addressed in subsequent 

project environmental analyses. From a broad programmatic standpoint, the impacts to karst and cave 

resources from the proposed alternatives would be the same as disclosed in the 2016 Forest Plan 

Amendment EIS due to implementation of the Forest Plan standards and guidelines. Karst inventories 

and vulnerability assessments would continue to be required before timber harvest could occur on 

suitable lands under all alternatives.

No additional harvest is anticipated in any areas mapped as high vulnerability karst under any alternative 

because they are included in the existing Special Interest Areas and are not suitable for harvest. 

However, where commercial thinning is determined to be an appropriate treatment on high vulnerability 

karst lands, effects to karst will be addressed through project-specific prescriptions and analysis to ensure 

karst management objectives can be met.

Cumulative Effects

There are approximately 549,522 acres (859 square miles) of karst lands within the boundaries of the 

Tongass. Some 431,000 acres (674 square miles) are on NFS lands. Past timber harvest has affected

the epikarst landscape on the Tongass. In some portions of the Tongass, 70 to 80 percent of the 

commercial forest land within specific karst blocks has been harvested. It is estimated that about 29 

percent (82,239 acres) of the karst lands on NFS lands have been harvested (based on the GIS 

database). In addition, several hundred miles of authorized and unauthorized roads have been 

constructed on karst lands. All alternatives would allow additional future harvests and associated road 

building and reconstruction on karst lands to varying degrees. For example, the Central Tongass Project 

could authorize an estimated 3,100 to 3,500 acres of harvests on karsts along with roads. However, 

Forest Plan karst and cave management direction would be implemented so there should be no 

cumulative detrimental effect to karst and cave resources.

Baichtal and Swanston (1996) observed sediment deposits and waterline marks in underground systems 

that suggested that past timber harvesting had increased sediment and debris transport and flooding of 

underground passages, many of which had not previously flooded for centuries. These timber harvests 

were conducted prior to the Karst and Cave Resources Standards and Guidelines implemented in the 

1997 Forest Plan. As a result, they had more significant effects on karst lands than current and future 

harvest activities. At that time, many cave entrances were filled or blocked by logging slash, sediment, 

and debris. Additional runoff generated from road surfaces commonly had been diverted into karst 

features. They also noted strong evidence of greatly increased surface runoff on karst landscapes and 
Environment and Effects 3

Final EIS 3-153 Karst Lands

adjacent surfaces after timber harvest, which increased sediment, nutrient, and debris transport capability 

of associated drainage networks.

Most easily accessible, low-elevation karst areas on Prince of Wales Island have been harvested. After 

the initial timber harvests, harvest activities concentrated on steeper, higher elevation karst landscapes 

characterized by shallower, excessively well-drained soils. Baichtal and Swanston (1996) suggested that 

trees were smaller and regeneration problems were greater on these steep, upper elevation sites. This 

condition possibly resulted from shallow soils with low nutrient availability, excessive drainage of surface 

and soil waters into subsurface karst systems, removal of much of the shallow soil because of inadequate 

log suspension, and continued desiccation of the soil once the protective forest canopy was removed. 

After timber removal, high rainfall rapidly transported fragile soils into the well-developed epikarst.

More recent monitoring of karst lands near harvested areas (USDA Forest Service 2015a) have 

confirmed that current timber harvest practices have adjusted substantially to accommodate Karst and 

Cave Standards and Guidelines. For example, karst resource input was provided for timber sales projects 

throughout the Tongass.

Extensive landscape changes and ground disturbance have occurred and are likely to continue to occur 

on non-federal lands in Southeast Alaska. These include timber harvest and road construction, mining, 

recreation and tourism, growth of human settlements, transportation projects, and energy and 

transmission projects. Forest Service regulations requiring protection of karst resources do not apply to 

non-federal lands.

Transfers of karst lands from NFS lands to other land managers or private owners could also occur under 

any of the alternatives through land adjustments (such as the Alaska Mental Health Trust Land 

Exchange). This type of future action could increase the amount of karst lands in Southeast Alaska that 

are not in a protected LUD.

The Forest Service identified a need to amend the 2016 Forest Plan. The amendment focused on 

Standard S-YG-KC-02 related to commercial timber harvest on lands identified as moderate vulnerability 

karst to provide greater flexibility in managing harvests to protect the karst resource based on site-specific 

conditions. The standards and guidelines for young-growth harvest on karst was amended in August 

2020 to reduce the limitation on harvest.
Environment and Effects 3

Final EIS 3-154 Karst Lands

This page is intentionally left blank.
Environment and Effects 3

Final EIS 3-155 Sensitive and Invasive Plants

Sensitive and Invasive Plants

Affected Environment

Threatened, Endangered, Sensitive, and Rare Plants

Threatened and Endangered Plants

There are no federally listed or proposed threatened or endangered plants under the Endangered 

Species Act known to occur on the Tongass. The only federally listed or proposed plant in Alaska is the 

endangered Aleutian hollyfern (Polystichum aleuticum), which is only known to occur on Adak Island and 

is not expected to occur on the Tongass. A petition to list yellow-cedar (Callitropsis nootkatensis) was 

filed with the U.S. Fish and Wildlife Service (USFWS) on June 24, 2014. The petition was subsequently 

determined not warranted on October 7, 2019 (84 Fed. Reg. 53336).

Alaska Region Sensitive Plants

Sensitive plants are those plants identified by the Regional Forester for which population viability is a 

concern on NFS lands within the region. The objective of the Forest Service Sensitive Species Program 

(Forest Service Manual 2600 [USDA Forest Service 1991]) is to ensure that species numbers and 

population distributions are adequate so that no federal listing will be required and no extirpation will 

occur on NFS lands. The Alaska Region Sensitive Species list, updated in 2009 (Goldstein et al. 2009), 

includes 18 plants designated as sensitive, 14 of which are known to occur on the Tongass and an 

additional 2 that are not known but are suspected to occur. The 16 sensitive plants known or suspected to 

occur in the Tongass are listed in Table 3.6-1 along with habitat and occurrence information. Our 

understanding of sensitive and rare plant distribution across the Tongass is limited because of the 

enormous size of the Tongass coupled with the fact that most botanical surveys are focused within 

planning areas for specific projects.

Rare Plants

The 2016 Tongass Land and Resource Management Plan (Forest Plan) defines rare plants as:

“...those with potential conservation concerns on the Tongass National Forest. They may be 

common elsewhere; however, the edge of their range is known or suspected to be on the 

Tongass National Forest, or disjunct populations of the plant species occur on the Tongass 

National Forest.”

The Alaska Natural Heritage Program (AKNHP) maintains a list of plants that are rare in Alaska. The 

AKNHP Rare Vascular Plant List was most recently updated in 2013. This list contains 126 vascular 

plants documented to occur on the Tongass.

Under the 2016 Forest Plan, rare plants have similar protection in the Forest-wide standards and 

guidelines as sensitive plants. The AKNHP Rare Vascular Plant List is used as guidance for determining 

which rare plants may be evaluated in the project-level analysis. Generally, plants with a state ranking of 

S1 (critically imperiled in state) or S2 (imperiled in state) are given consideration during project analysis. 

Plants with a state ranking of S3-5 are sometimes given consideration if they are known to be rare in a 

specific location on the Forest.
Environment and Effects 3

Final EIS 3-156 Sensitive and Invasive Plants

Table 3.6-1

Alaska Region Sensitive Plants Known or Suspected to Occur on the Tongass National 

Forest

Common Name

(Scientific Name) Habitat and Occurrences on the Tongass National Forest2

Eschscholtz’s little nightmare 

(Aphragmus 

eschscholtzianus)

Grows in moist mossy areas, seeps, heaths, and scree slopes in subalpine and 

alpine areas. Suspected to occur in mountainous areas on the northern mainland of 

the Tongass, but has not been documented on the Tongass. 

Spatulate moonwort

(Botrychium spathulatum)

Habitat includes coastal forests, stabilized coastal dunes, upper beach meadows, 

well-drained open areas, alpine habitats, and riparian forests. In southeastern 

Alaska, populations are known from Kruzof Island (on lands managed by the State of 

Alaska) and one on Chichagof Island on the Tongass. 

Moosewort 

(Botrychium tunux)

Grows on upper beach meadows, coastal dunes, stream, terraces, river bars, and 

subalpine and alpine slopes. Ten known occurrences on the Tongass; 8 on the 

Yakutat Ranger District, 1 on the Wrangell Ranger District, and 1 in the Admiralty 

National Monument.

Giant moonwort 

(Botrychium yaaxudakeit)

Grows on upper beach meadows, beach dunes, coastal outwash plains, abandoned 

fields, and roadsides. Six known occurrences on the Tongass, one on the Hoonah

Ranger District, and five on beach meadows on the Yakutat Ranger District.

Macoun’s thistle 

(Cirsium edule var. macounii)

Grows in moist to dry open meadows, open forests in the upper montane to lower 

alpine zone, on scree slopes and talus slopes, and along glacial streams and 

lakeshores. Two known occurrences on the Tongass, both on the Ketchikan Misty 

Fjords Ranger District. 

Mountain lady’s slipper 

(Cypripedium montanum)

Habitat includes upper beach meadows, areas along the beach-forest ecotone, open 

forests, muskegs, and wet meadows. Known from one population on the Tongass, 

on the Wrangell Ranger District.

Large yellow lady’s slipper

(Cypripedium parviflorum var. 

pubescens)

On the Tongass, grows in peatlands on calcareous substrates. Two known 

occurrences on the Tongass, both on northern Prince of Wales Island. 

Calder’s lovage 

(Ligusticum calderi)

Habitat includes alpine and subalpine meadows, boggy slopes, open mixed conifer 

forests, and rocky areas. There are 24 known occurrences on the Tongass: 23 on 

the Craig Ranger District and one on the Thorne Bay Ranger District. 

Pale poppy

(Papaver alboroseum)

Grows in open, well-drained areas, in rocky tundra of ridges and mountain summits, 

ash and cinder slopes, and sand and gravel of glacial outwash and river floodplains. 

Occasional disturbance can create or maintain habitat, including by humans (e.g., 

stabilized road sides, railroad trackbeds) can create habitat. Not known from, but 

suspected to occur on, the Tongass.

Lesser round-leaved orchid

(Platanthera orbiculata)

Occurs in a variety of habitats including temperate, boreal, deciduous, and wetland 

forests. In Alaska, grows in low-elevation forested wetlands, medium to high volume 

old-growth hemlock forests with high bryophyte cover and red cedar, forest edges or 

near gaps in shady forests, near muskegs, open water, or boggy areas. This species 

is known from 285 occurrences on the Tongass, comprising 61 distinct populations.

Alaska rein orchid

(Platanthera unalascensis)

3

Habitat includes dry open sites, riparian areas, mesic meadows, drier areas in 

coniferous and mixed evergreen forests, and bogs and heath habitat from low to 

subalpine elevations. On the Tongass, generally grows in low-productivity forests at 

lower elevations in poorly drained soils. Known from 27 occurrences on the Tongass: 

2 on the Ketchikan Misty Fjords Ranger District, 6 on the Sitka Ranger District, and 

19 on the Thorne Bay Ranger District.

Kruckeberg’s swordfern 

(Polystichum kruckebergii)

Habitat includes ultramafic rock outcrops. Known from nine occurrences: five on the 

Ketchikan Misty Fjords Ranger District and four on the Sitka Ranger District.

Lichen, no common name 

(Ricasolia amplissima (Scop.) 

De Not. Subsp. Sheiyi Derr & 

Dillman)4

Grows on trunks and main branches of Sitka spruce, Pacific crab apple (Malus 

fusca), and western hemlock in old-growth beach fringe forest. There are 30 known 

occurrences on the Tongass: 6 on the Petersburg Ranger District, 9 on the Sitka 

Ranger District, 13 on the Thorne Bay Ranger District, and 2 on the Wrangell Ranger 

District.

Unalaska mist-maid

(Romanzoffia unalaschcensis)

Grows on ledges and crevices in rock outcrops and in gravelly areas along stream 

banks, often along coasts. Two known occurrences on the Tongass, both on the 

Thorne Bay Ranger District.
Environment and Effects 3

Final EIS 3-157 Sensitive and Invasive Plants

Table 3.6-1 (continued)

Alaska Region Sensitive Plants Known or Suspected to Occur on the Tongass National 

Forest1

Common Name (Scientific Name) Range and Habitat2

Henderson’s checkermallow 

(Sidalcea hendersonii)

Habitat includes wet meadows, estuaries, and tidal flats. On the Tongass, the 

one known population grows at the upper edge of an upper beach meadow 

near the edge of a hemlock and spruce forest. This population was located on 

the Juneau Ranger District; however, during surveys conducted in 2013 and 

2017, the occurrence was not located.

Dune tansy

Tanacetum camphoratum Less. 

(syn. = Tanacetum bipinnatum (L.) 

Sch. Bip. Pro parte)5

Habitat includes upper beaches, sand dunes, and well-drained and calcareous 

soils. Known from seven occurrences on the Tongass, all on the Sitka Ranger 

District.

1 Sensitive Plant list updated February 2009.

2 Habitat and occurrence information based on: AKNHP 2018; Dillman 2004, 2008, 2011; Douglas et al. 1999; eFloras 2018;

Goldstein et al. 2009; Nawrocki et al. 2013; USDA Forest Service 2012b, 2015e, 2019g. 3 New taxonomy: Nawrocki et al. 2017. 4 New taxonomy: Dillman et al. 2017; Cornejo et al. 2017 5 New taxonomy: Carlson and Fulkerson 2018.

Invasive Plants

Executive Order 13112 (1999) defines an “invasive species” as a species that is 1) non-native (or alien) to 

the habitat under consideration, and 2) whose purposeful or accidental introduction causes or is likely to 

cause economic or environmental harm or harm to human health. This Executive Order directs all federal 

agencies to address invasive species concerns and refrain from actions likely to increase invasive 

species problems.

Invasive plants can negatively affect habitat by competing with native plants for resources such as water

and light, establishing and changing the community composition, eliminating or reducing native plants, or 

changing the vegetation structure. The changes in community composition or vegetation structure can 

reduce native plant populations as well as negatively affect habitat for wildlife and fish. Compared to other 

states, Alaska has a low level of invasive plant infestations; however, invasive plant infestations within the 

state are increasing (Carlson and Shephard 2007; Nawrocki et al. 2011; Schrader and Hennon 2005).

Policy and guidance for managing invasive plants are provided by the Forest Service Manuals and 

Handbooks and Forest Service policy, including the Invasive Species Management Policy (Forest Service 

Manual [FSM] 2900), the National Strategic Framework for Invasive Species Management (USDA Forest 

Service 2013a), the Alaska Region Invasive Species Strategy (USDA Forest Service 2006), and the 

Tongass National Forest Invasive Plant Management Plan (Lerum and Krosse 2005). Additionally, the 

Tongass established an integrated weed management plan that includes manual and mechanical, as well 

as herbicidal, treatments of target invasive species on the Wrangell and Petersburg Ranger Districts 

(USDA Forest Service 2013b). FSM 2900 and Forest-wide standards and guidelines include direction to 

review proposed projects to determine the risk of introduction or spread of invasive plants and implement 

appropriate mitigation measures. They also include direction to control existing invasions and rehabilitate 

habitats impacted by invasive species.

Occurrences of invasive plants throughout Alaska are tracked by the Alaska Exotic Plants Information 

Clearinghouse (AKEPIC), a cooperative project between the Forest Service, State and Private Forestry, 

the National Park Service, U.S. Geological Survey, University of Alaska, and other federal, state, and 

local agencies. The AKEPIC database maintains a georeferenced inventory of Alaska’s invasive plants 

(AKEPIC 2018). Additionally, all invasive plant surveys, invasive plant finds, and treatments are entered 

into the Forest Service’s Natural Resource Information System (NRIS) georeferenced invasive species

database (USDA Forest Service 2018i). As of January 2019, 125 species of invasive plants have been 

documented on the Tongass. The Forest Service database (NRIS-INVP) and associated map provides an 

estimate of the extent of infestations, as well as the locations of invasive species observed. Table 3.7-3 of 

the 2016 Forest Plan Amendment EIS (USDA Forest Service 2016b) lists the invasive plants known on 

the Tongass, the number of observations of each species, and their invasiveness ranking. At the time of 
Environment and Effects 3

Final EIS 3-158 Sensitive and Invasive Plants

publication of the 2016 Forest Plan Amendment EIS, there were 23,386 documented observations of 124 

different invasive plant species on the Tongass. Currently, there are 24,257 known occurrences of 125 

invasive plant species known on the Tongass.

Environmental Consequences

This section compares effects of the six alternatives on sensitive, rare, and invasive plants. There would 

be no effects to threatened or endangered plants under any of the alternatives because none are known 

on the Tongass and changes to the Roadless rule are not the source of causation for any potential effects 

to threatened or endangered species.

The alternatives described in Chapter 2 differ in the locations and extent of land designated as roadless 

and the management categories designated for lands within roadless areas. None of the alternatives 

authorize any site-specific projects or other ground-disturbing activities; rather the alternatives describe 

exceptions under which certain activities might be allowed within roadless areas. Specific projects that 

include ground disturbance or timber harvest must undergo site-specific environmental analysis when 

they are proposed as required by the NEPA. Additionally, the activities must still comply with applicable 

standards and guidelines identified in Forest land management plans.

Activities allowed under the action alternatives would primarily affect productive old-growth and younggrowth forest habitats. Although there would be effects on unproductive forest, non-forest or other 

vegetation types, as roads are constructed through many types of habitat, these effects would be more 

limited since these vegetation types would not be the focus of any future timber harvest and associated 

road construction.

Indirect Effects

Sensitive and Rare Plants

Effects Common to All Alternatives

Effects of future timber harvest and road construction on sensitive or rare plants could include physical 

damage by cutting, trampling, or crushing them with vehicles, other machinery, foot traffic, or felled trees. 

Severe impacts may cause mortality or inhibit the vigor and reproductive capability of the plants.

Indirect effects to sensitive or rare plants from timber harvest or road construction and reconstruction 

involves alteration of habitat, such as changes in sunlight or hydrology, herbivore or pollinator behavior, 

soil structure and fertility, vegetation structure, fragmentation of habitat, and competition from other native 

plants as well as invasive plants. Some indirect effects, such as changes in sunlight or hydrology, can be 

beneficial or harmful depending on the effect and the species’ life history. Other activities likely to cause 

indirect effects to sensitive and rare plants include increased off-road vehicle use, increased access, and 

increased use and associated trampling by recreationists.

A BE is conducted as part of the site-specific environmental analysis for individual project proposals. This 

type of sensitive plant review is required to include sufficient detail to determine how any proposed action 

may affect each sensitive species. In addition, existing Forest-wide standards and guidelines would be 

applied to avoid or minimize impacts to those sensitive plants and their habitat.

As a part of a NEPA analysis, an effects analysis may also be conducted for rare plants; however, a 

formal BE is not required. All alternatives would continue to follow the current Forest-wide standards and 

guidelines for rare plants.

Effects Specific to Each Alternative

In general, alternatives that are less permissive of road construction would have less risk of adverse 

effects to sensitive and rare plants and alternatives more permissive of road construction would have 

more risk of adverse effects. New road construction would be similar under all alternatives because roads 

on the Tongass are largely developed in support of timber harvesting and the PTSQ under the 2016 

Forest Plan does not vary between the alternatives. Thus, the predicted 1,000 new road miles on NFS 

lands over 100 years for the No Action alternative (Table 3.3-21) would be similar for all alternatives, with 
Environment and Effects 3

Final EIS 3-159 Sensitive and Invasive Plants

minor variations. Under Alternatives 1 and 2, nearly 1,000 miles of new roads are estimated to be built on 

the Tongass over the next 100 years. Slightly more roads would likely be constructed under Alternative 3; 

however, the difference would likely be negligible. Alternatives 4, 5, and 6 are likely to result in the most 

road miles because they add the most remote suitable timber acres. However, the overall differences 

among alternatives in total new road miles are expected to be low because total harvest levels would 

remain the same among all alternatives.

Species-Specific Impacts to Sensitive and Rare Plants

Approximately 126 plants listed on the AKNHP Rare Vascular Plant List have been documented on the 

Tongass; because of the large number of rare plants, species-specific impacts to rare plants are not 

discussed in this document, but if, during project planning, they are known or suspected within the project 

area, they would be evaluated. Potential effects to the 16 sensitive plant species known or suspected to 

occur on the Tongass under each of the alternatives are discussed below.

As discussed above, 16 sensitive plant species are known or suspected to occur on the Tongass. Two of 

these 16 sensitive plant species, Escholtz’s little nightmare (Aphragmus escholtzianus) and pale poppy 

(Papaver alboroseum), are suspected, but not known to occur on the Tongass. Therefore, there is a very 

low risk that any of the alternatives would adversely impact these two sensitive species.

Potential impacts to the 14 sensitive plant species that have been documented on the Tongass can be 

estimated by looking at the proportion of known occurrences of each sensitive plant species in areas 

suitable for young-growth and old-growth timber harvest, and the percentage of harvest expected in each 

of these suitable areas under each alternative. Only four sensitive plant species have known occurrences 

expected to be within suitable young-growth or old-growth harvest areas over 100 years (Table 3.6-2). 

As shown in Table 3.6-2, no known occurrences of Macoun’s thistle (Cirsium edule var. macounii) or large 

yellow lady’s-slipper (Cypripedium parviflorum var. pubescens) are expected within old-growth harvest 

areas under any of the alternatives. The proportion of known occurrences of Alaska rein-orchid 

(Platanthera unalascensis) expected within old-growth harvest areas over 100 years includes 0.3 to 0.6 

occurrences under all alternatives. For lesser round-leaved orchid (Platanthera orbiculata), the proportion 

of known occurrences expected within old-growth harvest units is 7.4 to 11.3 over 100 years under all 

alternatives. However, differences may be explained by the variable level of effort expended searching for 

sensitive plants.

Within young-growth harvest areas, the proportion of known occurrences of Macoun’s thistle expected 

within harvest areas is 0.8 to 0.9 for all alternatives over 100 years. The proportion of known occurrences 

of large yellow lady’s-slipper and Alaska rein-orchid expected within young-growth harvest areas is 1.6 to 

1.7 under alternatives over 100 years. The proportion of known occurrences of lesser round-leaved orchid 

expected within young-growth harvest units is 27.0 to 28.9 under all alternatives over 100 years. 

Therefore, the differences among alternatives appear to be insignificant, and may be related to the 

variable effort expended in sensitive plant surveys in one area versus another. 

Under all alternatives, if previously undocumented populations of any sensitive plant species are located 

during project surveys, Forest-wide standards and guidelines under all alternatives would consider 

protection to minimize impacts to these species on the Tongass. For additional discussion of potential 

impacts to sensitive plant species from future timber harvest, road construction, and other development 

projects on the Tongass, see the 2016 Forest Plan Amendment EIS (USDA Forest Service 2016b). 

Additional details on the assessment of impacts to lesser round-leaved orchid are provided in the Plants

BE (Krosse 2016).
Environment and Effects 3

Final EIS 3-160 Sensitive and Invasive Plants

Table 3.6-2

Known Occurrences of Sensitive Plant Species within Estimated Old-Growth and YoungGrowth Harvest Areas over 100 Years by Alternative

Alternative Harvest Type

Species

Macoun’s 

thistle

(Cirsium edule 

var. macounii)

Large yellow lady’s 

slipper

(Cypripedium parviflorum

var. pubescens)

Lesser roundleaved orchid 

(Platanthera 

orbiculata))

Alaska reinorchid 

(Platanthera 

unalascensis)

1

Known Occurrences in 

Est. YG Harvest Areas 0.9 1.7 28.9 1.7

Known Occurrences in 

Est. OG Harvest Areas 0 0 13.4 0.7

2

Known Occurrences in 

Est. YG Harvest Areas 0.8 1.6 28.0 1.6

Known Occurrences in 

Est. OG Harvest Areas 0 0 13.1 0.6

3

Known Occurrences in 

Est. YG Harvest Areas 0.8 1.6 27.7 1.6

Known Occurrences in 

Est. OG Harvest Areas 0 0 10.7 0.5

4

Known Occurrences in 

Est. YG Harvest Areas 0.8 1.6 27.7 1.6

Known Occurrences in 

Est. OG Harvest Areas 0 0 9.3 0.4

5

Known Occurrences in 

Est. YG Harvest Areas 0.8 1.6 27.6 1.6

Known Occurrences in 

Est. OG Harvest Areas 0 0 9.1 0.4

6

Known Occurrences in 

Est. YG Harvest Areas 0.8 1.6 27.3 1.6

Known Occurrences in 

Est. OG Harvest Areas 0 0 9.1 0.4

OG = old growth; YG = young growth

Invasive Plants

Effects Common to All Alternatives

Ground disturbance associated with timber harvest, road construction, and other development or 

management activity on the Forest provides an opportunity for invasive plant introduction or expansion. 

Introduction and spread of invasive plants can occur because these activities disturb soil and/or remove 

existing vegetation, providing openings for invasive plants to establish or spread. Additionally, movement 

of equipment and personnel can also provide opportunities for transport of invasive plant seeds or 

propagules into new areas. Indirect effects can include the establishment or spread of invasive plants 

through the use of roads after harvest for recreation or during road maintenance. Similarly, construction 

and maintenance of energy and transmission line projects and associated road construction, 

maintenance, and use increases the risk of invasive species spread and colonization. The impacts of 

invasive plant spread and colonization can often spread beyond the area of disturbance.

Effects Specific to Each Alternative

The potential for the introduction and spread of invasive plant species due to ground disturbance 

associated with timber harvest, road construction, and other development or management activity exists 

under all alternatives. Increased disturbance increases the risk of establishment or spread of invasive 

plants. As discussed above, the volume of timber anticipated to be harvested and the miles of new roads 

anticipated to be constructed are not expected to be significantly different under the six alternatives. As a 

result, the alternatives are not expected to differ significantly in regard to their contributions to the 

introduction and spread of invasive species on the Tongass. Timber harvest and road construction in 
Environment and Effects 3

Final EIS 3-161 Sensitive and Invasive Plants

inventoried roadless areas, however, could potentially lead to the introduction and spread of invasive 

species where these species do not currently exist. Thus, Alternatives 1 and 2 would have little effect on 

the spread of invasive species, and Alternative 3 would only have a slightly larger effect. Alternatives 4, 5, 

and 6 would have the largest potential to result in the spread of invasive into currently roadless areas 

because they include the most suitable forest land in remote areas and would likely result in more road 

construction.

The number of documented occurrences of invasive plant species within suitable young-growth and oldgrowth stands is similar under all the alternatives. Additionally, none of the alternatives authorize any sitespecific projects or other ground-disturbing activities. Specific projects that include ground disturbance or 

timber harvest must undergo site-specific environmental analysis when they are proposed as required by 

NEPA, and the activities must still comply with applicable standards and guidelines identified in forest 

land management plans, including management of invasive species.

Cumulative Effects

Sensitive and Rare Plants

There are no federally listed or proposed threatened or endangered plants that are known to occur or are 

likely to occur on the Tongass; therefore, there would be no contribution to cumulative effects to 

threatened or endangered plants under any of the alternatives.

When considering effects to sensitive and rare plants, it is important to look at the cumulative effects of 

past, present, and reasonably foreseeable future activities on all land ownerships within the geographic 

area. The significance of any direct or indirect effect in contributing to the cumulative effects on sensitive 

and rare plants from management activities depend on the amount and type of disturbance in the 

cumulative effects analysis area and how that disturbance may affect known locations of sensitive and 

rare plants.

Past plus expected timber harvest, road construction, and implementation of other development projects 

on all land ownerships within the Forest boundary on all lands in Southeast Alaska can be used to 

compare the risk that each alternative would add to cumulative effects on both sensitive and rare plants. 

Therefore, all lands in Southeast Alaska constitute the cumulative effects analysis area for sensitive and 

rare plants. Appendix B provides a full list of all the projects considered in the cumulative effects analysis.

As stated above, overall timber harvest levels are not expected to vary significantly among the proposed 

alternatives. Therefore, the contribution of cumulative effects to sensitive or rare plants due to timber 

harvest and road construction would be similar for all alternatives. Other activities that have occurred in 

the past and are reasonably foreseeable to occur in the future that have the potential to add to cumulative 

effects to rare and sensitive plants include mineral extraction, energy and transmission line projects, 

hydroelectric projects, transportation developments, and urban and recreational site development 

(Appendix B). Each of the activities could include clearing vegetation and disturbing habitat for 

construction and maintenance; therefore, they have the potential to affect sensitive and rare plants and 

their habitat. These impacts would be considered in project analysis and an assessment of cumulative 

effects to sensitive and rare plants would also be done for individual projects as part of the NEPA process 

for the relevant analysis area. Timber harvesting on state, municipal, and private land is governed by the 

Alaska Forest Resources and Practices Act (AS 41.17). Alaska Forest Resources and Practices 

Regulations (ADNR 2013) do not address threatened, endangered, or rare plants; however, they do 

recommend minimizing road construction and limiting disturbance in marshes and muskegs, which would 

provide some protection for some of the sensitive and rare plants.

Changes in Alaska’s climate (discussed in the Climate and Carbon section of this chapter) could affect 

the hydrology and other habitat conditions where sensitive and rare plants occur. While the models do not 

fully agree on the climate change predictions for Southeast Alaska, they generally predict warmer 

weather with increased rainfall, and a decrease of snowfall. Recent research by Shanley et al. (2015) 

predicted an increase in mean annual temperature of approximately 3 to 10 degrees Fahrenheit, a 3 to 18 

percent increase in mean annual precipitation, and a 22 to 58 percent decrease in snowfall by the 2080s 

(Shanley et al. 2015). These changes would likely result in lower soil moisture due to increased 
Environment and Effects 3

Final EIS 3-162 Sensitive and Invasive Plants

evaporation during warmer summer months. Also, a precipitation shift from snow to rain could lead to 

more water running off the landscape rather than being stored as snow and feeding streams and 

wetlands in the late spring and summer, thus increasing evaporation and reducing water storage. These 

factors could lead to drier streams, meadows, and wetlands.

Changes in temperature and hydrologic conditions would likely favor some plants and stress others. 

There has been little research into the effects of changes in environmental conditions for each of the 

sensitive and rare species; consequently, there is uncertainty as to the effect of changes in the climate on 

sensitive and rare plant species known or suspected to occur on the Tongass.

Invasive Plants 

Invasive plants on any land ownership in Southeast Alaska can affect establishment or spread of invasive 

plants on NFS lands and vice versa. As mentioned in the direct and indirect effects, activities can have 

wider effects on invasive plant spread than the specific area of land disturbance due to the 

interconnectedness of land. The cumulative effects of invasive plants from management activities would 

depend on factors such as the following:

Amount and location of ground disturbance;

Existence and extent of invasive plants at the time of project implementation;

Overall habitat alteration due to invasive plants expected as a result of past, present, and foreseeable 

projects; and

Anticipated response of invasive plants to the proposed actions and any management considerations 

or mitigation and monitoring that will be applied to each project.

Past, present, and future timber harvest, road construction, and other development activities on both 

private and public lands can be used to compare the risk of cumulative effects of the six alternatives on 

invasive plant introduction or spread. As stated above, overall timber harvest levels are not expected to 

vary significantly among the alternatives. Therefore, the contribution of cumulative effects to invasive 

plants due to timber harvest and road construction would be similar for all alternatives (road miles vary 

less by about 50 miles between alternatives over 100 years; see Table 3.3-21). 

As discussed under cumulative effects for sensitive and rare plants, there are fewer restrictions on timber 

activities on non-NFS lands than on NFS lands. Timber activities on non-NFS lands that can contribute to 

the introduction or spread of invasive plants are not specifically regulated by the State of Alaska. Other 

activities that have occurred and are reasonably foreseeable to occur in the future that have the potential 

to add to cumulative effects of invasive plants include mineral activities, renewable energy and 

transmission line projects, hydroelectric projects, transportation developments, and urban and 

recreational site development (Appendix B). Each of these activities can include clearing vegetation, 

construction, transportation for construction and ongoing activities, and maintenance. Therefore, they 

have the potential to introduce or spread invasive plants in an area and would need to be considered in 

the project analysis.

Changes in Southeast Alaska’s climate (discussed in the Climate and Carbon section of this chapter) 

could also create the conditions that encourage the spread of invasive plants by altering opportunities for 

invasive plants to colonize new areas, where could be compounded by climate change. Changing climate 

may also result in range extensions for some species that are native at more southerly latitudes, and they 

may become established or become more widespread on the Tongass, as a result. Changes in growing 

conditions would likely favor some plant species and stress others. There is uncertainty about the effect 

of changes in climate on invasive plants on the Tongass.

With any of the action alternatives, applying mitigation measures in the form of Forest-wide standards and 

guidelines as well as ongoing invasive plant control and management programs will contribute to 

lessening the cumulative effects of invasive plants across Southeast Alaska. For additional discussion of 

Forest-wide standards and guidelines and mitigation measures used by the Forest Service for prevention 

and control of invasive plants during implementation of management actions, see the 2016 Forest Plan 

Amendment EIS (USDA Forest Service 2016b).
Environment and Effects 3

Final EIS 3-163 Transportation, Energy, Communications,

and Infrastructure

Transportation, Energy, Communications, and Infrastructure

Affected Environment

Transportation

Residents of the region are dependent on air and water transportation for travel between most 

communities, rather than roads or rail. A roaded transportation system has developed on NFS lands, 

largely in support of timber harvesting, but for the most part does not connect communities except on 

Prince of Wales Island. 

Regional Transportation System

The Alaska Department of Transportation & Public Facilities (ADOT&PF) issued the comprehensive 

Southeast Alaska Transportation Plan (SATP) in 2004 (ADOT&PF 2004). The 2004 SATP called for 

transitioning away from the long-distance ferry runs to a system that connects the communities of 

Southeast Alaska with roads and relies on shuttle ferries to fill the gaps in the road network. The 2004 

SATP identified 34 essential highway and utility corridors and requested they be reserved and 

incorporated into the Forest Plan. A Draft SATP was published in June 2014 (ADOT&PF 2014) that 

includes the same 34 essential corridors.

In recent years, ADOT&PF completed about 30 miles of highway construction in furtherance of the SATP 

goals. An additional 140 miles of highways are funded for design and construction in the SATP corridors, 

and a portion of those projects were scheduled to move to the construction phase in the 2019 and 2020 

construction seasons. There are also 16 miles of highway funded for environmental permitting and design 

in the SATP corridors, without current appropriations for construction activities. The multiple highway 

projects will deliver improved transportation of goods and services through Southeast Alaska and will 

ease the development of connecting utilities in the region.

Because the ADOT&PF’s Southcoast Region lies largely within the Tongass National Forest’s boundaries, 

many of the proposed road projects cross NFS lands and require Forest Service authorization. The 

proposed linkages for the East Lynn Canal Highway (Juneau Access Improvement Project), the Kake to 

Petersburg road, and the Sitka to Warm Spring Bay road are examples of projects that would cross NFS 

land.

In August 2005, Congress enacted Section 4407 of the Safe, Accountable, Flexible, Efficient 

Transportation Equity Act - A Legacy for Users (SAFETEA-LU; Public Law 109-59), which states: 

“Notwithstanding any other provision of law, the reciprocal rights-of-way and easements identified on the 

map numbered 92337 and dated June 15, 2005, are hereby enacted into law.” In 2015, the President 

signed into law Public Law 114-94, Fixing America’s Surface Transportation Act. This law amended 

Section 4407 of SAFETEA-LU by striking “hereby enacted into law” and inserting “granted” affecting 

about 25 transportation and utility corridors to connect communities and providing marine access to 

Forest Service lands over State-managed lands.

National Forest System Roads

NFS roads are constructed to provide access to NFS lands and are included in the Forest Development 

Transportation Plan (see Transportation Standards and Guidelines in Chapter 4 of the 2016 Forest Plan 

Amendment EIS [USDA Forest Service 2016a]). Most NFS roads are unpaved, single-lane roads.

On the Tongass, the demand for roads has historically been for access to timber resources. The 

maintenance and reconstruction requirements of the existing system depend mainly on the volume of 

timber hauled and, to a lesser extent, on recreational use. The need for future road development is 

largely determined by the need to access timber resources. There are approximately 4,900 miles of roads 

on Tongass NFS lands, including both opened and closed system roads (3,600 miles) and non-system or 

decommissioned roads (1,300 miles) (see Table 3.3-21). Of the 3,700 miles of classified Tongass NFS 
Environment and Effects 3

Final EIS 3-164 Transportation, Energy, Communications,

and Infrastructure

roads, over 80 percent are not open to use or not maintained for highway vehicles. There are another 

4,300 miles of roads that are on non-NFS lands.

All timber harvest requires some road construction and maintenance and repair. If the planned harvest 

area is roaded, often the case for timber harvest which comprises solely regenerated timber stands, then 

most of the activity expected is road maintenance and repair. Otherwise, road construction is the primary 

activity.

Log Transfer Facilities

The transport of harvested timber from Southeast Alaska requires both land and water routes to reach 

processing facilities. Log transfer facilities (LTFs) are used to transfer logs to barges or rafts for towing. 

Over 100 LTFs exist on the Tongass. A Memorandum of Understanding (MOU) provided a framework for 

the State to grant the Forest Service tideland easements to use the 126 LTFs on state lands listed on 

Map 92337. There are currently over 60 LTFs with active permits.

Transportation Systems in the Forest Plan

The 2016 Forest Plan applies the Transportation Systems Corridors Direction to existing and future 

transportation system corridors such as the those considered under the SATP and applicable laws (i.e., 

Section 4407 of Public Law 109-59; Alaska National Interest Lands Conservation Act of 1980 [ANILCA] 

Title XI, Public Law 96-487).

Within IRAs, the Roadless Rule generally prohibits construction or reconstruction of roads with some 

exceptions. The Forest Service may authorize a road in an IRA if they determine it meets certain criteria 

(see Chapter 2).

Energy

Twenty-two operating hydroelectric projects are located either on NFS lands or on adjacent state or 

private land. These projects have a total installed capacityof 216.9 megawatts (MW) and range in size 

from less than 1 MW to 78 MW insize. Most hydropower sites are licensed by the Federal Energy 

Regulatory Commission under the Federal Power Act.

The existing transmission system in Southeast Alaska is limited. The electric systems in a few 

communities are currently interconnected. These may be summarized by region, as follows:

Southeast Alaska Power Agency (SEAPA) Region—The SEAPA system connects Ketchikan, 

Petersburg, and Wrangell.

Juneau Area—The Alaska Electric Light & Power system connects Juneau, Douglas Island, Auke 

Bay, and Greens Creek Mine.

Prince of Wales Island—The Alaska Power & Telephone (AP&T) system connects Coffman Cove, 

Craig, Hollis, Hydaburg, Kasaan, Klawock, and Thorne Bay.

Upper Lynn Canal Region—A separate AP&T system connects Haines and Skagway in the Upper 

Lynn Canal Region and is connected via an intertie to the existing Inside Passage Electrical 

Cooperative) system that serves Klukwan and Chilkat Valley.

Kake to Petersburg Intertie (approved but not constructed) — In 2016, the Forest Service issued a 

Record of Decision approving the construction of a transmission line connecting Kake and 

Petersburg.

Inventoried Roadless Areas

Currently, there are five proposed or unconstructed renewable energy projects in IRAs (see Table 3.7-1). 

In addition, proposed transmission lines serving as power interties among Southeast Alaska communities, 

including the line between Kake and Petersburg, would also cross IRAs.
Environment and Effects 3

Final EIS 3-165 Transportation, Energy, Communications,

and Infrastructure

Table 3.7-1

Proposed or Unconstructed Renewable Energy Projects in IRAs

Name

Ranger 

District Power Destination IRA

Sweetheart Lake Juneau Juneau 302

Crooked Creek/Jim’s Lake Hoonah Elfin Cove 311

Little Port Walter Sitka Little Port Walter Marine Station 334

Bell Island Geothermal1 KMF Swan-Tyee Intertie 529

Mahoney Lake2 KMF Swan-Tyee Intertie 524

1 See Minerals section for geothermal discussion. 2 Federal Energy Regulatory Commission licensed in 1998, unconstructed.

Hydroelectric projects are not prohibited in IRAs28 on the Tongass. The Federal Power Act (FPA) grants 

the Federal Energy Regulatory Commission (FERC) the authority to issue and administer licenses for

hydropower projects. For projects located on NFS lands, Section 4(e) of the FPA requires FERC to 

determine whether the project is consistent with National Forest purposes and the land management 

plan. Section 4(e) also gives the Forest Service authority to impose mandatory conditions in the FERC 

license to ensure the adequate protection and use of NFS land and resources.

The Roadless Rule does not prohibit the construction or maintenance of transmission lines that do not 

require road construction or reconstruction. Temporary or permanent roads are not permitted in IRAs, 

with exceptions, though temporary linear construction zones can be authorized. The restriction on road 

building, including construction access roads, may pose a challenge for routes that cross IRAs, potentially 

increasing construction and maintenance costs. As of January 2018, 10 hydropower or intertie projects 

have been approved in IRAs in the Alaska Region, including the 2016 approval of the Kake to Petersburg

intertie.

Communication Sites 

Appendix E of the 2016 Forest Plan (USDA Forest Service 2016a) lists approved communication sites on 

the Tongass (Table E-1). Sites approved for telecommunication facilities are characterized by antennas, 

electronic transmitters, equipment shelters, and a wide variety of electronic communication support 

equipment such as those listed in Forest Service Handbook 2709.11, Chapter 90.

Proposals for new communications uses on the Tongass will be encouraged to co-locate on an approved 

communications site, unless the proponent demonstrates that communication sites approved in the Forest 

Plan are not technically feasible due to geographic location or are incompatible with the requested use.

Communication and infrastructure are not prohibited in IRAs.

Environmental Consequences

The 2016 Forest Plan provides Forest-wide direction for Renewable Energy and for Transportation 

Systems Corridors and other activities, which allows greater flexibility in development including renewable 

energy development to help Southeast Alaska communities reduce fossil fuel energy dependence. 

Energy project development and regional transportation development are possible under all alternatives 

with limitations that vary by alternative. Although these projects can be permitted under Alternative 1, 

there is likely to be improvement for project development under each of the action alternatives because of 

the broadening of the rule language regarding access for the construction, expansion, or maintenance of

facilities.

28 In reinstating the Roadless Rule on the Tongass, the Alaska District Court’s judgement in Organized Village of Kake, et al., v. USDA, 

et al. clarified that “nothing in this judgement shall be construed to prohibit any person or entity from seeking, or the USDA from 

approving, otherwise lawful road construction, road reconstruction, or the cutting or removal of timber for hydroelectric development 

pursuant to the standards and procedures set forth in the Federal Power Act.”
Environment and Effects 3

Final EIS 3-166 Transportation, Energy, Communications,

and Infrastructure

The following discussions address the indirect and cumulative effects of the alternatives on the 

transportation and other infrastructure of Southeast Alaska. Direct effects would result from on-the-ground 

activities that could occur in or outside of roadless areas under the Forest Plan and would be evaluated 

when they are proposed.

Transportation Effects

National Forest System Roads

The amount of new road construction would be similar under all alternatives because roads on the 

Tongass are largely developed in support of timber harvesting and the PTSQ under the 2016 Forest Plan 

does not vary between the alternatives. Thus, the predicted 1,000 new road miles on NFS lands over 100 

years for the No Action alternative would be similar for all alternatives, with minor variations (about 49

miles difference; Table 3.3-21). Because the locations of future harvests and associated roadbuilding are 

unknown, a qualitative discussion of the predicted difference is used here.

There are about 5,100 miles of system and non-system roads on NFS lands (Table 3.3-21). Over the next 

100 years, an estimated additional 1,000 miles of new roads would be constructed under all alternatives, 

totaling about 6,100 miles of roads over 100 years. This would be an increase of about 21 percent over 

existing conditions. In addition to new construction, some roads would be constructed or reconstructed 

over decommissioned roadbeds. Reconstruction involves the rehabilitation of the original roadbed, and 

can include cleaning ditches, replacing drainage structures, re-installing bridges, and grading and 

shaping. The estimated 500 miles of roads constructed over decommissioned roadbeds and 1,100 miles 

of road reconstruction over 100 years would occur under all alternatives.

Alternatives 1 and 2 would have roughly the same amount of road miles because additional timber 

harvest opportunities would be provided through the removal of roadless area designation within roadless 

areas that generally have roads (known as roaded roadless). In roaded areas, most of the activity 

expected is road maintenance and repair.

Alternative 3 is expected to result in slightly more new road miles than Alternatives 1 and 2 because 

additional timber harvest opportunities may be provided through extending areas removed from roadless 

designation to forest lands adjacent to existing road systems in addition to the roaded roadless areas. 

Thus, some new roads may be constructed to access these adjacent areas, and road maintenance and 

repair would occur within previously roaded areas.

Alternatives 4, 5 and 6 would be similar and have the potential for slightly more road miles than 

Alternative 3 because they would allow harvests and roadbuilding in areas farther from existing road 

systems. However, the economics of building roads to access forest land farther from the forest 

transportation system would be a limiting factor for new road construction.

Most roads developed for timber harvest would be closed to motorized traffic once their initial use is over. 

These roads are built for silvicultural purposes under exemptions granted under Section 404(f)(1) of the 

Clean Water Act. Roads constructed and maintained specifically for recreation or other uses do not 

qualify under this exemption (USACE 2004).

The effects of operations at LTFs are likely to be same under all alternatives because the PTSQ does not 

vary between the alternatives. Guidelines for LTF siting, construction and operation, and monitoring are 

provided in Appendix G of the 2016 Forest Plan.

Regardless, the decision on this Alaska Roadless Rulemaking would not result in any direct on-theground effects. Future Forest Service activities that would result in road building, maintenance, or 

removal would be subject to additional project-level NEPA analysis.
Environment and Effects 3

Final EIS 3-167 Transportation, Energy, Communications,

and Infrastructure

Effects on Regional Transportation Opportunities

Alternative 1

Transportation Systems Corridor plan components under the Forest Plan would apply to major road 

systems such as state and federal highways, railroads, and those identified by the State of Alaska in the 

current version of the SATP and applicable laws (for example, Section 4407 of Public Law 109-59, as 

amended, Title XI of ANILCA, Public Law 96-487).

The 2001 Roadless Rule provides an exception to allow construction, reconstruction, or realignment of a 

Federal Aid Highway to occur in IRAs and pursuant to reserved or outstanding rights, or as provided by 

statute or treaty. However, the exception provided for Federal Aid Highway projects applies only when no 

other reasonable or prudent alternative exists, which limits its applicability. Additionally, regional 

transportation projects may be funded by the State and would also fall outside of this exception.

Action Alternatives

Each of the action alternatives would add or remove areas or roadless designations to varying degrees 

(Table 2-12) that would affect where and for what purpose roads could be developed. Generally, roads 

would be prohibited in ARAs unless they met the one of the exceptions listed in Table 2-2. The 

exceptions vary by ARAs. Watershed Priority ARAs (Alternatives 2 and 3) are the most restrictive to road 

building. Timber Priority ARAs (Alternative 4) place no prohibition on permanent or temporary roads, and 

Community Priority ARAs allow more exceptions than Alternative 1. LUD II and Roadless Priority ARAs 

fall in the middle.

The effect to the potential for development of regional transportation systems within each ARA is 

discussed below.

All ARAs

Exceptions are provided for Federal Aid Highway projects roads and roads authorization pursuant to 

reserved or outstanding rights, or as provided for by statute or treaty, among others. See Table 2-2. 

Additional exceptions are applied according to the ARA designations.

Watershed Priority (Alternatives 2 and 3)

With the exception of the authorities provided for all ARAs, roads may not be constructed or 

reconstructed in an Alaska Roadless Area designated as Watershed Priority. Watershed Priority ARAs 

would be more restrictive on regional transportation routes than Roadless, Timber, or Community Use 

Priority designated ARAs because there is no exception for State highways, utility systems, or for 

accessing facilities such as airports, marine access points, and communication sites.

LUD II Priority (Alternatives 2, 4, and 5)

Within LUD II Priority ARAs roads may be constructed or reconstructed if consistent with the legislated 

management restrictions established in Section 201 of the Tongass Timber Reform Act.

Roadless Priority (Alternatives 2, 3, 4, and 5)

In addition to the exceptions provided for all ARAs, roads would be permissible for State of Alaska’s 

SATP projects for the connection of communities and development of the regional transportation system, 

and for facilities and utility systems (Table 2-2 for complete list).

Timber Priority (Alternative 4 only)

Timber Priority ARAs would not prohibit road building and would make the process to develop regional 

transportation systems less restrictive. 

Community Priority (Alternative 3 only)

In addition to the exceptions provided for all ARAs, roads would be permissible for public facilities and 

utility systems (Table 2-2 for complete list). Like Watershed Priority ARAs, there is no exception for State 

highways.
Environment and Effects 3

Final EIS 3-168 Transportation, Energy, Communications,

and Infrastructure

Alternative 2

Alternative 2 includes Watershed, LUD II, and Roadless Priority ARAs. With 3.28 million acres (1.1 million 

acres of development LUDs) of Watershed Priority ARAs, Alternative 2 would be more restrictive on 

regional transportation opportunities than Alternative 1 within Watershed Priority ARAs because there is 

no exception for State SATP routes (though Federal Highway and roads authorized by other laws would 

still be permissible). However, the exceptions for regional road systems would be increased in LUD II 

(854,000 acres) and Roadless Priority ARAs (5.21 million acres) compared to the 2011 Roadless Rule.

The 2004 SATP (ADOT&PF 2004) identified 34 essential highway and utility corridors distributed 

throughout Southeast Alaska and the Forest. Roadless areas exist along many of these routes and, 

under Alternative 2, several of the crossed roadless areas would be designated as Watershed Priority

ARAs, which do not include the exception for State roads included in the LUD II and Roadless Priority

ARA. However, most of these routes were granted by Congress in 2005 (Public Law 109-59). Routes 

identified in the 2004 SATP that were not granted by Public Law 109-59 that could be prohibited in 

Watershed Priority ARAs include:

A route on the east side of Eastern Passage (SATP Map 13); Portions of the Kuiu Island Corridor 

(SATP Map 19);

A route on the Cleveland Peninsula north of Ketchikan (SATP Map 23);

A portion of the route on Chichagof Island between Pelican and Tenakee Inlet (SATP Map 17); and

A beachfront segment along Clarence Strait southeast of Coffman Cove (SATP Map 14).

Alternative 3

Alternative 3 includes 8.2 million acres of Watershed Priority, Community Priority, and Roadless Priority

ARAs. Like Alternative 2, Alternative 3 would include 3.26 million acres (1.1 million acres of development 

LUDs) of Watershed Priority ARAs and would be more restrictive than Alternative 1 on regional 

transportation opportunities in these areas. However, the exceptions for regional road systems would be 

increased in Roadless Priority ARAs (4.6 million acres) compared to the 2011 Roadless Rule. By 

decreasing roadless areas by 1.25 million acres, Alternative 3 would be more permissive to road building 

than Alternatives 1 and 2 (although 847,000 acres of this would be in LUD II areas).

Like Alternative 2, opportunities for development of regional transportation systems that were not granted 

by Congress (Public Law 109-59) could be prohibited within Watershed Priority ARAs. Additionally, while 

Community Priority ARAs provide more exceptions for road building, including Federal Aid Highway 

projects, there is no exception for State highways.

Alternative 4

Alternative 4 includes about 9 million acres of LUD II, Roadless, and Timber Priority ARAs. Alternative 4 

would be more permissive to road building than Alternatives 1 and 2 because it decreases roadless area 

acres by about 343,000 million acres and designates about 749,000 acres as Timber Priority ARAs. 

Together, the area removed from roadless designation and the area of Timber Priority ARAs would be 

about 1.1 million acres, similar to Alternative 3. Road-building restrictions imposed by the Roadless Rule 

within development LUDs would be removed from these 1.1 million acres. Of the remaining 8.2 million 

acres of ARAs in Alternative 4, 7.4 million acres would be designated as Roadless Priority, and the 

remaining 854,000 acres would be designated as LUD II Priority.

Alternative 5

Alternative 5 includes 7.0 million acres of ARAs and would be more permissive to road building than 

Alternatives 1 through 4 because it decreases roadless area acres by about 2.3 million acres. All 

remaining ARAs would be Roadless Priority, which provide more exceptions for regional road systems 

compared to the 2001 Roadless Rule, or LUD II Priority. A total of 6.2 million acres would be Roadless 

Priority ARAs and 0.85 million acres would be LUD II Priority. The remaining Roadless and LUD II Priority 

ARAs would have more exceptions for road systems compared to the 2001 Roadless Rule.
Environment and Effects 3

Final EIS 3-169 Transportation, Energy, Communications,

and Infrastructure

Alternative 6

Alternative 6 would be the most permissive to road systems because it would remove all 9.3 million acres 

of roadless areas.

Energy and Infrastructure Effects

Five proposed hydropower projects are located in IRAs. Other hydropower projects and other types of 

energy projects could be developed in the future. Potential impacts to roadless areas would be addressed 

during the permitting and licensing of these projects, with most requiring NEPA analysis and oversight by 

the Federal Energy Regulatory Commission. Potential impacts would be mitigated, but some impacts, like 

the presence of a road or facilities in a roadless area, would be unavoidable.

No significant adverse consequences related to energy projects and related infrastructure are anticipated 

for any of the alternatives. Removing roadless designations in areas under Alternatives 2 through 6 would 

simplify the process for projects but would not necessarily result in an increase in the number of projects 

developed. If new roadless areas are added or expanded, the permitting process could be more 

burdensome, but projects would not be prohibited. An exception for utility systems in Roadless Priority

ARAs under Alternatives 2, 3, 4, and 5 and Community Priority under Alternative 3 would allow for timber 

harvest and road construction. Under Alternative 4, lands within the Timber Priority ARA would not 

prohibit timber harvest or road construction at all. If roadless areas are removed, or exceptions for utility 

systems added, the greatest effect may be in making the permitting process for developers less 

burdensome and with less regulatory uncertainty, resulting in a quicker permitting process and potentially 

lower costs, rather than an increase in the number of projects developed. Additionally, exceptions for road 

building for the construction, expansion, or maintenance of utility systems would improve long-term 

access to utility infrastructure for operations and maintenance. Thus, operation and maintenance costs 

could be reduced and service reliability improved.

Under all alternatives, energy projects would need to be consistent with the Forest Plan (particularly 

Chapter 5). Existing and proposed renewable energy projects are widely distributed across the Forest, 

with five proposed renewable energy projects in roadless areas (Table 3.7-2). This would reduce the 

cumulative effects of these activities on any specific roadless area. Overall, none of the alternatives would 

likely have additional adverse effects to roadless areas relative to current conditions.

Management and administration would remain the same in all the action alternatives. For projects located 

on NFS lands, Section 4(e) of the FPA requires FERC to determine that the license will not be 

inconsistent with National Forest purposes. The Forest Service will continue to use Section 4(e) to impose 

mandatory conditions in the FERC license to ensure the adequate protection and use of NFS land and 

resources. Non-FERC projects would continue to be administered through issuance of a special use 

authorization, with specified conditions and in accordance with other federal and state permits and/or 

permissions, to allow construction and operation of projects.

Table 3.7-2 

Alaska Roadless Area Priorities at Proposed or Unconstructed Renewable 

Energy Projects in IRAs1

Name

Roadless 

Area

Action Alternatives

2 3 4 5 6

Sweetheart Lake 302 W W R R Rv

Crooked Creek/Jim’s Lake 311 R R R R Rv

Little Port Walter 334 R R R R Rv

Bell Island Geothermal2 529 W W R R Rv

Mahoney Lake 524 R R R R Rv 1 R = Roadless Priority; W = Watershed Priority; Rv = Removed 2 See Minerals section for geothermal discussion.

Communications and infrastructure projects that do not require tree cutting or road construction / 

reconstruction are not prohibited in IRAs, nor would they be in ARAs. Added exceptions for energy 
Environment and Effects 3

Final EIS 3-170 Transportation, Energy, Communications,

and Infrastructure

infrastructure and essential facilities in Roadless Priority and Community Use Priority ARAs, and to a 

lesser extent LUD II Priority ARAs would facilitate development of projects such as transmission lines, 

airports, marine access points, and communication sites.

Cumulative Effects

The road construction projected for non-NFS lands primarily includes roads needed for timber harvest, 

but also includes roads that may be built to serve or connect communities. Road corridors covered by 

Public Law 109-59 would, if developed, connect additional areas in Southeast Alaska to the continental 

highway system, and improve transportation between communities.

There is considerable uncertainty concerning the future development of Southeast Alaska’s road system. 

As stated above, the ADOT&PF has prepared a Draft SATP and is delivering transportation projects 

under that plan. However, new roads linking communities and linking Southeast Alaska to the continental 

highway system are expensive to build and maintain.

If new wood-processing facilities and markets are not developed, especially for young-growth products, 

the levels of harvest predicted in the 2016 Forest Plan Amendment EIS (USDA Forest Service 2016b) are 

unlikely to occur, and new road construction would be less than anticipated. There is also uncertainty 

concerning the funds to maintain the existing NFS road network, to place existing roads into storage 

status, and to decommission roads that are no longer needed. Risks associated with inadequate funding 

include adverse effects to fish, water quality, and wildlife and increased safety hazards as older roads and 

stream crossings deteriorate.
Environment and Effects 3

Final EIS 3-171 Timber Resources

Timber Resources

Affected Environment

Introduction

The forests of Southeast Alaska are primarily the western hemlock-Sitka spruce forest type. This forest 

type is part of the temperate rain forest that occupies a coastal strip 2,000 miles long from northern 

California to Southcentral Alaska. While western hemlock and Sitka spruce comprise the majority of the 

stocking in this forest type, associated species include, depending on location, yellow-cedar, western 

redcedar, mountain hemlock, and silver fir (Harris and Johnson 1983). Other forest lands support 

relatively small stands dominated by yellow-cedar, lodgepole pine (shore pine), red alder, or black 

cottonwood. Western hemlock is used for pilings, poles, railway ties, windowsills, doors, and construction 

lumber, and has been an important fiber source for pulp. Sitka spruce is used for lumber and commodity 

products, as well as specialty products, such as piano sounding boards, guitar faces, oars, planking, 

masts, and spars for custom-made or traditional boats, and ladders. For centuries Alaska Natives have 

used cedar species for canoes and paddles, housing (along with Sitka spruce), and totem poles. Today, 

redcedar is primarily used as a roofing material and yellow-cedar has many uses, including boats, utility 

poles, heavy flooring, framing, and marine decking and piling.

The forests of Southeast Alaska are the major source of raw materials for the region’s wood products 

industry. Generally, timber harvested on NFS lands is available for processing by the local wood products 

industry but most timber harvested on non-NFS lands is exported. Due to economic conditions in recent 

years, the exporting of timber from NFS lands has been allowed under certain circumstances. The wood 

products industry and associated regional employment is discussed in more detail in the Key Issue 2 

section of this document.

Current Condition of the Forest Land Base

Approximately 56 percent of the forest land on the Tongass (approximately 5.5 million acres) is classified 

as productive forest land; these lands are considered biologically capable of producing industrial wood 

products. Approximately 0.5 million acres of the productive forest lands on the Tongass have been 

converted to young-growth forest due to harvest or other disturbances such as fire or wind. This is 

approximately 5 percent of the total forest land base and 10 percent of the productive forest lands and 

represents approximately 15 billion board feet of harvested timber.

In addition to productive forest lands, the Tongass includes approximately 4.4 million acres of 

unproductive forest. These are lands that are not capable of producing industrial forest products, but are 

important for watershed protection, wildlife habitat, recreation, and other uses. Unproductive forest is land 

incapable of yielding crops of industrial wood, usually because of adverse site conditions. These 

conditions may include sterile or poorly drained soil, subalpine conditions, and steep rocky areas where 

landslides or avalanches curtail timber development.

Currently, the forest land suitable for timber production covers approximately 564,000 mapped acres 

(230,000 old growth and 334,000 young growth). Following field verification, the suitable acreage is 

expected to amount to approximately 474,000 acres. This is based on the level of falldown assumed in 

the 2016 Forest Plan. Falldown is the reduction in suitable acreage that occurs when a project is 

implemented and taken from the paper plan stage to an actual field-based plan. It is mostly due to finding 

new streams, over steepened slopes, difficult to log areas, muskegs, etc., within areas that were mapped 

as suitable.

Current Condition of the Timber Resource

Age Class Distribution. The Tongass is a mix of old-growth stands and naturally regenerated younggrowth forest, which consists of both wind-created and harvest-created young growth. Harvest-created 

young growth amounts to approximately 5 percent of the total forest land area. Suitable forest lands are 

classified into five stand conditions: 1) old-growth sawtimber, 2) young-growth sawtimber, 3) pole timber, 
Environment and Effects 3

Final EIS 3-172 Timber Resources

4) seedling and sapling, and 5) non-stocked. For timber inventory purposes, stands of trees 150 years old 

or older are designated as old growth. Over 85 percent of productive forest lands meet the criteria for oldgrowth sawtimber (USDA Forest Service 2016b). Forests less than 150 years (harvest and natural) cover 

approximately 0.5 million acres; forests that are 150 years of age or older cover over 5 million acres.

Approximately 46 percent of the area harvested over the past century is no longer suitable, due to 

Congressional designations such as Wilderness, State and Native land selections, or Forest Plan LUD

allocations. For example, areas designated as Wilderness or LUD II by Congress are no longer suitable.

Approximately 80 percent of harvested young growth stands on the Tongass are less than 55 years of 

age and about 10 percent of young-growth stands are 56 to 65 years of age. Because stands on the 

Tongass need to be about 65 years old or older to have a chance of being economic to harvest, less than 

10 percent of the Tongass harvested young-growth stands are currently in this category.

Volume Strata

The Forest currently uses three volume strata to categorize commercial timber: high, medium, and low 

volume. Average volumes for each category vary with geographic area on the Tongass. In terms of net 

sawlog volume, the high-volume stratum averages about 25 to 33 thousand board feet (MBF) per acre, 

medium volume averages about 18 to 28 MBF per acre, and low volume averages about 5 to 15 MBF per 

acre, depending on geographic area (USDA Forest Service 2016b, Table 3.13-4).

While the three-strata approach is useful for estimating timber volume for forest planning purposes, it is 

not a good tool for identifying other important forest elements, including forest structure, biological 

diversity, and wildlife habitat. For example, two stands may have the same volume, but one may be a 

dense stand of medium-sized trees with a single canopy layer, while the other stand may be a 

combination of widely-spaced large overstory trees and two or three lower canopy layers containing 

small- and medium-sized trees. To help account for these differences, the Size Density Model (SDM), 

which is based on a combination of tree sizes and tree densities (Caouette et al. 2001), has proven to be 

a better tool for representing these other forest elements. Using tree sizes and densities provides a more 

comprehensive forest measuring system for describing habitat than timber volume (Spies and Franklin 

1991). The SDM (Caouette and DeGayner 2005) is described and used in the Biological Diversity and 

other sections.

Non-National Forest System Lands

The State of Alaska, Native village corporations, Sealaska (the Native regional corporation), and 

individuals own over 1,186,000 acres of land in Southeast Alaska, inside the Forest boundary. 

Approximately 364,000 acres of this land currently consists of productive old-growth forest and 422,000 

acres consists of young growth. This means that approximately 54 percent of the original productive old 

growth on non-NFS lands has been harvested (based on geographic information system analysis and 

information provided by the landowners; USDA Forest Service 2016b). Most timber harvested from 

Department of Natural Resources state lands in recent years has been processed locally, while timber 

harvested from University Trust and Mental Health Trust lands has been exported.

Current Practices

Young-Growth Management

Managing young-growth forests in Southeast Alaska will become an increasingly important component of 

forest management on the Tongass in the next decade. Young-growth stands can be treated through 

thinning and other intermediate treatments to concentrate growth in fewer, larger trees, improve lumber 

quality, and/or to enhance habitat conditions for wildlife. Zaborske et al. (2000) concluded that the types 

of treatments applied to young stands will have a profound effect on the types of materials available in the 

future, including log diameter, knot size, and wood strength.
Environment and Effects 3

Final EIS 3-173 Timber Resources

Public Law 113-291 specifies that the Tongass may harvest trees prior to 95 percent of culmination of 

mean annual increment (CMAI) to facilitate the transition away from commercial timber harvest of oldgrowth stands, given certain acreage and time limitations.

Over 200,000 acres have been precommercially thinned on the Tongass since 1979. In recent years, 

precommercial thinning has averaged approximately 5,600 acres per year. The Forest has less 

experience with other young-growth management techniques, such as pruning and commercial thinning.

There has been increased interest in commercial thinning in recent years, not only to improve timber 

values, but as a tool to improve wildlife habitat. Studies in other forest types in the Pacific Northwest 

indicate that stand structures that are similar to old-growth forest conditions can be developed through 

thinning (Thysell and Carey 2000). However, there are many unanswered questions as to how to 

implement thinning treatments that provide a sustainable source of high-value wood products while 

maintaining biological diversity (Zaborske et al. 2000). In a study comparing the lumber harvested from 

thinned and unthinned, 90-year-old stands on the Tongass, Christensen et al. (2002) found that there was 

no difference in volume recovery or lumber grade in thinned and unthinned Sitka spruce. For western 

hemlock, the unthinned stands produced more wood volume, but the thinned stands produced more highgrade lumber. The Prince of Wales Commercial Thinning Study was awarded as an Integrated Resource 

Service Contract at the end of Fiscal Year 2008. This study looks at five different commercial thinning 

prescriptions that offer a range of potential treatments that could be used on the Tongass. The five 

different prescriptions were implemented at three replicates: near Harris River, in the Maybeso 

Experimental Forest, and near Naukati. The objectives of the study are to assess how mechanized 

equipment operates, how the different prescriptions hold up to Southeast Alaska’s weather, and what the 

understory response is after treatment. A 5-year re-measurement of the sites was completed in 2014.

There is also increased interest in managing young-growth stands to increase and maintain understory 

vegetation, especially as forage for deer and other wildlife. Hanley et al. (2005) noted that much research 

is needed on new approaches involving thinning of older stands, including red alder in the secondary 

successional sequence. Zaborske et al. (2002) found that thinning greatly increased forage production, 

though the amount of useful forage produced varied by the type of thinning implemented.

In addition to their continuing research on managing young forests, scientists at the Pacific Northwest 

Research Station joined with the Tongass in 2001 to establish an operational-scale adaptive 

management study of young-growth management options. This program, called the Tongass-wide 

Young-Growth Studies (TWYGS), is designed to evaluate the potential benefits of treating young-growth 

stands to increase wildlife habitat and wood production. Currently, TWYGS includes experiments that test 

the effectiveness of alder interplanting, precommercial thinning, slash treatments, girdling and pruning.

Regeneration Methods and Reforestation

Regeneration methods are the harvest methods used to create a new age class within a stand. The 

methods used on the Forest are not expected to differ when applied to old-growth or young-growth 

stands. A description of the primary methods is provided in the Timber section of the 2016 Forest Plan 

Amendment EIS (USDA Forest Service 2016b). They cover even-aged, two-aged, and uneven-aged 

systems.

The National Forest Management Act (NFMA) requires assurance that all areas receiving final removal 

harvest can be adequately restocked with trees within 5 years of that harvest. On the Tongass, natural 

restocking is usually adequate to meet this objective because both western hemlock and Sitka spruce are 

prolific seed producers (USDA Forest Service 1983). The new stand originates from advance 

regeneration and from seeds that come from residual trees or from trees adjacent to the harvest unit.

Species Composition

Of the four major commercial tree species on the Tongass, western hemlock is the most shade tolerant, 

followed by western redcedar, yellow-cedar, and Sitka spruce, in that order (USDA Forest Service 1990). 

Western hemlock is by far the most prevalent species, making up 83 percent of the old-growth forests 

(Farr and McClellan 1994). Western hemlock has the lowest economic value of these four species. 
Environment and Effects 3

Final EIS 3-174 Timber Resources

Having a diverse species mix contributes to wildlife habitat quality, economic value, and minimizes losses 

due to insects and diseases that are species-specific.

Regeneration harvest methods that create open conditions and expose bare mineral soil, such as 

clearcutting, would encourage germination and growth of Sitka spruce and the cedars. Group selection 

with openings of at least 2 acres could also encourage germination and growth of Sitka spruce and the 

cedars, but to a lesser degree than clearcutting due to side shading. The amount of sun reaching the 

surface would vary depending on the size, shape, and aspect of the opening. Regeneration methods that 

create less ground disturbance and smaller openings in the canopy such as single tree selection, smaller 

sized groups in group selection, overstory removals, and treatments with many reserve trees would 

encourage growth of western hemlock at the expense of the other species. However, limited retrospective 

studies indicate that Sitka spruce can be maintained in mixed hemlock-Sitka spruce stands over a wide 

range of cutting intensities if enough Sitka spruce trees are present in the stand after harvest (McClellan 

2005). Two-aged harvest would be similar to even-aged harvest if leave trees are concentrated near the 

unit boundaries but may be more favorable for western hemlock regeneration if reserve trees are 

scattered through the unit, due to shading from the residual overstory.

Forest Health

Insects, diseases, related decay processes, and windthrow are an integral and natural part of forest 

ecosystems. Many of these appear to play key roles in gap-level disturbance (see discussion of oldgrowth forests in the Biological Diversity section of this chapter) and in providing wildlife habitat. The 

majority of the forests on the Tongass are old-growth forests. Losses to the timber resource caused by 

heart rot in live trees are considerable in old-growth forests. Approximately one-third of the volume of the 

old-growth hemlock-spruce forests in Southeast Alaska is decayed by heart rot fungi (USDA Forest 

Service and ADNR 2014).

In addition to heart rot, some of the more common destructive insects, diseases, and conditions within 

Southeast Alaska are the black-headed budworm (Acleris gloverana), hemlock sawfly (Neodiprion 

tsugae), hemlock dwarf mistletoe, (Arceuthobium tsugense) and other decays, Alaska yellow-cedar 

decline, and windthrow.

Decline and mortality of yellow-cedar continues to be one of the most widespread and important forest 

problems in Southeast Alaska. This decline is associated with wet, poorly drained sites, and recent 

research has demonstrated that no organism is the primary cause of the decline (Hennon and Shaw 

1997). As the climate continues to warm, cedar decline is likely to continue to spread, especially in the 

south and east. Conversely, yellow-cedar appears to be spreading northward as climate warms, into 

areas that retain snow longer into the spring.

Windthrow is the dominant disturbance agent in Southeast Alaska. Two forms occur: small-scale events 

(gap disturbance) and large-scale events (catastrophic disturbance). Most of the Forest is subject to 

small-scale windthrow events. Individual trees or small groups of trees blow over during storm events, 

opening gaps in the canopy that allow young trees to grow to fill the openings. This results in complex, 

mixed-aged stands. Disease and decay agents also play a role in this process. Small-scale events occur 

on a regular basis and result in openings from 6 to 13 percent on the canopy (Nowacki and Kramer 

1998). Areas not protected by topographic barriers from the severe effects of infrequent, major storms are 

subject to large-scale windthrow events that cause catastrophic damage. Entire stands have been blown 

down in the past, resulting in the regeneration of more even-aged stands with more uniform canopies 

(Nowacki and Kramer 1998). Both forms of windthrow are a part of the natural forest generation, growth, 

and development. Juday et al. (1998) rated many potential impacts on the coastal forests of Southeast 

Alaska due to climate change. They concluded that there was a high risk of increased large-scale 

blowdown across Southeast Alaska as well as increased windthrow around harvest units.

Environmental Consequences

The analysis of the potential effects of the alternatives addresses the following questions:

How much land would be allocated to timber production?
Environment and Effects 3

Final EIS 3-175 Timber Resources

What would be the future condition of the Forest in 100 years?

The analysis of timber supply and demand for timber products, as well as how existing sales under 

contract and timber volume in preparation may be affected by the alternatives is discussed in the Key 

Issue 2 section of this EIS. The effects on the timber industry infrastructure and employment levels are 

also discussed in that section.

Suitable Timber Lands

Most importantly, the Tongass has initiated a formal transition from predominantly old-growth harvest to 

predominantly young-growth harvest. The 2016 Forest Plan prescribes an average of 46 MMBF per year 

while transitioning to predominantly young growth harvest after about 16 years. See a more complete 

discussion of the market demand, the young-growth transition strategy, and the export policy in the Key 

Issue 2 section of this EIS.

There are approximately 5.5 million acres of productive forest land on the Tongass. Approximately 

1,000,000 acres were mapped as suitable for timber production under the 2008 Forest Plan (which 

included roadless areas). Under the 2016 Forest Plan (which excluded roadless), approximately 564,000 

acres (230,000 acres of old growth and 334,000 acres of young growth) were mapped as suitable for 

timber production. In this EIS, the amount of suitable land would vary by alternative for both young growth 

and old growth (Table 3.8-1) (see Maps 7-12 on the thumb drive and website, which show suitable by 

alternative).

Table 3.8-1

Mapped Suitable Acreage of Old-Growth and Young-Growth under Each Alternative 

(thousands of acres)1

Classification

Alternative

1 2 3 4 5 6

Suitable Forest Land

Mapped Suitable Old Growth 230 247 305 388 395 395

Mapped Suitable Young Growth 334 344 348 349 351 354

Total Estimated Suitable Old Growth 564 592 653 736 746 749

1 Sums and differences may not appear exact due to rounding.

Mapped suitable old-growth acreage would range from 230,000 acres under Alternative 1 to 395,000 

acres under Alternatives 5 and 6, which is a 72 percent increase relative to Alternative 1. Mapped suitable 

young-growth acreage is relatively consistent among alternatives, however, ranging from 334,000 to 

354,000 acres, only a 5 percent increase. The vast majority of suitable young growth is already suitable in 

Alternative 1. An exception is the roaded roadless areas, which are designated as roadless but include 

10,000 acres of suitable young growth along with their access roads. These roaded roadless areas are 

incorporated into Alternative 2 and the other action alternatives.

Projected Timber Harvest

The PTSQ of each of the alternatives is an indicator of possible future timber supply level that each 

alternative would produce. PTSQ is the estimated quantity of timber meeting applicable utilization 

standards that is expected to be sold during the plan period.

The PTSQ for the Tongass under the 2016 Forest Plan, based on an annual average, is 46 MMBF in the 

initial years (about 15 or more years). The projection is 34.5 MMBF from old growth and 11.5 from young 

growth for the first decade. Full transition is expected about Year 16 with 41 MMBF of young growth and 

5 MMBF of old growth. After that, young growth harvest is permitted to grow, but old growth harvest must 

remain at 5 MMBF per year.

All alternatives would have the same PTSQ. There would be no change in young-growth or old-growth 

harvest. Aside from the changes in suitable timber land acres, none of the alternatives include any 

changes to the 2016 Forest Plan, so the only changes are the removal of the roadless designation 

overlay.
Environment and Effects 3

Final EIS 3-176 Timber Resources

The main effect of the alternatives on timber would be the ability to develop economic sales. Although no 

additional harvest would take place, the expansion of suitable areas means that greater area is available 

for the development of sales, allowing more choices for the development of economic ones. Therefore, 

the resultant effect would be the same harvest spread out over a larger area. Alternative 2 would add 

suitable acres from the roaded roadless areas, which, because of their existing infrastructure and 

connection to the existing road systems should include some of the most economic areas. Alternative 3 

would result in even more added suitable acres in areas where roads already exist, in areas where roads 

could be logically extended within the same watershed, and in Community Priority ARAs and, therefore, 

are also generally considered relatively economic to harvest. Alternatives 4, 5, and 6 would result in a 

greater increase in harvest in remote areas; however, a number of factors would limit this increase. First, 

remote areas almost entirely consist of old growth, so once transition starts resulting in a greater 

proportion of young growth in the harvest in 10 to 15 years, there is little reason to move away from 

existing roads. Second, current economic conditions suggest that economic sale requirements may limit 

the level of entry into remote areas, at least for the next 5 or 10 years. This suggests that while 

Alternatives 2 and 3 may result in improvements in sale economics because they open up areas that 

appear likely to be more economic due to accessibility, the additional expansion produced by Alternatives 

4, 5, and 6 may not produce further improvements in economic sales.

Cumulative Effects

In 1954, there were approximately 6.3 million acres of productive forest land on all ownerships inside the 

Tongass Forest boundary (including Annette Island). The amount of forest land in Southeast Alaska that 

is available for timber management has declined over the past century, largely due to Wilderness and 

LUD II designation by Congress, land selections by the State and ANSCA, land restricted by roadless 

designations, and land allocated to non-development LUDs in the current Forest Plan. This, along with 

mill closures and changes in timber markets, has contributed to a decline in timber harvest. Harvest on all 

lands in Southeast Alaska peaked from the late 1960s through the early 1990s and has been in decline 

since then. Total harvest on federal, state, and private lands declined from just under 1,000 MMBF in 

1989 to less than 80 MMBF in 2017. Approximately 722,000 acres of productive forest land have been 

harvested since 1954 in this portion of Southeast Alaska; approximately 64 percent of this is NFS land 

and 36 percent is on Alaska Native corporation, state, and other lands (USDA Forest Service 2016b).

Currently, there are between 0.56 and 0.75 million acres of NFS lands considered suitable for timber 

management on the Tongass, depending on the alternative. In addition, approximately 0.5 million acres of 

state, Alaska Native corporation, and other private lands are available for harvest. Potential annual 

harvest on state and private land is estimated to be approximately 90 MMBF (Daniels et al. 2016). Based 

on past experience, most of the harvest on private land would be exported and would not contribute to 

meeting local demand. Using this estimate, cumulative harvest in Southeast Alaska would be about 136 

MMBF for the next decade, increasing slowly in succeeding decades, and would be the same for all 

alternatives. Table 3.8-2 displays the cumulative harvest under the alternatives.

Table 3.8-2

Maximum Estimated Average Annual Timber Harvest in Southeast 

Alaska during the Next Decade (MMBF)

Alternative National Forest1 State and Private2 Total

1 46 90 136

2 46 90 136

3 46 90 136

4 46 90 136

5 46 90 136

6 46 90 136

1 PTSQ in the current Forest Plan 2 70 MMBF/year from Native corporation lands and 20 MMBF/year from state land (Daniels 2015). Most 

harvest on private land is exported.

MMBF = million board feet; PTSQ = projected timber sale quantity
Environment and Effects 3

Final EIS 3-177 Minerals

Minerals

Affected Environment

Mineral deposit types and mineral resource occurrences were described thoroughly in the 2016 and 2008 

Forest Plan Amendment Environmental Impact Statements (EIS; USDA Forest Service 2016b, 2008b) 

and the 1997 Forest Plan EIS (USDA Forest Service 1997a).

With respect to National Forest management, mineral resources are divided into three groups: locatable 

minerals, leasable minerals, and salable minerals. The Forest Service manages mineral resource 

programs that are specific to each group of minerals.

The Forest Plan, as amended, allocates about 249,570 acres of the Forest to the Minerals LUD. The 

intent of the Minerals LUD is to encourage exploration and development of locatable minerals in areas of 

high mineral potential, while taking other resource values into account.

Locatable Minerals

Locatable minerals are those minerals that may be located and removed from Federal lands under the 

authority of the General Mining Law of 1872, as amended. Examples of some locatable minerals on the 

Tongass are gold, silver, copper, molybdenum, iron, nickel, lead, and zinc. The General Mining Law of 

1872, as amended, grants every United States citizen the right to prospect and explore public domain 

lands open to mineral entry. The right of reasonable access is guaranteed and is not at the discretion of 

the Forest Service.

The Forest Service works with mining claimants and operators to provide reasonable access to their 

claims, minimize adverse environmental impacts on surface resources, and ensure reasonable 

reclamation of disturbed lands affected by mining operations. Protection of surface resources is 

accomplished by reviewing the mining plan of operations submitted by the claimant, disclosing impacts of 

the proposed mining operations in a project-specific environmental analysis, approving only those 

activities that are reasonably incident to the proposed operation, monitoring operations to ensure 

environmental standards are met, and ensuring prompt and reasonable reclamation of disturbed areas.

By law, designated Wilderness, National Monuments, Research Natural Areas, Enacted Municipal 

Watersheds, and Wild Rivers (when designated by Congress) are withdrawn from mining claim location, 

subject to valid existing rights.

On the Tongass, Modified Landscape, Scenic Viewshed, Recreational Rivers, Timber Production, and 

Minerals LUDs are open to mineral entry. The Primitive Recreation, Semi-Remote Recreation, Old-growth 

Habitat, Experimental Forest, Special Interest Areas, Scenic Rivers, and LUD II LUDs remain open to 

mining activities; however, special stipulations and more stringent mitigation measures may be required 

for mining activities in these LUDs. Similarly, roadless areas within any of these LUDs are open to mineral 

entry.

Leasable Minerals

Certain types of minerals, primarily energy resources (e.g., oil, gas, coal, and geothermal resources), are 

not subject to mining claim location but are available for exploration and development under provisions of 

the Mineral Leasing Act of 1920 and other mineral leasing laws. Access to these types of minerals is 

provided through leases, permits, or licenses that include fee and/or royalty payment conditions. The 

authority to manage these minerals is presently administered by the U.S. Department of Interior, Bureau 

of Land Management (BLM) in cooperation with the Forest Service. National Monuments, Wilderness

Areas, and Wild Rivers are withdrawn from mineral leasing.

No leasable minerals are presently being produced on the Tongass, nor have they been since at least the 

1997 Forest Plan, and the anticipated demand is expected to remain low. There are three existing 

geothermal leases on Bell Island but they have not been developed. Previous assessments have

indicated a potential for oil and gas occurrence in the Yakutat region (BLM 2006; URS Corporation 2006); 
Environment and Effects 3

Final EIS 3-178 Minerals

however, the resource development potential is considered low. Outside of the Yakutat area, oil and gas 

occurrence potential elsewhere in the Tongass is considered low to none. Coal is found at several 

locations in Southeast Alaska; however, the development of these resources is considered uneconomic, 

other than possibly for local use, and exploration or development activity is unlikely.

Geothermal resources occur in 19 known locations in Southeast Alaska.Thermal springs in several 

locations have been developed for small-scale commercial uses such as tourism, aquaculture, community 

bathhouses, and district heating of buildings (URS Corporation 2006). There has been some recent 

interest in geothermal resources in the Bell Island area, but no projects are currently under consideration 

by the Forest Service. In 2012, the Forest Service issued a consent determination on the Bell Island lease 

application areas being made available for leasing and the adjacent mainland (USDA Forest Service 

2012c). Of note, the consent determination included restrictions on new road construction or 

reconstruction (Roadless Area Stipulation) on any leases within NFS Inventoried Roadless Areas (IRAs).

While the occurrence potential for geothermal resources is considered high in several locations and some 

exploration could occur, geothermal development activity is not anticipated in the near future.

Salable Minerals

Salable, or “common variety,” minerals are sold rather than located or leased. These minerals include 

petrified wood and common varieties of sand, rock, building stone, gravel, pumice, clay, and other similar 

materials. Crushed rock is the most common saleable mineral extracted on the Tongass and is often 

used to construct roads. The supply of quality rock sources is largely dependent upon the locations of 

active logging operations.

Mineral Resource Inventory and Development Potential

The 2008 Forest Plan Amendment provides a summary of Mineral Resource Inventory and Development 

potential on the Tongass including identified mineral resources and undiscovered resources. There has 

been no update to mineral inventories since that time.

Mineral Resource Demand

The extent to which identified and undiscovered mineral resources on the Tongass will be developed in 

the future depends largely upon the level of demand for those resources. Demand for mineral resources 

can be inferred based on the amount of money spent by the mining industry to prospect and explore for 

mineral resources in Southeast Alaska. Between 1982 and 1987, the mineral industry spent an average 

of $2.92 million per year on mineral exploration in Southeast Alaska, with a high of $5.85 million in 1987 

(USDA Forest Service 1997a). Exploration expenditures increased drastically for the 1988 to 1991 period, 

when the industry spent more than $20 million each year. Expenditures generally declined for the next 10

years, reaching $1.6 million in 2001, before increasing again to a level of $9.9 million in 2006 (Alaska 

Department of Natural Resources [ADNR], Alaska’s Mineral Industry annual reports and summaries for 

1997 to 2005). Annual exploration expenditures remained high between 2007 and 2013, averaging $20 

million with a high of $34.3 million in 2011. Recently, statewide exploration spending increased 

significantly to $120.8 million in 2017, doubling 2016 exploration spending (Athey and Werdon 2018), but 

exploration spending for Southeast Alaska alone was not provided.

Environmental Consequences

Indirect Effects

None of the alternatives propose any changes to the Forest Plan relating to minerals management. 

Operators will continue to submit plans of operation to the Forest Service for approval, and regulations 

under which those operating plans are processed will not change by alternative. Identified and 

undiscovered mineral resource tracts, characteristics and location of mineral deposits, and Southeast 

Alaska geology will not vary as a result of implementing any of the alternatives.
Environment and Effects 3

Final EIS 3-179 Minerals

Locatable Minerals

Under any alternative, future exploration and development (except for valid, currently existing rights) 

would be precluded in areas withdrawn from mineral entry, such as Wilderness.

Future exploration, mining, and mineral processing activities would continue to occur in ARAs where 

valuable deposits exist. When necessary, construction or reconstruction of roads for locatable mineral 

exploration or development is part of the reasonable right of access provided under the General Mining 

Law. Therefore, none of the alternatives would affect rights of reasonable access to prospect and explore 

lands open to mineral entry and to develop valid claims.

All proposals for locatable mineral exploration or development are subject to the planning and design 

requirements governing locatable minerals in 36 CFR 228, subpart A, and the appropriate level of 

environmental analysis. The plan of operations would be approved subject to modifications identified in 

the environmental analysis and would be binding on the operator.

Under Alternative 5, roadless areas would be removed from areas with the highest potential for locatable 

mineral development (areas within the Forest Plan Minerals LUD). The minerals overlay LUD aims to 

encourage the prospecting, exploration, development, mining, and processing of locatable minerals in 

these areas. These areas would also be removed from roadless under Alternative 6, the full exemption 

alternative.

Leasable Minerals

The effects of any mineral leasing activity would be analyzed at the appropriate future time if the Forest 

Service receives specific requests for access to leasable minerals.

Alternative 1

The Tongass has three active geothermal leases but the anticipated demand for leasable minerals is 

generally expected to remain low. The Forest Service is aware of some level of interest in leasable 

minerals in specific areas of the Tongass; however, there are no active leasable projects nor have there 

been since at least the 1997 Forest Plan. Consistent with the current Forest Plan, any mineral leasing 

activity would need to be consistent with the standards and guidelines for the respective LUDs affected by 

the leasable mineral activity. The Forest Service currently prohibits roadbuilding for any new leasable 

projects, including geothermal projects, within IRAs. Although the road building is prohibited, these 

projects may include the incidental cutting, sale, and/or removal of trees.

Alternatives 2, 3, 4, and 5

Roadless areas would be added and removed under Alternatives 2, 3, 4, and 5 (see Chapter 2, Table 2-

12). The Forest Service currently prohibits roadbuilding for any new leasable projects, including 

geothermal, within IRAs. This prohibition would continue in newly designated ARAs except within the 

Timber Priority ARA. Following project-specific analyses, roads could be approved for leasable projects 

within Timber Priority (Alternative 4) ARA. If the geothermal project was developed as a public utility 

system, roads would be permissible under the exceptions provided for in Roadless Priority (Alternatives 2, 

3, 4, and 5) and Community Use Priority (Alternative 3) designated ARAs.

Regarding the Bell Island geothermal site, the island would retain its roadless designation under each of 

these alternatives. It would be designated a Roadless Priority ARA under Alternatives 4, and 5, which 

would allow roads under the provided exceptions if the geothermal project was developed as a 

community utility system. It would be designated a Watershed Priority ARA under Alternatives 2 and 3, 

which would not allow for road building associated with leasable projects. 

The effects of any geothermal or other leasable project would be analyzed at the appropriate future time if 

the Forest Service receives specific requests for such projects.
Environment and Effects 3

Final EIS 3-180 Minerals

Alternative 6

Under Alternative 6, there would be no areas under a roadless designation. Consistent with the current 

Forest Plan, any mineral leasing activity would need to be consistent with the standards and guidelines 

for the respective LUDs affected by the leasable mineral activity.

Salable Minerals

The predominant use of salable minerals is to construct roads in support of the Tongass transportation 

system. Since road construction is not expected to vary much between alternatives, there would be little 

difference in salable mineral development between the alternatives.

Cumulative Effects

Under all alternatives, the right to prospect and explore public domain lands open to locatable mineral 

entry are preserved. Existing mineral projects are expected to continue and new projects are expected to 

be explored and developed. The effects of any mineral activity operating under the standards and 

guidelines of the Forest Plan would be evaluated at the time appropriate future time if the Forest Service 

receives specific requests for such projects.

In September 2018, the Forest Service published two separate Advance Notices of Proposed Rulemaking 

in the FR as first steps to update the agency’s regulations that address surface activities associated with 

exploration and development of locatable minerals, and to update regulations that address leasing and 

subsequent development of oil and gas resources. Revision of the regulations governing both locatable 

minerals and oil and gas resources should help achieve more efficient permitting processes, which in turn 

reduces regulatory burdens.
Environment and Effects 3

Final EIS 3-181 Recreation and Tourism

Recreation and Tourism

Affected Environment

Southeast Alaska possesses a remarkable and unique combination of features including inland 

waterways with over 11,000 miles of shoreline, mountains, fjords, glaciers, and large fish and wildlife 

populations that provide opportunities for a wide range of outdoor recreation experiences. Many Alaska 

residents purposefully live in proximity to such settings as a part of their lifestyle. Most visitors who travel 

to see Alaska expect to find it in a wild and unspoiled state, but also expect comfort and convenience, 

reliable transportation, and other features requiring some level of infrastructure and development. The 

challenge for recreation managers is to identify and understand the relationship between the settings and 

the variety of groups seeking to recreate on or near the Tongass. Commercial providers of recreation 

activities base much of their marketing strategy on particular environmental settings and identified 

recreation places within those settings.

The Tongass includes approximately 16.7 million acres of land available for recreation. This land 

contributes to the feeling of vastness and solitude that dominates the region; however, much of the land is 

not heavily used for outdoor recreation. Difficult and steep terrain, wetlands, icefields, glaciers, and heavy 

vegetation confine most recreation activities to accessible shorelines, river and stream bottoms, and 

around the many lakes within the Forest. Extensive use is made of some of the icefields and alpine areas 

(above tree line), but access to these areas is usually by aircraft. Both residents and visitors use 

developed campground and picnic areas, beaches, trails, cabins, shelters, and visitor centers that are 

located near communities. An inventory of developed recreation sites on the Tongass is presented in 

Table 3.10-1.

Table 3.10-1

Tongass Recreation Facilities, 2015

Type of Facility Number

Anchor Buoys 42

Boating Sites 7

Campgrounds 15

 - Number of Sites 220

Camping Areas 7

Day Use Areas 10

Picnic Sites 33

Group Picnic Sites 2

Hotel, Lodge, Resort 2

Interpretive Site 3

Interpretive Visitor Centers 3

Lookout/Cabin 147

Shelters 39

Observation Site 2

Swimming Site 2

Trailheads 120

Trails (number of miles):

 – Nonwilderness 876

 – Wilderness 92

 – Total Trail Miles 969

Wildlife Viewing Sites 10

The National Park Service (NPS) and the State of Alaska also provide recreation opportunities in 

Southeast Alaska. The NPS manages 3.3 million acres in three park units, with the majority of this land 
Environment and Effects 3

Final EIS 3-182 Recreation and Tourism

located within the Glacier Bay National Park and Preserve. Alaska State Parks manages about 80,000 

acres and 34 park units, including 16 marine parks, in Southeast Alaska. In addition, the Alaska Department of 

Fish and Game (ADF&G) manages two state wildlife refuges, two critical habitat areas, and one wildlife 

sanctuary, and the Alaska Division of Forestry manages the 247,000-acre Haines State Forest.

Community road systems are limited and used for access to recreation sites and attractions near local 

communities. Existing road systems are primarily located near the communities of Juneau, Sitka, 

Ketchikan, Petersburg, and Wrangell. There is also an extensive road system connecting the 

communities on Prince of Wales Island, as well as road systems near the communities of Hoonah and 

Kake. There is no interconnecting highway system between islands or between communities on the 

mainland.

Roads exist in other locations where timber harvest has taken place. Residents, as well as independent 

visitors from elsewhere, often use road systems that are accessible from the Alaska Marine Highway 

System ferries or from local communities for recreational purposes. Roads in locations where there are no 

communities or interconnecting ferry access receive relatively low levels of recreation use. However, 

recreation-related vehicle use has been growing on certain remote islands, including Kruzof, Zarembo, 

and Etolin Islands, and isolated systems on Kuiu and Kupreanof Islands. While the total amount of 

recreation use on these islands is low, it can be heavy at times, such as during hunting season.

Supply of Recreation Opportunities

Recreation Opportunity Spectrum

The 2016 Forest Plan (USDA Forest Service 2016a) uses the ROS to help identify, quantify, and describe 

the range of recreation settings provided by the Forest. The ROS system portrays the combination of 

activities, settings, and experience expectations along a continuum that ranges from highly modified to 

primitive environments. The following seven classifications are identified along this continuum from most 

to least developed:

Primitive (P)

Semi-Primitive Non-Motorized (SPNM)

Semi-Primitive Motorized (SPM)

Roaded Natural (RN)

Roaded Modified (RM)

Rural (R) and Urban (U)

The setting indicators and applicable standards and guidelines for the seven ROS classes are described 

in Appendix I to the 2016 Forest Plan (USDA Forest Service 2016a). These classes and associated 

indicators may be used in recreation planning and project analysis to describe the current condition 

across the landscape (ROS inventory) and assess the potential effects of the alternatives on recreation 

settings. Viewed in terms of acres, the Primitive (P) ROS setting is the largest on the Tongass, with 

approximately 62 percent of the forest (10.4 million acres) allocated to this setting (Table 3.10-2). SPNM 

accounts for a further 18 percent (3.1 million acres), followed by RM (10 percent) and SPM (9 percent) 

(Table 3.10-2).
Environment and Effects 3

Final EIS 3-183 Recreation and Tourism

Table 3.10-2

Forest-wide Recreation Opportunity Spectrum Acres

ROS Class Acres Percent of ROS Total

Primitive (P) 10,357,832 62

Semi-Primitive Non-Motorized (SPNM) 3,052,410 18

Semi-Primitive Motorized (SPM) 1,458,528 9

Roaded Natural (RN) 157,386 1

Roaded Modified (RM) 1,662,825 10

Rural and Urban (R and U) 5,618 <0

Note:

The total acres by Recreation Opportunity Spectrum (ROS) class shown in this table are slightly lower 

than the Forest-wide total because the ROS inventory does not include the entire Forest. Source: 

USDA Forest Service 2016b, Table 3.15-3

Recreation Places

The pattern of use associated with known protected boat anchorages, boat landings, aircraft landing 

sites, and the limited road systems makes it possible to identify specific “recreation places” on the 

Tongass. A total of 1,436 recreation places, encompassing approximately 3.6 million acres, were 

identified as part of the planning process for 1997 Forest Plan Revision (USDA Forest Service 1997a). 

Recreation places are classified in two basic ways. First, recognizing that access plays a key role in 

recreation in Southeast Alaska, “home ranges” were defined for each community. Inventoried recreation 

places were classified into two categories: those located within a radius of approximately 20 miles from 

communities (“home range”) and those farther than 20 miles from a community. Almost half (48 percent) 

of the identified recreation place acres are within a community home range. Second, recreation places 

were identified as either important or ordinary/common based on five categories: facilities, marine, 

hunting, fishing, and tourism. Recreation places may be important for one, several, or none of the 

identified categories. Important recreation places by category are summarized in Table 3.10-3 and 

discussed further in the Recreation and Tourism section of the 1997 Forest Plan Revision FEIS (USDA 

Forest Service 1997b, pp. 3-109, 3-111).

Table 3.10-3

Important Recreation Places by Category and as a Share of Total Recreation 

Places1

Number of Places Percent of Total2 Acres (1,000s) Percent of Total2

Facilities3 402 28 1,053 29

Marine4 617 43 1,089 30

Hunting5 373 26 1,452 40

Fishing6 187 13 472 13

Tourism 876 61 1,924 53

Total7 1,436 NA 3,630 NA

na = not applicable

1 Recreation places are rated as either important or common/ordinary.

2 The Percent of Total columns sum to more than 100 because a recreation place can be rated important in more 

than one category.

3 All recreation places with facilities were rated as being important. In addition, other recreation places with some 

type of facility, such as a viewing platform, and facilities authorized by a special use permit for recreation purposes, 

were identified as important. 4 The marine category identified here is different to the marine type identified in Table 3.15-6 (USDA Forest Service 

2016b). The marine category in this table only includes those recreation places that are truly unique or typify the 

Southeast Alaska marine experience. 5 Important hunting areas were distinguished from ordinary hunting areas based on a number of factors, including

heavy recurring use, hunter success, ease of access, opportunities for several species, and prized species, such as 

mountain goats and moose. 6 Important fishing recreation places were identified using ADF&G ratings for recreational fishing. Source: USDA 

Forest Service 2016b, Table 3.15-7. 7

Totals are for all recreation places (important and ordinary/common) and are not the sum of the preceding rows.
Environment and Effects 3

Final EIS 3-184 Recreation and Tourism

Recreation Use

Many residents of Southeast Alaska place a high value on the quality and availability of outdoor 

recreation opportunities in the region, with the proportion of Alaskan residents who participate in outdoor 

activities generally much higher than elsewhere in the United States (Bowker 2001). Many local residents 

engage in dispersed recreation activities on National Forest System (NFS) land and adjacent saltwater. 

Most recreation activities take place in and depend upon settings that are primarily undeveloped and 

widely dispersed. Much of the recreation on the Forest occurs as day trips originating from a nearby 

community. Although there are some locations on the Tongass where fees are collected and locations 

where people can be easily counted, accurate data on dispersed recreation use is difficult to obtain. As a 

result, while there is a general consensus that outdoor recreation opportunities provided by the Tongass 

are highly important to residents, there is limited data that accurately quantifies resident recreation use.

Resident recreation demand is influenced by a number of factors, including regional population levels, per 

capita participation rates, and recreation travel behavior. Over time, the supply of certain recreation 

opportunities in Southeast Alaska has increased. Road systems have expanded into previously 

inaccessible areas and visitor services and in some cases resulted in supply-induced increases in 

participation. Supply-induced participation changes have also been accompanied by additional demand 

for specific recreation places or facilities for a related activity. Increased opportunities for roaded access 

and activities are typically accompanied by a need for parking, dispersed campsites, picnic sites, trails to 

scenic attractions, and additional short access routes to cabin sites and previously inaccessible beaches. 

Based on the results of the National Visitor Use Monitoring (NVUM) program for 2010 to 2014 and 

coefficients developed by White and Stynes (2010), the Forest Service (2017f) calculated a visitation 

estimate of 2,874,000 annual visits to the Tongass. The results of earlier surveys indicated that half of 

Alaska residents surveyed who live in Southeast Alaska reported using a boat or plane to access the 

national forest (White and Stynes 2010). Almost half (49.7 percent) of non-resident visits to the Tongass 

involved the use of a guide or outfitter at some point, with local cruises, wildlife viewing, and flightseeing 

reported most frequently. Alaska residents in contrast were found to very rarely use outfitters or guides 

(White and Stynes 2010).

The Tongass is home to a vibrant and growing tourism industry. Cruise ship and other package visitors 

are a very large group that uses the Tongass. These visitors spend less time in the area than 

independent visitors and generally follow preplanned and regimented itineraries. Shore excursions have, 

however, become an important part of the cruise ship experience, with much of this activity centered 

around ports of call that accommodate large or mid-sized cruise ships. Trends in visitation in areas near 

communities that serve as large cruise ship ports (such as Juneau, Ketchikan, Sitka, and Hoonah) 

include a desire for shorter, “softer” adventure excursions that do not require “hard” skills to experience 

wild Alaska (Zegre et al. 2012). Half-day and day excursions into the Forest have increased in popularity, 

providing increased revenues for ship operators and opportunities for local entrepreneurs.

Independent visitors, who constitute a much smaller group, tend to arrive by air, ferry, and highway and 

engage in a variety of activities.29 Independent visitors spend more time in the communities and on the 

Forest, and may secure the services of outfitters and guides, restaurants, motels, and transportation 

services such as floatplanes, boats, and gas stations. Independent travelers tend to plan their own 

itineraries, but often secure the services of mini-packages, such as day excursions or fishing charters. 

These types of visitors compete more directly with residents for recreation opportunities on the Forest.

Lodges have grown in popularity in recent years, with fishing lodges playing an important role in the 

tourism industry in some areas. This is, for example, the case with Elfin Cove, an unincorporated town 

located west of Hoonah, where nine recreational fishing lodges are located in the vicinity of the town 

(Dugan et al. 2009). Fishing lodges accounted for 79 percent of the non-cruise, multi-day packages 

identified in Summer 2016, with wilderness lodges and adventure tours accounting for a further 6 percent 

of the total each. Rail packages (1 percent), motor coach tours (1 percent), rental car/recreational vehicle 

29 Three Southeast Alaska communities – Haines, Hyder, and Skagway – can be accessed from outside the region via highway. As 

noted above, there is no interconnecting highway system between islands or between communities on the mainland.
Environment and Effects 3

Final EIS 3-185 Recreation and Tourism

package (2 percent), and hunting (less than 1 percent) accounted for the remaining share of multi-day 

packages (McDowell Group 2017).

The marketing of recreation opportunities by suppliers has important similarities to resident recreation 

concerns. For example, many businesses that provide boat or aircraft access for wildlife viewing and 

other activities have a low tolerance for the presence of other groups in the same area. The presence of 

more than two or three other parties in a bay or area may cause such operators to seek other locations. 

Similarly, resident recreationists who traditionally use an area may be discouraged by businesses 

operating in the same area. Outfitter/guide businesses are discussed in the next section.

Outfitter and Guide Use

The Forest Service authorizes outfitter and guiding services to provide for public health and safety and 

foster successful small businesses. Outfitters and guides are typically skilled and experienced individuals 

who conduct activities in a manner that protects environmental resources and ensures that national forest 

visitors receive high-quality services. Due to its remote and rugged nature, recreation use on much of the

Tongass requires good outdoor skills and/or specialized equipment. Outfitters and guides provide access 

and equipment to assist people who might not otherwise be able to pursue certain recreation activities on 

the Forest. Outfitter/guides on the Tongass range from small family-run operations to larger corporations 

and non-profit organizations, with activities ranging from fishing and hunting to helicopter flights and 

photography. Both residents and nonresidents use the services of outfitter/guides, but nonresidents tend 

to use outfitter/guides more often because they do not have the local knowledge or necessary equipment. 

Outfitter/guides are authorized to operate on the Tongass through special use permits and are required to 

report use as a condition of their permit.

While people often participate in several different activities in one or more settings on any given trip, 

different activities result in different numbers of people in a group and different amounts of time spent on 

the Forest. At one end of the spectrum, guided bear hunting consists of many small groups of one or two 

people. (State regulations require non-resident hunters to use guides for hunting brown bear and 

mountain goats). Hunters are dispersed across a large area and are on the Forest for typically 5 to 10 

days, during spring and fall. At the other end of the use spectrum are mid-sized nature-viewing tour boats 

with group sizes from 12 to 70 people. These groups are typically concentrated in a few areas of the 

Forest. Their use is short-term and typically concentrated in late spring, summer, and early fall.

Using information provided by outfitter/guides as part of their permit requirements, the Forest Service 

compiles data for 143 separate outfitter/guide use areas, which are used to identify and manage 

recreation use. These use areas are subdivisions of the Guide Use Areas that ADF&G uses to manage 

commercial big game guiding. Use areas are distinct geographic areas that range in size from about 500 

acres to more than 1.3 million acres. Outfitter/guide use areas consist of a mix of IRAs, Wilderness, and 

LUD II areas, as well as other areas managed for a range of non-development and development use 

under the 2016 Forest Plan. Thirteen outfitter/guide use areas have no IRA acres and 11 more include 

less than 100 acres. IRAs make up more than half the total acres of 96 of the 143 use areas (66 percent), 

with the roadless area share ranging from 51 percent to 100 percent.

A total of 3.1 million outfitter/guide clients or service days were reported on the Tongass from 2013 to 

2017, for an annual average of 632,100 service days. A service day is defined as a day or any part of a 

day for which an outfitter or guide provides service to a client on NFS lands. Reported use in 2017 was 

641,149 service days, higher than the five-year average. Reported use is presented for 2013 to 2017 for 

the 143 outfitter/guide use areas in Table C-1 in Appendix C. The following sections provide an overview 

of existing outfitter/guide use by ranger district. More detailed information on outfitter/guide use and 

management is available in the Outfitter and Guide Management Plan documents that address 

outfitter/guide use on the Forest (USDA Forest Service 2009b, 2009c, 2012d, 2012e, 2017e).

Admiralty National Monument

Admiralty National Monument is composed of 11 outfitter/guide use areas, 8 of which do not include any IRAs. 

The roadless share of the other three areas ranges from 14 percent to 31 percent. A total of 14,221 

outfitter/guide service days were reported on Admiralty National Monument from 2013 to 2017, for an annual 
Environment and Effects 3

Final EIS 3-186 Recreation and Tourism

average of 2,844 service days (Table 3.10-4). Viewed in terms of service days, wildlife viewing at Pack Creek 

Zoological Area was the most popular activity, accounting for 23 percent of total outfitter/guide use on 

Admiralty National Monument. Pack Creek Zoological Area is located in the Pack Creek use area, which does 

not include any roadless areas and would not be affected under any of the alternatives. Freshwater fishing was 

the next most popular activity making up 21 percent of service days. The Greens Creek use area accounted 

for almost half (47 percent) of total freshwater fishing service days.

Craig Ranger District

Outfitter/guide data are compiled for the Craig Ranger District as a whole. Approximately 77 percent of the 

0.93 million acres that comprise this area are roadless. A total of 9,343 outfitter/guide service days were 

reported from 2013 to 2017, for an annual average of 1,869 service days. Wildlife viewing was the most 

popular outfitter/guide activity in this area, accounting for 84 percent of total service days (Table 3.10-4).

Table 3.10-4

Outfitter/Guide Average Annual Use 2013 to 2017 by Ranger District and Activity

Reported Activity1

Ranger District

AdmiraltyCraigHoonahJuneauKetchikanMisty FjordsPetersburgSitkaThorne BayWrangellYakutat

Total Service Days 2,844 1,869 6,079 575,802 17,399 8,266 13,431 1,239 2,346 2,831

Percent of Total by Ranger District

Camping 1 1 5 0 0 18 5 26 42 1

Fishing 21 2 4 0 3 2 10 23 2 90

Flightseeing 0 0 0 0 36 0 0 0 0 0

Helicopter ski/tours 0 0 0 15 0 0 0 0 0 0

Hiking/Mountaineering 17 0 52 7 31 63 43 28 8 0

Hunting 14 9 1 0 0 6 5 4 1 3

Nature Viewing 1 0 0 0 0 0 2 0 0 0

Non-Motorized Boating 1 0 1 3 3 0 0 0 0 0

Other 0 1 0 2 0 0 5 0 0 0

Remote-Setting Nature Tours 15 2 10 0 12 6 14 3 12 0

Road-Based Activities 0 1 26 0 2 1 15 0 0 0

Sightseeing 7 1 1 0 0 3 1 16 4 2

Visitor Center 0 0 0 71 1 0 0 0 0 0

Wildlife Viewing 23 84 0 0 12 0 0 0 29 0

Note:

1 Reported activities and service days are from the Forest Service outfitter/guide database.

Hoonah Ranger District

The Hoonah Ranger District includes 10 outfitter/guide use areas and parts of two others, Tenakee Inlet 

and West Yakobi Island, which are also partially in the Sitka Ranger District. Four of the 12 areas do not 

include any roadless areas. The roadless share of the other eight areas ranges from 61 percent to 100 

percent. A total of 30,394 outfitter/guide service days were reported from 2013 to 2017, for an annual 

average of 6,079 service days. Hiking/mountaineering accounted for 52 percent of average annual use. 

Road-based activities were the second most popular activity (26 percent), followed by remote-setting 

nature tours (10 percent) (Table 3.10-4). Viewed by use area, hiking/mountaineering service days were 

concentrated in two use areas, Port Althorp and Idaho Inlet, which together accounted for 81 percent of 

total service days. Port Althorp also accounted for more than one-third (39 percent) of the remote-setting 

nature tour visitor days. Road-based activities were concentrated in the Port Frederick and Freshwater 

Bay areas, which together accounted for 99 percent of total road-based service days.
Environment and Effects 3

Final EIS 3-187 Recreation and Tourism

Juneau Ranger District

The Juneau Ranger District includes 28 outfitter/guide use areas. Three of the 28 areas do not include 

any roadless areas. The roadless share of the remaining 25 areas ranged from 67 percent to 100 

percent. A total of 2,879,009 outfitter/guide service days were reported from 2013 to 2017, for an annual 

average of 575,802 service days (Table 3.10-4). Visits to the Juneau Ranger District accounted for 91 

percent of Forest-wide outfitter/guide service days over this period. Put another way, outfitter/guides using 

the Juneau Ranger District reported 10 times as many service days as the other nine districts (including 

Admiralty National Monument) combined. Visits to one use area, Juneau Icefield 4 – Mendenhall Glacier, 

accounted for 90 percent of reported service days, with the majority of these service days (79 percent of 

total Mendenhall Glacier service days) consisting of trips to the Forest Service’s Mendenhall Glacier 

Visitor Center. Helicopter ski/tours accounted for 15 percent of total service days on the Juneau Ranger 

District and were mainly reported for the seven Juneau Icefield and three Skagway Icefield use areas, 

with Juneau Icefield 4 – Mendenhall Glacier accounting for almost half (48 percent) of the reportedtotal.

Ketchikan Misty Fjords Ranger District

The Ketchikan Misty Fjords Ranger District includes 28 outfitter/guide use areas. Four of the 28 areas do 

not include any roadless areas, and two more had less than 50 roadless acres each. The roadless share 

of the remaining 22 areas ranged from 6 percent to 98 percent. A total of 86,997 outfitter/guide service 

days were reported from 2013 to 2017, for an annual average of 17,339 service days. Flightseeing 

accounted for 36 percent of service days, followed by hiking/mountaineering (31 percent) (Table 3.10-4). 

More than 99 percent of flightseeing service days were reported in the Misty Core Lakes use area. This 

area does not include any roadless areas and would not be affected under any of the alternatives.

Hiking/mountaineering service days on the Ketchikan Misty Fjords Ranger District were reported for a 

number of areas, with the largest use occurring in the Betton Island use area, which accounted for about 

72 percent of service days in this category. Other important types of use included remote-setting nature 

tours (12 percent of service days) and wildlife viewing-developed sites (12 percent of service days) (Table 

3.10-4). Almost all (98 percent) of the remote setting nature tour service days were reported in the Betton 

Island use area. Wildlife viewing-developed site service days were all reported for the Margaret Creek 

Wildlife Viewing Area, which is part of the Margaret Bay outfitter/guide use area.

Petersburg Ranger District

The Petersburg Ranger District includes 20 outfitter/guide use areas, one of which does not include any 

roadless acres. The roadless share of the remaining 19 areas ranges from 2 percent to 99 percent. A 

total of 41,328 outfitter/guide service days were reported from 2013 to 2017, for an annual average of 

8,266 service days. 

Hiking/mountaineering was the most popular outfitter/guide activity (63 percent of service days), followed 

by camping (18 percent) (Table 3.10-4). Hiking/mountaineering service days were reported for a number 

of use areas, with relatively large numbers reported for the Thomas Bay/Point Vandeput (30 percent) and 

Petersburg Creek/Duncan Salt Chuck (25 percent) use areas. Camping service days were reported in 

almost all of the outfitter/guide use areas on the Petersburg Ranger District.

Sitka Ranger District

The Sitka Ranger District includes 13 outfitter/guide use areas and parts of two others, Tenakee Inlet and 

West Yakobi Island, which are also partially in the Hoonah Ranger District. Two of the 15 areas include 

less than 10 roadless acres, with the roadless share of the other 13 areas ranging from 70 percent to 99 

percent. A total of 67,156 outfitter/guide service days were reported from 2013 to 2017, for an annual 

average of 13,431 service days.

Hiking/mountaineering accounted for 43 percent of reported service days, followed by road-based 

activities (15 percent), and remote-setting nature tours (14 percent) (Table 3.10-4). Two outfitter/guide 

use areas, the Sitka Area and Kelp Bay use areas, together accounted for more than three-quarters of 

reported visitor days. Hiking/mountaineering and remote-setting nature tour service days were 
Environment and Effects 3

Final EIS 3-188 Recreation and Tourism

concentrated in these use areas, with the Sitka Area also accounting for most of the road-based activity 

service days. 

Thorne Bay Ranger District

Outfitter/guide data are compiled for the Thorne Bay Ranger District as a whole. Approximately 40 

percent of the 0.9 million acres that comprise this area are roadless. A total of 6,196 outfitter/guide 

service days were reported from 2013 to 2017, for an annual average of 1,239 service days.

Hiking/mountaineering, camping, and fishing were the most popular outfitter/guide activities in this area, 

accounting for 28 percent, 26 percent, and 23 percent of total service days, respectively (Table 3.10-4).

Wrangell Ranger District

The Wrangell Ranger District includes 13 outfitter/guide use areas. Two of the 13 areas had no roadless 

acres, with the roadless share of the other 11 areas ranging from 40 percent to 99 percent. A total of 

11,730 outfitter/guide service days were reported from 2013 to 2017, for an annual average of 2,346 

service days. Camping was the most popular outfitter/guide activity, accounting for 42 percent of total 

service days, followed by wildlife viewing-developed sites (29 percent) and remote-setting nature tours 

(12 percent) (Table 3.10-4).

Camping service days were reported for most of the use areas. Wildlife viewing-developed site service 

days were all reported for the Anan Creek wildlife viewing area, which is part of the Anan Creek 

outfitter/guide use area. Remote-setting nature tour service days were reported for a number of use 

areas, with the Stikine-LeConte Wilderness use area accounting for 71 percent of the total.

Yakutat Ranger District

The Yakutat Ranger District includes 16 outfitter/guide use areas, with roadless shares ranging from 1 

percent to 99 percent. A total of 14,157 outfitter/guide service days were reported from 2013 to 2017, for 

an annual average of 2,831 service days. Fishing was the most popular outfitter/guide activity accounting 

for 90 percent of service days (Table 3.10-4). Fishing visitor days were reported for a number of use 

areas, with the Situk River use area accounting for 71 percent of the total. 

Environmental Consequences

Supply of Recreation Opportunities

Recreation Opportunity Spectrum

This EIS is programmatic, meaning that it examines potential effects arising from direction and allowable 

activities for broad land areas, rather than specific activities in specific locations. The action alternatives 

would increase the acres available for timber harvest, but harvest levels are expected to remain the same 

across all alternatives. In addition, while there may be some variation by alternative, the amount of new or 

reconstructed road miles is expected to be broadly similar across all alternatives because roads on the 

Tongass are largely developed in support of timber harvesting and harvest levels are expected to remain 

similar. Estimated road miles by alternative are summarized in Table 3.3-21 (in the Key Issue 3 section, 

above).

Alternatives 2 to 6 would result in changes to the number of suitable old-growth and young-growth acres 

available for harvest30 in development LUDs (Timber Production, Modified Landscape, and Scenic 

Viewshed) presently managed as roadless. Total suitable acres are, therefore, used here as a relative 

measure of timber opportunity by ROS setting to differentiate between alternatives. They do not represent 

estimates of how much harvest would occur under each alternative, which, as noted above, is expected to 

be the same across all alternatives. In addition, harvest projections are used to provide another 

30 Changes in roadless management, areas in development LUDs managed as roadless, and suitable timber are discussed in more 

detail in the Outfitter and Guide Use section below.
Environment and Effects 3

Final EIS 3-189 Recreation and Tourism

perspective on potential programmatic changes in ROS settings. Actual harvest locations would depend on 

the timber sales that are carried out during Forest Plan implementation.

As discussed in the preceding affected environment section, the ROS system is designed to help identify 

and quantify different types of recreation setting on the Tongass and portrays the combination of 

activities, settings, and experience expectations along a continuum that ranges from highly modified to 

primitive environments (Table 3.10-2). Recreational visitors with an expectation of a remote experience 

would be most affected by timber harvest in Primitive, SPNM, and SPM settings. 

Figure 3.10-1 shows total old-growth suitable acres by ROS setting and alternative. Total old-growth 

suitable acres would increase relative to Alternative 1 under all five action alternatives, with increases 

ranging from about 20,000 acres (9 percent) (Alternative 2) to 168,000 acres (74 percent) (Alternatives 5 

and 6). The total number of suitable acres would increase in all ROS settings. The largest increase for 

Alternatives 4 to 6 would occur in the SPNM setting, with approximately 79,000 acres of old-growth 

suitable acres added in SPNM settings under Alternatives 5 and 6. Large absolute increases would also 

occur in RM, with approximately 62,600 acres added to RM settings under Alternatives 5 and 6 (Figure 

3.10-1).

Young-growth acres suitable for timber production would remain relatively constant across all 

alternatives. Suitable young-growth acres would range from 334,000 acres for Alternative 1 to 354,000 

acres for Alternative 6. More than 90 percent of young-growth suitable for harvest is in the RM setting 

under all six alternatives.

Although the alternatives would vary in terms of the amount and location of acres suitable for timber 

harvest, the total volumes expected to be harvested would be the same under each alternative. An 

estimated 42,500 acres of old growth would be harvested over 100 years.31 As described above, the 

following analysis assumes that the estimated total number of acres harvested would be the same for 

each alternative. Based on this analysis, RM as a share of the estimated total would decrease relative to 

Alternative 1 under all alternatives, decreasing from 91 percent under Alternative 1 to 72 percent under 

Alternatives 4 to 6 (Figure 3.10-2). Much of this decrease in RM would be made up by an increase in 

SPNM acres. SPNM as a share of the estimated total would range from 4 to 5 percent under Alternatives 

1 and 2 to 18 percent under Alternatives 4 to 6 (Figure 3.10-2).

Using the same assumptions for young growth, an estimated 284,000 acres of young growth would be 

harvested over 100 years under all alternatives.32 Harvest would largely be concentrated in RM settings 

under all six alternatives, with RM accounting for 93 to 96 percent of total harvest acres by alternative.

31 These estimates of total old growth (42,500 acres) and young growth (284,000 acres) that would be harvested over 100 years were 

developed as part of the 2016 Forest Plan Amendment EIS modeling for the Forest Plan (Alternative 1 in this EIS).

32 See previous footnote.
Environment and Effects 3

Final EIS 3-190 Recreation and Tourism

Figure 3.10-1

Old-Growth Suitable Acres by ROS Setting and Alternative

Note:

1 Urban (U) and Rural (R) ROS settings are not shown because they each make up a very small share of suitable acres 

under all six alternatives, less than 10 acres and between 100 and 200 acres, respectively.

Figure 3.10-2

Old-Growth Acres Expected to be Harvested After 100 Years by ROS Setting and 

Alternative

Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

P 118 587 2,200 5,622 5,753 5,756

SPNM 12,359 14,723 45,256 87,566 91,249 91,250

SPM 8,531 9,763 17,750 26,868 28,770 28,770

RN 3,735 3,770 3,921 3,900 4,029 4,029

RM 202,414 217,833 242,638 263,713 265,022 265,023

 -

 50,000

 100,000

 150,000

 200,000

 250,000

 300,000

 350,000

 400,000

Suitable Acres

Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

P 20 153 288 753 753 753

SPNM 1,687 2,039 5,285 7,769 7,769 7,769

SPM 1,391 1,621 2,059 2,899 2,899 2,899

RN 829 757 640 557 557 557

RM 38,526 37,885 34,171 30,471 30,471 30,471

 -

 5,000

 10,000

 15,000

 20,000

 25,000

 30,000

 35,000

 40,000

 45,000

Harvest Acres
Environment and Effects 3

Final EIS 3-191 Recreation and Tourism

Recreation Places

As with the preceding ROS assessment, total suitable acres available for timber production are used here 

as a relative measure of timber opportunity by recreation place to differentiate between alternatives. They 

do not represent estimates of how much harvest would occur under each alternative, which is expected to 

be the same across all alternatives. Figure 3.10-3 shows total old-growth suitable acres by important 

recreation place category and alternative. Total old-growth suitable acres in recreation places would 

increase relative to Alternative 1 under all five action alternatives. The total number of suitable old-growth 

acres would increase for all recreation place categories. The largest absolute increases would occur in 

home range recreation places, with net increases of approximately 25,400 suitable old-growth acres 

under Alternatives 5 and 6. Home range recreation places are those inventoried recreation places within 

an approximate 20-mile radius of one or more communities. Large increases would also occur under 

Alternatives 5 and 6 in recreation places important for marine use, hunting, and tourism, with net 

increases of about 12,400 to 14,500 suitable old-growth acres (Figure 3.10-3).

Total young-growth acres suitable for harvest would remain relatively constant across all alternatives, with 

the largest increase anticipated for home range recreation places under Alternative 6, a net gain of almost 

4,000 acres.

Figure 3.10-3

Old-Growth Suitable Acres by Recreation Place Category and Alternative

Note:

1 Recreation place categories are not mutually exclusive. A recreation place can be rated as important in 

more than one category. 

As discussed with respect to ROS settings, although the alternatives would vary in terms of the amount 

and location of acres suitable for timber production, the total volumes expected to be harvested would be 

the same under each alternative. The following analysis assumes that the estimated total number of 

acres harvested over 100 years would be the same for each alternative. Harvest would be distributed 

across available suitable acres, including those that coincide with important recreation places. Based on 

this analysis, the acres of old-growth acres harvested within four of the recreation place categories (home 

range, facilities, marine, and hunting) would mostly decrease relative to Alternative 1 (Figure 3.10-4). OldAlt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

Tourism 16,258 15,326 20,355 29,272 30,754 30,755

Fishing 7,761 6,060 8,149 16,664 17,087 17,088

Hunting 26,296 25,456 29,682 38,127 38,703 38,703

Marine 17,548 16,744 20,627 28,871 30,307 30,308

Facilities 13,019 14,272 17,480 18,270 19,570 19,570

Home Range 49,553 51,666 61,374 73,539 74,970 74,971

 -

 50,000

 100,000

 150,000

 200,000

 250,000

Suitable Acres
Environment and Effects 3

Final EIS 3-192 Recreation and Tourism

growth acres harvested in recreation places important for fishing and tourism would be expected to 

increase relative to Alternative 1.

Using the same assumptions for young-growth, total acres harvested in important recreation places over 

100 years would be similar across all alternatives, with changes relative to Alternative 1 ranging from a 

decrease of 1.3 percent (Alternative 6) to an increase of 1.3 percent (Alternative 2).

Overall, the total share of recreation place acres that would be harvested over 100 years would be small 

under all alternatives. Viewed as a share of total recreation place acres in each category, estimated oldgrowth and young growth harvest would range from about 2 percent (facilities and tourism) to 4 percent 

(home range and fishing) of total acres, with harvest in the other two categories (marine and hunting) 

equivalent to about 3 percent of total acres. Total acres by category are shown in Table 3.10-3. Actual 

harvest locations would depend on the timber sales that are carried out during plan implementation.

Figure 3.10-4

Old-Growth Acres Expected to be Harvested After 100 Years by Recreation 

Place Category and Alternative

Note:

1 Recreation place categories are not mutually exclusive. A recreation place can be rated as important in more 

than one category.

Recreation Use

As noted above, this EIS evaluates direction and allowable activities for broad land areas, rather than 

authorizing specific activities in specific locations. Actual timber harvest locations and associated road 

development activities would depend on the timber sales that are carried out during Forest Plan 

implementation. Further, timber harvest levels are expected to be similar under all alternatives. This 

makes it difficult to evaluate the effects of the alternatives on particular groups of recreation users or 

resources. The following discussion addresses potential impacts at the programmatic or Forest-scale and 

assesses relative potential impacts in terms of suitable acres available for harvest as a measure of 

potential timber opportunity. Forest-wide suitable acres are shown by alternative in Maps 7 to 12 (on 

thumb drive or website).

Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

Tourism 2,497 2,420 2,586 3,049 2,543 2,543

Fishing 764 727 800 846 870 870

Hunting 3,625 3,489 3,232 2,898 2,947 2,947

Marine 3,246 3,357 2,939 2,709 2,803 2,803

Facilities 2,592 2,582 2,568 2,217 2,336 2,336

Home Range 8,154 8,190 7,882 7,072 7,268 7,268

 -

 5,000

 10,000

 15,000

 20,000

 25,000

Harvest Areas
Environment and Effects 3

Final EIS 3-193 Recreation and Tourism

Changes in roadless area designations have the potential to affect the spatial distribution of future 

development activities, especially timber harvest. Figure 3.10-1 indicates that Alternatives 4 to 6 would result in 

relatively large increases in suitable old-growth acres available for harvest in SPNM ROS settings, as well as 

RM settings. Harvest projections over the next 100 years for each alternative indicate that the share of harvest 

in Primitive, SPM, and especially SPNM settings would increase relative to Alternative 1 under all the action 

alternatives with the largest increases occurring under Alternatives 4 to 6 (Figure 3.10-2). Similarly, the number 

of suitable acres available for harvest in important recreation places would increase relative to Alternative 1 

under all action alternatives with the largest increases under Alternatives 4 to 6 (Figure 3.10-3).

Timber harvest and associated road construction in Primitive and Semi-Primitive (SPNM and SPM) ROS

settings has the potential to affect recreation activities and users dependent on remote, natural settings 

with low to no evidence of human use. Harvest in these settings could affect the quality of the recreation 

experience and displace visitors to other parts of the Forest. These types of impacts are likely to occur in 

Primitive, SPNM, and SPM ROS settings in recreation places, especially in “home range” recreation 

places (i.e., those within approximately 20 miles of communities). Impacts are likely to be most acute in 

Primitive and Semi-Primitive areas where recreation use is already at or near capacity, including areas 

where competition already exists between resident recreationists, independent visitors, and outfitter/guide 

operations. Outfitter/guide use is discussed in more detail below.

Changes in roadless area designations could also indirectly affect nearby Primitive and Semi-Primitive 

ROS settings, as displaced recreationists seek other locations with similar qualities. In addition to longterm impacts in Primitive and Semi-Primitive settings, in the short term, resident and other recreationists 

could be displaced by logging operators in the nearby vicinity, with the presence of logging equipment 

potentially affecting access and the overall quality of the recreation experience. This type of short-term 

impact would potentially affect recreationists across all ROS settings.

The alternatives evaluated here could also result in different supply-induced changes in participation. In 

the past, supply-induced changes in participation on the Tongass have been mainly related to changes in 

road systems and road access. This type of change in participation appears to have occurred on Prince 

of Wales, Wrangell, and Mitkof Islands, for example. In these locations, road systems developed for 

timber harvesting created an opportunity for road-related access to previously inaccessible recreation 

settings and, therefore, an opportunity for recreation activities involving wheeled vehicles. In addition, new 

roads that provide easier access to a wider area may create new semi-primitive opportunities that 

increase the capacity of a recreation place or create a new recreation place. Continuation of such new 

opportunities would be dependent on the availability of funds for road maintenance and other system 

management needs. 

There would be some new road access in the long term under all alternatives. In addition, the Community 

Priority ARA (Alternative 3) would allow road construction and reconstruction in conjunction with the

construction, expansion, or maintenance of a developed recreation site. Nearly all new roads constructed 

under the alternatives would be closed following harvest. These roads would, therefore, not be available 

for use by highway vehicles or high-clearance vehicles. They may, however, be available for access by 

other methods and would, as a result, have the potential to affect existing recreation patterns. Any 

potential increase in recreational access may be limited by the extent to which road closures include 

restoring the road bed to a more natural condition, possibly blocking or discouraging non-vehicle access 

as well. The action alternatives would increase the acres available for timber harvest, but acres harvested 

and timber volume removed are expected to remain the same across all alternatives. As a result, the 

amount of new or reconstructed road miles would be similar across the alternatives, but would be lowest 

under Alternatives 1 and 2 and highest under Alternatives 4, 5, and 6. Alternative 3 would likely result in 

more roads than Alternatives 1 and 2, and fewer than Alternatives 4 to 6. In addition, based on the 

distribution of suitable acres, Alternatives 4 to 6 would be more likely to result in new road construction in 

Primitive or Semi-Primitive ROS settings. 

Outfitter and Guide Use

Land management activities that affect the natural appearance of the landscape have the potential to 

affect outfitter/guide operations that provide commercial recreation opportunities on the Forest. Impacts to 
Environment and Effects 3

Final EIS 3-194 Recreation and Tourism

existing outfitter/guide use are likely to be greatest where changes in roadless designations allow 

development in remote areas that are used for outfitter/guide activities dependent on high scenic integrity

and undisturbed landscapes.

Changes in roadless area designations could also affect outfitter/guide use in other adjacent or nearby 

areas as outfitter/guides displaced from one location seek other places to take clients. Some use areas 

are currently at capacity, which could serve to exacerbate potential displacement effects. Long-term 

changes in roadless area management could affect the Forest’s ability to meet future outfitter/guide 

demand, especially for operators seeking more remote areas. In the short term, commercial recreation 

operators could be displaced by logging operations in the nearby vicinity, with the presence of logging 

equipment and related noise affecting the quality of the recreation experience.

In some locations, new road construction could create new opportunities for operators who use Forest 

roads for access. However, nearly all new roads constructed under the alternatives would be closed 

following harvest.

The following analysis assesses potential impacts to the 143 outfitter/guide use areas that the Forest 

Service uses to manage outfitter/guide use using the following primary measures by alternative: 1) 

change in acres managed as roadless; 2) change in acres in development LUDs managed as roadless; 

3) change in suitable old-growth and young-growth acres available for harvest; and 4) projected oldgrowth and young-growth harvest. As described below, a screening review based on existing 

outfitter/guide use and changes in suitable old-growth acres is used to help focus on a smaller group of 

outfitter/guide use areas for more detailed review. 

Changes in Roadless Area Acres

The change in acres managed as roadless provides a broad overview of the changes in the current 

management situation by outfitter/guide use area. Changes in roadless acres are presented by 

outfitter/guide use area and alternative in Table C-2 in Appendix C.

Under Alternative 3, roadless designation would be removed from “roaded roadless” and “logical 

extension” areas, as discussed in Chapter 2. Alternative 3 would also remove protection from the 843,000 

LUD II acres that are currently within an IRA. LUD II acres removed from roadless designation would still 

retain their congressionally-designated protections, which require that these areas be managed in a 

roadless state to retain their wildland character. Therefore, decreases shown for Alternative 3 tend to 

overstate the amount of acres that would no longer be protected.

Two sets of estimates are provided for Alternative 4. Three ARAs would be designated under this 

alternative: LUD II Priority, Roadless Priority, and Timber Priority. The Timber Priority ARA would exempt 

timber harvest and road construction. The first set of estimates (4a) shows the net change in acres 

classified as roadless; the second set (4b) also subtracts the acres that would be managed as Timber 

Priority ARA because road construction would be allowed in these areas.

Changes in Acres in Development LUDs Managed as Roadless

Not all acres removed from roadless management would be available for development. LUD II acres 

removed from roadless designation under Alternative 3, for example, would, as noted above, still retain 

their congressionally-designated protections, which require that these areas be managed in a roadless 

state to maintain their wildland character. Other areas removed from roadless designation occur in nondevelopment LUDs, such as Old-growth Habitat and Remote and Semi-remote Recreation, which do not 

allow old-growth timber harvest. The change in acres in development LUDs managed as roadless serves 

as a measure of development potential.

Development LUDs for the purposes of this analysis are Timber Production, Modified Landscape, and 

Scenic Viewshed. These three LUDs all allow timber production, with Timber Production generally 

considered an intensive development LUD and Modified Landscape and Scenic Viewshed considered 

moderate development LUDs. Approximately 7 percent (1,152,700 acres) of the Forest is presently 

managed in development LUDs without roadless designation. This total does not include development 
Environment and Effects 3

Final EIS 3-195 Recreation and Tourism

LUD acres that are presently in IRAs. Total development LUD acres without roadless designation would 

increase under all action alternatives, with net gains ranging from about 53,300 acres (Alternative 2) to 

more than 2.1 million acres (Alternatives 5 and 6), as areas are removed from roadless designation.

Changes in development LUDs are presented by outfitter/guide use area and alternative in Table C-3 in 

Appendix C.

Changes in Suitable Timber

Not all lands allocated to development LUDs are available for timber management. As described in 

Appendix A to the 2016 Forest Plan (USDA Forest Service 2016a), old-growth forest located within 

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

Tongass 77 (T77) Watersheds and The Nature Conservancy (TNC)/Audubon Conservation Priority Areas 

is identified as not suitable for timber production. As a result, not all increases in development LUD acres 

would provide additional opportunities for timber harvest. Changes in suitable old-growth and younggrowth acres available for harvest are, therefore, used as a relative measure of timber opportunity to 

differentiate between alternatives (see Tables C-3 and C-4 in Appendix C, respectively). Suitable acres in 

this context serve as a relative measure of timber resources that would be potentially available under the 

current Forest Plan by outfitter/guide use area and alternative. Forest-wide, approximately 227,300 acres 

are presently considered suitable old-growth available for harvest. This total would increase under all the 

action alternatives, with gains ranging from about 19,500 acres (Alternative 2) to 160,600 to 167,800 

acres (Alternatives 4 to 6). Approximately 333,700 acres are considered suitable for young-growth 

harvest, with estimated increases ranging from about 11,300 acres (Alternative 2) to 20,200 acres 

(Alternative 6).

Estimated Timber Harvest over 100 Years

Total acres harvested are assumed to remain constant across all alternatives. After 25 years of Forest Plan 

implementation, an estimated 24,000 old-growth acres would be harvested. Old growth would continue to 

be harvested over time, but at a much reduced rate, with an estimated total of 42,500 old-growth acres 

expected to be harvested after 100 years. The corresponding totals for young growth are 43,300 acres 

after 25 years and 284,100 acres after 100 years. Estimated harvest totals over 100 years show the amount 

of harvest likely to occur by alternative and outfitter/guide use area. Estimated harvest acres were distributed 

over the suitable old-growth base using the following assumptions: 1) all harvest acres were assigned to 

medium- and high-volume old growth only; 2) based on historic harvest distributions, 95 percent of old-growth 

harvest was assumed to occur on the five south ranger districts (Craig, Ketchikan Misty Fjords, Petersburg, 

Thorne Bay, and Wrangell); and 3) harvest was assumed to occur in VCUs with higher stumpage values 

as estimated for the 2008 Forest Plan using the Spectrum model. The resulting distributions represent best 

estimates based on the available information and the above assumptions. Actual harvest locations will 

depend on the timber sales that are carried out during plan implementation.

Effects on Selected Outfitter/Guide Use Areas

The following analysis uses changes in suitable old-growth acres in conjunction with information on 

existing outfitter/guide use to help focus on potentially affected areas. Changes in suitable old-growth 

acres are presented by outfitter/guide use area and alternative in Table C-4 in Appendix C. Reported 

service days for 2013 to 2017 are presented for each outfitter/guide use area in Table C-1 in Appendix C. 

Not all of the outfitter/guide use areas were used over the past 5 years; a number do not include any 

roadless acres; others include roadless acres, but none are suitable for old-growth harvest; and others 

would see little change in suitable old-growth acres by alternative. A screening review based on these 

factors identified 15 outfitter/guide use areas where potential conflicts between existing outfitter/guide use 

and future management could occur based on recent patterns of existing use. These are outfitter/guide 

use areas with recent outfitter/guide use where there would be increases in suitable old-growth acres 

under one or more of the action alternatives. Areas with no or limited existing use and no or small 

estimated changes in suitable old-growth acres relative to Alternative 1 were removed from further review. 

A majority of the areas removed had no or minimal change in suitable old-growth acres under all five 

action alternatives (see Table C-4 in Appendix C).
Environment and Effects 3

Final EIS 3-196 Recreation and Tourism

This screening was undertaken to help focus on potentially affected areas as part of this programmatic 

review and is not meant to imply that potential conflict between changes in roadless management and 

outfitter/guide use would be limited to the 15 identified areas only. Outfitter/guide use could also be 

affected in site-specific locations in other areas. Further, changes in roadless area designations in one or

more of the 15 identified outfitter/guide use areas could indirectly affect use in adjacent or nearby areas 

as displaced outfitter/guides seek other places to take clients. It is also important to note that the 

screening review looked at recent outfitter/guide use only, and did not consider future patterns of 

outfitter/guide use or Forest Service outfitter/guide management actions.

The 15 areas identified for further discussion are identified in Table 3.10-5, which also identifies the total 

number of acres in each area and the share presently in IRAs and provides a summary of reported 

service days for 2013 to 2017. Eight of the 15 identified outfitter/guide use areas are located on the north 

part of the Forest, in the Juneau, Sitka, and Hoonah Ranger Districts. The remaining seven areas include 

the entire Craig and Thorne Bay Ranger Districts, and outfitter/guide use areas on the Petersburg (four 

areas) and Ketchikan Misty Fjords (one area) Ranger Districts. These areas are identified in Figure 3.10-

5, which shows these areas along with the areas presently in development LUDs not managed as 

roadless. These 15 areas and the other 128 outfitter/guide use areas are shown on Map 13, which also 

shows existing roadless areas and suitable old-growth and young-growth acres presently available for 

harvest.

Table 3.10-5

Total Area, Percent Roadless, and Reported Service Days for Selected 

Outfitter/Guide Use Area

Outfitter/Guide Use Area

Total 

Acres

Percent 

in IRA

Reported Service Days

2013 2014 2015 2016 2017

Grand 

Total

Annual 

Average

01-03 East Chilkats 361,545 67% 446 454 179 146 246 1,471 294

04-03 Sitka Area 345,862 85% 5,213 4,733 6,005 5,614 6,597 28,162 5,632

04-04A Rodman Bay 75,427 60% 250 428 385 347 508 1,918 384

04-04B Kelp Bay 144,680 89% 4,048 4,427 5,316 5,343 5,494 24,628 4,926

04-11A Port Frederick 112,512 77% 10 15 78 1,358 3,021 4,482 896

04-11B Freshwater Bay 160,078 61% 178 228 1,838 2,235 2,468 6,947 1,389

04-12 Tenakee Inlet 312,435 79% 95 89 108 230 407 929 186

04-13 Peril Strait 232,130 72% 744 1,057 1,473 1,254 1,368 5,896 1,179

CRD 00 Craig Ranger District 925,877 77% 2,574 1,920 2,125 1,798 926 9,343 1,869

K19 North Revilla 70,401 83% 217 269 101 286 193 1,066 213

P01 Mitkof Island 109,302 32% 1,179 1,106 1,105 681 568 4,639 928

P08 North Lindenberg 

Peninsula

75,605 78% 200 227 482 224 255 1,388 278

P12B Kuiu Island Road 

System

134,852 31% 167 91 174 156 108 696 139

P21 Muddy River Area 63,357 68% 474 330 411 263 257 1,735 347

TBRD 00 Thorne Bay Ranger 

District

901,507 40% 1,872 1,495 953 1,006 870 6,196 1,239

Source: Most recent five years of data (2013-2017) from the Tongass National Forest Outfitter/Guide Database.

The following sections assess potential impacts by alternative to existing outfitter/guide use in each of the 

15 identified areas. This assessment is a programmatic review based on the distribution of suitable oldgrowth and young-growth acres available for harvest by alternative, and locations where outfitter/guides 

have reported use as part of their permit requirements. Projected old-growth and young-growth harvest is 

also reviewed for each of the 15 areas. Reported outfitter/guide use information includes number of 

groups and service days, primary activity, and usually a named location (e.g., Teardrop Creek, Mirror 

Creek, Mosquito Cove Trail). This location information is useful at the programmatic level, but does not 

identify actual patterns of outfitter/guide use, which may extend over relatively large areas, depending on 
Environment and Effects 3

Final EIS 3-197 Recreation and Tourism

the activity. It is also important to note that the 15 outfitter/guide use areas identified are large areas 

ranging from about 63,000 acres to more than 900,000 acres in size. All 15 areas are larger than the 

District of Columbia and the two largest areas (Craig Ranger District and Thorne Bay Ranger District) are 

each larger than the state of Rhode Island. Use in some of these areas involves multiple outfitter/guides, 

activities, and locations. Potential conflict could occur in multiple locations in each area. The following 

assessment is not a site-specific review, rather it uses available information to illustrate broad patterns of 

use and differentiate between alternatives. More detailed information on outfitter/guide use and 

management is available in the Outfitter and Guide Management Plan documents that address 

outfitter/guide use on the Forest (USDA Forest Service 2009b, 2009c, 2012d, 2012e, 2017e).

With these caveats in mind, the following review found that in almost all of these areas existing 

outfitter/guide use occurs on or near shorelines and along Forest road systems where development has 

occurred in the past. Viewed in terms of increases in acres suitable for harvest, impacts under 

Alternatives 2 and 3 would be minimal in all areas, with increases in roadless acres and reductions in 

suitable acres occurring in some areas under these alternatives. Alternatives 4 to 6 would add similar 

numbers of suitable acres in all areas. In most cases, additions under Alternatives 4 to 6 would expand 

areas of existing suitable acres around an existing road system, for example, rather than open-up new 

areas for potential harvest. For old-growth this is at least partially due to the definition of suitable, which 

allows harvest only in Phase 1 of the Tongass Timber Sale Program Adaptive Management Strategy and 

excludes the T77 Watersheds and TNC/Audubon Conservation Priority Areas, as noted above. These 

exclusions result in roadless restrictions being removed in development LUDs, with no corresponding 

increase in suitable acres.

In most of the following outfitter/guide use areas, harvest that could already occur in these areas (under 

Alternative 1) has the potential to conflict with existing outfitter/guide use. By expanding the acres 

available for harvest, Alternatives 4 to 6 could add to these potential impacts by increasing the number 

and geographic extent of the acres affected. The addition of acres could also improve the economics of a 

potential timber sale, increasing the potential for a sale to be proposed in that area.

The following review by outfitter/guide use area also considers projected old-growth and young-growth 

harvest by alternative. Based on the assumptions used to distribute estimated old-growth harvest acres, 

very limited to no old-growth harvest is projected to occur in 8 of the 15 outfitter/guide use areas 

discussed below, specifically those areas located on the north part of the Forest. In other cases, oldgrowth and young-growth harvest is projected to decrease relative to Alternative 1, based on the relative 

distribution of suitable acres across the Forest. 

Areas in development LUDs without roadless designations are shown for the six alternatives in Figures 

3.10-5 to 3.10-10, which also highlight the 15 outfitter/guide use areas discussed below. More detailed 

maps showing suitable old-growth and young-growth acres available for harvest for each alternative and 

outfitter/guide use area are provided as Maps 13 to 18 (on thumb drive or website).
Environment and Effects 3

Final EIS 3-198 Recreation and Tourism

Figure 3.10-5

Alternative 1 with 15 Selected Outfitter/Guide Use Areas
Environment and Effects 3

Final EIS 3-199 Recreation and Tourism

Figure 3.10-6

Alternative 2 with 15 Selected Outfitter/Guide Use Areas
Environment and Effects 3

Final EIS 3-200 Recreation and Tourism

Figure 3.10-7

Alternative 3 with 15 Selected Outfitter/Guide Use Areas
Environment and Effects 3

Final EIS 3-201 Recreation and Tourism

Figure 3.10-8

Alternative 4 with 15 Selected Outfitter/Guide Use Areas
Environment and Effects 3

Final EIS 3-202 Recreation and Tourism

Figure 3.10-9

Alternative 5 with 15 Selected Outfitter/Guide Use Areas
Environment and Effects 3

Final EIS 3-203 Recreation and Tourism

Figure 3.10-10

Alternative 6 with 15 Selected Outfitter/Guide Use Areas
Environment and Effects 3

Final EIS 3-204 Recreation and Tourism

01-03 East Chilkats

The East Chilkats outfitter/guide use area is located on the Juneau Ranger District and consists of 

361,545 acres, almost two-thirds of which (67 percent) are located in IRAs (Table 3.10-5). Located on the 

south end of the Chilkat Peninsula, this use area is bordered to the west by Glacier Bay National Park 

and Lynn Canal to the east, with the Endicott River Wilderness located alongside the north part of the 

area. An existing NFS road system that is open for public use is located at the southern end of the area.

Seven outfitter/guides reported use in this area from 2013 to 2017, two of which used the area regularly 

(4 out of 5 years). An annual average of 294 service days were reported over this period (Table 3.10-5). 

The majority of the use involved one operator conducting guided freshwater fishing trips. Fishing 

accounted for the majority (86 percent) of reported service days, followed by hiking/mountaineering (11 

percent). Use was reported at 12 locations, with Teardrop Creek accounting for 36 percent of reported 

service days, followed by Couverden Creek (31 percent) and Mirror Creek (19 percent).

The East Chilkats use area includes about 16,100 acres of lands in development LUDs outside of 

roadless, with about 6,350 acres of suitable old-growth available for harvest and 3,800 acres of suitable 

young-growth. Existing suitable old-growth acres are concentrated around the existing logging road 

system at Point Couverden on the south end of the peninsula. Suitable young-growth is also located 

along this road system and along the shorelines near Excursion Inlet on the west side, and near St. 

James Bay and Sullivan Island to the east. 

Table 3.10-6

Change in Roadless Area, Development LUDs without Roadless Designation, and 

Suitable Timber by Alternative for the East Chilkats Outfitter/Guide Use Area

Management Type

Total Acres Change from Alternative 1 (acres)

Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

Roadless Area1, 2 244,171 -2,259 -2,259 -2,259 -50,978 -244,171

Development LUDs – Not Roadless2 16,105 2,049 2,049 2,049 50,441 50,441

Suitable Old Growth 6,345 291 291 3,421 4,350 4,350

Suitable Young Growth 3,777 687 687 688 1,061 1,105

Old-Growth Harvest 292 1 -44 -98 -80 -80

Young-Growth Harvest 3,216 461 422 421 704 704

Notes:

1 Changes in roadless area acres for Alternative 3 include LUD II acres, which would be removed from roadless classification, but 

would still be managed in a roadless condition.

2 Roadless acres managed as Timber Priority ARA under Alternative 4 are included in the roadless area total and excluded from 

the development LUD total, which has the effect of understating the changes in these categories.

The number of roadless acres in the East Chilkats use area would decrease under the action alternatives, 

with decreases ranging from about 2,250 acres (Alternatives 2, 3, and 4) to about 244,200 acres under 

Alternative 6, which would remove roadless designation from all lands. Alternative 5 would remove 

roadless designation for about 51,000 acres (Table 3.10-6). Increases in the number of acres in 

development LUDs without roadless designation would range from about 2,050 acres (Alternatives 2 to 4) 

to 50,450 acres (Alternatives 5 and 6). Increases in suitable old-growth would range from less than 300 

acres (Alternatives 2 and 3) to about 4,350 acres (Alternatives 5 and 6). Suitable young-growth acres 

would increase by about 700 acres (Alternatives 2 to 4) to 1,100 acres (Alternatives 5 and 6) (Table 

3.10-6).

Suitable old-growth and young-growth acres would be added in and around the existing road system 

under all alternatives. Alternatives 5 and 6 would add more suitable old growth along the Excursion Inlet 

shoreline north of the past harvest area. Young-growth acres would also be added along the shoreline, 

north of William Henry Bay (all action alternatives) and south of Lynn Sisters (Alternatives 5 and 6). 

Harvest near Lynn Sisters under Alternatives 5 and 6 could conflict with existing outfitter/guide use in that 

area. Fishing at Lynn Sisters accounted for about 10 percent of reported service days from 2013 to 2017. 

The East Chilkats outfitter/guide use area is located on the Juneau Ranger District and, therefore, only 

very limited old-growth harvest is projected to occur over the next 100 years under all of the alternatives, 
Environment and Effects 3

Final EIS 3-205 Recreation and Tourism

with estimated harvest totals ranging from about 200 to 300 acres. An estimated total of 3,200 acres of 

young growth are projected to be harvested over the next 100 years under Alternative 1, with harvest 

acres expected to increase under all five action alternatives, with net increases of 420 acres (Alternatives

3 and 4) to 700 acres (Alternatives 5 and 6) (Table 3.10-6). 

04-03 Sitka Area

The Sitka Area outfitter/guide use area is located on the Sitka Ranger District and consists of 345,862 

acres, 85 percent of which are located in IRAs (Table 3.10-5). This use area includes Sitka and northwest 

Baranof Island from north of Fish Bay to south of Three Entrance Bay, as well as Kruzof, Partofshikof, 

Halleck, Krestof, and Siginaka Islands. Much of the shoreline is protected and provides easy access to 

the bays, sounds, and straits located throughout the area.

Thirty-two outfitter/guides reported use in this area from 2013 to 2017, 11 of which used the area 

regularly (4 out of 5 years). An annual average of 5,632 service days were reported over this period, more 

than 40 percent of the total reported for all areas on the Sitka Ranger District. Hiking accounted for 39 

percent of reported use, followed by road-based nature tours (32 percent) and remote-setting nature tours 

(12 percent). Use was reported in multiple locations, with relatively high use identified for the Mud Bay

road system and Iris Meadows, which together accounted for 31 percent of reported service days, 

followed by the Mosquito Cove Trail, with 20 percent of service days.

The Mud Bay road system and Iris Meadows are mainly used for road-based nature tours. The Mosquito 

Cove Trail is mainly used for hiking, with some road-based nature tour use also reported.

The Sitka Area includes 24,400 acres of lands in development LUDs outside of roadless, with about 

2,300 acres identified as suitable for old-growth harvest and 9,850 acres suitable for young-growth 

harvest (Table 3.10-7). Existing suitable old-growth acres are almost entirely located on Kruzof Island, 

primarily along the existing Mud Bay road system. Suitable young-growth acres are also located in this 

area, as well as along FR 7595 on the north part of Kruzof Island.

Suitable young-growth acres are also available along existing Forest road systems near Fish Bay, St. 

John Baptist Bay, and along NakwasinaSound.

Table 3.10-7

Change in Roadless Area, Development LUDs without Roadless Designation, and 

Suitable Timber by Alternative for the Sitka Area Outfitter/Guide Use Area

Management Type

Total Acres Change from Alternative 1 (acres)

Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

Roadless Area1, 2 296,576 456 456 -1,479 -60,038 -296,576

Development LUDs – Not Roadless2 24,386 465 465 467 58,947 58,951

Suitable Old Growth 2,322 20 20 2,529 2,530 2,530

Suitable Young Growth 9,849 1 9 9 9 37

Old-Growth Harvest 0 0 0 6 5 5

Young-Growth Harvest 8,384 -274 -353 -356 -397 -448

Note:

1 Changes in roadless area acres for Alternative 3 include LUD II acres, which would be removed from roadless classification, 

but would still be managed in a roadless condition.

2 Roadless acres managed as Timber Priority ARA under Alternative 4 are included in the roadless area total and excluded 

from the development LUD total, which has the effect of understating the changes in these categories.

Changes in roadless area acres in the Sitka Area would be minimal under Alternatives 2 to 4, with 

Alternatives 2 and 3 adding about 450 acres to roadless designation. Alternative 4 would remove about 

1,500 acres from roadless, with this total increasing to 26,900 acres (9 percent of the roadless area), if 

acres designated as Timber Priority ARA are included with those removed. Alternative 5 would remove 

roadless designations from about 60,000 acres. Alternative 6 would remove regulatory roadless 

prohibitions from all lands in existing IRAs, approximately 296,600 acres (Table 3.10-7). 
Environment and Effects 3

Final EIS 3-206 Recreation and Tourism

Alternatives 2 to 4 would have very little effect on development potential, as measured by acres in 

development LUDs without roadless designation, with each alternative adding about 470 acres, about 2 

percent of the existing total. Alternatives 5 and 6, on the other hand, would increase existing development 

LUD acres without roadless designation more than three-fold, with a net increase of 58,950 acres under 

each alternative. There would be essentially no change in suitable young-growth acres under any 

alternative, and a negligible decrease in suitable old-growth acres under Alternatives 2 and 3. Alternatives 

4 to 6 would each add about 2,500 suitable old-growth acres, mainly along the north side of the Mud Bay 

road system on Kruzof Island.

The Mud Bay road system is heavily used by outfitter/guides, mainly offering road-based nature tours. 

The existing old-growth suitable acres in this area are along this road system. The addition of 2,500 

suitable old-growth acres under Alternatives 4 to 6 would extend the area available for harvest. Harvest of 

existing suitable old-growth and young-growth acres under all alternatives would conflict with 

outfitter/guide use in the area. The old-growth acres that would be added under Alternatives 4 to 6 could 

potentially make harvest in this area more likely by expanding available volumes and improving 

economics; potentially exacerbating the level of adverse impact if harvest were to occur in these areas. 

However, little to no old-growth harvest is projected to occur over the next 100 years in this area under 

any of the alternatives. An estimated 8,400 acres of young growth are projected to be harvested over the 

next 100 years under Alternative 1, with harvest acres expected to decrease under all five action 

alternatives, with drops ranging from about 300 acres (Alternative 2) to 450 acres (Alternative 6) (Table 

3.10-7).

04-04A Rodman Bay

The Rodman Bay outfitter/guide use area is located on the Sitka Ranger District and consists of 75,427 

acres, 60 percent of which are located in IRAs (Table 3.10-5). This use area is located on the north end of 

Baranof Island extending from just west of Peschani Point to Point Moses, just east of the Lake Eva Trail. 

Shorelines are easily accessed in the area’s bays: Rodman Bay, Appleton Cove, and Saook Bay.

Twenty outfitter/guides reported use in this area from 2013 to 2017, five of which used the area regularly 

(4 out of 5 years), with one outfitter/guide accounting for more than half (57 percent) of total reported use. 

An annual average of 384 service days were reported over this period (Table 3.10-5). Hiking accounted 

for almost half (46 percent) of reported use, followed by freshwater fishing (37 percent), and remotesetting nature tours (13 percent). Use was reported at eight locations around the area’s three bays. 

Almost three-quarters (74 percent) of reported service days were for Saook Bay or Saook Bay Creek.

The Rodman Bay use area includes 24,400 acres of lands in development LUDs outside of roadless, with 

about 750 acres identified as suitable for old-growth harvest and 7,500 acres suitable for young-growth 

harvest (Table 3.10-8). Existing suitable young-growth acres are located along the existing road systems 

around Rodman Bay, Appleton Creek, and Saook Bay, along Rodman Creek, and extending northeast 

along the Duffield Peninsula toward Peschani Point. Existing suitable old-growth acres are located either 

side of the suitable young-growth along Forest Road 7587 on the Duffield Peninsula. 

The number of roadless acres in the Rodman Bay use area would increase under Alternatives 2 and 3, 

with net gains of approximately 7,650 aces, about 10 percent of the total use area. The number of acres 

with roadless designation would decrease under Alternatives 4, 5, and 6. Alternative 5 would remove 

roadless designation for about 34,500 acres, and Alternative 6 would remove regulatory roadless 

prohibitions from all lands, approximately 45,400 acres (Table 3.10-8).
Environment and Effects 3

Final EIS 3-207 Recreation and Tourism

Table 3.10-8

Change in Roadless Area, Development LUDs without Roadless Designation, and 

Suitable Timber by Alternative for the Rodman Bay Outfitter/Guide Use Area

Management Type

Total Acres Change from Alternative 1 (acres)

Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

Roadless Area1, 2 45,371 7,639 7,639 -423 -34,452 -45,371

Development LUDs – Not Roadless2 24,368 -6,257 -6,257 302 34,306 34,306

Suitable Old Growth 749 61 61 2,661 2,662 2,662

Suitable Young Growth 7,508 -44 -44 0 0 0

Old-Growth Harvest 0 0 0 0 0 0

Young-Growth Harvest 6,392 -245 -311 -277 -309 -364

Note:

1 Changes in roadless area acres for Alternative 3 include LUD II acres, which would be removed from roadless classification, 

but would still be managed in a roadless condition.

2 Roadless acres managed as Timber Priority ARA under Alternative 4 are included in the roadless area total and excluded 

from the development LUD total, which has the effect of understating the changes in these categories.

Changes in the total number of acres in development LUDs without roadless designation would range 

from a decrease of about 6,300 acres under Alternatives 2 and 3 to an increase of about 34,300 acres for 

Alternatives 5 and 6. Increases in suitable old-growth acres available for harvest would range from a 

negligible increase under Alternatives 2 and 3 (about 20 acres) to about 2,700 acres (Alternatives 4 to 6) 

(Table 3.10-8). Suitable old-growth acres would be entirely added to the Duffield Peninsula, extending the 

existing narrow bands of suitable old-growth to the north and south. None of the action alternatives would 

add suitable young-growth acres (with negligible decreases expected for Alternatives 2 and 3).

Harvest of existing suitable young-growth acres under all alternatives would conflict with outfitter/guide 

use in the area. Projected young-growth harvest is, however, expected to decrease relative to Alternative 

1 under all five action alternatives, with decreases ranging from about 250 acres (4 percent) to 360 acres 

(6 percent) (Table 3.10-8). The suitable old-growth acres added on Duffield Peninsula under Alternatives

4 to 6 are located farther away from areas that receive relatively high levels of existing outfitter/guide use. 

In addition, no old-growth harvest is projected to occur over the next 100 years in this area under any of 

the alternatives (Table 3.10-8).

04-04B Kelp Bay

The Kelp Bay outfitter/guide use area is located on the Sitka Ranger District and consists of 144,680 

acres, 89 percent of which are located in IRAs (Table 3.10-5). Located on the northern end of Baranof 

Island, this use area extends from Hanus Bay to south of Takatz Bay and includes Catherine Island and 

surrounding islands, as well as the islands in Kelp Bay. Easily accessible shorelines include Hanus Bay,

Cosmos Cove, Kasnyku Bay, Takatz Bay, and Kelp Bay.

Almost 40 outfitter/guides reported use in this area from 2013 to 2017, 20 of which used the area 

regularly (4 out of 5 years). An annual average of 4,926 service days were reported over this period 

(Table 3.10-5). Hiking accounted for more than half (54 percent) of reported use, followed by remotesetting nature tours (17 percent) and hatchery tours (13 percent). Use was reported at 31 locations, with 

the Lake Eva Trail accounting for almost half (46 percent) of reported service days. Other popular 

locations were Hidden Falls Hatchery (21 percent of total service days) and various locations around Kelp 

Bay (10 percent of total service days).

Conflicts between guided groups (hunting, remote-setting nature tour, and freshwater fishing) have been 

reported during spring and fall hunting seasons at Hanus Bay and Kelp Bay. Concerns have also been 

expressed about small cruise ship activity in Kelp Bay and the impact of larger groups on the remote 

experience being sought by other outfitter and guide operators in the area (USDA Forest Service 2017e).

The Kelp Bay use area includes about 10,500 acres of lands in development LUDs outside of roadless, 

with about 2,500 acres identified as suitable for old-growth harvest and 3,500 acres suitable for younggrowth harvest (Table 3.10-9).
Environment and Effects 3

Final EIS 3-208 Recreation and Tourism

Existing suitable old-growth and young-growth acres are located on the north end of Catherine Island, 

around Hanus Bay, and either side of Portage Arm. Suitable young-growth acres are also along existing

roads near Kelp Bay.

Table 3.10-9

Change in Roadless Area, Development LUDs without Roadless Designation, and 

Suitable Timber by Alternative for the Kelp Bay Outfitter/Guide Use Area

Management Type

Total Acres Change from Alternative 1 (acres)

Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

Roadless Area1, 2 131,182 230 230 -228 -22,462 -131,182

Development LUDs - Not Roadless2 10,447 182 182 195 22,341 22,341

Suitable Old Growth 2,524 66 66 3,880 3,880 3,880

Suitable Young Growth 3,535 0 0 0 0 0

Old-Growth Harvest 109 1 -16 95 86 86

Young-Growth Harvest 3,009 -97 -129 -130 -144 -167

Notes:

1 Changes in roadless area acres for Alternative 3 include LUD II acres, which would be removed from roadless 

classification, but would still be managed in a roadless condition.

2 Roadless acres managed as Timber Priority ARA under Alternative 4 are included in the roadless area total and excluded 

from the development LUD total, which has the effect of understating the changes in these categories.

The number of roadless acres in the Kelp Bay use area would increase slightly under Alternatives 2 and 3 

and decrease under the other action alternatives. Alternative 5 would remove roadless designation for 

about 22,500 acres, and Alternative 6 would remove regulatory roadless prohibitions from all lands, 

approximately 131,200 acres (Table 3.10-9).

The total number of acres in development LUDs without roadless designation would range from slight 

increases under Alternatives 2 and 3 (less than 200 acres) to about 22,350 acres (Alternatives 5 and 6). 

Increases in suitable old-growth acres available for harvest would range from a negligible increase under 

Alternatives 2 and 3 (less than 100 acres) to 3,900 acres (Alternatives 4 to 6). Suitable old-growth acres 

would be added next to the areas of existing suitable old-growth, extending further south on Catherine 

Island and northwest on Baranof Island toward Lake Eva. None of the action alternatives would add 

suitable young-growth and projected young-growth harvest is expected to decrease slightly relative to 

Alternative 1 under all five action alternatives (Table 3.10-9). Harvest of existing suitable old-growth and 

young-growth acres under all alternatives would conflict with outfitter/guide use in the area. The oldgrowth acres that would be added under Alternatives 4 to 6 could potentially exacerbate these impacts if 

harvest were to occur in these areas. However, only very limited old-growth harvest is projected to occur 

over the next 100 years under all of the alternatives, with estimated harvest totals ranging from about 100 

to 200 acres (Table 3.10-9).

04-11A Port Frederick

The Port Frederick outfitter/guide use area is located on the Hoonah Ranger District and consists of 

112,512 acres, 77 percent of which are located in IRAs (Table 3.10-5). This use area encompasses the 

north and northeast portions of Chichagof Island from Chicken Creek east to Port Frederick. The area 

also includes the city of Hoonah, Alaska Native corporation lands, State properties, and several private 

inholdings. Access is via boat or floatplane.

Fourteen outfitter/guides reported use in this area from 2013 to 2017, two of which used the area 

regularly (4 out of 5 years). An annual average of 896 service days were reported over this period. Use 

has, however, increased substantially over recent years, with reported service days increasing from 10 

(2013) to 1,358 and 3,021 in 2016 and 2017, respectively (Table 3.10-5).

Road-based nature tours accounted for almost two-thirds (62 percent) of reported use, followed by hiking 

(34 percent). Use was reported at 12 locations, with Burnt Point and the Neka Bay North Bight Large 

Group Area each accounting for more than one-third of reported service days, followed by Game Creek 

(20 percent).
Environment and Effects 3

Final EIS 3-209 Recreation and Tourism

The Port Frederick use area includes about 14,800 acres of lands in development LUDs outside of 

roadless, with about 1,500 acres of old-growth identified as suitable for harvest and 3,800 acres of younggrowth suitable for harvest (Table 3.10-10). Existing suitable old-growth acres are mainly located east of 

Hoonah. Suitable young-growth acres are located south of Port Frederick and along the existing road 

system that follows the Neka River.

Table 3.10-10

Change in Roadless Area, Development LUDs without Roadless Designation, and 

Suitable Timber by Alternative for the Port Frederick Outfitter/Guide Use Area

Management Type

Total Acres Change from Alternative 1 (acres)

Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

Roadless Area1, 2 88,043 3,278 3,122 -368 -48,870 -88,043

Development LUDs – Not Roadless2 14,815 -3,051 -2,957 209 48,677 48,677

Suitable Old Growth 1,502 19 73 3,766 3,867 3,867

Suitable Young Growth 3,789 2 2 13 18 126

Old-Growth Harvest 104 -2 -17 147 136 136

Young-Growth Harvest 3,225 -104 -137 -130 -141 -83

Notes:

1 Changes in roadless area acres for Alternative 3 include LUD II acres, which would be removed from roadless classification, 

but would still be managed in a roadless condition.

2 Roadless acres managed as Timber Priority ARA under Alternative 4 are included in the roadless area total and excluded 

from the development LUD total, which has the effect of understating the changes in these categories.

The number of roadless acres in the Port Frederick use area would increase by more than 3,000 acres 

under Alternatives 2 and 3 and decrease under the other action alternatives. Alternative 5 would remove 

roadless designation for about 48,900 acres, and Alternative 6 would regulatory roadless prohibitions

from all lands, approximately 88,000 acres (Table 3.10-10).

The total number of acres in development LUDs without roadless designation would decrease by about 

3,000 acres under Alternatives 2 and 3 and increase by about 48,700 acres under Alternatives 5 and 6. 

Increases in suitable old-growth acres available for harvest would range from a negligible increase under 

Alternatives 2 and 3 (less than 100 acres) to about 3,800 acres (Alternative 4) and 3,900 acres 

(Alternatives 5 and 6). Suitable old-growth acres would be added south and east of Hoonah in areas that 

do not presently receive high outfitter/guide use. Further, only very limited old-growth harvest is projected 

to occur over the next 100 years under all of the alternatives, with estimated harvest totals ranging from 

about 100 to 250 acres (Table 3.10-10). Changes in suitable young-growth acres available for harvest are 

negligible (about 125 acres or less). Projected young-growth harvest is expected to decrease slightly 

relative to Alternative 1 under all five action alternatives (Table 3.10-10).

04-11B Freshwater Bay

The Freshwater Bay outfitter/guide use area is located on the Hoonah Ranger District and consists of 

about 160,078 acres, 61 percent of which are located in IRAs (Table 3.10-5). This use area encompasses 

the north and northeast portion of Chichagof Island from Whitestone Harbor east to Freshwater Bay. 

Access is via floatplane, boat, or the Hoonah forest road system.

Fifteen outfitter/guides reported use in this area from 2013 to 2017, three of which used the area regularly 

(4 out of 5 years). An annual average of about 1,389 service days were reported over this period. Use 

has, however, increased over recent years, with reported service days increasing from 178 (2013) to 

2,235 and 2,468 in 2016 and 2017, respectively (Table 3.10-5).

Road-based nature tours accounted for more than three-quarters (78 percent) of reported use, followed 

by hiking (9 percent) and freshwater fishing (8 percent). Use was reported at 14 locations, with Upper 

Game Creek accounting for almost half (45 percent) of reported service days, followed by Kennel Creek 

(23 percent) and Freshwater Bay (13 percent).
Environment and Effects 3

Final EIS 3-210 Recreation and Tourism

The Freshwater Bay use area includes about 47,200 acres of lands in development LUDs not currently 

classified as roadless, with about 16,600 acres of suitable old-growth available for harvest and 12,400 

acres of suitable young growth (Table 3.10-11). Existing suitable old-growth and young-growth acres are 

located along the existing road systems in the area with almost half (46 percent) of the non-roadless 

portion of the area considered suitable and available for harvest.

The number of roadless acres in the Freshwater Bay use area would decrease under all of the action 

alternatives with decreases ranging from about 1,300 acres (Alternative 2) to 97,500 acres under 

Alternative 6, which would remove regulatory roadless prohibitions from all lands. Alternative 5 would 

remove roadless designation for about 49,400 acres, with a similar reduction under Alternative 4 (49,400 

acres), if acres designated as Timber Priority ARA are included with those removed.

Table 3.10-11

Change in Roadless Area, Development LUDs without Roadless Designation, and 

Suitable Timber by Alternative for the Freshwater Bay Outfitter/Guide Use Area

Management Type

Total Acres Change from Alternative 1 (acres)

Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

Roadless Area1, 2 97,513 -1,319 -11,085 -11,714 -49,438 -97,513

Development LUDs – Not Roadless2 47,176 1,667 10,737 10,737 49,119 49,120

Suitable Old Growth 16,587 530 3,646 12,120 12,236 12,236

Suitable Young Growth 12,373 171 196 316 363 1,205

Old-Growth Harvest 718 0 38 -39 -67 -67

Young-Growth Harvest 10,534 -204 -293 -200 -215 368

Notes:

1 Changes in roadless area acres for Alternative 3 include LUD II acres, which would be removed from roadless classification, but 

would still be managed in a roadless condition.

2 Roadless acres managed as Timber Priority ARA under Alternative 4 are included in the roadless area total and excluded from 

the development LUD total, which has the effect of understating the changes in these categories.

The total number of acres in development LUDs outside of roadless would increase under all alternatives 

with gains ranging from about 1,700 acres (Alternative 2) to 49,100 (Alternatives 5 and 6). Increases in 

suitable old-growth acres available for harvest would range from about 550 acres (Alternative 2) to more 

than 12,000 acres (Alternatives 4 to 6). Suitable young-growth acres available for harvest would increase 

under all alternatives, with the largest increase (about 1,200 acres) under Alternative 6 (Table 3.10-11). 

Suitable old-growth acres would be added throughout the area under Alternatives 4 to 6. Harvest of 

existing suitable old-growth and young-growth acres under all of the alternatives would conflict with 

outfitter/guide use in the area. The old-growth acres that would be added under Alternatives 4 to 6 could 

potentially exacerbate these impacts if harvest were to occur in these areas. 

However, only limited old-growth harvest is projected to occur over the next 100 years under all of the 

alternatives, with estimated harvest totals ranging from about 650 acres (Alternatives 5 and 6) to 750 

acres (Alternative 3) (Table 3.10-11). An estimated 10,500 acres of young growth are projected to be 

harvested over the next 100 years under Alternative 1, with minor changes in projected harvest acres 

expected under all five action alternatives, ranging from a drop of about 300 acres (Alternative 3) to an 

increase of around 400 acres (Alternative 6) (Table 3.10-11).

04-12 Tenakee Inlet

The Tenakee Inlet outfitter/guide use area is located on the Sitka and Hoonah Ranger Districts and 

consists of 312,435 acres, 79 percent of which are located in IRAs (Table 3.10-5). This use area 

encompasses the central and eastern portions of Chichagof Island that surround Tenakee Inlet, as well 

as the lands adjacent to Chatham Strait from the mouth of Tenakee Inlet south to Florence Bay.

Sixteen outfitter/guides reported use in this area from 2013 to 2017, with none using the area more than 3 

out of 5 years. Reported use has increased in recent years, jumping from 95 service days in 2013 to 407 

in 2017, for a 5-year annual average of 186 service days (Table 3.10-5). Hiking accounted for almost half 

(47 percent) of reported use, followed by brown bear hunting (33 percent) and remote-setting nature tours 
Environment and Effects 3

Final EIS 3-211 Recreation and Tourism

(10 percent). Use was reported at more than 20 locations, with much of the use reported at the bays on 

the south side of Tenakee Inlet. Seal Bay received the most use (29 percent of total service days), 

followed by Corner Bay (20 percent) and Basket Bay (10 percent).

The Tenakee Inlet use area includes about 47,500 acres of lands in development LUDs outside of 

roadless, with about 13,300 acres identified as suitable for old-growth harvest and 10,100 acres suitable 

for young-growth harvest (Table 3.10-12). Existing suitable old-growth and young-growth acres are 

located along the existing road systems that are excluded from the Chichagof IRA (IRA 311).

The number of roadless designated acres in Tenakee Inlet would increase under Alternative 2, with a net 

gain of approximately 7,900 acres, about 2 percent of the total use area. The number of acres with 

roadless designation would decrease under the other action alternatives. Alternative 5 would remove 

roadless designation from about 104,400 acres, and Alternative 6 would remove regulatory roadless 

prohibitions from all lands, approximately 247,600 acres.

Table 3.10-12

Change in Roadless Area, Development LUDs without Roadless Designation, and 

Suitable Timber by Alternative for the Tenakee Inlet Outfitter/Guide Use Area

Management Type

Total Acres Change from Alternative 1 (acres)

Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

Roadless Area1, 2 247,557 7,869 -47,029 -16,774 -104,363 -247,557

Development LUDs – Not Roadless2 47,494 -7,562 2,825 11,844 104,096 104,100

Suitable Old Growth 13,299 -1,348 1,736 11,727 11,735 11,736

Suitable Young Growth 10,114 94 94 95 140 174

Old-Growth Harvest 581 1 90 -78 -99 -99

Young-Growth Harvest 8,610 -204 -294 -297 -302 -351

Notes:

1 Changes in roadless area acres for Alternative 3 include LUD II acres, which would be removed from roadless classification, but 

would still be managed in a roadless condition.

2 Roadless acres managed as Timber Priority ARA under Alternative 4 are included in the roadless area total and excluded from 

the development LUD total, which has the effect of understating the changes in these categories.

The total number of acres in development LUDs without roadless designation would decrease by about 

7,600 acres under Alternative 2. Increases in development LUDs outside of roadless for the other 

alternatives would range from about 2,800 acres (Alternative 3) to about 104,100 acres (Alternatives 5

and 6). Changes in suitable old-growth acres available for harvest would range from a drop of 1,350 

acres (Alternative 2) to increases of more than 11,700 acres (Alternatives 4 to 6). Suitable old-growth 

acres would mainly be added to areas in and around existing roads, extending the areas of existing 

suitable old-growth available for harvesting. The action alternatives would each add less than 150 acres 

of suitable young-growth.

Suitable old-growth acres would be added in the vicinity of Basket Bay and Corner Bay, both of which 

receive relatively high levels of reported outfitter/guide use. Suitable old-growth acres would also be 

added south of Crab Bay, another area with reported outfitter/guide use, under Alternatives 4 to 6. These 

additions would extend existing areas of suitable acres that are presently available for harvest. Harvest of 

these areas under all of the alternatives, including Alternative 1, would have the potential to conflict with 

existing outfitter/guide use, but particularly under Alternatives 4 to 6, which would increase suitable oldgrowth acres by 87 percent.

However, only very limited old-growth harvest is projected to occur in this area over the next 100 years 

under all of the alternatives, with estimated harvest totals ranging from about 400 acres (Alternatives 5 

and 6) to 700 acres (Alternative 3) (Table 3.10-12). An estimated 8,600 acres of young-growth are 

projected to be harvested over the next 100 years under Alternative 1, with decreases in projected 

harvest acres expected under all five action alternatives, ranging from drops of about 200 acres 

(Alternative 2) to 350 acres (Alternative 6) (Table 3.10-12).
Environment and Effects 3

Final EIS 3-212 Recreation and Tourism

04-13 Peril Strait

The Peril Strait outfitter/guide use area is located on the Sitka Ranger District and consists of 232,130 

acres, 72 percent of which are located in IRAs (Table 3.10-5). This use area encompasses the southern 

end of Chichagof Island surrounding Hoonah Sound and Peril Strait, from near Sergius Point to Point 

Hayes. Access to the shoreline along Hoonah Sound and Peril Strait is dictated by weather conditions 

and tidal flow.

Twenty-one outfitter/guides reported use in this area from 2013 to 2017, eight of which used the area 

regularly (4 out of 5 years). An annual average of 1,179 service days were reported over this period 

(Table 3.10-5). Hiking accounted for more than half (58 percent) of reported use, followed by freshwater 

fishing (15 percent), brown bear hunting (9 percent), and road-based nature tours (9 percent). Use was 

reported at more than 30 locations, with about one-third of service days reported at Sitkoh Bay, Sitkoh 

Creek, and Sitkoh Lake on the south end of Chichagof Island. Relatively high use was also reported for 

Eammon Island (18 percent of total service days), Deep Bay, Sergius Narrows (11 percent), and the 

False Island Road System (10 percent).

The Peril Strait use area includes 49,400 acres of lands in development LUDs outside of roadless, with 

about 3,000 acres identified as suitable for old-growth harvest and 9,000 acres suitable for young-growth 

harvest (Table 3.10-13). Existing suitable old-growth and young-growth acres are mainly located along 

the existing road systems at the south end of Chichagof Island, and further northwest around two existing 

roads on the north shore of Peril Strait.

Table 3.10-13

Change in Roadless Area, Development LUDs without Roadless Designation, and 

Suitable Timber by Alternative for the Peril Strait Outfitter/Guide Use Area

Management Type

Total Acres Change from Alternative 1 (acres)

Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

Roadless Area1, 2 168,913 19,926 -64,777 -1,120 -53,059 -168,913

Development LUDs – Not Roadless2 49,419 -17,470 -17,464 712 52,386 52,391

Suitable Old Growth 2,998 28 28 1,537 2,536 2,536

Suitable Young Growth 9,063 99 99 126 129 188

Old-Growth Harvest 313 -2 -50 -30 18 18

Young-Growth Harvest 7,716 -171 -251 -233 -268 -288

Notes:

1 Changes in roadless area acres for Alternative 3 include LUD II acres, which would be removed from roadless classification, 

but would still be managed in a roadless condition.

2 Roadless acres managed as Timber Priority ARA under Alternative 4 are included in the roadless area total and excluded 

from the development LUD total, which has the effect of understating the changes in these categories.

The number of designated roadless acres in the Peril Strait use area would increase under Alternative 2, 

with an estimated net gain of approximately 19,900 aces, about 12 percent of the total use area. The 

number of acres with roadless designation would decrease under the other action alternatives. Alternative 

5 would remove roadless designation from about 53,100 acres, and Alternative 6 would remove 

regulatory roadless prohibitions from all lands, approximately 168,900 acres (Table 3.10-13).

The total number of acres in development LUDs without roadless designations would decrease by almost 

17,500 acres under Alternatives 2 and 3. Increases in development LUDs outside of roadless for the other 

alternatives would range from about 700 acres (Alternative 4) to about 52,400 acres (Alternatives 5 and 6). 

Changes in suitable old-growth acres available for harvest would range from about 30 acres (Alternatives 2 

and 3) to about 2,550 acres (Alternatives 5 and 6). Suitable old-growth acres would mainly be added in areas 

in and around existing roads, extending the areas of existing suitable old-growth available for harvesting. The 

action alternatives would each add less than 200 acres of suitable young-growth.

Suitable old-growth acres would be added south of Sitkoh Lake, on the north side of the False Island road 

system, and around the existing roads further northwest on the north shore of Peril Strait under 

Alternatives 4 to 6. These additions would extend existing areas of suitable acres that are presently 
Environment and Effects 3

Final EIS 3-213 Recreation and Tourism

available for harvest. Harvest of these areas under Alternatives 4 to 6 would have the potential to conflict 

with existing outfitter/guide use.

However, only very limited old-growth harvest is projected to occur in this area over the next 100 years 

under all of the alternatives, with estimated harvest totals ranging from about 260 acres (Alternative 3) to 

330 acres (Alternatives 5 and 6) (Table 3.10-13). An estimated 7,700 acres of young-growth are projected 

to be harvested over the next 100 years under Alternative 1, with decreases in projected harvest acres 

expected under all five action alternatives, ranging from drops of about 200 acres (Alternative 2) to 300 

acres (Alternative 6) (Table 3.10-13).

CRD 00 Craig Ranger District

The CRD 00 outfitter/guide use area, which consists of the entire Craig Ranger District, encompasses 

about 926,000 acres, 77 percent of which are located in IRAs (Table 3.10-5). The Craig Ranger District is 

located on the southern half of Prince of Wales Island, the largest island in Southeast Alaska. Prince of 

Wales Island has the most extensive road system in Southeast Alaska, ranging from paved scenic 

byways to logging roads that require four-wheel drive. These roads provide access to numerous areas 

with opportunities to fish, hike, camp, hunt, boat, and view wildlife.

Twenty-one outfitter/guides reported use in this area from 2013 to 2017, five of which used the area 

regularly (4 out of 5 years). An annual average of 1,869 service days were reported over this period. Use 

in this area was noticeably lower in 2017 than in previous years, with just 926 reported service days, 

about half the annual average (Table 3.10-5). Wildlife viewing accounted for 85 percent of reported 

service days, followed by hunting (7 percent). Use was reported at 75 locations, with the Dog Salmon fish

pass wildlife viewing site and Polk Inlet accounting for 39 percent and 17 percent of service days, 

respectively. Reported use at Dog Salmon fish pass was mainly from 2014 to 2016; use at Polk Inlet was 

mainly reported in 2013.

The Craig Ranger District includes about 66,300 acres of lands in development LUDs outside of roadless, 

with about 12,900 acres of suitable old growth available for harvest and 17,000 acres of suitable young 

growth (Table 3.10-14). Existing suitable acres are located along the road systems throughout the nonroadless parts of the area, including areas near Dog Salmon fish pass and Polk Inlet. The Craig Ranger 

District use area includes Congressionally designated LUD II areas, as well the South Prince of Wales 

Wilderness.

Table 3.10-14

Change in Roadless Area, Development LUDs without Roadless Designation, and 

Suitable Timber by Alternative for the Craig Ranger District Outfitter/Guide Use Area

Management Type

Total Acres Change from Alternative 1 (acres)

Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

Roadless Area1, 2 735,240 -4,049 -157,633 -39,977 -268,322 -735,240

Development LUDs - Not 

Roadless2 66,339 16,393 37,161 41,389 244,548 256,527

Suitable Old Growth 12,932 4,312 9,921 14,856 15,847 15,851

Suitable Young Growth 16,958 2,916 3,929 3,937 4,093 4,242

Old-Growth Harvest 3,124 495 741 706 804 804

Young-Growth Harvest 14,461 1,928 2,579 2,578 2,618 2,582

Note:

1 Changes in roadless area acres for Alternative 3 include LUD II acres, which would be removed from roadless classification, 

but would still be managed in a roadless condition.

2 Roadless acres managed as Timber Priority ARA under Alternative 4 are included in the roadless area total and excluded 

from the development LUD total, which has the effect of understating the changes in these categories.

The number of roadless acres in the Craig Ranger District would decrease under all of the action 

alternatives with drops ranging from about 4,050 acres (Alternative 2) to about 735,200 acres under 

Alternative 6, which would remove regulatory roadless prohibitions from all lands. Alternative 5 would 

remove roadless designation from about 268,300 acres (Table 3.10-14).
Environment and Effects 3

Final EIS 3-214 Recreation and Tourism

The total number of acres in development LUDs outside of roadless would increase under all alternatives 

with gains ranging from about 16,400 acres (Alternative 2) to 256,500 acres (Alternative 6). Increases in 

suitable old-growth acres available for harvest would range from about 4,300 acres (Alternative 2) to 

about 14,900 to 15,850 acres (Alternatives 4 to 6), which would more than double the amount available. 

Increases in suitable young-growth acres would range from about 2,900 acres (Alternative 2) to about 

4,250 acres (Alternative 6) (Table 3.10-14). Suitable acres would mainly be added in the north central 

part of the area, near the communities of Craig, Klawock, and Hollis in the Twelvemile and Soda Bay 

IRAs (IRAs 534 and 505), with smaller concentrations on the south part of Sumez Island and east of 

Cholmondeley Sound. These additions would expand the areas presently available for harvest in the 

vicinity of Dog Salmon fish pass and Polk Inlet. Harvest of suitable acres in the vicinity of these areas 

under all alternatives would have the potential to conflict with existing outfitter/guide use.

Projected old-growth harvest is estimated to range from 3,100 acres (Alternative 1) to almost 4,000 acres 

(Alternatives 3 to 6). Young-growth harvest is projected to range from 14,500 acres (Alternative 1) to 

about 17,000 acres (Alternatives 3 to 6) (Table 3.10-14).

K19 North Revilla

The North Revilla outfitter/guide use area is located on the Ketchikan Misty Fjords Ranger District and 

consists of 70,400 acres, 83 percent of which are located in IRAs (Table 3.10-5). The North Revilla area 

encompasses the northern, non-wilderness portion of Revillagigedo Island, including Hassler Island and 

Black Island.

Eight outfitter/guides reported use in this area from 2013 to 2017, five of which used the area regularly (4 

out of 5 years). An annual average of 213 service days were reported over this period (Table 3.10-5). 

Hiking accounted for most (82 percent) of reported use, followed by fishing (17 percent). Use was 

reported for three locations. Hiking use was reported at Klu Bay and the Orchard Lake Trail, with fishing 

reported at Orchard Lake.

The North Revilla use area includes about 9,400 acres of lands in development LUDs outside of roadless, 

with 2,200 acres identified as suitable for old-growth harvest and 2,300 acres suitable for young-growth 

harvest (Table 3.10-15). Existing suitable old-growth and young-growth acres occupy much of the nonroadless portions of this use area, including Hassler Island, along the south shoreline, and around 

Orchard Lake.

Table 3.10-15

Change in Roadless Area, Development LUDs without Roadless Designation, and 

Suitable Timber by Alternative for the North Revilla Outfitter/Guide Use Area

Management Type

Total Acres Change from Alternative 1 (acres)

Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

Roadless Area1, 2 59,814 -426 -426 -427 -13,347 -59,814

Development LUDs – Not Roadless2 9,377 303 303 303 13,208 13,209

Suitable Old Growth 2,181 103 103 2,384 2,654 2,655

Suitable Young Growth 2,278 5 5 133 144 154

Old-Growth Harvest 262 -2 -51 266 256 256

Young-Growth Harvest 1,939 -59 -79 24 23 13

Notes:

1 Changes in roadless area acres for Alternative 3 include LUD II acres, which would be removed from roadless classification, 

but would still be managed in a roadless condition.

2 Roadless acres managed as Timber Priority ARA under Alternative 4 are included in the roadless area total and excluded from 

the development LUD total, which has the effect of understating the changes in these categories.

Changes in roadless area acres in North Revilla would be minimal under Alternatives 2 to 4, with roadless 

designation removed from less than 450 acres. This total increases to 9,600 for Alternative 4, if acres 

designated as Timber Priority ARA are included with those removed. Alternative 5 would remove roadless 

designation from about 13,350 acres, with Alternative 6 removing roadless designation from all lands in 

existing IRAs, approximately 59,800 acres (Table 3.10-15).
Environment and Effects 3

Final EIS 3-215 Recreation and Tourism

Alternatives 2 to 4 would have little effect on development potential, as measured by acres in 

development LUDs outside of roadless, with each alternative adding about 300 acres, about 3 percent of 

the existing total. Alternatives 5 and 6, on the other hand, would more than double existing development 

LUD acres without roadless designation, with a net increase of about 13,200 acres under each 

alternative. 

Changes in suitable old-growth acres available for harvest would range from about 100 acres 

(Alternatives 2 and 3) to an increase of about 2,400 to 2,650 acres under Alternatives 4 to 6, more than 

double the suitable old-growth acres under Alternative 1. Suitable old-growth acres would mainly be 

added on Black Island and north of the existing suitable acres on Revillagigedo Island. The action 

alternatives would each add less than 200 acres of suitable young growth. Harvest of existing suitable 

old-growth and young-growth acres under all of the alternatives would conflict with outfitter/guide use in 

this area. The old-growth acres that would be added under Alternatives 4 to 6 could potentially 

exacerbate these impacts if harvest to occur in these areas. However, only limited old-growth harvest is 

anticipated under all of the alternatives, with projected harvest over the next 100 years estimated to range 

from about 260 acres (Alternative 1) to 510 acres (Alternative 6). Projected young-growth harvest is not 

expected to vary much across the alternatives (Table 3.10-15).

P1 Mitkof Island

The Mitkof Island outfitter/guide use area is located on the Petersburg Ranger District and consists of 

109,300 acres, 32 percent of which are located in IRAs (Table 3.10-5). This use area encompasses all of 

Mitkof Island and includes the city of Petersburg.

Fifteen outfitter/guides reported use in this area from 2013 to 2017, five of which used the area regularly 

(4 out of 5 years). An annual average of about 928 service days were reported over this period (Table 

3.10-5). Hiking accounted for more than half (59 percent) of reported service days, followed by camping 

(9 percent) and remote-setting nature tours (15 percent). Use was reported at 11 locations, with the Ideal 

Cove Trail accounting for 71 percent of reported service days, followed by Point Alexander (13 percent).

The Mitkof Island use area includes about 57,000 acres of lands in development LUDs outside of 

roadless (slightly more than half the total area), with about 15,500 acres of suitable old-growth available 

for harvest and 9,800 acres of suitable young-growth (Table 3.10-16). Existing suitable old-growth and 

young-growth acres are located along the existing road systems through the center of the island, as well 

as along the roads that wrap around the south side of the Sumner Mountains.

Table 3.10-16

Change in Roadless Area, Development LUDs without Roadless Designation, and 

Suitable Timber by Alternative for the Mitkof Island Outfitter/Guide Use Area

Management Type

Total Acres Change from Alternative 1 (acres)

Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

Roadless Area1, 2 35,054 -286 -4,244 -4,376 -22,476 -35,054

Development LUDs – Not Roadless2 56,859 140 4,098 4,098 22,198 22,199

Suitable Old Growth 15,527 9 1,431 3,385 3,572 3,572

Suitable Young Growth 9,756 5 6 23 31 57

Old-Growth Harvest 3,588 -331 -704 -846 -866 -866

Young-Growth Harvest 8,306 -267 -352 -342 -376 -427

Notes:

1 Changes in roadless area acres for Alternative 3 include LUD II acres, which would be removed from roadless classification, 

but would still be managed in a roadless condition.

2 Roadless acres managed as Timber Priority ARA under Alternative 4 are included in the roadless area total and excluded 

from the development LUD total, which has the effect of understating the changes in these categories.

The number of roadless acres in the Mitkof Island use area would decrease under all of the action 

alternatives with drops ranging from less than 300 acres (Alternative 2) to about 35,000 acres under 

Alternative 6, which would remove regulatory roadless prohibitions from all lands. Alternative 5 would 

remove roadless designation from about 22,500 acres (Table 3.10-16).
Environment and Effects 3

Final EIS 3-216 Recreation and Tourism

The total number of acres in development LUDs outside of roadless would increase under all alternatives 

with gains ranging from less than 150 acres (Alternative 2) to 22,200 (Alternatives 5 and 6). Increases in 

suitable old-growth acres available for harvest would range from about 1,400 acres (Alternative 3) to 

about 3,400 acres (Alternative 4) and 3,600 acres (Alternatives 5 and 6). Suitable old-growth acres would 

be added to the timber base in three main locations under Alternatives 4 to 6, none of which would likely 

conflict with areas receiving relative high levels of existing outfitter/guide use. Further, projected oldgrowth harvest in this area is expected to drop relative to Alternative 1 under all of the action alternatives 

(Table 3.10-16).

Increases in suitable young-growth acres would be negligible (less than 60 acres) under all of the action 

alternatives, with projected young-growth harvest expected to drop under all five of the action 

alternatives.

P08 North Lindenberg Peninsula

The North Lindenberg Peninsula outfitter/guide use area is located on the Petersburg Ranger District and 

consists of 75,600 acres, 78 percent of which are located in IRAs (Table 3.10-5). Located on the north 

end of Kupreanof Island, this use area is bordered to the north and east by Frederick Sound and includes 

Portage Bay.

Twelve outfitter/guides reported use in this area from 2013 to 2017, three of which used the area regularly 

(4 out of 5 years). An annual average of 278 service days were reported over this period (Table 3.10-5). 

Camping accounted for more than three-quarters (76 percent) of reported service days, followed by 

remote-setting nature tours (9 percent). Use was reported at 11 locations, with locations around Portage 

Bay accounting for 46 percent of reported service days, followed by Five Mile Creek (29 percent).

The North Lindenberg Peninsula use area includes about 13,500 acres of lands in development LUDs 

outside of roadless, with about 4,700 acres of suitable old-growth available for harvest and 3,700 acres of 

suitable young growth (Table 3.10-17). Existing suitable old-growth and young-growth acres are located 

along the existing roads on the east side of Portage Bay.

The number of roadless acres in the North Lindenberg Peninsula use area would decrease under all of 

the action alternatives with drops ranging from 10,700 acres (Alternative 2) to about 59,000 acres under 

Alternative 6, which would remove regulatory roadless prohibitions from all lands. Alternative 5 would 

remove roadless designation from about 49,000 acres (Table 3.10-17).

Table 3.10-17

Change in Roadless Area, Development LUDs without Roadless Designation, and 

Suitable Timber by Alternative for the North Lindenberg Peninsula Outfitter/Guide Use 

Area

Management Type

Total Acres Change from Alternative 1 (acres)

Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

Roadless Area1, 2 59,007 -10,681 -28,098 -28,123 -48,981 -59,007

Development LUDs – Not Roadless2 13,525 10,157 24,318 24,335 48,445 48,446

Suitable Old Growth 4,661 3,263 7,320 8,770 8,862 8,862

Suitable Young Growth 3,685 742 756 756 804 815

Old-Growth Harvest 1,263 549 829 743 723 723

Young-Growth Harvest 3,137 509 481 479 500 475

Notes:

1 Changes in roadless area acres for Alternative 3 include LUD II acres, which would be removed from roadless classification, but 

would still be managed in a roadless condition.

2 Roadless acres managed as Timber Priority ARA under Alternative 4 are included in the roadless area total and excluded from 

the development LUD total, which has the effect of understating the changes in these categories.

The total number of acres in development LUDs without roadless designation would increase under all 

alternatives with gains ranging from about 10,150 acres (Alternative 2) to 48,450 (Alternatives 5 and 6). 

Increases in suitable old-growth acres available for harvest would range from about 3,300 acres 
Environment and Effects 3

Final EIS 3-217 Recreation and Tourism

(Alternative 2) to about 8,800 to 8,900 acres (Alternatives 4 to 6) (Table 3.10-17). Old-growth acres would 

be added throughout the area under Alternatives 4 to 6. Increases in suitable young growth acres would 

range from about 750 to 800 acres under all of the action alternatives. Harvest of existing suitable oldgrowth and young-growth acres under all alternatives (including Alternative 1) would conflict with 

outfitter/guide use in the area. The old-growth acres that would be added under Alternatives 4 to 6 could 

potentially exacerbate these impacts if harvest were to occur in these areas. Projected old-growth harvest 

in this area is estimated to increase relative to Alternative 1 under all of the action alternatives, with 

increases ranging from about 550 acres (Alternative 2) to 830 acres (Alternative 3). Projected younggrowth harvest would also increase under all of the action alternatives (Table 3.10-17).

P12B Kuiu Island Road System

The Kuiu Island Road System outfitter/guide use area is located on the Petersburg Ranger District and 

consists of 134,850 acres, 31 percent of which are located in IRAs (Table 3.10-5). The Kuiu Island Road 

System area is located on the north end of Kuiu Island. The area includes the mainline and spur roads on 

Kuiu Island. Roads extend to Saginaw Bay, Security Bay, Rowan Bay, Bay of Pillars, Port Camden, and 

Three Mile Arm.

Nine outfitter/guides reported use in this area from 2013 to 2017, five of which used the area regularly (4 

out of 5 years). An annual average of about 139 service days were reported over this period (Table 3.10-

5). Hunting, mainly for black bear, and camping each accounted for about one-third (33 percent and 32 

percent, respectively) of reported service days, followed by freshwater fishing (26 percent). Use was 

reported at 13 locations, with Kadake Creek and Port Camden each accounting for slightly more than 

one-quarter (26 percent) of reported service days, with various locations along the road system making 

up 24 percent.

The Kuiu Island Road System use area includes about 77,000 acres of lands in development LUDs 

outside of roadless, with about 14,750 acres of suitable old-growth available for harvest and 19,600 acres 

of suitable young-growth (Table 3.10-18). Existing suitable old-growth acres are located in the center of 

the area and north of Rowan Bay. Existing young-growth acres are distributed along the existing road 

system throughout the area.

The number of roadless acres in the Kuiu Island Road System use area would increase under Alternative 

2 (2,500 acres) and decrease under the other action alternatives, with drops ranging up to about 41,400 

acres under Alternative 6, which would remove regulatory roadless prohibitions from all lands. Alternative 

5 would remove roadless designation from about 30,900 acres (Table 3.10-18).

Table 3.10-18

Change in Roadless Area, Development LUDs without Roadless Designation, and 

Suitable Timber by Alternative for the Kuiu Island Road System Outfitter/Guide Use 

Area

Management Type

Total Acres Change from Alternative 1 (acres)

Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

Roadless Area1, 2 41,428 2,529 -4,458 -8,197 -30,932 -41,428

Development LUDs – Not Roadless2 76,994 -2,558 4,425 7,913 30,622 30,622

Suitable Old Growth 14,741 -1,351 1,049 4,247 4,248 4,248

Suitable Young Growth 19,585 0 2 25 34 49

Old-Growth Harvest 4,025 -738 -899 -736 -797 -797

Young-Growth Harvest 16,673 -545 -716 -704 -778 -910

Notes:

1 Changes in roadless area acres for Alternative 3 include LUD II acres, which would be removed from roadless classification, 

but would still be managed in a roadless condition.

2 Roadless acres managed as Timber Priority ARA under Alternative 4 are included in the roadless area total and excluded from 

the development LUD total, which has the effect of understating the changes in these categories.

The total number of acres in development LUDs outside of roadless would decrease under Alternative 2, 

by about 2,600 acres. Increases in development LUD acres outside of roadless under the other action 
Environment and Effects 3

Final EIS 3-218 Recreation and Tourism

alternatives would range up to about 30,600 acres (Alternatives 5 and 6). Total suitable old-growth acres 

would decrease under Alternative 2, dropping by about 1,350 acres. Increases under the other action 

alternatives would range from about 1,050 acres (Alternative 3) to 4,250 acres (Alternatives 4 to 6). 

Increases in suitable young-growth would be about 50 acres or less under all alternatives. 

Suitable old-growth acres would mainly be added in the north central and southwest parts of this area. 

Harvest of existing suitable old-growth and young-growth acres under all alternatives would conflict with 

existing outfitter/guide use in this use area. An estimated 4,000 old-growth acres are projected to be 

harvested in this area over 100 years under Alternative 1. Projected old-growth harvest acres in this area 

are estimated to decrease relative to Alternative 1 under all five of the action alternatives. Projected 

young-growth harvest is estimated to decrease relative to Alternative 1 under all five alternatives, with 

drops ranging from about 550 acres (Alternative 2) to 900 acres (Alternative 6) (Table 3.10-18).

P21 Muddy River Area

The Muddy River Area outfitter/guide use area is located on the Petersburg Ranger District and consists 

of 63,357 acres, 68 percent of which are located in IRAs (Table 3.10-5). The Muddy River Area is located 

on the mainland east of Frederick Sound. The area includes the Thomas Bay road system, Patterson 

River, Muddy River, Point Agassiz, and a portion of Thomas Bay.

Eight outfitter/guides reported use in this area from 2013 to 2017, three of which used the area regularly 

(4 out of 5 years). An annual average of 347 service days were reported over this period (Table 3.10-5). 

Hiking accounted for more than three quarters (78 percent) of reported use, followed by camping (9 

percent). Use was reported for seven locations, with relatively high use identified for Patterson River (62 

percent), followed by Ruth Island, Thomas Bay (23 percent). Service days reported for Patterson River 

were mainly hiking, with some mountain goat hunting use also reported.

The Muddy River Area includes about 16,650 acres of lands in development LUDs outside of roadless, 

with about 2,900 acres identified as suitable for old-growth harvest and 4,200 acres suitable for younggrowth harvest (Table 3.10-19). Existing suitable old-growth and young-growth acres are located along 

the existing road system and extend south along the Muddy River and Crystal Creek drainages reflecting 

past harvest in the area. Suitable old-growth acres are also located on Point Agassiz Peninsula and Deer 

Island.

Table 3.10-19

Change in Roadless Area, Development LUDs without Roadless Designation, and 

Suitable Timber by Alternative for the Muddy River Outfitter/Guide Use Area

Management Type

Total Acres Change from Alternative 1 (acres)

Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

Roadless Area1, 2 43,101 -233 -7,917 -7,924 -28,919 -43,101

Development LUDs – Not Roadless2 16,651 236 7,796 7,796 28,713 28,713

Suitable Old Growth 2,891 115 3,180 6,764 6,772 6,772

Suitable Young Growth 4,218 0 0 0 0 13

Old-Growth Harvest 617 -28 356 805 780 780

Young-Growth Harvest 3,591 -117 -154 -156 -173 -194

Notes:

1 Changes in roadless area acres for Alternative 3 include LUD II acres, which would be removed from roadless classification, 

but would still be managed in a roadless condition.

2 Roadless acres managed as Timber Priority ARA under Alternative 4 are included in the roadless area total and excluded 

from the development LUD total, which has the effect of understating the changes in these categories.

Decreases in roadless area acres in the Muddy River Area would range from about 200 acres (Alternative 

2) to about 43,100 acres under Alternative 6, which would remove regulatory roadless prohibitions from 

all lands. Increases in development LUDs outside of roadless would range up to 28,700 acres 

(Alternatives 5 and 6). There would be no change in suitable young-growth acres by alternative. Changes 

in suitable old-growth acres available for harvest would range from about 100 acres (Alternative 2) to an 

increase of almost 6,800 acres (Alternatives 4 to 6) (Table 3.10-19).
Environment and Effects 3

Final EIS 3-219 Recreation and Tourism

Suitable old-growth acres would mainly be added in the south portion of the area. Harvest of existing suitable 

old-growth and young-growth acres under all alternatives (including Alternative 1) would conflict with 

outfitter/guide use in this area. The old-growth acres that would be added under Alternatives 4 to 6 could 

potentially exacerbate these impacts if harvest were to occur in these areas. Projected old-growth harvest is 

estimated to range from about 600 acres (Alternative 2) to 1,400 acres (Alternatives 4 to 6). Young-growth 

harvest is projected to decrease relative to Alternative 1 under all five action alternatives (Table 3.10-19).

TBRD 00 Thorne Bay Ranger District

The TBRD 00 outfitter/guide use area, which consists of the entire Thorne Bay Ranger District, 

encompasses about 901,500 acres, 40 percent of which are located in IRAs (Table 3.10-5). The Thorne 

Bay Ranger District is located on the northern half of Prince of Wales Island. The largest island in 

Southeast Alaska, Prince of Wales Island has an extensive road system that provides access to 

numerous areas with opportunities to fish, hike, camp, hunt, boat, and view wildlife. The Thorne Bay 

Ranger District is known for its cave systems and karst topography.

Twenty-seven outfitter/guides reported use in this area from 2013 to 2017, 11 of which used the area 

regularly (4 out of 5 years). An annual average of 1,239 service days were reported over this period. Use 

in this area was lower in 2017 than in previous years, with about 870 reported service days, slightly more 

than two-thirds of the annual average (Table 3.10-5). Freshwater fishing accounted for 43 percent of 

reported service days, followed by sightseeing (20 percent), and camping (13 percent) and remote-setting 

nature tours (13 percent). Use was reported at 65 locations, with the El Capitan Cave interpretative site 

accounting for 39 percent, followed by locations along Staney Creek (9 percent) and Thorne River (8

percent).

The Thorne Bay Ranger District includes about 327,000 acres of lands in development LUDs outside of 

roadless, with about 62,300 acres of suitable old-growth available for harvest and 127,000 acres of suitable 

young-growth (Table 3.10-20). Existing suitable acres are located along the road systems throughout the 

non-roadless parts of the area. The Thorne Bay Ranger District use area includes Congressionally 

designated LUD II areas, as well the Coronation Island, Warren Island, and Karta River Wildernesses.

Table 3.10-20

Change in Roadless Area, Development LUDs without Roadless Designation, and 

Suitable Timber by Alternative for the Thorne Bay Ranger District Outfitter/Guide Use 

Area

Management Type

Total Acres Change from Alternative 1 (acres)

Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

Roadless Area1, 2 364,798 -13,619 -193,327 -80,038 -133,003 -364,798

Development LUDs – Not Roadless2 326,652 12,415 60,737 61,064 127,126 127,126

Suitable Old Growth 62,326 3,114 14,383 20,349 21,299 21,299

Suitable Young Growth 126,994 1,241 1,296 1,351 1,353 1,560

Old-Growth Harvest 13,469 -752 -1,877 -2,643 -2,723 -2,723

Young-Growth Harvest 108,114 -2,512 -3,595 -3,593 -4,126 -4,903

Notes:

1 Changes in roadless area acres for Alternative 3 include LUD II acres, which would be removed from roadless classification, 

but would still be managed in a roadless condition.

2 Roadless acres managed as Timber Priority ARA under Alternative 4 are included in the roadless area total and excluded from 

the development LUD total, which has the effect of understating the changes in these categories.

The number of roadless acres in the Thorne Bay Ranger District would decrease under all of the action 

alternatives, with decreases ranging from about 13,600 acres (Alternative 2) to about 365,000 acres 

under Alternative 6, which would remove regulatory roadless prohibitions from all lands. Alternative 5 

would remove roadless designation for about 133,000 acres (Table 3.10-20).

The total number of acres in development LUDs outside of roadless would increase under all alternatives 

with gains ranging from about 12,400 acres (Alternative 2) to 127,100 acres (Alternatives 5 and 6). 

Increases in suitable old-growth acres available for harvest would range from about 3,100 acres 
Environment and Effects 3

Final EIS 3-220 Recreation and Tourism

(Alternative 2) to about 20,350 acres (Alternative 4) and 21,300 acres (Alternatives 5 and 6). Increases in 

suitable young-growth acres would range from about 1,200 to 1,600 acres across all the action 

alternatives (Table 3.10-20). Suitable old-growth acres would be added throughout the area, with larger 

additions near Klawock in the Kogish IRA (IRA 509) and Karta IRA (IRA 510), with relatively large gains in 

the northwest part of the area in the El Capitan IRA (IRA 517). These additions are not expected to 

conflict with outfitter/guide use at the most visited locations in this use area because changes are not 

proposed in those areas. In addition, both projected old-growth and young-growth harvest acres are 

estimated to decrease relative to Alternative 1 under all five action alternatives (Table 3.10-20).

Cumulative Effects

This section considers the incremental effects of the alternatives when added to other past, present, and 

reasonably foreseeable actions. The effects of past and present actions on recreation are included in the 

Affected Environment portion of this section, which discusses current recreation facilities and activities on 

the Tongass. Past actions include past timber harvest and road building that has facilitated roaded 

recreation and changed ROS settings, as well as the development of recreation facilities, such as cabins, 

campgrounds, interpretive sites, and visitor centers. Present actions include the impacts of current 

management policies on existing recreation patterns, particularly those that are authorized by special use 

permits. For outfitter/guide use, recent and reasonably foreseeable actions include ongoing capacity 

determinations and use allocations on many Ranger Districts (USDA Forest Service 2009b, 2009c, 

2012d, 2012e, 2017e). Some use areas are currently at capacity, which could serve to exacerbate 

potential displacement effects from long-term changes in roadless area management.

The number of cruise ship passengers visiting the region remains a significant source of current and 

future recreation demand on the Tongass. Current recreation patterns on the Tongass also reflect past 

timber harvest and road building activities on adjacent private and Alaska Native corporation lands, as 

well as wildland recreation opportunities on federal- and state-managed lands elsewhere in the region.

Reasonably foreseeable actions on NFS lands include the projected levels of future timber harvest and 

other developments that are used in the preceding analysis to assess the potential impacts of the 

alternatives on the supply of recreation opportunities, recreation use, and commercial outfitter/guide use. 

Other reasonably foreseeable actions include regional transportation development as defined by the 

State Transportation Plan and the Forest Service Alaska Region Long Range Transportation Plan, as well 

as road paving on Prince of Wales Island, the closing of roads, and construction of the Angoon Airport. In 

addition, the expansion of cities like Juneau, Ketchikan, and Sitka, recreational cabin development, land 

auctions by the State, and land adjustments could include additional road construction, timber harvest, 

and facility construction. It is not possible at this time to predict exactly which roads would be developed or 

their likely impact on future recreation patterns. 

Reasonably foreseeable future actions also include an expected growth in recreation and tourism 

businesses, as well as the development of additional fishing and other lodges. This type of development 

would facilitate additional recreation and tourism in the region and on the Forest. Human settlement 

expansion around the region’s larger cities, as well as residential expansion that could potentially result 

from state land auctions, would likely result in increased demand for a range of recreation activities, with 

some developments favoring developed recreation opportunities, and others more dependent on 

undeveloped lands. Mining activities are expected to expand at existing sites, including Greens Creek on 

Admiralty Island and Kensington Gold Mine north of Juneau, as well as possible future sites, including the 

Bokan Mountain and Niblack sites on the southern end of Prince of Wales Island. Mining projects are for 

the most part expected to have a negative effect on recreation activities, because most recreational 

activities are incompatible with these types of land use.
Environment and Effects 3

Final EIS 3-221 Scenery

Scenery

Affected Environment

The Tongass offers a variety of scenery to its visitors, from mountain ranges and the glaciers of the 

mainland to low-lying marine landscapes composed of intricate waterways, bays, and island groups. The 

Forest is viewed from a variety of vantage points, including the communities of Southeast Alaska, the 

Alaska Marine Highway ferry route, cruise ship routes, existing road systems, popular small boat routes 

and anchorages, developed recreation sites and facilities, and hiking trails. Visitor-related flight seeing via 

small aircraft is increasing in popularity and provides aerial views of the forest landscape.

The Forest Service developed a Visual Management System (VMS) in 1974 to integrate aesthetic 

considerations into large-scale resource management decisions. Due to advances in technology, as well 

as the increased demand for high-quality scenery, the Scenery Management System (SMS) was released 

in 1996. The SMS integrates the increased understanding of ecosystem processes and cultural 

landscapes in identifying the effects of various management practices on scenic resources. The SMS was 

used in this analysis to inventory existing scenic resources, provide measurable scenic quality 

management objectives for each portion of the landscape, and estimate the landscape’s sensitivity based 

on the visibility from priority travelways and use areas.

To apply the SMS to the Forest, a viewshed analysis of the entire Tongass was completed using the 

Tongass Geographic Information System (GIS) and is described in the Scenery section of the 2016 

Forest Plan Amendment EIS (USDA Forest Service 2016b). This viewshed analysis was completed 

separately for each Ranger District and was based on the viewsheds of selected points along Visual 

Priority Routes and Use Areas. The analysis included identification of distance zones, which were 

subsequently overlaid with the LUDs to generate the Scenic Integrity Objectives (SIOs) (refer to the 

Forest-wide standards and guidelines in the Forest Plan for details on how SIOs were determined for 

each LUD).

Existing Scenic Integrity

The existing scenic resources of the Tongass encompass everything from vast tracts unmodified by 

human activity to areas of heavily modified landscapes. Existing Scenic Integrity (ESI) ratings are used by 

the Forest Service to analyze the degree of intactness of the landscape character. These ratings are used 

to categorize the degree of alteration visible in the landscape on a continuum from a natural setting to a 

heavily altered landscape. The ratings apply to the broad landscape affected, not just the acres altered. 

As described below, ESI ratings range over six levels of integrity, from Very High to Unacceptably Low.

Very High—Landscapes where the valued landscape character is intact with only minute deviations, 

if any. The existing landscape character and sense of place is expressed at the highest possible level.

High—Landscapes where the valued landscape character appears intact. Deviations may be 

present, but must repeat the form, line, color, texture, and pattern common to the landscape 

character so completely and at such scale that they are not evident.

Moderate—Landscapes where the valued landscape character appears slightly altered. Noticeable 

deviations must remain visually subordinate to the landscape character being viewed.

Low—Landscapes where the valued landscape character appears moderately altered. Deviations 

begin to dominate the valued landscape character being viewed, but they borrow valued attributes 

such as size, shape, edge effect and pattern of natural openings, vegetative type changes or 

architectural styles outside the landscape being viewed. They should not only appear as valued 

character outside the landscape being viewed, but compatible or complementary to the character 

within.

Very Low—Landscapes where the valued landscape character appears heavily altered. Deviations 

may strongly dominate the valued landscape character. They may not borrow from valued attributes 
Environment and Effects 3

Final EIS 3-222 Scenery

such as size, shape, edge effect and pattern of natural openings, vegetative type changes, or 

architectural styles within or outside the landscape being viewed.

Unacceptably Low—Landscapes where the valued landscape character being viewed appears 

extremely altered. Deviations are extremely dominant and borrow little if any form, line, color, texture, 

pattern or scale from the landscape character.

Table 3.16-1 in the 2016 Forest Plan Amendment EIS (USDA Forest Service 2016b) displays the percent 

of acres of each ESI for the Tongass. A breakdown between “seen” and “seldom seen” areas is 

presented. Seen areas are those areas that can be viewed in the foreground, middleground, or 

background from inventoried Visual Priority Routes and Use Areas with a concern level of 1 or 2, the 

travelways and use areas with the highest number of users. Seldom seen areas are all the rest of the 

Forest. The ESI for wilderness is also included in this table. Approximately 88 percent of the Tongass is 

rated as a Very High ESI, which is a visually unaltered condition. About 10 percent of the land is rated as 

Low, Very Low, or Unacceptably Low, which indicates noticeable development activity. The remainder of 

the Forest is rated as High or Moderate. Some of the wilderness acres have a High or lower rating. This is 

mostly due to the landscape effect of developments adjacent to wilderness and past development 

activities within wildernesses.

Under the Forest Plan, all land has a designated LUD, which guides the types and intensity of 

development actions. The LUDs designate the SIOs for each area, which define the degree to which the 

natural landscape can be altered, and provide guidelines for timber harvest, road building, and other 

activities to ensure they are conducted in a way that allows the scenic objectives to be achieved. A LUD 

may have different SIOs depending on the distance zone (foreground, middleground, background) in 

which the development activity is to take place.

SIOs are classified using the same terms outlined above for ESI: Very High, High, Moderate, Low, and 

Very Low. The Unacceptably Low rating is only used to inventory existing conditions and cannot be used 

as a management objective.

The current adopted SIOs for all land within the Tongass are displayed in Table 3.11-1. This table 

separates the percent of acres of each SIO into five categories: foreground, middleground, 

background, seldom seen, and other (municipal watersheds and non-wilderness national monuments 

where the SIO is determined on a project-by-project basis). The Very High SIO is typically assigned

to wilderness; however, it is not used for Tongass wilderness because of the potential alterations 

allowed under the Alaska National Interest Lands Conservation Act (ANILCA). The vast majority of 

wilderness acreage will be managed through the specific wilderness plans with a Very High SIO. 

Thus, over 60 percent of the Tongass is to be managed at the High or Very High Scenic Integrity

level.

Demand for scenic quality can be represented by the increase in visitor-related travel to the Tongass, 

as well as a heightened awareness and sensitivity of Alaskan residents to scenic resource values. 

This results in a strong indirect connection between scenic resource values and the economy of 

Southeast Alaska. For example, Southeast Alaska’s Inside Passage is advertised and promoted by 

the Alaska Department of Commerce, cruise ship operators, and the Southeast Alaska Tourism

Council. Their marketing strategy focuses on the scenery of the Tongass as a major attraction. The 

visitors to Southeast Alaska arrive with expectations and an image of the environment and scenery 

awaiting them. If recent trends continue, demand for viewing scenic landscapes will increase. A report 

published by the Alaska Department of Community and Economic Development shows that the 

largest number of visitors (1.96 million) for 2013-2014 was 5,000 more than the last record set in 

2007-2008. This increase also represents a 6 percent increase over 2012-2013.

Lands adjacent to the Alaska Marine Highway, cruise ship routes, flight-seeing routes, high-use 

recreation areas, and other marine and land-based travel routes will be seen by more people, more 

frequently, and for greater duration.
Environment and Effects 3

Final EIS 3-223 Scenery

Table 3.11-1

Adopted Scenic Integrity Objectives for the Tongass (percent)

Category

Scenic Integrity Objective

High Moderate Low Very Low Other Total 1

Foreground 7.6 3.6 1.4 0.0 0.5 13.1

Middleground 18.1 7.2 2.4 5.9 0.5 34.1

Background 0.8 0.4 0.0 0.1 0.0 1.4

Seldom seen 34.1 8.6 0.0 7.4 0.9 51.1

Unmapped 0.1 0.0 0.0 0.0 0.3 0.3

Total 60.6 19.8 3.9 13.5 2.2 100.0

1 Includes land in the Municipal Watershed and Non-wilderness National Monument LUDs. SIOs in these 

LUDs are to be determined on a project-by-project basis. Generally, the High SIO will be met. 

Source: USDA Forest Service, Tongass National Forest 2018 GIS. Numbers are not exact and may not 

sum correctly due to rounding.

Environmental Consequences

The Tongass has adopted specific management objectives for scenic resources (i.e., SIOs) for each LUD

in the Forest. The adopted SIOs indicate the desired or acceptable level of human-induced alteration to 

the valued landscape character. No changes in the SIOs or related Scenery standards and guidelines are 

proposed under any alternative. Harvest of old growth would follow the SIOs of the 2016 Forest Plan for 

all alternatives. However, the Forest Plan relaxes the SIOs for young-growth harvest to increase the 

availability of young growth, especially in the first few decades. In other words, all alternatives have 

reduced SIOs in viewsheds where young growth is to be harvested. As a result, the current SIO 

designated for the LUD in which young-growth harvest takes place is not likely to be met in many cases. 

In addition, currently two projects are proposing forest plan amendments for SIOs to ensure economical 

old-growth timber sales. The effects of these amendments are analyzed in the environmental documents 

specific to these projects, are limited in scope and scale to the project, and do not change the overall 

efficacy of the SIOs in achieving scenic resource objectives outlined in the Forest Plan for the planning 

unit.

Adopted SIOs can be thought of as an indicator of long-term cumulative effects. SIOs are adopted to 

provide a threshold for the amount of modification to the landscape during land-altering activities; 

therefore, land may have an adopted SIO of Low, but currently meet the High SIO.

The potential effects to the scenic resource are primarily described in the following two ways:

1. A display of acres of each SIO adopted for suitable young growth, along with LUD, for 

each alternative.

2. A display of the effects of each alternative on a selected group of key 

viewsheds throughout the Tongass (described below).

Indirect and Cumulative Forest-wide Effects

Changes in Scenic Integrity Objective Acres

The Forest Plan relaxes the SIOs for young-growth harvest to Very Low, no matter what the SIO is 

currently, in all development LUDs. However, young-growth harvest is also allowed in the Old-Growth 

Habitat LUD and there is no change in the SIO for this LUD (it would remain High). All alternatives would 

follow these same SIO definitions for young-growth harvest. Table 3.11-2 displays the acres of suitable 

young growth in each SIO that would result from the six alternatives.

Overall old-growth and young-growth harvest would be similar under all alternatives. However, the 

distribution of harvest acres would vary based on the locations of suitable forest land. As shown in Table 

3.11-2, the vast majority of young-growth harvest areas would have Very Low SIOs in all alternatives, 

which could result in adverse effects on scenery. The only variation from Very Low SIOs would occur for 
Environment and Effects 3

Final EIS 3-224 Scenery

young-growth harvest in Old-Growth Habitat LUDs. These harvest areas would have High SIOs. All 

alternatives would have similar percentages of High SIOs.

Table 3.11-2

Scenery Integrity Objectives for Suitable Young Growth by LUD and Alternative (percent)

SIO/LUD

Alternative

1 2 3 4 5 6

Very Low/Timber Production 60% 61% 61% 61% 61% 60%

Very Low/Modified Landscape 23% 23% 22% 22% 22% 22%

Very Low/Scenic Viewshed 5% 6% 6% 6% 6% 6%

High/Old-Growth Habitat 11% 11% 11% 11% 11% 12%

Total Young-Growth Suitable Acres 334,000 345,000 349,000 349,000 351,000 354,000

1 Consists of unmapped areas.

Note: Numbers are based on GIS estimates and are not exact due to rounding.

Effects on Selected Viewsheds

To help focus the visual effects on more familiar areas, the alternatives were analyzed by selected large 

viewsheds in the Tongass. These 23 viewsheds were selected for their popularity and intensity of public 

use and travel and are the same as those analyzed in the EIS associated with the 1997 Forest Plan 

(USDA Forest Service 1997a) and in the EISs associated with the 2008 and 2016 Forest Plan 

Amendment EIS (USDA Forest Service 2008b, 2016b). They technically represent a series of viewsheds 

along a travelway and take in entire VCUs. Table 3.11-3 compares suitable and projected harvest acres 

for young-growth and old-growth timber under the six alternatives for each of the viewsheds. The table 

also includes the total acres of each viewshed and the percent of each viewshed consisting of non-NFS 

lands. Acres that are seldom seen or unseen from any viewpoint along the travelway are excluded from 

the viewshed, which are displayed in Figure 3.11-1.

While the previous section of this effects analysis summarized overall effects by alternative, this section is 

intended to be a viewshed-specific assessment of effects. As such, it takes into account past harvest and 

represents a cumulative assessment of scenery effects. Listed below are some summary points that can 

be observed from the viewshed-specific assessment:

Three of the 23 viewsheds (Hyder/Salmon River Highway, Stephens Passage, and Mendenhall 

Glacier) include less than 500 acres of suitable young growth in all alternatives.

Six of the 23 viewsheds (Hyder/Salmon River Highway, Mendenhall Glacier, Stephens Passage, 

Ernest Sound, Lynn Canal, and Salmon Bay Lake) include less than 150 acres of suitable old growth 

in all alternatives.

In most viewsheds, the highest effects on scenery would be associated with Alternatives 5 and 6, 

followed in order by Alternatives 4, 3, 2, and 1.

Viewsheds with the highest potential for negative effects from young-growth harvest include Chatham 

Strait, Duncan Canal, Frederick Sound, Lynn Canal, and Stikine Strait, based on both the percent 

increase and the increase in acreage of young growth suitable and projected harvest relative to 

Alternative 1.

Viewsheds with the highest potential for negative effects from old-growth harvest include Duncan 

Canal, Eastern Passage, Frederick Sound, Stikine Strait, Tenakee Inlet to Tenakee Springs, and 

Zimovia Strait, based on both the percent increase and the increase in acreage of old growth suitable 

and projected harvest relative to Alternative 1.
Environment and Effects 3

Final EIS 3-225 Scenery

Table 3.11-3

Suitable/Projected Harvest (in acres) for Young Growth and Old Growth in Selected 

General Viewsheds 1,2

Viewshed and Category

Alternative

1 2 3 4 5 6

Behm Canal (West)

Suitable YG Acres by SIO & Dist. Zone

High SIO-Foreground/Middleground 803 803 804 804 803 846

Very Low SIO-Foreground/Middleground 8,114 8,114 8,114 8,115 8,127 8,127

Suitable OG Acres – All SIOs and Dist. Zones 8,223 8,279 8,469 9,205 9,420 9,420

Projected YG Harvest Acres in 

Foreground/Middleground over 100 Years

7,592 7,344 7,267 7,265 7,236 7,204

Projected OG Harvest Acres in 

Foreground/Middleground over 100 Years

1,628 1,489 1,237 1,192 1,170 1,170 

Total Acres in Viewshed (2% is Non-NFS) 48,956 48,956 48,956 48,956 48,956 48,956

Carroll Inlet

Suitable YG Acres by SIO & Dist. Zone

High SIO-Foreground/Middleground 86 90 90 90 90 91

Very Low SIO-Foreground/Middleground 7,026 7,312 7,312 7,312 7,312 7,312

Suitable OG Acres – All SIOs and Dist. Zones 6,288 7,154 9,110 9,756 9,756 9,756

Projected YG Harvest Acres in 

Foreground/Middleground over 100 Years

6,055 6,097 6,032 6,029 5,998 5,945

Projected OG Harvest Acres in 

Foreground/Middleground over 100 Years

1,559 1,626 1,686 1,543 1,514 1,514 

Total Acres in Viewshed (6% is Non-NFS) 52,422 52,422 52,422 52,422 52,422 52,422

Chatham Strait

Suitable YG Acres by SIO & Dist. Zone

High SIO-Foreground/Middleground 2,326 2,316 2,316 2,337 2,326 2,898

Very Low SIO-Foreground/Middleground 4,850 4,850 4,875 4,938 4,940 4,940

Suitable OG Acres – All SIOs and Dist. Zones 8,136 8,309 10,495 12,449 12,516 12,516

Projected YG Harvest Acres in 

Foreground/Middleground over 100 Years

6,109 5,902 5,860 5,925 5,896 6,293

Projected OG Harvest Acres in 

Foreground/Middleground over 100 Years

651 657 728 617 592 592 

Total Acres in Viewshed (4% is Non-NFS) 107,411 107,411 107,411 107,411 107,411 107,411

Cholmondeley Sound

Suitable YG Acres by SIO & Dist. Zone

High SIO-Foreground/Middleground 91 91 91 91 91 96

Very Low SIO-Foreground/Middleground 711 727 727 727 728 728

Suitable OG Acres – All SIOs and Dist. Zones 958 977 1,176 1,724 1,726 1,726

Projected YG Harvest Acres in 

Foreground/Middleground over 100 Years

682 673 666 666 664 662

Projected OG Harvest Acres in 

Foreground/Middleground over 100 Years

237 218 177 206 202 202 

Total Acres in Viewshed (21% is Non-NFS) 36,157 36,157 36,157 36,157 36,157 36,157
Environment and Effects 3

Final EIS 3-226 Scenery

Table 3.11-3 (continued)

Suitable/Projected Harvest (in acres) for Young Growth and Old Growth in Selected 

General Viewsheds 1,2

Viewshed and Category Alternative

1 2 3 4 5 6

Clarence Strait

Suitable YG Acres by SIO & Dist. Zone

High SIO-Foreground/Middleground 1,181 1,243 1,254 1,248 1,256 1,290

Very Low SIO-Foreground/Middleground 17,272 17,565 17,816 17,689 17,864 17,864

Suitable OG Acres – All SIOs and Dist. Zones 9,910 10,661 12,328 13,771 13,773 13,773

Projected YG Harvest Acres in 

Foreground/Middleground over 100 Years

15,702 15,490 15,538 15,424 15,493 15,379

Projected OG Harvest Acres in 

Foreground/Middleground over 100 Years

1,902 1,804 1,524 1,357 1,333 1,333 

Total Acres in Viewshed (11% is Non-NFS) 200,380 200,380 200,380 200,380 200,380 200,380

Duncan Canal

Suitable YG Acres by SIO & Dist. Zone

High SIO-Foreground/Middleground 351 351 351 351 351 362

Very Low SIO-Foreground/Middleground 1,919 2,448 2,448 2,448 2,477 2,477

Suitable OG Acres – All SIOs and Dist. Zones 1,618 2,871 4,392 4,415 4,415 4,416

Projected YG Harvest Acres in 

Foreground/Middleground over 100 Years

1,933 2,305 2,281 2,280 2,292 2,280

Projected OG Harvest Acres in 

Foreground/Middleground over 100 Years

410 705 888 772 757 758 

Total Acres in Viewshed (0% is Non-NFS) 69,641 69,641 69,641 69,641 69,641 69,641

Eastern Passage

Suitable YG Acres by SIO & Dist. Zone

High SIO-Foreground/Middleground 342 342 342 342 342 468

Very Low SIO-Foreground/Middleground 2,343 2,428 2,428 2,428 2,465 2,465

Suitable OG Acres – All SIOs and Dist. Zones 4,217 4,924 8,361 8,361 8,361 8,361

Projected YG Harvest Acres in 

Foreground/Middleground over 100 Years

2,286 2,282 2,257 2,256 2,275 2,355

Projected OG Harvest Acres in 

Foreground/Middleground over 100 Years

876 941 1,316 1,138 1,117 1,117 

Total Acres in Viewshed (9% is Non-NFS) 135,673 135,673 135,673 135,673 135,673 135,673

Ernest Sound

Suitable YG Acres by SIO & Dist. Zone

High SIO-Foreground/Middleground 31 33 33 33 33 53

Very Low SIO-Foreground/Middleground 464 464 464 464 464 464

Suitable OG Acres – All SIOs and Dist. Zones 0 0 0 0 0 0

Projected YG Harvest Acres in 

Foreground/Middleground over 100 Years

421 409 405 405 403 415

Projected OG Harvest Acres in 

Foreground/Middleground over 100 Years

0 0 0 0 0 0

Total Acres in Viewshed (7% is Non-NFS) 36,131 36,131 36,131 36,131 36,131 36,131
Environment and Effects 3

Final EIS 3-227 Scenery

Table 3.11-3 (continued)

Suitable/Projected Harvest (in acres) for Young Growth and Old Growth in Selected 

General Viewsheds 1,2

Viewshed and Category Alternative

1 2 3 4 5 6

Frederick Sound

Suitable YG Acres by SIO & Dist. Zone

High SIO-Foreground/Middleground 526 590 618 596 590 635

Very Low SIO-Foreground/Middleground 7,424 8,183 8,196 8,197 8,218 8,218

Suitable OG Acres – All SIOs and Dist. Zones 9,080 12,136 16,684 20,509 20,601 20,601

Projected YG Harvest Acres in 

Foreground/Middleground over 100 Years

6,769 7,225 7,182 7,162 7,137 7,108

Projected OG Harvest Acres in 

Foreground/Middleground over 100 Years

2,275 2,680 2,803 2,982 2,944 2,944 

Total Acres in Viewshed (2% is Non-NFS) 163,068 163,068 163,068 163,068 163,068 163,068

Salmon Bay Lake

Suitable YG Acres by SIO & Dist. Zone

High SIO-Foreground/Middleground 256 256 256 256 256 256

Very Low SIO-Foreground/Middleground 1,103 1,103 1,103 1,103 1,103 1,103

Suitable OG Acres – All SIOs and Dist. Zones 12 12 14 14 14 14

Projected YG Harvest Acres in 

Foreground/Middleground over 100 Years

1,156 1,119 1,107 1,106 1,101 1,091

Projected OG Harvest Acres in 

Foreground/Middleground over 100 Years

4 3 3 3 3 3 

Total Acres in Viewshed (0% is Non-NFS) 8,422 8,422 8,422 8,422 8,422 8,422

Icy Strait

Suitable YG Acres by SIO & Dist. Zone

High SIO-Foreground/Middleground 16 17 17 17 17 132

Very Low SIO-Foreground/Middleground 2,418 2,436 2,436 2,439 2,564 2,564

Suitable OG Acres – All SIOs and Dist. Zones 8,049 8,246 8,418 10,515 11,179 11,179

Projected YG Harvest Acres in 

Foreground/Middleground over 100 Years

2,072 2,020 1,999 2,001 2,091 2,165

Projected OG Harvest Acres in 

Foreground/Middleground over 100 Years

586 583 509 412 421 421 

Total Acres in Viewshed (5% is Non-NFS) 71,116 71,116 71,116 71,116 71,116 71,116

Lynn Canal

Suitable YG Acres by SIO & Dist. Zone

High SIO-Foreground/Middleground 1 2 2 2 26 83

Very Low SIO-Foreground/Middleground 40 646 646 696 928 928

Suitable OG Acres – All SIOs and Dist. Zones 34 53 53 73 106 106

Projected YG Harvest Acres in 

Foreground/Middleground over 100 Years

34 534 528 569 774 812

Projected OG Harvest Acres in 

Foreground/Middleground over 100 Years

0 0 0 0 2 2 

Total Acres in Viewshed (15% is Non-NFS) 233,552 233,552 233,552 233,552 233,552 233,552
Environment and Effects 3

Final EIS 3-228 Scenery

Table 3.11-3 (continued)

Suitable/Projected Harvest (in acres) for Young Growth and Old Growth in Selected 

General Viewsheds 1,2

Viewshed and Category Alternative

1 2 3 4 5 6

Mendenhall Glacier

Suitable YG Acres by SIO & Dist. Zone

High SIO-Foreground/Middleground 0 0 0 0 0 0

Very Low SIO-Foreground/Middleground 0 0 0 0 0 0

Suitable OG Acres – All SIOs and Dist. Zones 0 0 0 0 0 0

Projected YG Harvest Acres in 

Foreground/Middleground over 100 Years

0 0 0 0 0 0

Projected OG Harvest Acres in 

Foreground/Middleground over 100 Years

0 0 0 0 0 0

Total Acres in Viewshed (3% is Non-NFS) 55,266 55,266 55,266 55,266 55,266 55,266

Peril Strait

Suitable YG Acres by SIO & Dist. Zone

High SIO-Foreground/Middleground 1,804 1,804 1,804 1,804 1,804 1,868

Very Low SIO-Foreground/Middleground 6,518 6,478 6,478 6,518 6,521 6,521

Suitable OG Acres – All SIOs and Dist. Zones 3,437 3,465 3,465 5,333 6,270 6,270

Projected YG Harvest Acres in 

Foreground/Middleground over 100 Years

7,086 6,821 6,748 6,778 6,746 6,736

Projected OG Harvest Acres in 

Foreground/Middleground over 100 Years

272 271 229 266 311 311 

Total Acres in Viewshed (7% is Non-NFS) 189,194 189,194 189,194 189,194 189,194 189,194

Hyder

Suitable YG Acres by SIO & Dist. Zone

High SIO-Foreground/Middleground 0 0 0 0 0 0

Very Low SIO-Foreground/Middleground 160 160 160 160 180 207

Suitable OG Acres – All SIOs and Dist. Zones 3 3 3 21 24 24

Projected YG Harvest Acres in 

Foreground/Middleground over 100 Years

136 132 130 130 146 166

Projected OG Harvest Acres in 

Foreground/Middleground over 100 Years

1 1 1 1 4 4 

Total Acres in Viewshed (3% is Non-NFS) 23,278 23,278 23,278 23,278 23,278 23,278

Stephens Passage

Suitable YG Acres by SIO & Dist. Zone

High SIO-Foreground/Middleground 21 21 21 21 21 156

Very Low SIO-Foreground/Middleground 120 124 124 145 258 258

Suitable OG Acres – All SIOs and Dist. Zones 0 0 1 36 49 50

Projected YG Harvest Acres in 

Foreground/Middleground over 100 Years

120 120 119 136 227 332

Projected OG Harvest Acres in 

Foreground/Middleground over 100 Years

0 0 0 0 1 1 

Total Acres in Viewshed (26% is Non-NFS) 258,966 258,966 258,966 258,966 258,966 258,966
Environment and Effects 3

Final EIS 3-229 Scenery

Table 3.11-3 (continued)

Suitable/Projected Harvest (in acres) for Young Growth and Old Growth in Selected 

General Viewsheds 1,2

Viewshed and Category Alternative

1 2 3 4 5 6

Stikine Strait

Suitable YG Acres by SIO & Dist. Zone

High SIO-Foreground/Middleground 350 361 367 367 361 511

Very Low SIO-Foreground/Middleground 3,222 3,800 3,801 3,857 3,958 3,958

Suitable OG Acres – All SIOs and Dist. Zones 2,025 2,327 2,344 4,150 5,281 5,281

Projected YG Harvest Acres in 

Foreground/Middleground over 100 Years

3,041 3,427 3,396 3,441 3,500 3,588

Projected OG Harvest Acres in 

Foreground/Middleground over 100 Years

464 476 388 602 767 767 

Total Acres in Viewshed (0% is Non-NFS) 60,654 60,654 60,654 60,654 60,654 60,654

Sumner Strait

Suitable YG Acres by SIO & Dist. Zone

High SIO-Foreground/Middleground 898 906 906 906 906 936

Very Low SIO-Foreground/Middleground 20,226 20,238 20,253 20,279 20,291 20,291

Suitable OG Acres – All SIOs and Dist. Zones 13,339 13,445 13,616 16,170 16,175 16,175

Projected YG Harvest Acres in 

Foreground/Middleground over 100 Years

17,985 17,414 17,240 17,254 17,176 17,044

Projected OG Harvest Acres in 

Foreground/Middleground over 100 Years

3,163 2,896 2,371 2,381 2,338 2,338 

Total Acres in Viewshed (5% is Non-NFS) 151,274 151,274 151,274 151,274 151,274 151,274

Sweetwater Lake/Honker Divide

Suitable YG Acres by SIO & Dist. Zone

High SIO-Foreground/Middleground 2,586 2,586 2,586 2,586 2,586 2,586

Very Low SIO-Foreground/Middleground 6.911 6,972 6,974 6,974 6,974 6,974

Suitable OG Acres – All SIOs and Dist. Zones 466 466 466 466 467 467

Projected YG Harvest Acres in 

Foreground/Middleground over 100 Years

8,085 7,871 7,789 7,786 7,746 7,676

Projected OG Harvest Acres in 

Foreground/Middleground over 100 Years

123 112 90 78 77 77 

Total Acres in Viewshed (9% is Non-NFS) 107,353 107,353 107,353 107,353 107,353 107,353

Tenakee Inlet to Tenakee Springs

Suitable YG Acres by SIO & Dist. Zone

High SIO-Foreground/Middleground 1,146 1,146 1,146 1,146 1,146 1,149

Very Low SIO-Foreground/Middleground 2,600 2,607 2,607 2,607 2,641 2,641

Suitable OG Acres – All SIOs and Dist. Zones 4,795 4,094 5,168 9,628 9,628 9,629

Projected YG Harvest Acres in 

Foreground/Middleground over 100 Years

3,189 3,091 3,058 3,057 3,068 3,043

Projected OG Harvest Acres in 

Foreground/Middleground over 100 Years

133 134 197 144 138 138 

Total Acres in Viewshed (1% is Non-NFS) 152,402 152,402 152,402 152,402 152,402 152,402
Environment and Effects 3

Final EIS 3-230 Scenery

Table 3.11-3 (continued)

Suitable/Projected Harvest (in acres) for Young Growth and Old Growth in Selected 

General Viewsheds 1,2

Viewshed and Category Alternative

1 2 3 4 5 6

West Coast Waterway-POW

Suitable YG Acres by SIO & Dist. Zone

High SIO-Foreground/Middleground 2,009 2,024 2,024 2,024 2,024 2,057

Very Low SIO-Foreground/Middleground 10,779 10,821 10,822 10,834 10,838 10,839

Suitable OG Acres – All SIOs and Dist. Zones 5,483 5,926 6,564 6,880 6,880 6,880

Projected YG Harvest Acres in 

Foreground/Middleground over 100 Years

10,888 10,579 10,466 10,472 10,422 10,354

Projected OG Harvest Acres in 

Foreground/Middleground over 100 Years

1,357 1,326 1,136 1,023 1,005 1,005 

Total Acres in Viewshed (15% is Non-NFS) 139,547 139,547 139,547 139,547 139,547 139,547

Wrangell Narrows

Suitable YG Acres by SIO & Dist. Zone

High SIO-Foreground/Middleground 513 562 562 562 562 587

Very Low SIO-Foreground/Middleground 2,257 2,394 2,394 2,394 2,432 2,432

Suitable OG Acres – All SIOs and Dist. Zones 5,860 6,326 6,434 8,410 8,872 8,872

Projected YG Harvest Acres in 

Foreground/Middleground over 100 Years

2,358 2,434 2,408 2,407 2,425 2,424

Projected OG Harvest Acres in 

Foreground/Middleground over 100 Years

1,289 1,287 1,062 1,223 1,281 1,281 

Total Acres in Viewshed (26% is Non-NFS) 87,438 87,438 87,438 87,438 87,438 87,438

Zimovia Strait

Suitable YG Acres by SIO & Dist. Zone

High SIO-Foreground/Middleground 663 666 666 666 666 730

Very Low SIO-Foreground/Middleground 2,807 3,158 3,181 3,195 3,198 3,198

Suitable OG Acres – All SIOs and Dist. Zones 4,448 5,506 7,056 8,127 8,128 8,128

Projected YG Harvest Acres in 

Foreground/Middleground over 100 Years

2,954 3,149 3,134 3,144 3,131 3,154

Projected OG Harvest Acres in 

Foreground/Middleground over 100 Years

1,023 1,061 1,114 1,160 1,139 1,139 

Total Acres in Viewshed (12% is Non-NFS) 82,695 82,695 82,695 82,695 82,695 82,695

1 SIO terms are defined in the Affected Environment portion of this section. 2 The numbers in this table are approximate acres seen from a Visual Priority Travel Route and Use Area.
Environment and Effects 3

Final EIS 3-231 Scenery

Figure 3.11-1

Map of Selected General Viewsheds

 
Environment and Effects 3

Final EIS 3-232 Scenery

Behm Canal (West)

All alternatives would have similar acres of suitable young growth in the Behm Canal West viewshed. 

Suitable old-growth acres would be similar for Alternatives 1, 2, and 3 and would be 10 to 15 percent 

higher for Alternatives 4, 5, and 6.

However, projected harvest in this viewshed would generally decrease for both young growth and old 

growth for the alternatives that include greater acreages of suitable lands. This is because harvest levels 

would remain the same under all alternatives and alternatives with greater acreages of suitable lands 

would experience a lower harvest rate on a per acre basis. Therefore, the total harvest acres for a 

viewshed depends on the total suitable acres in the viewshed relative to the total suitable acres in all 

other viewsheds. 

In some areas, particularly on the Revilla Island side of the west Canal, existing harvest is likely near the 

level allowed by the adopted SIOs. Additional harvest may need to be deferred in some areas in the 

coming decade. A high portion of the existing harvest acres are along the beach fringe in all alternatives.

Clearcutting and patch cutting, with up to 10-acre openings, are allowed, but a 200-foot shoreline buffer 

would be maintained, which would help conceal the opening created by clearcuts. Therefore, all 

alternatives could have localized higher effects during the first few decades.

Carroll Inlet

Suitable acres of young growth in Carroll Inlet would increase by about 4 percent for all action alternatives 

relative to Alternative 1. Suitable acres of old growth would increase by 14 and 45 percent under 

Alternatives 2 and 3, respectively, relative to Alternative 1, and by 55 percent under Alternatives 4, 5, and 

6. Again, however, projected harvest levels would decrease or increase slightly under each of the action 

alternatives because the constant harvest levels dictated by the Forest Plan would be spread over larger 

acreages of suitable forest lands. 

Carroll Inlet has experienced relatively heavy past harvest and existing harvest is likely near the level 

allowed by the adopted SIOs in some areas. Additional harvest may need to be deferred in localized 

areas in the coming decade depending on the SIO. A high portion of young-growth acres are scattered 

along the beach fringe in all alternatives. Clearcutting and patch cutting, with up to 10-acre openings, are 

allowed, but a 200-foot shoreline buffer would be maintained, which would help conceal the opening 

created by clearcuts. Therefore, all alternatives could have localized moderate effects during the first few 

decades.

Chatham Strait (West side)

Suitable young-growth acres in this viewshed would be similar under Alternatives 1, 2, 3, 4, and 5, 

varying by about 1 percent or less, and increasing by about 9 percent under Alternative 6. Suitable oldgrowth acres would also be similar under Alternatives 1 and 2, would increase by 29 percent under 

Alternative 3, and would increase by about 53 to 54 percent under Alternatives 4, 5, and 6. Again 

however, young-growth and old-growth projected harvest under the action alternatives would be the same 

or less than under Alternative 1, with the exception of young-growth harvest under Alternative 6, which 

would increase by about 3 percent.

Chatham Strait has experienced relatively high past harvest but much of it is in seldom seen areas. 

Further, the number of young-growth acres of harvestable age within the next decade is very limited 

(USDA Forest Service 2016b, Table 3.16-5). Therefore, all of the alternatives are expected to have low 

effects during the first few decades.

Cholmondeley Sound

In this viewshed, suitable young-growth acres would be similar under all alternatives, varying by less than 

3 percent. Using Alternative 1 as the baseline, suitable old-growth acres, however, would increase by 23 

percent under Alternative 3, and by 80 percent under Alternatives 4, 5, and 6. Suitable old-growth acres 

would be almost identical under Alternatives 1and 2. Projected young-growth and old-growth harvest 

would be less than the Alternative 1 level for all alternatives.
Environment and Effects 3

Final EIS 3-233 Scenery

Cholmondeley Sound has experienced limited past harvest on NFS lands, but high past harvest on nonNFS lands. About 21 percent of the viewshed consists of non-NFS lands. The number of young-growth 

acres of harvestable age within the next decade is very limited (USDA Forest Service 2016b, Table 3.16-

5) and the projected harvest of old growth is less than 200 acres over the next 100 years. Therefore, with 

the possible exception of Alternatives 5 and 6, all of the alternatives are expected to have relatively low 

effects during the first few decades. However, additional harvest may need to be deferred in localized 

areas near non-NFS land, especially where harvest includes openings in the beach fringe.

Clarence Strait

Clarence Strait is a large viewshed (over 200,000 acres), extending along both sides of the strait, from its 

northern end south to Gravina Island. The viewshed includes portions of the South Etolin Wilderness

Area, which would have an SIO of High under all alternatives; however, a Very High SIO would likely be 

achieved. 

Relative to Alternative 1, the suitable young-growth acres would vary by 4 percent (Alternatives 5 or 6) or 

less and suitable old-growth acres wouldincrease by up to 39 percent (under Alternatives 4, 5, and 6). 

However, because of the constant overall harvest level under all alternatives, projected harvest acreage 

would be at Alternative 1 levels or less for both young growth and old growth.

Clarence Strait has experienced considerable past harvest, but much of it is not readily visible from the 

Strait, so much of the viewshed appears relatively pristine. However, the number of young-growth acres 

of harvestable age within the next decade is considerable (USDA Forest Service 2016b, Table 3.16-5). A 

number of these acres are scattered along the beach fringe, especially along Prince of Wales and 

adjacent islands. Therefore, all alternatives could have localized moderate effects during the first few 

decades.

Duncan Canal

In the Duncan Canal viewshed, suitable young-growth acres would increase from 23 to 25 percent and 

the projected harvest would increase by 19 percent under all action alternatives. However, suitable oldgrowth acres would increase from 77 to 173 percent and projected harvest would increase from 72 to 166 

percent under the action alternatives.

Duncan Canal has experienced considerable past harvest on the east side of the Canal, but much of it is 

not readily visible from the Strait. However, the number of young-growth acres of harvestable age within 

the next decade exceeds 100 acres (USDA Forest Service 2016b, Table 3.16-5). A number of these 

acres are scattered along the beach fringe in all alternatives. Therefore, all alternatives could have local 

effects along the travelway during the first few decades.

Eastern Passage

Suitable young-growth acres for each alternative vary by only 9 percent, with the highest acreage in 

Alternatives 5 and 6. The increase in suitable old-growth acres relative to Alternative 1 would range up to 

98 percent in Alternatives 4, 5, and 6. Projected young-growth harvest would vary by 4 percent or less 

under the alternatives but projected old-growth harvest would range up to 28 percent more acres than 

under Alternative 1.

Eastern Passage has experienced considerable past harvest on the Wrangell Island side, but much of it 

is not readily visible from the Passage. A few older young-growth acres are scattered along the beach 

fringe in all alternatives.

Therefore, all alternatives could have local effects along the travelway during the first few decades.

Ernest Sound

Both suitable and projected harvest acres in the Ernest Sound viewshed for young growth and old growth 

do not vary significantly among the alternatives. There are no suitable old-growth acres under any 

alternative.

Ernest Sound has experienced considerable past harvest on Deer Island and along the beach to the 

north. A considerable number of young-growth acres of harvestable age during the next decade occur 
Environment and Effects 3

Final EIS 3-234 Scenery

within the viewshed (USDA Forest Service 2016b, Table 3.16-5) and most of these acres are along the 

beach fringe in all alternatives. Clearcutting and patch cutting, with up to 10-acre openings, are allowed, 

and a 200-foot shoreline buffer would mitigate opening size.

Therefore, all alternatives could have localized effects during the first few decades.

Frederick Sound

In the Frederick Sound viewshed, suitable young-growth acres would increase from 10 to 11 percent and 

the projected harvest would increase from 5 to 6 percent under all action alternatives. However, suitable 

old-growth acres would increase more substantially under all alternatives ranging from 34 percent under 

Alternative 2 to 127 percent under Alternatives 5 and 6. Projected harvest would increase from 18 percent 

under Alternative 2 to 31 percent under Alternative 4.

Frederick Sound is a large viewshed (163,000 acres) along Kupreanof Island and the mainland. Frederick 

Sound has experienced considerable past harvest in local areas on Kupreanof Island and along the 

mainland. It includes a substantial acreage of young-growth of harvestable age within the next decade 

(USDA Forest Service 2016b, Table 3.16-5). Some of these acres are along the beach fringe in all 

alternatives. Clearcutting and patch cutting, with up to 10-acre openings, are allowed, and a 200-foot 

shoreline buffer would mitigate opening size. Therefore, all alternatives could have localized moderate 

effects during the first few decades.

Salmon Bay Lake

In the Salmon Bay Lake Viewshed, suitable acres of young growth and old growth would remain the 

same as Alternative 1 acres under all alternatives. Projected harvest would remain the same as 

Alternative 1 or be slightly lower. Harvest of old growth would be 2 acres or less.

None of the alternatives would have any young-growth acres that would be of harvestable age within the 

next decade (USDA Forest Service 2016b, Table 3.16-5). Therefore, none of the alternatives are 

expected to have more than minor effects on scenery in the next few decades.

Icy Strait

Icy Strait would experience limited effects due partly to the Wilderness LUDs on Pleasant and Lemesurier 

Islands and the LUD II at Point Adolphus. Wilderness areas would have an SIO of High under all 

alternatives, but would likely achieve an SIO of Very High.

Suitable young growth and projected harvest acres would be similar under Alternatives 1, 2, 3, and 4 

varying by only 22 suitable acres and up to 4 percent for projected harvest acres. Under Alternatives 5 

and 6, suitable young growth would increase by about 11 percent. For suitable old-growth acreage, 

Alternatives 1, 2, and 3 would vary by up to 5 percent, while these acres would increase by 31 to 39 

percent under Alternatives 4, 5, and 6. Projected old-growth harvest, however, would be lower under all 

action alternatives because of the fact that Forest-wide harvest would be constant under all alternatives.

No young-growth acres of harvestable age within the next decade occur in the viewshed (USDA Forest 

Service 2016b, Table 3.16-5). Therefore, minor effects are expected to occur under any alternatives 

during the first few decades.

Lynn Canal

Scenic effects within the Lynn Canal Viewshed would be very limited under Alternative 1 because of 

minor suitable acreages of young growth and old growth. In addition, very minor differences would result 

under all alternatives for old growth suitable (34-106 acres) and projected harvest acreages (0-2 acres). 

In contrast, young-growth suitable and projected harvest acreages would increase considerably for all 

action alternatives, especially for Alternatives 5 and 6. However, projected young-growth harvest over 

100 years would be less than 900 acres for all alternatives, or less than 0.4 percent of this large viewshed 

(234,000 acres).
Environment and Effects 3

Final EIS 3-235 Scenery

Mendenhall Glacier

No effects would occur in the Mendenhall Glacier Viewshed under any of the alternatives. No suitable 

young growth or old growth occurs within the viewshed.

Peril Strait/Neva-Olga Strait/Sitka

This viewshed is a large one (189,000 acres) that begins near Sitka and wraps around the northern end 

of Chichagof Island and the southern end of Baranof Island. Young growth suitable acres would vary 

insignificantly under all alternatives, and projected harvest acres for young growth under all action 

alternatives would be less than under Alternative 1. Suitable old-growth acres would be relatively constant 

for Alternatives 1, 2, and 3, but would increase by 55 to 82 percent under Alternatives 4, 5, and 6. 

Projected old-growth harvest acres would be less than Alternative 1 for Alternatives 2, 3, and 4, but would 

be 6 percent higher under Alternatives 5 and 6.

The Peril Strait complex has experienced considerable past harvest in local areas, mostly on Chichagof, 

Kruzof, and adjacent small islands. The number of young-growth acres of harvestable age within the next 

decade is substantial for all alternatives (USDA Forest Service 2016b, Table 3.16-5). Many of these acres 

are along the beach fringe in all alternatives. Clearcutting or patch cutting, with up to 10-acre openings, 

are allowed in the beach fringe, along with a 200-foot shoreline buffer, which would mitigate opening size. 

Therefore, all alternatives could have local moderate effects during the first few decades.

Hyder/Salmon River

Only minor amounts of suitable young-growth and old-growth acres occur in this viewshed under all of the 

alternatives. Therefore, little to no impacts related to scenic quality are expected to occur.

Stephens Passage

Stephens Passage is a large viewshed (259,000 acres) running between Admiralty Island and the 

mainland. It excludes the majority of the wilderness portion of the Admiralty National Monument.

Young growth suitable acres are relatively minor under all alternatives and old growth suitable acres are 

insignificant. Only Alternatives 5 and 6 have a projected young-growth harvest over 200 acres. Although 

many of the young-growth acres are older stands in the beach fringe, they are scattered throughout the 

large viewshed.

Stikine Strait

This viewshed covers the corridors between Etolin, Zarembo, and Woronkofski Islands. Suitable young 

growth would increase under the action alternatives by 16 percent for Alternatives 2 and 3 and by 18 to 

25 percent for Alternatives 4, 5, and 6. Projected young-growth harvest would also increase under all 

action alternatives ranging from 12 percent for Alternative 3, to 18 percent forAlternative 6. Suitable old 

growth would be about 15 percent higher under Alternatives 2 and 3, but up to 161 percent higher under 

Alternatives 4, 5, and 6. Projected old-growth harvest would be similar under Alternatives 1, 2, and 3, 

ranging from 3 percent higher to 16 percent lower than Alternative 1, but would be 30 percent higher 

under Alternative 4 and 65 percent higher under Alternatives 5 and 6.

The Stikine Strait Viewshed has experienced considerable past harvest in most areas within the 

viewshed. The number of young-growth acres of harvestable age within the next decade are relatively 

low, but many of these acres are along the beach fringe. Because of the low number of acres of younggrowth of harvestable age within the next decade, harvest of young growth is expected to produce low 

scenery effects.

Sumner Strait

The Sumner Strait Viewshed is a large viewshed (152,000 acres) along northern Prince of Wales, 

Kosciusko, Kuiu, Kupreanof, Zarembo, and other islands. It includes portions of the Kuiu Wilderness and 

the Mt. Calder/Mt. Holbrook and Salmon Bay LUD II areas. These areas would have an SIO of High but 

would likely achieve an SIO of Very High.

Suitable young-growth acres in this viewshed are essentially the same under all alternatives. Suitable oldgrowth acres are also similar for Alternatives 1, 2, and 3, but increase by 21 percent for Alternatives 4, 5, 
Environment and Effects 3

Final EIS 3-236 Scenery

and 6. Projected old-growth and young-growth harvest, however, would decrease for the action 

alternatives because all alternatives would have the same overall harvest level. The number of younggrowth acres of harvestable age within the next decade is relatively high (USDA Forest Service 2016b, 

Table 3.16-5), and many of these acres are along the beach fringe in all alternatives. Clearcutting and 

patch cutting, with up to 10-acre openings, are allowed in addition to a 200-foot shoreline buffer, which 

would mitigate opening size. Therefore, all alternatives could have relatively high effects along the 

shoreline during the first few decades.

Sweetwater Lake/Honker Divide

Suitable young-growth and old-growth acres are essentially the same under all alternatives in this 

viewshed. Therefore, there would be little difference among the alternatives; however, both young-growth 

and old-growth harvest would steadily decline from Alternative 1 through Alternatives 2, 3, 4, 5, and 6, in 

that order.

The Sweetwater Lake/Honker Divide Viewshed has experienced relatively heavy past harvest in some 

portions. Additional harvest may need to be deferred in localized areas in the coming decade.

Tenakee Inlet to Tenakee Springs

This is a large viewshed (152,000 acres), which contains the Trap Bay and Kadashan LUD II areas, 

which have an SIO of High under all alternatives. The viewshed also contains land designated as 

Research Natural Area and Wild River LUDs, which also have a High SIO under all alternatives.

Suitable young-growth acres are essentially the same under all alternatives in this viewshed, so there 

would be little difference among the alternatives in terms of young growth. Old-growth suitable acres, 

however, would decrease by 15 percent under Alternative 2 and increase by 8 percent under Alternative 

3 and by 101 percent under Alternatives 4, 5, and 6. Projected harvest would increase by 1 percent for

Alternative 2, by 48 percent for Alternative 3, and by 4 to 8 percent for Alternatives 4, 5, and 6.

The Tenakee Inlet to Tenakee Springs Viewshed has experienced considerable past harvest in many 

areas within the viewshed. The number of young-growth acres of harvestable age within the next decade 

is considerable (USDA Forest Service 2016b, Table 3.16-5). Many of these acres are along the beach 

fringe in all alternatives. Clearcutting and patch cutting, with up to 10-acre openings, are allowed in 

addition to a 200-foot shoreline buffer, which would mitigate opening size. Therefore, all of the 

alternatives could have relatively high localized effects during the first few decades.

West Coast Waterway/Prince of Wales

This large viewshed (140,000 acres) contains the Mt. Calder/Mt. Holbrook LUD II area, which would have 

an SIO of High under all alternatives. Suitable young-growth acres and projected harvest acres would 

vary by only 1 and 5 percent, respectively, under all alternatives. Suitable old-growth acres would 

generally increase and range up to 25 percent (Alternatives 4, 5, and 6) higher under the action 

alternatives relative to Alternative 1. However, projected old-growth harvest in the viewshed would decline 

under the action alternatives relative to Alternative 1, because of the fact that all alternatives would have 

the same overall harvest level and the action alternatives would spread that harvest over a larger suitable 

area.

The West Coast Waterway/Prince of Wales Viewshed has experienced relatively heavy past harvest in 

many areas within the viewshed. The number of young-growth acres of harvestable age within the next 

decade is relatively high (USDA Forest Service 2016b, Table 3.16-5). Many of these acres are along the 

beach fringe in all alternatives. Clearcutting and patch cutting, with up to 10-acre openings, are allowed 

along with a 200-foot shoreline buffer, which would mitigate opening size. Therefore, the alternatives 

could have relatively high localized effects during the first few decades.

Wrangell Narrows

Suitable young-growth acres would be up to 9 percent higher for the action alternatives relative to 

Alternative 1, and projected harvest acres would be up to 3 percent higher under the action alternatives. 

Suitable old-growth acres would generally increase and range up to 51 percent (Alternatives 5 and 6) 

higher under the action alternatives relative to Alternative 1. However, projected old-growth harvest acres 
Environment and Effects 3

Final EIS 3-237 Scenery

in the viewshed would decline by up to 18 percent under the action alternatives relative to Alternative 1, 

because all alternatives would have the same overall harvest level and the action alternatives would 

spread that harvest over a larger suitable area.

The Wrangell Narrows Viewshed has experienced relatively high past harvest in many areas within the 

viewshed and includes 26 percent non-NFS lands.

However, the number of young-growth acres of harvestable age within the next decade is relatively low. 

Most of these acres are along the beach fringe and, therefore, all of the alternatives could have localized 

effects during the first few decades.

Zimovia Strait

The Zimovia Strait Viewshed runs between Etolin and Wrangell Islands. Suitable young-growth acres 

would be 10 to 13 percent higher for the action alternatives relative to Alternative 1 and projected younggrowth harvest acres would be about 7 percent higher under all action alternatives. Suitable old-growth 

acres would generally increase and range from 24 percent (Alternative 2) up to 83 percent (Alternatives 4, 

5, and 6) higher under the action alternatives relative to Alternative 1. Projected old-growth harvest acres 

in the viewshed would also increase ranging up to 13 percent higher under the action alternatives relative 

to Alternative 1.

The Zimovia Strait Viewshed has experienced relatively high past harvest in some areas within the 

viewshed. There are a considerable number of young-growth acres of harvestable age over the next 

decade within the viewshed (USDA Forest Service 2016b, Table 3.16-5). Most of these acres are along 

the beach fringe in all alternatives and, therefore, all alternatives could have localized moderate effects 

during the first few decades if these isolated beach units are harvested. Actual effects depend on the type 

of harvest implemented.

Non-Timber Actions

A range of other developments may occur within areas removed from roadless designation or in areas 

where roadless designations have been modified, as occurs under the action alternatives. These other 

developments include mining related actions, energy development, transmission lines, state highway 

development, and others. Essentially all of these developments are allowed under Alternative 1 so 

changes in their likelihood are expected to be minor.

Effects from these projects on scenery would heavily depend on site-specific plans. In general, project 

activities that would impact scenery could include mine development and expansion; new access road 

construction; forest clearing and ground disturbance; dam, powerhouse, and penstock construction; 

transmission line construction; and others. There is a wide range of types and sizes for these 

disturbances and facilities and the eventual impacts to scenery will depend on the location and design 

features. All potential impacts to scenery resources would be addressed during the permitting and 

licensing of the projects, and would include National Environmental Policy Act assessment.

The impacts to scenery associated with the action alternatives are expected to be similar to those 

associated with Alternative 1, as these alternatives would make only minor changes to regulations that 

affect the potential for their development. Impacts associated with Alternative 1 are expected to be slightly 

lower because of the development of slightly fewer projects over the long term; however, the Alternative 1 

standards and guidelines for scenery related to these other projects are similar to the plan components of 

the action alternatives.

Although on a site-specific basis differences would occur, on a Forest-wide basis the scenery effects 

associated with all of the alternatives would show little differences because of the small number of 

projects likely to be developed.

Cumulative Effects

This section considers the incremental effects of the alternatives when added to other past, present, and 

reasonably foreseeable actions. The effects of past and present actions on scenery are included in the 

Affected Environment portion of this section, which discusses the level of scenic quality on the Tongass. 
Environment and Effects 3

Final EIS 3-238 Scenery

Past actions include past timber harvest and road building, as well as the development of facilities and 

mines, which have resulted in reduced ESIs in many areas.

Present actions include the impacts of current management policies on scenery; these have resulted in 

modifications to SIOs.

Reasonably foreseeable actions on NFS lands include the projected levels of future timber harvest and 

other developments that are used in the preceding analysis to assess the potential impacts of the 

alternatives on the scenic quality. Other reasonably foreseeable actions include regional transportation 

development as defined by the State Transportation Plan and the Forest Service Alaska Region LongRange Transportation Plan, as well as road paving on Prince of Wales Island, the closing of roads, and 

construction of the Angoon Airport. In addition, the expansion of cities like Juneau, Ketchikan, and Sitka, 

recreational cabin development, land auctions by the State, and land adjustments could include additional 

road construction, timber harvest, and facility construction.

It is not possible at this time to predict exactly which roads, energy projects, or other projects would be 

developed or their likely impact on future scenic integrity. Human settlement expansion is expected to 

occur around the region’s larger cities with residential expansion also expected as a result of state land 

auctions. These developments would likely result in increased impacts on scenery. Mining activities are 

expected to expand at existing sites, including Greens Creek on Admiralty Island and Kensington Gold 

Mine north of Juneau, as well as possible future sites, including the Bokan Mountain and Niblack sites on 

the southern end of Prince of Wales Island. Mining projects are for the most part expected to have a 

negative local effect on scenery. Overall, the cumulative effects of past, present, and future actions on 

scenery are expected to be adverse, but are not expected to be substantially different than the effects 

associated with the actions addressed under direct and indirect effects.
Environment and Effects 3

Final EIS 3-239 Subsistence

Subsistence

Affected Environment

Harvest and use of natural resources for food, shelter, clothing, transportation, handicrafts, and trade, 

commonly called “subsistence,” has a long history in Alaska. Alaska Native peoples engaged in 

subsistence for thousands of years prior to statehood; living off the land is the core of Alaska Native 

peoples’ culture. In more recent history, non-Native people living in rural Alaska have come to rely on 

natural resources for their livelihoods as well (Office of Subsistence Management 2016). A number of 

people providing testimony during the subsistence hearings held for this rulemaking stated a preference 

for the term “way of life,” rather than subsistence. The term subsistence as used in this EIS is consistent 

with the definition provided in ANILCA Section 803. 

Within the context of Southeast Alaska’s seasonal and cyclical resource-based employment, subsistence 

harvest of fish and wildlife resources takes on special importance. The use of these resources may play a 

major role in supplementing cash incomes during periods when the opportunity to participate in the wage 

economy is either marginal or nonexistent. Because of high prices of commercial products provided 

through the retail sector of the cash economy, especially in remote communities, the economic role of 

locally available fish and game takes on added importance.

Rural Native and non-Native communities both have high subsistence participation rates and rely heavily 

on wild foods, with approximately 79 percent of rural households in Southeast Alaska using wild game 

and 95 percent using fish (Fall 2016). The opportunity to participate in subsistence activities reinforces a 

variety of cultural and related values in both Native and non-Native communities. For example, the 

distribution of harvested fish and wildlife contributes to the cohesion of kinship groups and community 

stability through the sharing of resources.

Subsistence resources provide the foundation for Native culture, forming the basis for different clans and 

potlatch ceremonies, as well as reinforcing basic values of respect for the earth and its resources. 

Participating in subsistence activities contributes to the self-reliance, independence, and ability to provide 

for oneself; values that social surveys indicate are important reasons why many non-Native people move 

to or remain in Southeast Alaska (USDA Forest Service 1997a).

The Legal Context for Subsistence Use

Congress defined subsistence use in Title VIII of the 1980 Alaska National Interest Lands Conservation 

Act (ANILCA). Section 803 of ANILCA as:

“the customary and traditional uses by rural Alaska residents of wild renewable resources for 

direct, personal, or family consumption as food, shelter, fuel, clothing, tools, or transportation; for 

the making and selling of handicraft articles out of non-edible byproducts of fish and wildlife 

resources taken for personal or family consumption; for barter, or sharing for personal or family 

consumption; and for customary trade.”

ANILCA provides for “the continuation of the opportunity for subsistence uses by rural residents of 

Alaska, including both Natives and non-Natives, on the public lands.” The provisions in ANILCA 

established a harvest priority for rural residents in an attempt to protect subsistence resource harvest. 

Under ANILCA, in times of resource scarcity or when demand exceeds biologically sound harvest levels, 

subsistence harvests have priority over other consumptive use of resources. Such a priority shall be 

implemented through appropriate limitations based on the application of the following criteria: (1) 

customary and direct dependence upon the populations as the mainstay of livelihood; (2) local residency; 

and (3) the availability of alternative resources. In practice, state or federal fish and wildlife management 

authorities would limit commercial, sport, or other harvests before subsistence harvests are limited. The 

Alaska legislature subsequently passed a regulation to comply with ANILCA, but in 1989, the Alaska 

Supreme Court ruled in McDowell v. State of Alaska that a harvest priority for rural residents conflicted 

with the state constitution, which guarantees all Alaskans equal access to the state’s natural resources. 

This ruling took the state out of compliance with ANILCA, and the federal government has managed 
Environment and Effects 3

Final EIS 3-240 Subsistence

subsistence resources on federal lands in Alaska since 1990. As a result, federal subsistence harvests of 

fish and wildlife on the Tongass are presently managed by the Forest Service and the Federal 

Subsistence Management Program (Schroeder and Mazza 2005).

ANILCA requires the evaluation of the potential effects of all actions on subsistence resources and uses 

and needs on federal lands in Alaska. This evaluation typically focuses on those food-related resources 

most likely to be affected by habitat degradation associated with land management activities. If significant 

restrictions to subsistence uses are identified, prior to putting the federal action into effect, notice and 

hearings must occur. Per ANILCA Sec. 810(a)(3), the following three determinations must be made: “(A) 

such a significant restriction of subsistence uses is necessary, consistent with sound management 

principles for the utilization of the public lands, (B) the proposed activity will involve the minimal amount of 

public lands necessary to accomplish the purposes of such use, occupancy, or other disposition, and (C) 

reasonable steps will be taken to minimize adverse impacts upon subsistence uses and resources 

resulting from such actions.” To make these three determinations, the Forest Service shall analyze the 

following: 1) resource distribution and abundance, 2) access to resources, and 3) competition for the use 

of resources. These factors are discussed in general terms in the following paragraphs.

Abundance and Distribution

Southeast Alaska subsistence resources include terrestrial wildlife (including deer, moose, mountain goat, 

black and brown bear, furbearers, and small game), waterfowl (including ducks, geese, and seabirds), 

marine mammals (harbor seal), salmon, other finfish, marine invertebrates, plants, and firewood. The 

abundance and distribution of subsistence resources on the Tongass is described in the 1997 Forest Plan 

EIS (USDA Forest Service 1997a) and other sections of this EIS provide detailed information on wildlife, 

fish, and plants (especially see the Biological Diversity, Wildlife, and Fish sections under Key Issue 3).

Access

Road building, a byproduct of timber harvesting and, to a lesser extent, mining, is an important agent of 

change in Southeast Alaska. New road networks often provide greater access to previously unconnected 

areas and can affect subsistence both positively and negatively by providing access, dispersing hunting 

and fishing pressure, and creating the potential for increased competition. On Prince of Wales Island, for 

example, areas that have become connected by road are now more easily reached by local residents and 

other nearby communities. Road systems tend to bring more people into an area and also give 

subsistence hunters access to previously remote regions and provide a greater opportunity for 

subsistence harvest.

Southeast Alaska comprises isolated islands unconnected by road systems; however, with the 

transportation means available (floatplanes, ferry systems, automobiles, and boats), Southeast Alaska 

residents are very mobile in their subsistence resource use activities. Wrangell, the fifth-largest 

community in Southeast Alaska, for example, has documented their subsistence gathering from the 

southern tip of Prince of Wales Island to Yakutat, covering most of the islands in between (Kruse and 

Muth 1990).

Competition

The Tongass, with nearly 17 million acres of largely undeveloped land, includes extensive subsistence 

resources. These resources are not, however, distributed or used evenly across the Forest. Where the 

resources are confined to island groups or river systems and access is costly or nonexistent, use of the 

resources is low. Where the resource is abundant, and a community is present but access by other 

communities is costly, the resource tends to be used primarily by the community that resides in the area. 

Where resources are abundant and access is readily available to local and other communities of 

Southeast Alaska, competition for resources may exist.

Increased competition may result when less expensive access to the area or within the area is provided. 

Such is the case when road systems are established to local communities. When areas historically not 

used for subsistence purposes are made available because of easier, more cost-effective access, the 

new area then tends to be used. When communities with road access to abundant resources are 
Environment and Effects 3

Final EIS 3-241 Subsistence

connected to a ferry system or to commercial air services, competition for the resources may be 

generated from outside communities with lower abundance of the same resource.

Examples of the effect of ease of access are readily available in Southeast Alaska. Chichagof Island, 

Prince of Wales Island, and the Yakutat Forelands at one time were isolated portions of the Tongass with 

small amounts of use by communities in the vicinity. Today, road construction, primarily a result of timber 

harvest activities, has created relatively large areas that are easily accessed from local communities. 

Access provided by ferry systems and small commuter planes to Chichagof and Prince of Wales Islands 

allows relatively easy access from off-island communities. Access to the Yakutat Forelands has been 

made easier because of commercial jet service and ferry service to the community ofYakutat.

Subsistence Users

Under ANILCA, only rural Alaska residents qualify for priority use of subsistence hunting and fishing on 

federal lands. Alaska residents living in urban areas can harvest under State subsistence, sport, personal 

use, or commercial regulations on federal public lands, but not under federal subsistence regulations. 

Following the Alaska Supreme Court’s 1989 ruling in McDowell v. State of Alaska, all Alaska residents 

qualify as subsistence users on state lands with federal lands continuing to be managed under ANILCA.

In 2019, Southeast Alaska had an estimated population of 72,373, with the majority (about 91 percent) 

living in established communities (either incorporated cities or Census Designated Places [CDP]) (Alaska 

Department of Labor [DOL] 2019).

Almost two-thirds (63 percent) of the area’s population lived in the city and borough of Juneau (44 

percent) or Ketchikan Gateway Borough (19 percent), the only two communities considered as urban 

areas for subsistence purposes. An additional 23 percent of the area’s population resided in the 

communities of Sitka, Petersburg, Wrangell, and Haines. The remaining share of the population living in 

established communities lived in communities ranging in size from Elfin Cove with 11 people to Metlakatla

with 1,359 people (Alaska DOL 2018).

A relatively small number of Southeast Alaska residents live at remote isolated locations. These include 

people living at home sites throughout Southeast Alaska, at summer fishing sites along the outer coast, 

tree thinners camped near areas where they have Forest Service contracts, trappers, and people living 

on floathouses and fishing boats. This diverse group is typically transient, generally has very low cash 

income, and is closely tied to non-commercial harvest of fish, game, and other renewable natural 

resources.

Alaska Natives made up an estimated 15 percent of the region’s population in 2019 (including Juneau

and Ketchikan), and an estimated 21 percent for rural communities (excluding Juneau and Ketchikan) 

(Figure 3.12-1). These rural communities include places that are predominately Native, such as 

Hydaburg, Kake, Saxman, and Metlakatla where Alaska Natives make up an estimated 72 percent 

(Hydaburg and Kake) and 71 percent (Saxman and Metlakatla) of the population; other communities that 

are predominately non-Native, like Edna Bay, Point Baker, and Whale Pass; and places with more mixed 

ethnicity where Alaska Natives range from about one-third to two-thirds of the population (Figure 3.12-1).

The Bureau of Indian Affairs identifies 17 federally recognized Indian tribes in the region, including the 

Metlakatla of the Annette Island Reserve. At the time of contact, indigenous people occupied seasonal 

camps and temporary villages throughout traditional territories. In the late 1800s, the individual tribes of 

the region coalesced at what had been their winter villages. The area’s extant tribes live within their 

earlier territories and use a similar set of subsistence resources and in this way maintain long standing 

ties to place. For Native people, this tie to place and the harvest, trade, and use of traditional foods are 

key elements in fostering Native cultural identity (Alaska Native Heritage Center 2014).
Environment and Effects 3

Final EIS 3-242 Subsistence

Figure 3.12-1

Native/Non-Native Components of Southeast Communities

Note:

1 Estimates are annual totals developed as part of the 2014-2018 American Community Survey 5-Year Estimates.

Source: U.S. Census Bureau 2019a

Subsistence Economy

Subsistence use of fish and wildlife has been and continues to be an important component of the 

economies of Southeast Alaska communities. In Native communities, harvest and use of wild resources 

supported the subsistence-based economy that predated the introduction of cash income. In the modern 

era, beginning in the late-1700s, the economies of Native communities have undergone a progressive 

transformation, incorporating cash income into the subsistence-based system. Southeast Alaska 

communities that were settled primarily by non-Native immigrants have also depended on a mix of 

subsistence use of wild resources and cash income.

Cash income in most Southeast Alaska rural communities is limited and intermittent, and frequently 

supports the purchase of fuel and equipment that are part of subsistence harvest technology. 

0% 20% 40% 60% 80% 100%

Edna Bay

Hyder

Kupreanof

Point Baker

Port Alexander

Port Protection

Tenakee Springs

Whale Pass

Thorne Bay

Skagway

Coffman Cove

Petersburg

Naukati Bay

Hollis

Gustavus

Juneau

Haines

Sitka

Ketchikan

Wrangell

Craig

Yakutat

Kasaan

Elfin Cove

Klawock

Angoon

Pelican

Hoonah

Saxman

Metlakatla

Kake

Hydaburg

Native Non-Native
Environment and Effects 3

Final EIS 3-243 Subsistence

Subsistence harvests have been found to fill essential food needs in rural communities in the region. 

These harvests are also customarily shared among community residents and between members of 

different communities. Some subsistence products are traded and bartered within the region. Subsistence 

harvests are not geared toward market sale or commercial profit. A mixed subsistence-market economy 

in which subsistence harvests and cash income are complementary characterizes the economies of most 

of the region’s rural communities and provides the economic basis for a way of life that is highly valued in 

these communities (Wolfe 2004; Wolfe and Walker 1987).

A compilation of traditional knowledge about the fisheries of Southeast Alaska demonstrated the 

continuing importance of sharing and trade of wild resources as a traditional practice across the region 

(Brock and Coiley-Kenner 2009). This compilation identified sharing as one of the most important 

activities associated with harvesting salmon, for example, with many respondents saying that sharing 

subsistence harvests is a core Tlingit value. Households who do not fish for salmon are often given fish 

by family and friends. Pride and respect were also identified as key concepts in the distribution of wild 

resources. Wild resources are traded in local communities and throughout the region, with sockeye 

salmon, for example, traded for other types of wild resources or trade items (Brock and Coiley-Kenner 

2009). These concepts documented in the above compilation were also expressed with respect to other 

subsistence resources during the subsistence public hearings held for this rulemaking. People providing 

testimony in Hoonah, for example, noted that when they hunt and gather, it is not for one household, but 

for many, and also reiterated that sharing harvest is an integral part of Tlingit culture.

Subsistence research conducted in Southeast Alaska over the past two decades has included detailed 

community studies, use area mapping, household surveys, and studies of specific subsistence harvests. 

During the 1980s, the Forest Service supported research that examined the impacts of timber harvests on 

the Tongass on subsistence resources in the area. The Tongass Resource Use Cooperative Survey 

(TRUCS) was completed in 1988. Data from TRUCS are summarized in the 1997 Tongass Land 

Management Plan Revision FEIS (USDA Forest Service 1997a).

From 1987 to 2001, interviews were conducted with 1,064 households in 24 Southeast Alaska 

communities as part of the Tongass Land and Resource Management Plan (Forest Plan) subsistence 

administrative studies. This fieldwork was conducted cooperatively with the participation of the Forest 

Service, Alaska Department of Fish and Game (ADF&G), and the area's tribes and communities. 

Summary data from this and more recent community harvest assessments were compiled from the 

ADF&G Subsistence Community Profile Database (www.state.ak.us) and harvest levels are presented by 

community and species in Figure 3.12-2. The data presented in this figure are the most recent available 

in the ADF&G database. The year these data were collected does, however, vary by community, and the 

data summarized should be considered a general overview of harvest patterns rather than an exact 

representation of current harvest activities.
Environment and Effects 3

Final EIS 3-244 Subsistence

Figure 3.12-2

Per Capita Subsistence Harvest by Community and Resource Type

Notes:

The year these data were collected varies by community, as follows:

1987: Elfin Cove, Gustavus, Hyder, Metlakatla, Meyers Chuck, Pelican, Port Alexander, Skagway, and Tenakee 

Springs

1996: Kake, Point Baker, Port Protection, and Sitka

1997: Craig, Hydaburg, and Klawock

1998: Coffman Cove, Edna Bay, Hollis, Kasaan, Naukati Bay, and Thorne Bay

1999: Saxman

2000: Petersburg, Wrangell, and Yakutat

2012: Angoon, Haines, Hoonah, Hydaburg, and Whale Pass

Source: ADF&G 2006, 2018b

The findings of this research are summarized in an unpublished paper by Schroeder and Mazza (2005) 

who identify a number of key subsistence characteristics that are evident in these data and generally 

consistent with the following past findings:

Wild foods account for a large share of the diet for residents of the studied communities, ranging from 

48 pounds per capita for Skagway in 1987 to over 500 pounds per capita for Hydaburg in 2012 

(Figure 3.12-2). The average American diet includes about 225 pounds of meat, fish, and poultry on a 

per capita basis. In more than half of the identified communities, wild foods came close to, or 

0 50 100 150 200 250 300 350 400 450 500 550

Skagway

Metlakatla

Haines

Petersburg

Wrangell

Hollis

Kake

Thorne Bay

Angoon

Sitka

Saxman

Craig

Gustavus

Naukati Bay

Whale Pass

Elfin Cove

Coffman Cove

Point Baker

Port Alexander

Klawock

Tenakee Springs

Hoonah

Hyder

Pelican

Edna Bay

Yakutat

Meyers Chuck

Port Protection

Kasaan

Hydaburg

Per Capita Harvest (Ibs)

Fish Marine Invertebrates Land Mammals Marine Mammals Plants and Other
Environment and Effects 3

Final EIS 3-245 Subsistence

exceeded, this national average (Figure 3.12-2). Although residents of subsistence communities 

purchase food, most could meet their entire protein need from wild sources.

Marine resources, including fish, mammals, and plants, comprise the majority of subsistence harvests 

in all communities when measured by food weight. Marine resources account for more than half of 

total per capita harvest in all Southeast Alaska communities, ranging from 55 percent in Tenakee 

Springs to 88 percent in Skagway (Figure 3.12-2). 

More recent subsistence harvest levels in the main Native communities and the larger non-Native 

communities appear very similar to harvest levels estimated in the late 1980s or before. Harvest 

levels identified in the recent assessments conducted in Angoon, Hoonah, Hydaburg, Kake,

Petersburg, Wrangell, and Yakutat, for example, are very similar to those identified in earlier studies. 

In a few communities, such as Coffman Cove, Kasaan, Klawock, and Port Protection, there are larger 

differences in harvest levels over time. However, these differences seem to be more influenced by 

special events or small community sizes than by patterned changes in subsistence harvests.

Subsistence harvest levels vary considerably from community to community. Recent research and 

other data suggest that intercommunity variability may not be fully explained by ethnicity, income, 

community size, or access to resources. Other factors, such as community demographic composition, 

cultural traditions and orientations, and community history, may have a larger influence on harvest 

levels than more easily analyzed standard socioeconomic variables.

Subsistence harvesters use a wide variety of species, but use tends to be concentrated on a 

relatively small number of species. In Yakutat, for example, individual subsistence harvesters use as 

many as 65 of the 150 different species that are harvested in the community, but 84 percent of overall 

community harvest (in food weight) involves just 10 species. That said, the contribution of a particular 

species to the total subsistence harvest generally appears to vary from year to year, although the 

overall total harvest in food weight may remain nearly constant.

A small number of high harvesting households account for a disproportionate share of the total 

community harvest and tend to harvest more fish and wildlife than their family members can 

consume. The surplus is distributed to other subsistence users through a kinship network and through 

barter and trade. These networks are also used to distribute specialty subsistence products such as 

herring roe and eulachon (hooligan) oil, which are produced in large quantities in only a few 

communities. In Yakutat, for example, just 25 percent of subsistence households account for about 

75 percent of total community subsistence harvest (in terms of food weight), with the lowest 

harvesting 50 percent of households taking just 8 percent of the total community harvest.

Subsistence Use Areas

Historically, subsistence use occurred where access to the resources cost less in energy than the 

resources gathered. Many of the gathering activities occurred in easily accessible areas. These activities 

occurred close to settlements where they could be accessed by foot or boat. Over time, as new 

technology developed, ease of access meant a movement outward into new resource use areas. The 

advent of motorized boats and the development of road systems associated with timber harvest activities 

have had a substantial influence on subsistence gathering activity in Southeast Alaska. Today, all 

communities use motorized boats and many are tied to nearby lands by road systems.

The distribution of subsistence harvest activity is described in further detail in the 1997 Tongass Land 

Management Plan Revision FEIS, with traditional household deer hunting areas mapped in Appendix H. 

These areas were identified based on the 1987 TRUCS (Kruse and Muth 1990). The traditional 

household deer hunting areas mapped in Appendix H show that the road systems are extensively used. 

This is particularly true on Prince of Wales Island. These maps also show that subsistence use tends to 

be concentrated in close proximity to individual communities and along beaches.

Each of the communities in Southeast Alaska has a distinct home range where concentrated use occurs, 

with a wide range of use typically occurring on a less concentrated scale outside the normal home range. 

More than half (54 percent) of all households surveyed in rural Southeast Alaska in 1987 traveled a 

minimum of 11 miles by boat to reach the one reliable deer hunting area that they chose to describe in 

TRUCS (Kruse and Muth 1990). An additional 18 percent of all households also used boats to reach their 
Environment and Effects 3

Final EIS 3-246 Subsistence

reliable deer hunting area, but traveled shorter distances (10 miles or less). Only 15 percent of all 

households used cars or trucks to travel to their most reliable areas. Thirteen percent used some other 

form of transportation, such as airplanes, walking, all-terrain vehicles, and the Alaska Marine Highway 

System (Kruse and Muth 1990).

While the majority of use occurs within about a 15-mile radius of rural communities, nearly all of the 

forested lands of the Tongass are used to some degree for subsistence deer hunting (USDA Forest 

Service 1997a). Appendix H in the 1997 Tongass Land Management Plan Revision FEIS also displays, 

by community, the individual WAAs where approximately 75 percent of the average annual deer harvest

occurred.

Kruse and Muth (1990) found that nearly one-half of the households harvesting deer mentioned the 

existence of clearcuts of various ages occurring in presently reliable areas (44 percent), most-often-used 

areas (48 percent), and areas no longer used (55 percent). They also reported that old-growth forests 

were mentioned as most reliable by 90 percent of households harvesting deer, were most-often-used 

areas by 91 percent of households, and were areas no longer used by 90 percent of those households 

harvesting deer.

Many of the fish and wildlife resource values of Southeast Alaska watersheds, based on the VCU 

classification of the Tongass, are summarized in the 1998 Tongass Fish and Wildlife Resource 

Assessment (ADF&G 1998). This report shows the relative value of areas for black bear, brown bear, 

deer, sport fishing, salmon production, and subsistence use. This resource assessment also included a 

ranking of the VCUs that have the highest community values.

Environmental Consequences

The following section provides a Forest-wide evaluation that assesses the three factors related to 

subsistence uses identified by ANILCA: abundance and distribution, access, and competition. This 

general analysis relies on the community discussions presented in Appendix E and also on the Forestwide effects analyses from the related resource sections (primarily Fish and Wildlife from the Key Issue 3

discussion) where abundance and distribution are of concern. The community discussions presented in 

Appendix E include information related to each community use area and assess potential subsistence 

impacts by community and alternative. Originally identified as part of the 1997 Forest Plan Revision 

(USDA Forest Service 1997a), community use areas represent the general area commonly used or related 

to by many of the community’s residents in their local day-to-day work, recreational, and subsistence 

activities. These areas do not necessarily define the limits of a community’s use or represent traditional use 

areas or territories. Community residents may also work or pursue recreation or subsistence activities 

elsewhere on the Forest. Traditional territories are shown in Appendix F, which presents maps from 

Goldschmidt and Haas’ (1946) landmark ethnographic study of Alaska Native land use, occupancy, and 

possession in Southeast Alaska.

Section 810 of ANILCA requires the Forest Service, in determining whether to withdraw, reserve, lease, 

or otherwise permit the use, occupancy, or disposition of NFS lands in Alaska, to evaluate the potential 

effects on subsistence uses and needs, followed by specific notice and determination procedures should 

there be a significant possibility of a significant restriction of subsistence uses. The Alaska Land Use 

Council’s definition of “significantly restrict subsistence use” is one guideline used in the evaluation:

“A proposed action shall be considered to significantly restrict subsistence uses, if after any 

modification warranted by consideration of alternatives, conditions, or stipulations, it can be 

expected to result in a substantial reduction in the opportunity to continue subsistence uses of 

renewable resources.”

Considerations of abundance and distribution, access, and competition (by non-rural residents) are 

mentioned.

It should be noted that the term “significant” as used in this context does not have the same definition as 

used in the implementing regulations for the NEPA. See 40 CFR 1508.27 for definitions of “significant” in 

a NEPA context.
Environment and Effects 3

Final EIS 3-247 Subsistence

The U.S. District Court Decision of Record in Kunaknana v. Watt provided additional clarification. In part it states:

“restrictions for subsistence uses would be significant if there were large reductions in abundance 

or major redistribution of these resources, substantial interference with harvestable access to 

active subsistence-use sites, or major increases in non-rural resident hunting.”

Direct and Indirect Effects

Abundance and Distribution

Based on the 1987 survey information compiled as part of TRUCS, 61 percent of subsistence resources 

(by weight) are fish or marine invertebrates, 21 percent are deer, 4 percent are other land mammals, and 

another 3 percent are marine mammals. More recent community data compiled by ADF&G (2014) 

indicate that fish and marine invertebrates still comprise the majority of subsistence harvest per capita (in 

pounds). As shown in Figure 3.12-2, the share of total subsistence harvest that consists of fish and 

marine invertebrates ranges from 55 percent in Tenakee Springs to 88 percent in Skagway.

The subsistence analysis conducted for the 1997 Forest Plan Revision FEIS found that the primary 

subsistence resource likely to be significantly affected by the alternatives was Sitka black-tailed deer. 

Some effects to fish habitat may also result from land management activities, but the analysis concluded 

that the magnitude of the effects could not be calculated. Alternatives with more roads and timber 

production within riparian management areas and/or beach and estuary fringe were found to generally 

have the highest potential for adverse effects to fish and wildlife resources in the Tongass. As a result of 

their association with old-growth forest habitat, which is the main terrestrial habitat type affected by the 

alternatives, deer are considered the “indicator” for potential subsistence resource consequences 

concerning the abundance and distribution of the resources. Effects to subsistence resources have the 

potential to affect subsistence users.

Both the 1997 Forest Plan Revision FEIS and 2008 Forest Plan Amendment FEIS concluded that deer 

habitat capabilities in several portions of the Tongass may not be adequate to sustain the current levels of 

deer harvests, and that implementation of any of the 1997 and 2008 alternatives could, therefore, be 

accompanied by a significant possibility of a significant restriction on the abundance and/or distribution of 

subsistence uses of deer. This possibility was largely due to the continuation of reduced habitat 

capabilities resulting from past habitat alterations, which is why it applied to all alternatives.

The 2016 Forest Plan Amendment EIS found that the possibility of a significant restriction, resulting from 

a change in abundance or distribution, would be less than the possibility under the 1997 Forest Plan or 

2008 Forest Plan for all of the alternatives considered in that EIS because of the lower anticipated rates 

of timber harvest. Further, although the harvest of old growth is likely to have negative effects on deer 

habitat, the vast majority of the harvest proposed under the 2016 Forest Plan Amendment EIS 

alternatives represented the harvest of young-growth stands that are currently in the stem exclusion stage 

of plant succession.

The interagency deer habitat capability model was used to assess existing habitat capability within the 

planning area. Table 3.3-16 (Wildlife section) summarizes the modeled deer habitat capability by 

biogeographic provinces. Forest-wide, approximately 89 percent of the original (1954) habitat capability 

remains, ranging from 72 to 100 percent depending on the biogeographic province. The greatest 

reductions in deer habitat capability have occurred in provinces where timber harvest has been 

concentrated (the North Central Prince of Wales, East Baranof, and Etolin Island and vicinity 

biogeographic provinces). Harvesting these stands currently in the stem exclusion stage would convert 

them to the stand initiation stage or open them up to provide more light to forage, which is generally of 

much higher value to deer. As a result, the harvest under all of the 2016 Forest Plan Amendment EIS 

alternatives would have both adverse and beneficial effects on deer habitat, depending on the stand. 

The alternatives evaluated in this EIS would all harvest approximately the same amounts of young-growth 

and old-growth acres and, therefore, the risk of a significant restriction would be the same under all of the 

alternatives. The transition from predominantly old-growth harvest to young-growth management would 

continue to slow the long-term decrease in deer habitat capability due to the reduction in POG harvest, 
Environment and Effects 3

Final EIS 3-248 Subsistence

under all of the alternatives. Because long-term POG harvest and road densities are not expected to 

differ significantly among alternatives, effects on old-growth–dependent wildlife species, including deer, 

are expected to be almost identical to those predicted under the 2016 Forest Plan Amendment EIS. 

Localized effects would likely vary by alternative (depending on the specific projects identified and 

implemented), but future harvest and road building is not expected to result in large reductions in 

abundance or a major redistribution of deer under any of the alternatives. 

In the short term, the effects of past harvest would override the effects of new harvest during the next 10 

years. In the long term, future harvesting of old growth would decrease substantially following the younggrowth transition under all of the alternatives, reducing the risk of a significant restriction when viewed in 

the context of past Forest Plan harvest projections. Total maximum old-growth harvest over 100 years 

would be approximately 42,500 acres under all of the alternatives. While harvest levels are expected to 

be the same or similar under all alternatives, the distribution of acres harvested is likely to vary by 

alternative. Maps showing the distribution of suitable old-growth and young-growth timber acres by 

alternative are provided in Appendix D for the community use areas identified for each of the 32 

communities evaluated in this EIS (see Appendix E).33, 34 The areas shown in these maps represent the 

distribution of suitable acres, not projected harvest acres, which would generally be a smaller subset of 

the areas shown. Appendix E presents an assessment of subsistence for each community. This 

assessment presents suitable old-growth and projected old-growth harvest by the most frequently used 

WAAs by community and alternative.

Access

Subsistence users typically hunt and fish in traditional areas surrounding their communities. Many of the 

communities in Southeast Alaska are compact, centralized places surrounded by undeveloped land with 

limited infrastructure. Most subsistence food production is supported by a central or core use area 

surrounding a community. Traditional household deer hunting areas are identified for 32 communities in 

Southeast Alaska in Appendix H to the 1997 Forest Plan EIS. Access to and use of surrounding areas for 

subsistence activities may be guided by local customary rules, as well as federal and state regulation and 

economic considerations, with traditional use areas for different communities often overlapping at their 

margins. Customary rules guiding subsistence harvest may be related to local histories and social 

customs of clans and communities (Wolfe 2004).

This EIS is programmatic, meaning that it examines direction and allowable activities for broad land areas 

and does not schedule specific activities in specific locations. This makes it difficult to evaluate the effects 

of the alternatives on particular groups of subsistence users or resources. The following discussion 

addresses potential impacts at the programmatic or forest scale and assesses relative potential impacts 

in terms of overall proposed road construction and timber management activities.

Viewed at this scale, none of the alternatives would directly limit the use of public lands for the purposes 

of subsistence gathering activities. Traditional access methods would remain available under all the 

alternatives for present and foreseeable future activities. Access methods differ by Game Management 

Unit (GMU). Those subsistence users who use a boat as their primary method of access may have 

temporary and localized disruptions where young-growth harvest occurs in the beach fringe.

Data on documented deer harvest by transportation type are available at the GMU level. Data from the 

2013 Deer Management Report are presented by transportation type and GMU in Table 3.12-1. GMU 4, 

the ABC Islands (Admiralty, Baranof, and Chichagof Islands), accounted for slightly more than half (52 

percent) of reported deer harvested in Southeast Alaska in 2013 (5,434 deer), with GMU 2, Prince of 

Wales Island, accounting for more than a third (36 percent) (3,702 deer). Hunters accessing hunting 

areas by boat accounted for 53 percent of total deer harvest in 2013. Hunters accessing the area by 

33 These maps are available electronically only. They are included on the electronic storage device accompanying this document and 

are also available online at: https://www.fs.usda.gov/project/?project=54511

34 The suitable old-growth acres shown in these maps include medium and high volume old growth only. In addition, the maps show 

only those suitable acres in VCUs with higher stumpage values as estimated for the 2008 Forest Plan using the Spectrum model. Oldgrowth harvest is assumed to be more likely to occur in these areas, with the majority of harvest expected to occur on the five south 

ranger districts (Craig, Ketchikan Misty Fjords, Petersburg, Thorne Bay, and Wrangell).
Environment and Effects 3

Final EIS 3-249 Subsistence

highway vehicle accounted for 33 percent of total deer harvest. The relative share of harvest by 

transportation type varies by GMU, with boat access, for example, accounting for 84 percent of harvest in 

GMU 1B, but just 27 percent in GMUs 1C and 2. Highway vehicle was the most frequently used method 

of access in GMU 2, Prince of Wales Island, accounting for almost two-thirds (65 percent) of deer harvest 

in 2013 (Table 3.12-1). This relatively high share reflects the more densely roaded nature of Prince of 

Wales Island and may be considered generally indicative of the effects of timber harvest and associated 

road building in areas connected to communities and the marine highway system.

New road construction is likely to result in the development of some new use patterns around some 

communities, but these changes are not likely to lead to a significant possibility of a significant restriction 

of subsistence access to the resources. Localized effects would likely occur and would vary by alternative 

(depending on the specific projects identified and implemented), but future harvest and road building are 

not expected to result in substantial interference with access to active subsistence use sites. New use 

patterns may, however, favor some subsistence groups and disadvantage others. Subsistence access 

may be via a number of different transportation types and often involves more than one form of 

transportation.

Subsistence users may, for example, access an area via boat followed by road (and on-foot) or via boat 

and on-foot, with types of access varying by location and user. Some hunters may access specific areas 

using more than one form of transportation, but others may favor one form of transportation over another, 

say highway vehicle over on-foot.

Table 3.12-1

Deer Harvest by Game Management Unit and Transportation Type, 2013

GMU 

Number1 Area2

Deer 

Harvested

Percent of Deer Harvested by Transportation Type3

Airplane Boat

3- or 4-

Wheeler

Highway 

Vehicle Foot Unknown

1A Ketchikan4 265 NA NA NA NA NA NA

1B Petersburg5 89 1 84 4 1 6 4

1C Juneau 413 0 27 0 47 21 5

25 Prince of Wales Island 3,702 3 27 NA 65 2 3

3 Central Islands 474 2 38 8 42 3 7

4 ABC Islands6 5,434 8 73 0 9 3 7

Total7 10,377 556 5,333 41 3,289 343 549

Percent of Total 100 5 53 0 33 3 5

Notes:

NA = not available; ABC Islands = Admiralty, Baranof, and Chichagof Islands 1 Game Management Units (GMUs) are a geographic unit of measurement established and used by ADF&G.

2 Harvest estimates are reported totals only and do not include estimates of unreported and illegal harvest.

3 These data were compiled as part of ADF&G’s mandatory hunt report cards issued in conjunction with deer harvest tickets. 

Hunters report transportation method for traveling to their hunting areas. Numbers may not sum to 100 percent due to 

rounding.

4 Airplane data are not available for this GMU. 

5 The foot category for this GMU includes 1 percent of hunters that used a horse/dog team to access their hunting area. 

6 In GMU 2, 3- or 4-Wheelers were accounted for in the Highway Vehicle category. 7 Total deer harvested by transportation type exclude Unit 1A, where transportation information is not available.

Source: ADF&G 2015

While there would be some new road access under all alternatives in the long run, nearly all new roads 

constructed under the alternatives would be closed following harvest, based on current transportation 

management practices. These roads would, therefore, not be available for use by highway vehicles or 

high-clearance vehicles. They may, however, be available for access by other methods (e.g., all-terrain 

vehicle or on foot) and would, as a result, have the potential to affect existing subsistence use patterns, 

especially in the short term. The action alternatives would increase the acres available for timber harvest, 

but harvest levels are expected to remain the same across all alternatives. As a result, the amount of new 

or reconstructed road miles would be similar across the alternatives, but would be lowest under 
Environment and Effects 3

Final EIS 3-250 Subsistence

Alternatives 1 and 2 and highest under Alternatives 4, 5, and 6. Alternative 3 would likely result in more 

roads than Alternatives 1 and 2, and fewer than Alternatives 4 through 6 (Table 3.3-21).

Some subsistence users have a preference for unroaded areas. Viewed at a programmatic level, 

Alternatives 1 and 2 would likely have the lowest impact on subsistence users who prefer unroaded areas 

because timber harvest would be limited to areas outside existing IRAs under Alternative 1 and areas 

outside IRAs and roaded roadless under Alternative 2. These alternatives would, therefore, tend to 

increase road density in already developed areas rather than provide new access to presently 

undeveloped areas. More harvest is likely to occur in the vicinity of existing roads under these alternatives 

with corresponding potential impacts to subsistence use. 

Another potential access impact relates to the effects of clearcut harvesting on the landscape. 

Subsistence hunters have varying opinions on the effects of clearcut harvest on hunting success. Some 

hunters say that timber harvest clearcuts are productive for some years after harvest, while others prefer 

not to use clearcuts. Hunters interviewed on Prince of Wales Island, for example, reported that the best 

hunting in clearcut areas begins approximately 2 years after an area is logged, with hunt quality typically 

starting to decline 9 years after the area was cut (Brinkman 2006). Concern has been expressed by 

hunters that clearcuts in the process of regrowth become impassable to hunters after a period of time 

(Galginaitus 2004). Young-growth harvest would likely improve hunting in many previously harvested 

areas, particularly those stands that are currently in the stem exclusion stage of plant succession. 

Harvesting these stands would convert them to the stand initiation stage which would initially increase 

forage quantity and quality for deer, and therefore provide for increased hunting opportunities in these 

areas for a period of time (see the Wildlife section).

In addition to long-term access effects, timber management activities may also have short-term, 

temporary displacement effects for subsistence users because it is standard practice to close logging 

roads to outside traffic when logging is taking place. Subsistence users who use existing roads for access 

would be preempted from using those roads for the duration of logging activity in the affected area. These 

types of effects would, however, be short term and temporary, and would not be likely to lead to a 

significant possibility of a significant restriction of subsistence access to the resources. In addition, as 

previously noted, most or all new roads would be closed following harvest.

Competition

More than half (55 percent) of the population in Southeast Alaska in 2019 resided in Juneau (44 percent) 

or Ketchikan city (11 percent) and is, therefore, considered non-rural from a subsistence perspective 

(Alaska DOL 2019).

Residents in the remaining communities are considered rural. Competition for the more abundant wildlife 

and fisheries resources near rural communities is affected by a number of factors, including fish and 

game regulations, the mobility of community residents, the Forest-wide distribution of game species, 

decreases in resource populations as a result of habitat reductions and/or over-harvest, and types of 

community access, such as roads, ferries, and commercial air services.

The following assumptions were made for the purposes of evaluating potential impacts to competition:

New road construction adjacent to communities with ferry access will result in increased competition 

from outside communities.

New road construction adjacent to existing road systems where interties between communities exist 

will result in increased competition from surrounding communities associated with the interconnected

roads.

Habitat reductions will result in increased competition if regulations allow sport use to remain 

constant, with the same number of users seeking fewer huntable resources.

The demand for resources will remain constant or increase slightly as the habitat capability remains 

the same or declines over time.
Environment and Effects 3

Final EIS 3-251 Subsistence

Given these assumptions, the 1997 Forest Plan Revision FEIS concluded that implementation of the 

Selected Alternative (Alternative 11) would result in a significant possibility of a significant restriction of 

subsistence use of deer by increasing competition for some subsistence resources by non-rural, as well 

as rural residents. This was judged most likely to occur on Chichagof, Baranof, and/or Prince of Wales 

Islands, where competition for deer and some other land mammals was identified as heavy, and habitat 

capability had already been reduced as a result of timber harvest.

The significant possibility of a significant restriction, resulting from a change in competition, still exists but 

would be less than the possibility under the 1997 Forest Plan Revision and 2008 amended Forest Plan 

for all of the alternatives considered in this EIS because of the much lower anticipated rates of timber 

harvest and road construction. This finding is consistent with the finding for the 2016 Forest Plan 

Amendment EIS. Viewed at a programmatic level, Alternatives 1, 2, and 3 would have a higher potential 

to result in additions to existing road systems because harvest would be limited to areas outside existing 

IRAs with the exception of roaded roadless (Alternatives 2 and 3) and logical extension areas (Alternative 

3). Harvest could also occur in these areas under Alternatives 4, 5, and 6, but additional acres in 

presently undeveloped areas would also be available for harvest under these alternatives. 

Cumulative Effects

Cumulative effects are discussed in four categories.

1. Effects Resulting from Timber Harvesting of Private Lands. Alaska Native corporation 

lands adjacent to the Tongass support extensive timber harvest operations, and old-growth 

forest wildlife habitat capability on Alaska Native corporation lands (especially that for deer) 

has declined. This decline has occurred primarily on North Chichagof, Kupreanof, Admiralty 

(localized), and Prince of Wales Islands, as well as in some mainland areas. The resulting 

lower habitat capabilities on these private lands are likely to increase hunting demands in 

adjacent National Forest areas, increasing competition and potentially leading to reduced 

hunter success, reduced or eliminated sport seasons, and in some places reduced or 

eliminated subsistence seasons.

2. Effects from Past Activities. Timber harvest has been more influential in changing the 

landscape than any other use of the resources of the Tongass. Timber harvest has 

historically been accompanied by road building, log transfer facility development, and 

reductions in old-growth forest habitat.

3. Effects of Present Activities. Implementation of the 2016 Forest Plan established an 

annual average PTSQ of 46 MMBF prior to the young-growth transition, with annual oldgrowth harvest stabilized at 5 MMBF following the transition to support small operators and 

specialty products. Under this plan, an estimated total of 24,000 acres of old-growth habitat 

would be converted to young-growth habitat after 25 years, with a total of 42,500 old-growth 

acres converted after 100 years. These estimates are assumed to remain the same under 

all of the alternatives considered in this EIS, with similar miles of road construction and 

reconstruction anticipated under each alternative, as discussed in the Effects section, 

above. Two mining operations, the Greens Creek Mine on Admiralty Island and Kensington 

Mine north of Juneau, are currently operating.

4. Effects of Reasonably Foreseeable Future Activities. Timber harvest activities have 

typically been accompanied by new access and often increased use of subsistence 

resources by rural and non-rural residents. The effects of timber harvest on deer habitat 

capability would be reduced over time as harvest areas transition from old growth to young 

growth under all alternatives.

Counting all lands in Southeast Alaska, an estimated 86 percent of the original old growth remains 

today. After 100 years of implementing any of the alternatives, it is estimated that the percentage of 

the original old growth remaining would be 82 percent, due to combined harvest on NFS and nonNFS lands, assuming maximum rates of harvest. The Biological Diversity section (see Key Issue 3, 

above) quantifies the estimated effects of cumulative future harvest on the amount of old growth by 

biogeographic province for all of Southeast Alaska (see Tables 3.3-10, 3.3-11, and 3.3-12).
Environment and Effects 3

Final EIS 3-252 Subsistence

Timber harvest of Alaska Native corporation lands is anticipated to continue at a relatively low but 

constant level over the next decade. New land conveyances under Public Law 113-291 could result in 

some previously unharvested areas being logged.

Actual mineral development is difficult to predict, but effects to subsistence resources would be highly 

localized where it does occur. Appendix B provides a full list of all the projects considered in the 

cumulative effects analysis.

ANILCA Determination

An ANILCA Section 810 evaluation and determination is not required for approval of the proposed Alaska 

Roadless Rule, which is a rulemaking process and a programmatic level decision and not a determination 

whether to “withdraw, reserve, lease, or otherwise permit the use, occupancy, or disposition” of National 

Forest land. This EIS is part of that rulemaking process and, therefore, does not require an ANILCA 

Section 810 evaluation and determination. However, in the spirit of cooperation, the Record of Decision 

voluntarily provides a forest-wide evaluation of the selected alternative for the Alaska Roadless Rule in 

accordance with ANILCA Section 810 (16 U.S.C. § 3120).

Public hearings on subsistence issues for the proposed Alaska Roadless Rule were held in 18 

communities throughout Alaska (Angoon, Craig, Ketchikan, Petersburg, Sitka, Tenakee Springs, 

Wrangell, Yakutat, Point Baker, Hoonah, Skagway, Gustavus, Haines, Thorne Bay, Kake, Kasaan, 

Hydaburg, and Pelican) between the Draft and Final versions of this EIS.
Environment and Effects 3

Final EIS 3-253 Environmental Justice

Environmental Justice

Affected Environment

Executive Order 12898, Federal Actions to Address Environmental Justice in Minority Populations and 

Low-Income Populations, requires each federal agency to make the achievement of environmental justice

part of its mission by identifying and addressing disproportionately high and adverse human health or 

environmental effects of its programs, policies, and activities on minority and low-income populations. The 

Order further stipulates that the agencies conduct their programs and activities in a manner that does not 

have the effect of excluding persons from participating in, denying persons the benefits of, or subjecting 

persons to discrimination under such programs, policies, and activities because of their race, color, or 

national origin.

Race and ethnicity are shown by borough in Table 3.13-1. According to the most recent Census 

estimates, approximately 63 percent of the population of Southeast Alaska is White. American Indian and 

Alaska Native was identified as the largest minority group, accounting for 15 percent of the total 

Southeast Alaska population. Table 3.13-1 indicates that there are relatively large proportions of Alaska 

Natives in Prince of Wales-Hyder, Hoonah-Angoon, and Yakutat. The populations of Haines, Juneau, 

Petersburg, and Skagway in contrast, have relatively low proportions of Alaska Natives, below the 

Southeast Alaska average of 15 percent.

Alaska Native populations are identified as a percentage of total population by community in Table E-1 in 

Appendix E. This information is presented graphically in Figure 3.12-1 (in the Subsistence section). These 

data indicate that 16 of Southeast Alaska’s 32 communities have Alaska Native populations that comprise 

a larger share of total population than the regional average. Alaska natives comprised a particularly large 

share of total population in Hydaburg (72 percent), Kake (72 percent), Saxman (71 percent), Metlakatla

(71 percent), and Hoonah (54 percent), all considered traditional Native communities. Other communities 

considered traditional Native communities include Angoon, Klawock, Kasaan, Saxman, and Yakutat.

Table 3.13-1

Race/Ethnicity by Borough/Census Area1

Geographic Area

Total 

Population

Percent of Total Population

White2

American 

Indian and 

Alaska 

Native2

Hispanic 

or Latino

Other 

Race2,3

Two or 

More 

Races2

Haines Borough 2,518 78 8 4 3 7

Hoonah-Angoon CA 2,132 43 36 7 6 8

Juneau City and Borough 32,330 65 11 7 9 9

Ketchikan Gateway Borough 13,804 64 14 5 9 8

Petersburg Borough 3,255 63 7 10 10 9

Prince of Wales-Hyder CA 6,474 45 39 4 2 9

Sitka City and Borough 8,738 62 12 6 8 11

Skagway Municipality 1,061 84 4 5 3 4

Wrangell City and Borough 2,484 66 17 5 3 8

Yakutat City and Borough 689 42 27 7 11 12

Southeast Alaska 73,485 63 15 6 8 9

Alaska 738,516 61 14 7 11 7

CA = Census Area

1 Estimates are annual totals developed as part of the 2014-2018 American Community Survey 5-Year Estimates. 2 Non-Hispanic only. The Federal Government considers race and Hispanic/Latino origin (ethnicity) to be two separate and distinct 

concepts. People identifying as Hispanic or Latino origin may be of any race. In this table people identifying as Hispanic or Latino 

are included in the Other Race category only.

3 The “Other Race” category presented here includes census respondents identified as Black or African American, Asian, Native 

Hawaiian and Other Pacific Islander, or Some Other Race. 

Source: U.S. Census Bureau 2019a
Environment and Effects 3

Final EIS 3-254 Environmental Justice

Median household income and the percent of households below the poverty line are presented by 

borough in Table 3.13-2. Statewide, the estimated share of the population below the poverty line was 

10.8 percent in 2018. Median household income was approximately $76,700. Juneau is the only borough 

in the region with median household income above the state median. Median household income as a 

share of the state median in the other boroughs ranged from 71 percent in Prince of Wales-Hyder to 94 

percent in Skagway (Table 3.13-2). The share of the population below the poverty level in 2018 ranged 

from 5.3 percent in Skagway to 15.2 percent in Prince of Wales-Hyder (Table 3.13-2).

The percent of households below the poverty line and the median household income are identified by 

community in Table E-1 in Appendix E. The U.S. Census identified 16 communities in Southeast Alaska 

with 10 percent or more of their population below the poverty line. All but three of the communities 

identified in Table E-1 where data are available had median household incomes below the state average.

Table 3.13-2

Income and Poverty by Borough/Census Area1

Geographic Area

Median Household Income Population 

Below the 

Poverty Level 

2018 Dollars (Percent)

Percent of 

State Median

Haines Borough 64,342 84 9.0

Hoonah-Angoon CA 63,603 83 9.7

Juneau City and Borough 88,213 115 7.9

Ketchikan Gateway Borough 70,356 92 10.5

Petersburg Borough 66,907 87 8.2

Prince of Wales-Hyder CA 54,191 71 15.2

Sitka City and Borough 71,534 93 7.5

Skagway Municipality 72,237 94 5.3

Wrangell City and Borough 57,583 75 7.8

Yakutat City and Borough 65,833 86 6.7

Alaska 76,715 100 10.8

CA = Census Area

1 Estimates are annual totals developed as part of the 2014-2018 American Community 

Survey 5-Year Estimates. 

Source: U.S. Census Bureau 2019b, 2019c

Environmental Consequences

As discussed elsewhere, this EIS is programmatic and, as such, examines direction and allowable 

activities for broad land areas, rather than schedules specific activities in specific locations. The action 

alternatives would increase the acres available for timber harvest, but harvest levels are expected to 

remain the same across all alternatives. In addition, while there may be some variation by alternative, the 

amount of new or reconstructed road miles is expected to be broadly similar across all alternatives. 

Similarly, the distribution of harvest is likely to vary by alternative, but it is difficult to predict this variation 

with any degree of accuracy because it depends on the specific projects proposed, economic conditions, 

and many other factors. This makes it difficult to evaluate the effects of the alternatives on particular 

communities or populations. 

The potential effects of the alternatives on the economic and social environment of Southeast Alaska are 

discussed in the Key Issue 2 section of this document. The principal regional effects would be those 

associated with changes in the timber industry and recreation and tourism. There could also be potential 

effects upon subsistence use and cultural resources that have particular significance for Alaska Native 

populations. The effects of the alternatives on communities are discussed by community in Appendix E. 

Changes in roadless management and acres are estimated for each community use area. Impacts to 

subsistence are discussed in the Subsistence section. 

Overall, small increases in risk to cultural resources may occur under all action alternatives (with 

Alternatives 4, 5, and 6 having the highest risk) because of slightly greater road lengths and activities in 
Environment and Effects 3

Final EIS 3-255 Environmental Justice

areas currently protected from development, associated with harvest activities. However, the potential 

effects of the alternatives upon cultural resources are expected to be the lower than under the 2008 

Forest Plan because of the much lower allowable timber harvest. 

Areas designated as Roadless Priority and Community Priority ARAs would explicitly allow the cutting, 

utilization, customary trade, and removal of trees for the purposes of Alaska Native customary and 

traditional uses, as well as road construction deemed necessary by a federally recognized Tribe for 

access to Alaska Native cultural sites. This type of use would also be allowed in Timber Priority ARAs, 

which allow timber harvest and road construction.
Environment and Effects 3

Final EIS 3-256 Environmental Justice

This page is intentionally left blank.
CHAPTER 4

PREPARERS AND CONTRIBUTORS
Preparers and Contributors 4

Final EIS 4-1 Preparers and Contributors

Chapter 4

Preparers and Contributors

Forest Service

Interdisciplinary Team

Jacqueline Chandler, Public Affairs Director

M.A., Public Communications, The College of Saint Rose, 2009

B.A., Mass Communications, University of Guam, 1991

Robin Dale, Regional Roadless Coordinator

B.S., Political Science, Montana State University, 1992

Henry Eichman, Economist

M.S., Agricultural and Resource Economics, Oregon State University, 2006

B.S., Biology, Colorado College, 2000

Jacqueline Foss, GIS Data Specialist

 B.S., General Engineering and Soil Science, Cal Poly San Luis Obispo, 2002

Nicole Grewe, Roadless Public Engagement Specialist

Ph.D., Rural Sociology, Iowa State University, 2003 

M.C.R.P., Community and Regional Planning, Iowa State University, 2001

M.S., Rural Sociology, Iowa State University, 1999

B.S., Sociology, North Dakota State University, 1996

Melinda Hernandez Burke, Tribal Relations Program Manager

B.A., Social Science (Anthropology emphasis), University of Alaska, Southeast, 2005

Suzanne Johnson, GIS/Database Specialist

B.S., Timber Management, Utah State University, 1984

Shannon O’Brien, NEPA Specialist

Sitka R. Pence, NEPA Specialist

M.S., Environmental Planning, University of Wollongong (Australia), 2009

B.S., Forest Resources, University of Idaho, 2007

B.S., Conservation Ecology, University of Idaho, 2006

Stephani D. Rust, NEPA Specialist

B.S., Biology, Chadron State College, 2006

Ken Tu, Interdisciplinary Team Lead

B.S., Forest Management, Colorado State University, 1987
Preparers and Contributors 4

Final EIS 4-2 Preparers and Contributors

Chad VanOrmer, Regional Planning and Budget Director

M.S., Natural Resources and Society, University of Idaho, 2002

B.S., Forestry, Southern Illinois University, 1997

Tetra Tech Team

Randal Fairbanks, Project Manager & Timber Resources

M.S., Forest Science/Biostatistics, University of Washington, 1979

B.S., Wildlife Science, University of Washington, 1972

David Cox, Tetra Tech Interdisciplinary Team Leader, Minerals, Transportation and Energy Lead

B.S., Environmental and Engineering Geology, Western Washington University, 2000

Matt Dadswell, Economist; Recreation and Roadless Lead

Ph.D., Candidate, Geography, University of Washington

M.A., Geography, University of Cincinnati, 1990

B.A., Economics and Geography, Portsmouth Polytechnic, 1988

John Knutzen, Fisheries Biologist/Aquatic Ecologist 

M.S., Fisheries, University of Washington, 1977

B.A., Biology, Western Washington State College, 1972

Steve Negri, Wildlife Biologist

M.S., Wildlife Ecology, Michigan State University, 1995

B.S., Business Finance, University of Missouri, 1985

Mary Jo Watson, GIS Analyst 

B.S., Computer Information Systems, Menlo College

Karen Brimacombe, Wetland Scientist/Botanist 

B.A., Botany, University of Washington, 2000

M.B.A., University of Chicago, 1993

Chris James, Hydrologist

M.S., Forest Hydrology, University of Washington, 2007

Certified, Watershed Management, Portland State University, 2005 

B.A., Environmental Resources (Chemistry minor), Lewis and Clark College, 1999

John Crookston, Biologist and Planner; Climate 

M.S., Ecology, San Diego State University, 2007

B.S., Biology, University of California San Diego, 2002

Rachael Katz, Environmental Planner

MPA, Environmental Policy and Natural Resource Management, University of Washington, Evans 

School of Public Policy and Governance, 2011

BA, Political Science and German Studies, New York University, 2005
Preparers and Contributors 4

Final EIS 4-3 Preparers and Contributors

Hope Herron, Climate

Master of Natural Resource Studies (M.NRS.), University of Queensland, Australia, 2006

M.A., International Communication, American University, Washington, D.C., 2007

B.A., English, University of Southern Mississippi, 2001

Cliff Barnhardt, Stuntzner Engineering and Forestry, Forester 

B.S., Forest Engineering, Oregon State University, 1987

David Gravender, Technical Editor

PhD, English (Candidate), University of Toronto, 1997

M.A., English, University of Toronto, 1991

B.A., English, University of Washington, 1990

Dawn Nelson, Desktop Publishing
Preparers and Contributors 4

Final EIS 4-4 Preparers and Contributors

This page is intentionally left blank.
CHAPTER 5

LIST OF DOCUMENT RECIPIENTS

AND THOSE NOTIFIED OR

CONSULTED
List of Document Recipients and Those Notified or Consulted 5

Final EIS 5-1 List of Document Recipients and

Those Notified or Consulted

Chapter 5

List of Document Recipients 

and Those Notified or 

Consulted

This section provides a list of the agencies that were notified of the draft EIS. This list includes federal, 

state, and local governments, elected officials, and federally recognized tribes who submitted comments 

or requested to be on the mailing list for this draft EIS. It does not include the thousands of individuals 

and organizations on the mailing list who were notified of the draft EISs availability on the Internet, 

depending on the preference they expressed. This information is available upon request.

Federal Agencies and Tribal Governments

Federal Energy Regulatory Commission, Environmental Compliance Branch

Federal Highway Administration, Division Administrator

Library of Congress

National Oceanic and Atmospheric Administration (NOAA), NWS Office of Strategic Planning and Policy

National Oceanic and Atmospheric Administration (NOAA), National Marine Fisheries Service, Habitat

Conservation Division, Alaska Region

National Environmental Coordinator, NRCS

US Government Accountability Office

US Government Publishing Office, Federal Digital System

US Advisory Council on Historic Preservation, Planning and Review

US Army Corps of Engineers, Pacific Ocean Division

US Coast Guard, Environmental Management CG-443

US Coast Guard, Coast Guard Commandant CG47th

USDA, APHIS PPD/EAD

USDA, National Agricultural Library

USDA, Natural Resources Conservation Service

USDA, Rural Development, Rural Utilities Service

US Department of Energy, Office of NEPA Policy and Compliance

US Department of the Interior, Bureau of Land Management, Alaska State Office

US Department of the Interior, Bureau of Land Management, Anchorage District

US Department of the Interior, Bureau of Land Management, Fairbanks District

US Department of the Interior, Federal Subsistence Management Program

US Department of the Interior, Office of Environmental Policy and Compliance

US Department of the Interior, US Geological Survey Alaska Science Center

US Department of Transportation, Federal Aviation Administration, Office of the Regional Director

US Department of Transportation, Federal Highway Administration, Alaska Division Administrator

US Environmental Protection Agency, Environmental Review and Sediment Management Unit

US Environmental Protection Agency, Region 10

US Fish and Wildlife Service, Anchorage Field Office

US Fish and Wildlife Service, Juneau Field Office

US Navy, Energy and Environmental Readiness Division

US Navy, Office of the Chief of Navy Operations

USGS Alaska Science Center
List of Document Recipients and Those Notified or Consulted 5

Final EIS 5-2 List of Document Recipients and

Those Notified or Consulted

Federal Congressional Representatives

Lisa Murkowski, U.S. Senator

Dan Sullivan, U.S. Senator

Don Young, U.S. Representative

Alaska Native Tribes and Corporations

Alaska Native Brotherhood Grand Camp

Alaska Native News

Alaska Tribal Leader Committee

Angoon Community Association

Alaska Native Sisterhood Grand Camp

Cape Fox Corporation

Central Council Tlingit & Haida Indian Tribes of Alaska

Chilkat Indian Village

Chilkoot Indian Association

Craig Tribal Association

Douglas Indian Association

Goldbelt, Incorporated

Haida Corporation

Hoonah Indian Association

Huna Totem Corporation

Hydaburg Cooperative Association

Kake Tribal Corporation

Kavilco Inc.

Ketchikan Indian Community

Klawock Cooperative Association

Klawock Heenya Corporation

Klukwan Inc.

Kootznoowoo Inc.

Metlakatla Indian Community

Organized Village of Kake

Organized Village of Kasaan

Organized Village of Saxman

Petersburg Indian Association

Sealaska Corporation

Individuals

Notifications of the availability of the final Environmental Impact Statement were also sent to over 62,000 

individuals.

Consultation 

The following organizations and agencies were consulted with on the development of this EIS: 

• Advisory Council on Historic Preservation: The Advisory Council was contacted for advice on the 

determination of whether this rulemaking effort constitutes an undertaking as defined under Section 

106 of the National Historic Preservation Act.
List of Document Recipients and Those Notified or Consulted 5

Final EIS 5-3 List of Document Recipients and

Those Notified or Consulted

• Alaska State Historic Preservation Office: The Forest Service notified the Alaska State Historic 

Preservation office of the proposed rule and that the agency determined that the proposed rule was 

not an undertaking as defined under Section 106 of the National Historic Preservation Act. 

• Angoon Community Association; Central Council Tlingit and Haida Indian Tribes of Alaska; 

Hoonah Indian Association; Hydaburg Cooperative Association; Organized Village of Kake; 

and Organized Village of Kasaan: These six tribes worked with the Forest Service as cooperating

agencies providing input on the development of this EIS.

• State of Alaska: The State of Alaska submitted the petition which provided the foundation for 

developing the proposed rule. The State worked with the Forest Service as a cooperating agency 

assisting in public meetings held throughout the state and providing input on the development of this 

EIS.

• U.S. Environmental Protection Agency: The Forest Service contacted the Environmental 

Protection Agency early in the process to discuss their concerns regarding the proposed rule and 

analysis expectations.

• U.S. Fish and Wildlife Service: The Forest Service contacted the U.S. Fish and Wildlife Service 

early in the process to discuss the proposed rule and their concerns regarding wildlife issues and 

analyses.

• U.S. National Marines Fisheries Service: The Forest Service contacted the National Marine 

Fisheries Service early in the process to discuss the proposed rule and their concerns regarding 

wildlife issues and analyses.
List of Document Recipients and Those Notified or Consulted 5

Final EIS 5-4 List of Document Recipients and

Those Notified or Consulted

This page is intentionally left blank.
CHAPTER 6

REFERENCES
References 6

Final EIS 6-1 References

Chapter 6

References

Abrahamson, M. 2013. Alaska’s Mining Industry. Strong growth in jobs, wages, and production value. 

Alaska Economic Trends 33(5):4-11. May.

ADED (Alaska Department of Economic Development). 2016. Trends and Opportunities in Alaska’s Small 

Cruise Vessel Market. Draft. January. Available online at: 

https://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fseprd530432.pdf

ADF&G (Alaska Department of Fish and Game). 2019. Alaska Sport Fishing Survey – Regional Estimates 

- Southeast Alaska Region. Accessed Web Site in 2019: 

https://www.adfg.alaska.gov/sf/sportfishingsurvey/index.cfm?ADFG=region.home

ADF&G. 2018a. 2018-2019 Alaska Hunting Regulations. Available online at: 

http://www.adfg.alaska.gov/index.cfm?adfg=wildliferegulations.hunting

ADF&G. 2018b. Community Subsistence Information System. Available online at: 

https://www.adfg.alaska.gov/sb/CSIS/

ADFE&G. 2017. Deciphering Wolf Diets in Southeast Alaska Using Stable Isotope Analyses and Prey 

Remains in Scats. Annual Performance Report. Grant AKW-20. 4 pg.

ADF&G. 2015. Deer Management Report of Survey-Inventory Activities 1 July 2012-30 June 2014. 

Alaska Department of Fish and Game, Species Management Report ADF&G/DWC/SMR-2015-3, 

Juneau. Patricia Harper and Laura A. McCarthy, editors. Available online at: 

http://www.adfg.alaska.gov/index.cfm?adfg=wildliferesearch.smr20153

ADF&G. 2006. Subsistence Community Profile Database. Available online at: 

http://www.state.ak.us/local/akpages/FISH.GAME/subsist

ADF&G. 2000. Southeast Alaska Unit 4 Brown Bear Management Strategy. Available online at: 

http://www.alaskabears.alaska.gov/management/planning/planning_pdfs/u4rep.pdf

ADF&G. 1998. Tongass Fish and Wildlife Resource Assessment.

ADNR (Alaska Department of Natural Resources). 2013. Alaska Forest Resources & Practices 

Regulations, 2013. Division of Forestry. Anchorage, Alaska.

ADNR. 1997-2005. Alaska’s Mineral Industry. Special Reports 51-59 (annual reports for 1996 through 

2004). Alaska Department of Natural Resources, Division of Geological and Geophysical 

Surveys. 

ADOT&PF (Alaska Department of Transportation and Public Facilities). 2014. Draft Southeast Alaska 

Transportation Plan. Available online at: 

http://dot.alaska.gov/sereg/projects/satp/assets/SATP_2014_Draft_Final_Web.pdf

ADOT&PF. 2004. Southeast Alaska Transportation Plan. August 2004. 

AKEPIC (Alaska Exotic Plants Information Clearinghouse). 2018. Non-Native Plant Species List. Alaska 

Center for Conservation Science, University of Alaska, Anchorage. Available online at: 

http://accs.uaa.alaska.edu/invasive-species/non-native-plant-species-list. 

AKNHP (Alaska Natural Heritage Program). 2018. Rare Plant Data Portal. Alaska Center for 

Conservation Science. University of Alaska Anchorage. Anchorage, AK. Available online at: 

http://accs.uaa.alaska.edu/botany/.
References 6

Final EIS 6-2 References

Alaska DCCED (Alaska Department of Commerce, Community, and Economic Development). 2018. 

Search and Database Download Information, Business License Download. Division of 

Corporations, Business and Professional Licensing. Available online at: 

https://www.commerce.alaska.gov/cbp/main/ 

Alaska DCCED. 2017. Commercial Passenger Vessel Excise Tax: Community Needs, Priorities, Shared 

Revenue, and Expenditures. Fiscal Years 2007 to 2016. Alaska Department of Commerce, 

Community, and Economic Development (Alaska DCCED) February. Available online at: 

https://www.commerce.alaska.gov/web/ded/DEV/TourismDevelopment/TourismResearch.aspx

Alaska DCCED. 2012. Report to the Alaska Timber Jobs Task Force, Division of Economic Development. 

Administrative Order 258, Task 8: Alaska’s Timber Resource and Wood Products. March.

Alaska DOL (Department of Labor). 2020. COVID-19 and Alaska’s Economy. Answering initial economic 

questions about the virus disruption. Alaska Economic Trends. April. Available online at: 

https://labor.alaska.gov/trends/ 

Alaska DOL. 2019a. Alaska Population Estimates by Borough, Census Area, City, and Census 

Designated Place (CDP), 2010 to 2019. Available online at: 

http://live.laborstats.alaska.gov/pop/index.cfm

Alaska DOL. 2019b. Fish Harvesting Employment by Species and Month, 2000 – 2018. Southeast 

Region. Available online at: http://live.laborstats.alaska.gov/seafood/seafoodsoutheast.cfm

Alaska DOL. 2019c. Southeast Economic Region Monthly Employment Statistics. Available online at: 

http://live.laborstats.alaska.gov/ces/ces.cfm?at=60&a=000001&adj=0

Alaska DOL. 2019d. Seafood Processing Workforce by Borough or Census Area, 2017. Southeast 

Region. Available online at: http://live.laborstats.alaska.gov/seafood/seafoodsoutheast.cfm

Alaska Native Heritage Center. 2014. Eyak, Tlingit, Haida & Tsimshian. Cultures of Alaska. Available 

online at: http://www.alaskanative.net/en/main-nav/education-and-programs/cultures-ofalaska/eyak-tlingit-haida-and-tsimshian/ Accessed on 12/29/2014

Alaska Shorebird Group. 2008. Alaska Shorebird Conservation Plan. Version II. Alaska Shorebird Group, 

Anchorage, Alaska. Available online at: 

http://www.fws.gov/alaska/mbsp/mbm/shorebirds/pdf/ascp_nov2008.pdf 

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. March 

2007.

Aley, T., C. Aley, W.R Elliott, and P. Huntoon. 1993. Karst and Cave Resource Significance Assessment 

Ketchikan Area, Tongass National Forest, Alaska. Final Report. Prepared for Ketchikan Area of 

the Tongass National Forest. 79 pp. and Appendix. 

Allen, B.M., and R.P. Angliss. 2014. Sperm Whale (Physeter macrocephalus): North Pacific Stock. In 

Alaska Marine Mammal Stock Assessments, 2014, 172–176. NOAA-TM-AFSC-301. Revised 

10/09/2014.

Andrén, H. 1994. Effects of Habitat Fragmentation on Birds and Mammals in Landscapes with Different 

Proportions of Suitable Habitat: A Review. Oikos 71:355–366.

Andres, B.A., and G.A. Falxa. 1995. Black oystercatcher (Haematopus bachmani). The Birds of North 

America Online. Cornell Lab of Ornithology, Ithaca, NY. Available online at: 

http://bna.birds.cornell.edu/bna/species/155/articles/introduction.
References 6

Final EIS 6-3 References

APLIC. 2006. Suggest Practices for Avian Protection on Power Lines: The State of the Art in 2006. 

Edison Electric Institute, APLIC, and the California Energy Commission. Washington, D.C. and 

Sacramento, CA.

As, S. 1999. Invasion of Matrix Species in Small Habitat Patches. Conservation Ecology [online] 3(1): 1. 

http://www.consecol.org/vol3/iss1/art1/

Athey, J.E., and M.B. Werdon. 2018. Alaska's Mineral Industry 2017. Alaska Division of Geological & 

Geophysical Surveys Special Report 73, 92 p. http://doi.org/10.14509/30075

Audubon Alaska and The Nature Conservancy. 2007. Coastal Forests and Mountains Ecoregions of 

Southeastern Alaska and the Tongass National Forest: A Conservation Assessment and 

Resource Synthesis. Available online at: 

https://www.conservationgateway.org/ConservationByGeography/NorthAmerica/UnitedStates/ala

ska/seak/era/cfm/Pages/CA-AKCFM.aspx

Baichtal, J. 2006. Geologic Resources, Paleontology, Geologic Special Areas, and Listing of Significant 

Caves. Forest Plan Adjustment Proposal Report. Rationale and process used in making the 

recommended changes to the Plan. USDA Forest Service, Tongass National Forest. File Code 

2880 Geology and Karst Resources. Letter to Lee Kramer, Forest Plan Adjustment Coordinator. 

March 24.

Baichtal, J.F., and D.N. Swanston. 1996. Karst Landscapes and Associated Resources: A Resource 

Assessment. General Technical Report, PNW-GTR-383. USDA Forest Service, Pacific Northwest 

Research Station, Portland, OR. 13 pp.

Barrett, T.M. 2014. Storage and Flux of Carbon in Live Trees, Snags, and Logs in the Chugach and 

Tongass National Forests. USDA-FS. General Technical Report PNW-GTR-889. 44 pp.

Bauder, P., and J. Heys. 2004. Exotic Plant Management at Wrangell-St. Elias National Park and 

Preserve; Summer 2004 Field Season Report. National Park Service. Wrangell-St. Elias National 

Park and Preserve.

Beechie, T.J., and T.H. Sibley. 1997. Relationships between channel characteristics, woody debris, and 

fish habitat in northwestern Washington streams. Transactions of the American Fisheries Society 

126:217-229.

Bell, C. 2015. Tourism in Southeast. Visitor-related Jobs a Key Part of the Region’s Economy. Alaska 

Economic Trends 35(8):4-8.

Ben-David, M., R.T. Bowyer and J.B. Faro. 1996. Niche Separation by Mink and River Otters: 

Coexistence in a Marine Environment. Oikos 75(1):41-48.

Benda, L., D. Miller, J. Sias, D. Martin, R. Bilby, C. Veldhuisen, and T. Dunne. 2003. Wood Recruitment 

Processes and wood budgeting. American Fisheries Society Symposium 37:49-73.

Berg, E.C., C.B. Gale, T.A. Morgan, A.M. Brackley, C.E. Keegan, S.J. Alexander, G.A. Christensen, C.P. 

McIver, and M.G. Scudder. 2014. Alaska’s Timber Harvest and Forest Products Industry, 2011. 

USDA Forest Service, Pacific Northwest Research Station, General Technical Report PNW-GTR903. November.

Bergman, R., M. E. Puettman, A. Taylor, and K. E. Skog. 2014. The Carbon Impacts of Wood Products. 

Forest Products Journal 64:220-231.

Bettridge, S., C. S. Baker, J. Barlow, P. J. Clapham, M. Ford, D. Gouveia, D. K. Mattila, R. M. Pace III, P. 

E. Rosel, G. K. Silber, and P. R. Wade. 2015. Status review of the humpback whale (Megaptera 

novaeangliae) under the Endangered Species Act. U.S. Dep. Commer., NOAA Tech. Memo. 

NMFS-SWFSC-540, 240 p.
References 6

Final EIS 6-4 References

Birdsey, R. A.; A. J. Dugan, S. P. Healey, K. Dante-Wood, F. Zhang, G. Mo, J. M. Chen, A. J. Hernandez, 

C. L. Raymond, and J. McCarter. 2019. Assessment of the influence of disturbance, management 

activities, and environmental factors on carbon stocks of U.S. national forests. Gen. Tech. Rep. 

RMRS-GTR-402. Fort Collins, CO: U.S. Department of Agriculture, Forest Service, Rocky

Mountain Research Station. 116 pages plus appendices.

Birdsey, R. A., A. J. Plantinga, and L. S. Heath. 1993. Past and Prospective Carbon Storage in United 

States Forests. Forest Ecology and Management 58:33-40. 

Bisson, P. A., R. E. Bilby, M. D. Bryant, C. A. Dolloff, G. B. Grette, R. A. House, M. L. Murphy, K.V. Koski, 

and J.R. Sedell. 1987. Large Woody Debris in forested Streams in the Pacific Northwest: Past, 

Present, and Future. In Streamside Management: Forestry and Fishery Interactions, edited by E.

O. Salo and T. W. Cundy, 143-190. College of Forest Resources, University of Washington, 

Seattle, Washington. Contribution No. 57. 

Bissonette, J. A., D. J. Harrison, C. D. Hargis, and T. G. Chapin. 1997. The influence of spatial scale and 

scale-sensitive properties on habitat selection by American marten. In Wildlife and Landscape 

Ecology, edited by J. A. Bissonette, 368-385. Springer-Verlag, NY. 

Bjornn, T. C., and D. W. Reiser. 1991. Habitat Requirements of Salmonids in Streams. In Influences of 

Forest and Rangeland Management on Salmonid Fishes and Their Habitats, edited by W.R. 

Meehan, 83-128. American Fisheries Society Special Publication 19. American Fisheries Society, 

Bethesda, Maryland 

BLM (Bureau of Land Management). 2006. Ring of Fire Proposed Resource Management Plan and Final 

Environmental Impact Statement. U.S. Department of the Interior, Bureau of Land Management, 

Anchorage Field Office. Anchorage, Alaska. July 2006.

Boag, D. A., and M. A. Schroeder. 1992. Spruce Grouse. In: A. Poole, P. Stettenheim, and F. Gill, editors. 

The Birds of North America. Philadelphia: The Academy of Natural Sciences. Washington, DC. 

The American Ornithologists’ Union.

Boland, J. L., W. P. Smith, and J. P. Hayes. 2009. Survey of Bats in Southeast Alaska with emphasis on 

Keen’s Myotis (Myotis keenii). Northwest Science 83(3):169-179.

Bonsal, B. R., and T. D. Prowse. 2006. Regional Assessment of CCM-Simulated Current Climate Over 

Northern Canada. Arctic 59(2):33-40

Bosakowski, T., B. McCullough, F. J. Lapsansky, and M. E. Vaughn. 1999. Northern Goshawks nesting 

on a private industrial forest in western Washington. Journal of Raptor Research 33:240-244.

Bowker, J. M. 2001. Outdoor recreation by Alaskans: projections for 2000 through 2020. General 

Technical Report PNW-GTR-527. Portland, Oregon: USDA Forest Service, Pacific Northwest 

Research Station. 22p. Available online at: http://www.fs.fed.us/pnw/pubs/gtr527.pdf

Bowyer, R. T., G. M. Blundell, M. Ben-David, S. C. Jewett, T. A. Dean, and L. K. Duffy. 2003. Effects of 

the Exxon Valdez Oil Spill on River Otters: Injury and Recovery of a Sentinel Species. Wildlife

Monographs 153:1-53.

Boyce, D. A., Jr., R. T. Reynolds, and R. T. Graham. 2006. Goshawk status and management: what do 

we know, what have we done, where are we going? In The Northern Goshawk: A Technical 

Assessment of its Status, Ecology, and Management, edited by M. L. Morrison, 312-325. Studies 

in Avian Biology No. 31, Cooper Ornithological Society.

BPIF (Boreal Partners in Flight Working Group). 1999. Landbird Conservation Plan for Alaska 

Biogeographic Regions, Version 1.0. Unpublished report, U.S. Fish and Wildlife Service, 

Anchorage, AK. 45 pp.
References 6

Final EIS 6-5 References

Bradner, T. 2014. Parnell Signs Bill to Boost Bokan, Niblack Mine Projects. Alaska Journal of Commerce.

June 19. Available online at: http://www.alaskajournal.com/business-and-finance/2014-06-

19/parnell-signs-bill-boost-bokan-niblack-mine-projects

Brinkman, T. J. 2009. Resilience of a Deer Hunting System in Southeast Alaska: Integrating Social, 

Ecological, and Genetic Dimensions. Dissertation. University of Alaska Fairbanks, Fairbanks, AK.

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

Responses to Interview Questions. Community Report. Unpublished report. February.

Brock, M., and P. Coiley-Kenner. 2009. A Compilation of Traditional Knowledge about the Fisheries of 

Southeast Alaska. Alaska Department of Fish and Game, Division of Subsistence in Collaboration 

with the Sitka Tribe of Alaska. September. Available online at: 

https://www.adfg.alaska.gov/index.cfm?adfg=ByAreaSubsistenceSE.research

Bryant, M. 2009. Global Climate Change and Potential Effects on Pacific Salmonids in Freshwater 

Ecosystems of Southeast Alaska. Climatic Change 95(1-2):165-193. doi 10.1007/s10584-008-

9530-x

Burger, A. E. 2002. Conservation assessment of Marbled Murrelets in British Columbia: a review of the 

biology, populations, habitat associations, and conservation. Technical Report Series No. 387. 

Canadian Wildlife Service, Pacific and Yukon Region, British Columbia. 

Burgner, R. L., J. T. Light, L. Margolis, T. Okazaki, A. Tautz, and S. Ito. 1991. Distribution and Origins of 

Steelhead Trout (Oncorhynchus mykiss) in Offshore Waters of the North Pacific Ocean. Bulletin 

Number 51. International North Pacific Fisheries Commission.

Burkey, T.V. 1995. Extinction Rates in Archipelagoes: Implications for Populations in Fragmented 

Habitats. Conservation Biology 9:527–541.

Buskirk, S. W., and W. J. Zielinski. 1997. American marten (Martes americana) ecology and conservation. 

In Mesocarnivores of northern California: biology, management, and survey techniques, 

workshop manual, edited by J.E. Harris, and C.V. Ogan, 17-22. August 12-15, 1997, Humboldt 

State University, Arcata, CA. The Wildlife Society, California North Coast Chapter, Arcata, CA. 

127 pp.

Calambokidis, J., E. A. Falcone, T. J. Quinn, A. M. Burdin, P. J. Clapham, J. K. B. Ford, C. M. Gabriele, 

R. LeDuc, D. Mattila, L. Rojas-Bracho, J. M. Straley, B. L. Taylor, J. Urbán R., D. Weller, B. H. 

Witteveen, M. Yamaguchi, A. Bendlin, D. Camacho, K. Flynn, A. Havron, J. Huggins, and N. 

Maloney. 2008. SPLASH: Structure of Populations, Levels of Abundance and Status of 

Humpback Whales in the North Pacific. Final Report for Contract AB133F-03-RP-00078. 58 p. 

Available online: http://www.cascadiaresearch.org/files/publications/SPLASH-contract-ReportMay08.pdf

Calkins, D. G. 1986. Marine Mammals. In The Gulf of Alaska Physical Environment and Biological 

resources, edited by D.W. Hood and S.T. Zimmerman, 527-560. Mineral Management Service 

Publication number OCS Study: MMS 86-0095, US Government Printing Office, Washington, DC.

Campbell, W. R., N. K. Dawe, I. McTaggart-Cowan, J. M. Cooper, G. W. Kaiser and M. C. E. McNall. 

1990. The Birds of British Columbia. Vol. 2. University of British Columbia Press, Vancouver, BC, 

Canada. 35pp. As cited in BPIF (1999).

Caouette, J. P., and E. J. DeGayner. 2005. Predictive Mapping for Tree Sizes and Densities in Southeast 

Alaska. Journal of Landscape and Urban Planning 72(1-3):49-63.

Caouette, J. P., M. G. Kramer, and G. J. Nowacki. 2001. Deconstructing the Timber Volume Paradigm in 

the Management of the Tongass National Forest. General Technical Report PNW-GTR-482. U.S. 

Department of Agriculture, Forest Service, Pacific Northwest Research Station. Portland, OR. 20 

pp.
References 6

Final EIS 6-6 References

Carey, A.B. 2000. Ecology of Northern Flying Squirrels: Implications for Ecosystem Management in the 

Pacific Northwest, USA. In Biology of Gliding Mammals, edited by R. L. Goldingay and J. S. 

Scheibe, 45-66. Filander Verlag, Forth, Germany.

Carlson, M.L. and J.R. Fulkerson. 2017. Tanacetum camphoratum Less. (syn. = Tanacetum bipinnatum 

(L.) Sch. Bip. pro parte): Conservation Assessment on the Tongass National Forest, Alaska 

Region. Alaska Natural Heritage Program, University of Alaska Anchorage. Anchorage, Alaska. 

41 pp.

Carlson, M., and M. Shephard. 2007. Is the Spread of Non-native plants in Alaska Accelerating? In 

Meeting the Challenge: Invasive Plants in Pacific Northwest Ecosystems. U.S. Department of 

Agriculture, Forest Service, Pacific Northwest Research Station. General Technical Report GTR694. Portland, OR. 

Center for Biological Diversity and Greenpeace. 2011. Petition to List the Alexander Archipelago Wolf

(Canis lupus ligoni) as Threatened or Endangered under the United States Endangered Species 

Act. Submitted to the U.S. Fish and Wildlife Service August 10, 2011.

Chalfoun, A. D., F. R. Thompson, and M. J. Ratnaswamy. 2002. Nest Predators and Fragmentation: A 

Review and Meta-Analysis. Conservation Biology 16:306–318.

Chamberlin, T. W., R. D. Harr, and F. H. Everest. 1991. Timber Harvesting, Silviculture, and Watershed

Processes. In: Influences of Forest and Rangeland Management on Salmonid Fishes and Their 

Habitats, edited by W.R. Meehan, 181-205. American Fisheries Society Special Publication 19. 

Chapin, T. G., D. J. Harrison, and D. D. Katnik. 1998. Influence of Landscape Pattern on Habitat Use by 

American Marten in an Industrial Forest. Conservation Biology 12:96-227.

Chapin, F.S., III, S.F. Trainor, P. Cochran, H. Huntington, C. Markon, M. McCammon, A. D. McGuire, and 

M. Serreze. 2014. Alaska. In Climate Change Impacts in the United States: The Third National 

Climate Assessment, J. M. Melillo, edited by Terese (T.C.) Richmond, and G. W. Yohe, 514-536 

(Chapter 2). U.S. Global Change Research Program. doi:10.7930/J00Z7150.

Chapman, D. W. 1988. Critical Review of Variables Used to Define Effects of Fines in Redds of Large 

Salmonids. Transactions of the American Fisheries Society 117:1-21.

Chapman, D. W. and K. P. McLeod. 1987. Development of Criteria for Fine Sediment in the Northern 

Rockies ecoregion. EPA 910/9-87-162. U.S. Environmental Protection Agency, Seattle, 

Washington.

Christensen, G. A., K. R. Julin, R. J. Ross, and S. Willits. 2002. Volume Recovery, Grade Yield and 

Properties of Lumber from Young-growth Sitka Spruce and Western Hemlock in Southeast 

Alaska. Forest Products Journal 52(5):81-87.

Colway, C., and D. E. Stevenson. 2007. Confirmed Records of Two Green Sturgeon from the Bering Sea 

and Gulf of Alaska. Northwestern Naturalist 88:188–192.

Conant, R. T., Michael G. Ryan, Göran I. Ågren, Hannah E. Birge, Eric A. Davidson, Peter E. Eliasson, 

Sarah E. Evans, Serita D. Frey, Christian P. Giardina, Francesca M. Hopkins, Riitta Hyvönen, 

Miko U. F. Kirschbaum, Jocelyn M. Lavallee, Jens Leifeld, William J. Parton, Jessica Megan 

Steinweg, Matthew D. Wallenstein, J. Å. Martin Wetterstedt, and Mark A. Bradford. 2011. 

Temperature and Soil Organic Matter Decomposition Rates – Synthesis of Current Knowledge 

and A Way Forward. Global Change Biology 17(11):3392-3404.

Conrad, S., and D. Gray. 2019. Overview of the 2018 Southeast Alaska and Yakutat Commercial, 

Personal Use, and Subsistence Salmon Fisheries. Fishery Management Report No. 19-06. 

Alaska Department of Fish and Game. Anchorage, AK.

Cook, J. A., N. G. Dawson, and S. O. MacDonald. 2006. Conservation of Highly Fragmented Systems: 

The North Temperate Alexander Archipelago. Biological Conservation 133:1-15.
References 6

Final EIS 6-7 References

Cook, J. A., A. L. Bidlack, C. J. Conroy, J. R. Demboski, M. A. Fleming, A. M. Runck, K. D. Stone, and S. 

O. MacDonald. 2001. A phylogeographic perspective on endemism in the Alexander Archipelago 

of southeast Alaska. Biological Conservation 97:215–227.

Cornejo, C., C. Derr, and K. Dillman. 2017. Ricasolia amplissima (Lobariaceae): one species, three 

genotypes and a new taxon from south-eastern Alaska. The Lichenologist 49(6):579–596.

Croke, J. C., and P. B. Hairsine. 2006. Sediment Delivery in Managed Forests: A Review. Environmental 

Review 14: 59–87. Available online at: http://er.nrc.ca/ (Accessed April – May 2011).

Dahlheim, M. E., J. M. Waite, and P. A. White. 2009. Cetaceans of Southeast Alaska: Distribution and 

Seasonal Occurrence. Publications, Agencies, and Staff of the U.S. Department of Commerce. 

Paper 157. Available online at: http://digitalcommons.unl.edu/usdeptcommercepub/157.

D’Amore, D. 2016. Personal communication between Patricia Krosse and David D’Amore (USDA Forest 

Service Research Scientist) on 4/11/2016.

D’Amore, D. V., and W. C. Lynn. 2002. Classification of forested Histosols in southeast Alaska. Soil

Science Society of America Journal 66:554-62

D’Amore, D., P. Herendeen, and E. Hood. 2015. Dissolved Organic Carbon Fluxes from Hydropendologic 

Units in Alaska Coastal Temperate Rainforest Watersheds. Soil Science Society of America 

Journal 79:378-388.

D’eon, R. G., S. M. Glenn, I. Parfitt, and M. Fortin. 2002. Landscape Connectivity as a Function of Scale 

and Organism Vagility in a Real Forested Landscape. Conservation Ecology 6:10. Available 

online: http://www.consecol.org/vol6/iss2/art10

Daniel, T. W., J. A. Helms, and F. S. Baker. 1979. Principles of Silviculture. Second Edition, McGraw-Hill, 

New York.

Daniels, J. M., M. D. Paruszkiewicz, and S. J. Alexander. 2016. Tongass National Forest timber demand: 

projections for 2015 to 2030. Gen. Tech. Rep. PNW-GTR-934. Portland, OR: U.S. Department of 

Agriculture, Forest Service, Pacific Northwest Research Station. 53 p.

Darimont, C. T., and T. E. Reimchen. 2002. Intra-hair Stable Isotope Analysis Implies Seasonal Shift to 

Salmon in Gray Wolf Diet. Canadian Journal of Zoology 80:1638-1632.

Davidson, E., and I. Janssens. 2006. Temperature Sensitivity of Soil Carbon Decomposition and 

Feedbacks to Climate Change. Nature 440:165-73.

Davis, H., A. N. Hamilton, A. S. Harestad, and R. D. Weir. 2012. Longevity and Reuse of Black Bear Dens 

in Managed Forests of Coastal British Columbia. The Journal of Wildlife Management 76:523–

527.

Dawson, N.G., S.O. MacDonald, J.A. Cook. 2007. Endemic mammals of the Alexander Archipelago. In 

The Coastal Forests and Mountains Ecoregion of Southeastern Alaska and the Tongass National 

Forest: A conservation assessment and resource synthesis, edited by J.W. Schoen and E. 

Dovichin, Chapter 6.7. The Nature Conservancy and Audubon Alaska.

Day, R.H., D. A. Nigro, A. K. Prichard. 2000. At-sea Habitat Use by the Kittlitz’s Murrelet (Brachyramphus 

brevirostris) in Nearshore Waters of Prince William Sound, Alaska. Marine Ornithology 28:105-

114.

Deal, R. L., and J. C. Tappeiner. 2002. The Effects of Partial Cutting on Stand Structure and Growth in 

Western Hemlock-Sitka Spruce Stands in Southeast Alaska. Forest Ecology and Management

159:173-186.

DeGange, A. 1996. A Conservation Assessment for the Marbled Murrelet in Southeast Alaska. U.S.

Department of Agriculture, Forest Service General Technical Report PNW-GTR-388.
References 6

Final EIS 6-8 References

DellaSala, D. 2016. The Tongass Rainforest as Alaska’s First Line of Climate Change Defense and 

Importance to the Paris Climate Change Agreements. 

DellaSala, D. 2014. Why Forests Are Pivotal in Planning for Climate Change. PowerPoint presentation.

DellaSala, D. A., K. A. Engel, D. P. Volsen, R. L. Fairbanks, W. C. McComb, and K. J. Raedeke. 1994. 

Effectiveness of Silvicultural Modifications of Young-Growth Forest for Enhancing Wildlife Habitat

on the Tongass National Forest. Prepared under contract for USDA Forest Service Region 10. 

Enserch Environmental Corporation.

Demboski, J. R., B. K. Jacobsen, and J. A. Cook. 1998. Implications of Cytochrome b Sequence Variation 

for Biogeography and Conservation of the Northern Flying Squirrel (Glaucomys sabrinus) of the 

Alexander Archipelago, Alaska. Canadian Journal of Zoology 76:1771–1776.

Dickerman, R.W., and J. Gustafson. 1996. The Prince of Wales spruce grouse: a new subspecies from 

southeastern Alaska. Western Birds 27:41–47.

Dillman, K. 2004. Epiphytic Lichens of the Forest-Marine Ecotone of Southeastern Alaska. M.S. Thesis, 

Arizona State University, Tempe.

Dillman, K.L. 2008. Conservation Assessment for the Large Round-leaved Orchid (Platanthera orbiculata

(Pursh.) Lindl. on the Tongass National Forest, Alaska Region. US. USDA Forest Service, 

Tongass National Forest. 

Dillman, K.L. 2011. Conservation Assessment of Piperia unalascensis (Spreng.) Rydb. Region 10 

Sensitive Species. USDA Forest Service, Tongass National Forest. 

Dillman, K., M. L. Carlson, B. Bernard, and J. R. Fulkerson. 2017. Ricasolia amplissima (Scop.) De Not. 

subspecies sheiyi Derr & Dillman: Conservation Assessment on the Tongass National Forest, 

Alaska Region. Alaska.

Domke, G.; Williams, C. A.; Birdsey, R.; Coulston, J.; Finzi, A.; Gough, C.; Haight, B.; Hicke, J.; Janowiak,

M.; de Jong, B.; Kurz, W. A.; Lucash, M.; Ogle, S.; Olguín-Álvarez, M.; Pan, Y.; Skutsch, M.; 

Smyth, C.; Swanston, C.; Templer, P.; Wear, D.; Woodall, C. W. 2018. Forests. In: Cavallaro, N.; 

Shrestha, G.; Birdsey, R.; Mayes, M. A.; Najjar, R. G.; Reed, S. C.; Romero-Lankao, P.; Zhu, Z., 

eds. Second State of the Carbon Cycle Report (SOCCR2): A Sustained Assessment Report. 

Washington, DC: U.S. Global Change Research Program: 365-398. Chapter 9: Forests. 

https://doi.org/10.7930/SOCCR2.2018.Ch9

Domke, G.M.; Perry, C.H.; Walters, B.F.; Nave, L.E.; Woodall, C.W.; Swanston, C.W. 2017. Toward 

inventory-based estimates of soil organic carbon in forests of the United States. Ecological 

Applications 27(4):1223-1235.

Douglas, G., G. Straley, D. Meidinger, and J. Pojar (eds.). 1999. Illustrated Flora of British Columbia, Vol. 

3: Dicotyledons (Diapensiaceae through Onagraceae). Victoria, British Columbia: British 

Columbia Ministry of Environment, Lands and Parks and Ministry of Forests. 

Doyle, F. I., and J. N. M. Smith. 1994. Population Responses of Northern Goshawks to the10-year Cycle 

in Numbers of Snowshoe Hares. Studies in Avian Biology 16:122-129. 

Dugan, D., G. Fay, H. Griego, and S. Colt. 2009. Nature-Based Tourism in Southeast Alaska. ISER 

Working Paper 2009.1. March. Institute of Social and Economic Research, University of Alaska 

Anchorage. Available online at: www.iser.uaa.alaska.edu 

Dunlap, R. 1996. Fish/Riparian Assessment Panel Summary, Tongass National Forest, Juneau, Alaska. 

February 13, 1996.

EcoAdapt. 2014. A Climate Change Vulnerability Assessment for Aquatic Resources in the Tongass 

National Forest. Bainbridge Island, WA. November.
References 6

Final EIS 6-9 References

ECONorthwest. 2014. The Economic Importance of Alaska’s Wildlife in 2011. Final Report prepared for 

Alaska Department of Fish & Game. May.

eFlora. 2018. Flora of North America. Missouri Botanical Garden, St. Louis, MO and Harvard University 

Herbaria, Cambridge, MA. Available online at: http://www.efloras.org/.

EIA (U.S. Energy Information Administration). 2013. How Much of U.S. Carbon Dioxide Emissions Are 

Associated with Electricity Generation? Available online at 

http://www.eia.gov/tools/faqs/faq.cfm?id=77&t=11

EPA (Environmental Protection Agency). 2017. Final Project Report: EPA Region 10 Climate Change and 

TMDL Pilot—South Fork Nooksack River, Washington. EPA/600/R-17/281. U.S. Environmental 

Protection Agency, National Health and Environmental Effects Research Laboratory, Western 

Ecology Division, Corvallis, OR.

EPA (U.S. Environmental Protection Agency). 2014a. EPA’s Climate Impacts in Alaska website. Available 

online at: http://www3.epa.gov/climatechange/impacts/alaska.html

EPA. 2014b. Sources of Greenhouse Gas Emissions. Available online at 

http://www.epa.gov/climatechange/ghgemissions/sources/electricity.html

Fall, J. A. 2016. Subsistence in Alaska: A Year 2014 Update. Division of Subsistence, ADF&G. 

December. Available online at: 

https://www.adfg.alaska.gov/static/home/subsistence/pdfs/subsistence_update_2014.pdf

Farmer, C. J., and M. D. Kirchhoff. 2007. Ecological classification of deer habitat in the Tongass National 

Forest, Alaska. Northwestern Naturalist 88:73–84.

Farr, W. A., and M. H. McClellan. 1994. Size and Age Structure of Trees in the Old-Growth Forests of 

Southeast Alaska. USDA Forest Service, Pacific Northwest Research Station. Unpublished, nonpeer-reviewed manuscript on file at Juneau Forestry Sciences Laboratory, Juneau, AK. Ref. R721.

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.

Flynn, R., T. V. Schumacher, and M. Ben-David. 2004. Abundance, Prey Availability, and Diets of 

American Martens: Implications for the Design of Old-Growth Reserves in Southeast Alaska. 

Wildlife Research Final Report. Alaska Department of Fish and Game and U.S. Fish and Wildlife 

Service. USFWS Grant DCN 70181-1-G133. Douglas, AK.

Flynn, R. W., and T. Schumacher. 2001. Ecology of martens in southeast Alaska, 1 July 2000-30 June 

2001. Alaska Department of Fish and Game. Federal aid in wildlife restoration final research 

performance report, grants W-23-4 to W-27-4. Study 7.16. Juneau, AK.

Franklin, J. F., D. R. Berg, D. A. Thornburgh, and J. C. Tappeiner. 1997. Alternative Silvicultural 

Approaches to Timber Harvesting: Variable Retention Harvest Systems. Pages in (eds). Creating 

a Forestry for the 21st Century, edited by K. A. Kohm and J. F. Franklin 111–140. Island Press, 

Washington, D.C.

Furniss, M. J., T. D. Roelofs, and C. S. Yee. 1991. Road Construction and Maintenance. In Influences of 

Forest Rangeland Management on Salmonid Fishes and Their Habitat, edited by W.R. Meehan, 

297-323. American Fisheries Society Special Publication 19.

Galginaitus, M. 2004. Subsistence Resource Report for the Couverden Forest Service Project. Applied 

Sociocultural Research. Anchorage, Alaska.

Gibson, J. R., R. L. Haedrich, and C. M. Wenerheim. 2005. Loss of Habitat as a Consequence of 

Inappropriately Constructed Stream. Fisheries 30(1):10-16.
References 6

Final EIS 6-10 References

Goldstein, M. I., A. J. Poe, E. Cooper, D. Youkey, B. A. Brown, and T. L. McDonald. 2005. Mountain Goat

Response to Helicopter Overflights in Alaska. Wildlife Society Bulletin 33(2):688-699.

Goldstein, M. I., D. Martin, and M. C. Stensvold. 2009. Forest Service Alaska Region Sensitive Species

List. Assessment and Proposed Revisions to the 2002 List. Juneau. Available online at: 

http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fsbdev2_037658.pdf. Accessed: December 

15, 2014. 

Goldschmidt, Walter R., and Theodore H. Hass. 1946. Possessory Rights of Natives of Southeastern 

Alaska. A Report to the Commissioner of Indian Affairs. Washington, DC. 176 pages, 13 charts 

and maps, 6 photographs, and 2 appendices.

Goldstein, M. I., L. H. Suring, C. D. Vojta, M. M. Rowland, and C. M. McCarthy. 2013. Developing a 

Habitat Monitoring Program: Three Examples from National Forest Planning. In A Technical 

Guide for Monitoring Wildlife Habitat, edited by M. M. Rowland and C. D. Vojta, 10-1 to 10-74. 

USDA Forest Service General Technical Report WO-GTR-89, Washington, D.C., USA.

Gomi, T., R. D. Moore, and M. A. Hassan. 2005. Suspended Sediment Dynamics in Small Forest Streams 

of the Pacific Northwest. Journal of the American Water Resources Association 41(4):877-898. 

June. 

Grant, G. E., S. L. Lewis, F. J. Swanson, J. H. Cissel, and J. J. McDonnell. 2008. Effect of Forest 

Practices on Peak Flows and Consequent Channel Response: A State-of-Science Report for 

Western Oregon and Washington. General Technical Report. PNW-GTR-760. Portland, Oregon: 

USDA Forest Service, Pacific Northwest Research Station. 76p.

Gregory, S. V., and P. A. Bisson. 1997. Degradation and Loss of Anadromous Salmonid Habitat in the 

Pacific Northwest. In Pacific Salmon and Their Ecosystems: Status and Future Options, edited by 

D. J. Stouder, P. A. Bisson, and R. J. Naiman, 277-314. Chapman and Hall, New York, New 

York.

Grewe, N. 2017. Tongass National Forest: Updated Timber Sale Procedures. USDA Forest Service, 

Alaska Region, R10-MB-823. May 8. Available online at: 

https://www.fs.usda.gov/detail/r10/landmanagement/resourcemanagement/?cid=fsbdev2_038785

Groot, C., and L. Margolis (eds.). 1991. Pacific Salmon Life History. University of British Columbia, 

Vancouver BC.

Gucinski, H., M. J. Furniss, R. R. Ziemer, and M. H. Brookes. 2001. Forest Roads: a Synthesis of 

Scientific Information. General Technical Report. PNW-GTR-509. Portland, OR, U.S. Department 

of Agriculture, Forest Service, Pacific Northwest Research Station. 103p.

Gullufsen, K. 2018. Controversial Timber Sale Can’t Find A Bidder. Juneau Empire. June 6. Available 

online at: https://www.juneauempire.com/news/controversial-timber-sale-cant-find-a-bidder/

Haggerty, M. 2009. Lake Ozette Sockeye Limiting Factors Analysis. Prepared for: The Makah Indian 

Tribe and NOAA Fisheries in cooperation with the Lake Ozette Sockeye Steering Committee.

Hanley, T. A., W. P. Smith, and S. M. Gende. 2005. Maintaining Wildlife Habitat in Southeastern Alaska: 

Implications of New Knowledge for Forest Management and Research. Landscape and Urban 

Planning 72:113-133.

Hanley, T. A., D. E. Spalinger, K. J. Mock, O. L. Weaver, and G. M. Harris. 2012. Forage resource 

Evaluation System for Habitat – Deer: An Interactive Deer Habitat Model. USDA Forest Service 

General Technical Report PNW-GTR-858, January 2012. 

Happe, P. J., K. J. Jenkins, E. E. Starkey, and S. H. Sharrow. 1990. Nutritional Quality and Tannin 

Astringency of Browse in Clear-cuts and Old-growth Forests. Journal of Wildlife Management 

54:557-566.
References 6

Final EIS 6-11 References

Harding, K. A., and D. C. Ford. 1993. Impacts of Primary Deforestation upon Limestone Slopes in 

Northern Vancouver Island, British Columbia. Environmental Geology 21:137-143.

Hargis C. D., J. A. Bissonette, and D. L. Turner. 1999. The Influence of Forest Fragmentation and 

Landscape Pattern on American Martens. Journal of Applied Ecology 36:157-172.

Harris, A. S. and D. L. Johnson. 1983. Western Hemlock-Sitka Spruce. In: Silvicultural Systems for the 

Major Forest Types of the United States, R. M. Burns (compiler), 5–8. Agriculture Handbook No. 

445. Washington, D.C.: USDA Forest Service. 

Hassan, M. A., M. Church, T. T. Lisle, F. Brardinoni, L. Benda, and G.E. Grant. 2005. Sediment Transport 

and Channel Morphology of Small, Forested Streams. Journal of the American Water Resources 

Association 41(4):853-876. August. 

Haufler, J., C. Mehl, and S. Yeats. 2010. Climate Change: Anticipated Effects on Ecosystem Services 

and Potential Actions by the Alaska Region, U.S. Forest Service. Ecosystem Management 

Research Institute, Seeley Lake, Montana.

Hayward, Gregory H.; Colt, Steve; McTeague, Monica L.; Hollingsworth, Teresa N., eds. 2017. Climate 

Change Vulnerability Assessment for the Chugach National Forest and the Kenai Peninsula. 

Gen. Tech. Rep. PNW-GTR-950. Portland, OR: U.S. Department of Agriculture, Forest Service, 

Pacific Northwest Research Station. 340 p.

Heath, L. S., J. E. Smith, C. W. Woodall, D. L. Azuma, and K. L. Waddell. 2011. Carbon stocks on 

forestland of the United States, with emphasis on USDA Forest Service ownership. Ecosphere 

2(1):article 6 doi:10.1890/ES10-00126.1 

Heard, W.R. 1991. Life History of Pink Salmon (Oncorhynchus gorbuscha). In: Pacific Salmon Life 

Histories, edited by C. Groot and L. Margolis, 119-230. University of British Columbia in cooperation with the Government of Canada, Department of Fisheries and Oceans. British 

Columbia, Canada.

Hejl, S. J., K. R. Newlon, M. E. McFadzen, J. S. Young, and C. K. Ghalambor. 2002. Brown Creeper 

(Certhia americana). In The Birds of North America No. 669, A. Poole and F. Gill, eds. 

Philadelphia, PA: The Birds of North America, Inc.

Hennon, P. E., and C. G. Shaw. 1997. The Enigma of Yellow-Cedar Decline. Journal of Forestry

95(12):4-10.

Hennon, P. E.; C. M. McKenzie, D. V. D’Amore, D. T. Wittwer, R. L. Mulvey, M. S. Lamb, F. E. Biles, and 

R. C. Cronn. 2016. A Climate Adaptation Strategy for Conservation and Management of YellowCedar in Alaska. Gen. Tech. Rep. PNW-GTR-917. Portland, OR: U.S. Department of Agriculture 

Forest Service.

Hilderbrand, G. V., C. C. Schwartz, C. Robbins, M. E. Jacoby, T. A. Hanley, S. M. Arthur, and C. 

Servheen. 1999. Importance of Meat, Particularly Salmon, to Body Size, Population Productivity, 

and Conservation of North American Brown Bears. Canadian Journal of Zoology 77:132-138.

Hodges, J. I. 2011. Bald Eagle Population Surveys of the North Pacific Ocean, 1967-2010. Northwestern 

Naturalist 92(1):7-12.

Hseih, J. 2020. Alaska’s cruise towns expected a record season, now tourism workers are reeling. Alaska 

Public Media. KTOO – Juneau. March 19. Available online at: 

https://www.alaskapublic.org/2020/03/19/in-alaskas-cruise-towns-tourism-workers-are-reeling/

Huff, D. D., S. T. Lindley, B. K. Wells, and F. Chai. 2012. Green Sturgeon Distribution in the Pacific 

Ocean Estimated from Modeled Oceanographic Features and Migration Behavior. PLOS ONE

7(9):1–12 (e45852).
References 6

Final EIS 6-12 References

Hupp, J. W., J. I. Hodges, Jr., B. P. Conant, B. W. Meixell, and D. J. Groves. 2010. Winter Distribution, 

Movements, and Annual Survival of Radiomarked Vancouver Canada Geese in Southeast 

Alaska. Journal of Wildlife Management 74(2):274–284.

IPCC (Intergovernmental Panel on Climate Change). 2018. Summary for Policymakers. In: Global 

warming of 1.5°C. An IPCC Special Report on the impacts of global warming of 1.5°C above preindustrial levels and related global greenhouse gas emission pathways, in the context of 

strengthening the global response to the threat of climate change, sustainable development, and 

efforts to eradicate poverty [V. Masson-Delmotte, P. Zhai, H. O. Pörtner, D. Roberts, J. Skea, P. 

R. Shukla, A. Pirani, W. Moufouma-Okia, C. Péan, R. Pidcock, S. Connors, J. B. R. Matthews, Y. 

Chen, X. Zhou, M. I. Gomis, E. Lonnoy, T. Maycock, M. Tignor, T. Waterfield (eds.)]. World 

Meteorological Organization, Geneva, Switzerland, 32 pp.

IPCC. 2014. Climate Change 2014: Synthesis Report. Contribution of Working Groups I, II and III to the 

Fifth Assessment Report of the Intergovernmental Panel on Climate Change [Core Writing Team, 

R.K. Pachauri and L.A. Meyer (eds.)]. IPCC, Geneva, Switzerland, 151 pp.

IPCC. 2007. Mitigation of climate change. Contribution of Working Group III to the Fourth Assessment 

Report of the Intergovernmental Panel on Climate Change. B. Metz, O.R. Davidson, P.R. Bosch, 

R. Dave, L.A. Meyer (eds). Cambridge University Press, Cambridge, United Kingdom and New 

York, NY, USA.

IPCC. 2000. Special Report on Land Use, Land Use Change and Forestry, Summary for Policy Makers, 

2000. IPCC, Geneva, Switzerland. 20 pp.

Isaacs, F. B., R. G. Anthony, R. W. Krahmer, B. D. Callahan, add J. P. Peck. 2005. Effects of Forest 

Management on Bald Eagles Nesting on State and Private Land in Oregon. Oregon Department 

of Fish and Wildlife. Bald Eagle Monitoring Report TR19. March 2005.

ISLES (Island Surveys to Learn about Endemic Species). 2013. Welcome to ISLES. 

http://msb.unm.edu/isles/ (Accessed March 2013).

Iverson, C. G., 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. Gen. Tech. Rep. PNW-GTR-387, November 1996, Pacific Northwest Research Station, 

Portland, Oregon. USDA, Forest Service. 101 pp.

Iwamoto, R. N., E. O. Salo, M. A. Madej, and R. L. McComas. 1978. Sediment and Water Quality: A 

Review of the Literature Including a Suggested Approach for Water Quality Criteria. EPA/910/9-

78-048. U.S. Environmental Protection Agency, Region Ten, Seattle, Washington.

Janisch, J. E., and M. E. Harmon. 2002. Successional Changes in Live and Dead Wood Carbon Stores: 

Implications for Net Ecosystem Productivity. Tree Physiology 22:77-89.

Johnson, A., J. Ryan Bellmore, S. Haught, and R. Medel. 2019. Quantifying the Monetary Value of Alaska 

National Forests to Commercial Pacific Salmon Fisheries. North American Fisheries Management

39(6):1119-1131

Jonsson, R., W. Mbongo, A. Felton, and M. Boman. 2012. Leakage Implications for European Timber

Markets from Reducing Deforestation in Developing Countries. Forests 3:736-744.

Juday, G. P., R. A, Ott, D. W. Valentine, and V. A. Barber. 1998. Forests, Climate Stress, Insects, and 

Fire. In: Implications of Gobal Change in Alaska and the Bering Sea Region – Proceedings of a 

Workshop. Center for Global Change and Arctic System Research.

Kahklen, K., and W. Hartsog. 1999. Results of Road Erosion Studies on the Tongass National Forest. 

Unpublished report. 47 pp. On file with: USDA Forest Service, Pacific Northwest Research 

Station, Forestry Sciences Laboratory, 2770 Sherwood Lane, Suite 200, Juneau, AK 99801.
References 6

Final EIS 6-13 References

Karwan, D. L., J. A. Gravelle, and J. A. Hubbart. 2007. Effects of Timber Harvest on Suspended 

Sediment Loads in Mica Creek, Idaho. Forest Science 53(2):181-188.

Kauffman, K. 1996. Lives of North American Birds. Houghton-Mifflin, New York. 675 pp. As cited in BPIF 

(1999).

Keane, J. J., M. L. Morrison, and D. M. Fry. 2006. Prey and Weather Factors Associated with Temporal

Variation in Northern Goshawk Reproduction in the Sierra Nevada California. Stud. Avian Biol.

31:85–99. 

Kelly, B. P., T. Ainsworth, D. A. Boyce Jr., E. Hood, P. Murphy, and J. Powell. 2007. Climate Change: 

Predicted Impacts on Juneau. Scientific Panel on Climate Change, City and Borough of Juneau. 

Report to Mayor Bruce Botelho and the City and Borough of Juneau Assembly. April 2007.

Kendall, N. W., J. R. McMillan, M. R. Sloat, T. W. Buehrens, T. P. Quinn, R. R. Pess, K. V. Kuzishchin, M. 

M. McClure, and R. W. Zabel. 2015. Anadromy and Residency in Steelhead and Rainbow Trout 

(Oncorhynchus mykiss): A Review of the Processes and Patterns. Canadian Journal of Fisheries 

and Aquatic Science 72: 319–342.

Keyser, T. L., and S. J. Zarnoch. 2012. Thinning, Age, and Site Quality Influence Live Tree Carbon 

Stocks in Upland Hardwood Forests of the Southern Appalachians. Forest Science 58(5):407-

418.

Kissling, M. L. 2003. Effects of Forested Buffer Width on Breeding Bird Communities in Coastal Forests of 

Southeast Alaska with a Comparison of Avian Sampling Techniques. M.S. Thesis, University of 

Idaho, Moscow, Idaho. 

Kissling, M. L., and E. O. Garton. 2008. Forested Buffer Strips and Breeding Bird Communities in 

Southeast Alaska. Journal of Wildlife Management 72:674-681.

Kissling, M. L., P. M. Lukacs, S. B. Lewis, S. M. Gende, K. J. Kuletz, N. R. Hatch, S. K. Schoen, and S. 

Oehlers. 2011. Distribution and Abundance of the Kittlitz’s Murrelet Brachyramphus brevirostris in 

Selected Areas of Southeastern Alaska. Marine Ornithology 39:3–11.

Kline, J. D. 2006. Defining and Economics Research Program to Describe and Evaluate Ecosystem 

Services. USDA Forest Service, Pacific Northwest Research Station. General Technical Report 

PNW-GTR-700. December.

Kreiger, R., S. Whitney, and D. Robinson. 2020. Nonresidents Working in Alaska: 2018. Alaska 

Department of Labor and Workforce Development. Research and Analysis Section. Available 

online at: http://live.laborstats.alaska.gov/reshire/index.cfm

Krosse, P. C. 2016. Biological Evaluation for Plants. Tongass National Forest. Ketchikan, AK.

Kruse, J., and R. Muth. 1990. Subsistence Use of Renewable Resources by Rural Residents of 

Southeast Alaska. August. 160 pp.

Kuletz, K. J., D. K. Marks, N. L. Naslund, N. J. Goodson, and M. B. Cody. 1995. Inland Habitat Suitability 

for the Marbled Murrelet in Southcentral Alaska. In Ecology and Conservation of the Marbled 

Murrelet, edited by C.J. Ralph, G.L. Hunt, Jr., M.G. Raphael, and J.F. Piatt, 141-150. General 

Technical Report PSW-GTR-152. Pacific Southwest Research Station, Forest Service, U.S. Dept. 

of Agriculture, Albany, CA.

Lafferty D. J. R., J. L. Belant, K. S. White, J. N. Womble, and A. T. Morzillo. 2014. Linking Wolf Diet to 

Changes in Marine and Terrestrial Prey Abundance. Arctic 67:143–148.

Larsen, P., O. Goldsmith, O. Smith, M. Wilson, K. Strzepek, P. Chinowsky, and B. Saylor. 2007. 

Estimating the Future Cost of Alaska Public infrastructure at Risk to Climate Change. Institute of 

Social and Economic Research.
References 6

Final EIS 6-14 References

Larsen, C. F., R. J. Motyka, J. T. Freymueller, K. A. Echelmeyer, and E. R. Ivins. 2005. Rapid Viscoelastic 

Uplift in Southeast Alaska Caused by post-Little Ice Age Glacial Retreat. Earth and Planetary 

Science Letters 237(3-4):548-560. September 15. https://doi.org/10.1016/j.epsl.2005.06.032

Law, B. 2014. Role of Forest Ecosystems in Climate Change Mitigation. PowerPoint presentation by 

Beverly Law, Professor, Global Change Biology and Terrestrial Systems Science, Oregon State 

University. February. 

Lee-Yaw, J. A., J. T. Irwin, and D. M. Green. 2008. Postglacial Range Expansion from Northern Refugia 

by the Wood Frog, Rana sylvatica. Molecular Ecology 17:867-884. https://doi.org/10.1111/j.1365-

294X.2007.03611.x

Leighty, W. W., S. P. Hamburg, and J. Caouette. 2006. Sequestration in Forest Biomass in Southeast 

Alaska. Ecosystems 9:1051-1065.

Lerum, L., and P. C. Krosse. 2005. Tongass National Forest Invasive Plant Management Plan. Tongass 

National Forest. Ketchikan, AK.

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, USA.

Lewis, S. B., K. Titus, and M. R. Fuller. 2006. Northern Goshawk Diet during the Breeding Season on 

Southeast Alaska. Journal of Wildlife Management 70(4):1151-1160. 

Lindley, S. T., M. L. Moser, D. L. Erickson, M. Belchik, D. W. Welch, E. L. Rechisky, J. T. Kelly, J. 

Heublein, and A. P. Klimley. 2008. Marine Migration of North American Green Sturgeon. 

Transactions of the American Fisheries Society 137:182–194.

MacDonald, S. O., and J. A. Cook. 2007. Mammals and Amphibians of Southeast Alaska. Museum of 

Southwestern Biology, Special Publication No. 8. 191 pp. 

Malt, J., and D. Lank. 2007. Temporal Dynamics of Edge Effects on Nest Predation Risk for the Marbled 

Murrelet. Biological Conservation 140(1-2):160–173.

Markon, C., S. Gray, M. Berman, L. Eerkes-Medrano, T. Hennessy, H. Huntington, J. Littell, M. 

McCammon, R. Thoman, and S. Trainor. 2018. Alaska. In Impacts, Risks, and Adaptation in the 

United States: Fourth National Climate Assessment, Volume II. [Reidmiller, D.R., C.W. Avery, 

D.R. Easterling, K.E. Kunkel, K.L.M. Lewis, T.K. Maycock, and B.C. Stewart (eds.)]. U.S. Global 

Change Research Program, Washington, DC, USA. doi: 10.7930/NCA4.2018.CH26.

May, C. L. , B. Pryor, T. E. Lisle, and M. Lang. 2009. Coupling Hydrodynamic Modeling and Empirical 

Measures of Bed Mobility to Predict the Risk of Scour and Fish of Salmon Redds in a Large 

Regulated River. Water Resources Research 45: W05402, doi:10.1029/2007WR006498.

McClaren, E. 2004. “Queen Charlotte” Goshawk. Accounts and Measures for Managing Identified 

Wildlife. Accounts V: 1-15.

McClellan, M. H. 2005. Recent Research on the Management of Hemlock-spruce Forests in Southeast 

Alaska. Landscape and Urban Planning 72:65–78. 

McDowell Group. 2019. The Economic Benefits of Alaska’s Mining Industry. Prepared for the Alaska 

Miners Association. March. Available online at: https://www.mcdowellgroup.net/wpcontent/uploads/2019/04/2019-ama-econ-report.pdf

McDowell Group. 2018a. Economic Impact of Alaska’s Visitor Industry 2017. Prepared for the: Alaska 

Department of Commerce, Community, and Economic Development, Division of Economic 

Development. November. Available online at: 

https://www.commerce.alaska.gov/web/ded/dev/tourismdevelopment/tourismresearch.aspx

McDowell Group. 2018b. The Economic Benefits of Alaska’s Mining Industry. Prepared for the Alaska 

Miners Association. March. 71 pp.
References 6

Final EIS 6-15 References

McDowell Group. 2017. Alaska Visitor Statistics Program 7. Summer 2016. Prepared for the State of 

Alaska Department of Commerce, Community and Economic Development, Division of Economic 

Development and the Alaska Travel Industry Association. May. Available online at: 

https://www.commerce.alaska.gov/web/ded/dev/tourismdevelopment/tourismresearch.aspx

McDowell Group. 2013. Bokan Mountain Rare Earth Element Mine Economic Impact Study. Prepared for 

Ucore Rare Metals, Inc. January. Available online at: http://ucore.com/McDowell.pdf

McKee, C. 2006. Exotic Plants in Alaska’s Parks. National Forest Service / Univer Alaska. Available at: 

www.uaf.edu/snras/afes/pubs.

McKinley, D., M. Ryan, R. Birdsey, C. Giardina, M. Harmon, L. Heath, R. Houghton, R. Jackson, J. 

Morrison, R. Murray, D. Pataki, and K. Skog. 2011. A synthesis of current knowledge on forests 

and carbon storage in the United States. Ecological Applications 21(6):1902–1924.

McNeil, W. J. 1964. Effect of Spawning Bed Environment on Reproduction of Pink and Chum Salmon. 

Fishery Bulletin 65:495-523.

McNeil, W. J. and D. C. Himsworth (eds.). 1980. Salmonid Ecosystems of the North Pacific. Oregon State 

University Press, Corvallis, Oregon.

McPherson, E. G., and R. J. Simpson 1999. Carbon Dioxide Reduction Through Urban Forestry: 

Guidelines for Professional and Volunteer Tree Planters. PSW-GTR-171. USDA Forest Service, 

Pacific Southwest Research Station. January.

Millar, C., R. Neilson, D. Bachelet, R. Drapek, and J. Lenihan. 2006. Climate Change at Multiple Scales. 

Chapter 3 in: Forest, Carbon and Climate Change: A Synthesis of Science Findings. Oregon 

Forest Resources Institute. Oregon State University College of Forestry.

Millennium Ecosystem Assessment. 2005. Ecosystems and Human Well-being: Synthesis. Island Press. 

Washington DC. http://www.millenniumassessment.org/en/Synthesis.aspx

Morse, K. S. 2000. Responding to the Market Demand for Tongass Timber: Using Adaptive Management

to Implement Section 101 of the 1990 Tongass Timber Reform Act. Management Bulletin R10-

MB-413. Juneau, AK. U.S. Department of Agriculture, Forest Service, Alaska Region. 43p.

Murcia, C. 1995. Edge Effects in Fragmented Forests: Implications for Conservation. Trends in Ecology 

and Evolution 10:58–62.

Murphy, M. L., and A. M. Milner. 1997. Alaska Timber Harvest and Fish Habitat. In Freshwaters of Alaska: 

Ecological Syntheses, edited by A. M. Milner and M. W. Oswood, 229-263. Springer-Verlag: New 

York.

Murphy, M. L., J. Heifetz, S. W. Johnson, K. V. Koski, and J. F. Thedinga. 1986. Effects of Clearcut 

Logging with and Without Buffer Strips on Juvenile Salmonids in Alaskan Streams. Canadian 

Journal of Fisheries and Aquatic Sciences 43:1521–1533.

Naiman, R. J., T. J. Beechie, L. E. Benda, D. R. Berg, P. A. Bisson, L. H. MacDonald, M. D. O’Connor, P. 

L. Olson, and E. A. Steel. 1992. Fundamental Elements of Ecologically Healthy Watersheds in 

the Pacific Northwest Coastal Ecoregion. In Watershed Management: Balancing Sustainability 

and Environmental Change, edited by R. J. Naiman, 127-188. Springer-Verlag, New York, New 

York.

Nawrocki, T., J.R. Fulkerson, K.L. Dillman, and M.L. Carlson. 2017. Platanthera unalascensis (Spreng.) 

Kurtz (slender-spire orchid): Species Assessment for the Tongass National Forest, Alaska 

Region.

Nawrocki, T., H. Klein, M. Carlson, L. Flagstad, J. Conn, R. DeVelice, A. Grant, G. Graziano, B. Million, 

and W. Rapp. 2011. Invasiveness Ranking of 50 Non-Native Plant Species for Alaska. Report 

prepared for the Alaska Association of Conservation Districts. Alaska Natural Heritage Program, 

University of Alaska Anchorage, Anchorage, AK. 253 pp.
References 6

Final EIS 6-16 References

Niblack Project LLC. 2015. Economic Benefits. Available online at: 

http://www.niblackproject.com/s/Project_Benefits.asp?ReportID=579363

Nilon, C. H., C. N. Long, and W. C. Zipperer. 1995. Effects of Wildland Development on Forest Bird 

Communities. Landscape and Urban Planning 32:81-92.

M. M. Muto, V. T. Helker, R. P. Angliss, B. A. Allen, P. L. Boveng, J. M. Breiwick, M. F. Cameron, P. J. 

Clapham, S. P. Dahle, M.E. Dahlheim, B. S. Fadely, M. C. Ferguson, L. W. Fritz, R. C. Hobbs, 

Y.V. Ivashchenko, A. S. Kennedy, J. M. London, S. A. Mizroch,R. R. Ream, E. L. Richmond, K. E. 

W. Shelden, R. G. Towell, P. R. Wade, J. M. Waite, and A. N. Zerbini. 2018. Alaska Marine 

Mammal Stock Assessments, 2017. U.S. Dept. Commer., NOAA Technical Memorandum NMFSAFSC, 378. June 2018. 382 p. Available online at: 

https://repository.library.noaa.gov/view/noaa/18114

NMFS (National Marine Fisheries Service). 2016. Tongass Forest Plan Amendment Letter of 

Concurrence, NMFS (#AKR-2016-9574). October 18, 2016 letter to Earl Stewart, Forest 

Supervisor. NMFS Juneau, AK.

NMFS. 2015a. ESA Species in Alaska. Endangered, Threatened and Candidate Species in Alaska. 

Update April 2014. Web access August 2015. 

https://alaskafisheries.noaa.gov/protectedresources/esa/ak_nmfs_species.pdf

NMFS. 2015b. Southern Distinct Population Segment of the North American Green Sturgeon (Acipenser 

medirostris). 5-Year Review: Summary and Evaluation. National Marine Fisheries Service, West 

Coast Region, Long Beach, CA.

NMFS. 2009a. Marine mammal fact pages. Available online at: 

http://www.nmfs.noaa.gov/pr/species/mammals/ 

NMFS. 2009b. Green, Leatherback and Loggerhead sea turtle fact pages. Available online at: 

http://www.nmfs.noaa.gov/pr/species/turtles 

NMFS. 1991. Recovery Plan for the Humpback Whale (Megaptera novaeangliae). Prepared by the 

Humpback Whale Recovery Team for the National Marine Fisheries Service, Silver Spring, 

Maryland. 

Nowacki, G. S., and M. G. Kramer. 1998. The Effects of Wind Disturbance on Temperate Rain Forest 

Structure and Dynamics of Southeast Alaska. USDA Forest Service. PNW GTR-421, April 1998.

Office of Subsistence Management. 2016. The Federal Subsistence Management Program: An Overview. 

Available online at: 

https://www.doi.gov/sites/doi.gov/files/uploads/subsistence_management_program_brochure_20

16_weblayout_508_reduced.pdf

Olliff, T., K. Legg, and B. Kaeding, editors. 1999. Effects of Winter Recreation on Wildlife of the Greater 

Yellowstone Area: A Literature Review and Assessment. Report to the Greater Yellowstone 

Coordinating Committee. Yellowstone National Park, Mammoth, Wyoming, USA.

Olsen, D. H., J. B. Leirness, P. G. Cunningham, and E. A. Steel. 2014. Riparian Buffers and Forest 

Thinning: Effects on Headwater Vertebrates 10 Years After Thinning. Forest Ecology and 

Management 321:81-93.

Oswood, N. W., A. M. Milner, and J. G. Irons III. 1992. Climate Change and Alaskan Rivers and Streams. 

In: Global Climate Change and Freshwater Ecosystems, edited by P. Firth and S. G. Stuart, 192-

210. Springer-Verlag. New York.

Parker, D. I., J. A. Cook, and S. W. Lewis. 1996. Effects of Timber Harvest on Bat Activity in Southeastern 

Alaska's Temperate Rainforest. In: Bats and Forests Symposium, October 19-21, 1995, Victoria,

edited by R. M. R. Barclay and R. M. Brigham., 277-292. Res. Br., B.C. Min. For., Victoria, B.C.
References 6

Final EIS 6-17 References

Parks, N., and T. Barrett. 2013. Tangled Trends for Temperate Rain Forests as Temperatures Tick Up. 

Science Findings 149. Portland, OR: USDA Forest Service, Pacific Northwest Research Station. 

6 p.

Parrent, D., N. Grewe, and J. Daniels. 2019. Tongass National Forest: 2018 Sawmill Capacity and 

Production Report. Report to Ecosystem Planning and Budget. USDA Forest Service. Alaska 

Region. July. Available online at: 

https://www.fs.usda.gov/detail/r10/landmanagement/resourcemanagement/?cid=fsbdev2_038785

Parrent, D., and N. Grewe. 2018. Tongass National Forest: 2017 Sawmill Capacity and Production 

Report. Report to Ecosystem Planning and Budget. USDA Forest Service. Alaska Region. 

September. Available online at: 

https://www.fs.usda.gov/detail/r10/landmanagement/resourcemanagement/?cid=fsbdev2_038785

Parson, E. A., L. Carter, P. Anderson, B. Wang, and G. Weller. 2001. Alaska. In Climate Change Impacts 

on the United States: Potential Consequences of Climate Variability and Change, National 

Assessment Synthesis Team, 283-314 (Chapter 10). Cambridge: Cambridge University Press.

Patriquin, K. J., and R. M. R. Barclay. 2003. Foraging by Bats in Cleared, Thinned and Unharvested 

Boreal Forest. Journal of Applied Ecology 40:646-657.

Peacock, E., M. M. Peacock, and K. Titus. 2007. Black Bears in Southeast Alaska: The Fate of Two 

Ancient Lineages in the Face of Contemporary Movement. Journal of Zoology 271:445–454.

Pearce, D. E., S. A. Hayes, M. H. Bond, C. V. Hanson, E. C. Anderson, R. B. Macfarlane, and J. C. 

Garza. 2009. Over the Fall? Rapid Evolution of Ecotypic Differentiation in Steelhead/Rainbow 

Trout (Oncorhynchus mykiss). Journal of Heredity 100(5):515–525. 

Person, D. K., and T. J. Brinkman. 2013. Succession Debt and Roads: Short and Long-term Effects of 

Timber Harvest on a Large-Mammal Predator-Prey Community in Southeast Alaska. Pages 143-

167 in Orians, G. and J. Schoen, editors. North Pacific Temperate Rainforests: Ecology and 

Conservation. University of Washington Press, Seattle, WA.

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-2011-1. Alaska Department of Fish and Game, Division of Wildlife 

Conservation, Juneau, AK. 

Person, D. K., and A. L. Russell. 2009. Reproduction and Den Site Selection by Wolves in a Disturbed 

Landscape. Northwest Science 83:211–224.

Person, D. K., and A. L. Russell. 2008. Correlates of mortality in an exploited wolf population. Journal of 

Wildlife Management 72:1540–1549.

Person, D. 2001. Alexander Archipelago Wolves: Ecology and Population Viability in a Disturbed, Insular 

Landscape. Doctoral dissertation, University of Alaska Fairbanks, AK.

Person, D. K., M. Kirchhoff, V. Van Ballenberghe, G. C. Iverson, and E. Grossman. 1996. The Alexander 

Archipelago Wolf: A Conservation Assessment. General Technical Report PNWGTR-384. U.S. 

Department of Agriculture, Forest Service, Pacific Northwest Research Station, Portland, OR.

Piatt, J. F., K. J. Kuletz, A. E. Burger, S. A. Hatch, V. L. Friesen, T. P. Birt, M. L. Arimitsu, G. S. Drew, A. 

M. A. Harding, and K. S. Bixler. 2007. Status Review of the Marbled Murrelet (Brachyramphus 

marmoratus) in Alaska and British Columbia. U.S. Geological Survey Open-File Report 2006-

1387. 258 pp.

Porter, B. 2018. Wolf Management Report and Plan, Game Management Unit 2: Report Period 1 July 

2010–30 June 2015, and Plan Period 1 July 2015–30 June 2020. Alaska Department of Fish and 

Game, Species Management Report and Plan ADF&G/DWC/SMR&P-2018-10, Juneau.
References 6

Final EIS 6-18 References

Porter, B. 2010. Unit 1A Mountain Goat Management Report. Pages 1-5 in P. Harper, editor. Mountain 

Goat Report of Survey and Inventory Activities 1 July 2007 – 30 June 2009. Alaska Department 

of Fish and Game. Project 12.0. Juneau, AK. 

Pyare, S., and W.P. Smith. 2005. Functional Connectivity of Tongass Old-Growth Reserves: An 

Assessment Based on Flying-Squirrel Movement Capability. Progress report for Tongass 

monitoring grants, April 30, 2005.

Pyare, S., W.P. Smith, and C.S. Shanley. 2010. Den Use and Selection by Northern Flying Squirrels in 

Fragmented Landscapes. Journal of Mammalogy 91:886–896.

Rabe, D. 2009. Population Status of Prince of Wales Spruce Grouse in Southeast Alaska. Final 

performance report. Alaska Department of Fish and Game, Juneau. September. 8 pp.

Ralph, C.J., and S.L. Miller. 1995. Offshore Population Estimates of Marbled Murrelets in California. In: 

Ecology and Conservation of the Marbled Murrelet, C.J. Ralph, G.L. Hunt, M. Raphael, and J.F. 

Piatt (tech. eds.). 353-360 (Chapter 33). General Technical Report PSW-GTR-152. Albany, CA. 

Pacific Southwest Experiment Station, Forest Service, U.S. Department of Agriculture. 420 pp.

Raphael, M. G., K. V. Rosenberg, and B. G. Marcot. 1988. Large-scale Changes in Bird Populations of 

Douglas-fir Forests, Northwestern California. Bird Conservation 3:63-83.

Reid, L.M. and T. Dunne. 1984. Sediment Production from Forest Road Surfaces. Water Resources 

Research, WRERAC 20(11):1753-1761. November 1984.

Reid, W.V., and K.R. Miller. 1989. Keeping Options Alive: The Scientific Basis for Conserving Biodiversity.

World Resources Institute, Washington, D.C. 

Reynolds, R. T., R. T. Graham, and D. A. Boyce Jr. 2006. An Ecosystem-based Conservation Strategy for 

the Northern Goshawk. In The Northern Goshawk: a Technical Assessment of its Status, 

Ecology, and Management, edited by M. L. Morrison, 299-311. Studies in Avian Biology No. 31, 

Cooper Ornithological Society.

Reynolds, R. T., R. T. Graham, M. H. Reiser, R. L. Bassett, P. L. Kennedy, D. A. Boyce, G. Goodwin, R. 

Smith, and E. L. Fisher. 1992. Management Recommendations for the Northern Goshawk in the 

Southwestern United States. General Technical Report RM-217. USDA Forest Service, Rocky 

Mountain Forest and Range Experiment Station, Fort Collins, Colorado.

Rich, T. D., C. J. Beardmore, H. Berlanga, P. J. Blancher, M. S. W. Bradstreet, G. S. Butcher, D. W. 

Demarest, E. H. Dunn, W. C. Hunter, E. E. Iñigo-Elias, J. A. Kennedy, A. M. Martell, A. O. 

Panjabi, D. N. Pashley, K. V. Rosenberg, C. M. Rustay, J. S. Wendt, T. C. Will. 2004. Partners in 

Flight North American Landbird Conservation Plan. Cornell Lab of Ornithology. Ithaca, NY. 

Partners in Flight website. http://www.partnersinflight.org/cont_plan/ (VERSION: March 2005).

Robinson, S. K., F. R. Thompson III, T. M. Donovan, D. R. Whitehead, and J. Faaborg. 1995. Regional 

Forest Fragmentation and the Nesting Success of Migratory Birds. Science 267:1987–1990.

Roffler, G., and D. Gregovich. 2018. Wolf Space Use During Denning Season on Prince of Wales Island, 

Alaska. Wildlife Biology 2018(1): doi: 10.2981/wlb.00468

Rosenberg K. V., J. A. Kennedy, R. Dettmers, R. P. Ford, D. Reynolds, J.D. Alexander, C. J. Beardmore, 

P. J. Blancher, R. E. Panjabi, D. N. Pashley, T. D. Rich, J. M. Ruth, H. Stabins, J. Stanton, T. 

Will. 2016. Partners in Flight Landbird Conservation Plan: 2016 Revision for Canada and 

Continental United States. Partners in Flight Science Committee. 119 pp.

Russell, A.L. 1999. Habitat Relationships of Spruce Grouse in Southeast Alaska. M. S. Thesis. Texas 

Tech University, Dallas, TX. May.

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.
References 6

Final EIS 6-19 References

Salafsky, S. R., R. T. Reynolds, and B. R. Noon. 2005. Patterns of Temporal Variation in Goshawk 

Reproduction and Prey Resources. Journal of Raptor Research 39:237-246.

Salo, E. O. 1991. Life History of Chum Salmon. (Oncorhynchus keta). In Pacific Salmon Life Histories, 

edited by C. Groot and L. Margolis, 231-310. University of British Columbia in co-operation with 

the Government of Canada, Department of Fisheries and Oceans. British Columbia, Canada.

Sauer, J.R., J. E. Hines, J. E. Fallon, K. L. Pardieck, D. J. Ziolkowski, Jr., and W. A. Link. 2014. The North 

American Breeding Bird Survey, Results and Analysis 1966 - 2013. Version 01.30.2015. USGS 

Patuxent Wildlife Research Center, Laurel, MD.

Scheibe, J. S., W. P. Smith, J. Bassham, and D. Magness. 2006. Locomotor Performance and Cost of 

Transport in the Northern Flying Squirrel Glaucomys sabrinus. Acta Theriologica 51(2):169–178.

Schoen, J., and L. Beier. 1990. Brown Bear Habitat Preferences and Brown Bear Logging and Mining 

Relationships in Southeast Alaska. Federal Aid in Wildlife Restoration. Final report. Grant W-22. 

Alaska Department of Fish and Game, Juneau, AK.

Schrader, B., and P. Hennon. 2005. Assessment of Invasive Species in Alaska and its National Forests. 

Compiled by Schrader and Hennon with contributing authors from USDA Forest Service Alaska 

Regional Offices. August 30, 2005. 26 pp.

Schroeder, R., and R. Mazza. 2005. A Synthesis of Recent Subsistence Research in Southeast Alaska. 

Available on request. 

Sealaska. 2018. 2018 Q1 Shareholder Newsletter. Available online: 

https://www.sealaska.com/sites/default/files/resources/2018%20Q1%20Shareholder%20Newslett

er.pdf

Semlitsch, R. D., B. D. Todd, S. M. Blomquist, A. J. K. Calhoun, J. W. Gibbons, J. P. Gibbs, G. J. Graeter, 

E. B. Harper, D. J. Hocking. M. L. Hunter Jr., D. A. Patrick, T. A. G. Rittenhouse, and B. B. 

Rothermel. 2009. Effects of Timber Harvest on Amphibian Populations: Understanding 

Mechanisms from Forest Experiments. BioScience 59(10):853-862.

Shanley, C. S, S. Pyare, M. Goldstien, P. Alaback, D. Albert, C. Beier, T. Brinkman, R. Edwards, E. Hood, 

A. MacKinnon, M. McPhee, T. Patterson, L. Suring, D. Tallmon, and M. Wipfli. 2015. Climate 

Change Implications in the Northern Coastal Temperate Rainforest of North America. Climatic 

Change 130:155-170.

Shanley, C. S., and D. M. Albert. 2014. Climate Change Sensitivity Index for Pacific Salmon habitat in 

Southeast Alaska. PLoS ONE 9(11):e104799.

Skog, K. E.; D. C. McKinley, R. A. Birdsey, S. J. Hines, C. W. Woodall, E. D. Reinhardt, and J. M. Vose. 

2014. Managing Carbon. In Climate Change and United States Forests, edited by D. L. Peterson 

et al., Chapter 7. Advances In Global Change Research 57. doi 10.1007/978-94-007-7515-2__7 

http://digitalcommons.unl.edu/usdafsfacpub/274

Sloat, M. R., G. H. Reeves, and K. R. Christiansen. 2016. Stream Network Geomorphology Mediates 

Predicted Vulnerability of Anadromous Fish Habitat to Hydrologic Change in Southeast Alaska. 

Global Change Biology 23(2). https://onlinelibrary.wiley.com/doi/full/10.1111/gcb.13466

Smith, J. E., G. M. Domke, M. C. Nichols, and B. F. Walters. 2019. Carbon stocks and stock change on 

federal forest lands of the United States. Ecosphere 10(3): article e02637. 10.1002/ecs2.2637

Smith, W. 2013. Spatially Explicit Analysis of Contributions of a Regional Conservation Strategy Toward 

Sustaining Northern Goshawk Habitat. Wildlife Society Bulletin 37:1–10.

Smith, N., R. Deal, J. Kline, D. Blahna, T. Patterson, T.A. Spies, and K. Bennett. 2011. Ecosystem 

Services as a Framework for Forest Stewardship: Deschutes National Forest Overview. Pacific 

Northwest Research Station General Technical Report PNW-GTR-852. August.
References 6

Final EIS 6-20 References

Smith, W. P. 2005. Evolutionary Diversity and Ecology of Endemic Small Mammals of Southeastern 

Alaska with Implications for Land Management Planning. Landscape and Urban Planning

72:135–155.

Smith, J. E., L. S. Heath, and P. B. Woodbury. 2004. How to Estimate Forest Carbon for Large areas from 

Inventory Data. Journal of Forestry July/August: 25-31. 

Southeast Conference. 2018. Southeast Alaska by the Numbers 2018. Prepared by Rain Coast Data. 

Available online at: 

http://www.seconference.org/sites/default/files/Southeast%20Alaska%20by%20the%20numbers

%202018%20FINAL-compressed.pdf

Southeast Conference. 2019. Southeast Alaska by the Numbers 2019. Prepared by Rain Coast Data. 

Available online at: http://www.seconference.org/

SNAP (Scenarios Network for Alaska & Arctic Planning). 2013. Community Charts: Juneau, Alaska. 

Soule, M. E. 1983. What do we really know about extinction? Pp 111-124 in C. M. Schonewald-Cox, S. 

M. Chambers, B. MacBryde, and W. L. Thomas, eds. Genetics and Conservation. 

Benjamin/Cummings, London. As Cited in Dawson et al. (2007). 

Spence, B. C., G. A. Lomnicky, R. M. Hughes, and R. P. Novitizki. 1996. An Ecosystem Approach to 

Salmonid Conservation. Report prepared by Management Technology. Sponsored by the 

National Marine Fisheries Service, U.S. Environmental Protection Agency, and the U.S. Fish and 

Wildlife Service, Washington, D.C.

Spies, T. A. 2004. Ecological Concepts and Diversity of Old-growth Forests. Journal of Forestry

102(3):14–20. April 1.

Spies, T. A., and J. F. Franklin. 1991. The Structure of Natural Young, Mature, and Old-growth Douglas-fir 

Forest in Oregon and Washington. In Wildlife and Vegetation of Unmanaged Douglas-fir Forests, 

edited by L. F. Ruggiero, K. B. Aubry, A. B. Carey, and M. H. Huff. General Technical Report 

PNW-285. USDA Forest Service, Pacific Northwest Research Station, Portland, OR.

Straley, J. M., C.M. Gabriele, and T.J. Quinn II. 2009. Assessment of Mark Recapture Models to Estimate 

the Abundance of a Humpback Whale Feeding Aggregation in Southeast Alaska. Journal of 

Biogeography 36:427-438.

Stephenson, N., A. Das, R. Condit, S. Russo, P. Baker, N. Beckman, D. Coomes, E. Lines, W. Morris, N. 

Ruger, E. Alvarez, C. Blundo, S. Bunyavejchewin, G. Chuyong, S. David, A. Duque, C. Ewango, 

O. Flores, J. Franklin, H. Grau, Z. Hao, M. Harmon, S. Hubbell, D. Kenfrack, Y. Lin, J. Makana, A. 

Malizia, R. Pabst, N. Pongpattananurak, S. Su, I. Sun, S. Tan, D. Thomas, P. Mantgem, X. 

Wang, S. Wiser, and M. Zavala. 2014. Rate of Tree Carbon Accumulation Increases 

Continuously with Tree Size. Nature: International Weekly Journal of Science 507(7490). 

Available online at: http://www.nature.com/nature/journal/v507/n7490/full/nature12914.html

Stillwater Sciences. 2012. Forest Management and Coho Salmon Population Dynamics in Southeast 

Alaska’s Staney Creek Watershed. Prepared by Stillwater Sciences, Portland, Oregon for The 

Wilderness Society, Anchorage, Alaska.

Stone, K. D., and J. A. Cook. 2000. Phylogeography of Black Bears (Ursus americanus) of the Pacific 

Northwest. Canadian Journal of Zoology 78:1218–1223.

Strong, D. 2014. Seafood Processors. Large Segment of a Massive Industry. Alaska Economic Trends

34(11):9–11.

Sullivan, P. F.; R. L. Mulvey, A. Brownlee, T. M. Barrett, and R. R. Pattison. 2015. Warm Summer Nights 

and the Growth Decline of Shore Pine in Southeast Alaska. Environmental Research Letters 10: 

124007. http://dx.doi.org/10.1088/1748-9326/10/12/124007.
References 6

Final EIS 6-21 References

Sullivan, K., T. E. Lisle, C. A. Dolloff, G. E. Grant, and L. M. Reid. 1987. Stream Channels: the Link 

between Forests and Fishes. In Streamside Management: Forestry and Fishery Interactions, 

edited by E. O. Salo and T. W. Cundy, 39-97. Institute of Forest Resources Contribution Number 

57. University of Washington, College of Forest Resources, Seattle, Washington.

Swanson, F. J., L. E. Benda, S. H. Duncan, G. E. Grant, W. F. Magahan, L. M. Reid, and R. R. Ziemer. 

1987. Mass Failures and Other Processes of Sediment Production in Pacific Northwest Forest 

Landscapes. In Streamside Management: Forestry and Fishery Interactions, edited by E.O. Salo 

and T.W. Cundy, 9-38. Institute of Forest Resources Contribution Number 57. University of 

Washington, College of Forest Resources, Seattle, Washington. 

Swanson, F. J., G. W. Lienkaemper, and J. R. Sedell. 1976. History, Physical Effects, and Management 

Implications of Large Organic Debris in Western Oregon Streams. General Technical Report 

PNW-56. USDA Forest Service, Portland, Oregon.

Szepanski, M. M., M. Ben-David, and V. Van Ballenberghe. 1999. Assessment of Anadromous Salmon 

Resources in the Diet of the Alexander Archipelago Wolf Using Stable Isotope Analysis. 

Oecologia 120: 327–335.

Taylor, P.D., L. Fahrig, K. Henein, and G. Merriam. 1993. Connectivity Is a Vital Element of Lanscape 

Structure. Oikos 68(3):571–572.

Tessler, D. F, M. L. Snively, and T. A. Gotthardt. 2014. New Insights on the Distribution, Ecology and 

Overwintering Behavior of the Little Brown Myotis (Myotis lucifugus) in Alaska. Northwestern 

Naturalist 95:251-263.

Tessler, D. F., J. A. Johnson, B. A. Andres, S. Thomas, and R. B. Lanctot. 2007. Black Oystercatcher 

(Haematopus bachmani) Conservation Action Plan. International Black Oystercatcher Working 

Group, Alaska Department of Fish and Game, Anchorage, AK; U.S. Fish and Wildlife Service, 

Anchorage, AK; and Manomet Center for Conservation Sciences, Manomet, MA.

Thompson, I. D., and A. S. Harestad. 1994. Effects of Logging on American Martens, and Models for 

Habitat Management. In Martens, Sables, and Fishers: Biology and Conservation, edited by S. 

W. Buskirk, A. S. Harestad, M. G. Raphael, and R. A. Powell, 355-367. Cornell University Press, 

Ithaca, NY.

Thysell, D. R., and A. B. Carry. 2000. Effects of Forest Management on Understory and Overstory 

Vegetation: A Retrospective Study. USDA Forest Service. PNW-GTR-488. March 2000. 

Titus, K., and L. Beier. 1999. Suitability of Stream Buffers and Riparian Habitats for Brown Bears. Ursus

11:149-156 (abstract only).

Tonina, D., C. H. Luce, B. Rieman, J. M. Buffington, P. Goodwin, S. R. Clayton, S. M. Ali, J. J. Barry, J. J, 

and C. Berenbrock. 2008. Hydrological Response to Timber Harvest in Northern Idaho: 

Implications for Channel Scour and Persistence of Salmonids. Hydrological Processes 22:3223-

3235.

Trudel, M., D. W. Welsh., J. F. T. Morris, M. E. Thiess, R. Candy, and T. D. Beacham. 2004. Using 

Genetic Markers to Understand the Coastal Migration of Juvenile Coho (Oncorhynchus kisutch) 

and Chinook Salmon (O. tshawytscha). North Pacific Anadromous Fish Commission Technical 

Report 5.

Trudel, M., J. Fisher, J. Orsi, J. Morris, M. Thiess, R. Sweeting, S. Hinton, E. Fergusson, and D. Welch. 

2009. Distribution and migration of Juvenile Chinook Salmon Derived from Coded Wire Tag 

Recoveries along the Continental Shelf of Western North America. Transactions of the American 

Fisheries Society 138:1369–1391.

Tucker, S., M. Trudel, D. W. Welch, J. R. Candy, J. F. T. Morris, M. E. Thiess, C. Wallace, and T. D. 

Beacham. 2011. Life History and Seasonal Stock-specific Ocean Migration of Juvenile Chinook 

Salmon. Transaction of the American Fisheries Society 140:1101–1191.
References 6

Final EIS 6-22 References

U.S. Census Bureau. 2019a. BO3002: Hispanic or Latino Origin by Race. 2014-2018 American 

Community Survey 5-Year Estimates. Available online at: https://data.census.gov/cedsci/

U.S. Census Bureau. 2019b. B19013: Median Household Income in the Past 12 Months (in 2018 

Inflation-Adjusted Dollars). 2014-2018 American Community Survey 5-Year Estimates. Available 

online at: https://data.census.gov/cedsci/

U.S. Census Bureau. 2019c. S1701: Poverty Status in the Past 12 Months. 2014-2018 American 

Community Survey 5-Year Estimates. Available online at: https://data.census.gov/cedsci/

U.S. NABCI (U.S. National Bird Conservation Initiative Committee). 2000. Bird Conservation Region 

Descriptions: A Supplement to the North American Bird Conservation Initiative Bird Conservation 

Regions Map. Available online at: http://www.nabci-us.org/aboutnabci/bcrdescrip.pdf

United Nations Environment Programme. 1991. Fourth Revised Draft Convention on Biological Diversity. 

United Nations Environment Programme.

URS Corporation. 2006. Mineral Potential Report, Ring of Fire Planning Area, Alaska. Prepared for 

Bureau of Land Management, Anchorage Field Office. Anchorage, Alaska. July 2006.

USACE (U.S. Army Corps of Engineers). 2004. Letter signed by John C. Leeds III, Juneau Field 

Regulatory Office, February 10, 2004. 

USDA Forest Service. In Review. Assessment of the Influence of Disturbance, Management Activities, 

and Environmental Factors on Carbon Stocks. Alaska Region. Office of Sustainability and 

Climate Change. Washington, D.C. 35 pp.

USDA Forest Service. 2020. Jobs and Harvest Tables 2002 to 2018. Data provided by Jean M. Daniels 

PhD, Research Forester, Pacific Northwest Research Station, Portland, Oregon.

USDA Forest Service. 2019a. Estimating the Range of FY19 Expected Tongass National Forest Timber

Purchase and Sale Offer. Briefing paper. May 10. Available online at: 

https://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fseprd632578.pdf

USDA Forest Service. 2019b. Tongass National Forest 5 Year Timber Sale Schedule 2019-2023. 

Available online at: https://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fseprd613987.pdf

USDA Forest Service. 2019c. U.S. Forest Service, Alaska Region, Remaining Timber Sales Volumes and 

Values on December 31, 2019. Available online at: 

https://www.fs.usda.gov/detail/r10/landmanagement/resourcemanagement/?cid=fsbdev2_038785

USDA Forest Service. 2019d. Tongass National Forest Log Exports and Interstate Shipments (MMBF) 

(Compiled by Tongass NF). Updated June. Available online at: 

https://www.fs.usda.gov/detail/r10/landmanagement/resourcemanagement/?cid=fsbdev2_038785

USDA Forest Service. 2019e. All Service Receipts (ASR) Final Payment Detail Report (ASR-10-03). 

Fiscal Year 2018. April 12. Available online at: https://www.fs.fed.us/

USDA Forest Service. 2019f. Tongass National Forest 2015 Annual Monitoring and Evaluation summary. 

R10-MB-811. Tongass National Forest Alaska.

USDA Forest Service. 2019g. Natural Resource Manager (NRM): Threatened, Endangered, and 

Sensitive Plants (TESP) Inventory.

USDA Forest Service. 2018a. Tongass Harvest and Employment, 2002 to 2017 Update. Data on file with 

Nicole Grewe, Ph.D. Regional Economist, USDA Forest Service, Alaska Region.

USDA Forest Service. 2018b. Estimating the Range of Expected Tongass National Forest Timber

Purchase and Sale Offer. Briefing paper. April. Available online at: 

https://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fseprd605841.pdf
References 6

Final EIS 6-23 References

USDA Forest Service. 2018c. Tongass National Forest 5 Year Timber Sale Schedule 2018-2022. 

Available online at: https://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fseprd575055.pdf

USDA Forest Service. 2018d. U.S. Forest Service, Alaska Region, Remaining Timber Sales Volumes and 

Values on November 30, 2018. Available online at: 

https://www.fs.usda.gov/detail/r10/landmanagement/resourcemanagement/?cid=fsbdev2_038785

USDA Forest Service. 2018e. Prince of Wales Landscape Level Analysis Project. Final Environmental 

Impact Statement. Alaska Region. Tongass National Forest, Thorne Bay Ranger District and 

Craig Ranger District. R10-MB-833e. October. Available online at: 

https://www.fs.usda.gov/detail/tongass/landmanagement/projects/?cid=fseprd529245

USDA Forest Service. 2018f. Draft Decision Notice for the Vallenar Young-growth Project. Ketchikan

Misty Fjords Ranger District. February. Available online at: 

https://www.fs.usda.gov/project/?project=51766

USDA Forest Service. 2018g. All Service Receipts (ASR) Final Payment Detail Report (ASR-10-03). 

Fiscal Year 2016. May 7. Available online at: https://www.fs.fed.us/

USDA Forest Service. 2018h. All Service Receipts (ASR) Final Payment Detail Report (ASR-10-03). 

Fiscal Year 2017. May 7. Available online at: https://www.fs.fed.us/

USDA Forest Service. 2018i. Natural Resource Information System (NRIS): Current Invasive Plants

Inventory. NRIS Invasive Plants Product Page. Available online at: 

http://data.fs.usda.gov/geodata/edw/datasets.php?dsetParent=InvasiveSpecies. Accessed: 

November 2018.

USDA Forest Service. 2017a. Estimating the Range of Expected Tongass National Forest Timber

Purchase and Sale Offer. Briefing paper. May.

USDA Forest Service. 2017b. U.S. Forest Service, Alaska Region, Remaining Timber Sales Volumes and 

Values on November 30. Available online at: 

https://www.fs.usda.gov/detail/r10/landmanagement/resourcemanagement/?cid=fsbdev2_038785

USDA Forest Service. 2017c. First Alaska timber sale sold under state-federal Good Neighbor Authority. 

Available online at: https://www.fs.usda.gov/detail/tongass/news-events/?cid=FSEPRD559699

USDA Forest Service. 2017d. Wrangell Island Project Record of Decision. Forest Service Alaska Region. 

Tongass National Forest. R10-MB-634d. December. Available online at: 

https://www.fs.usda.gov/project/?project=34831

USDA Forest Service. 2017e. Shoreline II Outfitter/Guide Final Environmental Impact Statement. Alaska 

Region. Tongass National Forest. R10-MB-793c. March. Available online at: 

https://www.fs.usda.gov/project/?project=38181

USDA Forest Service. 2017f. Economic Effects of National Forest Recreation in Alaska. Alaska Region. 

Briefing Paper. March. Available online at: 

https://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fseprd511800.docx 

USDA Forest Service. 2016a. Tongass Land and Resource Management Plan. R10-MB-769g. June.

USDA Forest Service. 2016b. Tongass Land and Resource Management Plan, Final Environmental 

Impact Statement Plan Amendment. R10-MB-769e, f. June. Available online at: 

https://www.fs.usda.gov/detail/tongass/landmanagement/planning/?cid=stelprd3801708

USDA Forest Service. 2016c. Tongass Land and Resource Management Plan Record of Decision. R10-

MB-769l. December.

USDA Forest Service. 2016d. All Service Receipts (ASR) Final Payment Detail Report (ASR-10-03). 

Fiscal Year 2015. January 22. Available online at: https://www.fs.fed.us/
References 6

Final EIS 6-24 References

USDA Forest Service. 2016e. Tongass National Forest Amendment Biological Assessment for Species 

Under the Jurisdiction of the National Marine Fisheries Service. Tongass National Forest, Alaska. 

40p.

USDA Forest Service. 2015a. All Service Receipts (ASR) Final Payment Detail Report (ASR-10-03). 

Fiscal Year 2013. January 8. Available online at: https://www.fs.fed.us/

USDA Forest Service. 2015b. All Service Receipts (ASR) Final Payment Detail Report (ASR-10-03). 

Fiscal Year 2014. April 22. Available online at: https://www.fs.fed.us/

USDA Forest Service. 2015c. 2014 Tongass Land Management Plan Monitoring & Evaluation Report. 

Available online 

https://www.fs.usda.gov/detail/tongass/landmanagement/planning/?cid=stelprd3856205 

[February 2019].

USDA Forest Service. 2015d. Baseline Estimates of Carbon Stocks in Forests and Harvested Wood 

Products for National Forest System Units; Alaska Region. 34 pp. Whitepaper. 

http://www.fs.fed.us/climatechange/documents/AlaskaRegionCarbonAssessment.pdf

USDA Forest Service. 2015e. Species Evaluations for 16 Plants and 3 Lichens on the Tongass National 

Forest: An Evaluation for Species of Conservation Concern. Unpublished, internal document. 170 

pp.

USDA Forest Service. 2014. 2013 Annual Tongass National Forest Monitoring and Evaluation Report. 

14a Stream and Fish Habitat: Fish Passage. Available on line 

http://www.fs.usda.gov/detail/tongass/landmanagement/planning/?cid=stelprdb5368225 

[November 2014]

USDA Forest Service. 2013a. Forest Service National Strategic Framework for Invasive Species FS1017. Washington, DC.

USDA Forest Service. 2013b. Environmental Assessment, Decision Notice and Finding of No Significant 

Impact, Wrangell-Petersburg Weed Management Project. Wrangell and Petersburg Ranger 

Districts, Tongass National Forest. R10-MB-758. July.

USDA Forest Service. 2012a. 2011 Tongass Monitoring and Evaluation Report. Tongass National Forest.

USDA Forest Service. 2012b. Alaska Region Sensitive Plants.

USDA Forest Service. 2012c. Bell Island Geothermal Leases Final Supplemental EIS and Record of 

Decision. Ketchikan Misty Fiords Ranger District, Tongass National Forest. R10-MB-750b. 

December 2012.

USDA Forest Service. 2012d. Ketchikan Misty Fiords Outfitter and Guide Management Plan Final 

Environmental Impact Statement. Tongass National Forest. R10-MB-737b. January. Available 

online at: https://www.fs.usda.gov/project/?project=32817

USDA Forest Service. 2012e. Prince of Wales Outfitter and Guide Management Plan Environmental 

Assessment. Tongass National Forest. R10-MB-743a. March. Available online at: 

https://www.fs.usda.gov/project/?project=27974

USDA Forest Service. 2011a. Timber Supply and Demand: 2010. Alaska National Interest Lands

Conservation Act Section 706(a) Report to Congress. USDA Forest Service, Alaska Region. 

Draft. October 12.

USDA Forest Service. 2011b. Forest Service Watershed Condition Framework. FS-977. Washington, DC: 

U.S. Department of Agriculture, Forest Service, Watershed, Fish, Wildlife, Air, and Rare Plants

Program.
References 6

Final EIS 6-25 References

USDA Forest Service. 2011c. Forest Service Watershed Condition Classification Technical Guide. FS978. Washington, DC: U.S. Department of Agriculture, Forest Service, Watershed, Fish, Wildlife, 

Air, and Rare Plants Program.

USDA Forest Service. 2009a. Forest Service Alaska Region Sensitive Species List, Assessment and 

Proposed Revisions to the 2002 List. Prepared by Michael I. Goldstein, Donald Martin, and Mary 

C. Stensvold. Tongass National Forest, Alaska. Available online at: 

https://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fsbdev2_037658.pdf

USDA Forest Service. 2009b. Petersburg Outfitter and Guide Management Plan Environmental 

Assessment. Tongass National Forest. R10-MB-706. December. Available online at: 

https://www.fs.usda.gov/project/?project=26239

USDA Forest Service. 2009c. Wrangell Outfitter and Guide Management Plan Environmental 

Assessment. Tongass National Forest. R10-MB-700. June. Available online at: 

https://www.fs.usda.gov/project/?project=24426

USDA Forest Service. 2008a. Land and Resource Management Plan, Tongass National Forest. R10-MB603b. January.

USDA Forest Service. 2008b. Tongass Land and Resource Management Plan, Final Environmental 

Impact Statement and Record of Decision. R10-MB-603a, c, d, e. January. 

USDA Forest Service. 2007. Tongass National Forest, 2006 Annual Monitoring and Evaluation Report. 

USDA Forest Service, Tongass National Forest. R10-MB-609.

USDA Forest Service. 2006. Invasive Species Strategy 2006-2010. Alaska Region. Juneau, AK.

USDA Forest Service. 2005. Alaska Region Invasive Plant Strategy. Alaska Region. Juneau, AK. 

USDA Forest Service. 2004. Tongass National Forest: 2004 Annual Monitoring and Evaluation Report: 

Fish Habitat and Soil and Water. Available online at: 

http://www.fs.fed.us/r10/tongass/projects/tlmp/monitoring/monitoring.shtml 

USDA Forest Service. 2003a. Final Supplemental Environmental Impact Statement - Roadless Area

Evaluation for Wilderness Recommendations. Volumes 1 through 4. R10-MB-481a, b, c, d. 

Ketchikan, Alaska.

USDA Forest Service. 2003b. Final Supplemental Environmental Impact Statement - Roadless Area

Evaluation for Wilderness Recommendations. Record of Decision. R10-MB-481g. Ketchikan, 

Alaska.

USDA Forest Service. 2001. USDA Forest Service Handbook, FSH 2090.21 – Aquatic Habitat 

Management Handbook. USDA Forest Service, Alaska Region, Juneau, Alaska. Amendment No. 

2090.21-2001-1. November. 

USDA Forest Service. 2000. Forest Service Roadless Area Conservation Rule Final Environmental 

Impact Statement. USDA Forest Service, Washington Office. November. Available online at: 

http://roadless.fs.fed.us/documents/feis/

USDA Forest Service. 1997a. Tongass National Forest Land and Resource Management Plan. R10-MB338dd. USDA Forest Service, Alaska Region. 1997. 

USDA Forest Service. 1997b. Tongass National Forest Land Management Plan Revision Final 

Environmental Impact Statement and Record of Decision. R10-MB-338a, b, c, e, f, g, h. USDA 

Forest Service, Alaska Region. January 1997.

USDA Forest Service. 1995. Report to Congress, Anadromous Fish Habitat Assessment. Pacific 

Northwest Research Station and Region 10. R10-MB-279. 
References 6

Final EIS 6-26 References

USDA Forest Service. 1991. Title 2600 - Wildlife, Fish, and Sensitive Plant Habitat Management. Forest 

Service Manual 2600. 

USDA Forest Service. 1990. Silvics of North America. Volume 1, Conifers. Agricultural Handbook 654. 

USDA Forest Service. 1983. Silvicultural Systems for the Major Forest Types of the United States. 

Agriculture Handbook 445. 

USDA Forest Service and ADNR. 2014. Forest Health Conditions in Alaska – 2013: FHP Protection 

Report R10-PR-035. Edited by E. Graham and T. Huette. R10-PR-035. February 2014. Available 

online at: http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprd3797075.pdf 

USFWS (U.S. Fish and Wildlife Service). 2015. Species Status Assessment for the Alexander 

Archipelago Wolf (Canis lupus ligoni). Version 1.0, December 2015. Alaska Region, Anchorage, 

Alaska. 162 pp.

USFWS. 2014. 5-Year Review: Summary and Evaluation of the Short-tailed Albatross. Anchorage Fish

and Wildlife Field Office Anchorage, Alaska. 43p.

USFWS. 2012a. The short-tailed albatross. Available online at: 

http://alaska.fws.gov/fisheries/endangered/listing.htm

USFWS. 2012b. The spectacled eider. Available online at: 

http://alaska.fws.gov/fisheries/endangered/listing.htm

USFWS. 2012c. The Steller’s eider. Available online at: 

http://alaska.fws.gov/fisheries/endangered/listing.htm

USFWS. 2012d. Aleutian tern counts from seabird colonies and nearshore marine bird surveys in the 

Kodiak Archipelago, Alaska 1975-2012. Unpublished Refuge Report 01-12. Prepared by R.M. 

Corcoran. U.S. Fish and Wildlife Service, Kodiak National Wildlife Refuge, Kodiak, AK. 

USFWS. 2010. Species assessment and listing priority assignment form: Falcipennis canadensis isleibi

Prince of Wales spruce grouse. U.S. Fish and Wildlife Service, Region 7.

USFWS. 2007. Queen Charlotte Goshawk Status Review. Alaska Region, Juneau Field Office.

Vercessi, L. 2015. Alaska Salmon Fisheries Enhancement Program 2014 Annual Report. Alaska 

Department of Fish and Game, Fisheries Management Report 15-15, Anchorage, AK.

Verschuyl, J., S. Riffell, D. Miller, and T.B. Wigley. 2011. Biodiversity Response to Intensive Biomass

Production From Forest Thinning in North American Forests – A Meta-analysis. Forest Ecology 

and Management 261:221-232.

Walton, K., T. Gotthardt, and T. Fields. 2013a. Little Brown Myotis. Alaska Species Ranking System 

Summary Report. Alaska Natural Heritage Program. University of Anchorage. Anchorage, AK. 

99501.

Walton, K., T. Gotthardt, and T. Fields. 2013b. Silver-haired bat. Alaska Species Ranking System 

Summary Report. Alaska Natural Heritage Program. University of Anchorage. Anchorage, AK. 

99501.

Walton, K., T. Gotthardt, and T. Fields. 2013c. Keen’s myotis. Alaska Species Ranking System Summary 

Report. Alaska Natural Heritage Program. University of Anchorage. Anchorage, AK. 99501.

Walton, K., T. Gotthardt, and T. Fields. 2013d. California myotis. Alaska Species Ranking System 

Summary Report. Alaska Natural Heritage Program. University of Anchorage. Anchorage, AK. 

99501.
References 6

Final EIS 6-27 References

Walton, K., T. Gotthardt, and T. Fields. 2013e. Long-legged myotis. Alaska Species Ranking System 

Summary Report. Alaska Natural Heritage Program. University of Anchorage. Anchorage, AK. 

99501.

Weckworth, B., S. Talbot, G. Sage, D. Person, and J. Cook. 2005. A Signal for Independent Coastal and 

Continental Histories for North American Wolves. Molecular Ecology 14:917–931.

Weckworth, B.V., S.L. Talbot, and J.A. Cook. 2010. Phylogeography of Wolves (Canis lupus) in the 

Pacific Northwest. Journal of Mammalogy 91:363–375.

Weckworth, B.V., N.G. Dawson, S.L. Talbot, M.J. Flamme, and J.A. Cook. 2011. Going Coastal: Shared 

Evolutionary History between Coastal British Columbia and Southeast Alaska Wolves (Canis 

lupus). PLoS ONE 6(5):1–8.

Wemple, B.C., and J. A. Jones. 2003. Runoff Production on Forest Roads in a Steep, Mountain 

Catchment. Water Resources Research 39(8):1220. doi: 10.1029/2002WR001744

White, E., and D. Stynes. 2010. Characterization of Resident and Non-resident Visitors to Alaska National 

Forests. Joint Venture Agreement between the USDA Forest Service Pacific Northwest 

Research Station and Oregon State University. Joint Venture Agreement # 10-JV-11261955-

018. August.

Williamson, S. J., D. Keppie, R. Davison, D. Bureau, S. Carriere, D. Rabe, and M. Schroeder. 2008. 

Spruce Grouse Conservation Plan. Association of Fish and Wildlife Agencies. Washington, D.C. 

73 pp.

Wolfe, R. J. 2004. Local Traditions and Subsistence: A Synopsis from Twenty-Five Years of Research by 

the State of Alaska. Technical Paper No. 284. Alaska Department of Fish and Game, Division of 

Subsistence, Juneau, Alaska. July. Available online at: http://www.subsistence.adfg.state.ak.us/

Wolfe, R. J., and R. J. Walker. 1987. Subsistence Economies in Alaska: Productivity, Geography, and 

Development Impacts. Arctic Anthropology 24(2):56-81. Available online at: 

https://www.jstor.org/stable/40316144

Wolf Technical Committee. 2017. Interagency Wolf Habitat Management Program: Recommendations for 

Game Management Unit 2. Management Bulletin R10-MB-822. USDA Forest Service, USDI Fish

and Wildlife Service, and Alaska Department of Fish and Game.

Wolken, J. M., T. N. Hollingsworth, T. S. Rupp, F. S. Chapin, S. F. Trainor, T. M. Barrett, P. F. Sullivan, A. 

D. McGuire, E. S. Euskirchen, P. E. Hennon, E. A. Beever, J. S. Conn, L. K. Crone, D. V. 

D’Amore, N. Fresco, T. A. Hanley, K. Kielland, J. J. Kruse, T. Patterson, E. A. Schuur, D. L. 

Verbyla, and J. Yarie. 2011. Evidence and Implications of Recent and Projected Climate Change 

in Alaska’s Forest Ecosystem. Ecosphere 2(11):Article 124. November.

Zaborske, R. R., M. H. McClellan, and T. A. Handley. 2002. Understory Vegetation Development 

Following Commercial Thinning in Southeast Alaska: Preliminary Results from the Second-growth 

Management Area Demonstration Project. In Beyond 2001: a silvicultural odyssey to sustaining 

terrestrial and aquatic ecosystems – proceedings of the national Silviculture workshop, May 6-10, 

Hood River OR, compiled by S. Parker and S. Stevens Hummel, 74–82. General Technical 

Report PNW-GTR-546. Portland, OR: USDA Forest Service, Pacific Northwest Research Station.

Zaborske, R. R., M. H. McClellan, J. Barbour, T. L. Laufenberg, and C. G. Shaw III. 2000. The Southeast 

Alaska Timber Resource and Industry: What Might the Future Hold? In Proceedings: Linking 

Healthy Forests and Communities Through Alaska Value-Added Forest Products, edited by T. L. 

Laufenberg and B. K. Brady, 23–26. General Technical Report PNW-GTR-500. Portland, OR: 

USDA Forest Service, Pacific Northwest Research Station. 

Zegre, S. J., M. D. Needham, L. E. Kruger, and R. S. Rosenberger. 2012. McDonaldization and 

Commercial Outdoor Recreation and Tourism in Alaska. Managing Leisure 17:333-348. Available 

online at: https://www.fs.usda.gov/treesearch/pubs/45837
References 6

Final EIS 6-28 References

This page is intentionally left blank.
CHAPTER 7

GLOSSARY
Glossary 7

Final EIS 7-1 Glossary

Chapter 7

Glossary

These definitions apply to Forest Service land management and planning. Meanings may differ when 

used in another context. Glossary definitions are not legal unless otherwise noted. Some definitions were 

shortened, paraphrased, or adapted to conditions in Southeast Alaska or on the Tongass National Forest 

and for ease of understanding. 

A

Adjacent 

Objects or parcels of land that are not widely separated, though perhaps they are not actually touching.

Alaska National Interest Lands Conservation Act (ANILCA)

Act of December 2, 1980. Public Law 96 487, 96th Congress, 94 Stat. 2371-2551.

Alaska Native corporation

One of the regional, urban, and village native corporations formed under the Alaska Native Claims 

Settlement Act of 1971.

Alaska Roadless Areas (ARA) (as proposed for Alaska Roadless Rule)

Areas identified in the set of ARA maps which the Alaska Roadless Rule applies to. These represent new 

roadless designations and are tied to new roadless rule language.

Alaska Roadless Categories (as proposed for Alaska Roadless Rule)

Areas identified with varying degrees of exceptions and prohibitions, designed based on land 

management priority.

Alpine

Parts of mountains above tree growth.

Alternative

An option proposed for decision making.

Anadromous fish

Fish that mature and spend much of their adult life in the ocean, returning to inland waters to spawn. 

Salmon and steelhead are examples.

Annual demand

As used in this document, the amount of timber that buyers are willing to purchase each year. Estimates 

of annual timber demand are based on a number of factors, including Pacific Northwest projections, 

installed mill capacity, utilization rates and market trends.

Aquaculture

Culture or husbandry of salmon or other aquatic fauna or flora.
Glossary 7

Final EIS 7-2 Glossary

Aquatic ecosystem

A stream channel, lake or estuary bed, the water itself, and the biotic communities that occur therein.

B

Background

The visible area greater than 5 miles and less than 15 miles from a visual priority route. (See the 

definitions for foreground and middleground.)

Bank

The continuous margin along a river or stream where all upland vegetation ceases.

Beach fringe

The area inland from salt water shorelines that is typically forested.

Benthic

Pertaining to the sea bottom or organisms that live on the sea bottom.

Best Management Practices (BMPs) 

Methods, measures, or practices selected by an agency to meet its nonpoint source control needs. BMPs 

include but are not limited to structural and nonstructural controls and operation and maintenance 

procedures. BMPs can be applied before, during, and after pollution-producing activities to reduce or 

eliminate the introduction of pollutants into receiving waters (36 CFR 219.19). BMPs are selected on the 

basis of site-specific conditions that reflect natural background conditions and political, social, economic, 

and technical feasibility. BMPs are found in the National Core BMP Technical Guide, FS-990a (USDA 

Forest Service 2012) and Forest Service Handbook 2509.22, Alaska Region Amendment.

Biogeographic provinces

Twenty-one ecological subdivisions of Southeast Alaska that are identified by generally similar 

physiogeography, climate, vegetation patterns and physical barriers such as mountains or saltwater 

(distinct ecological and biogeographic features). Plant and animal species composition, climate, and 

geology within each province are generally more similar within than among adjacent provinces. Historical 

events (such as glaciers, wind, and tectonic uplifting) are important to the nature of the province and to 

the barriers that distinguish each province (Martin and Alaback 1990).

Biological assessment

A "biological evaluation" conducted for major federal construction projects requiring an environmental 

impact statement, in accordance with legal requirements under section 7 of the Endangered Species Act 

of 1973, as amended (16 U.S.C. 1536(c)). The purpose of the assessment and resulting document is to 

determine whether the proposed action is likely to affect an endangered, threatened, or proposed 

species. (FSM 2600, Ch. 2670)

Biological diversity

The variety of life forms and processes, including the complexity of species, communities, gene pools, 

and ecological functions, within the area covered by a land management plan.

The variety and abundance of life forms, processes, functions, and structures of plants, animals and other 

living organisms, including the relative complexity of species, communities, gene pools and ecosystems 

at the spatial scales that range from local through regional to global. 2. An index of richness in a 

community, ecosystem or landscape and the relative abundance of these species – Note: 1. There are 

commonly five levels of biodiversity: (a) genetic diversity, referring to the genetic variation within a 
Glossary 7

Final EIS 7-3 Glossary

species; (b) species diversity, referring to the variety of species in an area; (c) community or ecosystem 

diversity, referring to the variety of communities or ecosystems in and area; and (d) regional diversity, 

referring to the variety of species, communities, ecosystems or landscapes within a specific geographic 

region – Note: each level of biodiversity has three components: (a) compositional diversity or the number 

of parts or elements within a system, indicated by such measures as the number of species, genes, 

communities or ecosystems; (b) structural diversity or the variety of patterns or organizations within a 

system, such as habitat structure, population structure, or species morphology; and (c) functional diversity 

or the number of ecological processes within a system such as disturbance regimes, roles played by 

species within a community, and nutrient cycling within a forest (Helm 1998).

Biological evaluation

A documented Forest Service review of Forest Service programs or activities in sufficient detail to 

determine how an action or proposed action may affect any threatened, endangered, proposed, or 

sensitive species. (FSM 2600, Ch. 2670)

Biomass

Organic matter available on a renewable basis; includes forest and mill residues, agricultural crops and 

wastes, wood and wood residues, animal wastes, livestock operation residues, aquatic plants, fastgrowing trees and plants, and municipal waste and industrial residues; can be used to produce liquid

transportation fuels, chemicals and other bioproducts, electric power, steam, and heat. Also refers to the 

total mass of living organisms in a given area or volume; recently dead plant material is often included as 

dead biomass.

Blowdown

See windthrow.

Board foot

A unit of timber measurement equaling the amount of wood contained in an unfinished board 1 inch thick, 

12 inches long, and 12 inches wide.

Buffer 

An area of vegetation of varying size, shape, and character managed to mitigate effects on a particular 

resource. 

C

Catastrophic event

Events resulting from a great and sudden calamity or disaster. In the case of forest stands, such events 

may include windstorms, wildfire, floods, snow slides, and insect outbreaks. Whether a disturbance event 

is called catastrophic is dependent on the context within which the event occurs, the scale of the event, 

and the effects of the event.

Capability

The potential of an area of land to produce resources, supply goods, and services, and allow resource 

uses under an assumed set of management practices and at a given level of management intensity.

Carrying capacity

The estimated maximum number (or biomass) of organisms of a given species that can be sustained or 

survive on a long-term basis within an ecosystem.
Glossary 7

Final EIS 7-4 Glossary

Cave

Cave is legally defined under federal law as “any naturally occurring void, cavity, recess, or system of 

interconnected passages which occurs beneath the surface of the earth or within a cliff or ledge and 

which is large enough to permit an individual to enter, whether or not the entrance is naturally formed or 

human-made. Such term shall include any natural pit, sinkhole or other feature which is an extension of 

the surface,” (Federal Cave Resource Protection Act of 1988). Speleologists use “cave” to refer to all 

parts, regardless of size, of an underground system that links openings and chambers and that may 

connect the system to the surface. Included in the term caves are tree molds and lava tubes associated 

with lava flows, erosional caves, and those formed by dissolution of bedrock.

Census designated place (CDP)

A concentration of population identified by the United States Census Bureau for statistical purposes. 

CDPs are delineated for each decennial census as the statistical counterparts of incorporated places, 

such as cities, towns, and villages. 

Channel

A natural waterway of perceptible extent that periodically or continuously contains moving water. It has a 

definite bed and banks that serve to confine the water.

The bed where a natural body of surface water flows or may flow; a natural passageway or depression of 

perceptible extent containing continuously or periodically flowing water, or forming a connecting link 

between two bodies of water, a water course (Haskins et al. 1998).

Clearcutting

An even-aged regeneration method in which essentially all trees have been removed in one operation to 

create an even-aged stand that is composed of a single age class in which tree ages are usually +/- 20 

percent of rotation. The area harvested may be a patch, stand, or strip large enough to be mapped or 

recorded as a separate age class in planning.

Code of Federal Regulations (CFR)

The codification of the general and permanent rules published in the Federal Register by the departments 

and agencies of the Federal Government. It is divided into 50 titles that represent broad areas subject to 

Federal regulation. The 50 subject matter titles contain one or more individual volumes, which are 

updated once each calendar year, on a staggered basis. Each title is divided into chapters, which usually 

bear the name of the issuing agency. Each chapter is further subdivided into parts that cover specific 

regulatory areas. Large parts may be subdivided into subparts. All parts are organized in sections, and 

most citations to the CFR refer to material at the section level.

Commercial forest land 

Forest land that is producing or is capable of producing crops of industrial wood and (a) has not been 

withdrawn by Congress, the Secretary, or the Chief; (b) existing technology and knowledge is available to 

ensure timber production without irreversible damage to soils productivity, or watershed conditions; and 

(c) existing technology and knowledge, as reflected in current research and experience, provides 

reasonable assurance that adequate restocking can be attained within 5 years after final harvesting.

Commercial timber

Trees, portions of trees, and other forest products on National Forest System lands may be sold for the 

purpose of achieving the policies set forth in the Multiple-Use Sustained-Yield Act of 1960, as amended 

(74 Stat. 215; 16 U.S.C. 528-531), the Forest and Rangeland Renewable Resources Planning Act of 

1974, as amended (88 Stat. 476; as amended, 16 U.S.C. 1600-161), and the Program thereunder. (See 

36 CFR 223.1 Authority to sell timber.)
Glossary 7

Final EIS 7-5 Glossary

Connectivity (landscape)

A measure of the extent that forest areas between or outside Old-growth habitat reserves and other Nondevelopment LUDs provide habitat for breeding, feeding, dispersal, and movement.

Connectivity (ecosystem)

Ecological conditions that exist at several spatial and temporal scales that provide landscape linkages 

that permit the exchange of flow, sediments and nutrients; the daily and seasonal movements of animals 

within home ranges; the dispersal and genetic interchange between populations; and the long distance 

range shifts of species, such as in response to climate change (FSM 1909.12, Ch. 10; 36 CFR 219.19).

Convey 

To pass or transmit the title to property from one to another.

Conveyance 

An instrument by which some estate or interest in lands is transferred from one person to another (Black 

1979); a transfer of legal title to land.

Corridor (transportation)

A linear strip of land defined for the present or future location of transportation rights-of-way within its 

boundaries. 

Corridor (wildlife)

Habitats, often linear, that facilitate dispersal and movement of wildlife between patches of suitable 

habitat. (Also see the definition for connectivity.)

Created opening

Openings in the forest canopy created by silvicultural practices, including shelterwood regeneration 

cutting, clearcutting, seed tree cutting, or group selection cutting.

Critical habitat

For a threatened or endangered species, (1) the specific areas within the geographical area occupied by 

the species, at the time it is listed in accordance with the provision of section 4 of the Endangered 

Species Act (ESA) (16 USC 1533), on which are found those physical or biological features (a) essential 

to the conservation of the species, and (b) which may require special management considerations or 

protections; and (2) specific areas outside the geographical area occupied by the species at the time it is 

listed in accordance with the provisions of section 4 of the ESA (16 USC 1533), upon a determination by 

the Secretary that such areas are essential for the conservation of the species. ESA, sec. 3 (5) (A), (16 

USC 1532 (3) (5) (A). Critical habitat is designated through rulemaking by the Secretary of Interior or 

Commerce. ESA, sec. 4 (a) (3) and (b) (2) (16 USC 1533 (a)(3) and (b)(2)).

Cultural resource

“An object or definite location of human activity, occupation, or use identifiable through field survey, 

historical documentation, or oral evidence. Cultural resources are prehistoric, historic, archeological, or 

architectural sites, structures, places, or objects and traditional cultural properties....cultural resources 

include the entire spectrum of resources for which the Heritage Program is responsible from artifacts to 

cultural landscapes without regard to eligibility for listing on the National Register of Historic Places” (FSM 

2360.5).
Glossary 7

Final EIS 7-6 Glossary

D

Demand

The quantity of a commodity or service that buyers are willing to purchase at a given price over a specific 

time period.

Demographic

Pertaining to the study of the characteristics of populations, such as size, growth, density, distribution, 

and vital statistics.

Detrimental soil disturbance 

The condition where established threshold values of soil properties are exceeded and result in significant 

change or impairment to long-term soil productivity. 

Developed recreation

The type of recreation that occurs where modifications (improvements) enhance recreation opportunities 

and accommodate intensive recreation activities in a defined area.

Developed Recreation Site

A discrete place containing a concentration of facilities, infrastructure, and services used to provide 

recreation opportunities to the public and evidencing a significant investment in facilities and management 

(FSH 2309.13- recreation site handbook) (such as campgrounds, picnic areas, and trailheads with 

recreation facilities.)

Development LUDs

Land use designations that permit commercial timber harvest and other commercial activities (Timber

Production, Modified Landscape, Scenic Viewshed, and Experimental Forest) and convert some of the 

old-growth forest to early-to mid-successional, regulated forests.

Distance zone

Areas of landscapes denoted by specified distances from the observer (foreground, middleground, or 

background). Used as a frame of reference in which to discuss landscape characteristics of management 

activities. (Also see the definitions for foreground, middleground, and background.)

Distinct population segment (DPS)

A DPS, or a distinct population segment, is a vertebrate population or group of populations that is discrete 

from other populations of the species and significant in relation to the entire species. The Endangered 

Species Act provides for listing species, subspecies, or distinct population segments of vertebrate 

species.

Disturbance

Any relatively discrete event in time that disrupts ecosystem, watershed, community, or species 

population structure and/or function and changes resources, substrate availability, or the physical 

environment (36 CFR 219.19).

E

Easement

An interest or right in land owned by another that entitles its holder to a specific limited use.
Glossary 7

Final EIS 7-7 Glossary

Ecological integrity 

The quality or condition of an ecosystem when its dominant ecological characteristics (for example, 

composition, structure, function, connectivity, and species composition and diversity) occur within the 

natural range of variation and can withstand and recover from most perturbations imposed by natural 

environmental dynamics or human influence (36 CFR 219.19).

Ecological sections

Ecosystems may be subdivided into ecological sections that consist of ecological subsections. There are 

14 ecological sections on the Tongass National Forest.

One mapping level of the National Hierarchical Framework of Ecological Units which delimits areas of 

different biological and physical potentials at varying geographical scales ranging from global to local. 

Ecological sections areas delimited at the sub regional scale and are characterized by combinations of 

climate, geomorphic processes, topography and stratigraphy that influence moisture availability and 

exposure to radiant solar energy, which in turn directly control hydrologic function, soil forming processes, 

and potential plant community distributions. Sections and subsections are the two ecological units 

mapped at this scale. Sections are broad areas of similar geomorphic process, stratigraphy, geologic 

origin, drainage networks, topography and regional climate. Such areas are often inferred by relating 

geologic maps to potential natural vegetation (series) groups as mapped by Kuchler (1964). The Tongass 

is divided into 14 ecological subsections, which are smaller areas of sections having similar surficial 

geology, lithology geomorphic processes; soil groups sub regional climate and potential natural 

communities (USDA 1993). 

Ecosystem

A spatially explicit, relatively homogenous area that includes all interacting organisms and the abiotic 

environment components. An ecosystem can be of various sizes (e.g., a log, a pond, a forest, or the 

earth’s biosphere).

Ecosystem services

Ecosystem services include the full suite of goods and services that are vital to human health and 

livelihood provided by ecosystems—in this case, ecosystems on the Tongass National Forest.

Edge effect 

The effect of adjoining vegetative communities on the population structure along the margin, which 

provides for greater numbers of species and higher population densities than either adjoining community. 

Edge may also result in negative effects, since habitat along the edge is different than within the patch, 

reducing the effective area of the habitat patch.

The modified environmental conditions or habitat along the margins (edges) of forest stands or patches 

(Helms 1998).

Effects

Environmental effects and impacts as used in the Council on Environmental Quality’s (CEQ) regulations 

(40 CFR parts 1508.7 and 1508.8) implementing the procedural provisions of the National Environmental 

Policy Act (NEPA) of 1969, as amended (42 U.S.C. parts 4321 et seq.) are synonymous and include: 

Direct effects, which are caused by the action and occur at the same time and place; 

Indirect effects, which are caused by the action and are later in time or farther removed in distance, but 

are still reasonably foreseeable; and

Cumulative impact, which is the impact on the environment which results from the incremental impact of 

the action when added to other past, present, and reasonably foreseeable future actions regardless of 
Glossary 7

Final EIS 7-8 Glossary

what agency (federal or non-federal) or person undertakes such other actions. Cumulative impacts can 

result from individually minor but collectively significant actions taking place over a period of time.

Effects may also include those resulting from actions which may have both beneficial and detrimental 

effects, even if on balance the agency believes that the effect will be beneficial.

Endangered species

Any species that the Secretary of the Interior or the Secretary of Commerce has determined is in danger 

of extinction throughout all or a significant portion of its range. Endangered species are listed at 50 CFR 

sections 17.11, 17.12, and 224.101 (FSM 1090.12).

Endemic

Living in or restricted to a particular locality. In this document the term endemic is used in two ways. First, 

it is used to describe plant and animal species, subspecies, or lineages that are native and restricted in 

their distribution to an island, a portion of Southeast Alaska, or Southeast Alaska. Second, it is used to 

describe a type of windthrow event that is a very localized windthrow event, where individual trees are 

blown over (see the definition for Windthrow in this Glossary).

Indigenous to (native) or characteristic of a particular restricted geographical area (Helms 1998).

Endemism

The ecological state of a species being unique to a defined geographic location, such as an island or 

other defined zone or habitat type; organisms that are indigenous to a place are not endemic to it if they 

are also found elsewhere.

Enhance

To improve, reinforce, enrich, or strengthen the existing condition, value, or beauty of a resource.

Environment

All the conditions, circumstances, and influences surrounding and affecting the development of an 

organism, or group of organisms.

Epikarst

The upper surface of karst, consisting of a network of intersecting fissures and cavities that collect and 

transport surface water and nutrients underground; epikarst depth can range from a few centimeters to 

tens of meters.

Erosion

The wearing away of the land surface by running water, wind, ice, gravity, or other geological activities.

Essential fish habitat (EFH)

Those waters and substrate necessary to fish for spawning, breeding, feeding, or growth to maturity for 

federally managed species as per 50 CFR 600, “Magnuson-Stevens Act Provisions.” For the purpose of 

interpreting the definition of essential fish habitat: “Waters” include aquatic areas and their associated 

physical, chemical, and biological properties that are used by fish and may include aquatic areas 

historically used by fish where appropriate; “substrate” includes sediment, hard bottom, structures 

underlying the waters, and associated biological communities, “necessary” means the habitat required to 

support a sustainable fishery and the managed species’ contribution to a healthy ecosystem; and 

“spawning, breeding, feeding growth to maturity” covers a species full life cycle.
Glossary 7

Final EIS 7-9 Glossary

Estuary 

An ecological system at the mouth of a stream where fresh water and salt water mix, and where salt

marshes and intertidal mudflats are present. The landward extent of an estuary is the limit of saltintolerant vegetation, and the seaward extent is a stream’s delta at mean low water.

Exceptions (as proposed for Alaska Roadless Rule)

Activities that would be allowed in different categories of ARAs.

F

Falldown

The difference between the number of acres planned for timber harvest and those actually harvested, 

usually experienced as a reduction in acres. Falldown results from many factors, including unmapped 

unsuitable timber land, newly available information, and project-level consideration of site-specific issues 

and non-timber resource needs. (Also see the definition for Management Implementation Reduction 

Factor.)

Federally recognized Indian tribe 

An Indian tribe, band, nation, or other organized group or community, including a native village, regional 

corporation or village corporation, as those terms are defined in Section 3 of the Alaska Native Claims

Settlement Act (43 U.S.C. 1602)(ANCSA), which is recognized as eligible for the special programs and 

services provided by the United States to Indians because of their status as Indians. 

Fiscal Year (FY)

October 1 to September 30. The Fiscal Year is referred to by the calendar year, which begins on January 

1. For example, October 1, 1996, to September 30, 1997, is referred to as Fiscal Year 1997.

Fish passage

The ability of both adult and juvenile fish to move both up and down stream.

Foreground

The visible area within 0.5 mile of a visual priority route. (See the definitions for background and 

middleground.)

Forest health

The perceived condition of a forest derived from concerns about such factors as its age, structure, 

composition, function, vigor, presence of unusual levels of insects or disease, and resilience to 

disturbance.

Forest Plan 

Source of management direction for an individual forest, specifying activity and output levels for a period 

of 10 to 15 years. Management direction in the Forest Plan is based on the issues identified at the time of 

the plan’s development. 

Forest transportation system

The system of National Forest System (NFS) roads, trails, and airfields on NFS lands (36 CFR 212.1). 
Glossary 7

Final EIS 7-10 Glossary

Fragmentation

The process by which a landscape is broken into smaller patches of forest within a mosaic of other forms 

of land use or ownership. 

G

Game Management Unit 

Geographical areas defined by the Alaska Department of Fish and Game to manage wildlife populations. 

Legal hunting and trapping regulations govern each unit. 

Group selection 

An uneven aged regeneration method in which trees are removed and new age classes are established 

in small groups where the widths of groups are commonly approximately twice the height of the mature 

trees. Note: the management unit or stand in which regeneration growth and yield are regulated consists 

of an aggregation of groups.

H

Habitat

A unit area of environment. 2. The place, natural or otherwise, (including climate, food, cover and water) 

where animal, plant, or populations naturally or normally lives and develops (Helms 1998).

Habitat capability

The estimated maximum number of fish or wildlife that can be supported by the amount and distribution of 

suitable habitat in an area.

Haul out

Areas used by marine mammals for resting and other social/biological activities that occur in the intertidal 

zone.

Historic property

“Any prehistoric or historic district, site, building, structure, or object included in, or eligible for inclusion in, 

the National Register of Historic Places maintained by the Secretary of the Interior. This term includes 

artifacts, records, and remains that are related to and located within such properties. The term includes 

properties of traditional religious and cultural importance to an Indian tribe or Native Hawaiian 

organization and that meet the National Register criteria” [36 CFR 800.16(l)(1)].

I

Industrial wood

All commercial roundwood products, except fuelwood.

Infrastructure

The facilities, utilities, and transportation systems needed to meet public and administrative needs.
Glossary 7

Final EIS 7-11 Glossary

Inherent capability

The ecological capacity or ecological potential of an area characterized by the interrelationship of its 

physical elements, its climatic regime, and natural disturbances (36 CFR 219.19).

Interdisciplinary Team (IDT) 

A group of individuals with different training assembled to solve a problem or perform a task. The team is 

assembled out of recognition that no one scientific discipline is sufficiently broad to adequately solve the 

problem. Through interaction, participants bring different points of view and a broader range of expertise 

to bear on the problem.

Interior old-growth forest

The region of a forested stand that has a stable microclimate relative to light, wind, humidity, moisture 

regime, etc. Natural forest ecotones “seal” a forest’s edge and stabilize these microclimate features. 

Ecotones created by management such as the old growth, clearcut edge may have “edge” effects that 

extend into a forest for several hundred feet (estimated 2 to 3 tree heights) before stable “interior forest” 

conditions are achieved and microclimatic effects of the edge are no longer evident.

Invasive species

An alien species whose introduction does or is likely to cause economic or environmental harm or harm to 

human health. A species that causes, or is likely to cause, harm and that is exotic to the ecosystem it has 

infested. Invasive species infest both aquatic and terrestrial areas and can be identified within any of the 

following four taxonomic categories: Plants, Vertebrates, Invertebrates, and Pathogens (Executive Order 

13112).

Inventoried roadless area (IRA)

Areas identified in a set of inventoried roadless area maps, contained in Forest Service Roadless Area

Conservation, Final Environmental Impact Statement, Volume 2, dated November 2000, which are held at 

the National headquarters office of the Forest Service, or any subsequent update or revision of those 

maps. (36 CFR 294.11).

Invertebrates

Animals without backbones. Land invertebrates include insects, snails, and slugs; freshwater 

invertebrates include aquatic insects; and marine invertebrates include crab, shrimp, and clams. 

Irretrievable commitments

A term that applies to the loss of production, harvest, or use of natural resources. For example, some or 

all of the timber production from an area is lost irretrievably while an area is serving as a winter sports 

site. The production lost is irretrievable, but the action is not irreversible. If the use changes, it is possible 

to resume timber production.

Irreversible commitments

A term that describes the loss of future options. Applies primarily to the effects of use of nonrenewable 

resources, such as minerals or cultural resources, or to those factors, such as soil productivity, that are 

renewable only over long periods of time.

Issue

A point, matter, or section of public discussion or interest to be addressed or decided.
Glossary 7

Final EIS 7-12 Glossary

J

K

Karst

A type of topography that develops in areas underlain by soluble rocks, primarily limestone. Dissolution of 

the subsurface strata results in areas of well-developed, surface drainage that are sinkholes, collapsed 

channels, or caves.

L

Land allocation

The decision to use land for various resource management objectives to best satisfy the issues, 

concerns, and opportunities, and meet assigned forest output targets.

Land exchange

A land adjustment transaction whereby the United States trades federal land, interests in land, and/or 

timber for not less than equal value of non-Federal land and/or interests in land needed for National 

Forest purposes, or programs. Some exchanges provide for cash equalization to equalize values.

Land Use Designation (LUD)

Defined areas of the Forest that are allocated for different uses or activities and have the same set of 

applicable plan components, but do not have to be spatially contiguous. (36 CFR 219.19)

Land Use Designation (LUD) II

Statutory land use designations managed in a roadless state to retain their wildland character as defined 

in the TTRA (Pub. L. 101-626, Title II, Section 201) and the National Defense Authorization Act for Fiscal 

Year 2015 (Pub. L. 113-291, 128 Stat. 3729, Section 3720(f)).

Landscape

A defined area irrespective of ownership or other artificial boundaries, such as a spatial mosaic of 

terrestrial and aquatic ecosystems, landforms, and plant communities, repeated in similar form throughout 

such a defined area (36 CFR 219.19).

Landslides

The moderately rapid to rapid downslope movement of soil and rock materials that may or may not be 

water-saturated.

Large woody debris (LWD)

Any piece of relatively stable woody material, having a diameter of 4 inches or greater and a length 

greater than 3 feet, that intrudes into a stream channel. Formerly called large organic debris. 

A term used to describe logs, tree boles, rootwads, and limbs that are in, on or near the stream channel, 

having a diameter of 4 inches or greater and a length equal to or greater than 3 feet, that intrudes into a 

stream channel.

Leasable minerals

Generally includes minerals such as coal, oil, gas, phosphate, sodium, potassium, oil shale, sulfur, and 

geothermal steam.
Glossary 7

Final EIS 7-13 Glossary

Lease

A type of special use authorization (usually granted for uses other than linear rights-of-way) that is used 

when substantial capital investment is required and when conveyance of a conditional and transferable 

interest in National Forest System lands is necessary or desirable to serve or facilitate authorized longterm uses, and that may be revocable and compensable according to its terms.

Legacy trees

A tree, usually mature or old growth that is retained on a site after harvesting or natural disturbance to 

provide a biological legacy.

Locatable minerals

Include, but not limited to, minerals such as gold, silver, lead, zinc, copper, and mercury.

Log transfer facilities (LTF) 

Log transfer facilities include the site and structures used for moving logs and timber products from landbased transportation forms to water-based transportation forms (or vice versa).

M

Managed stand

A forested stand whose natural structure has been purposely altered through some regeneration or 

stocking control treatment.

Management Indicator Species 

Plant or animal species, communities, or special habitats selected for emphasis in planning, and which 

are monitored during forest plan implementation to assess the effects of management activities on their 

populations and the populations of other species with similar habitat needs that they may represent.

Management practices

The activities applied to a defined area of land (land use designation as defined in the Forest Plan) to 

attain multiple-use and other goals and objectives.

Management prescription

Management practices and intensity selected and scheduled for application on a specific area (e.g., a 

land use designation) to attain multiple-use and other goals and objectives.

Mariculture

The cultivation of plants and animals in saltwater, with no freshwater component. Mariculture does not 

include anadromous fish farming.

Marine access point 

An area that is used by humans to transfer items to saltwater generally where there is a trail that leads to 

saltwater and that has no associated structures.

Matrix

A term used in the Old-growth habitat conservation strategy that refers to the lands with LUD allocations 

where commercial timber harvest may occur. 
Glossary 7

Final EIS 7-14 Glossary

Mean annual increment (MAI) 

The total increment of a tree or stand, up to a given age in years, divided by that age.

Memorandum of Understanding (MOU)

An agreement between the Forest Service and other agencies resulting from consultation between 

agencies that states specific measures the agencies will follow to accomplish a large or complex project. 

A memorandum of understanding is not a fund obligating document.

Microsale

A microsale is a timber sale proposed by a prospective purchaser consisting of dead or down timber of 

approximately 50 thousand board feet (MBF) or less and the District Ranger agrees to offer for bidding.

Middleground

The visible area between foreground and background of a visual priority route. (See the definitions for 

foreground and background.)

Million board feet (MMBF)

A measurement of the number of millions of board feet of timber. The letter "M" is borrowed from Roman 

numerals, but instead of "MM" representing the value 2,000, the industry treats them as variables in 

algebra and interprets them based on the rules of mathematics (where two adjacent variables are 

multiplied), thus the product is 1 million (1,000 times 1,000) board feet of timber.

Mineral development

The activities and facilities associated with extracting mineral deposits.

Mineral entry

Filing a mining claim on public land to obtain the right to mine any minerals it may contain. Also the filing 

for a mill site on federal land for the purpose of processing off-site minerals.

Mineral exploration

The search for valuable minerals on lands open to mineral entry.

Mineral lease

A lease that authorizes the development and production of leasable minerals from public lands.

Mining claims

A geographic area of the public lands held under the general mining laws in which the right of exclusive 

possession is vested in the locator of a valuable mineral deposit. 

Mitigate

To avoid, minimize, rectify, reduce, or compensate the adverse environmental impacts associated with an 

action.

Mixed conifer

In Southeast Alaska, mixed conifer stands usually consist of the following species: western hemlock, 

mountain hemlock, and yellow-cedar, redcedar, and Sitka spruce. Shorepine may occasionally be present 

depending on individual sites. Redcedar is not usually in mixed conifer stands on the central and northern 

portions of the Tongass. Mixed conifer sites indicate poor drainage and/or shallow soils.
Glossary 7

Final EIS 7-15 Glossary

Model

An idealized representation of reality developed to describe, analyze, or understand it; a mathematical 

representation of the relationships under study (e.g., Woodstock, wildlife habitat capability models).

Model Implementation Reduction Factor (MIRF)

An adjustment made to the timber outputs of the computer model to account for anticipated effects on 

timber availability that cannot be accounted for in the computer model. (Also see the definition for 

falldown.)

Monitoring

A systematic process of collecting information to evaluate effects of actions or changes in conditions or 

relationships (36 CFR 219.19).

Multiple use

The management of all the various renewable surface resources of the National Forest System so that 

they are used in the combination that will best meet the needs of the American people; making the most 

judicious use of the land for some or all of these resources or related services over areas large enough to 

provide sufficient latitude for periodic adjustments in use to conform to changing needs and conditions; 

that some land will be used for less than all of the resources; and harmonious and coordinated 

management of the various resources, each with the other, without impairment of the productivity of the 

land, with consideration being given to the relative values of the various resources, and not necessarily 

the combination of uses that will give the greatest dollar return or the greatest unit output, consistent with 

the Multiple-Use Sustained-Yield Act of 1960 (16 U.S.C. 528–531) (36 CFR 219.19).

Municipal Watershed

A watershed, designated on the Forest Plan Land Use Designation Map, which provides municipal water

supplies. On the Tongass these include the municipal watersheds for Ketchikan, Petersburg, Sitka, 

Juneau, Wrangell, Kake, Klawock, Craig, and Hydaburg. Compare to public water supply definition.

Muskeg

Algonquin term for peatland. Usually applied to areas with sphagnum mosses, tussocky sedges, and an 

open growth of scrubby trees. 

N

National Environmental Policy Act of 1969 (NEPA)

An act declaring a national policy to encourage productive and enjoyable harmony between man and his 

environment, to promote efforts which will prevent or eliminate damage to the environment and the 

biosphere and stimulate the health and welfare of man, to enrich the understanding of the ecological 

systems and natural resources important to the Nation and to establish a Council on Environmental 

Quality. 

National Forest Management Act (NFMA) 

A law passed in 1976 that amends the Forest and Rangeland Renewable Resources Planning Act and 

requires the preparation of Forest Plans. 

National Forest System (NFS) land

Federal lands that have been designated by Executive Order or statute as National Forests, National 

Grasslands, or Purchase Units, or other lands under the administration of the Forest Service.
Glossary 7

Final EIS 7-16 Glossary

National Forest System (NFS) road 

A forest road other than a road which has been authorized by a legally documented right-of-way held by a 

state, county, or local public road authority (36 CFR 212.1). The term “National Forest System road” is 

synonymous with the term “forest development road” as used in 23 U.S.C. 205. 

National Historic Preservation Act

The National Historic Preservation Act (NHPA), 54 U.S.C. § 300101 et seq., is the primary federal law 

governing the preservation of cultural and historic resources in the United States.

National Marine Fisheries Service

An office of the National Oceanic and Atmospheric Administration that is responsible for the stewardship 

of the nation's ocean resources and their habitat with authorities under the Marine Mammal Protection Act 

and the Endangered Species Act.

National Wild and Scenic River System

Rivers with outstanding scenic, recreational, geological, fish and wildlife, historic, cultural, or other similar 

values designated by Congress under the Wild and Scenic Rivers Act for preservation of their free-flowing 

condition.

Net sawlog volume 

Trees suitable in size and quality for producing logs that can be processed into lumber. 

No-Action Alternative

The most likely condition expected to exist in the future if current management direction were to continue 

unchanged. There are two distinct interpretations of "no action" depending on the nature of the proposal 

being evaluated. The first situation might involve an action such as updating a land management plan 

where ongoing programs initiated under existing legislation and regulations will continue, even as new 

plans are developed. In these cases "no action" is "no change" from current management direction or 

level of management intensity. To construct an alternative that is based on no management at all would 

be a useless academic exercise. Therefore, the "no action" alternative may be thought of in terms of 

continuing with the present course of action until that action is changed.

The second interpretation of "no action" is illustrated in instances involving federal decisions on proposals 

for projects. "No action" in such cases would mean the proposed activity would not take place, and the 

resulting environmental effects from taking no action would be compared with the effects of permitting the 

proposed activity or an alternative activity to go forward.

Non-development LUDs

Land use designations that do not permit commercial timber harvest. 

Wilderness and Natural Setting LUDs make up the non-development LUDs. These LUDs are: 

• Wilderness

• Wilderness National Monument

• Non-wilderness National Monument

• LUD II

• Remote Recreation

• Semi-Remote Recreation

• Municipal Watershed

• Old-Growth Habitat (except young-growth as 

allowed by Chapter 5 plan content)

• Research Natural Area

• Special Interest Area

• Wild River

• Scenic River

• Recreational River
Glossary 7

Final EIS 7-17 Glossary

Non-System road (Unauthorized Road)

A road or trail that is not a Forest road or trail or a temporary road or trail and that is not included in a 

Forest transportation atlas (36 CFR 212.1).

O

Old-growth forest

The (usually) late successional stage of forest development. Old-growth forests are defined in many 

ways; generally, structural characteristics used to describe old-growth forests include a) live trees: 

number and minimum size of both seral and climax dominants; b) canopy conditions: commonly including 

multi-layering; c) snags: minimum number and specific size; and d) logs and large (coarse) woody debris.

Old-growth habitat conservation strategy

An integrated science-based old-growth forest habitat conservation strategy developed and adopted 

during the 1997 Forest Plan Revision process. The old-growth strategy has two basic components: 1) a 

forest-wide reserve network that protects the integrity of the old-growth forest by retaining blocks of intact, 

largely undisturbed habitat; and 2) management of the matrix (that is, lands that are suitable for timber 

harvest). (See Appendix D of the 2016 Forest Plan Amendment EIS)

Old-growth reserve (OGR)

A contiguous unit of old-growth forest habitat to be managed to maintain the integrity of the old-growth 

forest ecosystem.

Overstory

The portion of trees in a forest that forms the uppermost canopy layer.

Overstory removal

The cutting of trees constituting an upper canopy layer to release trees or other vegetation in an 

understory.

P

Personal use (free use)

Bona fide settlers, miners, residents, and prospectors for minerals in Alaska may take free of charge 

green or dried timber from the National Forests in Alaska for personal use but not for sale. Permits will be 

required for green saw timber. Other material may be taken without permit. The amount of material 

granted to any one person in one year shall not exceed 10,000 board feet of saw timber and 25 cords of 

wood, or an equivalent volume in other forms. Persons obtaining materials shall, on demand, forward to 

the supervisor a statement of the quantity taken and the location from which it was removed (36 CFR 

223.10). 

Plan components

The parts of a land management plan that guide future project and activity decision-making. Specific plan 

components may apply to the entire plan area, to specific management areas or geographic areas, or to 

other areas as identified in the plan. Every plan must include the following plan components: desired 

conditions, objectives, standards, guidelines, and suitability of lands. A plan may also include goals as an 

optional component. Plan components can only be changed through plan amendment or revision.
Glossary 7

Final EIS 7-18 Glossary

Plan implementation

To carry out or fulfill Standards and Guidelines and other direction contained in the Land and Resource 

Management Plan (Forest Plan).

Plan of Operations

A Plan of Operations is required from anyone who proposed operations, under the 1872 Mining Law, 

would cause, “significant surface disturbance.” See 36 CFR 228, Subpart A.

Plan period 

The period of time a Forest Plan is in effect, typically 10 years, but no longer than 15 years.

Planning area

All the lands addressed in a land management plan. For this document, it is the Tongass National Forest.

Planning cycle demand

As used in this document, the amount of timber that buyers are estimated to be willing to purchase over 

the next 10 to 15 years. Also see the definition for annual demand.

Planning horizon

The overall time period considered in the planning process that spans all activities covered in the analysis 

or plan, and all future conditions and effects of proposed actions that would influence the planning 

decisions more than 100 years.

Planning period

Generally a 10- to 15-year period. The time interval within the planning horizon that is used to show 

incremental changes to yields, costs, effects, and benefits.

Planning record

A system that records decisions and activities that result from the process of developing a forest plan, 

revision, or significant amendment.

Plant association

A plant community type based on land management potential, successional patterns, and species 

composition.

Plant communities

An assemblage of plants that, in general, occur together on similar site conditions.

Population viability

Probability that a population will persist for a specified period of time across its range despite normal 

fluctuations in population and environmental conditions.

Precommercial Thinning 

See the definition for thinning.

Prescribed fire 

A wildland fire burning under planned conditions to accomplish specific land and resource objectives. It 

may result from either a management or natural ignition.
Glossary 7

Final EIS 7-19 Glossary

Priority use

A Forest Service commitment to the holder of a permit for outfitting and guiding to give priority 

consideration to granting the holder a specific amount of available future use. 

Authorization of use for up to 10-years, based on the holder's past use and performance and applicable 

programmatic or project decisions to allocate use. Except as provided in 36 CFR 251, Subpart E, 

authorizations providing for priority use are subject to renewal (FSH 2709.14, section 53.1m).

Productive old growth (POG)

Old-growth forest capable of producing at least 20 cubic feet of wood fiber per acre per year, or having 

greater than 8,000 board feet per acre.

Programmatic Environmental Impact Statement (PEIS)

The document disclosing the environmental consequences of a program or plan that guides or prescribes 

the use of resources, allocates resources, or establishes rules and policies in contrast to disclosure of the 

environmental consequences of a site-specific project.

Prohibitions (as proposed for Alaska Roadless Rule)

Activities that would not be allowed in different categories of ARAs.

Project

An organized effort to achieve an outcome on National Forest System lands identified by location, tasks, 

outputs, effects, times, and responsibilities for execution (36 CFR 219.19).

Projected Timber Sale Quantity (PTSQ)

A subset of the projected wood sale quantity and is an estimate of the quantity of timber expected to be 

sold during the plan period. The volume in the projected timber sale quantity is the volume that meets 

utilization standards (FSH 1909.12, Chapter 60, section 64.34). Except as provided in section 64.33 of 

FSH1909.12 (departure from sustained yield limit), the projected timber sale quantity must be equal to or 

below the sustained yield limit for each decade of the plan.

PTSQ must take into account the fiscal capability of the planning unit and be consistent with all plan 

components. Estimates of the projected timber sale quantity do not include any volumes anticipated from 

salvage or sanitation harvests. 

Projected Wood Sale Quantity (PWSQ)

An estimate of the volume of all timber and other wood products that is expected to be sold during the 

plan period from expected harvests for any purpose (except salvage harvest or sanitation harvest) on all 

lands in the plan area. The projected wood sale quantity includes all woody material likely to be sold from 

these harvests whether or not the woody material meets the utilization standards (FSH 1909.12, Chapter 

60, section 64.34). 

PWSQ must take into account the fiscal capability of the planning unit and be consistent with all plan 

components. Estimates of the projected wood sale quantity do not include any volumes anticipated from 

salvage or sanitation harvests. 
Glossary 7

Final EIS 7-20 Glossary

Q

R

Rare plants

Rare plants include plant species identified on the Alaska Natural Heritage Program (ANHP) Rare 

Vascular Plant Tracking List that are known to occur on the Tongass (ANHP, 2008), is considered 

globally rare (G1/T1, G2/T2) and/or rare in the State (S1, S2 and some S3 are considered); or is 

considered rare because of a range extension or disjunct populations on the Tongass but not yet given a 

state ranking on the ANHP list. 

Recreation Opportunity Spectrum (ROS) 

A system for planning and managing recreation resources that categorizes recreation opportunities into 

seven classes. Each class is defined in terms of the degree to which it satisfies certain recreation 

experience needs based on the extent to which the natural environment has been modified, the type of 

facilities provided, the degree of outdoor skills needed to enjoy the area and the relative density of 

recreation use. The seven classes are:

Primitive. An unmodified environment generally greater than 5,000 acres in size and located 

generally at least 3 miles from all roads and other motorized travel routes. A very low interaction 

between users (generally less than 3 group encounters per day) results in a very high probability 

of experiencing solitude, freedom, closeness to nature, tranquility, self-reliance, challenge, and 

risk. Evidence of other users is low. Restrictions and controls are not evident after entering the 

land unit. Motorized use is rare. 

Semi-Primitive Non-Motorized. A natural or natural-appearing environment generally greater 

than 2,500 acres in size and generally located at least 0.5 mile (greater or less depending on 

terrain and vegetation, but no less than 0.25 mile) but not further than 3 miles from all roads and 

other motorized travel routes. Concentration of users is low (generally less than 10 group 

encounters per day), but there is often evidence of other users. There is a high probability of 

experiencing solitude, freedom, closeness of nature, tranquility, self-reliance, challenge, and risk. 

There is a minimum of subtle on-site controls. No roads are present in the area. 

Semi-Primitive Motorized. A natural or natural-appearing environment generally greater than 

2,500 acres in size and generally located within 0.5 mile of primitive roads and other motorized 

travel routes used by motor vehicles; but not closer than 0.5 mile (greater or less depending on 

terrain and vegetation, but no less than 0.25 mile) from better-than-primitive roads and other 

motored travel routes. Concentration of users is low (generally less than 10 group encounters per 

day), but there is often evidence of other users. There is a moderate probability of experiencing 

solitude, closeness to nature, and tranquility along with a high degree of self-reliance, challenge, 

and risk in using motorized equipment. Local roads may be present, or along saltwater shorelines 

there may be extensive boat traffic. 

Roaded Natural. Resource modification and utilization are evident, in a predominantly naturallyappearing environment generally occurring within 0.5 mile (greater or less depending on terrain 

and vegetation, but no less than 0.25 mile) from better-than-primitive roads and other motorized 

travel routes. Interactions between users may be moderate to high (generally less than 20 group 

encounters per day), with evidence of other users prevalent. There is an opportunity to affiliate 

with other users in developed sites but with some chance for privacy. Self-reliance on outdoor 

skills is only of moderate importance with little opportunity for challenge and risk. Motorized use is 

allowed.

Roaded Modified. Vegetative and landform alterations typically dominate the landscape. There 

is little on-site control of users except for gated roads. There is moderate evidence of other users 

on roads (generally less than 20 group encounters per day), and little evidence of others or 
Glossary 7

Final EIS 7-21 Glossary

interactions at campsites. There is opportunity to get away from others but with easy access. 

Some self-reliance is required in building campsites and use of motorized equipment. A feeling of 

independence and freedom exists with little challenge and risk. Recreation users will likely 

encounter timber management activities. 

Rural. The natural environment is substantially modified by land use activities. Opportunity to 

observe and affiliate with other users is important as is convenience of facilities. There is little 

opportunity for challenge and risk and self-reliance on outdoor skills is of little importance. 

Recreation facilities designed for group use are compatible. Users may have more than 20 group 

encounters per day. 

Urban. Urbanized environment with dominant structures, traffic lights and paved streets. May 

have natural appearing backdrop. Recreation places may be city parks and large resorts. 

Opportunity to observe and affiliate with other users is very important as is convenience of 

facilities and recreation opportunities. Interaction between large numbers of users is high. 

Outdoor skills, risk, and challenge are unimportant except for competitive sports. Intensive on-site 

controls are numerous.

Recreation places

Identified geographical areas having one or more physical characteristics that are particularly attractive to 

people engaging in recreation activities. They may be beaches, streamside or roadside areas, trail 

corridors, hunting areas of the immediate area surrounding a lake, cabin site, or campground.

Reforestation

The re-establishment of forest cover either naturally (natural seeding, coppice, or root suckers) or 

artificially (direct seeding or planting).

Research Natural Area (RNA)

An area in as near a natural condition as possible, which exemplifies typical or unique vegetation and 

associated biotic, soil, geologic, and aquatic features. The area is set aside to preserve a representative 

sample of an ecological community primarily for scientific and educational purposes; commercial and 

most public uses are not allowed.

Reserve Trees

Dead, dying, defective, or damaged trees left standing after harvest to provide wildlife habitat.

Resident fish

Fish that are not migratory and complete their entire life cycle in fresh water.

Resource values

The tangible and intangible worth of forest resources.

Responsible official

The Forest Service employee who has the delegated authority to make a specific decision.

Retention

The amount of commercial forest land removed from the timber base to protect other resource values.

Riparian area

Riparian areas encompass the zone of interaction between aquatic and terrestrial environments 

associated with streamsides, lakeshores, and floodplains, and display distinctive ecological conditions 

characterized by high species diversity, wildlife value, and resource productivity. 
Glossary 7

Final EIS 7-22 Glossary

Riparian management area (RMA)

Land areas delineated in the Forest Plan to provide for the management of riparian resources. Specific 

standards and guidelines, by stream process group, are associated with riparian management areas. 

Riparian management areas standards and guidelines may be modified by watershed analysis. 

Portions of a watershed where riparian-dependent resources receive primary emphasis, and for which 

plans include plan components to maintain or restore riparian functions and ecological functions (36 CFR 

219.19).

Road

A motor vehicle route over 50 inches wide, unless identified and managed as a trail (36 CFR 212.1). 

Road construction or reconstruction

Supervising, inspecting, actual building of the subgrade, base course or surfacing coarse of a roadway, 

and incurrence of all costs incidental to the construction or reconstruction of a road (36 CFR 212.1). 

Road decommissioning

Activities that result in the restoration of unneeded roads to a more natural state (FSM 7734).

Road density

The number of road miles per square mile of land area.

Roaded roadless

Portions of inventoried roadless areas (IRAs) that were roaded before the 2001 Roadless Rule or during 

the 2001 Roadless Rule exemption period for the Tongass. Includes areas that have been substantially 

altered due to road construction and/or timber harvest.

Roadless area

See Inventoried roadless area (IRA) definition. Within this document, roadless areas may also be used to 

describe areas proposed to be designated as Alaska Roadless Areas.

Recreation Opportunity Spectrum (ROS) 

The ROS system portrays the combination of activities, settings, and experience expectations along a 

continuum that ranges from highly modified to primitive environments. See Appendix I to the 2016 Forest 

Plan (USDA Forest Service 2016a). 

Rotation

In even-age systems, the period between regeneration establishment and final cutting. 

S

Sacred sites

Executive Order 13007 defines a sacred site as “any specific, discrete, narrowly delineated location on 

federal land that is identified by an Indian tribe or Indian individual determined to be an appropriately 

authoritative representative of an Indian religion, as sacred by virtue of its established religious 

significance to, or ceremonial use by, an Indian religion; provided that the tribe or appropriately 

authoritative representative of an Indian religion has informed the agency of the existence of such a site.” 
Glossary 7

Final EIS 7-23 Glossary

Salmonid

Any fish belonging to the family Salmonidae, which includes salmon and trout.

Salvage cutting/sales

The removal of dead trees or trees damaged or dying because of injurious agents other than competition 

to recover economic value that would otherwise be lost.

Sawlogs (Sawtimber)

The portion of a tree that is suitable in size and quality for the production of dimension lumber, collectively 

known as sawtimber.

Scenic Integrity Objective (SIO)

A desired level of scenic quality and diversity of natural features based on physical and sociological 

characteristics of an area. Refers to the degree of acceptable alterations of the characteristic landscape. 

The adopted SIO is the SIO to be achieved as a result of management direction identified in the approved 

Forest Plan. SIOs are described below: 

Very High: Landscapes where the landscape character is intact with only minute, if any, 

deviations. The existing landscape character and sense of place is expressed at the highest 

possible level.

High: Landscapes where the landscape character “appears” intact. Deviations may be present 

but must repeat the form, line, color, texture, and pattern common to the landscape character so 

completely and at such scale that they are not evident.

Moderate: Landscapes where the landscape character “appears slightly altered.” Noticeable 

deviations must remain visually subordinate to the landscape being viewed.

Low: Landscapes where the landscape character “appears moderately altered.” Deviations begin 

to dominate the landscape character being viewed but borrow valued attributes such as size, 

shape, edge effect, and pattern of natural openings, vegetative type changes, or architectural 

styles outside the landscape being viewed. They should not only appear as valued character 

outside the landscape being viewed but compatible or complimentary to the character within.

Very Low: Landscapes where the landscape character “appears heavily altered.” Deviations may 

strongly dominate the landscape character. They may not borrow from attributes such as size, 

shape, edge effect, and pattern of natural openings, vegetative type changes, or architectural 

styles within or outside the landscape being viewed. However, deviations must be shaped and 

blended with the natural terrain so that elements such as unnatural edges, roads, landings, and 

structures do not dominate the composition.

Unacceptably Low: Landscapes where the valued landscape character being viewed appears 

extremely altered. Deviations are extremely dominant and borrow little if any form, line, color, 

texture, pattern or scale from the landscape character. Landscapes at this level of integrity need 

rehabilitation.

Scoping

The issues for consideration in the planning phase are identified in the NEPA document through public 

and governmental participation opportunities provided in the early stages of the planning process. 

Governments, agencies, and the public may submit any additional or new scientific information for 

consideration in the planning process, and the Responsible Official shall determine whether any such 

information is the best available scientific information.
Glossary 7

Final EIS 7-24 Glossary

Second-growth forest

Trees that cover an area after the removal of the original stand, as by cutting or fire. (American Heritage 

Dictionary of the English Language, Fifth Edition 2011).

Also referred to as young-growth forest and used interchangeably in places within the 1997 Forest Plan 

revision, as amended. 

Secondary succession

The process of re-establishing vegetation after normal succession is disrupted by fire, cultivation, 

lumbering, windthrow, or any similar disturbance.

Sediment 

Solid material, both mineral and organic, that is in suspension, is being transported, or has been moved 

from its site of origin by air, water, gravity, or ice and has come to rest on the earth's surface either above 

or below sea level.

Sensitive species

Plant or animal species that are susceptible or vulnerable to habitat alterations or management activities 

resulting in a viability concern for the species long-term persistence. Sensitive species may be those 

species under consideration for official listing as endangered or threatened species, are on an official 

state list, or are recognized by the Regional Forester as needing special consideration to ensure viable 

populations and to prevent their being placed on federal or state lists.

Sensitive travel route

A road system or marine water way that receives a moderate to high degree of use by the public, both 

Alaskan residents and tourists.

Silvicultural system

A planned series of treatments for tending, harvesting, and re-establishing a stand. Note: The individual 

system name is based on the number of age classes (even-aged, two-aged, uneven-aged) or the 

regeneration method (clearcutting, seed tree, shelterwood, selection) used. 

Small sale

Timber sales that are generally less than 10 million board feet (MMBF).

Smolt

A young silvery-colored salmon or trout that has undergone physiological changes to move from 

freshwater environment to saltwater.

Snag

A dead standing tree usually greater than 5 feet tall and 6 inches in diameter at breast height. The interior 

of the snag may be sound or rotted. 

Soil productivity

The capacity of a soil, in its normal environment, to produce a specific plant or sequence of plants under 

a specific system of management.

Special Interest Areas (SIA)

A designation for areas possessing unique or unusual scenic, historic, prehistoric, geodesic scientific or 

other characteristics.
Glossary 7

Final EIS 7-25 Glossary

Special use authorization

A written permit, term permit, lease, or easement that authorizes use or occupancy of National Forest 

System lands and specifies the terms and conditions under which the use or occupancy may occur. (36 

CFR 251.51)

Stand

A contiguous group of trees sufficiently uniform in composition, age class distribution, and growing on a 

site of sufficiently uniform quality, to be a distinguishable unit.

Standard 

A mandatory constraint on project and activity decision-making, established to help achieve or maintain 

the desired condition or conditions, to avoid or mitigate undesirable effects, or to meet applicable legal 

requirements. (36 CFR 219.12)

Size Density Model (SDM)

A forest-mapping model based on average tree size (quadratic mean diameter) and average tree density 

(stand density index), used to describe stand structural characteristics. SDM uses timber volume class, 

hydric soil class, and aspect to characterize forest structure.

State Historic Preservation Officer (SHPO)

The official appointed or designated pursuant to Section 101(b)(1) of the National Historic Preservation 

Act of 1966, as amended, to administer the State Historic Preservation Program.

Stream bed

The substrate plane bounded by the stream banks, over which the water column moves. Also called the 

stream bottom.

Stream bank

The portion of the channel cross section that restricts lateral movement of water at normal water levels. 

The bank often has a gradient steeper than 45 degrees and exhibits a distinct break in slope from the 

stream bottom. An obvious change in substrate may be a reliable delineation of the bank.

Stream class

A means to categorize stream channels based on their fish production values. There are four stream 

classes on the Tongass National Forest (FSH 2090.21 (2001) Chapter 10, Section 12).

Structure

A term in ecology referring to the arrangement of plant communities or ecosystems across a landscape 

and how they are connected, and to variations in tree heights and diameters within a stand or between 

stands.

Subsistence

Section 803 of the Alaska National Interest Lands Conservation Act defines subsistence use as, “the 

customary and traditional uses by rural Alaska residents of wild renewable resources for direct, personal 

or family consumption as food, shelter, fuel, clothing, tools, or transportation; for the making and selling of 

handicraft articles out of nonedible byproducts of fish and wildlife resources taken for personal or family 

consumption; for barter, or sharing for personal or family consumption; and for customary trade.”
Glossary 7

Final EIS 7-26 Glossary

Subspecies

An aggregate of similar populations of a species generally inhabiting a geographic subdivision of the 

range of the species and differing taxonomically (e.g., different size or color) from other populations of the 

species.

Substantially altered areas 

In this document, this includes areas where road construction and/or timber harvest have occurred (see 

roaded roadless.)

Suitability of Lands

A determination that specific lands within a plan area may be used, or not, for various multiple uses or 

activities, based on the desired conditions applicable to those lands. The suitability of lands 

determinations need not be made for every use or activity, but every plan must identify those lands that 

are not suitable for timber production (FSH 1909.12 chapter 20, section 22.15). (See FSH 1909.12 

chapter 60 for timber production suitability.) 

Suitable Timber Lands

Forested lands that have been determined to be suitable for timber production. See 2016 Forest Plan 

Appendix A.

Sustained yield

The yield that a forest can continuously produce at a given intensity of management.

T

Taxa

For the purposes of this Plan and FEIS, taxa are animal species or sub-species.

Temporary roads

Roads authorized by contract, permit, lease, or emergency operation, not intended to be part of the forest 

transportation system and not necessary for long-term resource management.

The Nature Conservancy/Audubon conservation priority watersheds

Watersheds identified by The Nature Conservancy and Audubon Alaska that include high-value intact 

watersheds in primarily intact conditions and generally encompass the highest current ecological values 

within each province.

Thinning

A silvicultural treatment made to reduce stand density of trees primarily to improve growth, enhance forest 

health, or recover potential mortality. Thinning may also be done to manipulate stand characteristics to 

improve wildlife or riparian habitat, or to enhance scenery. Types of thinning include:

Precommercial (PCT). The removal of trees not for immediate financial return but to reduce 

stocking to concentrate growth on the more desirable trees. 

Commercial (CT). Any type of thinning producing merchantable material at least equal to the 

value of the direct costs of harvesting. 
Glossary 7

Final EIS 7-27 Glossary

Threatened species 

A plant or animal species likely to become an endangered species within the foreseeable future 

throughout all or a significant portion of its range. Threatened species are identified and defined in 

accordance with the 1973 Endangered Species Act and published in the Federal Register.

Any species that the Secretary of the Interior or the Secretary of Commerce has determined is likely to 

become an endangered species within the foreseeable future throughout all or a significant portion of its 

range. Threatened species are listed at 50 CFR sections 17.11, 17.12, and 223.102. 

Tiering

Elimination of repetitive discussions of the same issue by incorporating, by reference, the general 

discussion in an environmental impact statement (EIS) of broader scope. For example, a project 

environmental assessment could be tiered to the Forest Plan EIS.

Timber

Wood, other than fuelwood, potentially useable for lumber.

Timber classification

Forested land is classified under each of the land management alternatives according to how it relates to 

the management of the timber resource. The following are definitions of timber classifications used for 

this purpose:

Non-Forest. Land that has never supported forests, and land formerly forested where use for 

timber production is precluded by development or other uses.

Forest. Land at least 10 percent stocked (based on crown cover) by forest trees of any size, or 

formerly having had such tree cover and not currently developed for non-forest use.

Suitable. Land to be managed for timber production on a regulated basis.

Unsuitable. Land withdrawn from timber utilization by statute or administrative regulation (e.g.,

Wilderness), or identified as inappropriate for timber production in the Forest planning process.

Commercial Forest. Land tentatively suitable for the production of continuous crops of timber 

and that has not been withdrawn.

Timber harvest (as proposed for Alaska Roadless Rule)

The cutting and removal, and/or sale of trees.

Timber Land Suitability

See suitability of lands.

Timber production

The purposeful growing, tending, harvesting, and regeneration of regulated crops of trees to be cut into 

logs, bolts, or other round sections for industrial or consumer use. (36 CFR 219.19)

Timber production suitability (lands suited and not suited for timber 

production)

A forest plan must identify the lands that are suited and not suited for timber production. (FSH 1909.12, 

chapter 60). 
Glossary 7

Final EIS 7-28 Glossary

Timber stand

A contiguous group of trees sufficiently uniform in age class distribution, composition, and structure, and 

growing on a site of sufficiently uniform quality, to be a distinguishable unit, such as mixed, pure, evenaged, and uneven-aged stands.

Tongass 77 (T77)

The Tongass 77 (T77) refers to value comparison units (VCUs), which approximate major watersheds 

located on National Forest System lands that Trout Unlimited, Alaska Program identified as priority 

salmon watersheds.

T77 Watersheds and The Nature Conservancy (TNC)/Audubon 

Conservation Priority Areas

Through involvement of private and public groups and agencies, a number of watersheds and Value 

Comparison Units (VCUs) in the Tongass were previously evaluated for relative importance for several 

metrics relating to fish and wildlife. Included among these are conservation priority areas identified by the 

The Nature Conservancy (TNC) and Audubon Alaska (Audubon Alaska and The Nature Conservancy 

2007), and the “Tongass 77” (T77) watersheds identified by Trout Unlimited. The Tongass 77 (T77) refers 

to value comparison units (VCUs), which approximate major watersheds located on the Tongass National 

Forest that Trout Unlimited, Alaska Program identified as priority salmon watersheds within the 2016 

Tongass National Forest Land and Resource Management Plan (USDA Forest Service 2016a).

Tongass Resource Use Cooperative Survey (TRUCS)

A study done to gather information on subsistence uses of the Forest.

Topography

The configuration of a land surface including its relief, elevation, and the position of its natural and 

human-made features.

Traditional Cultural Property (TCP)

A traditional cultural property is generally one that is eligible for inclusion in the National Register because 

of its association with cultural practices or beliefs of a living community that (a) are rooted in that 

community's history, and (b) are important in maintaining the continuing cultural identity of the community. 

Examples include a rural community whose organization, buildings and structures, or patterns of land use 

reflect the cultural traditions valued by its long-term residents; or a location where Native American 

religious practitioners have historically gone, and are known or thought to go today, to perform ceremonial 

activities in accordance with traditional cultural rules of practice.

Transmission line (electric) 

An interconnected group of lines and associated equipment for the movement or transfer of electric 

energy between points of supply and points at which it is transformed for delivery to customers or is 

delivered to other electric systems.

Transportation Systems Corridors (TSC)

Existing and future transportation systems such as those identified by the State of Alaska in the current 

version of the Southeast Alaska Transportation Plan (SATP) and applicable laws (for example, Section 

4407 of Public Law 109-59, Title XI of the Alaska National Interest Lands Conservation Act (Public Law 

96-487). 

Transportation/Utility corridor

A linear strip of land identified for the present location of transportation or utility rights-of-way within its 

boundaries.
Glossary 7

Final EIS 7-29 Glossary

Travel Management Plan 

The plan for the system of access roads, trails, and airfields needed for the protection, administration, and 

utilization of the National Forests and other lands administered by the Forest Service, or the development 

and use of resources upon which communities within or adjacent to the National Forests are dependent 

(36 CFR 212.1). The plan also addresses permanent or temporary road closures necessary for resource 

protection or public safety.

Turbidity

An expression of the optical property that causes light to be scattered and absorbed rather than 

transmitted in straight lines through a water sample; turbidity in water is caused by the presence of 

suspended matter such as clay, silt, finely divided organic and inorganic matter, plankton, and other 

microscopic organisms.

Two-aged management

A regeneration method that regenerates and maintains a stand with two-age classes where the reserved 

trees are distributed somewhat evenly as individual or clumps and represent 15 percent or more of the 

stand’s pre-treatment basal area. The resulting stand may be two-aged or trend towards an uneven-aged 

condition as a consequence of both an extended period of regeneration establishment and the retention 

of reserved trees that may represent one or more age classes. Two-aged stands are created using these 

regeneration methods:

1. Clearcutting with reserves

2. Seed tree with reserves

3. Shelterwood with reserves.

The reserved trees are not harvested to attain goals other than regeneration.

U

Understory vegetation

All forest vegetation growing under an overstory.

Undertaking

“A project, activity, or program funded in whole or in part under the direct or indirect jurisdiction of a 

Federal agency, including those carried out by or on behalf of a Federal agency; those carried out with 

Federal financial assistance; and those requiring a Federal permit, license or approval” (36 CFR 

800.16(y)).

Uneven-aged management 

A planned sequence of treatments designed to maintain and regenerate a stand with three or more age 

classes.

Unproductive forest land

Forest land incapable of yielding crops of industrial wood because of adverse site conditions.

Unsuitable lands

Forest land not managed for timber production because: 1) Congress, the Secretary, or the Chief has 

withdrawn it; 2) it is not producing or capable of producing industrial wood; 3) technology is not available 

to prevent irreversible damage to soils productivity or watershed conditions; 4) there is no reasonable 

assurance, based on existing technology and knowledge, that it is possible to restock lands within 5 years 

after final harvest; 5) there is, at present, a lack of adequate information about responses to timber 
Glossary 7

Final EIS 7-30 Glossary

management activities; or 6) timber management is inconsistent with or not cost efficient in meeting the 

management requirements and multiple-use objectives specified in the Forest Plan.

Upland

Areas that do not classify as wetlands or riparian areas. 

Utility system 

A system that provides a community or communities with services such as municipal water or 

wastewater, natural gas, telephone, and electricity. This applies whenever the project or proposal is 

developed to supply services for public use or consumption

V

Value Comparison Unit (VCU)

First developed for the 1979 Tongass Land Management Plan as distinct geographic areas that generally 

encompass a drainage basin containing one or more large stream systems. Boundaries usually follow 

easily recognizable watershed divides. There are 926 units established to provide a common set of areas 

for which resource inventories could be conducted and resource value interpretations made.

Viable population

For forest planning purposes, a fish or wildlife population that has the estimated number and distribution 

of reproductive individuals to insure its continued existence is well distributed in the National Forest.

A population of a species that continues to persist over the long term with sufficient distribution to be 

resilient and adaptable to stressors and likely future environments. (36 CFR 219.19)

Viewshed

An expansive landscape or panoramic vista seen from a road, marine waterway, or specific viewpoint.

The area that is potentially seen from a specific viewing point using a planimetric approach.

W

Watershed

A region or land area drained by a single stream, river, or drainage network; a drainage basin (36 CFR 

219.19). Typically, watersheds are delineated as hierarchical Hydrologic Units in the national Watershed

Boundary Dataset, cooperatively managed by state and federal agencies. In the context of the Forest 

Plan, watersheds may correspond to VCU or LUD boundaries which may or may not correspond to the 

boundaries delineated in the Watershed Boundary Dataset.

Wetlands

Areas that are inundated or saturated by surface or groundwater at a frequency and duration sufficient to 

support, and that under normal circumstances do support, a prevalence of vegetation typically adapted to 

life in saturated soil conditions. Wetlands generally include swamps, marshes, bogs, and similar areas.

Wild and Scenic Rivers

A river designated by Congress as part of the National Wild and Scenic Rivers System that was 

established in the Wild and Scenic Rivers Act of 1968 (16 U.S.C. 1271 (note), 1271–1287) (36 CFR 

219.19).
Glossary 7

Final EIS 7-31 Glossary

Wilderness

Areas designated by congressional action under the 1964 Wilderness Act or subsequent Acts. 

Wilderness is defined as undeveloped federal land retaining its primeval character and influence without 

permanent improvements or human habitation. Wilderness areas are protected and managed to preserve 

their natural conditions, which generally appear to have been affected primarily by the forces of nature, 

with the imprint of human activity substantially unnoticeable; have outstanding opportunities for solitude or 

for a primitive and confined type of recreation; include at least 5,000 acres or are of sufficient size to 

make practical their preservation, enjoyment, and use in an unimpaired condition; and may contain 

features of scientific, educational, scenic, or historic value as well as ecologic and geologic interest. On 

the Tongass National Forest, Wilderness has been designated by the Alaska National Interest Lands

Conservation Act of 1980 and Tongass Timber Reform Act of 1990.

Wildlife Analysis Area

A division of land used by the Alaska Department of Fish and Game for wildlife analysis (WAA).

Windthrow

The act of trees being uprooted by the wind. In Southeast Alaska, Sitka spruce and hemlock trees are 

shallow rooted and susceptible to windthrow. There are generally three types of windthrow—endemic

where individual trees are blown over; catastrophic where a major windstorm can destroy hundreds of 

acres; and management related, where the clearing of trees in an area make the adjacent standing trees 

vulnerable to windthrow.

Withdrawal

The withholding of an area of federal land from settlement, sale, location, or entry under some or all of the 

general land laws for the purpose of limiting activities under those laws in order to maintain other public 

values in the area.

Y

Yarding

To convey logs or trees to a landing by cable, helicopter or other systems. Shovel- yarding is also used in 

Southeast Alaska. 

Young growth

Forest growth that has regenerated naturally or has been planted after some disturbance (e.g., clearcut 

harvest, serious fire, catastrophic windthrow, or insect attack) to the previous forest growth.

The term young growth is synonymous with second growth.

Young-growth forest

A relatively young forest that has been regenerated naturally or artificially after some drastic interference 

such as extensive cutting, wildfire, insect or disease attack, or blowdown (Helms 1998). On the Tongass 

a forest younger than 150 years is considered young-growth forest.

Z
Glossary 7

Final EIS 7-32 Glossary

This page intentionally left blank.
CHAPTER 8

INDEX
Index 8

Final EIS 8-1 Index

Chapter 8

Index

Action Alternative, 3-20, 3-21, 3-51, 3-111, 3-

148, 3-167, 3-169, 7-16

Adaptive Management, 2-2, 3-5, 3-37, 3-195, 3-

197 

Air, 1-12, 3-15, 3-150

air quality, 1-9, 1-12, 3-13, 3-15

Alaska Roadless Area, 1-9, 2-2, 2-3, 2-4, 2-5, 2-

6, 2-7, 2-8, 3-10, 3-11, 3-51, 3-112, 3-167, 3-

169, 7-1, 7-7

Alaska Roadless Rule, 1-1, 1-5, 1-6, 1-7, 1-11, 

1-13, 1-16, 2-3, 2-5, 2-12, 2-15, 2-16, 3-9, 3-

10, 3-11, 3-24, 3-50, 3-110, 3-112, 3-113, 3-

114, 3-116, 3-117, 3-126, 3-134, 3-140, 3-

141, 3-142, 3-148, 3-166, 3-252, 7-1, 7-9, 7-4, 

7-12

Alexander Archipelago Wolf, 3-100, 3-120 

Alternatives, 1-7, 1-11, 1-12, 1-13, 2-1, 2-2, 2-3, 

2-4, 2-6, 2-7, 2-9, 2-14, 2-17, 2-18, 2-19, 2-

21, 2-22, 2-23, 2-24, 2-25, 2-29, 3-6, 3-14, 3-

15, 3-16, 3-17, 3-23, 3-25, 3-26, 3-27, 3-51, 3-

52, 3-56, 3-57, 3-58, 3-59, 3-73, 3-82, 3-83, 3-

84, 3-111, 3-112, 3-115, 3-117, 3-119, 3-121, 

3-125, 3-135, 3-136, 3-137, 3-138, 3-139, 3-

152, 3-158, 3-159, 3-160, 3-161, 3-166, 3-

167, 3-168, 3-169, 3-175, 3-176, 3-179, 3-

188, 3-189, 3-191, 3-193, 3-195, 3-197, 3-

204, 3-205, 3-206, 3-207, 3-208, 3-209, 3-

210, 3-211, 3-212, 3-213, 3-214, 3-215, 3-

216, 3-218, 3-219, 3-224, 3-232, 3-233, 3-

234, 3-235, 3-236, 3-237, 3-247, 3-250, 3-

251, 3-254

Alternatives Considered in Detail, 2-9

Angoon, 1-5, 1-6, 3-29, 3-31, 3-50, 3-220, 3-

238, 3-244, 3-245, 3-252, 3-253, 3-254, 5-2, 

5-3

bald eagle, 3-102, 3-121, 3-122, 3-128

beach fringe, 3-75, 3-80, 3-81, 3-82, 3-83, 3-84, 

3-98, 3-99, 3-104, 3-110, 3-111, 3-115, 3-116, 

3-156, 3-232, 3-233, 3-234, 3-235, 3-236, 3-

237, 3-248

biogeographic provinces, 3-2, 3-7, 3-14, 3-61, 3-

62, 3-63, 3-64, 3-69, 3-71, 3-75, 3-80, 3-81, 3-

82, 3-83, 3-84, 3-86, 3-87, 3-88, 3-96, 3-114, 

3-116, 3-120, 3-127, 3-247

biological diversity, 1-9, 1-10, 2-24, 3-13, 3-14, 

3-61, 3-66, 3-69, 3-71, 3-72, 3-73, 3-74, 3-75, 

3-80, 3-81, 3-82, 3-83, 3-84, 3-85, 3-89, 3-95, 

3-100, 3-103, 3-110, 3-114, 3-125, 3-126, 3-

127, 3-172, 3-173, 3-174, 3-240, 3-251

biomass, 2-2, 3-145, 3-146, 3-147, 3-149, 7-3

black bear, 3-98, 3-100, 3-108, 3-109, 3-117, 3-

118, 3-119, 3-128, 3-217, 3-246

brown bear, 2-29, 3-14, 3-99, 3-100, 3-109, 3-

111, 3-119, 3-127, 3-185, 3-210, 3-212, 3-

240, 3-246

brown creeper, 3-103, 3-122, 3-126

cave, 1-11, 3-151, 3-152, 3-219, 7-4

Cave, 3-151, 3-152, 3-153, 3-219, 7-4

clearcutting, 3-124, 3-132, 3-174, 7-5, 7-9

Coffman Cove, 3-42, 3-164, 3-168, 3-244, 3-245

communities, 1-3, 1-5, 1-7, 1-8, 1-9, 1-10, 2-2, 

2-3, 2-4, 2-5, 2-7, 2-19, 2-22, 2-24, 2-27, 3-9, 

3-10, 3-11, 3-12, 3-13, 3-16, 3-24, 3-29, 3-30, 

3-31, 3-33, 3-41, 3-44, 3-45, 3-47, 3-49, 3-58, 

3-62, 3-71, 3-74, 3-107, 3-117, 3-163, 3-164, 

3-165, 3-167, 3-170, 3-181, 3-182, 3-183, 3-

184, 3-191, 3-193, 3-214, 3-221, 3-239, 3-

240, 3-241, 3-242, 3-243, 3-244, 3-245, 3-

246, 3-248, 3-249, 3-250, 3-252, 3-253, 3-

254, 7-2, 7-7, 7-8, 7-12, 7-13, 7-3, 7-10, 7-13, 

7-15

Community Use Priority, 3-167, 3-170, 3-179

Comparison of Alternatives, 2-26, 2-27, 2-29

connectivity, 3-14, 3-61, 3-71, 3-72, 3-73, 3-85, 

3-89, 3-98, 3-99, 3-108, 3-109, 3-110, 3-111, 

3-114, 3-119, 3-122, 3-123, 3-125, 3-126, 3-

127, 7-5, 7-7

corridor, 3-63, 7-13

Craig, 1-5, 1-6, 3-5, 3-19, 3-22, 3-23, 3-24, 3-25, 

3-26, 3-40, 3-42, 3-53, 3-54, 3-156, 3-164, 3-

186, 3-195, 3-196, 3-197, 3-213, 3-214, 3-

244, 3-248, 3-252, 7-15

cumulative effects, 3-1, 3-2, 3-27, 3-84, 3-85, 3-

126, 3-127, 3-128, 3-141, 3-142, 3-149, 3-

150, 3-152, 3-161, 3-162, 3-166, 3-169, 3-

170, 3-176, 3-180, 3-220, 3-223, 3-237, 3-

238, 3-251, 3-252

ecosystem services, 1-9, 3-13, 3-26, 3-143, 3-

148

Edna Bay, 3-42, 3-241, 3-244

EFH (Essential Fish Habitat), 1-13, 7-8

Elfin Cove, 3-165, 3-184, 3-241, 3-244

Employment and Income, 3-55
Index 8

Final EIS 8-2 Index

endemic, 2-29, 3-13, 3-14, 3-63, 3-71, 3-89, 3-

98, 3-100, 3-107, 3-108, 3-109, 3-112, 3-124, 

3-125, 3-127, 7-8, 7-16

endemism, 3-107, 3-108, 3-124, 7-8 

environmental justice, 3-253

exceptions, 1-1, 1-8, 1-15, 1-16, 2-4, 2-6, 2-9, 2-

11, 2-12, 2-13, 2-14, 2-15, 2-16, 2-17, 2-23, 3-

17, 3-24, 3-58, 3-59, 3-60, 3-137, 3-139, 3-

158, 3-164, 3-165, 3-167, 3-168, 3-169, 3-179

fish, 1-9, 1-10, 1-13, 2-3, 2-6, 2-7, 2-8, 2-20, 2-

21, 2-22, 2-25, 3-10, 3-11, 3-12, 3-13, 3-29, 3-

33, 3-48, 3-57, 3-90, 3-100, 3-115, 3-129, 3-

131, 3-132, 3-133, 3-134, 3-135, 3-136, 3-

137, 3-138, 3-139, 3-140, 3-141, 3-142, 3-

143, 3-144, 3-155, 3-157, 3-170, 3-181, 3-

182, 3-205, 3-213, 3-214, 3-219, 3-239, 3-

240, 3-241, 3-242, 3-243, 3-244, 3-245, 3-

246, 3-247, 3-248, 3-250

fish habitat, 1-9, 1-10, 1-13, 2-7, 2-25, 3-129, 3-

131, 3-132, 3-136, 3-137, 3-138, 3-143, 3-247

Fish Habitat, 2-25, 3-131, 3-132, 3-134

flying squirrel, 3-108, 3-109, 3-111, 3-125, 3-127

Forest Health, 3-144, 3-174

fragmentation, 1-9, 3-14, 3-15, 3-61, 3-71, 3-72, 

3-75, 3-80, 3-81, 3-82, 3-83, 3-84, 3-85, 3-89,

3-99, 3-103, 3-104, 3-107, 3-108, 3-109, 3-

111, 3-118, 3-119, 3-122, 3-123, 3-124, 3-

125, 3-126, 3-127, 3-158

geology, 1-11, 3-66, 3-67, 3-151, 3-178

Gustavus, 1-5, 3-42, 3-63, 3-244, 3-252

Haines, 1-3, 1-5, 3-29, 3-31, 3-42, 3-44, 3-45, 3-

50, 3-84, 3-115, 3-164, 3-182, 3-184, 3-241, 

3-244, 3-252, 3-253, 3-254

hairy woodpecker, 3-103, 3-122, 3-126

Hairy Woodpecker, 3-103, 3-122

Hollis, 3-164, 3-214, 3-244

Hoonah, 1-5, 1-6, 3-5, 3-19, 3-21, 3-22, 3-23, 3-

29, 3-31, 3-40, 3-42, 3-44, 3-45, 3-50, 3-54, 3-

156, 3-165, 3-182, 3-184, 3-186, 3-187, 3-

196, 3-208, 3-209, 3-210, 3-212, 3-243, 3-

244, 3-245, 3-252, 3-253, 3-254

Hydaburg, 1-5, 1-6, 1-7, 2-5, 2-12, 3-22, 3-164, 

3-241, 3-244, 3-245, 3-252, 3-253

Hyder, 1-3, 3-22, 3-29, 3-31, 3-50, 3-184, 3-224, 

3-228, 3-235, 3-244, 3-253, 3-254

invasive species, 1-13, 3-10, 3-61, 3-71, 3-89, 3-

157, 3-160, 3-161

IRA (Inventoried Roadless Area), 1-7, 2-4, 2-9, 

2-10, 2-11, 2-13, 2-14, 2-17, 3-8, 3-9, 3-17, 3-

19, 3-20, 3-21, 3-22, 3-24, 3-25, 3-26, 3-164,

3-165, 3-185, 3-194, 3-196, 3-211, 3-220, 7-

11, 7-7

Juneau, 1-5, 1-7, 2-5, 2-12, 3-5, 3-9, 3-19, 3-20, 

3-22, 3-23, 3-29, 3-30, 3-32, 3-44, 3-45, 3-46,

3-47, 3-49, 3-50, 3-54, 3-108, 3-115, 3-143, 3-

157, 3-163, 3-164, 3-165, 3-182, 3-184, 3-

186, 3-187, 3-196, 3-204, 3-220, 3-238, 3-

241, 3-249, 3-250, 3-251, 3-253, 3-254

Kake, 1-5, 1-7, 2-5, 2-12, 3-163, 3-164, 3-165, 

3-182, 3-241, 3-244, 3-245, 3-252, 3-253

karst, 1-11, 3-17, 3-67, 3-72, 3-151, 3-152, 3-

153, 3-219

Kasaan, 1-5, 1-6, 3-21, 3-22, 3-164, 3-244, 3-

245, 3-252, 3-253

Ketchikan, 1-5, 1-6, 1-7, 2-5, 2-12, 3-5, 3-19, 3-

22, 3-23, 3-25, 3-26, 3-29, 3-30, 3-34, 3-39, 3-

42, 3-44, 3-45, 3-46, 3-47, 3-50, 3-54, 3-84, 3-

144, 3-156, 3-164, 3-168, 3-182, 3-184, 3-

186, 3-187, 3-195, 3-196, 3-214, 3-220, 3-

238, 3-241, 3-248, 3-250, 3-252, 3-253, 3-254

Key Issue, 1-8, 1-9, 1-10, 2-18, 2-21, 2-24, 2-26, 

2-28, 2-29, 3-8, 3-9, 3-13, 3-14, 3-26, 3-29, 3-

48, 3-57, 3-61, 3-171, 3-175, 3-188, 3-240, 3-

246, 3-251, 3-254

Klawock, 3-42, 3-164, 3-214, 3-220, 3-244, 3-

245, 3-253

Kupreanof, 3-19, 3-20, 3-24, 3-25, 3-26, 3-62, 3-

63, 3-65, 3-68, 3-69, 3-70, 3-75, 3-76, 3-77, 3-

78, 3-79, 3-80, 3-81, 3-82, 3-83, 3-84, 3-86, 3-

87, 3-88, 3-97, 3-101, 3-114, 3-120, 3-127, 3-

182, 3-216, 3-234, 3-235, 3-251 

Land Divisions, 3-6 

Land Use Designation, 2-1, 2-4, 2-11, 2-12, 2-

14, 2-15, 2-16, 3-4, 3-6, 3-7, 3-80

Lands, 1-5, 2-2, 2-6, 2-11, 2-28, 2-29, 3-4, 3-12, 

3-36, 3-65, 3-68, 3-69, 3-70, 3-73, 3-86, 3-87,

3-88, 3-97, 3-99, 3-101, 3-121, 3-135, 3-136,

3-141, 3-151, 3-164, 3-172, 3-222, 3-239, 3-

251

Leasable Minerals, 3-177, 3-179

Locatable Minerals, 3-177, 3-179

Log Transfer Facilities, 3-164

LTF, 3-51, 3-115, 3-128, 3-166, 7-13

LUD, 1-1, 2-4, 2-5, 2-6, 2-11, 2-12, 2-13, 2-14, 

2-15, 2-16, 2-18, 2-19, 2-25, 2-26, 2-28, 2-29,

3-6, 3-7, 3-17, 3-18, 3-23, 3-24, 3-26, 3-58, 3-

59, 3-60, 3-69, 3-72, 3-74, 3-75, 3-80, 3-81, 3-

82, 3-83, 3-84, 3-110, 3-111, 3-112, 3-114, 3-

115, 3-117, 3-137, 3-138, 3-139, 3-153, 3-

167, 3-168, 3-170, 3-172, 3-176, 3-177, 3-

179, 3-185, 3-194, 3-195, 3-204, 3-205, 3-

206, 3-207, 3-208, 3-209, 3-210, 3-211, 3-

212, 3-213, 3-214, 3-215, 3-216, 3-217, 3-

218, 3-219, 3-221, 3-222, 3-223, 3-224, 3-

234, 3-235, 3-236

LUD II, 1-1, 2-4, 2-5, 2-6, 2-11, 2-12, 2-13, 2-14, 

2-15, 2-16, 2-18, 2-19, 2-26, 2-29, 3-7, 3-17,

3-18, 3-23, 3-24, 3-26, 3-58, 3-59, 3-60, 3-72,

3-80, 3-82, 3-111, 3-112, 3-137, 3-138, 3-139,

3-167, 3-168, 3-170, 3-172, 3-176, 3-177, 3-

185, 3-194, 3-204, 3-205, 3-207, 3-208, 3-

209, 3-210, 3-211, 3-212, 3-213, 3-214, 3-
Index 8

Final EIS 8-3 Index

215, 3-216, 3-217, 3-218, 3-219, 3-234, 3-

235, 3-236

LUD II Priority, 2-4, 2-5, 2-6, 2-11, 2-12, 2-14, 2-

15, 2-16, 2-18, 2-19, 2-26, 2-29, 3-18, 3-24, 3-

26, 3-58, 3-59, 3-60, 3-82, 3-112, 3-137, 3-

138, 3-139, 3-167, 3-168, 3-170, 3-194

Mammals, 2-29

marbled murrelet, 3-106, 3-107, 3-123, 3-124, 3-

126

marten, 2-29, 3-14, 3-98, 3-99, 3-102, 3-108, 3-

109, 3-111, 3-118, 3-119, 3-126, 6-4, 6-5 

Metlakatla, 3-45, 3-241, 3-244, 3-253

Meyers Chuck, 3-244

migratory bird, 3-63, 3-89, 3-104, 3-112, 3-123

Minerals, 2-26, 3-7, 3-165, 3-169, 3-177, 3-179

MIS, 3-89, 3-96, 3-102, 3-112, 3-132

Mountain Goat, 3-97, 3-117, 3-118, 6-10, 6-18

Naukati Bay, 3-244

non-system road, 3-166

OGR (old-growth reserve), 3-72, 3-85, 3-119, 3-

125, 3-126, 3-127

old-growth forest, 1-10, 2-2, 2-3, 2-19, 3-10, 3-

12, 3-13, 3-14, 3-38, 3-66, 3-71, 3-72, 3-74, 3-

75, 3-80, 3-81, 3-82, 3-83, 3-84, 3-85, 3-89, 3-

92, 3-95, 3-98, 3-100, 3-103, 3-107, 3-108, 3-

113, 3-114, 3-119, 3-122, 3-124, 3-126, 3-

127, 3-128, 3-141, 3-172, 3-173, 3-174, 3-

195, 3-246, 3-247, 3-251

Pelican, 1-5, 3-168, 3-244, 3-252

Petersburg, 1-5, 3-5, 3-19, 3-22, 3-23, 3-24, 3-

25, 3-26, 3-29, 3-40, 3-42, 3-45, 3-47, 3-50, 3-

54, 3-156, 3-157, 3-163, 3-164, 3-165, 3-182, 

3-186, 3-187, 3-195, 3-196, 3-215, 3-216, 3-

217, 3-218, 3-241, 3-244, 3-245, 3-248, 3-

252, 3-253, 3-254

Plants, 3-13, 3-14, 3-155, 3-156, 3-157, 3-158, 

3-159, 3-160, 3-161, 3-162

Point Baker, 1-5, 3-241, 3-244, 3-252

Port Alexander, 3-21, 3-42, 3-244

Port Protection, 3-244, 3-245

Preferred Alternative, 2-16

prohibitions, 1-3, 1-5, 1-8, 1-15, 1-16, 2-5, 2-9, 

2-11, 2-12, 2-14, 2-15, 2-16, 2-17, 2-19, 3-17,

3-26, 3-51, 3-58, 3-205, 3-206, 3-208, 3-209,

3-210, 3-211, 3-212, 3-213, 3-215, 3-216, 3-

217, 3-218, 3-219

PTSQ, 1-11, 1-14, 2-1, 2-11, 2-12, 2-14, 2-15, 2-

16, 2-21, 3-3, 3-4, 3-50, 3-53, 3-135, 3-136, 3-

137, 3-141, 3-152, 3-158, 3-166, 3-175, 3-

176, 3-251, 7-4 

public utility system, 3-179

Purpose and Need, 1-5 

PWSQ, 2-1, 2-11, 2-12, 2-14, 2-15, 2-16

Queen Charlotte goshawk, 3-14, 3-92, 3-94, 3-

113

Recreation and Tourism, 2-22, 3-15, 3-43, 3-46, 

3-48, 3-56, 3-57, 3-181, 3-183

Recreation Places, 3-183, 3-191

red squirrel, 3-95, 3-102, 3-103, 3-122, 3-126

red-breasted sapsucker, 3-103, 3-122

Research Natural Areas, 3-7, 3-16, 3-177

reserve trees, 3-174

river otter, 3-98, 3-118, 3-128

RMA (Riparian Management Area), 2-25, 2-28, 

3-69, 3-75, 3-98, 3-110, 3-137

Roadless Area, 1-1, 1-3, 1-9, 1-15, 2-3, 2-6, 2-7, 

2-11, 2-12, 2-13, 2-15, 2-16, 2-18, 2-19, 2-21,

2-26, 3-9, 3-10, 3-11, 3-12, 3-14, 3-18, 3-20,

3-21, 3-22, 3-51, 3-52, 3-58, 3-164, 3-169, 3-

178, 3-194, 3-204, 3-205, 3-207, 3-208, 3-

209, 3-210, 3-211, 3-212, 3-213, 3-214, 3-

215, 3-216, 3-217, 3-218, 3-219

Roadless Priority, 2-4, 2-5, 2-7, 2-11, 2-12, 2-13, 

2-14, 2-15, 2-16, 2-18, 2-19, 2-23, 2-26, 3-18,

3-23, 3-24, 3-26, 3-58, 3-59, 3-60, 3-80, 3-82,

3-111, 3-112, 3-137, 3-138, 3-139, 3-167, 3-

168, 3-169, 3-170, 3-179, 3-194, 3-255

ROS (Recreation Opportunity Spectrum), 3-15, 

3-16, 3-56, 3-182, 3-183, 3-188, 3-189, 3-190,

3-191, 3-193, 3-220

Sacred Sites, 3-16

salable minerals, 3-57, 3-177, 3-178, 3-180

salmon harvesting, 2-22, 3-33, 3-57

Saxman, 1-6, 3-241, 3-244, 3-253

Scenery, 2-3, 2-21, 3-11, 3-12, 3-221, 3-223, 3-

224

Sensitive Species, 3-89, 3-91, 3-92, 3-94, 3-95, 

3-113, 3-133, 3-140, 3-155

Sitka, 1-5, 1-6, 1-7, 2-5, 2-12, 3-5, 3-19, 3-21, 3-

22, 3-23, 3-29, 3-30, 3-34, 3-38, 3-39, 3-44, 3-

45, 3-47, 3-48, 3-50, 3-54, 3-56, 3-62, 3-93, 3-

95, 3-96, 3-106, 3-108, 3-109, 3-116, 3-146, 

3-156, 3-157, 3-163, 3-165, 3-171, 3-173, 3-

174, 3-182, 3-184, 3-186, 3-187, 3-196, 3-

205, 3-206, 3-207, 3-210, 3-212, 3-220, 3-

235, 3-238, 3-241, 3-244, 3-247, 3-252, 3-

253, 3-254

Sitka black-tailed deer, 3-96, 3-247

Skagway, 1-3, 1-5, 3-9, 3-20, 3-29, 3-31, 3-33, 

3-44, 3-45, 3-46, 3-48, 3-50, 3-84, 3-143, 3-

164, 3-184, 3-187, 3-244, 3-245, 3-247, 3-

252, 3-253, 3-254

Soil, 1-11, 3-15

Special Interest Areas, 3-16, 3-151, 3-152, 3-

177

spruce grouse, 3-95, 3-108, 3-109, 3-111, 3-

125, 3-126, 3-127, 6-8, 6-26

Subsistence, 2-23, 2-27, 3-7, 3-29, 3-33, 3-60, 

3-89, 3-102, 3-120, 3-129, 3-239, 3-240, 3-

241, 3-242, 3-243, 3-244, 3-245, 3-248, 3-

249, 3-250, 3-253, 3-254
Index 8

Final EIS 8-4 Index

suitable timber land, -7, 2-12, 2-13, 2-14, 2-15, 

2-16, 2-17, 3-4, 3-175

Suitable Timber Lands, 3-175

Tenakee Springs, 1-5, 3-42, 3-224, 3-229, 3-

236, 3-244, 3-245, 3-247, 3-252

Thorne Bay, 1-5, 3-5, 3-19, 3-22, 3-23, 3-25, 3-

26, 3-40, 3-42, 3-53, 3-54, 3-156, 3-164, 3-

186, 3-188, 3-195, 3-196, 3-197, 3-219, 3-

244, 3-248, 3-252

Threatened and Endangered Species, 3-91, 3-

92, 3-140

Timber, 1-5, 1-14, 2-1, 2-2, 2-3, 2-4, 2-5, 2-6, 2-

7, 2-8, 2-10, 2-11, 2-12, 2-13, 2-14, 2-15, 2-

16, 2-17, 2-18, 2-19, 2-21, 2-22, 2-23, 2-26, 2-

27, 2-29, 3-3, 3-4, 3-5, 3-7, 3-18, 3-24, 3-25, 

3-32, 3-34, 3-35, 3-36, 3-37, 3-38, 3-39, 3-40,

3-42, 3-50, 3-51, 3-52, 3-54, 3-55, 3-58, 3-59,

3-60, 3-61, 3-69, 3-72, 3-73, 3-77, 3-78, 3-79,

3-81, 3-85, 3-89, 3-98, 3-103, 3-104, 3-106, 3-

107, 3-109, 3-111, 3-112, 3-113, 3-117, 3-

124, 3-126, 3-127, 3-132, 3-136, 3-137, 3-

147, 3-148, 3-160, 3-161, 3-162, 3-167, 3-

168, 3-169, 3-171, 3-173, 3-175, 3-176, 3-

177, 3-179, 3-188, 3-193, 3-194, 3-195, 3-

197, 3-204, 3-205, 3-207, 3-208, 3-209, 3-

210, 3-211, 3-212, 3-213, 3-214, 3-215, 3-

216, 3-217, 3-218, 3-219, 3-224, 3-237, 3-

251, 3-252, 3-255

Timber Employment, 3-34

timber harvest, 1-1, 1-5, 1-7, 1-8, 1-11, 1-12, 1-

13, 1-14, 1-15, 1-16, 2-1, 2-2, 2-4, 2-5, 2-6, 2-

8, 2-10, 2-11, 2-12, 2-13, 2-14, 2-15, 2-16, 2-

18, 2-19, 2-22, 2-23, 2-24, 2-25, 2-29, 3-3, 3-

5, 3-14, 3-15, 3-16, 3-17, 3-23, 3-25, 3-26, 3-

34, 3-39, 3-50, 3-51, 3-52, 3-53, 3-54, 3-55, 3-

57, 3-58, 3-59, 3-61, 3-66, 3-69, 3-71, 3-72, 3-

74, 3-75, 3-80, 3-81, 3-82, 3-83, 3-84, 3-85, 3-

89, 3-96, 3-98, 3-99, 3-102, 3-103, 3-104, 3-

107, 3-108, 3-109, 3-110, 3-111, 3-115, 3-

116, 3-118, 3-119, 3-120, 3-121, 3-123, 3-

124, 3-125, 3-126, 3-127, 3-128, 3-132, 3-

135, 3-137, 3-138, 3-139, 3-140, 3-141, 3-

145, 3-146, 3-147, 3-148, 3-149, 3-150, 3-

152, 3-153, 3-158, 3-159, 3-160, 3-161, 3-

162, 3-163, 3-164, 3-166, 3-169, 3-170, 3-

171, 3-172, 3-173, 3-176, 3-182, 3-188, 3-

189, 3-192, 3-193, 3-194, 3-195, 3-220, 3-

222, 3-238, 3-240, 3-241, 3-243, 3-245, 3-

247, 3-249, 3-250, 3-251, 3-254, 3-255

timber industry, 1-14, 2-23, 2-24, 2-27, 3-3, 3-5, 

3-34, 3-35, 3-40, 3-59, 3-175, 3-254

Timber Management, 2-29

Timber Priority, 2-2, 2-4, 2-5, 2-8, 2-14, 2-15, 2-

18, 2-19, 2-23, 2-26, 2-29, 3-18, 3-24, 3-25, 3-

51, 3-54, 3-58, 3-59, 3-60, 3-81, 3-112, 3-137, 

3-167, 3-168, 3-169, 3-179, 3-194, 3-204, 3-

205, 3-207, 3-208, 3-209, 3-210, 3-211, 3-

212, 3-213, 3-214, 3-215, 3-216, 3-217, 3-

218, 3-219, 3-255

Timber Sale Program, 2-2, 3-5, 3-195, 3-197

Timber Suitability, 2-2, 3-51

Tourism, 2-26, 3-47, 3-56, 3-183, 3-222

transmission line, 2-2, 3-116, 3-122, 3-160, 3-

161, 3-162, 3-164, 3-165, 3-170, 3-237

TTRA, 1-5, 1-14, 2-4, 3-75, 3-110, 3-136

Vancouver Canada goose, 3-103, 3-122, 3-123

Viewsheds, 2-14, 3-224, 3-225, 3-226, 3-231

Visual Management System, 3-221

water, 1-10, 1-12, 1-13, 2-2, 2-3, 2-7, 2-19, 2-20, 

3-5, 3-10, 3-12, 3-13, 3-15, 3-46, 3-56, 3-61,

3-100, 3-102, 3-105, 3-115, 3-116, 3-118, 3-

124, 3-128, 3-129, 3-131, 3-132, 3-134, 3-

135, 3-136, 3-141, 3-142, 3-143, 3-151, 3-

152, 3-156, 3-157, 3-162, 3-163, 3-164, 3-170

Water, 1-8, 1-12, 2-3, 2-6, 2-10, 2-20, 3-10, 3-

12, 3-15, 3-65, 3-128, 3-141, 3-166

water quality, 1-13, 2-7, 3-10, 3-13, 3-15, 3-100, 

3-102, 3-115, 3-116, 3-124, 3-128, 3-132, 3-

141, 3-170

Water Quality, 1-12, 3-128

water quantity, 1-12, 3-135

Watershed, 2-4, 2-5, 2-6, 2-7, 2-11, 2-12, 2-13, 

2-18, 2-19, 2-26, 3-6, 3-7, 3-18, 3-23, 3-24, 3-

58, 3-59, 3-60, 3-80, 3-111, 3-134, 3-137, 3-

138, 3-139, 3-167, 3-168, 3-169, 3-179, 3-223

Watershed Priority, 2-4, 2-5, 2-6, 2-7, 2-11, 2-

12, 2-13, 2-18, 2-19, 2-26, 3-18, 3-23, 3-24, 3-

58, 3-59, 3-60, 3-80, 3-111, 3-137, 3-138, 3-

139, 3-167, 3-168, 3-169, 3-179

wetlands, 1-13, 3-61, 3-62, 3-71, 3-89, 3-98, 3-

103, 3-122, 3-124, 3-136, 3-146, 3-156, 3-

162, 3-181

Whale Pass, 3-241, 3-244

Wild and Scenic Rivers, 3-7 

Wilderness, 1-1, 1-7, 1-15, 3-6, 3-7, 3-9, 3-11, 3-

17, 3-72, 3-172, 3-176, 3-177, 3-179, 3-181, 

3-185, 3-188, 3-204, 3-213, 3-233, 3-234, 3-

235

Wildlife, 1-8, 1-10, 1-12, 3-2, 3-7, 3-13, 3-14, 3-

66, 3-71, 3-72, 3-74, 3-89, 3-90, 3-94, 3-96, 3-

97, 3-99, 3-104, 3-108, 3-109, 3-115, 3-116, 

3-126, 3-133, 3-155, 3-181, 3-186, 3-187, 3-

188, 3-213, 3-240, 3-246, 3-247, 3-250

wildlife viability, 3-126

Windthrow, 3-174

Wrangell, 1-5, 1-6, 2-5, 2-12, 3-5, 3-19, 3-20, 3-

22, 3-23, 3-25, 3-26, 3-29, 3-33, 3-38, 3-44, 3-

45, 3-47, 3-50, 3-54, 3-99, 3-108, 3-156, 3-

157, 3-164, 3-182, 3-186, 3-188, 3-193, 3-

195, 3-230, 3-233, 3-236, 3-237, 3-240, 3-

241, 3-244, 3-245, 3-248, 3-252, 3-253, 3-254
Index 8

Final EIS 8-5 Index

Yakutat, 1-3, 1-5, 2-5, 2-12, 3-2, 3-5, 3-21, 3-22, 

3-23, 3-29, 3-42, 3-50, 3-54, 3-62, 3-65, 3-68,

3-70, 3-76, 3-77, 3-78, 3-79, 3-84, 3-86, 3-87,

3-88, 3-93, 3-95, 3-96, 3-97, 3-101, 3-105, 3-

109, 3-115, 3-129, 3-130, 3-156, 3-177, 3-

186, 3-188, 3-240, 3-241, 3-244, 3-245, 3-

252, 3-253, 3-254

young-growth harvest, 1-10, 1-14, 2-21, 3-3, 3-5, 

3-6, 3-14, 3-50, 3-57, 3-69, 3-73, 3-74, 3-80,

3-81, 3-82, 3-83, 3-84, 3-85, 3-103, 3-107, 3-

110, 3-115, 3-117, 3-118, 3-119, 3-120, 3-

123, 3-124, 3-125, 3-126, 3-127, 3-137, 3-

138, 3-151, 3-159, 3-175, 3-194, 3-195, 3-

196, 3-197, 3-205, 3-206, 3-207, 3-208, 3-

209, 3-211, 3-212, 3-214, 3-215, 3-216, 3-

217, 3-218, 3-220, 3-223, 3-224, 3-232, 3-

233, 3-234, 3-235, 3-236, 3-237, 3-248
 Index 8

Final EIS 8-6 Glossary

This page intentionally left blank.
APPENDIX A

STATE OF ALASKA’S PETITION

FOR RULEMAKING
Appendix A

Final EIS State of Alaska’s Petition for Rulemaking

Appendix A

State of Alaska’s Petition for Rulemaking

Note: The full petition, including exhibits, can be found here: 

https://www.fs.usda.gov/project/?project=54511
Appendix A

Final EIS A-1 State of Alaska’s Petition for Rulemaking
Appendix A

State of Alaska’s Petition for Rulemaking A-2 Final EIS
Appendix A

Final EIS A-3 State of Alaska’s Petition for Rulemaking
Appendix A

State of Alaska’s Petition for Rulemaking A-4 Final EIS
Appendix A

Final EIS A-5 State of Alaska’s Petition for Rulemaking
Appendix A

State of Alaska’s Petition for Rulemaking A-6 Final EIS
Appendix A

Final EIS A-7 State of Alaska’s Petition for Rulemaking
Appendix A

State of Alaska’s Petition for Rulemaking A-8 Final EIS
Appendix A

Final EIS A-9 State of Alaska’s Petition for Rulemaking
Appendix A

State of Alaska’s Petition for Rulemaking A-10 Final EIS

This page is intentionally left blank.
APPENDIX B

CUMULATIVE EFFECTS
Appendix B

Final EIS B-i Cumulative Effects

Appendix B

Cumulative Effects

CONTENTS

Introduction ............................................................................................................................................ B-1

Assumptions .......................................................................................................................................... B-2

Timeframe for Analysis .......................................................................................................................... B-2

Relevant Past, Present, and Reasonably Foreseeable Actions............................................................ B-2

Rulemaking and Policy ........................................................................................................................B-2

Roadless Rules .............................................................................................................................. B-2

Locatable and Leasable Minerals .................................................................................................. B-2

2012 Planning Rule........................................................................................................................ B-3

Subsistence Regulations for Tongass National Forest Submerged Lands ................................... B-3

USDA Strategic Plan 2018 – 2022................................................................................................. B-3

Tongass Young-growth Transition ................................................................................................. B-4

Actions within the Boundaries of the Tongass National Forest...........................................................B-4

References........................................................................................................................................... B-10

TABLES

Table B-1 Regional Projects Considered in Cumulative Effects Analyses ......................................... B-4

Table B-2 Interactions Between Resources and Actions or Projects ................................................. B-9
Appendix B

Final EIS B-1 Cumulative Effects

Appendix B

Cumulative Effects

Introduction

Prior to September 14, 20201, the Council on Environmental Quality (CEQ) regulations defined 

cumulative effects as “the impact on the environment which results from the incremental impact of the 

action when added to other past, present, and reasonably foreseeable future actions regardless of what 

agency (Federal or non-Federal) or person undertakes such other actions. Cumulative impacts can result 

from individually minor but collectively significant actions taking place over a period of time” (40 Code of 

Federal Regulations [CFR] 1508.7). Cumulative actions are defined as “actions, which when viewed with 

other proposed actions, have cumulatively significant impacts and should therefore be discussed in the 

same impact statement” (40 CFR 1508.25). Cumulative effects are discussed in detail for each resource 

in the Environmental Impact Statement (EIS). This document discusses the projects considered and 

records which projects were considered for each resource.

For cumulative impacts to accrue, there must first be an impact from the action under review that can then 

be added to the impacts of other past, present, or reasonably foreseeable future actions that affect the 

same resource. The proposed Alaska Roadless Rule alternatives would affect management of roadless 

areas on the Tongass, as it relates to what and where harvests and road building could occur under the 

2016 Tongass Land and Resource Management Plan (Forest Plan). The 2016 Forest Plan in turn will 

guide the management the Forest.

For most resources, the analysis area for the Alaska Roadless Rule constitutes lands within the 

boundaries of the Tongass National Forest (approximately 17.9 million acres, including 1.2 million acres 

of non-National Forest System [NFS] lands). However, the effect to Roadless Areas is considered both 

locally, at the Forest-scale, and nationally. At the national scale, the affected environment for the Alaska 

Roadless Rule constitutes all NFS lands currently, or in the past, managed under the Roadless Rule. As 

noted in CEQ’s guidance memorandum of June 24, 2005 (CEQ 2005), the effects of past actions can 

generally be captured by a description of the affected environment, which is detailed in the Chapter 3 of 

this EIS. Cumulative effects to Roadless Areas nationwide are presented in Chapter 3, Key Issue 1 –

Protection of Roadless Area Characteristics.

The Forest Service and U.S. Department of Agriculture (USDA) have a number of ongoing or recently 

finalized rulemaking and policy efforts that alone or in combination with the Alaska Roadless rule might 

affect management of NFS lands and resources. As these rules and policies are finalized, the Agency 

can integrate or clarify certain provisions within each rule or policy to ensure consistency, clarity, and

effectiveness with other ongoing initiatives. The relationships of these efforts to the proposed and 

alternative planning rules are discussed below.

Cumulative effects have been discussed throughout Chapter 3. The discussion of effects for many of the 

resources explores the effects of the alternatives in combination with other ongoing initiatives, strategies, 

policies, laws, etc.

1 On September 14, 2020, the Council on Environmental Quality’s revised NEPA regulations became effective (see 

85 FR 43304). Those regulations apply to NEPA processes begun after September 14, 2020 (40 CFR 1506.13). 

While agencies may apply CEQ’s revised regulations to ongoing activities and environmental documents begun 

before September 14, 2020, the Forest Service has elected to complete this NEPA process using the prior 

regulations, recognizing that where existing agency NEPA procedures are inconsistent with CEQ’s revised 

regulations CEQ’s revised regulations govern unless there is a clear and fundamental conflict with the requirements 

of another statute. 
Appendix B

Cumulative Effects B-2 Final EIS

Assumptions

Projects and actions included in the cumulative effects analysis were identified by reviewing past records, 

reviewing scoping comments, interviewing knowledgeable individuals, analyzing the existing condition of 

the project area using the Tongass and other geographic information system (GIS) layers, reviewing 

current plans, and, where necessary, making reasonable assumptions. An underlying assumption 

throughout this EIS is that none of the Alaska Roadless Rule alternatives propose or authorized specific 

actions on the ground. Although road construction and/or timber harvest could potentially increase within 

some roadless areas, none of the alternatives predict a projected timber sale quantity (PTSQ) greater 

than the amount disclosed in the 2016 Forest Plan Amendment EIS (46 million board feet [MMBF] per 

year). On-the-ground activities, which would result in both direct and indirect effects, would be based on 

site-specific proposals, which are currently unknown, and would be addressed in subsequent project 

environmental analyses, including cumulative effects. 

Timeframe for Analysis

The timeframe for this cumulative effects analysis encompasses past and future activities. Past activities 

include timber harvest and other activities that date back over 70 years, while future activities consider 

timber harvest up to 100 years in the future. Most other future activities can only be considered as 

reasonably foreseeable about 25 years or less into the future because of uncertainties beyond that point.

Relevant Past, Present, and Reasonably Foreseeable Actions 

Rulemaking and Policy

Roadless Rules

In determining the cumulative effects, the Agency considered the current status of the various roadless 

rules:

 The Roadless Area Conservation Rule, issued in 2001 (36 CFR Part 294);

 The Idaho Roadless Rule, issued in 2008 (36 CFR Part 294 subpart C);

 The Colorado Roadless Rule, issued in (36 CFR Part 394 subpart D); and

 Utah petition for a Utah Roadless Rule.

The Agency also considered current roadless area guidance, including Secretary’s Memorandum 1042-

157 (USDA 2012) and the Forest Service Chief’s delegation of authority to approve exceptions to the 

2001 Roadless Rule (USDA Forest Service 2018). The potential for combined effects of the alternatives 

in this programmatic EIS were considered with the anticipated effects of the Idaho Roadless Rule, the 

Colorado State Roadless Rule, and the Utah State rulemaking petition and preliminary alternatives. While 

it is possible that changes to roadless area conservation could happen at a national scale, by future 

congressional or executive action, these possibilities for change are too speculative and, therefore, are 

not analyzed.

The effects of the Idaho Roadless Rule, the Colorado State Roadless Rule, and the Utah State 

rulemaking petition would not overlap; together they would modify the Roadless Rule or remove roadless 

lands. See Chapter 3, Key Issue 1 – Protection of Roadless Area Characteristics for discussion.

Locatable and Leasable Minerals

In September 2018, the Forest Service published two separate Advance Notices of Proposed Rulemaking 

(ANPR) in the Federal Register as first steps to update the agency’s regulations that address surface 

activities associated with exploration and development of locatable minerals, and to update regulations 

that address leasing and subsequent development of oil and gas resources. Revision of the regulations 

governing both locatable minerals and oil and gas resources (36 CFR 228 Subparts A & E) will help 

achieve more efficient permitting processes, which in turn reduces regulatory burdens. This would have a 
Appendix B

Final EIS B-3 Cumulative Effects

positive effect on locatable and leasable mineral development. While development of locatable minerals 

within the Tongass would not be measurably affected by any of the Roadless Rule alternatives, access to 

leasable minerals could be improved within Roadless and Timber Priority Alaska Roadless Areas (ARAs), 

which would be a cumulative positive effect on leasable mineral development.

Tongass Forest Plan – Karst Amendment

The Tongass National Forest amended the Tongass Forest Plan in August 2020. The amendment 

removed Forest Plan Standard S-YG-KC-02 related to commercial timber harvest of young growth on 

lands identified as moderate vulnerability karst, modify Standard S-YG-KC-03. The purpose is to broaden 

the availability of young growth that is suitable for timber production by making the restrictions 

comparable to those for old-growth harvest on moderate vulnerability karst. The changes allow the 

transition to predominantly young-growth harvest to proceed more efficiently.

Tongass Forest Plan – Central Tongass and South Revilla Project-specific 

Scenery Standard Amendment

The Tongass National Forest is considering a project-specific amendment to the Tongass Forest Plan to 

allow the Central Tongass Project and the South Revilla Project to proceed in a manner that fulfills each

project's stated purpose and need while otherwise being consistent with the Plan. The amendment would 

be to relax the Scenic Integrity Objectives (Forest Plan, p. 4-54) on portions of Mitkof, Zarembo, and 

Wrangell Islands, and Portage Bay located on Kupreanof Island and on Revilla Island, to improve timber 

sale economics for the commercial timber sales undertaken as part of this project only. 

2012 Planning Rule

The 2012 planning rule for land management planning for the National Forest System was published in 

the Federal Register (FR) on April 9, 2012 (77 FR 21162), and it became effective on May 9, 2012. It was 

developed through the most collaborative rulemaking effort in Agency history to ensure an adaptive land 

management planning process that is inclusive, efficient, collaborative and science-based to promote 

healthy, resilient, diverse and productive National Forests and Grasslands. In January 2015, the Forest 

Service published the final planning directives, the key set of agency guidance documents that direct 

implementation of the 2012 planning rule. The 2016 Forest Plan Amendment was consistent with the new 

planning rule. Future Plan amendments or revisions would be consistent with the rule as well.

Subsistence Regulations for Tongass National Forest Submerged Lands

In May 2018, the Secretaries of the Departments of Agriculture and the Interior published the final rule for 

the Federal Subsistence Management Regulations for the Tongass National Forest Submerged Lands.

This rule added submerged public lands within the Tongass National Forest to the subsistence 

regulations. Additional listings will be published as the Bureau of Land Management and the Forest 

Service continue their review of pre-statehood withdrawals. This rule would not affect the roadless areas, 

and none of the Alaska Roadless Rule alternatives would affect access or use of submerged lands for 

subsistence purposes.

USDA Strategic Plan 2018 – 2022

The USDA Strategic Plan for 2018–2022 (USDA 2018) includes a goal to ensure national forests and 

grasslands are managed to ensure productive and sustainable use. Objectives of this goal include 

contributing to the economic health of rural communities through use and access opportunities and 

ensuring lands and watersheds are sustainable, healthy, and productive. 

The Forest Service’s Strategic Plan for 2015-2020 (USDA Forest Service 2015) goals and objectives 

include sustaining the Nation’s forests and grasslands by fostering resilient, adaptive ecosystems to 
Appendix B

Cumulative Effects B-4 Final EIS

mitigate climate change; mitigating wildfire risk; and delivering benefits to the public by providing 

abundant clean water, strengthening communities, and connecting people to the outdoors.

Tongass Young-growth Transition

On July 2, 2013, Secretary of Agriculture Thomas Vilsack issued Memorandum 1044-009, Addressing 

Sustainable Forestry in Southeast Alaska (USDA 2013). The memorandum directs management of the Tongass 

National Forest to expedite the transition away from old-growth timber harvesting and towards a forest products 

industry that uses predominantly second-growth – or young-growth – forests. Secretary Vilsack’s memorandum 

also directs that the transition must be implemented in a manner that preserves a viable timber industry that 

provides jobs and opportunities for Southeast Alaska residents. USDA's goal is to effectuate this transition, over 

the next 10 to 15 years, so that at the end of this period the vast majority of timber sold by the Tongass will be 

young growth. The Forest Plan was amended in 2016 to effectuate this transition.

Each of the Alaska Roadless Rule action alternatives would help facilitate this transition by making more forest, 

including young growth, available for planning and offering timber sales under the 2016 Plan and increasing the 

Forest Service’s flexibility in locating harvests. None of the alternatives would alter the PTSQ. It is expected that 

the each of the Alaska Roadless Rule alternatives would improve the agency’s goal of transitioning away from 

old-growth harvesting towards a predominantly young-growth based industry.

Actions within the Boundaries of the Tongass National Forest

The 2016 Forest Plan FEIS, Appendix C (USDA Forest Service 2016) provides a full and detailed list of 

all the projects considered in the cumulative effects analysis, which has not changed substantially to date.

Such reasonably foreseeable activities include, but are not limited to, timber harvest, residential 

development, mining, recreation and tourism, and road construction. This section summarizes and 

updates the list of past, present, and future activities considered based on a review of published material 

and available information about the Tongass National Forest and adjoining lands on various agency 

websites and the scoping process. It also examines other past projects, but most importantly, by looking 

hard at current conditions, residual effects of past human actions and natural events are captured, 

regardless of which particular action or event contributed those effects. The CEQ issued an interpretive 

memorandum on June 24, 2005 regarding analysis of past actions which states, “agencies can conduct 

an adequate cumulative effects analysis by focusing on the current aggregate effects of past actions 

without delving into the historical details of individual past actions.” For these reasons, the primary 

method of analyzing past actions is based on the cumulative change in environmental conditions to the 

present, as described in the affected environment sections of the EIS. To keep the cumulative effects 

analysis useful, manageable, and concentrated on the effects that are meaningful, greater effort is given 

to future activities that are more certain and geographically close to the affected lands with a focus on 

issues of greatest concern. 

Table B-1 lists and describes the past, present, and reasonably foreseeable projects and activities that 

are considered for analysis of cumulative effects. Table B-2 identifies the primary areas with potential 

interactions among the identified projects and actions and the primary resource areas.

Table B-1

Regional Projects Considered in Cumulative Effects Analyses

Action or Activity Location Timing Description

Past Actions

Timber harvests and 

road construction

Throughout 

Southeast 

Alaska

1950s to 

present

Over 460,000 acres of forest have been harvested and 

9,400 miles of road have been constructed on Forest as of 

2016. Additionally, there have been over 450,000 acres of 

forest land harvested on non-National Forest System (NFS)

lands within the Forest boundary. Harvests and road 

construction have been concentrated on Prince of Wales 

and adjacent islands with large portions on Wrangell, Mitkof, 

Kupreanof, Kuiu, Revillagigedo, and Baranof Islands.
Appendix B

Final EIS B-5 Cumulative Effects

Table B-1 (continued)

Regional Projects Considered in Cumulative Effects Analyses

Action or Activity Location Timing Description

Land Adjustments Throughout 

Southeast 

Alaska

Various NFS lands have been conveyed to non-federal parties under 

the Native Allotment Act, Alaska Native Claims Settlement 

Act (ANCSA), Alaska National Interest Lands Conservation 

Act (ANILCA) and other authorities. In 2015, Sealaska 

Corporation received its final ANSCA entitlement and 

conveyance of 70,075 acres. Public Law 113-291 added 8 

new Land Use Designation (LUD) II areas, containing 

152,000 acres. Other land adjustments have occurred in the 

past and the Forest Service began acquiring lands at Cube 

Cove on Admiralty Island in 2016 and continues through the 

present.

Mining Throughout 

Southeast 

Alaska

1800s to 

present

Historic mines include the Treadwell Mine and the Alaska 

Juneau Mine in Juneau; the Kensington and Jualin mines 

north of Juneau (recently reopened); the Ross-Adams 

uranium mine on Prince of Wales Island; the undeveloped 

Quartz Hill molybdenum deposit in the non-Wilderness 

Misty-Fjord National Monument; copper mines in the 

Ketchikan area; and many other deposits that were explored 

or developed throughout the Tongass. Mineral exploration 

and extraction have continued, at some level, since the first 

discoveries. More recently, the Greens Creek mine has 

been operating since the late 1980s, less three years during 

a shutdown in the 1990s, and the Kensington Mine 

reopened in 2010.

Energy Throughout 

Southeast 

Alaska

1800s to 

present

There are about 20 existing hydropower projects on the 

Forest with a total capacity of about 200 megawatts.

Recreation and 

Tourism

Throughout 

Southeast 

Alaska

1800s to 

present

Tourism has occurred in Southeast Alaska since the late 

1800s. Over 1.2 million people visited Southeast Alaska in 

2016. Tourism activities on the Forest include use hunting 

and fishing outfitters and guides, helicopter landings and 

tours, access of the Forest from lodges, and enjoying Forest 

Service visitor centers. Dispersed recreation has steadily 

increased in Southeast Alaska along with the growth of the 

tourism industry, the growth of communities, and the 

development of roads.

Community 

Development

Throughout 

Southeast 

Alaska

1800s to 

present

Settlement and community development in Southeast 

Alaska occurred primarily from the late 1800s to the present. 

Mining, fishing, and fish canneries were the primary early 

factors encouraging settlement, later followed by logging. 

Today there are 32 communities in Southeast Alaska.

Eleven of these communities have less than 100 people 

ranging up to Juneau with over 33,000. The footprint of 

these communities ranges in size from a few acres to 

several thousand acres. Road development is associated 

with community development and is covered above under 

timber harvest activities.

Fish and Wildlife 

Habitat Enhancement 

and Regulatory Actions

Forest-Wide 1960s to 

present

A range of fish and wildlife habitat enhancement projects 

has occurred throughout Southeast Alaska. These projects 

were designed to improve forest, riparian, and stream

habitats for fish and wildlife. They include extensive precommercial thinning, riparian thinning, snag creation, 

instream and riparian rehabilitation; placement of large 

woody debris in streams; improving fish passage; and 

decommissioning roads. The number of locations and 

number of projects will vary year to year based on funding 

and need.
Appendix B

Cumulative Effects B-6 Final EIS

Table B-1 (continued)

Regional Projects Considered in Cumulative Effects Analyses

Action or Activity Location Timing Description

Yellow cedar decline Throughout 

Southeast 

Alaska

Past 50 

years

Yellow-cedar decline and mortality has dramatically 

changed many of the forests of Southeast Alaska and this 

decline is believed to have been climate related. Aerial 

surveys have mapped approximately 585,000 acres of 

decline in a wide band from western Chichagof and Baranof 

Islands to the Ketchikan area (USDA Forest Service and 

ADNR 2015).

Fire Throughout 

Southeast 

Alaska

Historical Because of high precipitation levels, fire has not been a 

major factor in shaping the forests of Southeast Alaska. 

However, approximately 400 to 500 acres have burned 

annually on the Tongass. 

Windthrow Events Throughout 

Southeast 

Alaska

Historical Small-scale windthrow events are very common throughout 

Southeast Alaska forests. These small events involve 

individual trees or small groups of trees. The open gaps in 

the canopy that result, allow young trees to colonize and fill 

the openings. Therefore, over time, complex, mixed-aged 

stands are produced. 

Present and Reasonably Foreseeable Actions

Timber harvests and 

road construction

Throughout 

Southeast 

Alaska

Present + 

100 years

Harvests and road construction will continue under the 

Forest Plan and may vary year to year. The 2016 Forest 

Plan FEIS predicted harvests of old- and young-growth over 

42,000 and 284,000 acres, respectively, over the next 100 

years with about 1,000 miles of new road. Harvests would 

affect an estimated 3.5 percent of the 9.7 million acres of 

forested land, 6 percent of all productive forest land, and 

less than 1 percent of productive old growth forests on the 

Tongass over 100 years. Harvests and road construction 

are expected to continue as described in the 2016 Forest 

Plan FEIS and transition to a young-growth based industry 

over 15 years. Additional harvests and road construction are 

expected on other lands.

Land Adjustments Forest-wide 2018-2019 Public Law 115-31 authorized land exchange between the 

Alaska Mental Health Trust Authority and the Forest 

Service. The land exchange encompasses lands from nine

remote Alaska communities and comprises approximately 

18,000 non-federal acres and 21,000 federal acres. Timber 

harvests are prohibited on the lands received from the 

Alaska Mental Health Trust Authority but are expected to 

occur on the lands provided. 

On the Tongass National Forest, the State of Alaska has 

approximately 12,145 acres remaining of land entitlement 

under the Alaska Statehood Act (43 CFR 2627.1(a)).

The Forest Service began purchasing lands at Cube Cove

and continues through the present and into the near future.

At almost 23,000 acres, it was the largest single in-holding 

in the Admiralty Island National Monument.
Appendix B

Final EIS B-7 Cumulative Effects

Table B-1 (continued)

Regional Projects Considered in Cumulative Effects Analyses

Action or Activity Location Timing Description

Mining Throughout 

Southeast 

Alaska

Present 

and 

beyond

Mineral exploration and development are expected to 

continue on the Forest and adjacent lands. Both the Greens 

Creek Mine on Admiralty Island and the Kensington Mine 

north of Juneau are active mines and expected to continue 

for some years based on successful continued exploration. 

As a result of successful exploration, the Greens Creek 

Mine has periodically sought and been authorized to expand 

its tailings tailings—the material left after the minerals have 

been removed—storage facility, most recently in 2013. 

Continued expansion is expected at both mines. Active 

mines generate waste water, waste rock, air emissions, and 

tailings. Several other sites are being prospected and 

explored with the intent to develop new mines. Development 

of leasable minerals, including geothermal, could occur, but 

there are no current leasable mineral activities on the 

Tongass and they are unlikely soon.

Energy Throughout 

Southeast 

Alaska

Present 

and 

beyond

Hydropower will continue to be an important source of 

energy on the in Southeast Alaska. New sites, such as 

Angoon Hydroelectric and Sweetheart Lake, are expected to 

be developed and decrease community reliance on diesel. 

Transmission lines will be constructed to deliver energy to 

communities.

Recreation and 

Tourism

Throughout 

Southeast 

Alaska

Present 

and 

beyond

Over the long-term, recreation and tourism are expected to 

continue and increase in the future.

In the near-term, levels of recreation and tourism are 

uncertain. At the time of writing, industry and government 

restrictions indicate that there will be no big cruise ships 

traveling to Southeast Alaska until at least July (Hseih 2020)

due to the ongoing coronavirus pandemic. The effects of the 

travel restrictions on recreation and tourism are uncertain, 

but it is expected there will be sharp decline in 2020.

General – Climate 

Change

Throughout 

Southeast 

Alaska

Present 

and 

beyond

Some climate models for Southeast Alaska predict rising 

temperatures, a 10 percent decrease in summer 

precipitation in portions of the region, and decreased soil 

moisture due to increased evaporation during warmer, drier 

summer weather. These factors may lead to an increase in 

fire frequency and severity, further yellow-cedar decline, 

higher rates of insect and disease infestations, more severe 

windthrow events, and uncertain effects on stream flows, 

water temperature, and fisheries.

Fish and Wildlife 

Habitat Enhancement

Throughout 

Southeast 

Alaska

Present 

and 

beyond

Fish and wildlife habitat enhancement projects will continue 

to be implemented on the Forest and other lands.

Yellow Cedar Decline Throughout 

Southeast 

Alaska

Present 

and 

beyond

As the climate continues to warm, yellow-cedar decline is 

likely to continue to spread, especially in the south and east. 

Conversely, yellow-cedar appears to be spreading 

northward as climate warms, into areas that retain snow 

longer into the spring.

Fire Throughout 

Southeast 

Alaska

Present 

and 

beyond

Approximately 400 to 500 acres burn annually on the 

Tongass National Forest. Due to climate change, there may 

be an increased risk of forest fires but the effects are likely 

to be minor at the forest level.

Regional 

Transportation

Throughout 

Southeast 

Alaska

Present 

and 

beyond

The State of Alaska will continue to maintain and improve its 

regional transportation system including road and marine 

systems. As funding allows, new road systems may be 

developed to connect communities. 
Appendix B

Cumulative Effects B-8 Final EIS

Table B-1 (continued)

Regional Projects Considered in Cumulative Effects Analyses

Action or Activity Location Timing Description

Other Transportation 

Projects

Throughout 

Southeast 

Alaska

2016 and 

beyond

The Forest Service will conduct transportation projects 

which will vary year to year based on funding and need. 

These include maintaining or improving existing roads and 

bridges, placing roads in storage, paving existing dirt roads, 

and improving fish passage at culverts. The State and local 

communities will also implement various transportation 

projects such as paving or resurfacing roads, road 

realignments, safety improvements, vessel and marine 

terminal improvements, etc.
Appendix B

Final EIS B-9 Cumulative Effects

Table B-2

Interactions Between Resources and Actions or Projects

Actions or Projects

Roadless AreasResource-based IndustriesFish, Wildlife and BiodiversityClimateKarstSensitive and Invasive PlantsTransportationEnergyTimberMineralsRecreationScenerySubsistence

Past

Timber harvests and road construction X X X X X X X X X X

Land Adjustments X X X X X X X X X X X

Mining X X X X

Energy X X X X X X X X X X

Recreation and Tourism X X X X X X X

Community Development X X X X X X X X X

Fish and Wildlife Habitat Enhancement X X X

Yellow-cedar decline X X X X

Fire X X X

Windthrow Events X X X

Present and Reasonably Foreseeable 

Timber harvests and road construction X X X X X X X X X X

Land Adjustments X X X X X X X X X X X

Mining X X X X

Energy X X X X X X X X X X

Recreation and Tourism X X X X X X X

General – Climate Change X X X X X X X

Fish and Wildlife Habitat Enhancement X X X

Yellow Cedar Decline X X X

Fire X X X

Regional Transportation X X X X X X X X X X X

Other Transportation Projects X X X X X X X X X X X
Appendix B

Final EIS B-10 Cumulative Effects

References

USDA (U.S. Department of Agriculture). 2018. USDA Strategic Plan FY 2018-2022. United States 

Department of Agriculture.

USDA. 2013. Secretary’s Memorandum 1044-009, Addressing Sustainable Forestry in Southeast Alaska.

USDA. 2012. Secretary’s Memorandum 1042-157. 

USDA Forest Service. 2018. Chief’s letter to Regional Foresters. October 24.

USDA Forest Service. 2016. Tongass Land and Resource Management Plan, Final Environmental Impact 

Statement Plan Amendment. R10-MB-769e, f. June. Available online at: 

https://www.fs.usda.gov/detail/tongass/landmanagement/planning/?cid=stelprd3801708

USDA Forest Service. 2015. USDA Forest Service Strategic Plan: FY 2015–2020. FS-1045.

USDA Forest Service and ADNR (Alaska Department of Natural Resources). 2015. Forest Health 

Conditions in Alaska-2014, A Forest Health Protection Report. Edited by T. Huette and G. 

Duboise R10-PR-032. February 2015. Available online at: 

http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprd3834154.pdf 
APPENDIX C

REFERENCE DATA TABLES FROM 

THE 2016 FOREST PLAN 

AMENDMENT FEIS BY RESOURCE
Appendix C

Final EIS C-i Outfitter/Guide Use Area Data Tables

Appendix C

Outfitter/Guide Use Area Data Tables

Table C-1 Reported Outfitter/Guide Service Days by Outfitter/Guide Use Area ................................ C-1

Table C-2 Change in Roadless Area Acres by Outfitter/Guide Use Area and Alternative ................. C-4

Table C-3 Change in Development LUD Acres without Roadless Protection by Outfitter/Guide 

Use Area and Alternative ................................................................................................... C-9

Table C-4 Change in Old-Growth Suitable Acres by Outfitter/Guide Use Area and Alternative....... C-14

Table C-5 Change in Young-Growth Suitable Acres by Outfitter/Guide Use Area and Alternative.. C-19
Appendix C

Final EIS C-1 Outfitter/Guide Use Area Data Tables

Table C-1

Reported Outfitter/Guide Service Days by Outfitter/Guide Use Area

Outfitter/Guide Use Area

Reported Service Days

2013 2014 2015 2016 2017

Grand 

Total

Annual 

Average

01-01 SKAGWAY AREA 5,392 3,716 3,496 3,561 3,411 19,576 3,915

01-02 HAINES AREA 0 0 0 0 0 0 0

01-03 EAST CHILKATS 446 454 179 146 246 1,471 294

01-04A BERNERS BAY 70 0 95 0 6 171 34

01-04B N. JUNEAU COAST 175 72 121 89 6 463 93

01-04C TAKU INLET 10 0 0 0 30 40 8

01-04D SLOCUM INLET 264 109 90 171 108 742 148

01-04E JUNEAU ICEFIELD 0 0 28 72 72 172 34

01-05A TAKU HARBOR 91 113 93 256 171 724 145

01-05B PORT SNETTISHAM 798 1,009 736 606 748 3,897 779

01-05C WINDHAM BAY 784 805 873 1,080 638 4,180 836

01-05D TRACY ARM 97 134 145 152 181 709 142

01-05E FORDS TERROR 197 170 244 152 138 901 180

01-05F ENDICOTT ARM 268 510 653 808 584 2,823 565

04-01A GUT BAY, BARANOF 304 255 237 214 211 1,221 244

04-01B PORT ARMSTRONG 125 88 113 130 68 524 105

04-01C NELSON BAY 3 11 11 0 44 69 14

04-02A REDOUBT LAKE 296 117 171 223 30 837 167

04-02B WHALE BAY 269 229 289 235 173 1,195 239

04-02C NECKER ISLANDS 143 86 71 56 90 446 89

04-02D SW BARANOF 26 24 10 12 40 112 22

04-03 SITKA AREA 5,213 4,733 6,005 5,614 6,597 28,162 5,632

04-04A RODMAN BAY 250 428 385 347 508 1,918 384

04-04B KELP BAY 4,048 4,427 5,316 5,343 5,494 24,628 4,926

04-04C BARANOF WARM SPRINGS 103 152 91 64 102 512 102

04-05 SW ADMIRALTY 263 341 220 278 398 1,500 300

04-05B MITCHELL BAY 118 4 6 6 118 252 50

04-06A PYBUS BAY 704 731 623 580 644 3,282 656

04-06B ELIZA HARBOR 108 113 133 249 241 844 169

04-07A GAMBIER BAY 151 114 138 110 96 609 122

04-07B CANOE ROUTE 61 115 129 171 108 584 117

04-08 NE ADMIRALTY 5 0 197 152 147 501 100

04-09A SEYMOUR CANAL 48 65 105 93 88 399 80

04-09B PACK CREEK 692 915 710 1,202 1,020 4,539 908

04-10A GREENS CREEK 221 401 358 178 272 1,430 286

04-10B NW ADMIRALTY 103 103 93 79 88 466 93

04-11A PORT FREDERICK 10 15 78 1,358 3,021 4,482 896

04-11B FRESHWATER BAY 178 228 1,838 2,235 2,468 6,947 1,389

04-12 TENAKEE INLET 95 89 108 230 407 929 186

04-13 PERIL STRAIT 744 1,057 1,473 1,254 1,368 5,896 1,179

04-14 SLOCUM ARM 54 101 86 106 120 467 93

04-15A LISIANSKI 68 3 82 33 14 200 40

04-15B WEST YAKOBI ISLAND 13 12 74 119 100 318 64

04-15C STAG BAY 0 0 0 0 0 0 0

04-15D PORTLOCK HARBOR 0 0 0 0 0 0 0

04-16A POINT ADOLPHUS 343 136 776 547 507 2,309 462

04-16B NORTH CHICHAGOF 32 61 236 218 188 735 147

04-16C IDAHO INLET 1,249 1,509 1,776 1,174 1,357 7,065 1,413

04-16D PLI WILDERNESS 9 7 82 109 124 331 66

04-16E PORT ALTHORP 1,330 1,469 1,711 1,917 1,820 8,247 1,649

CRD 00-00NO AREA DESIGNATED 2,574 1,920 2,125 1,798 926 9,343 1,869

J01 JUNEAU ICEFIELD 1 - GILKEY 

BACKCOUNTRY

1,979 847 1,004 678 477 4,985 997

J02 JUNEAU ICEFIELD 2 - EAGLE 36 0 0 8 0 44 9

J03 JUNEAU ICEFIELD 3 - HERBERT 8,777 10,727 11,368 13,934 14,436 59,242 11,848
Appendix C

Outfitter/Guide Use Area Data Tables C-2 Final EIS

Table C-1 (continued)

Reported Outfitter/Guide Service Days by Outfitter/Guide Use Area

Outfitter/Guide Use Area

Reported Service Days

2013 2014 2015 2016 2017

Grand 

Total

Annual 

Average

J04 JUNEAU ICEFIELD 4 -

MENDENHALL

498,478 513,379 526,612 526,179 519,867 2,584,515 516,903

J05 JUNEAU ICEFIELD 5 - LEMON 0 3 145 129 70 347 69

J06 JUNEAU ICEFIELD 6 - DEATH 

VALLEY

47 0 0 9 32 88 18

J07 JUNEAU ICEFIELD 7 - NORRIS 9,832 8,801 8,433 9,087 7,531 43,684 8,737

J08 JUNEAU ICEFIELD 8 - TAKU 8,190 6,308 8,316 3,853 4,895 31,562 6,312

J09 JUNEAU ICEFIELD 9 - TWIN 0 0 0 0 0 0 0

K01 WEST MISTY 28 30 26 9 4 97 19

K02 NORTHEAST MISTY 138 90 63 25 67 383 77

K03 SOUTH MISTY 35 70 76 38 19 238 48

K04 DUKE ISLAND 0 0 0 0 0 0 0

K05 SOUTH MISTY LAKES 26 20 56 50 15 167 33

K06 MISTY CORE LAKES 8,635 7,228 5,861 5,474 5,140 32,338 6,468

K07 WALKER CHICKAMIN 30 44 15 15 6 110 22

K08 BURROUGHS UNUK 16 40 19 33 10 118 24

K09 ALAVA PRINCESS MANZANITA 4 17 8 57 86 17

K10 RUDYERD WINSTANLEY 72 70 80 14 48 284 57

K11 GRAVINA ISLAND 0 0 0 0 0 0 0

K12 BELL ISLAND 402 376 461 471 441 2,151 430

K13 EAST CLEVELAND 0 0 8 0 0 8 2

K14 WEST CLEVELAND 3 9 0 0 0 12 2

K15 WILSON BAKEWELL 50 28 88 118 52 336 67

K16 KETCHIKAN CORE SPNW 2 1 0 0 0 3 1

K17 GEORGE CARROLL THORNE 41 59 70 108 56 334 67

K18 CENTRAL REVILLA SPNW 0 0 0 0 0 0 0

K19 NORTH REVILLA 217 269 101 286 193 1,066 213

K20 HYDER SPNW 0 0 0 0 0 0 0

K21 PERCY HOTSPUR MARY 0 0 0 0 0 0 0

K22 HYDER NA 190 569 225 451 423 1,858 372

K23 BETTON ISLAND 8 7,517 7,505 8,861 7,347 31,238 6,248

K24 KETCHIKAN CORE NA 536 1,368 1,058 1,297 1,999 6,258 1,252

K25 SOUTH REVILLA 0 0 0 0 0 0 0

K26 CENTRAL REVILLA NA 0 0 28 15 74 117 23

K27 MARGARET BAY 1,682 1,929 1,954 1,914 2,309 9,788 1,958

K28 NAHA BAY 0 0 0 0 7 7 1

P01 MITKOF ISLAND 1,179 1,106 1,105 681 568 4,639 928

P02 DUNCAN CANAL - WEST SIDE 130 80 111 61 110 492 98

P04 DUNCAN CANAL - EAST SIDE 0 0 0 0 0 0 0

P05 WRANGELL 

NARROWS/WOEWODSKI IS.

27 23 13 0 52 115 23

P06 KUPREANOF ISLAND - NORTH 

SHORE

92 137 235 172 114 750 150

P07 PETERSBURG CREEK/DUNCAN 

SALT CHUCK

1,050 851 884 2,105 2,591 7,481 1,496

P08 NORTH LINDENBERG 

PENINSULA

200 227 482 224 255 1,388 278

P09 CENTRAL KUPREANOF 

ISLAND/ROAD SYSTEM

0 3 0 64 0 67 13

P10 SOUTHWEST KUPREANOF 

ISLAND

263 405 398 349 337 1,752 350

P11 ROWAN BAY/BAY OF PILLARS 907 822 540 459 613 3,341 668

P12A SAGINAW/SECURITY/

WASHINGTON BAYS

548 696 808 1,225 1,764 5,041 1,008
Appendix C

Final EIS C-3 Outfitter/Guide Use Area Data Tables

Table C-1 (continued)

Reported Outfitter/Guide Service Days by Outfitter/Guide Use Area

Outfitter/Guide Use Area

Reported Service Days

2013 2014 2015 2016 2017

Grand 

Total

Annual 

Average

P12B KUIU ISLAND ROAD SYSTEM 167 91 174 156 108 696 139

P13 TEBENKOF BAY/KUIU WLDN 156 179 60 85 117 597 119

P14 KEKU STRAIT/PORT CAMDEN 403 454 496 806 506 2,665 533

P15 SOUTH KUIU ISLAND 116 157 0 56 19 348 70

P16 REID/NO NAME BAYS 80 64 0 35 2 181 36

P21 MUDDY RIVER AREA 474 330 411 263 257 1,735 347

P22 THOMAS BAY/POINT 

VANDEPUT

2,150 2,146 1,329 1,838 1,873 9,336 1,867

P23 FARRAGUT BAY/CAPE 

FANSHAW

81 85 108 150 180 604 121

P24 BAIRD/PATTERSON GLACIERS 13 8 30 16 33 100 20

SKAGWAY ICEFIELD - DENVER 8,950 10,109 7,319 7,271 9,816 43,465 8,693

SI-EF SKAGWAY ICEFIELD - EAST 

FORK

0 0 0 0 0 0 0

SI-LG SKAGWAY ICEFIELD - LE 

GRANDE

0 0 0 0 0 0 0

SI-M SKAGWAY ICEFIELD - MEADE 13,324 14,352 15,219 15,204 16,751 74,850 14,970

SI-S SKAGWAY ICEFIELD -

SCHUBEE

0 173 0 0 0 173 35

TBRD 00-00NO AREA DESIGNATED 1,872 1,495 953 1,006 870 6,196 1,239

W10 STIKINE - LECONTE 

WILDERNESS

1,115 15 9 24 8 1,171 234

W100 NORTH ETOLIN ISLAND 1,205 31 19 8 10 1,273 255

W120 SOUTH ETOLIN ISLAND 

WILDERNESS

794 7 9 0 12 822 164

W130 VANK ISLAND GROUP 52 0 0 0 0 52 10

W140 KASHEVAROF GROUP 125 14 24 93 210 466 93

W150 LECONTE BAY (S-LC 

WILDERNESS)

285 162 156 317 287 1,207 241

W30 GARNET/MILL CREEK 31 24 0 221 158 434 87

W40 MADAN/BOULDER 589 0 41 11 15 656 131

W50 BRADFIELD CANAL AND 

RIVER

136 2 7 0 0 145 29

W60 ANAN CREEK 2,396 350 235 340 285 3,606 721

W70 CLEVELAND PEN./DEER 

ISLAND

963 10 0 0 0 973 195

W80 WRANGELL ISLAND 756 3 0 0 0 759 152

W90 ZAREMBO 95 26 26 8 11 166 33

Y01 YAKUTAT BAY 0 0 46 0 0 46 9

Y02 LOST TAWAH 20 0 35 12 0 67 13

Y03 KUNYOSH SEAL CREEKS 0 0 12 0 0 12 2

Y04 AHRNKLIN ANTLEN 0 0 213 0 0 213 43

Y05 PIKE LAKES MOSER CREEK 0 0 0 0 0 0 0

Y06 DANGEROUS RIVER 0 144 11 0 0 155 31

Y07 OLD MIDDLE ITALIO 229 670 364 232 0 1,495 299

Y08 ITALIO 61 180 87 45 0 373 75

Y09 LOWER AKWE 184 238 604 400 0 1,426 285

Y10 UPPER AKWE 0 2 28 5 0 35 7

Y11 USTAY TANIS 11 4 0 0 0 15 3

Y12 DRY BAY ALSEK 286 388 175 5 0 854 171

Y13 BRABAZONS 0 0 10 0 10 2

Y14 HARLEQUIN LAKE 0 6 79 11 0 96 19

Y15 RUSSELL NUNATAK FJORDS 0 4 33 33 28 98 20

Y16 SITUK RIVER 345 1,787 2,897 1,955 2,278 9,262 1,852

Source: Most recent five years of data (2013-2017) from the Tongass National Forest Outfitter/Guide Database.
Appendix C

Outfitter/Guide Use Area Data Tables C-4 Final EIS

Table C-2

Change in Roadless Area Acres by Outfitter/Guide Use Area and Alternative

Outfitter/Guide Use Area Total Acres

Total 

Roadless 

Acres Change in Roadless Acres from Alt 1

Alt 1 Alt 2 Alt 3 Alt 4a* Alt 4b** Alt 5 Alt 6

01-01 SKAGWAY AREA 255,036 252,160 2,876 2,876 0 -2,168 -2,168 -252,160

01-02 HAINES AREA 19,514 18,369 46 46 -2 -2,671 -7,735 -18,369

01-03 EAST CHILKATS 361,545 244,171 -2,259 -2,259 -2,259 -18,638 -50,978 -244,171

01-04A BERNERS BAY 239,889 237,760 -691 -46,139 -708 -18,450 -20,787 -237,760

01-04B N. JUNEAU COAST 49,659 45,584 -1,084 -1,084 -1,088 -1,088 -17,091 -45,584

01-04C TAKU INLET 259,153 255,094 1,987 1,987 -387 -387 -33,494 -255,094

01-04D SLOCUM INLET 17,214 16,665 0 0 0 0 -13,446 -16,665

01-04E JUNEAU ICEFIELD 230,787 230,758 -3 -5 -3 -3 -25,933 -230,758

01-05A TAKU HARBOR 19,639 18,332 0 0 0 0 -5,393 -18,332

01-05B PORT SNETTISHAM 370,367 366,502 837 837 0 0 -32,573 -366,502

01-05C WINDHAM BAY 161,216 159,929 625 625 0 -44,063 -118,146 -159,929

01-05D TRACY ARM 330,739 20 0 0 0 0 0 -20

01-05E FORDS TERROR 24,386 - 0 0 0 0 0 0

01-05F ENDICOTT ARM 368,545 69 0 0 0 -20 -42 -69

04-01A GUT BAY, BARANOF 93,986 9 0 0 0 0 0 -9

04-01B PORT ARMSTRONG 70,962 70,897 21 21 0 0 0 -70,897

04-01C NELSON BAY 44,166 44,159 2 2 0 0 0 -44,159

04-02A REDOUBT LAKE 45,074 41,918 -150 -150 -500 -5,617 -6,049 -41,918

04-02B WHALE BAY 221,835 13 5 5 0 0 0 -13

04-02C NECKER ISLANDS 6,197 3,205 1,749 1,749 0 -20 -20 -3,205

04-02D SW BARANOF 54,366 54,104 239 239 0 0 0 -54,104

04-03 SITKA AREA 345,862 296,576 456 456 -1,479 -26,870 -60,038 -296,576

04-04A RODMAN BAY 75,427 45,371 7,639 7,639 -423 -5,405 -34,452 -45,371

04-04B KELP BAY 144,680 131,182 230 230 -228 -11,569 -22,462 -131,182

04-04C BARANOF WARM SPRINGS 28,929 28,929 0 0 0 0 0 -28,929

04-05 SW ADMIRALTY 114,955 - 0 0 0 0 0 0

04-05B MITCHELL BAY 61,008 - 0 0 0 0 0 0

04-06A PYBUS BAY 55,674 - 0 0 0 0 0 0

04-06B ELIZA HARBOR 85,206 - 0 0 0 0 0 0

04-07A GAMBIER BAY 119,252 - 0 0 0 0 0 0

04-07B CANOE ROUTE 86,687 - 0 0 0 0 0 0

04-08 NE ADMIRALTY 128,063 40,137 -177 -177 -199 -199 -2,443 -40,137

04-09A SEYMOUR CANAL 88,164 59 0 0 0 0 0 -59

04-09B PACK CREEK 65,426 - 0 0 0 0 0 0

04-10A GREENS CREEK 2,575 448 0 0 0 0 0 -448

04-10B NW ADMIRALTY 256,234 39,783 -72 -72 -76 -76 -10,879 -39,783
Appendix C

Final EIS C-5 Outfitter/Guide Use Area Data Tables

Table C-2 (continued)

Change in Roadless Area Acres by Outfitter/Guide Use Area and Alternative

Outfitter/Guide Use Area Total Acres

Total 

Roadless 

Acres Change in Roadless Acres from Alt 1

Alt 1 Alt 2 Alt 3 Alt 4a* Alt 4b** Alt 5 Alt 6

04-11A PORT FREDERICK 112,512 88,043 3,278 3,122 -368 -25,213 -48,870 -88,043

04-11B FRESHWATER BAY 160,078 97,513 -1,319 -11,085 -11,714 -49,397 -49,438 -97,513

04-12 TENAKEE INLET 312,435 247,557 7,869 -47,029 -16,774 -46,470 -104,363 -247,557

04-13 PERIL STRAIT 232,130 168,913 19,926 -64,777 -1,120 -7,308 -53,059 -168,913

04-14 SLOCUM ARM 97,008 146 8 5 0 0 -95 -146

04-15A LISIANSKI 90,638 89,243 117 -54,256 -32 -32 -4,752 -89,243

04-15B WEST YAKOBI ISLAND 39,706 20 0 -1 0 0 -2 -20

04-15C STAG BAY 26,663 18 0 -1 0 0 0 -18

04-15D PORTLOCK HARBOR 107,904 25 0 -25 0 0 0 -25

04-16A POINT ADOLPHUS 8,888 8,888 0 -6,806 0 0 0 -8,888

04-16B NORTH CHICHAGOF 64,726 59,828 12 -41,102 12 -15,065 -15,263 -59,828

04-16C IDAHO INLET 53,504 53,437 67 -53,338 67 66 -94 -53,437

04-16D PLI WILDERNESS 23,079 - 0 0 0 0 0 0

04-16E PORT ALTHORP 19,475 19,341 127 -14,622 5 5 0 -19,341

CRD 00-00NO AREA DESIGNATED 925,877 735,240 -4,049 -157,633 -39,977 -125,853 -268,322 -735,240

J01 JUNEAU ICEFIELD 1 - GILKEY 

BACKCOUNTRY

315,751 315,751 0 -164 0 0 0 -315,751

J02 JUNEAU ICEFIELD 2 - EAGLE 10,300 10,300 0 0 0 0 0 -10,300

J03 JUNEAU ICEFIELD 3 - HERBERT 12,636 12,636 0 0 0 0 -226 -12,636

J04 JUNEAU ICEFIELD 4 - MENDENHALL 38,095 36,528 -531 -531 -531 -531 -9,728 -36,528

J05 JUNEAU ICEFIELD 5 - LEMON 12,427 12,427 0 0 0 0 -1,542 -12,427

J06 JUNEAU ICEFIELD 6 - DEATH VALLEY 54,498 54,498 0 0 0 0 0 -54,498

J07 JUNEAU ICEFIELD 7 - NORRIS 37,781 37,781 0 0 0 0 0 -37,781

J08 JUNEAU ICEFIELD 8 - TAKU 35,343 35,343 0 0 0 0 0 -35,343

J09 JUNEAU ICEFIELD 9 - TWIN 61,660 61,660 0 0 0 0 0 -61,660

K01 WEST MISTY 192,830 573 0 -106 -106 -181 -226 -573

K02 NORTHEAST MISTY 1,300,687 132,415 0 0 0 -41 -70 -132,415

K03 SOUTH MISTY 628,890 2,532 0 0 0 0 0 -2,532

K04 DUKE ISLAND 40,202 39,757 380 380 0 0 0 -39,757

K05 SOUTH MISTY LAKES 14,878 1,022 0 0 0 0 0 -1,022

K06 MISTY CORE LAKES 57,861 25 0 0 0 0 0 -25

K07 WALKER CHICKAMIN 14,320 - 0 0 0 0 0 0

K08 BURROUGHS UNUK 29,455 - 0 0 0 0 0 0

K09 ALAVA PRINCESS MANZANITA 20,568 5 1 1 0 0 0 -5

K10 RUDYERD WINSTANLEY 20,285 - 0 0 0 0 0 0

K11 GRAVINA ISLAND 39,700 38,265 -333 -333 -591 -3,604 -17,105 -38,265
Appendix C

Outfitter/Guide Use Area Data Tables C-6 Final EIS

Table C-2 (continued)

Change in Roadless Area Acres by Outfitter/Guide Use Area and Alternative

Outfitter/Guide Use Area Total Acres

Total 

Roadless 

Acres Change in Roadless Acres from Alt 1

Alt 1 Alt 2 Alt 3 Alt 4a* Alt 4b** Alt 5 Alt 6

K12 BELL ISLAND 137,694 137,358 36 31 -9 -9 -21,837 -137,358

K13 EAST CLEVELAND 87,531 85,189 -329 -329 -462 -462 -34,417 -85,189

K14 WEST CLEVELAND 73,232 73,137 -1,139 -1,139 -1,216 -1,216 -28,633 -73,137

K15 WILSON BAKEWELL 13,440 10,981 -134 -134 -154 -154 -154 -10,981

K16 KETCHIKAN CORE SPNW 46,341 44,886 -122 -9,169 -5,539 -8,999 -18,459 -44,886

K17 GEORGE CARROLL THORNE 137,434 117,781 -5,237 -25,165 -25,022 -48,596 -57,294 -117,781

K18 CENTRAL REVILLA SPNW 92,792 62,011 -707 -31,452 -9,182 -30,385 -28,006 -62,011

K19 NORTH REVILLA 70,401 59,814 -426 -426 -427 -9,602 -13,347 -59,814

K20 HYDER SPNW 121,348 117,841 -111 -111 -111 -111 -35,363 -117,841

K21 PERCY HOTSPUR MARY 6,924 5,329 689 689 -4 -4 -4 -5,329

K22 HYDER NA 7,261 4,065 -21 -21 -21 -21 -3,878 -4,065

K23 BETTON ISLAND 5,028 4,351 -575 -575 -1,126 -1,126 -1,126 -4,351

K24 KETCHIKAN CORE NA 19,239 15,148 -743 -1,429 -1,429 -1,487 -1,484 -15,148

K25 SOUTH REVILLA 40,219 8,460 -4,609 -5,780 -5,660 -7,337 -7,001 -8,460

K26 CENTRAL REVILLA NA 15,451 405 -22 -398 -398 -405 -405 -405

K27 MARGARET BAY 9,707 627 -82 -328 -306 -507 -506 -627

K28 NAHA BAY 5,273 5,264 9 -4,961 -65 -65 -166 -5,264

P01 MITKOF ISLAND 109,302 35,054 -286 -4,244 -4,376 -18,048 -22,476 -35,054

P02 DUNCAN CANAL - WEST SIDE 73,636 67,468 180 180 -31 -9,677 -29,826 -67,468

P04 DUNCAN CANAL - EAST SIDE 53,325 31,441 -5,988 -17,748 -17,817 -24,557 -22,933 -31,441

P05 WRANGELL NARROWS/WOEWODSKI 

IS.

17,033 15,293 235 40 -311 -1,605 -12,225 -15,293

P06 KUPREANOF ISLAND - NORTH 

SHORE

11,303 11,244 -4 -130 -133 -1,579 -1,454 -11,244

P07 PETERSBURG CREEK/DUNCAN SALT 

CHUCK

49,950 1,469 1,343 1,167 -203 -223 -207 -1,469

P08 NORTH LINDENBERG PENINSULA 75,605 59,007 -10,681 -28,098 -28,123 -38,976 -48,981 -59,007

P09 CENTRAL KUPREANOF 

ISLAND/ROAD SYSTEM

223,302 190,321 -12,963 -16,236 -16,662 -52,068 -132,338 -190,321

P10 SOUTHWEST KUPREANOF ISLAND 93,507 87,142 -567 -33,846 -723 -10,820 -43,283 -87,142

P11 ROWAN BAY/BAY OF PILLARS 28,721 24,944 520 -19,688 -35 -35 -35 -24,944

P12A SAGINAW/SECURITY/

WASHINGTON BAYS

32,450 25,571 -560 -562 -776 -1,152 -1,250 -25,571

P12B KUIU ISLAND ROAD SYSTEM 134,852 41,428 2,529 -4,458 -8,197 -19,049 -30,932 -41,428

P13 TEBENKOF BAY/KUIU WILDERNESS 127,218 299 31 -75 0 0 -36 -299

P14 KEKU STRAIT/PORT CAMDEN 102,299 97,504 975 939 -595 -3,415 -22,559 -97,504

P15 SOUTH KUIU ISLAND 62,824 62,150 313 313 -3 -3 -3 -62,150
Appendix C

Final EIS C-7 Outfitter/Guide Use Area Data Tables

Table C-2 (continued)

Change in Roadless Area Acres by Outfitter/Guide Use Area and Alternative

Outfitter/Guide Use Area Total Acres

Total 

Roadless 

Acres Change in Roadless Acres from Alt 1

Alt 1 Alt 2 Alt 3 Alt 4a* Alt 4b** Alt 5 Alt 6

P16 REID/NO NAME BAYS 43,191 27,185 13,874 10,588 -110 -868 -11,915 -27,185

P21 MUDDY RIVER AREA 63,357 43,101 -233 -7,917 -7,924 -26,689 -28,919 -43,101

P22 THOMAS BAY/POINT VANDEPUT 76,810 74,892 -95 -95 -124 -4,117 -12,122 -74,892

P23 FARRAGUT BAY/CAPE FANSHAW 66,716 66,026 -106 -106 -182 -2,994 -33,655 -66,026

P24 BAIRD/PATTERSON GLACIERS 402,216 402,198 0 0 0 -9 -1,651 -402,198

SI-D SKAGWAY ICEFIELD - DENVER 19,600 19,600 0 0 0 0 0 -19,600

SI-EF SKAGWAY ICEFIELD - EAST FORK 499 499 0 0 0 0 0 -499

SI-LG SKAGWAY ICEFIELD - LE GRANDE 640 640 0 0 0 0 0 -640

SI-M SKAGWAY ICEFIELD - MEADE 25,730 25,730 0 0 0 0 0 -25,730

SI-S SKAGWAY ICEFIELD - SCHUBEE 2,934 2,934 0 0 0 0 0 -2,934

TBRD 00-00NO AREA DESIGNATED 901,506 364,798 -13,619 -193,327 -80,038 -112,386 -133,003 -364,798

W10 STIKINE - LECONTE WILDERNESS 263,581 192 0 0 0 0 -47 -192

W100 NORTH ETOLIN ISLAND 151,750 121,633 -5,213 -19,838 -21,021 -35,299 -74,491 -121,633

W120 SOUTH ETOLIN ISLAND 

WILDERNESS

82,517 180 -12 -12 -12 -89 -176 -180

W130 VANK ISLAND GROUP 22,927 13,121 -40 -40 -76 -76 -8,857 -13,121

W140 KASHEVAROF GROUP 11,470 4,773 1,040 1,040 -41 -41 -41 -4,773

W150 LECONTE BAY (S-LC WILDERNESS) 175,361 894 14 14 0 -50 -50 -894

W30 GARNET/MILL CREEK 56,850 56,830 0 0 0 0 -46,032 -56,830

W40 MADAN/BOULDER 105,035 104,872 -316 -316 -358 -358 -22,198 -104,872

W50 BRADFIELD CANAL AND RIVER 516,308 488,672 206 176 -76 -125,730 -147,741 -488,672

W60 ANAN CREEK 38,615 38,305 0 -37,926 -116 -279 -247 -38,305

W70 CLEVELAND PEN./DEER ISLAND 48,383 38,451 -4,237 -8,086 -8,605 -15,986 -29,415 -38,451

W80 WRANGELL ISLAND 113,539 69,791 -5,177 -20,655 -21,019 -38,878 -51,543 -69,791

W90 ZAREMBO 116,402 54,049 -8,562 -12,204 -12,220 -32,237 -32,228 -54,049

Y01 YAKUTAT BAY 69,745 9,378 94 -8,307 -8,787 -8,787 -386 -9,378

Y02 LOST TAWAH 9,112 3,330 -283 -283 -283 -3,279 -3,330 -3,330

Y03 KUNYOSH SEAL CREEKS 49,765 47,087 -593 -593 -593 -5,274 -5,381 -47,087

Y04 AHRNKLIN ANTLEN 30,315 28,637 -92 -92 -92 -2,121 -2,158 -28,637

Y05 PIKE LAKES MOSER CREEK 43,577 10,681 -72 -72 -72 -5,452 -5,492 -10,681

Y06 DANGEROUS RIVER 27,110 26,328 268 -18,797 -4,855 -5,231 -440 -26,328

Y07 OLD MIDDLE ITALIO 20,869 20,869 -38 -20,869 -2,904 -2,904 -38 -20,869

Y08 ITALIO 23,500 23,464 0 -23,199 -48 -48 0 -23,464

Y09 LOWER AKWE 3,234 1,641 -125 -1,641 -1,423 -1,423 -125 -1,641

Y10 UPPER AKWE 43,230 42,503 0 -32,801 -183 -183 0 -42,503

Y11 USTAY TANIS 53,356 52,180 -62 -24,319 -559 -559 -62 -52,180

Y12 DRY BAY ALSEK 53,339 51,712 16 -29,232 -4,015 -4,015 0 -51,712
Appendix C

Outfitter/Guide Use Area Data Tables C-8 Final EIS

Table C-2 (continued)

Change in Roadless Area Acres by Outfitter/Guide Use Area and Alternative

Outfitter/Guide Use Area Total Acres

Total 

Roadless 

Acres Change in Roadless Acres from Alt 1

Alt 1 Alt 2 Alt 3 Alt 4a* Alt 4b** Alt 5 Alt 6

Y13 BRABAZONS 436,629 426,364 0 0 0 0 0 -426,364

Y14 HARLEQUIN LAKE 103,270 75,526 0 -293 0 -1,080 -1,088 -75,526

Y15 RUSSELL NUNATAK FJORDS 214,066 1,851 -64 -64 -64 -64 -64 -1,851

Y16 SITUK RIVER 38,676 19,868 -8,227 -10,016 -10,072 -11,676 -10,263 -19,868

Total 16,730,220 9,368,434 -32,163 -1,144,256 -393,934 -1,151,291 -2,321,230 -9,368,434

*The first set of estimates for Alternative 4 (4a) shows the net change in acres classified as roadless.

**The second set of estimates for Alternative 4 (4b) also subtracts the acres that would be managed as Timber Priority because road construction would be 

allowed in these areas. 
Appendix C

Final EIS C-9 Outfitter/Guide Use Area Data Tables

Table C-3

Change in Development LUD Acres without Roadless Protection by Outfitter/Guide Use Area and Alternative

Outfitter/Guide Use Area Total Acres

Total 

Development 

LUD Acres Change in Development LUD Acres from Alt 1

Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

01-01 SKAGWAY AREA 255,036 0 0 0 0 2,168 2,168

01-02 HAINES AREA 19,514 480 2 2 2 5,263 5,263

01-03 EAST CHILKATS 361,545 16,105 2,049 2,049 2,049 50,441 50,441

01-04A BERNERS BAY 239,889 990 581 581 581 19,466 19,466

01-04B N. JUNEAU COAST 49,659 610 2 2 2 3,064 3,064

01-04C TAKU INLET 259,153 1,416 297 297 297 30,382 30,382

01-04D SLOCUM INLET 17,214 504 0 0 0 13,446 13,446

01-04E JUNEAU ICEFIELD 230,787 11 0 0 0 14 14

01-05A TAKU HARBOR 19,639 189 0 0 0 5,358 5,358

01-05B PORT SNETTISHAM 370,367 808 0 0 0 32,569 32,569

01-05C WINDHAM BAY 161,216 584 -149 -149 0 117,850 117,852

01-05D TRACY ARM 330,739 0 0 0 0 0 0

01-05E FORDS TERROR 24,386 0 0 0 0 0 0

01-05F ENDICOTT ARM 368,545 0 0 0 0 42 42

04-01A GUT BAY, BARANOF 93,986 0 0 0 0 0 0

04-01B PORT ARMSTRONG 70,962 0 0 0 0 0 0

04-01C NELSON BAY 44,166 0 0 0 0 0 0

04-02A REDOUBT LAKE 45,074 1,686 301 301 301 5,849 5,849

04-02B WHALE BAY 221,835 0 0 0 0 0 0

04-02C NECKER ISLANDS 6,197 0 0 0 0 20 20

04-02D SW BARANOF 54,366 0 0 0 0 0 0

04-03 SITKA AREA 345,862 24,386 465 465 467 58,947 58,951

04-04A RODMAN BAY 75,427 24,368 -6,257 -6,257 302 34,306 34,306

04-04B KELP BAY 144,680 10,447 182 182 195 22,341 22,341

04-04C BARANOF WARM SPRINGS 28,929 0 0 0 0 0 0

04-05A SW ADMIRALTY 114,955 0 0 0 0 0 0

04-05B MITCHELL BAY 61,008 0 0 0 0 0 0

04-06A PYBUS BAY 55,674 0 0 0 0 0 0

04-06B ELIZA HARBOR 85,206 0 0 0 0 0 0

04-07A GAMBIER BAY 119,252 0 0 0 0 0 0

04-07B CANOE ROUTE 86,687 0 0 0 0 0 0

04-08 NE ADMIRALTY 128,063 0 0 0 0 0 0

04-09A SEYMOUR CANAL 88,164 0 0 0 0 0 0

04-09B PACK CREEK 65,426 0 0 0 0 0 0

04-10A GREENS CREEK 2,575 0 0 0 0 0 0

04-10B NW ADMIRALTY 256,234 0 0 0 0 0 0

04-11A PORT FREDERICK 112,512 14,815 -3,051 -2,957 209 48,677 48,677
Appendix C

Outfitter/Guide Use Area Data Tables C-10 Final EIS

Table C-3 (continued)

Change in Development LUD Acres without Roadless Protection by Outfitter/Guide Use Area and Alternative

Outfitter/Guide Use Area Total Acres

Total 

Development 

LUD Acres Change in Development LUD Acres from Alt 1

Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

04-11B FRESHWATER BAY 160,078 47,176 1,667 10,737 10,737 49,119 49,120

04-12 TENAKEE INLET 312,370 47,494 -7,562 2,825 11,844 104,096 104,100

04-13 PERIL STRAIT 232,130 49,419 -17,470 -17,464 712 52,386 52,391

04-14 SLOCUM ARM 97,008 0 0 0 0 95 95

04-15A LISIANSKI 90,638 0 0 0 0 0 0

04-15B WEST YAKOBI ISLAND 39,706 0 0 0 0 0 0

04-15C STAG BAY 26,663 0 0 0 0 0 0

04-15D PORTLOCK HARBOR 107,904 0 0 0 0 0 0

04-16A POINT ADOLPHUS 8,888 0 0 0 0 0 0

04-16B NORTH CHICHAGOF 64,726 4,789 34 34 34 15,204 15,204

04-16C IDAHO INLET 53,504 0 0 0 0 94 94

04-16D PLI WILDERNESS 23,079 0 0 0 0 0 0

04-16D PORT ALTHORP 19,475 0 0 0 0 0 0

CRD 00-00NO AREA DESIGNATED 925,876 66,339 16,393 37,161 41,389 244,548 256,527

J01 JUNEAU ICEFIELD 1 - GILKEY 

BACKCOUNTRY

315,751 0 0 0 0 0 0

J02 JUNEAU ICEFIELD 2 - EAGLE 10,300 0 0 0 0 0 0

J03 JUNEAU ICEFIELD 3 - HERBERT 12,636 0 0 0 0 0 0

J04 JUNEAU ICEFIELD 4 - MENDENHALL 38,095 0 0 0 0 0 0

J05 JUNEAU ICEFIELD 5 - LEMON 12,427 0 0 0 0 0 0

J06 JUNEAU ICEFIELD 6 - DEATH VALLEY 54,498 0 0 0 0 0 0

J07 JUNEAU ICEFIELD 7 - NORRIS 37,781 0 0 0 0 0 0

J08 JUNEAU ICEFIELD 8 - TAKU 35,343 0 0 0 0 0 0

J09 JUNEAU ICEFIELD 9 - TWIN 61,660 0 0 0 0 0 0

K01 WEST MISTY 192,830 35 0 106 106 225 225

K02 NORTHEAST MISTY 1,300,687 0 0 0 0 41 41

K03 SOUTH MISTY 628,890 0 0 0 0 0 0

K04 DUKE ISLAND 40,202 0 0 0 0 0 0

K05 SOUTH MISTY LAKES 14,878 0 0 0 0 0 0

K06 MISTY CORE LAKES 57,861 0 0 0 0 0 0

K07 WALKER CHICKAMIN 14,320 0 0 0 0 0 0

K08 BURROUGHS UNUK 29,455 0 0 0 0 0 0

K09 ALAVA PRINCESS MANZANITA 20,568 0 0 0 0 0 0

K10 RUDYERD WINSTANLEY 20,285 0 0 0 0 0 0

K11 GRAVINA ISLAND 39,700 1,044 358 358 358 16,218 16,218

K12 BELL ISLAND 137,694 62 0 0 0 21,784 21,785
Appendix C

Final EIS C-11 Outfitter/Guide Use Area Data Tables

Table C-3 (continued)

Change in Development LUD Acres without Roadless Protection by Outfitter/Guide Use Area and Alternative

Outfitter/Guide Use Area Total Acres

Total 

Development 

LUD Acres Change in Development LUD Acres from Alt 1

Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

K13 EAST CLEVELAND 87,531 156 137 137 137 33,504 33,505

K14 WEST CLEVELAND 73,232 0 0 0 0 24,216 24,216

K15 WILSON BAKEWELL 13,440 0 0 0 0 0 0

K16 KETCHIKAN CORE SPNW 46,341 1,255 27 5,245 5,245 18,349 18,349

K17 GEORGE CARROLL THORNE 137,434 16,590 4,471 23,611 23,612 56,195 56,196

K18 CENTRAL REVILLA SPNW 92,792 24,899 634 6,697 6,697 27,933 27,934

K19 NORTH REVILLA 70,401 9,377 303 303 303 13,208 13,209

K20 HYDER SPNW 121,348 98 0 0 0 4,013 4,100

K21 PERCY HOTSPUR MARY 6,924 0 0 0 0 0 0

K22 HYDER NA 7,261 2,953 6 6 6 3,279 3,333

K23 BETTON ISLAND 5,028 0 0 0 0 0 0

K24 KETCHIKAN CORE NA 19,239 1,616 13 695 695 754 754

K25 SOUTH REVILLA 40,219 29,389 4,186 4,899 4,899 6,576 6,576

K26 CENTRAL REVILLA NA 15,451 12,318 22 398 398 405 405

K27 MARGARET BAY 9,707 7,090 72 295 295 497 497

K28 NAHA BAY 5,273 0 0 67 67 166 166

P01 MITKOF ISLAND 109,302 56,859 140 4,098 4,098 22,198 22,199

P02 DUNCAN CANAL - WEST SIDE 73,636 1,823 9 9 9 29,788 29,795

P04 DUNCAN CANAL - EAST SIDE 53,325 19,011 5,417 14,660 14,729 22,363 22,364

P05 WRANGELL NARROWS/WOEWODSKI 

IS.

17,033 489 -194 1 309 12,130 12,130

P06 KUPREANOF ISLAND - NORTH 

SHORE

11,303 0 0 1 1 1,446 1,446

P07 PETERSBURG CREEK/DUNCAN SALT 

CHUCK

49,950 0 27 114 114 207 207

P08 NORTH LINDENBERG PENINSULA 75,605 13,525 10,157 24,318 24,335 48,445 48,446

P09 CENTRAL KUPREANOF ISLAND/ROAD 

SYSTEM

223,302 28,963 12,924 14,527 14,527 131,863 131,868

P10 SOUTHWEST KUPREANOF ISLAND 93,507 3,241 355 355 355 42,877 42,877

P11 ROWAN BAY/BAY OF PILLARS 28,721 46 0 0 0 0 0

P12A SAGINAW/SECURITY/WASHINGTON 

BAYS

32,450 4,006 635 636 636 1,098 1,099

P12B KUIU ISLAND ROAD SYSTEM 134,852 76,994 -2,558 4,425 7,913 30,622 30,622

P13 TEBENKOF BAY/KUIU WILDERNESS 127,218 13 -13 -13 0 36 36

P14 KEKU STRAIT/PORT CAMDEN 102,299 1,134 415 450 485 22,275 22,284

P15 SOUTH KUIU ISLAND 62,824 0 0 0 0 0 0

P16 REID/NO NAME BAYS 43,191 13,380 -11,862 -11,862 292 11,892 11,892
Appendix C

Outfitter/Guide Use Area Data Tables C-12 Final EIS

Table C-3 (continued)

Change in Development LUD Acres without Roadless Protection by Outfitter/Guide Use Area and Alternative

Outfitter/Guide Use Area Total Acres

Total 

Development 

LUD Acres Change in Development LUD Acres from Alt 1

Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

P21 MUDDY RIVER AREA 63,357 16,651 236 7,796 7,796 28,713 28,713

P22 THOMAS BAY/POINT VANDEPUT 76,810 1,160 114 114 114 12,111 12,111

P23 FARRAGUT BAY/CAPE FANSHAW 66,716 166 76 76 76 33,546 33,546

P24 BAIRD/PATTERSON GLACIERS 402,216 0 0 0 0 1,651 1,651

SI-D SKAGWAY ICEFIELD - DENVER 19,600 0 0 0 0 0 0

SI-EF SKAGWAY ICEFIELD - EAST FORK 499 0 0 0 0 0 0

SI-LG SKAGWAY ICEFIELD - LE GRANDE 640 0 0 0 0 0 0

SI-M SKAGWAY ICEFIELD - MEADE 25,730 0 0 0 0 0 0

SI-S SKAGWAY ICEFIELD - SCHUBEE 2,934 0 0 0 0 0 0

TBRD 00-00NO AREA DESIGNATED 901,507 326,652 12,415 60,737 61,064 127,126 127,126

W10 STIKINE - LECONTE WILDERNESS 263,581 0 0 0 0 47 47

W100 NORTH ETOLIN ISLAND 151,750 26,040 5,977 18,098 18,253 73,999 74,002

W120 SOUTH ETOLIN ISLAND 

WILDERNESS

82,517 0 12 12 12 176 176

W130 VANK ISLAND GROUP 22,927 9,420 74 74 74 8,850 8,850

W140 KASHEVAROF GROUP 11,470 5,507 -4 -4 0 0 0

W150 LECONTE BAY (S-LC WILDERNESS) 175,361 0 0 0 0 50 50

W30 GARNET/MILL CREEK 56,850 0 0 0 0 45,821 45,821

W40 MADAN/BOULDER 105,035 88 34 34 34 14,610 14,632

W50 BRADFIELD CANAL AND RIVER 516,308 17,806 64 64 64 147,638 147,638

W60 ANAN CREEK 38,615 0 0 62 62 247 247

W70 CLEVELAND PEN./DEER ISLAND 48,383 8,245 4,848 6,435 6,435 29,268 29,269

W80 WRANGELL ISLAND 113,539 30,549 5,109 16,538 16,538 51,069 51,069

W90 ZAREMBO 116,402 49,859 6,402 9,921 9,922 30,043 30,043

Y01 YAKUTAT BAY 69,745 57 0 0 0 0 0

Y02 LOST TAWAH 9,112 4,483 234 234 234 3,280 3,280

Y03 KUNYOSH SEAL CREEKS 49,765 2,547 535 535 535 5,323 5,323

Y04 AHRNKLIN ANTLEN 30,315 1,608 60 60 60 2,126 2,126

Y05 PIKE LAKES MOSER CREEK 43,577 2,604 69 69 69 5,489 5,489

Y06 DANGEROUS RIVER 27,110 421 23 23 23 436 436

Y07 OLD MIDDLE ITALIO 20,869 0 0 0 0 0 0

Y08 ITALIO 23,500 0 0 0 0 0 0

Y09 LOWER AKWE 3,234 0 0 0 0 0 0

Y10 UPPER AKWE 43,230 0 0 0 0 0 0

Y11 USTAY TANIS 53,356 0 0 0 0 0 0

Y12 DRY BAY ALSEK 53,339 0 0 0 0 0 0

Y13 BRABAZONS 436,629 0 0 0 0 0 0
Appendix C

Final EIS C-13 Outfitter/Guide Use Area Data Tables

Table C-3 (continued)

Change in Development LUD Acres without Roadless Protection by Outfitter/Guide Use Area and Alternative

Outfitter/Guide Use Area Total Acres

Total 

Development 

LUD Acres Change in Development LUD Acres from Alt 1

Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

Y14 HARLEQUIN LAKE 103,270 415 0 0 0 1,088 1,088

Y15 RUSSELL NUNATAK FJORDS 214,066 727 64 64 64 64 64

Y16 SITUK RIVER 38,676 7,664 3,829 3,829 3,829 5,809 5,809

Total 16,725,517 1,151,654 53,333 247,113 305,000 2,148,933 2,161,125
Appendix C

Outfitter/Guide Use Area Data Tables C-14 Final EIS

Table C-4

Change in Old-Growth Suitable Acres by Outfitter/Guide Use Area and Alternative

Outfitter/Guide Use Area Total Acres

Old-Growth 

Suitable 

Acres Change in Old-Growth Suitable Acres from Alt 1

Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

01-01 SKAGWAY AREA 255,036 0 0 0 0 0 0

01-02 HAINES AREA 19,514 0 0 0 0 0 0

01-03 EAST CHILKATS 361,545 6,345 291 291 3,421 4,350 4,350

01-04A BERNERS BAY 239,889 34 19 19 40 69 69

01-04B N. JUNEAU COAST 49,659 0 0 0 0 0 0

01-04C TAKU INLET 259,153 0 0 0 0 13 13

01-04D SLOCUM INLET 17,214 0 0 0 0 0 0

01-04E JUNEAU ICEFIELD 230,787 0 0 0 0 0 0

01-05A TAKU HARBOR 19,639 0 0 0 0 0 0

01-05B PORT SNETTISHAM 370,367 0 0 0 0 0 0

01-05C WINDHAM BAY 161,216 0 0 0 114 114 114

01-05D TRACY ARM 330,739 0 0 0 0 0 0

01-05E FORDS TERROR 24,386 0 0 0 0 0 0

01-05F ENDICOTT ARM 368,545 0 0 0 10 12 12

04-01A GUT BAY, BARANOF 93,986 0 0 0 0 0 0

04-01B PORT ARMSTRONG 70,962 0 0 0 0 0 0

04-01C NELSON BAY 44,166 0 0 0 0 0 0

04-02A REDOUBT LAKE 45,074 7 8 8 12 12 12

04-02B WHALE BAY 221,835 0 0 0 0 0 0

04-02C NECKER ISLANDS 6,197 0 0 0 0 0 0

04-02D SW BARANOF 54,366 0 0 0 0 0 0

04-03 SITKA AREA 345,862 2,322 20 20 2,529 2,530 2,530

04-04A RODMAN BAY 75,427 749 61 61 2,661 2,662 2,662

04-04B KELP BAY 144,680 2,524 66 66 3,880 3,880 3,880

04-04C BARANOF WARM SPRINGS 28,929 0 0 0 0 0 0

04-05A SW ADMIRALTY 114,955 0 0 0 0 0 0

04-05B MITCHELL BAY 61,008 0 0 0 0 0 0

04-06A PYBUS BAY 55,674 0 0 0 0 0 0

04-06B ELIZA HARBOR 85,206 0 0 0 0 0 0

04-07A GAMBIER BAY 119,252 0 0 0 0 0 0

04-07B CANOE ROUTE 86,687 0 0 0 0 0 0

04-08 NE ADMIRALTY 128,063 0 0 0 0 0 0

04-09A SEYMOUR CANAL 88,164 0 0 0 0 0 0

04-09B PACK CREEK 65,426 0 0 0 0 0 0

04-10A GREENS CREEK 2,575 0 0 0 0 0 0

04-10B NW ADMIRALTY 256,234 0 0 0 0 0 0

04-11A PORT FREDERICK 112,512 1,502 19 73 3,766 3,867 3,867
Appendix C

Final EIS C-15 Outfitter/Guide Use Area Data Tables

Table C-4 (continued)

Change in Old-Growth Suitable Acres by Outfitter/Guide Use Area and Alternative

Outfitter/Guide Use Area Total Acres

Old-Growth 

Suitable 

Acres Change in Old-Growth Suitable Acres from Alt 1

Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

04-11B FRESHWATER BAY 160,078 16,587 530 3,646 12,120 12,236 12,236

04-12 TENAKEE INLET 312,370 13,299 -1,348 1,736 11,727 11,735 11,736

04-13 PERIL STRAIT 232,130 2,998 28 28 1,537 2,536 2,536

04-14 SLOCUM ARM 97,008 0 0 0 0 0 0

04-15A LISIANSKI 90,638 0 0 0 0 0 0

04-15B WEST YAKOBI ISLAND 39,706 0 0 0 0 0 0

04-15C STAG BAY 26,663 0 0 0 0 0 0

04-15D PORTLOCK HARBOR 107,904 0 0 0 0 0 0

04-16A POINT ADOLPHUS 8,888 0 0 0 0 0 0

04-16B NORTH CHICHAGOF 64,726 0 0 0 0 0 0

04-16C IDAHO INLET 53,504 0 0 0 0 0 0

04-16D PLI WILDERNESS 23,079 0 0 0 0 0 0

04-16D PORT ALTHORP 19,475 0 0 0 0 0 0

CRD 00-00NO AREA DESIGNATED 925,876 12,932 4,312 9,921 14,856 15,847 15,851

J01 JUNEAU ICEFIELD 1 - GILKEY 

BACKCOUNTRY

315,751 0 0 0 0 0 0

J02 JUNEAU ICEFIELD 2 - EAGLE 10,300 0 0 0 0 0 0

J03 JUNEAU ICEFIELD 3 - HERBERT 12,636 0 0 0 0 0 0

J04 JUNEAU ICEFIELD 4 - MENDENHALL 38,095 0 0 0 0 0 0

J05 JUNEAU ICEFIELD 5 - LEMON 12,427 0 0 0 0 0 0

J06 JUNEAU ICEFIELD 6 - DEATH VALLEY 54,498 0 0 0 0 0 0

J07 JUNEAU ICEFIELD 7 - NORRIS 37,781 0 0 0 0 0 0

J08 JUNEAU ICEFIELD 8 - TAKU 35,343 0 0 0 0 0 0

J09 JUNEAU ICEFIELD 9 - TWIN 61,660 0 0 0 0 0 0

K01 WEST MISTY 192,830 23 0 15 15 27 27

K02 NORTHEAST MISTY 1,300,687 0 0 0 0 0 0

K03 SOUTH MISTY 628,890 0 0 0 0 0 0

K04 DUKE ISLAND 40,202 0 0 0 0 0 0

K05 SOUTH MISTY LAKES 14,878 0 0 0 0 0 0

K06 MISTY CORE LAKES 57,861 0 0 0 0 0 0

K07 WALKER CHICKAMIN 14,320 0 0 0 0 0 0

K08 BURROUGHS UNUK 29,455 0 0 0 0 0 0

K09 ALAVA PRINCESS MANZANITA 20,568 0 0 0 0 0 0

K10 RUDYERD WINSTANLEY 20,285 0 0 0 0 0 0

K11 GRAVINA ISLAND 39,700 70 94 1,032 1,030 1,045 1,045

K12 BELL ISLAND 137,694 0 0 0 0 0 0
Appendix C

Outfitter/Guide Use Area Data Tables C-16 Final EIS

Table C-4 (continued)

Change in Old-Growth Suitable Acres by Outfitter/Guide Use Area and Alternative

Outfitter/Guide Use Area Total Acres

Old-Growth 

Suitable 

Acres Change in Old-Growth Suitable Acres from Alt 1

Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

K13 EAST CLEVELAND 87,531 0 0 0 0 116 116

K14 WEST CLEVELAND 73,232 0 0 0 0 0 0

K15 WILSON BAKEWELL 13,440 0 0 0 0 0 0

K16 KETCHIKAN CORE SPNW 46,341 408 22 3,282 2,628 3,311 3,311

K17 GEORGE CARROLL THORNE 137,434 3,829 1,638 7,393 9,671 9,673 9,673

K18 CENTRAL REVILLA SPNW 92,792 6,140 220 1,568 5,266 5,266 5,266

K19 NORTH REVILLA 70,401 2,181 103 103 2,384 2,654 2,655

K20 HYDER SPNW 121,348 0 0 0 0 9 9

K21 PERCY HOTSPUR MARY 6,924 0 0 0 0 0 0

K22 HYDER NA 7,261 3 0 0 0 12 12

K23 BETTON ISLAND 5,028 0 0 0 0 0 0

K24 KETCHIKAN CORE NA 19,239 417 6 87 87 87 87

K25 SOUTH REVILLA 40,219 8,007 1,627 1,887 2,266 2,266 2,266

K26 CENTRAL REVILLA NA 15,451 3,564 8 218 221 221 221

K27 MARGARET BAY 9,707 2,058 31 121 203 203 203

K28 NAHA BAY 5,273 0 0 0 0 0 0

P01 MITKOF ISLAND 109,302 15,527 9 1,431 3,385 3,572 3,572

P02 DUNCAN CANAL - WEST SIDE 73,636 0 0 0 0 0 0

P04 DUNCAN CANAL - EAST SIDE 53,325 3,760 2,352 4,570 6,365 6,595 6,595

P05 WRANGELL NARROWS/WOEWODSKI 

IS.

17,033 118 -97 -49 361 509 509

P06 KUPREANOF ISLAND - NORTH 

SHORE

11,303 0 0 0 0 0 0

P07 PETERSBURG CREEK/DUNCAN SALT 

CHUCK

49,950 0 2 28 30 36 36

P08 NORTH LINDENBERG PENINSULA 75,605 4,661 3,263 7,320 8,770 8,862 8,862

P09 CENTRAL KUPREANOF ISLAND/ROAD 

SYSTEM

223,302 8,367 457 5,794 5,799 5,799 5,799

P10 SOUTHWEST KUPREANOF ISLAND 93,507 0 0 0 0 0 0

P11 ROWAN BAY/BAY OF PILLARS 28,721 4 0 0 0 0 0

P12A SAGINAW/SECURITY/WASHINGTON 

BAYS

32,450 311 0 0 0 0 0

P12B KUIU ISLAND ROAD SYSTEM 134,852 14,741 -1,351 1,049 4,247 4,248 4,248

P13 TEBENKOF BAY/KUIU WILDERNESS 127,218 0 0 0 0 0 0

P14 KEKU STRAIT/PORT CAMDEN 102,299 61 0 905 930 930 930

P15 SOUTH KUIU ISLAND 62,824 0 0 0 0 0 0

P16 REID/NO NAME BAYS 43,191 0 0 0 297 297 297
Appendix C

Final EIS C-17 Outfitter/Guide Use Area Data Tables

Table C-4 (continued)

Change in Old-Growth Suitable Acres by Outfitter/Guide Use Area and Alternative

Outfitter/Guide Use Area Total Acres

Old-Growth 

Suitable 

Acres Change in Old-Growth Suitable Acres from Alt 1

Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

P21 MUDDY RIVER AREA 63,357 2,891 115 3,180 6,764 6,772 6,772

P22 THOMAS BAY/POINT VANDEPUT 76,810 0 0 0 0 0 0

P23 FARRAGUT BAY/CAPE FANSHAW 66,716 0 0 0 0 0 0

P24 BAIRD/PATTERSON GLACIERS 402,216 0 0 0 0 0 0

SI-D SKAGWAY ICEFIELD - DENVER 19,600 0 0 0 0 0 0

SI-EF SKAGWAY ICEFIELD - EAST FORK 499 0 0 0 0 0 0

SI-LG SKAGWAY ICEFIELD - LE GRANDE 640 0 0 0 0 0 0

SI-M SKAGWAY ICEFIELD - MEADE 25,730 0 0 0 0 0 0

SI-S SKAGWAY ICEFIELD - SCHUBEE 2,934 0 0 0 0 0 0

TBRD 00-00NO AREA DESIGNATED 901,507 62,326 3,114 14,383 20,349 21,299 21,299

W10 STIKINE - LECONTE WILDERNESS 263,581 0 0 0 0 4 4

W100 NORTH ETOLIN ISLAND 151,750 3,207 35 1,604 2,980 4,102 4,102

W120 SOUTH ETOLIN ISLAND 

WILDERNESS

82,517 0 0 0 20 20 20

W130 VANK ISLAND GROUP 22,927 459 0 0 0 0 0

W140 KASHEVAROF GROUP 11,470 706 0 0 0 0 0

W150 LECONTE BAY (S-LC WILDERNESS) 175,361 0 0 0 0 0 0

W30 GARNET/MILL CREEK 56,850 0 0 0 0 1 1

W40 MADAN/BOULDER 105,035 0 0 0 0 0 0

W50 BRADFIELD CANAL AND RIVER 516,308 1 0 0 0 0 0

W60 ANAN CREEK 38,615 0 0 12 12 13 13

W70 CLEVELAND PEN./DEER ISLAND 48,383 1,529 122 351 1,697 1,697 1,697

W80 WRANGELL ISLAND 113,539 8,186 1,869 9,711 9,711 9,713 9,713

W90 ZAREMBO 116,402 14,334 1,871 2,825 8,432 8,528 8,528

Y01 YAKUTAT BAY 69,745 0 0 0 0 0 0

Y02 LOST TAWAH 9,112 52 0 0 0 0 0

Y03 KUNYOSH SEAL CREEKS 49,765 0 0 0 0 0 0

Y04 AHRNKLIN ANTLEN 30,315 0 0 0 0 0 0

Y05 PIKE LAKES MOSER CREEK 43,577 0 0 0 0 0 0

Y06 DANGEROUS RIVER 27,110 0 0 0 0 0 0

Y07 OLD MIDDLE ITALIO 20,869 0 0 0 0 0 0

Y08 ITALIO 23,500 0 0 0 0 0 0

Y09 LOWER AKWE 3,234 0 0 0 0 0 0

Y10 UPPER AKWE 43,230 0 0 0 0 0 0

Y11 USTAY TANIS 53,356 0 0 0 0 0 0

Y12 DRY BAY ALSEK 53,339 0 0 0 0 0 0

Y13 BRABAZONS 436,629 0 0 0 0 0 0
Appendix C

Outfitter/Guide Use Area Data Tables C-18 Final EIS

Table C-4 (continued)

Change in Old-Growth Suitable Acres by Outfitter/Guide Use Area and Alternative

Outfitter/Guide Use Area Total Acres

Old-Growth 

Suitable 

Acres Change in Old-Growth Suitable Acres from Alt 1

Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

Y14 HARLEQUIN LAKE 103,270 0 0 0 0 0 0

Y15 RUSSELL NUNATAK FJORDS 214,066 0 0 0 0 0 0

Y16 SITUK RIVER 38,676 10 2 2 2 2 2

Total 16,725,517 227,251 19,518 84,692 160,596 167,749 167,755
Appendix C

Final EIS C-19 Outfitter/Guide Use Area Data Tables

Table C-5

Change in Young-Growth Suitable Acres by Outfitter/Guide Use Area and Alternative

Outfitter/Guide Use Area Total Acres

Young-Growth 

Suitable Acres Change in Young-Growth Suitable Acres from Alt 1

Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

01-01 SKAGWAY AREA 255,036 0 0 0 38 38 38

01-02 HAINES AREA 19,514 654 0 0 0 5 75

01-03 EAST CHILKATS 361,545 3,777 687 687 688 1,061 1,105

01-04A BERNERS BAY 239,889 3 2 2 15 39 95

01-04B N. JUNEAU COAST 49,659 2 0 0 0 0 0

01-04C TAKU INLET 259,153 4 7 7 7 79 79

01-04D SLOCUM INLET 17,214 4 0 0 0 43 43

01-04E JUNEAU ICEFIELD 230,787 0 0 0 0 0 0

01-05A TAKU HARBOR 19,639 18 0 0 0 0 104

01-05B PORT SNETTISHAM 370,367 69 0 0 0 0 0

01-05C WINDHAM BAY 161,216 66 0 0 24 24 55

01-05D TRACY ARM 330,739 0 0 0 0 0 0

01-05E FORDS TERROR 24,386 0 0 0 0 0 0

01-05F ENDICOTT ARM 368,545 0 0 0 0 0 0

04-01A GUT BAY, BARANOF 93,986 0 0 0 0 0 0

04-01B PORT ARMSTRONG 70,962 0 0 0 0 0 0

04-01C NELSON BAY 44,166 0 0 0 0 0 0

04-02A REDOUBT LAKE 45,074 702 41 41 41 41 60

04-02B WHALE BAY 221,835 0 0 0 0 0 0

04-02C NECKER ISLANDS 6,197 0 0 0 0 0 0

04-02D SW BARANOF 54,366 0 0 0 0 0 0

04-03 SITKA AREA 345,862 9,849 1 9 9 9 37

04-04A RODMAN BAY 75,427 7,508 -44 -44 0 0 0

04-04B KELP BAY 144,680 3,535 1 1 1 1 6

04-04C BARANOF WARM SPRINGS 28,929 0 0 0 0 0 0

04-05A SW ADMIRALTY 114,955 0 0 0 0 0 0

04-05B MITCHELL BAY 61,008 0 0 0 0 0 0

04-06A PYBUS BAY 55,674 0 0 0 0 0 0

04-06B ELIZA HARBOR 85,206 0 0 0 0 0 0

04-07A GAMBIER BAY 119,252 0 0 0 0 0 0

04-07B CANOE ROUTE 86,687 0 0 0 0 0 0

04-08 NE ADMIRALTY 128,063 0 0 0 0 0 0

04-09A SEYMOUR CANAL 88,164 0 0 0 0 0 0

04-09B PACK CREEK 65,426 0 0 0 0 0 0

04-10A GREENS CREEK 2,575 0 0 0 0 0 0

04-10B NW ADMIRALTY 256,234 0 0 0 0 0 0
Appendix C

Outfitter/Guide Use Area Data Tables C-20 Final EIS

Table C-5 (continued)

Change in Young-Growth Suitable Acres by Outfitter/Guide Use Area and Alternative

Outfitter/Guide Use Area Total Acres

Young-Growth 

Suitable Acres Change in Young-Growth Suitable Acres from Alt 1

Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

04-11A PORT FREDERICK 112,512 3,789 2 2 13 18 126

04-11B FRESHWATER BAY 160,078 12,373 171 196 316 363 1,205

04-12 TENAKEE INLET 312,370 10,114 94 94 95 140 174

04-13 PERIL STRAIT 232,130 9,063 99 99 126 129 188

04-14 SLOCUM ARM 97,008 0 0 0 0 0 0

04-15A LISIANSKI 90,638 0 0 0 0 0 0

04-15B WEST YAKOBI ISLAND 39,706 0 0 0 0 0 0

04-15C STAG BAY 26,663 0 0 0 0 0 0

04-15D PORTLOCK HARBOR 107,904 0 0 0 0 0 0

04-16A POINT ADOLPHUS 8,888 0 0 0 0 0 0

04-16B NORTH CHICHAGOF 64,726 855 0 0 3 3 3

04-16C IDAHO INLET 53,504 0 0 0 0 0 0

04-16D PLI WILDERNESS 23,079 0 0 0 0 0 0

04-16D PORT ALTHORP 19,475 0 0 0 0 0 0

CRD 00-00NO AREA DESIGNATED 925,876 16,958 2,916 3,929 3,937 4,093 4,242

J01 JUNEAU ICEFIELD 1 - GILKEY 

BACKCOUNTRY

315,751 0 0 0 0 0 0

J02 JUNEAU ICEFIELD 2 - EAGLE 10,300 0 0 0 0 0 0

J03 JUNEAU ICEFIELD 3 - HERBERT 12,636 0 0 0 0 0 0

J04 JUNEAU ICEFIELD 4 - MENDENHALL 38,095 0 0 0 0 0 0

J05 JUNEAU ICEFIELD 5 - LEMON 12,427 0 0 0 0 0 0

J06 JUNEAU ICEFIELD 6 - DEATH VALLEY 54,498 0 0 0 0 0 0

J07 JUNEAU ICEFIELD 7 - NORRIS 37,781 0 0 0 0 0 0

J08 JUNEAU ICEFIELD 8 - TAKU 35,343 0 0 0 0 0 0

J09 JUNEAU ICEFIELD 9 - TWIN 61,660 0 0 0 0 0 0

K01 WEST MISTY 192,830 5 0 0 0 0 0

K02 NORTHEAST MISTY 1,300,687 0 0 0 0 0 0

K03 SOUTH MISTY 628,890 0 0 0 0 0 0

K04 DUKE ISLAND 40,202 0 0 0 0 0 0

K05 SOUTH MISTY LAKES 14,878 0 0 0 0 0 0

K06 MISTY CORE LAKES 57,861 0 0 0 0 0 0

K07 WALKER CHICKAMIN 14,320 0 0 0 0 0 0

K08 BURROUGHS UNUK 29,455 0 0 0 0 0 0

K09 ALAVA PRINCESS MANZANITA 20,568 0 0 0 0 0 0

K10 RUDYERD WINSTANLEY 20,285 0 0 0 0 0 0

K11 GRAVINA ISLAND 39,700 331 133 408 133 417 475

K12 BELL ISLAND 137,694 8 0 0 0 37 37

K13 EAST CLEVELAND 87,531 117 21 21 21 69 80
Appendix C

Final EIS C-21 Outfitter/Guide Use Area Data Tables

Table C-5 (continued)

Change in Young-Growth Suitable Acres by Outfitter/Guide Use Area and Alternative

Outfitter/Guide Use Area Total Acres

Young-Growth 

Suitable Acres Change in Young-Growth Suitable Acres from Alt 1

Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

K14 WEST CLEVELAND 73,232 0 9 9 9 31 56

K15 WILSON BAKEWELL 13,440 0 0 0 0 0 0

K16 KETCHIKAN CORE SPNW 46,341 501 11 80 19 60 103

K17 GEORGE CARROLL THORNE 137,434 4,166 324 337 381 380 382

K18 CENTRAL REVILLA SPNW 92,792 7,655 4 19 53 48 80

K19 NORTH REVILLA 70,401 2,278 5 5 133 144 154

K20 HYDER SPNW 121,348 5 0 0 0 1 15

K21 PERCY HOTSPUR MARY 6,924 0 0 0 0 0 0

K22 HYDER NA 7,261 169 0 0 0 28 46

K23 BETTON ISLAND 5,028 0 0 0 0 0 0

K24 KETCHIKAN CORE NA 19,239 267 0 43 24 24 43

K25 SOUTH REVILLA 40,219 8,224 425 427 435 434 435

K26 CENTRAL REVILLA NA 15,451 4,575 0 2 2 2 2

K27 MARGARET BAY 9,707 2,505 0 1 1 0 7

K28 NAHA BAY 5,273 0 0 0 0 0 0

P01 MITKOF ISLAND 109,302 9,756 5 6 23 31 57

P02 DUNCAN CANAL - WEST SIDE 73,636 647 0 0 0 33 44

P04 DUNCAN CANAL - EAST SIDE 53,325 4,356 826 826 826 826 826

P05 WRANGELL NARROWS/WOEWODSKI IS. 17,033 71 0 0 0 35 35

P06 KUPREANOF ISLAND - NORTH 

SHORE

11,303 11 0 9 0 0 9

P07 PETERSBURG CREEK/DUNCAN SALT 

CHUCK

49,950 0 0 0 0 0 0

P08 NORTH LINDENBERG PENINSULA 75,605 3,685 742 756 756 804 815

P09 CENTRAL KUPREANOF ISLAND/ROAD 

SYSTEM

223,302 6,887 1,312 1,359 1,347 1,368 1,404

P10 SOUTHWEST KUPREANOF ISLAND 93,507 1,632 102 102 102 124 124

P11 ROWAN BAY/BAY OF PILLARS 28,721 288 0 0 0 0 0

P12A SAGINAW/SECURITY/WASHINGTON 

BAYS

32,450 390 0 9 14 14 14

P12B KUIU ISLAND ROAD SYSTEM 134,852 19,585 0 2 25 34 49

P13 TEBENKOF BAY/KUIU WILDERNESS 127,218 0 0 0 0 0 0

P14 KEKU STRAIT/PORT CAMDEN 102,299 332 64 92 82 104 124

P15 SOUTH KUIU ISLAND 62,824 0 0 0 0 0 0

P16 REID/NO NAME BAYS 43,191 381 -53 -53 36 41 67

P21 MUDDY RIVER AREA 63,357 4,218 0 0 0 0 13

P22 THOMAS BAY/POINT VANDEPUT 76,810 384 0 0 0 0 0

P23 FARRAGUT BAY/CAPE FANSHAW 66,716 12 0 0 0 0 49
Appendix C

Outfitter/Guide Use Area Data Tables C-22 Final EIS

Table C-5 (continued)

Change in Young-Growth Suitable Acres by Outfitter/Guide Use Area and Alternative

Outfitter/Guide Use Area Total Acres

Young-Growth 

Suitable Acres Change in Young-Growth Suitable Acres from Alt 1

Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

P24 BAIRD/PATTERSON GLACIERS 402,216 0 0 0 0 0 0

SI-D SKAGWAY ICEFIELD - DENVER 19,600 0 0 0 0 0 0

SI-EF SKAGWAY ICEFIELD - EAST FORK 499 0 0 0 0 0 0

SI-LG SKAGWAY ICEFIELD - LE GRANDE 640 0 0 0 0 0 0

SI-M SKAGWAY ICEFIELD - MEADE 25,730 0 0 0 0 0 0

SI-S SKAGWAY ICEFIELD - SCHUBEE 2,934 0 0 0 0 0 0

TBRD 00-00NO AREA DESIGNATED 901,507 126,994 1,241 1,296 1,351 1,353 1,560

W10 STIKINE - LECONTE WILDERNESS 263,581 0 0 0 0 0 0

W100 NORTH ETOLIN ISLAND 151,750 4,459 521 553 593 959 1,143

W120 SOUTH ETOLIN ISLAND 

WILDERNESS

82,517 0 0 0 0 0 0

W130 VANK ISLAND GROUP 22,927 4,426 2 2 2 81 95

W140 KASHEVAROF GROUP 11,470 2,812 0 0 0 0 0

W150 LECONTE BAY (S-LC WILDERNESS) 175,361 0 0 0 0 0 0

W30 GARNET/MILL CREEK 56,850 0 0 0 0 49 221

W40 MADAN/BOULDER 105,035 27 0 0 0 12 12

W50 BRADFIELD CANAL AND RIVER 516,308 4,572 0 0 25 26 35

W60 ANAN CREEK 38,615 1 0 0 0 0 0

W70 CLEVELAND PEN./DEER ISLAND 48,383 1,641 0 0 0 0 3

W80 WRANGELL ISLAND 113,539 5,841 488 506 496 503 512

W90 ZAREMBO 116,402 13,985 755 879 931 931 1,094

Y01 YAKUTAT BAY 69,745 42 1 206 206 1 206

Y02 LOST TAWAH 9,112 727 0 0 0 0 0

Y03 KUNYOSH SEAL CREEKS 49,765 462 4 4 4 4 4

Y04 AHRNKLIN ANTLEN 30,315 76 1 352 351 355 355

Y05 PIKE LAKES MOSER CREEK 43,577 190 5 929 694 695 929

Y06 DANGEROUS RIVER 27,110 227 14 225 198 225 225

Y07 OLD MIDDLE ITALIO 20,869 0 0 0 0 0 0

Y08 ITALIO 23,500 0 0 0 0 0 0

Y09 LOWER AKWE 3,234 0 0 0 0 0 0

Y10 UPPER AKWE 43,230 0 0 0 0 0 0

Y11 USTAY TANIS 53,356 0 0 0 0 0 0

Y12 DRY BAY ALSEK 53,339 0 0 0 0 0 0

Y13 BRABAZONS 436,629 0 0 0 0 0 0

Y14 HARLEQUIN LAKE 103,270 184 0 218 213 219 219

Y15 RUSSELL NUNATAK FJORDS 214,066 345 0 0 0 0 0

Y16 SITUK RIVER 38,676 3,935 338 349 348 351 361

Total 16,725,517 333,729 11,278 15,003 15,146 16,939 20,152
APPENDIX D 

SUITABLE TIMBER BY COMMUNITY 
Appendix D

Final EIS D-1 Suitable Timber by Community

Appendix D

Suitable Timber by Community

Suitable timber maps for each community are available on the electronic storage device accompanying 

this document and available online at: https://www.fs.usda.gov/project/?project=54511.

Suitability maps were created for each community use area and alternative. These maps show suitable 

old-growth and young-growth. However, to better approximate where future old-growth harvest might 

occur, some suitable old growth is not shown because it is less desirable low-volume old growth or for 

poor economics. These maps do not reflect the fact that most harvest currently occurs on the southern 

ranger districts. These maps support the analysis in the FEIS and in Appendix E and are provided as 

another tool to help reviewers understand where harvests might occur.

Readers wishing to view unaltered old-growth suitability maps are referred to Maps 7-12 on the thumb 

drive and website, which show suitability by alternative.
APPENDIX E

COMMUNITIES
Appendix E

Final EIS E-i Communities

Appendix E

Communities

CONTENTS

Affected Environment............................................................................................................................. E-1

Individual Community Profiles ............................................................................................................... E-4

Angoon (Aangóon) ..............................................................................................................................E-4

Coffman Cove (Shaan da)...................................................................................................................E-4

Craig ....................................................................................................................................................E-4

Edna Bay .............................................................................................................................................E-5

Elfin Cove ............................................................................................................................................E-5

Gustavus..............................................................................................................................................E-5

Haines..................................................................................................................................................E-5

Hollis ....................................................................................................................................................E-5

Hoonah (Xunaa) ..................................................................................................................................E-6

Hydaburg .............................................................................................................................................E-6

Hyder ...................................................................................................................................................E-6

Juneau (Dzántik’I Héeni) .....................................................................................................................E-6

Kake (Kéex’) ........................................................................................................................................E-6

Kasaan.................................................................................................................................................E-7

Ketchikan (Kicháan) ............................................................................................................................E-7

Klawock (Lawáak)................................................................................................................................E-7

Kupreanof ............................................................................................................................................E-7

Metlakatla ............................................................................................................................................E-8

Naukati Bay .........................................................................................................................................E-8

Pelican .................................................................................................................................................E-8

Petersburg (Gánti Yaaks Séedi)..........................................................................................................E-8

Point Baker ..........................................................................................................................................E-8

Port Alexander.....................................................................................................................................E-9

Port Protection.....................................................................................................................................E-9

Saxman................................................................................................................................................E-9

Sitka (Sheet’ká) ...................................................................................................................................E-9

Skagway ..............................................................................................................................................E-9

Tenakee Springs................................................................................................................................E-10

Thorne Bay ........................................................................................................................................E-10

Whale Pass........................................................................................................................................E-10

Wrangell (Kaachxana.áak’w).............................................................................................................E-10

Yakutat (Yaakwdáat) .........................................................................................................................E-10

Environmental Consequences ............................................................................................................ E-11

Analyzing Impacts to Communities...................................................................................................... E-11

ARA Management Categories and Changes in Roadless Area Acres .............................................E-12

Changes in Development LUDs ........................................................................................................E-13

Changes in Suitable Timber ..............................................................................................................E-13
Appendix E

Communities E-ii Final EIS

Estimated Timber Harvest over 100 Years .......................................................................................E-13

Potential Impacts by Resource Area ................................................................................................... E-14

Forest Products .................................................................................................................................E-14

Recreation and Tourism ....................................................................................................................E-14

Infrastructure Development ...............................................................................................................E-14

Alaska Native Customary and Traditional Uses ................................................................................E-15

Subsistence .......................................................................................................................................E-15

Individual Community Assessments .................................................................................................... E-17

Angoon (Aangóon) ............................................................................................................................E-17

Coffman Cove....................................................................................................................................E-21

Craig (Shaan da) ...............................................................................................................................E-24

Edna Bay ...........................................................................................................................................E-27

Elfin Cove ..........................................................................................................................................E-30

Gustavus............................................................................................................................................E-33

Haines................................................................................................................................................E-35

Hollis ..................................................................................................................................................E-40

Hoonah (Xunaa) ................................................................................................................................E-43

Hydaburg ...........................................................................................................................................E-47

Hyder .................................................................................................................................................E-50

Juneau (Dzántik’I Héeni) ...................................................................................................................E-52

Kake (Kéex’) ......................................................................................................................................E-54

Kasaan...............................................................................................................................................E-57

Ketchikan (Kicháan) ..........................................................................................................................E-60

Klawock (Lawáak)..............................................................................................................................E-62

Metlakatla ..........................................................................................................................................E-66

Naukati Bay .......................................................................................................................................E-69

Pelican ...............................................................................................................................................E-72

Petersburg (Gánti Yaaks Séedi) and Kupreanof ...............................................................................E-75

Point Baker ........................................................................................................................................E-78

Port Alexander...................................................................................................................................E-82

Port Protection...................................................................................................................................E-84

Saxman..............................................................................................................................................E-87

Sitka (Sheet’ká) .................................................................................................................................E-89

Skagway ............................................................................................................................................E-93

Tenakee Springs................................................................................................................................E-96

Thorne Bay ........................................................................................................................................E-99

Whale Pass......................................................................................................................................E-102

Wrangell (Kaachxana.áak’w)...........................................................................................................E-105

Yakutat (Yaakwdáat) .......................................................................................................................E-108

References........................................................................................................................................... E-111

List of Tables

Table E-1 Southeast Alaska Community Statistics............................................................................. E-1

Table E-2 Southeast Alaska Community Employment and Business License Data .......................... E-3

Table E-3 Roadless Areas, ARA Management Categories, and Development Opportunity in 

Angoon’s Community Use Area....................................................................................... E-18
Appendix E

Final EIS E-iii Communities

Table E-4 Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where 

Angoon Residents Obtain Approximately 75 Percent of their Average Annual Deer 

Harvest1............................................................................................................................ E-20

Table E-5 Suitable Old-Growth by WAA and Alternative for the WAAs where Angoon Residents 

Obtain Approximately 75 Percent of their Average Annual Deer Harvest ....................... E-20

Table E-6 Projected Old-Growth Harvest by WAA and Alternative for the WAAs where Angoon 

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest...... E-20

Table E-7 Roadless Areas, ARA Management Categories, and Development Opportunity in 

Coffman Cove’s Community Use Area ............................................................................ E-22

Table E-8 Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where 

Coffman Cove Residents Obtain Approximately 75 Percent of their Average Annual 

Deer Harvest1 ................................................................................................................... E-23

Table E-9 Suitable Old-Growth by WAA and Alternative for the WAAs where Coffman Cove 

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest...... E-23

Table E-10 Projected Old-Growth Harvest by WAA and Alternative for the WAAs where Coffman 

Cove Residents Obtain Approximately 75 Percent of their Average Annual Deer 

Harvest............................................................................................................................. E-23

Table E-11 Roadless Areas, ARA Management Categories, and Development Opportunity in 

Craig’s Community Use Area........................................................................................... E-25

Table E-12 Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where Craig 

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest1..... E-26

Table E-13 Suitable Old-Growth by WAA and Alternative for the WAAs where Craig Residents 

Obtain Approximately 75 Percent of their Average Annual Deer Harvest ....................... E-27

Table E-14 Projected Old-Growth Timber Harvest over 100 Years by WAA and Alternative for 

the WAAs where Craig Residents Obtain Approximately 75 Percent of their Average 

Annual Deer Harvest........................................................................................................ E-27

Table E-15 Roadless Areas, ARA Management Categories, and Development Opportunity in 

Edna Bay’s Community Use Area.................................................................................... E-28

Table E-16 Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where Edna 

Bay Residents Obtain Approximately 75 Percent of their Average Annual Deer 

Harvest1............................................................................................................................ E-29

Table E-17 Suitable Old-Growth by WAA and Alternative for the WAAs where Edna Bay 

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest...... E-30

Table E-18 Projected Old-Growth Harvest by WAA and Alternative for the WAAs where Edna 

Bay Residents Obtain Approximately 75 Percent of their Average Annual Deer 

Harvest............................................................................................................................. E-30

Table E-19 Roadless Areas, ARA Management Categories, and Development Opportunity in

Elfin Cove's Community Use Area ................................................................................... E-31

Table E-20 Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where Elfin 

Cove Residents Obtain Approximately 75 Percent of their Average Annual Deer 

Harvest1............................................................................................................................ E-32

Table E-21 Suitable Old-Growth by WAA and Alternative for the WAAs where Elfin Cove 

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest...... E-32

Table E-22 Projected Old-Growth Harvest by WAA and Alternative for the WAAs where Elfin 

Cove Residents Obtain Approximately 75 Percent of their Average Annual Deer 

Harvest............................................................................................................................. E-32

Table E-23 Roadless Areas, ARA Management Categories, and Development Opportunity in 

Gustavus' Community Use Area ...................................................................................... E-34

Table E-24 Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where 

Gustavus Residents Obtain Approximately 75 Percent of their Average Annual Deer 

Harvest1............................................................................................................................ E-35
Appendix E

Communities E-iv Final EIS

Table E-25 Suitable Old-Growth by WAA and Alternative for the WAAs where Gustavus 

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest...... E-35

Table E-26 Projected Old-Growth Harvest by WAA and Alternative for the WAAs where 

Gustavus Residents Obtain Approximately 75 Percent of their Average Annual Deer 

Harvest............................................................................................................................. E-35

Table E-27 Roadless Areas, ARA Management Categories, and Development Opportunity in

Haines' Community Use Area .......................................................................................... E-36

Table E-28 Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where 

Haines Residents Obtain Approximately 75 Percent of their Average Annual Deer 

Harvest1............................................................................................................................ E-37

Table E-29 Suitable Old-Growth by WAA and Alternative for the WAAs where Haines Residents 

Obtain Approximately 75 Percent of their Average Annual Deer Harvest ....................... E-39

Table E-30 Projected Old-Growth Harvest by WAA and Alternative for the WAAs where Haines 

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest...... E-39

Table E-31 Roadless Areas, ARA Management Categories, and Development Opportunity in 

Hollis' Community Use Area............................................................................................. E-42

Table E-32 Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where Hollis 

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest1..... E-42

Table E-33 Suitable Old-Growth by WAA and Alternative for the WAAs where Hollis Residents 

Obtain Approximately 75 Percent of their Average Annual Deer Harvest ....................... E-43

Table E-34 Projected Old-Growth Harvest by WAA and Alternative for the WAAs where Hollis 

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest...... E-43

Table E-35 Roadless Areas, ARA Management Categories, and Development Opportunity in 

Hoonah's Community Use Area....................................................................................... E-45

Table E-36 Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where 

Hoonah Residents Obtain Approximately 75 Percent of their Average Annual Deer 

Harvest1............................................................................................................................ E-46

Table E-37 Suitable Old-Growth by WAA and Alternative for the WAAs where Hoonah Residents 

Obtain Approximately 75 Percent of their Average Annual Deer Harvest ....................... E-46

Table E-38 Projected Old-Growth Harvest by WAA and Alternative for the WAAs where Hoonah 

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest...... E-47

Table E-39 Roadless Areas, ARA Management Categories, and Development Opportunity in 

Hydaburg’s Community Use Area.................................................................................... E-48

Table E-40 Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where 

Hydaburg Residents Obtain Approximately 75 Percent of their Average Annual Deer 

Harvest1............................................................................................................................ E-49

Table E-41 Suitable Old-Growth by WAA and Alternative for the WAAs where Hydaburg 

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest...... E-50

Table E-42 Projected Old-Growth Harvest by WAA and Alternative for the WAAs where 

Hydaburg Residents Obtain Approximately 75 Percent of their Average Annual Deer 

Harvest............................................................................................................................. E-50

Table E-43 Roadless Areas, ARA Management Categories, and Development Opportunity in 

Hyder's Community Use Area.......................................................................................... E-51

Table E-44 Roadless Areas, ARA Management Categories, and Development Opportunity in 

Juneau's Community Use Area........................................................................................ E-53

Table E-45 Roadless Areas, ARA Management Categories, and Development Opportunity in 

Kake's Community Use Area ........................................................................................... E-55

Table E-46 Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where Kake 

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest1..... E-56

Table E-47 Suitable Old-Growth by WAA and Alternative for the WAAs where Kake Residents 

Obtain Approximately 75 Percent of their Average Annual Deer Harvest ....................... E-57
Appendix E

Final EIS E-v Communities

Table E-48 Projected Old-Growth Harvest by WAA and Alternative for the WAAs where Kake 

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest...... E-57

Table E-49 Roadless Areas, ARA Management Categories, and Development Opportunity in 

Kasaan's Community Use Area ....................................................................................... E-58

Table E-50 Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where 

Kasaan Residents Obtain Approximately 75 Percent of their Average Annual Deer 

Harvest1............................................................................................................................ E-59

Table E-51 Suitable Old-Growth by WAA and Alternative for the WAAs where Kasaan Residents 

Obtain Approximately 75 Percent of their Average Annual Deer Harvest ....................... E-60

Table E-52 Projected Old-Growth Harvest by WAA and Alternative for the WAAs where Kasaan 

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest...... E-60

Table E-53 Roadless Areas, ARA Management Categories, and Development Opportunity in 

Ketchikan's Community Use Area.................................................................................... E-61

Table E-54 Roadless Areas, ARA Management Categories, and Development Opportunity in 

Klawock's Community Use Area ...................................................................................... E-63

Table E-55 Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where 

Klawock Residents Obtain Approximately 75 Percent of their Average Annual Deer 

Harvest1............................................................................................................................ E-64

Table E-56 Suitable Old-Growth by WAA and Alternative for the WAAs where Klawock 

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest...... E-65

Table E-57 Projected Old-Growth Harvest by WAA and Alternative for the WAAs where Klawock 

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest...... E-65

Table E-58 Roadless Areas, ARA Management Categories, and Development Opportunity in 

Metlakatla's Community Use Area ................................................................................... E-67

Table E-59 Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where 

Metlakatla Residents Obtain Approximately 75 Percent of their Average Annual Deer 

Harvest1............................................................................................................................ E-68

Table E-60 Suitable Old-Growth by WAA and Alternative for the WAAs where Metlakatla 

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest...... E-68

Table E-61 Projected Old-Growth Harvest by WAA and Alternative for the WAAs where 

Metlakatla Residents Obtain Approximately 75 Percent of their Average Annual Deer 

Harvest............................................................................................................................. E-69

Table E-62 Roadless Areas, ARA Management Categories, and Development Opportunity in 

Naukati Bay's Community Use Area ................................................................................ E-70

Table E-63 Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where 

Naukati Bay Residents Obtain Approximately 75 Percent of their Average Annual 

Deer Harvest1 ................................................................................................................... E-71

Table E-64 Suitable Old-Growth by WAA and Alternative for the WAAs where Naukati Bay 

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest...... E-72

Table E-65 Projected Old-Growth Harvest by WAA and Alternative for the WAAs where Naukati 

Bay Residents Obtain Approximately 75 Percent of their Average Annual Deer 

Harvest............................................................................................................................. E-72

Table E-66 Roadless Areas, ARA Management Categories, and Development Opportunity in 

Pelican's Community Use Area........................................................................................ E-73

Table E-67 Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where 

Pelican Residents Obtain Approximately 75 Percent of their Average Annual Deer 

Harvest1............................................................................................................................ E-74

Table E-68 Suitable Old-Growth by WAA and Alternative for the WAAs where Pelican Residents 

Obtain Approximately 75 Percent of their Average Annual Deer Harvest ....................... E-74

Table E-69 Projected Old-Growth Harvest by WAA and Alternative for the WAAs where Pelican 

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest...... E-74
Appendix E

Communities E-vi Final EIS

Table E-70 Roadless Areas, ARA Management Categories, and Development Opportunity in 

Petersburg's Community Use Area.................................................................................. E-76

Table E-71 Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where 

Petersburg and Kupreanof Residents Obtain Approximately 75 Percent of their 

Average Annual Deer Harvest1 ........................................................................................ E-77

Table E-72 Suitable Old-Growth by WAA and Alternative for the WAAs where Petersburg and 

Kupreanof Residents Obtain Approximately 75 Percent of their Average Annual Deer 

Harvest............................................................................................................................. E-78

Table E-73 Projected Old-Growth Harvest by WAA and Alternative for the WAAs where 

Petersburg and Kupreanof Residents Obtain Approximately 75 Percent of their 

Average Annual Deer Harvest ......................................................................................... E-78

Table E-74 Roadless Areas, ARA Management Categories, and Development Opportunity in 

Point Baker's Community Use Area................................................................................. E-80

Table E-75 Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where Point 

Baker Residents Obtain Approximately 75 Percent of their Average Annual Deer 

Harvest1............................................................................................................................ E-81

Table E-76 Suitable Old-Growth by WAA and Alternative for the WAAs where Point Baker 

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest...... E-81

Table E-77 Projected Old-Growth Harvest by WAA and Alternative for the WAAs where Point 

Baker Residents Obtain Approximately 75 Percent of their Average Annual Deer 

Harvest............................................................................................................................. E-81

Table E-78 Roadless Areas, ARA Management Categories, and Development Opportunity in 

Port Alexander's Community Use Area............................................................................ E-83

Table E-79 Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where Port 

Alexander Residents Obtain Approximately 75 Percent of their Average Annual Deer 

Harvest1............................................................................................................................ E-83

Table E-80 Suitable Old-Growth by WAA and Alternative for the WAAs where Port Alexander 

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest...... E-84

Table E-81 Projected Old-Growth Harvest by WAA and Alternative for the WAAs where Port 

Alexander Residents Obtain Approximately 75 Percent of their Average Annual Deer 

Harvest............................................................................................................................. E-84

Table E-82 Roadless Areas, ARA Management Categories, and Development Opportunity in 

Port Protection's Community Use Area............................................................................ E-85

Table E-83 Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where Port 

Protection Residents Obtain Approximately 75 Percent of their Average Annual Deer 

Harvest1............................................................................................................................ E-86

Table E-84 Suitable Old-Growth by WAA and Alternative for the WAAs where Port Protection 

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest...... E-87

Table E-85 Projected Old-Growth Harvest by WAA and Alternative for the WAAs where Port 

Protection Residents Obtain Approximately 75 Percent of their Average Annual Deer 

Harvest............................................................................................................................. E-87

Table E-86 Roadless Areas, ARA Management Categories, and Development Opportunity in 

Saxman's Community Use Area ...................................................................................... E-88

Table E-87 Roadless Areas, ARA Management Categories, and Development Opportunity in 

Sitka's Community Use Area ........................................................................................... E-90

Table E-88 Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where Sitka 

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest1..... E-92

Table E-89 Suitable Old-Growth by WAA and Alternative for the WAAs where Sitka Residents 

Obtain Approximately 75 Percent of their Average Annual Deer Harvest ....................... E-93

Table E-90 Projected Old-Growth Harvest by WAA and Alternative for the WAAs where Sitka 

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest...... E-93
Appendix E

Final EIS E-vii Communities

Table E-91 Roadless Areas, ARA Management Categories, and Development Opportunity in 

Skagway's Community Use Area..................................................................................... E-95

Table E-92 Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where 

Skagway Residents Obtain Approximately 75 Percent of their Average Annual Deer 

Harvest1............................................................................................................................ E-95

Table E-93 Suitable Old-Growth by WAA and Alternative for the WAAs where Skagway 

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest...... E-96

Table E-94 Projected Old-Growth Harvest by WAA and Alternative for the WAAs where 

Skagway Residents Obtain Approximately 75 Percent of their Average Annual Deer 

Harvest............................................................................................................................. E-96

Table E-95 Roadless Areas, ARA Management Categories, and Development Opportunity in 

Tenakee Springs' Community Use Area.......................................................................... E-97

Table E-96 Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where 

Tenakee Springs Residents Obtain Approximately 75 Percent of their Average 

Annual Deer Harvest1....................................................................................................... E-98

Table E-97 Suitable Old-Growth by WAA and Alternative for the WAAs where Tenakee Springs 

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest...... E-99

Table E-98 Projected Old-Growth Harvest by WAA and Alternative for the WAAs where Tenakee 

Springs Residents Obtain Approximately 75 Percent of their Average Annual Deer 

Harvest............................................................................................................................. E-99

Table E-99 Roadless Areas, ARA Management Categories, and Development Opportunity in 

Thorne Bay's Community Use Area............................................................................... E-100

Table E-100 Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where 

Thorne Bay Residents Obtain Approximately 75 Percent of their Average Annual 

Deer Harvest1 ................................................................................................................. E-101

Table E-101 Suitable Old-Growth by WAA and Alternative for the WAAs where Thorne Bay 

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest.... E-102

Table E-102 Projected Old-Growth Harvest by WAA and Alternative for the WAAs where Thorne 

Bay Residents Obtain Approximately 75 Percent of their Average Annual Deer 

Harvest........................................................................................................................... E-102

Table E-103 Roadless Areas, ARA Management Categories, and Development Opportunity in 

Whale Pass' Community Use Area ................................................................................ E-103

Table E-104 Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where Whale 

Pass Residents Obtain Approximately 75 Percent of their Average Annual Deer 

Harvest1.......................................................................................................................... E-104

Table E-105 Suitable Old-Growth by WAA and Alternative for the WAAs where Whale Pass 

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest.... E-105

Table E-106 Projected Old-Growth Harvest by WAA and Alternative for the WAAs where Whale 

Pass Residents Obtain Approximately 75 Percent of their Average Annual Deer 

Harvest........................................................................................................................... E-105

Table E-107 Roadless Areas, ARA Management Categories, and Development Opportunity in 

Wrangell's Community Use Area ................................................................................... E-106

Table E-108 Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where 

Wrangell Residents Obtain Approximately 75 Percent of their Average Annual Deer 

Harvest1.......................................................................................................................... E-107

Table E-109 Suitable Old-Growth by WAA and Alternative for the WAAs where Wrangell 

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest.... E-108

Table E-110 Projected Old-Growth Harvest by WAA and Alternative for the WAAs where Wrangell 

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest.... E-108

Table E-111 Roadless Areas, ARA Management Categories, and Development Opportunity in 

Yakutat's Community Use Area ..................................................................................... E-109
Appendix E

Communities E-viii Final EIS

Table E-112 Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where 

Yakutat Residents Obtain Approximately 75 Percent of their Average Annual Deer 

Harvest1.......................................................................................................................... E-110

Table E-113 Suitable Old-Growth by WAA and Alternative for the WAAs where Yakutat Residents 

Obtain Approximately 75 Percent of their Average Annual Deer Harvest ..................... E-111

Table E-114 Projected Old-Growth Harvest by WAA and Alternative for the WAAs where Yakutat 

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest.... E-111

List of Figures

Figure E-1 Angoon’s Community Use Area ...................................................................................... E-18

Figure E-2 Coffman Cove’s Community Use Area ........................................................................... E-21

Figure E-3 Craig’s Community Use Area.......................................................................................... E-24

Figure E-4 Edna Bay’s Community Use Area................................................................................... E-28

Figure E-5 Elfin Cove’s Community Use Area .................................................................................. E-31

Figure E-6 Gustavus Community Use Area...................................................................................... E-33

Figure E-7 Haines Community Use Area.......................................................................................... E-36

Figure E-8 Hollis’ Community Use Area............................................................................................ E-41

Figure E-9 Hoonah’s Community Use Area...................................................................................... E-44

Figure E-10 Hydaburg’s Community Use Area................................................................................... E-48

Figure E-11 Hyder’s Community Use Area......................................................................................... E-51

Figure E-12 Juneau’s Community Use Area....................................................................................... E-53

Figure E-13 Kake’s Community Use Area .......................................................................................... E-55

Figure E-14 Kasaan’s Community Use Area ...................................................................................... E-58

Figure E-15 Ketchikan’s Community Use Area................................................................................... E-61

Figure E-16 Klawock’s Community Use Area ..................................................................................... E-63

Figure E-17 Metlakatla’s Community Use Area .................................................................................. E-66

Figure E-18 Naukati Bay’s Community Use Area ............................................................................... E-70

Figure E-19 Pelican’s Community Use Area....................................................................................... E-73

Figure E-20 Petersburg’s Community Use Area................................................................................. E-75

Figure E-21 Point Baker’s Community Use Area................................................................................ E-79

Figure E-22 Port Alexander’s Community Use Area........................................................................... E-82

Figure E-23 Port Protection’s Community Use Area........................................................................... E-85

Figure E-24 Saxman’s Community Use Area ..................................................................................... E-88

Figure E-25 Sitka’s Community Use Area .......................................................................................... E-90

Figure E-26 Skagway’s Community Use Area.................................................................................... E-94

Figure E-27 Tenakee Springs’ Community Use Area......................................................................... E-97

Figure E-28 Thorne Bay’s Community Use Area.............................................................................. E-100

Figure E-29 Whale Pass’ Community Use Area ............................................................................... E-103

Figure E-30 Wrangell’s Community Use Area .................................................................................. E-106

Figure E-31 Yakutat’s Community Use Area .................................................................................... E-109
Appendix E

Final EIS E-1 Communities

Communities

Affected Environment

Southeast Alaska includes more than 30 towns and villages located in and around the Forest (Table E-1). 

The communities identified in Table E-1 include incorporated places, as well as Census Designated Places 

(CDPs). CDPs are statistical areas delineated by the U.S. Census Bureau. CDPs typically represent areas 

with local population, but have no legal status. Estimated population totals by community ranged from less 

than 20 (Elfin Cove, Point Baker, and Kupreanof) to almost 32,000 (Juneau) in 2019. More than one-third 

(12) of the 32 Southeast communities identified in Table E-1 lost population between 2010 and 2019, with 

estimated decreases ranging from -1 percent (Coffman Cove) to -45 percent (Elfin Cove). Viewed in absolute 

terms, losses ranged from less than 10 residents (Elfin Cove, Hyder, Point Baker, and Coffman Cove) to 

more than 100 (Sitka, Craig, and Yakutat), reflecting the relative size of the affected communities. The 

regional population total fluctuated over this period, increasing from 71,664 in 2010 to a high of 74,518 in 

2014 and has since dropped five years in a row (Alaska DOL 2019a; see Key Issue 2 in this EIS, Figure 2-1).

Table E-1

Southeast Alaska Community Statistics

Community

Population

Median Household 

Income Percent 

Below 

Poverty 

Line in 

20182

Subsistence 

Use (Ibs per 

capita)4 20191

Percent 

Change 2010 

to 2019

Percent 

Native in 

20182 20182

Percent of 

State 

Median3

Angoon 404 -12 43 43,542 59 17.4 182

Coffman Cove 174 -1 5 56,250 76 0.0 276

Craig 1,074 -11 19 64,853 87 14.7 232

Edna Bay 47 12 0 na na 91.2 383

Elfin Cove 11 -45 33 na na na 263

Gustavus 537 21 8 80,000 108 1.7 241

Haines 1,784 4 11 75,833 102 4.0 137

Hollis 132 18 8 na na 7.9 169

Hoonah 782 3 54 63,750 86 11.1 343

Hydaburg 397 6 72 34,028 46 39.1 531

Hyder 78 -10 0 na na na 345

Juneau 31,986 2 11 88,213 119 7.9 na

Kake 570 2 72 54,625 73 9.4 179

Kasaan 85 73 31 45,000 61 14.7 452

Ketchikan 8,103 1 16 59,132 80 12.6 na

Klawock 761 1 42 54,821 74 19.5 350

Kupreanof 17 -37 0 na na na na

Metlakatla 1,359 -3 71 53,409 72 14.4 70

Naukati Bay 137 21 7 na na 25.0 242

Pelican 69 -22 44 70,500 95 8.6 355

Petersburg 2,963 1 7 69,514 94 8.1 161

Point Baker 12 -20 0 na na na 289

Port Alexander 57 10 0 69,375 93 9.3 312

Port Protection 29 -40 0 na na 73.7 451

Saxman 434 6 71 42,083 57 16.2 217

Sitka 8,532 -4 12 71,534 96 7.5 205

Skagway 1,045 14 4 71,500 96 5.6 48

Tenakee Springs 140 7 0 55,833 75 3.9 330

Thorne Bay 562 19 2 55,682 75 6.9 118

Whale Pass 57 84 0 41,154 55 na 247
Appendix E

Communities E-2 Final EIS

Table E-1 (continued)

Southeast Alaska Community Statistics

Community

Population

Median Household 

Income Percent 

Below 

Poverty 

Line in 

20182

Subsistence 

Use (Ibs per 

capita)4 20191

Percent 

Change 2010 

to 2019

Percent 

Native in 

20182 20182

Percent of 

State 

Median3

Wrangell 2,400 1 17 57,583 77 7.8 168

Yakutat 540 -18 28 65,833 89 6.9 386

na = not available

1 Population estimates are from the Alaska DOL (2019).

2 Estimates are annual totals developed as part of the 2014-2018 American Community Survey (ACS) 5-Year Estimates. Total 

population estimates developed as part of the ACS differ in some cases from those prepared by the Alaska DOL.

3 Median state income in Alaska was $74,346 in 2018 (U.S. Census Bureau 2019b). 

4 The year these data were collected varies by community, as follows:

1987: Elfin Cove, Gustavus, Hyder, Metlakatla, Pelican, Port Alexander, Skagway, and Tenakee Springs;

1996: Kake, Point Baker, Port Protection, and Sitka.

1997: Craig and Klawock.

1998: Coffman Cove, Edna Bay, Hollis, Kasaan, Naukati Bay, and Thorne Bay.

1999: Saxman

2000: Petersburg, Wrangell, and Yakutat.

2012: Angoon, Haines, Hoonah, Hydaburg, and Whale Pass.

Source: ADF&G 2018; Alaska DOL 2019a; U.S. Census Bureau 2019a, 2019b, 2019c

Alaska Natives made up an estimated 15 percent of the region’s population in 2019 (including Juneau 

and Ketchikan) and an estimated 21 percent for rural communities (excluding Juneau and Ketchikan). 

These rural communities include places that are predominately Native, such as Hydaburg, Kake, 

Saxman, and Metlakatla where Alaska Natives make up an estimated 72 percent (Hydaburg and Kake) 

and 71 percent (Saxman and Metlakatla) of the population; other communities that are predominately 

non-Native, like Edna Bay, Point Baker, and Whale Pass; and places with more mixed ethnicity where 

Alaska Natives range from about one-third to two-thirds of the population (Table E-1; see also Figure 

3.12-1 in the Subsistence section). 

U.S. Census estimates identified 12 communities in Southeast Alaska with 10 percent or more of their 

population below the poverty line in 2018. All but three of the communities identified in Table E-1 where data 

are available had estimated median household incomes below the state average in 2018. The three 

communities with estimated median household incomes above the state average were Juneau, Gustavus, and 

Haines. It should, however, be noted that using standard socioeconomic indicators to characterize communities 

in Southeast Alaska is challenging due to the small population sizes, alternative lifestyle choices and values, 

and the mixing of cash and subsistence economies. What may be perceived as a low-income community by 

standard economic metrics may more accurately be characterized as a community where residents practice 

subsistence activities, value a homestead culture, and earn seasonal or project-based income.

Wild foods account for a large share of the diet for residents of the studied communities, ranging from 48 

pounds per capita for Skagway in 1987 to over 500 pounds per capita for Hydaburg in 2012 (Table E-1). 

The average American diet includes about 225 pounds of meat, fish, and poultry on a per capita basis 

(Schroeder and Mazza 2005). In more than half of the identified communities, wild foods came close to, 

or exceeded, this national average (Table E-1). Although residents of subsistence communities purchase 

food, most could meet their entire protein need from wild sources. 

Marine resources, including fish, mammals, and plants, comprise the majority of subsistence harvests in 

all communities when measured by food weight. Marine resources account for more than half of total per 

capita harvest in all Southeast Alaska communities, ranging from 55 percent in Tenakee Springs to 88 

percent in Skagway (see Figure 3.12-2 in the Subsistence section of this EIS). As a result, management 

activities that restrict access for subsistence harvest of land mammals have had a relatively small effect 

on overall subsistence harvest by weight (Schroeder and Mazza 2005).

Employment and business license data are presented by Southeast Alaska community in Table E-2. These 

measures, as explained in the table footnotes, provide different perspectives on the presence of natural 

resource- and visitor-related business activities by communities. An estimated total of 29,500 residents were 

employed in Southeast Alaska communities in 2016, with 3 percent of total employed in the natural resources 

and mining industry and 10 percent employed in the leisure and hospitality industry (Table E-2). 
Appendix E

Final EIS E-3 Communities

Table E-2

Southeast Alaska Community Employment and Business License Data

Community

Total 

Employment 

(2016)1

Percent of Total Employed Total 

Number of 

Business 

Licenses 

(2018)2

Percent of Total Business Licenses

Natural 

Resources and 

Mining Industry 

(2016)2

Leisure and 

Hospitality 

Industry 

(2016)3

Forest Products 

Industry (2018)2,3

Visitor Industry 

(2018)2,4

Angoon 176 4% 10% 23 0% 52%

Coffman Cove 74 7% 0% 59 8% 17%

Craig 474 8% 6% 251 6% 17%

Edna Bay 12 25% 0% 17 18% 0%

Elfin Cove 13 0% 0% 0 0% 0%

Gustavus 180 2% 9% 134 3% 23%

Haines 720 4% 16% 465 3% 13%

Hollis 66 6% 6% 27 7% 22%

Hoonah 382 4% 28% 116 6% 18%

Hydaburg 125 1% 3% 19 5% 21%

Hyder 20 5% 10% 20 0% 25%

Juneau 15,431 3% 9% 3,824 0% 8%

Kake 211 4% 1% 16 0% 19%

Kasaan 102 3% 3% 11 0% 18%

Ketchikan 3,559 1% 13% 2,221 1% 10%

Klawock 396 8% 7% 118 7% 19%

Kupreanof na na na 3 0% 0%

Metlakatla 632 0% 1% 19 0% 0%

Naukati 41 5% 5% 30 13% 7%

Pelican 32 0% 3% 30 0% 23%

Petersburg 1,113 2% 8% 466 2% 9%

Point Baker 6 0% 0% 4 0% 0%

Port Alexander 24 0% 0% 17 6% 41%

Port Protection 16 0% 6% 3 33% 33%

Saxman 173 1% 17% 1 0% 100%

Sitka 3,642 1% 10% 1,332 0% 11%

Skagway 425 0% 17% 324 0% 22%

Tenakee Springs 42 2% 0% 24 17% 17%

Thorne Bay 187 6% 12% 98 14% 12%

Whale Pass 22 18% 9% 24 17% 29%

Wrangell 882 2% 7% 308 2% 11%

Yakutat 276 1% 13% 119 2% 35%

Total 29,500 3% 10% 10,133 2% 11%

na = not available

1 Employment data by community were compiled for 2016, the most recent year available, from Alaska Department of Labor and Workforce 

Development, Research and Analysis, Alaska Local and Regional Information (ALARI) data (Alaska DOL 2019b). These data are a 

combination of Census data and Alaska’s Permanent Fund Dividend information. Employment estimates are for the resident workforce only 

and do not include summer season transients.

2

The Natural Resources and Mining Industry includes two economic sectors: 1) Agriculture, Forestry, Fishing, and Hunting; and 2) Mining, 

Quarrying, and Oil and Gas Extraction (Alaska DOL 2019b). 3

The Leisure and Hospitality Industry includes the Arts, Entertainment, and Recreation; Accommodation and Food Services; Repair and 

Maintenance; and Personal and Laundry Services sectors, among others (Alaska DOL 2019b). 4 These counts and percentages are based on a point-in-time analysis of business license data from December 2018. Data were reviewed at 

the six-digit North American Industry Classification System (NAICS) code level based on the physical location of the business, rather than 

the mailing address (as identified in the Alaska DCCED database).

5 This assessment used the same definition of the Forest Products industry as a previous review conducted in 2012 (Alaska DCCED 2012). 

This definition identified 34 forestry-related business types (at the six-digit NAICS level) that make up the Forest Products industry, including 

timber harvesting, timber processing, direct and indirect forestry support, and manufacturing activities. Business licenses in 16 of these 34 

sectors were identified in Southeast Alaska communities.

6 Recreation and tourism-related employment is difficult to accurately quantify because visitors spend their money throughout the local 

economy. Recreation and tourism is not classified or measured as a standard industrial category. Components of travel and tourism 

activities are instead partially captured in other economic sectors, such as retail trade (e.g., grocery stores and gift shops), transportation, 

hotels and other lodging places, and amusement and recreation services. This assessment identified business licenses in 24 six-digit NAICS 

sectors that are primarily visitor-oriented, and did not include business licenses for gasoline stations, grocery stores, or food and drinking 

establishments, which may be partially supported by visitors.

Sources: Alaska DCCED 2018, Alaska DOL 2019b
Appendix E

Communities E-4 Final EIS

Shares of total employment in the natural resources and mining industry ranged from 0 (in seven 

communities) to 18 percent (Whale Pass) and 25 percent (Edna Bay). Natural resources and mining 

employment accounts for a relatively large share of employment in Whale Pass and Edna Bay, but due to 

the small size of the communities represents less than 5 jobs in each case. Viewed in terms of absolute 

employment, Juneau employed the largest number of workers in the natural resources and mining 

industry, with 463 workers. Craig and Klawock also had relatively large shares of employment in natural 

resources and mining, which accounted for 8 percent of total employment in each community. 

Employment in the leisure and hospitality industry by community ranged from 0 (in six communities) to 28 

percent (Hoonah). Six other communities also had more than 10 percent of total employment in the 

leisure and hospitality industry (Table E-2). Viewed in absolute terms, Juneau employed the largest 

number of workers in the leisure and hospitality industry, with almost 1,400 workers.

Review of the state business license database identified more than 10,000 business licenses in 

Southeast Alaska communities, with forest products businesses accounting for 2 percent and the visitor 

industry making up 11 percent of the total (Table E-2). Viewed at the community level, forest products 

businesses ranged from 0 to 33 percent of total business licenses. Visitor-related business licenses as a 

share of the total ranged from 0 to 100 percent. In both cases, the upper ranges reflect the small number 

of total licenses in the affected community (Table E-2).

In the event a subsistence harvest priority is needed for rural residents, the state or federal fish and 

wildlife management authorities would first limit commercial, sport, and non-local subsistence harvests to 

mitigate impacts to local subsistence harvests.

Individual Community Profiles

The following community profiles are presented alphabetically. Data cited in the profiles are from 

Table E-1 unless otherwise noted. 

Angoon (Aangóon)

Angoon is a Tlingit village and the only settlement on Admiralty Island located on the southwest coast of 

Kootznahoo Inlet. The population totaled 404 residents in 2019. Angoon is located 55 air miles southwest 

of Juneau and 41 air miles northeast of Sitka. Angoon residents practice a subsistence activities and 

participate in commercial fishing. The community is only accessible by floatplane or boat. Scheduled and 

charter floatplane services are available from the state-owned seaplane base on Kootznahoo Inlet. 

Angoon's facilities also include a deep draft dock, small boat harbor, and an Alaska Marine Highway 

System ferry terminal.

Coffman Cove (Shaan da)

Coffman Cove is located on the northeast coast of Prince of Wales Island. It was first settled as a logging 

camp during the 1950s and incorporated as a city government in 1989. Residents that remained after 

closure of the pulp mills have largely transitioned to livelihoods such as value-added niche forest 

products, tourism, and seafood products. Population has fluctuated over the past two decades; as of 

2019, the estimated population totaled 174 residents. Coffman Cove is accessible by floatplane, boat, 

and paved road from Hollis, where the ferry terminal is located. Nearby recreational opportunities 

including camping, hiking, biking, kayaking, and wildlife viewing attract visitors to the community. 

Craig

Craig is located on the west coast of Prince of Wales Island. Tlingit and Haida tribes historically used the 

area around Craig for its rich natural resources. Cold storage, fish processing, canneries, and a nearby 

sawmill have been mainstays of Craig’s local economy since the early 1900s. Craig includes a city 

government, federally-recognized tribe (Craig Tribal Association), and a village corporation established 

via the 1971 Alaska Native Claims Settlement Act (Shaan-Seet Incorporated). Craig’s estimated
Appendix E

Final EIS E-5 Communities

population was 1,074 in 2019. The community serves as the Prince of Wales Island regional hub for 

medical services, retail goods and services, arts and entertainment, educational opportunities, and 

gatherings for island residents. With the decline of the timber industry, Craig has worked to diversify its 

economy including adding marine infrastructure, encouraging independent tourism, and improving an 

industrial park. 

Edna Bay

Edna Bay is a small, remote community on Kosciusko Island, located off Prince of Wales Island’s 

northwest coast. It is one of Alaska’s newest city governments, incorporating in 2014. Edna Bay was 

originally established as a company logging camp for assembling ocean-going log rafts. Currently, Edna 

Bay is largely a community of commercial fishing families and includes both seasonal and year-round 

residents. Year-round residents are largely either retired or work in commercial fishing or forest products. 

Because of Edna Bay’s remote location, household livelihoods are supplemented with subsistence 

hunting, fishing, and gathering. Edna Bay’s population has declined by about half from 1990 to 2019, from 

86 to 47 residents. 

Elfin Cove

Elfin Cove, located on Chichagof Island at Cross Sound, is a fish-buying and supply center for the 

commercial fishing industry. The population is highly seasonal as residents participate in commercial 

fishing, sport fishing, and charter services. The estimated population in 2019 was 11 residents. There are 

several lodges located in Elfin Cove that operate on a seasonal basis. Additional retail businesses that 

serve visitors also provide employment opportunities. A state-owned seaplane base is available with air 

taxi service from Juneau. Skiffs provide local transportation.

Gustavus

Gustavus is the gateway community to Glacier Bay National Park and attracts a large quantity of 

seasonal residents and recreation enthusiasts. The estimated population was 537 in 2019. Glacier Bay 

National Park is the largest employer in the community followed by a variety of tourism establishments. 

Gustavus offers a state-owned airport with year-round daily air taxi service and jet service during the 

summer season. Floatplanes also land at nearby Bartlett Cove. Air traffic is relatively high during peak 

summer months, and several cruise ships include Glacier Bay in their itinerary, but do not visit the 

Gustavus community. There is a 10-mile paved road connecting the national park with the airport. 

Gustavus residents use portions of the project area for their recreation use and subsistence gathering. 

There are also outfitters and guides who use National Forest System lands who have businesses 

originating in Gustavus.

Haines

Haines is a northern terminus of the Alaska Marine Highway System, a cruise ship port of call, and hub 

for transportation to and from Southeast Alaska. The estimated population was 1,784 residents in 2019.

Many jobs are seasonal, with tourism businesses and access to the interior Alaska highway system 

becoming increasingly important. Haines is a major transshipment point because of its ice-free deepwater port and dock and year-round road access to Canada and interior Alaska. Air service is provided 

daily via the Haines airport and seaplane base.

Hollis

Hollis is situated on the east side of Prince of Wales Island on Twelvemile Arm. Hollis was originally a 

mining town in the early 1900s with nearby gold and silver deposits. During the 1950s, Hollis transitioned 

to a company logging camp and timber operations base for Ketchikan’s pulp mill. Today, Hollis is 

considered a community that provides timber and recreation industry support services, and contains a 

growing number of seasonal residences. Hollis also serves as the island’s transportation gateway; the 
Appendix E

Communities E-6 Final EIS

year-round, daily ferry service between Ketchikan and Hollis is a key mode of access to Prince of Wales 

Island. The estimated population was 132 residents in 2019.

Hoonah (Xunaa)

Hoonah is the largest Tlingit village in Alaska, with an estimated population of 782 residents as of 2019.

Many residents maintain a subsistence activities that includes hunting, fishing, and gathering edible 

plants and berries. The State of Alaska owns and operates the local airport and seaplane base. Air taxi 

services and the Alaska Marine Highway System provide regular access to Hoonah. Icy Strait Point, a 

restored cannery at Point Sophia owned by Huna Totem Corporation, opened as Southeast’s newest 

cruise industry port of call in 2004. The introduction of cruise industry to Hoonah’s local economy has 

yielded multiple economic benefits as new retail, leisure, and hospitality businesses have opened or 

increased operations to serve visitors. Hoonah is surrounded by an extensive road system on northwest 

Chichagof Island.

Hydaburg

Hydaburg is located on the southwest coast of Prince of Wales Island and is Alaska’s largest Haida 

village, dating from the early 1700s. Current-day Hydaburg was established in the early 1900s and was 

incorporated as a city government during the 1960s. Hydaburg includes a federally-recognized tribe 

(Hydaburg Cooperative Association) and a village corporation established via the 1971 Alaska Native 

Claims Settlement Act (Haida Corporation). As of 2019, the estimated population totaled 397 residents.

Fisheries are important to the community, both for subsistence and employment opportunities. Hydaburg 

is also home to world-renowned totem carvers, culture bearers, and other artisans practicing Haida art, 

culture, and tradition. 

Hyder

Hyder is a small community located at the head of Portland Canal, a 70-mile-long fjord that forms part of 

the United States/Canadian border. As of 2019, Hyder had an estimated population of 78 residents.

Historically, Nass River Tsimshians inhabited the area, which they called Skam-a-Kounst, “a safe place,” 

prior to the coming of white prospectors in the late 1890s. The first official exploration and building at the 

town site occurred in 1896 by the U.S. Army Corps of Engineers, with an initial economic base in mining. 

Hyder’s present-day economy is primarily based on tourism, mining, logging, fishing, and sport 

hunting/fishing, and, as such, is largely seasonal. Hyder is just 2 miles from Stewart, British Columbia, 

and the two towns share visitor services. Hyder is one of three Southeast Alaska communities connected 

by road to Canada and many tourists enter Hyder from Canada. 

Juneau (Dzántik’I Héeni)

Juneau, Alaska’s state capital, is the largest community in the analysis area with an estimated population 

of 31,986 in 2019. The community is a service and recreation center for residents and visitors alike. 

Tourism is a significant contributor to the local economy, especially during the summer months. The most 

popular local attractions include the Mendenhall Glacier, Mount Roberts Tram, Juneau Icefield, and Tracy 

Arm. Juneau is accessible by only air or water transportation. Scheduled commercial jet and air taxi 

service is available year-round at the Juneau International Airport. Marine facilities include multiple 

seaplane facilities, deep draft docks, small boat harbors, and a state ferry terminal. The Alaska Marine 

Highway System and commercial barge services provide year-round marine transportation access.

Kake (Kéex’)

Kake (Kéex’), a predominantly Tlingit village, is located alongside Kupreanof Island’s west side alongside 

Keku Strait and directly south of Admiralty Island. The estimated population totaled 570 residents in 2019.

Kake is 38 air miles northwest of Petersburg and 95 air miles southwest of Juneau. Kake’s economy is 

primarily based on government, education, tourism, and fishing employment. Subsistence activities and 
Appendix E

Final EIS E-7 Communities

resources are also an important component of Kake’s economy and community fabric. The Organized 

Village of Kake, a federally-recognized tribe, was established during 1947. A first-class city government, 

incorporated under the laws of the State of Alaska, was incorporated during 1952. Kake Tribal 

Corporation, an Alaska Native village corporation, was established pursuant to the Alaska Native Claims 

Settlement Act during 1971. Kake community members, the Kéex’ Kwaan people, uses Kuiu, Kupreanof, 

Admiralty, and Baranof Islands and mainland’s Hobart Bay for subsistence activities.

Kasaan

Kasaan is located on eastern Prince of Wales Island in Kasaan Bay. Haidas migrated north from the 

Queen Charlotte Islands in the early 1700s to the Island and established the village known as “Old 

Kasaan.” In 1898 the Copper Queen mine, camp, sawmill, post office, and store were built on Kasaan 

Bay, and the Haida people subsequently relocated to this new site in 1904. Kasaan was incorporated as 

a city government during the 1970s. It includes a federally-recognized tribe (Organized Village of 

Kasaan), and a village corporation established via the 1971 Alaska Native Claims Settlement Act (Kavilco 

Incorporated). In 2019, the estimated population totaled 85 residents. The majority of local residents are 

employed in the public sector. In recent years, Kasaan has also been encouraging tourism by marketing 

its Totems Historic District, newly-built Discovery Cabins, and reopening the Totem Trail Café.

Ketchikan (Kicháan)

Ketchikan is located on Revillagigedo Island near the southernmost boundary of Alaska, approximately 

235 miles south of Juneau. As of 2019, Ketchikan had an estimated population of 8,103 residents.

Historically, the Ketchikan area was a summer fishing camp for the Tlingit Alaska Natives. Its abundant 

fish and timber resources eventually attracted non-Natives, with the first cannery opening in Ketchikan in 

1886 and four more by 1912. Currently, Ketchikan is an industrial center and a major port of entry in 

Southeast Alaska (it is the first Alaska port-of-call for northbound ships). It has a diverse economy, 

supported by a large fishing fleet, fish processing facilities, timber and tourism. While the timber industry 

remains important to the economy and a home base for several timber companies, the Ketchikan Pulp 

Corporation’s pulp mill closed in 1997. Tourism and local retail are growing economic sectors, particularly 

related to cruise ship passengers.

Klawock (Lawáak)

Klawock is on the west coast of Prince of Wales Island, 7 miles from Craig, connected by paved road. 

Klawock had a total estimated population of 761 in 2019, and together, Klawock and Craig form the major 

population center of Prince of Wales Island. Originally, Klawock was used by the Tlingits as a summer 

fishing camp, later becoming a permanent village site. Currently, Klawock includes a federally-recognized 

tribe (Klawock Cooperative Association), and Alaska Native Claims Settlement Act (1971) village 

corporation (Klawock Heenya Corporation). Klawock’s economy includes commercial fishing, retail and 

other service professionals, and the timber industry; Viking Lumber is located between Klawock and 

Craig. At the same time, many residents continue to pursue a subsistence activities. Klawock airport has 

the only runway that can accommodate wheeled-aircraft on Prince of Wales Island. The community 

maintains a strong Tlingit cultural tradition with the Klawock Totem Park, which includes restored totem 

poles, a heritage center, and a traditional long house. 

Kupreanof

The City of Kupreanof is located across the Wrangell Narrows from Petersburg, on the northeast shore of 

Kupreanof Island. Incorporated as a city in 1975, the municipality has no full-time staff, few services, and 

no public utilities. Kupreanof is a small, non-Native community, with a total estimated population of 17 

residents in 2019. The community is built entirely on the waterfront; there are no roads. Residents use 

skiffs to travel to Petersburg for schooling, goods, and services. The majority of Kupreanof’s working 

residents are self-employed, although some commute by boat to jobs in Petersburg. Subsistence and 
Appendix E

Communities E-8 Final EIS

recreation uses of resources around Kupreanof supplement household incomes; deer, salmon, halibut, 

shrimp and crab are favorites. 

Metlakatla

Metlakatla is located on Annette Island, 15 miles south of Ketchikan, with an estimated population of 

1,359 in 2019. Believed to have been occupied at one time by Tlingit Indians, Metlakatla was settled in 

1887 by Church of England minister William Duncan and about 830 Tsimshian followers from northern 

British Columbia. In 1891, an Act of Congress declared Annette Island an Indian Reservation (the Annette 

Island Reserve), the only one in Alaska. Today, Metlakatla is a traditional Tsimshian community with a 

subsistence activities. The 86,000-acre Island reservation and surrounding 3,000 feet of coastal waters 

are not subject to state jurisdiction. The Metlakatla Indian Community regulates commercial fishing in 

these waters, and as the largest employer, operates a salmon hatchery on Tamgas Creek, the tribal 

court, and all local services and utilities.

Naukati Bay

Naukati Bay, commonly referred to as “Naukati”, is located on the northwest coast of Prince of Wales 

Island. The estimated population totaled 137 residents in 2019. Naukati was originally established as a 

logging camp to support Ketchikan’s pulp mill. The community remained after the pulp mill closed and, 

while unincorporated as a city, residents are represented by two non-profit associations (i.e., Naukati 

West and Naukati East) for addressing local issues and improving local infrastructure. Residents are 

primarily logging, small sawmill, and homesteading families, with growth in emerging tourism enterprises 

during the past decade. Many residents rely on subsistence activities to maintain cultural ties and support 

economic well-being. Naukati is also home to Shikat Bay Farm, an oyster nursery that raises oyster spat 

(seed) for oyster farmers across coastal Alaska. 

Pelican

Pelican is a fishing community with most residents participating in commercial, sport, and subsistence 

fishing activities. Located in Chichagof Island’s remote Lisianski Inlet, Pelican is dependent on boats, 

floatplanes, and the Alaska Marine Highway System for service. Daily scheduled air taxi service is 

available from Juneau and Sitka. Additional community facilities include a state-owned seaplane base, a

small boat harbor, dock, and state ferry terminal. As of 2019, the estimated population totaled 69

residents. 

Petersburg (Gánti Yaaks Séedi)

Petersburg is located on the northern tip of Mitkof Island, with an estimated population of 2,963 in 2019.

Petersburg’s economy is primarily based on the commercial fishing and timber industries. The city 

includes several fish processors operating cold storage, canneries, and custom packing services and the 

state-run Crystal Lake salmon hatchery. Petersburg also has two small active saw mills, and provides 

supplies and services for many of the area logging camps. Many residents also participate in subsistence 

gathering. While there is no deep-water dock suitable for large cruise ships, there are outfitters and 

guides who use National Forest System lands who have businesses originating in Petersburg.

Point Baker

Point Baker is on the northern tip of Prince of Wales Island and is only accessible via seaplane or boat, 

with an estimated population of 12 residents in 2019. Point Baker is considered a small fishing 

community, but neighboring lodges have been established providing sportfishing, wildlife viewing, and 

other outdoor experiences. The community’s proximity to Sumner Strait, an exceptional fishing site for all

five species of Pacific salmon and halibut, makes Point Baker a particularly appealing fishing destination. 

Point Baker remains an unincorporated community where residents practice a subsistence and 

homestead lifestyle without city government. 
Appendix E

Final EIS E-9 Communities

Port Alexander

Port Alexander is a small community located on the south end of Baranof Island, 65 air miles south of 

Sitka. The estimated population totaled 57 residents in 2019. Port Alexander has long provided safe 

harbor for commercial fishing boats during Chatham Strait gales and storms. Commercial fishing, 

subsistence activities, and tourism are important elements of the local economy. Access to Port 

Alexander is by floatplane or boat. The State of Alaska owns and maintains a seaplane base. Residents 

and visitors fly to Port Alexander via commercial or chartered floatplane service from Sitka, Petersburg, 

Wrangell, and Juneau. Other local facilities include a breakwater, dock, and small boat harbor. There are 

no roads in Port Alexander; skiffs provide local transportation.

Port Protection

Port Protection is on the northern tip of Prince of Wales Island, near Point Baker, and is only accessible 

via seaplane or boat. The estimated population totaled 29 residents in 2019. Port Protection was 

established as a fish buying center that provided safe harbor, fuel, and supplies for commercial fishing 

vessels. Port Protection has remained a small fishing community with no roads, where residents practice 

a rural and subsistence activities. All homes and other buildings are located along docks or upland 

boardwalks. 

Saxman

Saxman is located on west Revillagigedo Island on the Tongass Highway, about three miles south of 

Ketchikan. The estimated population totaled 434 residents in 2019. In 1894, Tlingits from the old Cape 

Fox and Tongass villages chose Saxman as the site for a new village and the location of a government 

school and a Presbyterian church, later incorporating as a municipality in 1929. In 1971 and 1973, 

respectively, Saxman was recognized and then certified as a Native village under the Alaska Native 

Claims Settlement Act. Most employment opportunities for Saxman residents are in the City of Ketchikan, 

though the City of Saxman, the Saxman Seaport, and the Cape Fox Corporation provide employment for 

some residents. The Saxman Totem Park, with a tribal house, a carving center, and a cultural hall for 

traditional Tlingit dance, has become an attraction for Ketchikan area visitors.

Sitka (Sheet’ká)

With an estimated population of 8,532 in 2019, Sitka is one of the larger communities in the analysis area 

and a popular visitor destination. Sitka is located on scenic Baranof Island and is a port of call for cruise 

ships throughout the summer season. Despite varied cruise ship visitation during the past decade, the 

leisure and hospitality industry remains an important part of Sitka’s economy. Other economic sectors 

include fishing, fish processing, government, health care services, transportation, and retail. The local 

government operates five small boat harbors, a seaplane base, and an airport. The community is served 

by the Alaska Marine Highway System and goods are transported to the community via regular 

commercial barge service.

Skagway

Skagway, with a population of 1,045 in 2019, is an important port of call for cruise ships and a transfer 

site for interior bus tours, such as to the Klondike Gold Rush National Historic Park. More than 600,000 

cruise ship passengers and numerous state ferry travelers visit Skagway each year. Skagway is also the 

site of trans-shipment of lead/zinc ore, fuel, and freight via the Port and Klondike Highway to and from 

Canada. The Klondike Highway and Alaska Highway provide road connections to British Columbia, the 

Yukon Territory, interior Alaska, and the Lower 48 states. Skagway is primarily accessed by air, road, and 

marine services. The State of Alaska owns the airport and seaplane base at the boat harbor with 

scheduled air service from Juneau. 
Appendix E

Communities E-10 Final EIS

Tenakee Springs

Tenakee Springs, located on Chichagof Island, has long been considered a retirement community and 

summer retreat for Juneau and Sitka residents, with limited opportunities for local employment. The 

estimated population totaled 140 residents in 2019. While fish processing has been a mainstay of its 

economy, tourism is growing in importance. Tenakee Springs is dependent on seaplanes and the Alaska 

Marine Highway Service for access. The City of Tenakee Springs operates a seaplane base and heliport 

with scheduled or chartered service from Juneau. The Alaska Marine Highway System provides access 

on a limited basis. Additional marine facilities include a small boat harbor and ferry terminal. Local 

transportation is primarily by bicycle or off-highway vehicle along a 3-mile local path.

Thorne Bay

Thorne Bay is on the east coast of Prince of Wales Island, with an estimated population of 562 residents 

in 2019. Originally established as a floating logging camp for the Ketchikan pulp mill in 1960, it grew 

substantially in 1962 when the Hollis logging camp was relocated there. A shop, log sort yard, and camp 

were built and soon thereafter, roads were constructed connecting Thorne Bay to Hollis, Craig, and 

Klawock. During the peak of island timber activities, Thorne Bay was considered the largest logging camp 

in North America. Today, Thorne Bay contains one of the log transfer sites on the island. Employment is 

primarily in barge and freight services, small sawmills, government, commercial fishing, and tourism as 

guided sport fishing charter opportunities increasingly attract visitors. To supplement incomes, residents 

engage in subsistence activities, fish, and trap. 

Whale Pass

Whale Pass is a small community located on northern Prince of Wales Island, with an estimated 

population of 57 residents in 2019. It was originally established as a logging camp during the early 1960s 

and the camps remained through the early 1980s. Whale Pass is situated at a remote area of the island, 

but is connected to other island communities via a gravel road. State government land disposal sales 

facilitated the transition from company-owned logging camp to a year-round community that incorporated 

in 2016. The economy is dependent on natural resources and tourism, with high levels of employment in

both the natural resources and mining and leisure and hospitality sectors. Residents also engage in 

subsistence activities. 

Wrangell (Kaachxana.áak’w)

Wrangell is located on the north end of Wrangell Island, near the mouth of the Stikine River, an historic 

trade route to the Canadian interior. Wrangel had a total estimated population of 2,400 residents as of 

2019. Wrangell began as an important Tlingit site primarily because of its proximity to the Stikine River. In 

1867, a military post named Fort Wrangell was established as part of the Alaska Territory. The community 

continued to grow as a fur trading center, and as an outfitter for gold prospectors between 1861 and the 

1930s. In 2008, residents decided by local election that the City of Wrangell should dissolve and 

incorporate as the City and Borough of Wrangell. This added the communities of Meyers Chuck, Union 

Bay, Thoms Place, Olive Cove, and Farm Island to the new unified city and borough. The Wrangell 

economy is primarily based on commercial fishing, fish processing, and tourism. While timber used to be 

part of the economy, by 2012 no timber-related employment was identified in Wrangell. 

Yakutat (Yaakwdáat)

Yakutat is located along the northern Gulf of Alaska at the mouth of Yakutat Bay. The estimated 

population totaled 540 residents in 2019. The original settlers, believed to have been Eyak people from 

the Copper River area, were later conquered by the Tlingits. By the mid-1800s, foreign traders were well 

established along the coast. The contemporary town grew up around “the old village,” which was 

established in 1889 by missionaries. Incorporated as a first-class city in 1948, Yakutat is governed by a 

mayor and a city council. Yakutat Borough, incorporated in 1992, expanded the original city boundaries to 
Appendix E

Final EIS E-11 Communities

include a large section of the Gulf Coast north of Cape Fairweather. Yakutat is accessible by jet service 

from Juneau and Anchorage. The economy is primarily dependent on fishing, fish processing, 

government, and tourism. Wrangell-Saint Elias National Park, Russell Fiords Wilderness, and Glacier Bay 

National Park are located northwest, northeast, and southeast of Yakutat, respectively.

Environmental Consequences

Analyzing Impacts to Communities

This EIS provides an assessment of the potential impacts that may result from the alternatives considered 

for a proposed Alaska Roadless Rule. This assessment and the proposed alternatives are programmatic, 

meaning that they establish direction and allowable activities for broad land areas, rather than schedule 

specific activities in specific locations. This makes it difficult to predict effects on individual communities. This 

is a common source of frustration to local residents, who want to know exactly how they and the places they 

care about could be affected. While many potentially affected outputs of forest management, such as 

scheduled timber harvest, generally translate into social and economic activity, such as employment in the 

timber industry, it is difficult to predict which communities would benefit the most from that activity. Forest 

Service activities provide economic opportunities to the private sector. How that sector and the various 

industries that comprise it respond depends on many variables in addition to Forest Service management. 

Communities that rely on a given resource-related industry would, however, be expected to be the first to 

benefit or lose from significant changes in planned output levels affecting that industry.

The 2016 Forest Plan Amendment EIS provides detailed assessments for the 32 communities addressed 

in the preceding section. In addition to providing detailed overviews of existing conditions, the 2016 EIS 

profiles evaluated potential effects to each community’s use area. Originally identified as part of the 1997 

Forest Plan Revision (USDA Forest Service 1997a), community use areas (CUA) represent the general 

area commonly used or related to by many of the community’s residents in their local day-to-day work, 

recreational, and subsistence activities. These areas do not necessarily define the limits of a community’s 

use or represent traditional use areas or territories. Community residents may work or pursue recreation or 

subsistence activities elsewhere on the Forest. Traditional territories are shown in Appendix F, which 

presents maps from Goldschmidt and Haas’ landmark ethnographic study of Alaska Native land use, 

occupancy, and possession in Southeast Alaska.

The analysis presented here draws upon these information sources to assess the effects of the six 

alternatives under consideration by community. Each community discussion includes a map of that 

community’s use area. These maps are accompanied by tables that summarize the Alaska Roadless 

Area (ARA) management designations and change in roadless area acres that would occur in the 

community’s use area by alternative. The summary tables also identify changes in acres in development 

Land Use Designations (LUD), changes in suitable acres available for harvest, and changes in acres of 

estimated harvest over 100 years by alternative for each CUA. These CUA maps and tables are intended 

to help community residents (and other readers) gain a better understanding of what management 

direction is proposed for their immediate surroundings under each alternative. As noted above, these 

CUAs do not necessarily define the limits of a community’s use or represent traditional use areas or 

territories.

The following assessment considers potential impacts to 32 Southeast Alaska CUAs using four primary 

measures by alternative: 1) acres by ARA management category and change in acres managed as 

roadless; 2) change in acres in development LUDs; 3) change in suitable old-growth acres available for 

harvest, and 4) changes in estimated harvest over 100 years. 

Average annual deer harvest for 2004 to 2013 is presented by Wildlife Analysis Area (WAA) for each 

community where these data are available and provides another indication of areas used by different 

communities. WAAs are a division of land used by the Alaska Department of Fish & Game (ADF&G) for 
Appendix E

Communities E-12 Final EIS

wildlife analysis.2 As part of the community assessments in the 2016 Forest Plan Amendment EIS (USDA 

Forest Service 2016), the Sitka black-tailed deer habitat capability model output was analyzed for the 

WAAs where each community obtained approximately 75 percent of their average annual deer harvest. 

This analysis originally prepared for the 1997 Forest Plan Revision FEIS (USDA Forest Service 1997b) 

was updated for the 2016 Forest Plan Amendment EIS. The results of the 2016 analysis for the current 

Forest Plan are used as part of the subsistence assessment presented below for each community. This 

assessment is discussed further below in the Potential Impacts by Resource Area section. 

ARA Management Categories and Changes in Roadless Area Acres

Alternatives 2, 3, 4, and 5 propose to correct and modify inventoried roadless area (IRA) boundaries 

based on ownership changes and updated mapping. Updated roadless areas would be known as Alaska 

Roadless Areas (or ARAs) and the Alaska Roadless Rule would apply to those identified lands. ARAs 

would be assigned to one of five designations of Alaska roadless areas: LUD II Priority, Watershed 

Priority, Community Priority, Roadless Priority, and Timber Priority. These designations are described in 

Chapter 2 of this EIS and briefly summarized below:

 The LUD II Priority management category provides for lands to be managed in a roadless state to 

retain their wildland character in accordance with applicable LUD II requirements.

 The Watershed Priority management category is more protective than the 2001 Roadless Rule and 

provides for activities specific to aquatic habitat improvement and protection. Alternatives 2 and 3 are

the only alternatives with lands that would be managed under this category.

 The Community Priority management category allows for small-scale timber harvest and associated 

road construction and reconstruction. In addition, it allows for infrastructure development to connect 

and support local communities and traditional Alaska Native cultural uses. This management 

category is only proposed under Alternative 3, and only lands adjacent to seven communities – Sitka, 

Wrangell, Juneau, Ketchikan, Kake, Hydaburg, and Yakutat – would be managed under this category.

 The Roadless Priority management category is similar to the 2001 Roadless Rule but is less 

restrictive and provides for Alaska specific concerns, specifically for infrastructure development to 

connect and support local communities, and road construction for leasable minerals.

 The Timber Priority management category exempts timber harvest and road 

construction/reconstruction within ARAs to facilitate timber management. This management category 

is only proposed for Alternative 4.

As described in Chapter 2, additional regulatory protection would also be applied to Tongass 77 (T77)

and The Nature Conservancy (TNC)/Audubon Conservation Priority Areas (high-priority watershed areas)

outside of the designated roadless area boundaries under Alternative 3. Old-growth harvest is currently 

prohibited in these areas under the existing 2016 Forest Plan. The additional protection would provide 

regulatory continuity for the T77 and TNC/Audubon Conservation Priority Areas in their entirety.

Management activities have the potential to have detrimental effects to roadless area characteristics. This 

is especially the case with timber harvest and associated road building. Additional timber harvest 

opportunities would primarily be provided by removing roadless protections for areas that are currently 

protected under the 2001 Roadless Rule (i.e., areas that are presently within IRAs). Timber harvest would 

also be allowed in ARAs assigned to the Timber Priority management category. 

Under Alternative 3, roadless protection would be removed from the 826,000 LUD II acres that are 

currently within an IRA. LUD II acres removed from roadless designation would still retain their 

Congressionally-designated protections, which require that these areas be managed in a roadless state 

to retain their wildland character. Therefore, decreases shown for Alternative 3 tend to overstate the 

number of acres that would no longer be protected.

2 ADF&G no longer compiles this data by WAA and, therefore, the summaries of harvest by WAA presented below 

use the data compiled for 2004 to 2013.
Appendix E

Final EIS E-13 Communities

Changes in Development LUDs

Not all acres removed from roadless management would be available for development. LUD II acres 

removed from roadless designation under Alternative 3, for example, would, as noted above, still retain 

their Congressionally-designated protections, which require that these areas be managed in a roadless 

state to retain their wildland character. Other areas removed from roadless protection occur in nondevelopment LUDs, such as Old-Growth Habitat and Remote and Semi-remote Recreation, which do not 

allow old-growth timber harvest. The change in acres in development LUDs (Timber Production, Modified 

Landscape, and Scenic Viewshed) managed as roadless serves as a measure of development potential. 

Approximately 7 percent (1,151,700 acres) of the Forest is presently managed in development LUDs. 

This total would increase under all action alternatives, with net gains ranging from about 53,300 acres 

(Alternative 2) to more than 2.1 million acres (Alternatives 5 and 6).

Changes in Suitable Timber

Not all lands allocated to development LUDs are available for timber management. As described in 

Appendix A to the 2016 Forest Plan, old-growth forest located within Phases 2 and 3 of the Tongass 

Timber Sale Program Adaptive Management Strategy or within the T77 Watersheds and The Nature 

Conservancy/Audubon Conservation Priority Areas is identified as not suitable for timber production. As a 

result, not all increases in development LUD acres would provide additional opportunities for timber 

harvest. Changes in suitable old-growth and young-growth acres available for harvest are, therefore, 

used as a relative measure of timber opportunity to differentiate between alternatives. These estimated 

changes do not represent estimates of how much harvest would occur under each alternative. Actual harvest 

locations would depend on the timber sales that are carried out during plan implementation. 

Forest-wide, approximately 227,000 acres are presently considered suitable old-growth available for 

harvest. This total would increase under all the action alternatives, with gains ranging from about 20,000 

acres (Alternative 2) to 168,000 acres (Alternatives 5 and 6). Approximately 334,000 acres are 

considered suitable for young-growth harvest, with estimated increases ranging from 3 to 6 percent of the 

existing total, about 11,000 acres (Alternative 2) to 20,000 acres (Alternative 6).

Appendix D presents suitable old-growth and young-growth timber maps by for each CUA by alternative. 

These maps are available electronically only. They are included on the electronic storage device 

accompanying this document and are also available online at: 

https://www.fs.usda.gov/project/?project=54511.

Estimated Timber Harvest over 100 Years

Total acres harvested are assumed to remain constant across all alternatives. After 25 years of Forest Plan 

implementation, an estimated 24,000 old-growth acres would be harvested. Old growth would continue to 

be harvested over time, but at a much reduced rate, with an estimated total of 42,500 old-growth acres 

expected to be harvested after 100 years. The corresponding totals for young-growth are 43,300 acres 

after 25 years and 284,100 acres after 100 years. Estimated harvest totals over 100 years show the amount 

of harvest likely to occur by alternative and CUA. Estimated harvest acres were distributed over the suitable 

old-growth base using the following assumptions: 1) all harvest acres were assigned to medium and high 

volume old-growth only; 2) based on historic harvest distributions, 95 percent of old-growth harvest was 

assumed to occur on the five south ranger districts (Craig, Ketchikan-Misty Fjords, Petersburg, Thorne 

Bay, and Wrangell); and 3) harvest was assumed to occur in Value Comparison Units with higher 

stumpage values as estimated for the 2008 Forest Plan using the Spectrum model. The resulting 

distributions represent best estimates based on the available information and the above assumptions.

Viewed by CUA, this measure is sensitive to the relative distribution of Forest-wide suitable acres. Decreases 

in the share of total Forest-wide suitable acres (as adjusted based on the above assumptions) relative to 

Alternative 1, for example, result in corresponding decreases in estimated harvest over 100 years, despite an

increase in suitable acres available for harvest. Actual harvest locations will depend on the timber sales that 

are carried out during plan implementation.
Appendix E

Communities E-14 Final EIS

Potential Impacts by Resource Area

The alternatives have implications for specific places on the Forest and particular parts of the CUAs of 

various communities. They also have potential implications for resource dependent industries, infrastructure 

development, Alaska Native customary and traditional uses, and the availability of subsistence resources. 

The following paragraphs discuss these potential implications in general terms to provide some background 

for the following community assessments.

Forest Products

The action alternatives would all increase the suitable acres available for harvest, with the potential to provide 

additional opportunities for the Forest Service to develop economic timber sale offerings. Suitable acres 

would be added in three broad categories or areas: areas that have been substantially altered as 

identified by known prior road construction or timber harvest3 (Alternatives 2 to 6); logical extension areas 

(Alternatives 3 to 6); and areas more distant from roads (Alternatives 4 to 6) (as discussed in Chapter 2 

and the Key Issue 2 section of this EIS). In addition, suitable old-growth acres would be added in 

Community Priority ARAs (Alternative 3). The added suitable acres in areas where roads already exist

(roaded roadless) or could be logically extended (logical extensions) are generally considered relatively 

economic to harvest. Acres identified as more distant from roads are likely to be more expensive to 

harvest and less likely to be accessed for timber production under the current 2016 Forest Plan.

Estimated direct forest products employment in the first decade of implementation would be very similar 

under all six alternatives as discussed in the Key Issue 2. Estimated employment is presented as a range 

from a maximum allowable export of timber scenario based on the existing Region 10 limited export policy to 

a maximum domestic processing scenario that assumes only Alaska yellow-cedar would be exported 

unprocessed.

Recreation and Tourism

Changes in land management have the potential to affect recreation opportunities on the Forest. Impacts 

could occur where timber management and development activities conflict with recreation opportunities 

for community residents and/or commercial recreation operators and their clients. Changes in suitable 

old-growth and young-growth acres for harvest provide an indicator of potential timber opportunity for 

each CUA by alternative. For some recreation uses, additional development for timber harvest and other 

infrastructure could provide increased access to the Forest and more opportunities. Impacts to ROS 

settings and recreation places are assessed in the Recreation section of this EIS. 

The Recreation section also assesses potential impacts to commercial outfitter/guide businesses. This 

assessment used changes in suitable old-growth acres in conjunction with information on existing 

outfitter/guide use to help focus on potentially affected areas. A screening review based on these factors 

identified 15 outfitter/guide use areas where potential conflicts between existing outfitter/guide use and 

future management could occur based on recent patterns of existing use. These are outfitter/guide use 

areas with recent outfitter/guide use where there would be increases in suitable old-growth acres under 

one or more of the action alternatives. These potential impacts are discussed in more detail in the 

Recreation section. 

Infrastructure Development

With some exceptions, federal and state road development is presently limited in IRAs. Exceptions 

include roads with reserved or outstanding rights, roads provided for by statute or treaty, or road 

development related to a Federal Aid Highway. Roadless protection would be removed to various 

degrees under the action alternatives with corresponding implications for regional highway development. 

In most cases, changes in roadless management, as well as changes in the number of acres managed as 

3 Removed areas include both development and non-development LUDs. These areas are generally known as 

“roaded roadless” areas but also include additional areas considered to be substantially altered.
Appendix E

Final EIS E-15 Communities

roadless, would be more permissive with respect to regional road systems. In addition to those roads 

presently excepted, Roadless Priority ARAs would also allow roads needed for the connection of 

communities and development of the regional transportation system as identified in the State of Alaska’s 

SATP. Timber Priority ARAs and areas removed from roadless protection would remove all roadless rulerelated restrictions on road building. As a result, more areas would be available for additional types of 

regional road development under Alternatives 4 to 6. Future road projects would be subject to funding 

constraints and evaluated in detail on a project-by-project basis. Potential transportation effects are 

discussed in more detail in the Transportation, Energy, Communications, and Infrastructure section of this 

EIS.

None of the alternatives are expected to substantially affect the development of energy projects or related 

infrastructure. Removing roadless designations in areas under Alternatives 2 through 6 would simplify the 

process for projects but would not necessarily result in an increase in the number of projects developed. 

In areas where new roadless areas are added or expanded, the permitting process could be more 

complicated, but projects would not be prohibited. An exemption for utility systems in Roadless Priority 

ARAs under Alternatives 2, 3, 4, and 5 and Community Priority ARAs (Alternative 3), would allow for tree 

cutting and road construction. Under Alternative 4, Timber Priority ARAs would not prohibit tree cutting or 

road construction at all. Where restrictions are removed, or exemptions added, the greatest effect may be 

in making the permitting process for developers less burdensome, resulting in more a rapid permitting 

process rather than an increase in the number of sites developed.

Alaska Native Customary and Traditional Uses

Areas allocated to Roadless Priority and Community Priority ARAs would explicitly allow the cutting, 

utilization, customary trade, and removal of trees for the purposes of Alaska Native customary and 

traditional uses, as well as road construction deemed necessary by a federally recognized Tribe for 

access to Alaska Native cultural sites. This type of use would also be allowed in Timber Priority ARAs, 

which allow all timber harvest and road construction. These types of uses would also be allowed in areas 

removed from roadless protection, subject to applicable Forest Plan standards and guidelines.

Management under the Roadless Priority and Community Priority ARAs is generally assumed to be more 

beneficial in this context than management under the Timber Priority ARA or full exemption because it 

potentially allows access for Alaska Native cultural purposes without also allowing access for commercial 

timber harvest and other competing uses.

Subsistence

Marine resources, including fish, mammals, and plants, account for more than half of total per capita 

harvest in all Southeast Alaska communities, ranging from 55 percent in Tenakee Springs to 88 percent 

in Skagway (see Figure 3.12-2 in the Subsistence section of this EIS). These resources are not expected 

to be affected by any of the alternatives. Among the subsistence resources of greatest importance (salmon, 

other finfish, marine invertebrates, and deer), deer is the only one that could be potentially significantly 

affected by the alternatives evaluated in the 2016 Forest Plan Amendment EIS (USDA Forest Service 2016). 

Therefore, the subsistence analyses prepared for each community for that EIS used deer as a key indicator 

for potential impacts to subsistence resources. Effects to subsistence resources have the potential to affect 

subsistence users.

Extensive analysis on deer was done for the 1997 Forest Plan and subsequent 2008 and 2016 Forest 

Plan Amendments. Analyses conducted during the 2016 Forest Plan Amendment EIS also included 

information on summer and winter forage and effects of roadbuilding, noting that the expected ecological 

responses of deer to old-growth and mature young-growth timber harvest, road building, and vegetation 

succession will be similar to those predicted previously, but the extent of future impacts would be 

expected to be reduced from earlier analyses because lower levels of old-growth harvest are proposed in 

all action alternatives. 

As part of the 2016 Forest Plan Amendment EIS, the interagency deer habitat capability model was used 

to assess existing habitat capability within the planning area. This analysis found that Forest-wide, 
Appendix E

Communities E-16 Final EIS

approximately 89 percent of the original (1954) habitat capability remains, ranging from 72 to 100 percent 

depending on the biogeographic province. The greatest reductions in deer habitat capability have 

occurred, and will continue to occur, in provinces where timber harvest has been concentrated (the North 

Central Prince of Wales, East Baranof, and Etolin Island biogeographic provinces). As noted above, the

model output was also analyzed for the WAAs where each community obtained approximately 75 percent 

of their average annual deer harvest. This analysis originally prepared for the 1997 Forest Plan Revision 

FEIS was updated for the 2016 Forest Plan Amendment EIS (USDA Forest Service 2016). The results of 

the 2016 analysis for the current Forest Plan are used as part of the subsistence assessment presented 

below for each community.

In addition to evaluating projected changes in deer habitat capability by WAA, the 2016 analysis also 

drew upon the Deer Availability and Anticipated Demand analysis completed for the 1997 Forest Plan 

Revision FEIS which assessed the ability of the 1997 alternatives to provide sufficient habitat capability 

over the long term for deer hunted by local residents, all rural hunters, and all hunters for each 

community. All of the 1997 alternatives included substantially higher levels of timber harvest than the 

alternatives evaluated in the 2016 Forest Plan Amendment EIS and, therefore, potential impacts were 

expected to be lower under all of the 2016 alternatives, including the current Forest Plan. However, the 

2016 Forest Plan Amendment EIS acknowledged that some impacts could still occur, with the 

subsistence use of deer potentially affected to the point in some areas that some restriction on hunting 

might be necessary over the long term, especially for non-rural hunters. The 2016 analysis identified this 

possibility for 19 of the 34 communities evaluated for all five alternatives analyzed in that EIS, with 

anticipated impacts largely due to past harvest in the affected areas. These communities were Coffman 

Cove, Craig, Haines, Hollis, Hoonah, Kake, Kasaan, Klawock, Naukati Bay, Petersburg/Kupreanof, Point 

Baker, Port Protection, Saxman, Sitka, Tenakee Springs, Thorne Bay, Whale Pass, Wrangell, and 

Yakutat. Impacts and possible restrictions were also identified for the non-rural communities of Juneau 

and Ketchikan.

The following assessment considers potential impacts to subsistence for 32 Southeast Alaska 

communities using the results of the 2016 Forest Plan Amendment EIS analysis and two primary 

measures by alternative: 1) change in suitable old-growth acres available for harvest, and 2) changes in 

projected old-growth harvest over 100 years. 

All six alternatives evaluated in this EIS, including No Action, would result in a reduction in deer habitat 

capability from existing conditions due to the harvest of mature young-growth and productive old-growth 

(POG) forest. Over the long term, reductions in habitat capability would reduce carrying capacity, or the 

numbers of deer an area is capable of supporting given the available resources. This could lead to a 

decline in the deer population, particularly following severe winters, if the demand for resources (e.g., 

food or habitat) exceeds the amount available. 

Timber harvest tends to affect deer-related subsistence activities in two ways. In the short run, approximately 

20 to 30 years following harvest, deer populations tend to increase in harvested areas. In the long run, 

populations tend to decline as the canopy in even-aged forest stands closes, resulting in lower habitat quality. 

Reductions in habitat quality can be reduced through management (e.g., thinning) of young-growth stands. 

Deer populations in unharvested areas are likely to remain at fairly constant levels that are typically lower 

than a comparable harvested area in the short run, but higher in the long run. Road construction also affects 

subsistence by providing subsistence hunters with ready access to areas that may have been previously 

inaccessible. This effect may be perceived as either positive or negative depending on the parties involved, 

as increased access may lead to increased competition for resources. Potential effects are likely to vary by 

community and may be perceived differently by members of the same or neighboring communities. 

While there would be some new road access under all alternatives in the long run, nearly all new roads 

constructed under the alternatives would be closed following harvest. These roads would, therefore, not 

be available for use by highway vehicles or high-clearance vehicles. They would, however, be available 

for access by other methods and would, as a result, have the potential to affect existing subsistence 

patterns.
Appendix E

Final EIS E-17 Communities

In the event a subsistence harvest priority is needed for rural residents, the state or federal fish and 

wildlife management authorities would first limit commercial, sport, and non-local subsistence harvests to 

mitigate impacts to local subsistence harvests.

Individual Community Assessments

The following community assessments are presented in alphabetical order. 

Angoon (Aangóon)

Community Use Area

Angoon’s CUA encompasses a total of 1,092,036 acres (Figure E-1). Almost half of this area (43 percent) 

is presently managed as roadless (Table E-3). This share would drop to 36 percent under Alternative 3 

and 26 percent under Alternative 5, with no acres managed as roadless under Alternative 6. The removal 

of LUD II acres under Alternative 3 accounts for the entire decrease in roadless acres under this 

alternative. These areas would retain their congressional protections and continue to be managed in a 

roadless state. Alternative 4 includes ARA acres that would be managed as Timber Priority and allow 

timber harvest and road building. Timber Priority acres account for 14 percent of the ARA in the Angoon

CUA under Alternative 4. Areas allocated to Roadless Priority and Community Priority ARAs would 

explicitly allow the cutting, utilization, customary trade, and removal of trees for the purposes of Alaska 

Native customary and traditional uses, as well as road construction deemed necessary by a federally 

recognized Tribe for access to Alaska Native cultural sites. This type of use would also be allowed in 

Timber Priority areas, which allow all timber harvest and road construction.
Appendix E

Communities E-18 Final EIS

Figure E-1

Angoon’s Community Use Area

Table E-3

Roadless Areas, ARA Management Categories, and Development Opportunity in 

Angoon’s Community Use Area

Roadless Category (acres)

Alternative

1 2 3 4 5 6

Total Community Use Area 1,092,036 1,092,036 1,092,036 1,092,036 1,092,036 1,092,036

Total Roadless Area 468,606 490,275 396,635 445,567 282,843 0

Roadless Share 43% 45% 36% 41% 26% 0%

ARA Management Categories (acres)

LUD II Priority na 73,141 0 73,141 73,062 0

Watershed Priority na 218,369 297 0 0 0

Roadless Priority na 198,765 177,968 311,309 209,781 0

Community Priority na 0 297 0 0 0

Timber Priority na 0 0 61,117 0 0

Development Opportunity

Development LUDs (acres) 137,603 118,644 134,479 155,409 322,599 322,608
Appendix E

Final EIS E-19 Communities

Table E-3 (continued)

Roadless Areas, ARA Management Categories, and Development Opportunity in 

Angoon’s Community Use Area

Roadless Category (acres)

Alternative

1 2 3 4 5 6

Timber Opportunity (Acres Suitable for Harvest)

Old-Growth 26,404 24,761 29,389 49,497 50,571 50,571

Young-Growth 34,326 34,378 34,378 34,460 34,475 34,816

Estimated Harvest over 100 Years (acres)

Old-Growth 1,235 1,235 1,254 1,170 1,181 1,181

Young-Growth 29,226 28,313 28,011 28,067 27,935 27,955

na = not applicable

Not all acres removed from roadless management would be available for development. The change in 

acres in development LUDs serves as a measure of development potential as it presently exists by 

alternative. Approximately 13 percent (137,600 acres) of the Angoon CUA is presently managed in 

development LUDs (Table E-3). This total would increase under Alternatives 4, 5, and 6, with net gains 

ranging from about 17,800 acres (Alternative 4) to approximately 185,000 acres (Alternatives 5 and 6). 

Under Alternatives 2 and 3, the total area of the Angoon CUA managed in development LUDs would 

decrease by approximately 19,000 and 3,100 acres, respectively.

Suitable old-growth and young-growth acres available for harvest would increase under Alternatives 3 

through 6, as well as for young-growth under Alternative 2. Estimated net gains in suitable old-growth 

range from about 3,000 acres (Alternative 3) to 24,200 acres (Alternatives 5 and 6). Under Alternative 2, 

suitable old-growth acres available for harvest would decrease by about 1,650 acres. Increases in 

suitable young-growth acres would be 1 percent or less under all action alternatives. 

Total acres harvested are assumed to remain constant across all alternatives. Estimated old-growth 

harvest over 100 years ranges from about 1,200 acres (Alternatives 5 and 6) to 1,250 acres (Alternatives 

1 to 3) in the Angoon CUA. This represents a small decrease relative to Alternative 1 for Alternatives 4 to 

6, and very little change for Alternatives 2 and 3. Estimated young-growth harvest ranges from about 

28,000 acres (Alternatives 3 to 6) to 29,200 acres (Alternative 1), with a decrease in potential younggrowth harvest relative to Alternative 1 in all cases, with slightly larger decreases under Alternatives 5 and 

6 (Table E-3).

Subsistence

No significant effect on salmon, other finfish, or invertebrate habitat capability is expected from 

implementation of any alternative. These resources account for 52 percent of the total edible pounds of 

subsistence resources harvested by Angoon households (Kruse and Frazier 1988). Marine resources 

(fish and marine invertebrates), primarily salmon, accounted for the majority (62 percent) of per capita 

subsistence harvest in Angoon in 2012 (ADF&G 2018).

The 1988 Tongass Resource Use Cooperative Survey (TRUCS) study found that deer accounted for 30 

percent of the total edible pounds of subsistence resources harvested by Angoon households (Kruse and 

Frazier 1988). Deer accounted for 28 percent of per capita subsistence harvest by Angoon residents in 

2012 (ADF&G 2018). 

From 2004 to 2013, Angoon residents took approximately 75 percent of their deer from six WAAs, with 

the majority (59 percent) obtained from three WAAs on Admiralty Island (4042, 4054, and 4055) (Table 

E-4). The 2016 Forest Plan Amendment EIS found that none of the three most important WAAs would be 

affected by the current Forest Plan. The next two WAAs in importance contribute 12 percent of Angoon’s 

deer harvest and would also not be affected by the current Forest Plan. The sixth WAA in importance, 

WAA 3308, with an annual average harvest of 4 deer, was found to be minimally affected by the current 

Forest Plan, with deer habitat capability forecast to decrease by 1 percent after 100 years, from 66 

percent to 65 percent (Table E-4). Therefore, the 2016 Forest Plan Amendment EIS analysis concluded 
Appendix E

Communities E-20 Final EIS

that the current Forest Plan should be able to provide habitat capability for deer hunted by Angoon 

residents, as well as for all deer hunted within the WAAs, over the course of Forest Plan implementation. 

Table E-4

Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where Angoon

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest1

WAA

Average Deer Harvest from 2004 to 2013 Deer Habitat Capability3

Angoon

Residents

All Rural 

Hunters2 All Hunters 2014

After 100 Years of 

Implementation Change

4042 31 32 41 100% 100% 0%

4055 28 33 48 99% 99% 0%

4054 18 19 21 100% 100% 0%

3939 9 71 105 100% 100% 0%

4041 6 16 19 91% 91% 0%

3308 4 61 107 66% 65% -1% 1 Calculated based on harvest where location is known. 2 The category “All Rural Hunters” includes residents of Southeast Alaska communities, excluding the cities of Juneau and 

Ketchikan.

3 Deer habitat capability in 2014 and after 100 Years of full implementation is expressed as a percent of the 1954 habitat 

capability. Data presented for 100 Years of Implementation are estimates developed for the current Forest Plan in the 2016 

Forest Plan Amendment EIS (USDA Forest Service 2016).

There are no suitable old-growth acres or projected harvest acres in the five most important WAAs under 

any of the alternatives evaluated in this EIS (Tables E-5 and E-6). The number of suitable old-growth 

acres would increase in WAA 3308, with net increases ranging from 100 acres (Alternative 2) to 3,510 

acres (Alternative 6), but projected harvest is expected to decrease relative to Alternative 1 under all five 

action alternatives, dropping from 710 acres (Alternative 1) to 640 acres (Alternative 6). Therefore, no 

additional impacts are anticipated under any of the alternatives.

Table E-5

Suitable Old-Growth by WAA and Alternative for the WAAs where Angoon Residents 

Obtain Approximately 75 Percent of their Average Annual Deer Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

4042 52,983 - - - - - -

4055 68,468 - - - - - -

4054 66,419 - - - - - -

3939 66,460 - - - - - -

4041 55,265 - - - - - -

3308 100,813 6,500 100 980 2,560 3,510 3,510

Table E-6

Projected Old-Growth Harvest by WAA and Alternative for the WAAs where Angoon 

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

4042 52,983 - - - - - -

4055 68,468 - - - - - -

4054 66,419 - - - - - -

3939 66,460 - - - - - -

4041 55,265 - - - - - -

3308 100,813 710 - (30) (110) (70) (70)
Appendix E

Final EIS E-21 Communities

Coffman Cove

Community Use Area

Coffman Cove’s CUA encompasses a total of 1,195,299 acres (Figure E-2). Almost half of this area (48

percent) is presently managed as roadless (Table E-7). This share would drop to 28 and 30 percent 

under Alternatives 3 and 5, respectively, with no acres managed as roadless under Alternative 6. The

removal of LUD II acres under Alternative 3 accounts for approximately 68 percent of the decrease in 

roadless acres under this alternative. These areas would retain their congressional protections and 

continue to be managed in a roadless state. Alternative 4 includes ARA acres that would be managed as 

Timber Priority and allow timber harvest and road building. Timber Priority acres account for 8 percent of 

the ARA in the Coffman Cove CUA. Areas allocated to Roadless Priority would explicitly allow the cutting, 

utilization, customary trade, and removal of trees for the purposes of Alaska Native customary and 

traditional uses, as well as road construction deemed necessary by a federally recognized Tribe for 

access to Alaska Native cultural sites. This type of use would also be allowed in Timber Priority areas, 

which allow all timber harvest and road construction.

Figure E-2

Coffman Cove’s Community Use Area
Appendix E

Communities E-22 Final EIS

Table E-7

Roadless Areas, ARA Management Categories, and Development Opportunity in 

Coffman Cove’s Community Use Area

Roadless Category 

(acres)

Alternative

1 2 3 4 5 6

Total Community Use Area 1,195,299 1,195,299 1,195,299 1,195,299 1,195,299 1,195,299

Total Roadless Area 578,856 561,853 340,328 488,512 354,946 0

Roadless Share 48% 47% 28% 41% 30% 0%

ARA Management Categories (acres)

LUD II Priority na 155,790 0 155,790 155,432 0

Watershed Priority na 239,472 237,978 0 0 0

Roadless Priority na 166,591 105,021 293,088 199,514 0

Community Priority na 0 0 0 0 0

Timber Priority na 0 0 39,633 0 0

Development Opportunity

Development LUDs (acres) 353,074 370,420 420,407 420,893 566,305 566,314

Timber Opportunity (Acres Suitable for Harvest)

Old-Growth 65,141 68,388 79,899 87,329 89,401 89,401

Young-Growth 133,766 134,995 135,051 135,131 135,502 135,851

Estimated Harvest over 100 Years (acres)

Old-Growth 14,072 13,285 12,077 11,431 11,514 11,514

Young-Growth 113,892 111,181 110,038 110,059 109,796 109,080

na = not applicable

Not all acres removed from roadless management would be available for development. The change in 

acres in development LUDs serves as a measure of development potential as it presently exists by 

alternative. Approximately 30 percent (353,100 acres) of the Coffman Cove CUA is presently managed in 

development LUDs. This total would increase under all action alternatives, with net gains ranging from 

about 17,350 acres (Alternative 2) to 213,200 acres (Alternatives 5 and 6). 

Suitable old-growth and young-growth acres available for harvest would increase under all action 

alternatives. Estimated net gains in suitable old growth range from about 3,250 acres (Alternative 2) to 

24,300 acres (Alternatives 5 and 6). Increases in suitable young-growth acres would be equivalent to 2 

percent or less of the existing total under all action alternatives.

Total acres harvested are assumed to remain constant across all alternatives. Estimated old-growth harvest 

over 100 years in the Coffman Cove CUA ranges from about 11,500 acres (Alternatives 5 and 6) to 

14,100 acres (Alternative 1). Estimated young-growth harvest ranges from about 109,100 acres 

(Alternative 6) to 113,900 acres (Alternative 1), with a decrease in potential young-growth harvest relative 

to Alternative 1 in all cases, with larger decreases under Alternatives 3 to 6 (Table E-7).

Subsistence

No significant effect on salmon, other finfish, or invertebrate habitat capability is expected from 

implementation of any alternative. These resources account for 65 percent of the total edible pounds of 

subsistence resources harvested by Coffman Cove households (Kruse and Frazier 1988). Marine 

resources (fish and marine invertebrates) accounted for the majority (71 percent) of per capita 

subsistence harvest in the community in 1998 (ADF&G 2018).

The 1988 TRUCS study found that deer accounted for 32 percent of the total edible pounds of subsistence 

resources harvested by Coffman Cove households (Kruse and Frazier 1988). Deer accounted for 20 percent 

of per capita subsistence harvest by Coffman Cove residents in 1998 (ADF&G 2018). 

Residents of Coffman Cove harvest the majority (70 percent) of their deer from two WAAs in the eastern 

half of north-central Prince of Wales Island (1420 and 1421). The Coffman Cove portion represents about 

one-quarter of the total harvest and about one-third of the rural hunter harvest in these WAAs. About 38 

percent of the combined harvest in these WAAs is by non-rural hunters, suggesting that there is a harvest 

buffer that could be restricted, if necessary, before restrictions are placed on rural harvests. 
Appendix E

Final EIS E-23 Communities

All of the important WAAs used by Coffman Cove residents (the above two and WAA 1315) occur in an 

area with substantial past timber harvest and, therefore, deer habitat capabilities are currently estimated 

to be considerably below 1954 levels (Table E-8). The 2016 Forest Plan Amendment EIS analysis found 

that the current Forest Plan would reduce estimated habitat capabilities after 100 years by a further 4 to 6

percent of 1954 levels (Table E-8). 

Table E-8

Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where Coffman 

Cove Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest1

WAA

Average Deer Harvest from 2004 to 2013 Deer Habitat Capability3

Coffman Cove 

Residents

All Rural 

Hunters2 All Hunters 2014

After 100 Years of 

Implementation Change

1420 59 158 276 49% 44% -5%

1421 31 76 102 68% 64% -4%

1315 7 201 317 56% 50% -6% 1 Calculated based on harvest where location is known. 2 The category “All Rural Hunters” includes residents of Southeast Alaska communities, excluding the cities of Juneau and 

Ketchikan.

3 Deer habitat capability in 2014 and after 100 Years of full implementation is expressed as a percent of the 1954 habitat 

capability. Data presented for 100 Years of Implementation are estimates developed for the current Forest Plan in the 2016 

Forest Plan Amendment EIS (USDA Forest Service 2016).

The 2016 Forest Plan Amendment EIS analysis found that use of most subsistence resources by Whale 

Pass residents (fish and marine invertebrates) was not expected to be affected by any of the alternatives. 

Based on the Deer Availability and Anticipated Demand analysis completed for the 1997 Forest Plan EIS, 

the 2016 analysis found that subsistence use of deer may be affected to the point that some restriction on

hunting might be necessary over the long term, especially for non-rural hunters. The risk of hunting 

restrictions would be reduced somewhat, through more intensive management (e.g., thinning) of the 

existing and future closed-canopy, young-growth forests in this area. Indirect effects associated with 

increased competition for deer within Coffman Cove’s subsistence use areas could also occur if hunters 

from other communities were displaced due to timber harvest activity. 

Suitable old-growth acres would increase relative to Alternative 1 in all three of the WAAs under all of the 

action alternatives (Table E-9). However, projected old-growth harvest would decrease relative to 

Alternative 1 in these WAAs under all of the action alternatives (Table E-10). These relative changes in 

projected harvest are small in absolute terms (i.e., number of acres) and none of the alternatives are 

expected to affect the findings of the 2016 Forest Plan Amendment.

Table E-9

Suitable Old-Growth by WAA and Alternative for the WAAs where Coffman Cove

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

1420 42,409 3,210 230 390 500 500 500

1421 90,038 2,510 - - 40 110 110

1315 55,043 3,820 230 1,240 1,240 1,240 1,240

Table E-10

Projected Old-Growth Harvest by WAA and Alternative for the WAAs where Coffman 

Cove Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

1420 42,409 960 (30) (170) (260) (270) (270)

1421 90,038 750 (70) (200) (270) (260) (260)

1315 55,043 1,140 (40) (30) (180) (200) (200)
Appendix E

Communities E-24 Final EIS

Craig (Shaan da)

Community Use Area

Craig’s CUA encompasses a total of 733,670 acres (Figure E-3). Over half of this area (57 percent) is 

presently managed as roadless (Table E-11). This share would drop to 33 percent under Alternatives 3 

and 5, with no acres managed as roadless under Alternative 6. The removal of LUD II acres under 

Alternative 3 accounts for approximately 55 percent of the decrease in roadless acres under this 

alternative. These areas would retain their congressional protections and continue to be managed in a 

roadless state. Alternative 4 includes ARA acres that would be managed as Timber Priority and allow 

timber harvest and road building. Timber Priority acres account for 12 percent of the ARA in the Craig 

CUA. Areas allocated to Roadless Priority would explicitly allow the cutting, utilization, customary trade, 

and removal of trees for the purposes of Alaska Native customary and traditional uses, as well as road 

construction deemed necessary by a federally recognized Tribe for access to Alaska Native cultural sites. 

This type of use would also be allowed in Timber Priority areas, which allow all timber harvest and road 

construction.

Figure E-3

Craig’s Community Use Area
Appendix E

Final EIS E-25 Communities

Table E-11

Roadless Areas, ARA Management Categories, and Development Opportunity in 

Craig’s Community Use Area

Roadless Category 

(acres)

Alternative

1 2 3 4 5 6

Total Community Use Area 733,670 733,670 733,670 733,670 733,670 733,670

Total Roadless Area 418,413 396,858 239,678 330,167 240,160 0

Roadless Share 57% 54% 33% 45% 33% 0%

ARA Management Categories (acres)

LUD II Priority na 99,731 0 99,731 98,201 0

Watershed Priority na 132,064 29,012 0 0 0

Roadless Priority na 165,063 80,188 192,343 141,960 0

Community Priority na 0 

29,012 0 0 0

Timber Priority na 0 0 38,093 0 0

Development Opportunity

Development LUDs (acres 204,185 225,706 276,493 280,712 375,588 381,527

Timber Opportunity (Acres Suitable for Harvest)

Old-Growth 40,738 46,824 60,255 64,177 65,495 65,495

Young-Growth 72,268 75,911 76,953 76,940 76,995 77,119

Estimated Harvest over 100 Years (acres)

Old-Growth 9,263 9,435 9,613 8,691 8,712 7,043

Young-Growth 61,531 62,519 62,701 62,665 62,388 61,922

na = not applicable

Not all acres removed from roadless management would be available for development. The change in 

acres in development LUDs serves as a measure of development potential as it presently exists by 

alternative. Approximately 28 percent (204,200 acres) of the Craig CUA is presently managed in 

development LUDs. This total would increase under all action alternatives, with net gains ranging from 

about 21,500 acres (Alternative 2) to 177,350 acres (Alternative 6).

Suitable old-growth and young-growth acres available for harvest would increase under all action 

alternatives. Estimated net gains in suitable old growth range from about 6,100 acres (Alternative 2) to 

24,800 acres (Alternatives 5 and 6). Increases in suitable young-growth acres range from about 3,650 

acres (Alternative 2) to 4,850 acres (Alternative 6).

Total acres harvested are assumed to remain constant across all alternatives. Estimated old-growth harvest 

over 100 years ranges from about 7,050 acres (Alternative 6) to 9,600 acres (Alternative 3). Estimated 

young-growth harvest ranges from about 61,500 acres (Alternative 1) to 62,700 acres (Alternatives 3 and 4), 

with an increase in potential young-growth harvest relative to Alternative 1 in all cases (Table E-11).

Subsistence

No significant effect on salmon, other finfish, or invertebrate habitat capability is expected from 

implementation of any alternative. These resources account for 70 percent of the total edible pounds of 

subsistence resources harvested by Craig households (Kruse and Frazier 1988). Marine resources (fish 

and marine invertebrates) accounted for 67 percent of per capita subsistence harvest in Craig in 1997 

(ADF&G 2018).

The 1988 TRUCS study found that deer accounted for 22 percent of the total edible pounds of 

subsistence resources harvested by Craig households (Kruse and Frazier 1988). Deer accounted for 19 

percent of per capita subsistence harvest by Craig residents in 1997 (ADF&G 2018). 

Deer harvest by Craig residents is spread over many WAAs, but a majority (55 percent) are harvested 

from six WAAs in central and northern Prince of Wales Island (the top six WAAs in Table E-12). The Craig 

portion of the harvest in these six WAAs represents about one-third of the total harvest and about onehalf of the rural hunter harvest (Table E-12). About 32 percent of the combined harvest in these WAAs is 

by non-rural hunters, indicating that there is a harvest buffer that could be restricted, if necessary, before 

restrictions are placed on rural harvests. 
Appendix E

Communities E-26 Final EIS

The majority of the WAAs used heavily by Craig residents are in areas with substantial past timber 

harvest, and deer habitat capabilities are currently estimated to be below 1954 levels (Table E-12). The 

2016 Forest Plan Amendment EIS analysis found that additional harvest under the current Forest Plan 

could further reduce estimated habitat capabilities by 1 to 7 percent after 100 years, except for two WAAs 

where there would be no effect (0902 and 1107) (Table E-12).

Table E-12

Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where Craig 

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest1

WAA

Average Deer Harvest from 2004 to 2013 Deer Habitat Capability3

Craig

Residents

All Rural 

Hunters2

All 

Hunters 2014

After 100 Years of 

Implementation Change

1422 106 247 383 57% 50% -7%

1318 70 159 198 90% 84% -6%

1214 60 120 235 77% 71% -6%

1332 56 67 76 88% 87% -1%

0902 55 65 82 100% 100% 0%

1317 51 93 133 58% 56% -2%

0901 43 56 66 95% 93% -2%

1319 40 169 226 74% 69% -5%

1107 30 99 130 99% 99% 0%

1315 29 201 317 56% 50% -6% 1 Calculated based on harvest where location is known. 2 The category “All Rural Hunters” includes residents of Southeast Alaska communities, excluding the cities of Juneau and 

Ketchikan.

3 Deer habitat capability in 2014 and after 100 Years of full implementation is expressed as a percent of the 1954 habitat capability. 

Data presented for 100 Years of Implementation are estimates developed for the current Forest Plan in the 2016 Forest Plan 

Amendment EIS (USDA Forest Service 2016).

The 2016 Forest Plan Amendment EIS analysis found that use of most subsistence resources by Craig 

residents (fish and marine invertebrates) was not expected to be affected by any of the alternatives. 

Based on the Deer Availability and Anticipated Demand analysis completed for the 1997 Forest Plan 

Revision EIS, the 2016 analysis found that subsistence use of deer may be affected to the point that 

some restriction in hunting might be necessary over the long term, especially for non-rural hunters. The 

risk of hunting restrictions would be reduced somewhat, through more intensive management (e.g., 

thinning) of the existing and future closed-canopy, young-growth forests in this area. Indirect effects 

associated with increased competition for deer within Craig’s subsistence use areas could also occur if 

hunters from other communities were displaced due to timber harvest activity. 

Suitable old-growth acres would increase relative to Alternative 1 under most of the action alternatives, 

with larger increases under Alternatives 5 and 6 (Table E-13). In five of the WAAs, projected old-growth 

harvest is mostly expected to decrease relative to Alternative 1 under all five action alternatives, with 

projected harvest mostly expected to increase in the other five WAAs (Table E-14). These relative 

changes in projected harvest are small in absolute terms (i.e., number of acres), and none of the 

alternatives are expected to affect the findings of the 2016 Forest Plan Amendment.
Appendix E

Final EIS E-27 Communities

Table E-13

Suitable Old-Growth by WAA and Alternative for the WAAs where Craig Residents 

Obtain Approximately 75 Percent of their Average Annual Deer Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

1422 120,282 10,120 350 3,770 3,900 3,900 3,900

1318 53,715 1,300 140 1,310 1,410 1,410 1,410

1214 61,675 3,440 1,910 3,190 3,190 3,190 3,190

1332 58,173 1,230 140 550 540 550 550

0902 105,924 - - - - 10 10

1317 57,222 2,460 730 2,190 2,510 3,380 3,380

0901 36,528 490 (10) (10) 1,270 1,270 1,270

1319 103,213 3,250 170 570 600 600 600

1107 124,051 360 10 80 80 90 90

1315 55,043 3,820 230 1,240 1,240 1,240 1,240

Table E-14

Projected Old-Growth Timber Harvest over 100 Years by WAA and Alternative for the 

WAAs where Craig Residents Obtain Approximately 75 Percent of their Average 

Annual Deer Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

1422 120,282 3,020 (180) 20 (360) (410) (410)

1318 53,715 390 - 180 120 110 110

1214 61,675 1,030 420 420 230 200 200

1332 58,173 370 - 20 (30) (40) (40)

0902 105,924 - - - - - -

1317 57,222 730 130 290 210 360 360

0901 36,528 140 (10) (30) 190 190 190

1319 103,213 970 (40) (130) (240) (250) (250)

1107 124,051 110 (10) (10) (30) (30) (30)

1315 55,043 1,140 (40) (30) (180) (200) (200)

Edna Bay

Community Use Area

Edna Bay’s CUA encompasses a total of 633,338 acres (Figure E-4). Slightly more than half of this area 

(55 percent) is presently managed as roadless (Table E-15). This share would drop to 28 percent under 

Alternative 3 and 37 percent under Alternative 5, with no acres managed as roadless under Alternative 6. 

The removal of LUD II acres under Alternative 3 accounts for approximately 84 percent of the decrease in 

roadless acres under this alternative. These areas would retain their congressional protections and 

continue to be managed in a roadless state. Alternative 4 includes ARA acres that would be managed as 

Timber Priority and allow timber harvest and road building. Timber Priority acres account for 14 percent of 

the ARA in the Edna Bay CUA. Areas allocated to Roadless Priority would explicitly allow the cutting, 

utilization, customary trade, and removal of trees for the purposes of Alaska Native customary and 

traditional uses, as well as road construction deemed necessary by a federally recognized Tribe for 

access to Alaska Native cultural sites. This type of use would also be allowed in Timber Priority areas, 

which allow all timber harvest and road construction.
Appendix E

Communities E-28 Final EIS

Figure E-4

Edna Bay’s Community Use Area

Table E-15

Roadless Areas, ARA Management Categories, and Development Opportunity in Edna 

Bay’s Community Use Area

Roadless Category (acres)

Alternative

1 2 3 4 5 6

Total Community Use Area 633,338 633,338 633,338 633,338 633,338 633,338

Total Roadless Area 351,471 354,821 175,658 316,399 231,780 0

Roadless Share 55% 56% 28% 50% 37% 0%

ARA Management Categories (acres)

LUD II Priority na 149,651 0 149,651 147,822 0

Watershed Priority na 91,728 6,833 0 0 0

Roadless Priority na 113,442 78,370 122,925 83,958 0

Community Priority na 0 6,833 0 0 0

Timber Priority na 0 0 43,822 0 0

Development Opportunity

Development LUDs (acres) 164,774 166,460 191,098 195,318 282,749 282,750

Timber Opportunity (Acres Suitable for Harvest)

Old-Growth 32,189 34,109 41,876 49,942 50,555 50,555

Young-Growth 63,907 64,461 64,480 64,536 64,544 64,550

Estimated Harvest over 100 Years (acres)

Old-Growth 7,675 7,223 6,695 6,771 6,754 6,754

Young-Growth 54,412 53,089 52,538 52,562 52,300 51,910

na = not applicable
Appendix E

Final EIS E-29 Communities

Not all acres removed from roadless management would be available for development. The change in 

acres in development LUDs serves as a measure of development potential as it presently exists by 

alternative. Approximately 26 percent (164,800 acres) of the Edna Bay CUA is presently managed in 

development LUDs. This total would increase under all action alternatives with net gains ranging from 

about 1,700 acres (Alternative 2) to 118,000 acres (Alternatives 5 and 6). 

Suitable old-growth and young-growth acres available for harvest would increase under all action 

alternatives. Estimated net gains in suitable old growth range from about 1,900 acres (Alternative 2) to 

18,400 acres (Alternatives 5 and 6). Increases in suitable young-growth acres would be about 1 percent 

of the existing total under all action alternatives.

Total acres harvested are assumed to remain constant across all alternatives. Estimated old-growth harvest 

in the Edna Bay CUA over 100 years ranges from about 6,800 acres (Alternatives 4 to 6) to 7,700 acres 

(Alternative 1). Estimated young-growth harvest ranges from about 51,900 acres (Alternative 6) to 54,400 

acres (Alternative 1), with a decrease in potential young-growth harvest relative to Alternative 1 in all 

cases (Table E-15).

Subsistence

No significant effect on salmon, other finfish, or invertebrate habitat capability is expected from 

implementation of any alternative. These resources accounted for 59 percent of the total edible pounds of 

subsistence resources harvested by Edna Bay households based on the 1988 TRUCS study (Kruse and 

Frazier 1988). Marine resources (fish and marine invertebrates) accounted for 67 percent of per capita 

subsistence harvest in Edna Bay in 1998 (ADF&G 2018).

The 1988 TRUCS study found that deer accounted for 21 percent of the total edible pounds of 

subsistence resources harvested by Edna Bay households (Kruse and Frazier 1988). Deer accounted for 

23 percent of per capita subsistence harvest by Edna Bay residents in 1998 (ADF&G 2018). 

Four WAAs have been identified as most important to Edna Bay residents for deer harvest, with about 68 

percent of Edna Bay’s harvest derived from WAA 1525 (Table E-16). Residents of Edna Bay are 

responsible for all of the deer harvested on Kosciusko Island (WAA 1525), but only a small portion of the 

deer harvested on Heceta Island (WAA 1003) and the other two WAAs identified as important. The Edna 

Bay share represents about 8 percent of the total harvested in these four WAAs and about 11 percent of 

the rural hunter harvest. About 23 percent of the combined harvest in these WAAs is by non-rural 

hunters, suggesting that there is a harvest buffer that could be restricted, if necessary, before restrictions 

are placed on rural harvests. 

Table E-16

Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where Edna Bay 

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest1

WAA

Average Deer Harvest from 2004 to 2013 Deer Habitat Capability3

Edna Bay 

Residents

All Rural 

Hunters2

All 

Hunters 2014

After 100 Years of 

Implementation Change

1525 18 18 18 59% 58% -1%

1003 3 28 44 59% 55% -4%

1318 1 159 198 90% 84% -6%

1526 1 9 18 91% 91% 0% 1 Calculated based on harvest where location is known. 2 The category “All Rural Hunters” includes residents of Southeast Alaska communities, excluding the cities of Juneau and 

Ketchikan.

3 Deer habitat capability in 2014 and after 100 Years of full implementation is expressed as a percent of the 1954 habitat 

capability. Data presented for 100 Years of Implementation are estimates developed for the current Forest Plan in the 2016 

Forest Plan Amendment EIS (USDA Forest Service 2016).

The WAA used most heavily by Edna Bay residents (WAA 1525) is in an area with substantial past timber

harvest and deer habitat capabilities are currently estimated to be considerably below 1954 levels (Table 

E-16). This is also the case with WAA 1003; the next two important WAAs have been less affected by 

past harvest, though are still under 1954 levels. The 2016 Forest Plan Amendment EIS analysis found 
Appendix E

Communities E-30 Final EIS

that additional harvest that could occur under the current Forest Plan would reduce estimated habitat 

capability by 1 percent to 6 percent in three of the WAAs (Table E-16).

The 2016 Forest Plan Amendment EIS analysis found that use of most subsistence resources by Edna 

Bay residents (fish and marine invertebrates) was not expected to be affected by any of the alternatives. 

Based on the Deer Availability and Anticipated Demand analysis completed for the 1997 Forest Plan EIS, 

the 2016 analysis found that there should be sufficient habitat capability over the long term for deer 

hunted by Edna Bay residents, all rural hunters, and all hunters, within the WAAs where Edna Bay 

hunters derive most of their deer harvest. Future young-growth management (e.g., thinning) was 

expected to further reduce the potential for effects on local hunters. It is possible, however, that additional 

timber harvest throughout Prince of Wales and adjacent islands would create increased competition for 

deer within Edna Bay’s subsistence use areas if hunters from other communities were displaced due to 

timber harvest activity. However, these impacts were estimated to be relatively minor based on the limited 

accessibility of these island areas to non-local hunters. 

The number of suitable old-growth acres would increase relative to Alternative 1 under most of the current 

action alternatives in all three of the four important WAAs used by Edna Bay residents, with relatively 

large increases in WAA 1318, which received the most use, almost entirely from hunters from outside 

Edna Bay (Table E-17). Projected old-growth timber harvest would, however, decrease relative to 

Alternative 1 in three of the four WAAs, with modest increases projected for WAA 1318 (Table E-18). As a 

result, none of the alternatives are expected to affect the findings of the 2016 Forest Plan Amendment.

Table E-17

Suitable Old-Growth by WAA and Alternative for the WAAs where Edna Bay Residents 

Obtain Approximately 75 Percent of their Average Annual Deer Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

1525 29,330 1,430 - 550 550 550 550

1003 40,620 4,100 140 140 260 260 260

1318 53,710 1,300 140 1,310 1,410 1,410 1,410

1526 67,360 70 - - - - -

Table E-18

Projected Old-Growth Harvest by WAA and Alternative for the WAAs where Edna Bay

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

1525 29,330 430 (40) - (60) (60) (60)

1003 40,620 1,220 (70) (290) (390) (410) (410)

1318 53,710 390 - 180 120 110 110

1526 67,360 20 - - (10) (10) (10)

Elfin Cove

Community Use Area

Elfin Cove’s CUA encompasses a total of 358,012 acres (Figure E-5). About half of this area (54 percent) 

is presently managed as roadless (Table E-19). This share would drop to 12 percent under Alternative 3, 

with no acres managed as roadless under Alternative 6. The removal of LUD II acres under Alternative 3 

accounts for the entire decrease in roadless acres under this alternative. These areas would retain their 

congressional protections and continue to be managed in a roadless state. Areas allocated to Roadless 

Priority would explicitly allow the cutting, utilization, customary trade, and removal of trees for the 

purposes of Alaska Native customary and traditional uses, as well as road construction deemed 

necessary by a federally recognized Tribe for access to Alaska Native cultural sites. This type of use 

would also be allowed in Timber Priority areas, which allow all timber harvest and road construction.
Appendix E

Final EIS E-31 Communities

Figure E-5

Elfin Cove’s Community Use Area

Table E-19

Roadless Areas, ARA Management Categories, and Development Opportunity in Elfin 

Cove's Community Use Area

Roadless Category (acres)

Alternative

1 2 3 4 5 6

Total Community Use Area 358,012 358,012 358,012 358,012 358,012 358,012

Total Roadless Area 194,411 194,769 44,410 194,497 189,595 0

Roadless Share 54% 54% 12% 54% 53% 0%

ARA Management Categories (acres)

LUD II Priority na 150,359 0 150,359 150,183 0

Watershed Priority na 5,207 0 0 0 0

Roadless Priority na 39,202 39,202 44,135 39,412 0

Community Priority na 0 0 0 0 0

Timber Priority na 0 0 0 0 0

Development Opportunity

Development LUDs (acres) 2 2 2 2 5 5

Timber Opportunity (Acres Suitable for Harvest)

Old-Growth 0 0 0 0 0 0

Young-Growth 0 0 0 0 0 0

Estimated Harvest over 100 Years (acres)

Old-Growth 0 0 0 0 0 0

Young-Growth 0 0 0 0 0 0

na = not applicable
Appendix E

Communities E-32 Final EIS

There would be no acres available for development or suitable for old-growth or young-growth harvest in 

the Elfin Cove CUA under any of the alternatives.

Subsistence

No significant effect on salmon, other finfish, or invertebrate habitat capability is expected from 

implementation of any alternative. These resources accounted for 63 percent of the total edible pounds of 

subsistence resources harvested by Elfin Cove households based on the 1988 TRUCS study (Kruse and 

Frazier 1988). 

The 1988 TRUCS study found that deer accounted for 27 percent of the total edible pounds of 

subsistence resources harvested by Elfin Cove households (Kruse and Frazier 1988). 

Elfin Cove residents take the majority (82 percent) of their deer from two WAAs (3421 and 3420). The 

2016 Forest Plan Amendment EIS analysis found that neither of these WAAs would be affected by the 

current Forest Plan because no timber harvest is proposed in these areas (Table E-20). The 2016 

analysis also concluded that Elfin Cove residents were unlikely to be affected by increased competition

because of the limited access and the lack of activities under the alternatives in this area. There are no 

suitable old-growth acres in either of these WAAs under any of the alternatives and no projected oldgrowth harvest (Tables E-21 and E-22). As a result, none of the alternatives are expected to affect the 

findings of the 2016 Forest Plan Amendment EIS.

Table E-20

Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where Elfin Cove 

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest1

WAA

Average Deer Harvest from 2004 to 2013 Deer Habitat Capability3

Elfin Cove 

Residents

All Rural 

Hunters2

All 

Hunters 2014

After 100 Years of 

Implementation Change

3421 13 42 66 100% 100% 0%

3420 2 19 52 100% 100% 0% 1 Calculated based on harvest where location is known. 2 The category “All Rural Hunters” includes residents of Southeast Alaska communities, excluding the cities of Juneau and 

Ketchikan.

3 Deer habitat capability in 2014 and after 100 Years of full implementation is expressed as a percent of the 1954 habitat 

capability. Data presented for 100 Years of Implementation are estimates developed for the current Forest Plan in the 2016 

Forest Plan Amendment EIS (USDA Forest Service 2016).

Table E-21

Suitable Old-Growth by WAA and Alternative for the WAAs where Elfin Cove Residents 

Obtain Approximately 75 Percent of their Average Annual Deer Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

3421 43,290 - - - - - -

3420 53,230 - - - - - -

Table E-22

Projected Old-Growth Harvest by WAA and Alternative for the WAAs where Elfin Cove

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

3421 43,290 - - - - - -

3420 53,230 - - - - - -
Appendix E

Final EIS E-33 Communities

Gustavus

Community Use Area

The Gustavus CUA encompasses a total of 481,696 acres (Figure E-6). Most of this area (81 percent) is

presently managed as roadless (Table E-23). This share would drop to 56 and 59 percent under 

Alternatives 3 and 5, respectively, with no acres managed as roadless under Alternative 6. The removal 

of LUD II acres under Alternative 3 accounts for approximately 97 percent of the decrease in roadless

acres under this alternative. These areas would retain their congressional protections and continue to be 

managed in a roadless state. Alternative 4 includes ARA acres that would be managed as Timber Priority 

and allow timber harvest and road building. Timber Priority acres account for 18 percent of the ARA in the 

Gustavus CUA. Areas allocated to Roadless Priority would explicitly allow the cutting, utilization, 

customary trade, and removal of trees for the purposes of Alaska Native customary and traditional uses, 

as well as road construction deemed necessary by a federally recognized Tribe for access to Alaska 

Native cultural sites. This type of use would also be allowed in Timber Priority areas, which allow all 

timber harvest and road construction.

Figure E-6

Gustavus Community Use Area
Appendix E

Communities E-34 Final EIS

Table E-23

Roadless Areas, ARA Management Categories, and Development Opportunity in 

Gustavus' Community Use Area

Roadless Category (acres)

Alternative

1 2 3 4 5 6

Total Community Use Area 481,696 481,696 481,696 481,696 481,696 481,696

Total Roadless Area 388,838 389,799 269,082 382,303 282,713 0

Roadless Share 81% 81% 56% 79% 59% 0%

ARA Management Categories (acres)

LUD II Priority na 116,308 0 116,308 16,132 0

Watershed Priority na 77,406 0 0 0 0

Roadless Priority na 196,085 191,676 196,709 166,581 0

Community Priority na 0 0 0 0 0

Timber Priority na 0 0 69,285 0 0

Development Opportunity

Development LUDs (acres) 43,019 42,544 46,258 48,435 144,642 144,643

Timber Opportunity (Acres Suitable for Harvest)

Old-Growth 13,607 14,128 15,753 26,653 27,623 27,623

Young-Growth 11,322 11,491 11,516 11,650 11,774 12,530

Estimated Harvest over 100 Years (acres)

Old-Growth 882 882 864 944 930 930

Young-Growth 9,640 9,464 9,384 9,488 9,540 10,061

na = not applicable

Not all acres removed from roadless management would be available for development. The change in 

acres in development LUDs serves as a measure of development potential as it presently exists by 

alternative. Approximately 9 percent (43,000 acres) of the Gustavus CUA is presently managed in 

development LUDs. This total would increase under Alternatives 3 to 6, with net gains ranging from about 

3,200 acres (Alternative 2) to about 101,600 acres (Alternatives 5 and 6); the total would drop by about 

500 acres under Alternative 2. 

Suitable old-growth and young-growth acres available for harvest would increase under all action

alternatives. Estimated net gains in suitable old-growth range from about 500 acres (Alternative 2) to 

14,000 acres (Alternatives 5 and 6). Increases in suitable young-growth acres range from about 170

acres (Alternative 2) to 1,200 acres (Alternative 6).

Total acres harvested are assumed to remain constant across all alternatives. Estimated old-growth 

harvest over 100 years in the Gustavus CUA would be similar across all alternatives, about 900 acres. 

Estimated young-growth harvest ranges from about 9,400 acres (Alternative 3) to 10,100 acres 

(Alternative 6) (Table E-23).

Subsistence

No significant effect on salmon, other finfish, or invertebrate habitat capability is expected from 

implementation of any alternative. Marine resources (fish and marine invertebrates) accounted for 69 

percent of per capita subsistence harvest in Gustavus in 1987 (Kruse and Frazier 1988). 

The 1988 TRUCS study found that deer accounted for 70 percent of the total edible pounds of 

subsistence resources harvested by Gustavus households (Kruse and Frazier 1988). 

Gustavus residents take the majority (73 percent) of their deer from two WAAs on northern Chichagof 

Island and Pleasant, Lemesurier, and Inian Islands (WAAs 4256 and 4222). The 2016 Forest Plan 

Amendment EIS analysis found that WAA 4256, which provides over half of Gustavus’ harvest, would not 

be affected under the current Forest Plan because it is in wilderness. WAA 4222 was expected to be 

affected by timber harvest that could occur under the current Forest Plan, with habitat capability 

estimated to be reduced by 1 percent (Table E-24).
Appendix E

Final EIS E-35 Communities

Table E-24

Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where 

Gustavus Residents Obtain Approximately 75 Percent of their Average Annual Deer 

Harvest1

WAA

Average Deer Harvest from 2004 to 2013 Deer Habitat Capability3 

Gustavus 

Residents

All Rural 

Hunters2

All 

Hunters 2014

After 100 Years of 

Implementation Change

4256 47 52 68 100% 100% 0%

4222 10 32 44 97% 96% -1% 1 Calculated based on harvest where location is known. 2 The category “All Rural Hunters” includes residents of Southeast Alaska communities, excluding the cities of Juneau and 

Ketchikan.

3 Deer habitat capability in 2014 and after 100 Years of full implementation is expressed as a percent of the 1954 habitat 

capability. Data presented for 100 Years of Implementation are estimates developed for the current Forest Plan in the 2016 

Forest Plan Amendment EIS (USDA Forest Service 2016).

The 2016 Forest Plan Amendment EIS analysis found that the use of most subsistence resources by 

Gustavus residents (fish and marine resources) was not expected to be affected by the current Forest 

Plan. The 2016 analysis also found that it was unlikely that Gustavus residents would be affected by 

increased competition because of the limited access and the lack of activities under the alternatives in 

this area. There are no suitable old-growth acres in either of these WAAs under any of the alternatives 

and no projected old-growth harvest (Tables E-25 and E-26). As a result, none of the alternatives are 

expected to affect the findings of the 2016 Forest Plan Amendment EIS.

Table E-25

Suitable Old-Growth by WAA and Alternative for the WAAs where Gustavus Residents 

Obtain Approximately 75 Percent of their Average Annual Deer Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

4256 18,940 - - - - - -

4222 89,910 - - - - - -

Table E-26

Projected Old-Growth Harvest by WAA and Alternative for the WAAs where Gustavus

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

4256 18,940 - - - - - -

4222 89,910 - - - - - -

Haines

Community Use Area

Haines’ CUA encompasses a total of 236,468 acres (Figure E-7). Nearly all of this area (98 percent) is 

presently managed as roadless (Table E-27). This share would lower to 84 percent under Alternative 5, 

with no acres managed as roadless under Alternative 6. Alternative 4 includes ARA acres that would be 

managed as Timber Priority and allow timber harvest and road building. Timber Priority acres account for 

8 percent of the ARA in the Haines CUA. Areas allocated to Roadless Priority would explicitly allow the 

cutting, utilization, customary trade, and removal of trees for the purposes of Alaska Native customary 

and traditional uses, as well as road construction deemed necessary by a federally recognized Tribe for 

access to Alaska Native cultural sites. This type of use would also be allowed in Timber Priority areas, 

which allow all timber harvest and road construction.
Appendix E

Communities E-36 Final EIS

Figure E-7

Haines Community Use Area

Table E-27

Roadless Areas, ARA Management Categories, and Development Opportunity in Haines' 

Community Use Area

Roadless Category (acres)

Alternative

1 2 3 4 5 6

Total Community Use Area 236,468 236,468 236,468 236,468 236,468 236,468

Total Roadless Area 232,027 230,323 230,323 230,109 198,410 0

Roadless Share 98% 97% 97% 97% 84% 0%

ARA Management Categories (acres)

LUD II Priority na 0 0 0 0 0

Watershed Priority na 90,333 0 0 0 0

Roadless Priority na 139,990 139,990 211,779 98,410 0

Community Priority na 0 0 0 0 0

Timber Priority na 0 0 18,330 0 0

Development Opportunity

Development LUDs (acres) 2,517 4,379 4,379 4,379 32,581 32,581

Timber Opportunity (Acres Suitable for Harvest)

Old-Growth 36 51 51 72 72 72

Young-Growth 1,428 2,089 2,089 2,135 2,336 2,406

Estimated Harvest over 100 Years (acres)

Old-Growth 0 0 0 0 0 0

Young-Growth 1,216 1,721 1,702 1,739 1,893 1,932

na = not applicable
Appendix E

Final EIS E-37 Communities

Not all acres removed from roadless management would be available for development. The change in 

acres in development LUDs serves as a measure of development potential as it presently exists by 

alternative. Approximately 1 percent (2,500 acres) of the Haines CUA is presently managed in 

development LUDs. This total would increase under all action alternatives, with net gains ranging from 

about 1,900 acres (Alternatives 2 to 4) to 30,100 acres (Alternatives 5 and 6). 

Suitable old-growth and young-growth acres available for harvest would stay the same or increase under 

all action alternatives. Estimated net gains in suitable old-growth are negligible (less than 50 acres) under 

all alternatives. Increases in suitable young-growth acres range from about 700 acres (Alternatives 2 to 4) 

to 1,000 acres (Alternative 6). 

Total acres harvested are assumed to remain constant across all alternatives. No old-growth acres are 

estimated to be harvested in the Haines CUA under any of the alternatives. Estimated young-growth harvest 

would increase slightly relative to Alternative 1 under all action alternatives, with increases from about 500 

acres (Alternatives 2 to 4) to about 700 acres (Alternatives 5 and 6) (Table E-27).

Subsistence

No significant effect on salmon, other finfish, or invertebrate habitat capability is expected from 

implementation of any alternative. These resources account for 68 percent of the total edible pounds of 

subsistence resources harvested by Haines households (Kruse and Frazier 1988). Marine resources (fish 

and marine invertebrates) accounted for 72 percent of per capita subsistence harvest in Haines in 2012 

(ADF&G 2018). 

The 1988 TRUCS study found that deer accounted for 15 percent of the total edible pounds of 

subsistence resources harvested by Haines households (Kruse and Frazier 1988). Deer accounted for 5 

percent of per capita subsistence harvest by Haines residents in 2012, with moose more important at 11 

percent per capita (ADF&G 2018). Moose availability would not be significantly affected under any of the 

alternatives.

Twenty-three WAAs account for about 75 percent of deer harvest by Haines residents. The three most 

heavily used WAAs (3421, 2202, and 3836) accounted for about 28 percent of total deer harvest by 

Haines residents (Table E-28). As these numbers suggest, deer harvest by Haines residents is spread 

over a fairly wide area and, as a result, Haines residents tend to comprise a relatively small share of total 

harvest by WAA, with one main exception – WAA 2202 on Sullivan Island, which has a low level of deer 

harvest but nearly all by Haines residents. 

The 2016 Forest Plan Amendment EIS analysis found that there would be no effect to deer habitat 

capability in 18 of the 23 WAAs under the current Forest Plan. Reductions in habitat capability in the other 

five WAAs were estimated to range from 1 to 6 percent (Table E-28). About 41 percent of the combined 

harvest in the 23 WAAs used by Haines residents is by non-rural hunters, suggesting that there is a 

harvest buffer that could be restricted, if necessary, before restrictions are placed on rural harvests.

Table E-28

Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where Haines 

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest1

WAA

Average Deer Harvest from 2004 to 2013 Deer Habitat Capability3

Haines 

Residents

All Rural 

Hunters2

All 

Hunters 2014

After 100 Years of 

Implementation Change

3421 20 42 66 68% 63% -5%

2202 18 18 18 91% 91% 0%

3836 10 16 210 100% 100% 0%

4252 9 51 72 92% 92% 0%

3420 9 19 52 100% 100% 0%

3938 7 41 75 100% 100% 0%

1106 7 17 33 100% 100% 0%

3416 6 78 88 100% 100% 0%
Appendix E

Communities E-38 Final EIS

Table E-28 (continued)

Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where Haines 

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest1

WAA

Average Deer Harvest from 2004 to 2013 Deer Habitat Capability3

Haines 

Residents

All Rural 

Hunters2

All 

Hunters 2014

After 100 Years of 

Implementation Change

4222 5 32 44 97% 96% -1%

3524 5 51 82 99% 98% -1%

3418 4 18 26 100% 100% 0%

4253 3 48 66 84% 84% 0%

3417 3 60 115 100% 100% 0%

3525 3 56 118 75% 70% -5%

4256 3 52 68 100% 100% 0%

3002 3 272 299 69% 69% 0%

3001 2 338 361 82% 82% 0%

4041 2 16 19 91% 91% 0%

2722 2 6 302 100% 100% 0%

3309 2 72 81 100% 100% 0%

3551 2 48 67 83% 77% -6%

4146 2 4 28 100% 100% 0%

3419 2 23 40 100% 100% 0% 1 Calculated based on harvest where location is known. 2 The category “All Rural Hunters” includes residents of Southeast Alaska communities, excluding the cities of Juneau and 

Ketchikan.

3 Deer habitat capability in 2014 and after 100 Years of full implementation is expressed as a percent of the 1954 habitat 

capability. Data presented for 100 Years of Implementation are estimates developed for the current Forest Plan in the 2016 

Forest Plan Amendment EIS (USDA Forest Service 2016).

The 2016 Forest Plan Amendment EIS analysis found that use of most subsistence resources by Haines 

residents (fish and marine invertebrates) was not expected to be affected by any of the alternatives. 

Based on the Deer Availability and Anticipated Demand analysis completed for the 1997 Forest Plan EIS, 

the 2016 analysis found that subsistence use of deer in some of the WAAs hunted by Haines residents may 

be affected to the point that some restriction in hunting might be necessary over the long term, especially for 

non-rural hunters. The risk of hunting restrictions would be reduced somewhat, through more intensive 

management (e.g., thinning) of the existing and future closed-canopy, young-growth forests in this area. 

Indirect effects associated with increased competition for deer within Haines’ subsistence use areas could also 

occur if hunters from other communities were displaced due to timber harvest activity.

There are no suitable old-growth acres and no projected old-growth harvest in 20 of the 23 important 

WAAs used by Haines residents (Tables E-29 and E-30). Suitable old-growth acres in the other three 

WAAs (3524, 3525, and 3551) would increase relative to Alternative 1 under most of the action 

alternatives, with larger increases under Alternatives 4 to 6. Projected old-growth harvest is mostly 

expected to decrease relative to Alternative 1 for two of the WAAs, with modest increases projected for 

the other WAA (Table 30). These relative changes in projected harvest are small in absolute terms (i.e., 

number of acres) and none of the alternatives are expected to affect the findings of the 2016 Forest Plan 

Amendment.
Appendix E

Final EIS E-39 Communities

Table E-29

Suitable Old-Growth by WAA and Alternative for the WAAs where Haines Residents 

Obtain Approximately 75 Percent of their Average Annual Deer Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

3421 43,290 - - - - - -

2202 49,630 - - - - - -

3836 53,460 - - - - - -

4252 19,540 - - - - - -

3420 53,230 - - - - - -

3938 76,970 - - - - - -

1106 7,420 - - - - - -

3416 65,170 - - - - - -

4222 89,910 - - - - - -

3524 13,760 30 - - 2,740 2,740 2,740

3418 53,510 - - - - - -

4253 45,890 - - - - - -

3417 134,230 - - - - - -

3525 73,120 2,350 40 380 600 610 610

4256 18,940 - - - - - -

3002 77,040 - - - - - -

3001 79,250 - - - - - -

4041 55,260 - - - - - -

2722 25,150 - - - - - -

3309 43,820 - - - - - -

3551 58,490 5,120 80 1,370 3,170 3,170 3,170

4146 65,430 - - - - - -

3419 84,930 - - - - - -

Table E-30

Projected Old-Growth Harvest by WAA and Alternative for the WAAs where Haines

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

3421 43,290 - - - - - -

2202 49,630 - - - - - -

3836 53,460 - - - - - -

4252 19,540 - - - - - -

3420 53,230 - - - - - -

3938 76,970 - - - - - -

1106 7,420 - - - - - -

3416 65,170 - - - - - -

4222 89,910 - - - - - -

3524 13,760 - - - 180 180 180

3418 53,510 - - - - - -

4253 45,890 - - - - - -

3417 134,230 - - - - - -

3525 73,120 260 - (10) (60) (70) (70)

4256 18,940 - - - - - -

3002 77,040 - - - - - -

3001 79,250 - - - - - -

4041 55,260 - - - - - -

2722 25,150 - - - - - -

3309 43,820 - - - - - -

3551 58,490 560 - 30 (10) (30) (30)

4146 65,430 - - - - - -

3419 84,930 - - - - - -
Appendix E

Communities E-40 Final EIS

Hollis

Community Use Area

The Hollis CUA encompasses a total of 274,440 acres (Figure E-8). More than two-thirds of this area (68

percent) is presently managed as roadless (Table E-31). This share would drop to 32 percent under 

Alternative 5, with no acres managed as roadless under Alternative 6. Alternative 4 includes ARA acres 

that would be managed as Timber Priority and allow timber harvest and road building. Timber Priority 

acres account for 11 percent of the ARA in the Hollis CUA. Areas allocated to Roadless Priority would 

explicitly allow the cutting, utilization, customary trade, and removal of trees for the purposes of Alaska 

Native customary and traditional uses, as well as road construction deemed necessary by a federally 

recognized Tribe for access to Alaska Native cultural sites. This type of use would also be allowed in 

Timber Priority areas, which allow all timber harvest and road construction.

Not all acres removed from roadless management would be available for development. The change in 

acres in development LUDs serves as a measure of development potential as it presently exists by 

alternative. Approximately 16 percent (45,000 acres) of the Hollis CUA is presently managed in 

development LUDs. This total would increase under all action alternatives, with net gains ranging from 

about 18,200 acres (Alternative 2) to 97,400 acres (Alternative 6). 

Suitable old-growth and young-growth acres available for harvest would increase under all action 

alternatives. Estimated net gains in suitable old-growth range from about 4,050 acres (Alternative 2) to 

9,750 acres (Alternatives 5 and 6). Increases in suitable young-growth acres range from about 2,700

acres (Alternative 2) to 3,950 acres (Alternative 6), representing an increase of 21 to 31 percent.

Total acres harvested are assumed to remain constant across all alternatives. Estimated old-growth harvest 

totals over 100 years in the Hollis CUA would be similar across all alternatives, ranging from about 2,300 

acres (Alternative 1) to 3,100 acres (Alternative 4). Estimated young-growth harvest ranges from about 

11,000 acres (Alternative 1) to about 13,500 acres (Alternatives 3 to 6) (Table E-31). 
Appendix E

Final EIS E-41 Communities

Figure E-8

Hollis’ Community Use Area
Appendix E

Communities E-42 Final EIS

Table E-31

Roadless Areas, ARA Management Categories, and Development Opportunity in Hollis' 

Community Use Area

Roadless Category (acres)

Alternative

1 2 3 4 5 6

Total Community Use Area 274,440 274,440 274,440 274,440 274,440 274,440

Total Roadless Area 186,848 164,768 142,056 141,408 87,519 0

Roadless Share 68% 60% 52% 52% 32% 0%

ARA Management Categories (acres)

LUD II Priority na 0 0 0 0 0

Watershed Priority na 87,257 17,343 0 0 0

Roadless Priority na 77,511 37,456 126,467 87,519 0

Community Priority na 0 17,343 0 0 0

Timber Priority na 0 0 14,941 0 0

Development Opportunity

Development LUDs (acres) 44,883 63,106 84,113 84,113 136,370 142,309

Timber Opportunity (Acres Suitable for Harvest)

Old-Growth 8,848 12,884 17,194 17,640 18,590 18,590

Young-Growth 12,886 15,597 16,637 16,610 16,641 16,841

Estimated Harvest over 100 Years (acres)

Old-Growth 2,270 2,832 3,091 2,733 2,845 2,845

Young-Growth 10,972 12,846 13,556 13,528 13,484 13,522

na = not applicable

Subsistence

No significant effect on salmon, other finfish, or invertebrate habitat capability is expected from 

implementation of any alternative. These resources account for 65 percent of the total edible pounds of 

subsistence resources harvested by Hollis households (Kruse and Frazier 1988). Marine resources (fish 

and marine invertebrates) accounted for 73 percent of per capita subsistence harvest in Hollis in 1998 

(ADF&G 2018). 

The 1988 TRUCS study found that deer account for 23 percent of the total edible pounds of subsistence 

resources harvested by Hollis households (Kruse and Frazier 1988). Deer accounted for 18 percent of the 

per capita subsistence harvest by Hollis residents in 1998 (ADF&G 2018). 

The three WAAs most used by Hollis residents are areas where substantial past timber harvest has 

occurred and, therefore, deer habitat capabilities are currently estimated to be well below 1954 levels. 

The 2016 Forest Plan Amendment EIS analysis found that additional harvest that could occur under the 

current Forest Plan would further reduce estimated habitat capabilities after 100 years by 2 percent to 7 

percent (Table E-32). 

Table E-32

Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where Hollis 

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest1

WAA

Average Deer Harvest from 2004 to 2013 Deer Habitat Capability3

Hollis 

Residents

All Rural 

Hunters2

All 

Hunters 2014

After 100 Years of 

Implementation Change

1214 11 121 235 77% 71% -6%

1317 10 95 133 58% 56% -2%

1422 3 247 383 57% 50% -7% 1 Calculated based on harvest where location is known. 2 The category “All Rural Hunters” includes residents of Southeast Alaska communities, excluding the cities of Juneau and 

Ketchikan.

3 Deer habitat capability in 2014 and after 100 Years of full implementation is expressed as a percent of the 1954 habitat 

capability. Data presented for 100 Years of Implementation are estimates developed for the current Forest Plan in the 2016 

Forest Plan Amendment EIS (USDA Forest Service 2016).
Appendix E

Final EIS E-43 Communities

The 2016 Forest Plan Amendment EIS analysis found that use of most subsistence resources by Hollis 

residents (fish and marine invertebrates) was not expected to be affected by any of the alternatives. 

Based on the Deer Availability and Anticipated Demand analysis completed for the 1997 Forest Plan EIS, 

the 2016 analysis found that subsistence use of deer may be affected to the point that some restriction in 

hunting might be necessary over the long term, especially for non-rural hunters. The risk of hunting 

restrictions would be reduced somewhat through more intensive management (e.g., thinning) of the 

existing and future closed-canopy, young-growth forests in this area. Indirect effects associated with 

increased competition could also occur if hunters from other communities were displaced due to timber 

harvest activity.

Suitable old-growth acres in all three WAAs important to Hollis residents would increase relative to 

Alternative 1 under all of the action alternatives, with larger increases under Alternatives 4 to 6 (Table 

E-33). Projected old-growth harvest is also expected to increase relative to Alternative 1 in two of the 

WAAs, with decreases anticipated under four of the five alternatives for the other WAA (Table E-34). 

These relative changes in projected harvest are small in absolute terms (i.e., number of acres) and none 

of the alternatives are expected to affect the findings of the 2016 Forest Plan Amendment.

Table E-33

Suitable Old-Growth by WAA and Alternative for the WAAs where Hollis Residents 

Obtain Approximately 75 Percent of their Average Annual Deer Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

1214 61,680 3,440 1,910 3,190 3,190 3,190 3,190

1317 57,220 2,460 730 2,190 2,510 3,380 3,380

1422 120,280 10,120 350 3,770 3,900 3,900 3,900

Table E-34

Projected Old-Growth Harvest by WAA and Alternative for the WAAs where Hollis

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

1214 61,680 1,030 420 420 230 200 200

1317 57,220 730 130 290 210 360 360

1422 120,280 3,020 (180) 20 (360) (410) (410)

Hoonah (Xunaa)

Community Use Area

Hoonah’s CUA encompasses a total of 585,102 acres (Figure E-9). About three-quarters of this area (76

percent) is presently managed as roadless (Table E-35). This share would drop to 57 and 50 percent under 

Alternatives 3 and 5, respectively, with no acres managed as roadless under Alternative 6. The removal of LUD 

II acres under Alternative 3 accounts for approximately 92 percent of the decrease in roadless acres under this 

alternative. These areas would retain their congressional protections and continue to be managed in a roadless 

state. Alternative 4 includes ARA acres that would be managed as Timber Priority and allow timber harvest and 

road building. Timber Priority acres account for 20 percent of the ARA in the Hoonah CUA. Areas allocated to 

Roadless Priority would explicitly allow the cutting, utilization, customary trade, and removal of trees for the 

purposes of Alaska Native customary and traditional uses, as well as road construction deemed necessary by a 

federally recognized Tribe for access to Alaska Native cultural sites. This type of use would also be allowed in 

Timber Priority areas, which allow all timber harvest and road construction.
Appendix E

Communities E-44 Final EIS

Figure E-9

Hoonah’s Community Use Area
Appendix E

Final EIS E-45 Communities

Table E-35

Roadless Areas, ARA Management Categories, and Development Opportunity in 

Hoonah's Community Use Area

Roadless Category 

(acres)

Alternative

1 2 3 4 5 6

Total Community Use 

Area 585,102 585,102 585,102 585,102 585,102 585,102

Total Roadless Area 446,273 447,147 336,145 433,045 290,934 0

Roadless Share 76% 76% 57% 74% 50% 0%

ARA Management Categories (acres)

LUD II Priority na 101,150 0 101,150 100,979 0

Watershed Priority na 120,847 0 0 0 0

Roadless Priority na 225,150 215,299 243,698 189,955 0

Community Priority na 0 0 0 0 0

Timber Priority na 0 0 88,197 0 0

Development Opportunity

Development LUDs 

(acres) 80,078 79,693 88,849 92,016 230,746 230,748

Timber Opportunity (Acres Suitable for Harvest)

Old-Growth 23,950 25,133 28,303 43,517 44,552 44,552

Young-Growth 20,079 20,340 20,365 20,498 20,625 20,621

Estimated Harvest over 100 Years (acres)

Old-Growth 1,140 1,139 1,112 1,140 1,119 1,119

Young-Growth 17,095 16,751 16,593 16,695 16,712 17,360

na = not applicable

Not all acres removed from roadless management would be available for development. The change in 

acres in development LUDs serves as a measure of development potential as it presently exists by 

alternative. Approximately 14 percent (80,100 acres) of the Hoonah CUA is presently managed in 

development LUDs. This total would increase under Alternatives 3 to 6, with net gains ranging from about 

8,800 acres (Alternative 3) to 150,700 acres (Alternatives 5 and 6); the total would drop by about 400 

acres under Alternative 2.

Suitable old-growth and young-growth acres available for harvest would increase under all action 

alternatives. Estimated net gains in suitable old-growth range from about 1,200 acres (Alternative 2) to 

20,600 acres (Alternatives 5 and 6). Increases in suitable young-growth acres range from about 250

acres (Alternative 2) to 1,550 acres (Alternative 6). 

Total acres harvested are assumed to remain constant across all alternatives. Estimated old-growth harvest 

over 100 years in the Hoonah CUA is similar across all alternatives, with estimated totals of about 1,100 

acres. Estimated young-growth harvest would also be similar across all alternatives, ranging from about 

16,600 acres (Alternative 3) to approximately 17,400 acres (Alternative 6) (Table E-35).

Subsistence

No significant effect on salmon, other finfish, or invertebrate habitat capability is expected from 

implementation of any alternative. These resources account for 59 percent of the total edible pounds of 

subsistence resources harvested by Hoonah households (Kruse and Frazier 1988). Marine resources 

(fish and marine invertebrates) accounted for 68 percent of per capita subsistence harvest in Hoonah in 

2012 (ADF&G 2018). 

The 1988 TRUCS study found that deer accounted for 23 percent of the total edible pounds of 

subsistence resources harvested by Hoonah households (Kruse and Frazier 1988). Deer accounted for 

15 percent of per capita subsistence harvest by Hoonah residents (ADF&G 2018). 

Hoonah residents mainly harvest deer on Chichagof Island. Six WAAs account for the majority (73 

percent) of deer harvest by Hoonah residents (Table E-36). The Hoonah portion represents about 89 

percent of the combined average rural hunter harvest and 57 percent of the total harvest in these WAAs. 
Appendix E

Communities E-46 Final EIS

About 36 percent of the combined harvest in these WAAs is by non-rural hunters, suggesting that there is 

a harvest buffer that could be restricted, if necessary, before restrictions are placed on rural harvests.

All of the WAAs identified in Table E-36 are in areas with at least some past timber harvest and deer 

habitat capabilities are currently estimated to be below 1954 levels. The 2016 Forest Plan Amendment 

EIS analysis found that additional harvest under the current Forest Plan would further reduce estimated 

habitat capabilities after 100 years in four of the WAAs by 1 to 6 percent. 

Table E-36

Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where Hoonah 

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest1

WAA

Average Deer Harvest from 2004 to 2013 Deer Habitat Capability3

Hoonah 

Residents

All Rural 

Hunters2

All 

Hunters 2014

After 100 Years of 

Implementation Change

3523 60 62 88 79% 75% -4%

3524 45 51 82 99% 98% -1%

3551 45 48 67 83% 77% -6%

3525 44 56 118 75% 70% -5%

4253 43 48 66 84% 84% 0%

4252 42 51 72 92% 92% 0% 1 Calculated based on harvest where location is known. 2 The category “All Rural Hunters” includes residents of Southeast Alaska communities, excluding the cities of Juneau and 

Ketchikan.

3 Deer habitat capability in 2014 and after 100 Years of full implementation is expressed as a percent of the 1954 habitat 

capability. Data presented for 100 Years of Implementation are estimates developed for the current Forest Plan in the 2016 

Forest Plan Amendment EIS (USDA Forest Service 2016).

The 2016 Forest Plan Amendment EIS analysis found that the use of most subsistence resources by 

Hoonah residents (fish and marine invertebrates) was not expected to be affected under the current 

Forest Plan. Based on the Deer Availability and Anticipated Demand analysis completed for the 1997 

Forest Plan EIS, the 2016 analysis found that subsistence use of deer may be affected to the point that 

some restriction in hunting might be necessary over the long term, especially for non-rural hunters. The 

risk of hunting restrictions would be reduced somewhat, through more intensive management (e.g., 

thinning) of the existing and future closed-canopy, young-growth forests in this area. Indirect effects 

associated with increased competition for deer within Hoonah’s subsistence use areas could also occur if 

hunters from other communities were displaced due to timber harvest activity. 

Suitable old-growth acres in three of the six WAAs important to Hoonah residents would increase relative 

to Alternative 1 under most of the action alternatives, with larger increases under Alternatives 4 to 6 

(Table E-37). Projected old-growth harvest is also expected to increase relative to Alternative 1 in one of 

these WAAs, with relative decreases anticipated for the other WAAs (Table E-38). These relative changes 

in projected harvest are small in absolute terms (i.e., number of acres) and none of the alternatives are 

expected to affect the findings of the 2016 Forest Plan Amendment.

Table E-37

Suitable Old-Growth by WAA and Alternative for the WAAs where Hoonah Residents 

Obtain Approximately 75 Percent of their Average Annual Deer Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

3523 45,310 - - - - - -

3524 13,760 30 - - 2,740 2,740 2,740

3551 58,490 5,120 80 1,370 3,170 3,170 3,170

3525 73,120 2,350 40 380 600 610 610

4253 45,890 - - - - - -

4252 19,540 - - - - - -
Appendix E

Final EIS E-47 Communities

Table E-38

Projected Old-Growth Harvest by WAA and Alternative for the WAAs where Hoonah

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

3523 45,310 - - - - - -

3524 13,760 - - - 180 180 180

3551 58,490 560 - 30 (10) (30) (30)

3525 73,120 260 - (10) (60) (70) (70)

4253 45,890 - - - - - -

4252 19,540 - - - - - -

Hydaburg

Community Use Area

Hydaburg’s CUA encompasses a total of 729,892 acres (Figure E-10). Approximately three-quarters of 

this area (75 percent) is presently managed as roadless (Table E-39). This share would drop to 41

percent under Alternative 5, with no acres managed as roadless under Alternative 6. The removal of LUD 

II acres under Alternative 3 accounts for approximately 61 percent of the decrease in roadless acres 

under this alternative. These areas would retain their congressional protections and continue to be 

managed in a roadless state. Alternative 4 includes ARA acres that would be managed as Timber Priority 

and allow timber harvest and road building. Timber Priority acres account for 14 percent of the ARA in the 

Hydaburg CUA. Areas allocated to Roadless Priority would explicitly allow the cutting, utilization, 

customary trade, and removal of trees for the purposes of Alaska Native customary and traditional uses, 

as well as road construction deemed necessary by a federally recognized Tribe for access to Alaska 

Native cultural sites. This type of use would also be allowed in Timber Priority areas, which allow all 

timber harvest and road construction.
Appendix E

Communities E-48 Final EIS

Figure E-10

Hydaburg’s Community Use Area

Table E-39

Roadless Areas, ARA Management Categories, and Development Opportunity in 

Hydaburg’s Community Use Area

Roadless Category (acres)

Alternative

1 2 3 4 5 6

Total Community Use Area 729,892 729,892 729,892 729,892 729,892 729,892

Total Roadless Area 545,979 539,082 461,005 504,796 301,522 0

Roadless Share 75% 74% 63% 69% 41% 0%

ARA Management Categories (acres)

LUD II Priority na 55,975 0 55,975 51,781 0

Watershed Priority na 264,103 31,369 0 0 0

Roadless Priority na 219,003 166,232 376,563 249,741 0

Community Priority na 0 31,369 0 0 0

Timber Priority na 0 0 72,257 0 0

Development Opportunity

Development LUDs (acres) 69,172 85,495 106,250 110,463 290,165 308,076

Timber Opportunity (Acres Suitable for Harvest)

Old-Growth 12,573 16,882 22,489 24,768 25,742 25,746

Young-Growth 16,758 19,674 20,687 20,694 20,840 20,962

Estimated Harvest over 100 Years (acres)

Old-Growth 3,092 3,592 3,842 3,568 3,669 3,669

Young-Growth 14,268 16,203 16,856 16,854 16,887 16,831

na = not applicable
Appendix E

Final EIS E-49 Communities

Not all acres removed from roadless management would be available for development. The change in 

acres in development LUDs serves as a measure of development potential as it presently exists by 

alternative. Approximately 9 percent (69,200 acres) of the Hydaburg CUA is presently managed in 

development LUDs. This total would increase under all action alternatives, with net gains ranging from 

about 16,300 acres (Alternative 2) to 238,900 acres (Alternative 6). 

Suitable old-growth and young-growth acres available for harvest would increase under all action 

alternatives. Estimated net gains in suitable old-growth range from about 4,300 acres (Alternative 2) to 

13,200 acres (Alternatives 5 and 6). Increases in suitable young-growth acres range from about 2,900 

acres (Alternative 2) to 4,200 acres (Alternative 6). 

Total acres harvested are assumed to remain constant across all alternatives. Estimated old-growth harvest 

totals over 100 years in the Hydaburg CUA would be similar under all alternatives, ranging from about 3,100 

acres (Alternative 1) to 3,850 acres (Alternative 3). Estimated young-growth harvest ranges from about 

14,300 acres (Alternative 1) to 16,900 acres (Alternatives 3 to 5) (Table E-39).

Subsistence

No significant effect on salmon, other finfish, or invertebrate habitat capability is expected from 

implementation of any alternative. These resources account for 80 percent of the total edible pounds of 

subsistence resources harvested by Hydaburg households (Kruse and Frazier 1988). Marine resources 

(fish and marine invertebrates) accounted for the majority (81 percent) of per capita subsistence harvest 

in Hydaburg in 2012 (ADF&G 2018). 

The 1988 TRUCS study found that deer accounted for 13 percent of the total edible pounds of 

subsistence resources harvested by Hydaburg households (Kruse and Frazier 1988). Deer accounted for 

13 percent of per capita subsistence harvest by Hydaburg residents in 2012 (ADF&G 2018). 

Hydaburg residents primarily harvest deer on south Prince of Wales Island. Residents of Hydaburg 

harvest the majority (73 percent) of their deer from three WAAs (Table E-40). The Hydaburg portion 

represents about 19 percent of the combined average rural hunter harvest and 11 percent of all harvest in 

these WAAs. About 41 percent of the combined harvest in these WAAs is by non-rural hunters, 

suggesting that there is a harvest buffer that could be restricted, if necessary, before restrictions are 

placed on rural harvests. 

The 2016 Forest Plan Amendment EIS analysis found that only one of the three WAAs would be affected 

under the current Forest Plan (Table E-40). In WAA 1214, where past timber harvest has already reduced 

deer habitat capability well below 1954 levels, additional harvest that could occur under the current Forest 

Plan was estimated to reduce habitat capabilities by a further 6 percent (Table E-40). 

Table E-40

Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where Hydaburg 

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest1

WAA

Average Deer Harvest from 2004 to 2013 Deer Habitat Capability3

Hydaburg 

Residents

All Rural 

Hunters2

All 

Hunters 2014

After 100 Years of 

Implementation Change

1107 34 99 130 99% 99% 0%

1214 6 120 235 77% 71% -6%

1106 4 17 33 100% 100% 0% 1 Calculated based on harvest where location is known. 2 The category “All Rural Hunters” includes residents of Southeast Alaska communities, excluding the cities of Juneau and 

Ketchikan.

3 Deer habitat capability in 2014 and after 100 Years of full implementation is expressed as a percent of the 1954 habitat 

capability. Data presented for 100 Years of Implementation are estimates developed for the current Forest Plan in the 2016 

Forest Plan Amendment EIS (USDA Forest Service 2016).

The 2016 Forest Plan Amendment EIS analysis found that the use of most subsistence resources by 

Hydaburg residents (fish and marine invertebrates) was not expected to be affected under the current 

Forest Plan. Based on the Deer Availability and Anticipated Demand analysis completed for the 1997 
Appendix E

Communities E-50 Final EIS

Forest Plan EIS, the 2016 analysis also found that subsistence use of deer was not likely to be directly 

affected at a level that would require hunting restrictions. Indirect effects associated with increased 

competition for deer within Hydaburg’s subsistence use areas could occur if hunters from other 

communities were displaced due to timber harvest activity. 

Suitable old-growth acres in two of the WAAs important to Hydaburg residents would increase relative to 

Alternative 1 under the action alternatives (Table E-41). Projected old-growth harvest is also expected to 

increase relative to Alternative 1 in one of these WAAs, with decreases anticipated for the other WAA 

(Table E-42). These relative changes in projected harvest are small in absolute terms (i.e., number of 

acres) and none of the alternatives are expected to affect the findings of the 2016 Forest Plan 

Amendment.

Table E-41

Suitable Old-Growth by WAA and Alternative for the WAAs where Hydaburg Residents 

Obtain Approximately 75 Percent of their Average Annual Deer Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

1107 124,050 360 10 80 80 90 90

1214 61,680 3,440 1,910 3,190 3,190 3,190 3,190

1106 7,420 - - - - - -

Table E-42

Projected Old-Growth Harvest by WAA and Alternative for the WAAs where Hydaburg

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

1107 124,050 110 (10) (10) (30) (30) (30)

1214 61,680 1,030 420 420 230 200 200

1106 7,420 - - - - - -

Hyder

Community Use Area

Hyder’s CUA encompasses a total of 108,628 acres (Figure E-11). Most of this area (94 percent) is 

presently managed as roadless (Table E-43). This share would drop to 58 percent under Alternative 5, 

with no acres managed as roadless under Alternative 6. No ARA acres in the Hyder CUA under any 

alternative would be managed as Timber Priority, which allow timber harvest and road building. Areas

allocated to Roadless Priority would explicitly allow the cutting, utilization, customary trade, and removal 

of trees for the purposes of Alaska Native customary and traditional uses, as well as road construction 

deemed necessary by a federally recognized Tribe for access to Alaska Native cultural sites. 
Appendix E

Final EIS E-51 Communities

Figure E-11

Hyder’s Community Use Area

Table E-43

Roadless Areas, ARA Management Categories, and Development Opportunity in 

Hyder's Community Use Area 

Roadless Category 

(acres)

Alternative

1 2 3 4 5 6

Total Community Use Area 108,628 108,628 108,628 108,628 108,628 108,628

Total Roadless Area 102,029 101,897 101,897 101,897 62,788 0

Roadless Share 94% 94% 94% 94% 58% 0%

ARA Management Categories (acres)

LUD II Priority na 0 0 0 0 0

Watershed Priority na 0 0 0 0 0

Roadless Priority na 101,897 101,897 101,897 62,788 0

Community Priority na 0 0 0 0 0

Timber Priority na 0 0 0 0 0

Development Opportunity

Development LUDs (acres) 3,051 3,057 3,057 3,057 10,343 10,485

Timber Opportunity (Acres Suitable for Harvest)

Old-Growth 3 3 3 3 24 24

Young-Growth 174 174 174 174 204 235

Estimated Harvest over 100 Years (acres)

Old-Growth 0 0 0 0 0 0

Young-Growth 149 144 142 142 165 189

na = not applicable

Not all acres removed from roadless management would be available for development. The change in 

acres in development LUDs serves as a measure of development potential as it presently exists by 

alternative. Approximately 3 percent (3,050 acres) of the Hyder CUA is presently managed in 
Appendix E

Communities E-52 Final EIS

development LUDs. This total would increase under Alternatives 5 and 6 by 7,300 acres to 7,450 acres, 

respectively (Table E-13). Very few of the acres included in development LUDs are suitable for harvest 

and timber harvest is not expected to take place in the Hyder CUA under any of the alternatives.

Subsistence

No significant effect on salmon, other finfish, or invertebrate habitat capability is expected from 

implementation of any alternative. These resources account for 80 percent of the total edible pounds of 

subsistence resources harvested by Hyder households (Kruse and Frazier 1988). Marine resources (fish 

and marine invertebrates) accounted for the majority (85 percent) of per capita subsistence in Hyder in 

1987 (ADF&G 2018). 

The 1988 TRUCS study found that deer accounted for only a fraction of the total edible pounds of 

subsistence resources harvested by Hyder households (Kruse and Frazier 1988). Bear, moose, and goat 

made up most of the land mammal subsistence harvest (ADF&G 2018). 

The 2016 Forest Plan Amendment EIS analysis found that bear, moose, and goat availability would not 

be significantly affected under the current Forest Plan. Data were not provided for Hyder in the ADF&G 

deer harvest reports for 2004 to 2013, but the majority of deer harvest by Hyder residents likely takes 

place in GMU 1A. As of 2013, deer numbers were at very low levels throughout most of GMU 1A and 

were no longer meeting local hunter demands or established deer harvest objectives (ADF&G 2015). 

Though not closed, starting in 2011 the deer hunting season was shortened to August 1 through 

November 30 instead of continuing through December. Hunters are known to be shifting efforts to other 

more productive areas, such as nearby GMU 2, leading to less hunter effort and fewer deer harvested in 

GMU 1A (ADF&G 2015). 

The 2016 Forest Plan Amendment EIS analysis found that use of most subsistence resources by Hyder 

residents (fish and marine invertebrates) was not expected to be affected by the current Forest Plan. 

Based on the Deer Availability and Anticipated Demand analysis completed for the 1997 Forest Plan EIS, 

the 2016 analysis found that subsistence use of deer was unlikely to be affected by the current Forest 

Plan; however, further hunting restrictions are possible due to existing conditions. The 2016 analysis also 

found that it was unlikely that Hyder residents would be affected by increased competition in WAA 826, 

which surrounds their community, because of the limited access to this area and current low deer 

numbers. None of the alternatives are expected to affect the findings of the 2016 Forest Plan 

Amendment.

Juneau (Dzántik’I Héeni)

Community Use Area

Juneau’s CUA encompasses a total of 2,029,329 acres (Figure E-12). Most of this area (81 percent) is

presently managed as roadless (Table E-44). This share would decrease to 71 percent under Alternative 

5, with no acres managed as roadless under Alternative 6. The removal of LUD II acres under Alternative 

3 accounts for all of the decrease in roadless acres under this alternative. These areas would retain their 

congressional protections and continue to be managed in a roadless state. Alternative 4 includes ARA

acres that would be managed as Timber Priority and allow timber harvest and road building. Timber 

Priority acres account for 1 percent of the ARA in the Juneau CUA. Areas allocated to Roadless Priority 

and Community Priority would explicitly allow the cutting, utilization, customary trade, and removal of 

trees for the purposes of Alaska Native customary and traditional uses, as well as road construction 

deemed necessary by a federally recognized Tribe for access to Alaska Native cultural sites. This type of 

use would also be allowed in Timber Priority areas, which allow all timber harvest and road construction.
Appendix E

Final EIS E-53 Communities

Figure E-12

Juneau’s Community Use Area

Table E-44

Roadless Areas, ARA Management Categories, and Development Opportunity in 

Juneau's Community Use Area

Roadless Category (acres)

Alternative

1 2 3 4 5 6

Total Community Use Area 2,029,329 2,029,329 2,029,329 2,029,329 2,029,329 2,029,329

Total Roadless Area 1,634,246 1,634,489 1,589,799 1,631,245 

1,446,811 0

Roadless Share 81% 81% 78% 80% 71% 0%

ARA Management Categories (acres)

LUD II Priority na 44,690 0 44,690 44,594 0

Watershed Priority na 489,310 77,991 0 0 0

Roadless Priority na 1,100,489 1,022,498 1,572,538 1,402,217 0

Community Priority na 0 77,991 0 0 0

Timber Priority na 0 0 14,016 0 0

Development Opportunity

Development LUDs (acres) 6,028 6,916 6,916 6,916 135,364 150,281

Timber Opportunity (Acres Suitable for Harvest)

Old-Growth 34 53 53 74 132 132

Young-Growth 719 727 727 733 967 1,128

Estimated Harvest over 100 Years (acres)

Old-Growth 0 0 0 0 0 0

Young-Growth 612 599 593 597 784 906

na = not applicable
Appendix E

Communities E-54 Final EIS

Not all acres removed from roadless management would be available for development. The change in 

acres in development LUDs serves as a measure of development potential as it presently exists by 

alternative. Less than 1 percent (6,000 acres) of the Juneau CUA is presently managed in development 

LUDs. This total would increase substantially under Alternatives 5 and 6 with respective increases of 

about 129,300 acres and 144,250 acres. There are, however, very limited suitable old-growth and younggrowth acres available for harvest in the Juneau CUA, with very little variation across alternatives. No oldgrowth and very limited young-growth harvest is estimated under any of the alternatives (Table E-44).

Subsistence

Juneau is not classified as a subsistence community; however, many residents use the surrounding 

Tongass National Forest for sport hunting and fishing. The City and Borough of Juneau had a total 

estimated population of 31,986 in 2019, accounting for approximately 44 percent of the population in 

Southeast Alaska (Alaska DOL 2019). Given the non-subsistence status of the community and its large 

size, no attempt is made here to summarize the WAAs that community residents use to hunt deer. 

However, the majority of deer harvest by Juneau residents likely takes place within the community’s 

identified use area (Figure E-12), which is mainly located within GMU 1C. 

The 2016 Forest Plan Amendment EIS analysis found use of most subsistence resources by Juneau

residents (fish and marine invertebrates) was not expected to be affected by the current Forest Plan. 

Based on the Deer Availability and Anticipated Demand analysis completed for the 1997 Forest Plan EIS, 

the 2016 analysis found that there should be sufficient habitat capability for deer hunted by all rural 

hunters in the short and long terms. However, with the addition of Juneau residents and other non-rural 

hunters, demand would likely exceed the capability of the habitat to produce deer populations sufficient to 

avoid effects on hunter success in both the short and long terms. The Final EIS analysis concluded that at 

some point a restriction in hunting might be necessary and would target urban residents before any 

restrictions were considered for rural hunters. None of the alternatives evaluated in this EIS are expected 

to affect the findings of the 2016 Forest Plan Amendment.

Kake (Kéex’)

Community Use Area

Kake’s CUA encompasses a total of 450,413 acres (Figure E-13). About half of this area (54 percent) is 

presently managed as roadless (Table E-45). This proportion of roadless area decreases to 33 percent 

under Alternative 5, with no acres managed as roadless under Alternative 6. Alternative 4 includes ARA

acres that would be managed as Timber Priority and allow timber harvest and road building. Timber 

Priority acres account for 21 percent of the ARA in the Kake CUA. Areas allocated to Roadless Priority 

would explicitly allow the cutting, utilization, customary trade, and removal of trees for the purposes of 

Alaska Native customary and traditional uses, as well as road construction deemed necessary by a 

federally recognized tribe for access to Alaska Native cultural sites. This type of use would also be 

allowed in Timber Priority areas, which allow all timber harvest and road construction.
Appendix E

Final EIS E-55 Communities

Figure E-13

Kake’s Community Use Area

Table E-45

Roadless Areas, ARA Management Categories, and Development Opportunity in Kake's 

Community Use Area

Roadless Category 

(acres)

Alternative

1 2 3 4 5 6

Total Community Use Area 450,413 450,413 450,413 450,413 450,413 450,413

Total Roadless Area 241,879 238,794 229,926 224,259 149,318 0

Roadless Share 54% 53% 51% 50% 33% 0%

ARA Management Categories (acres)

LUD II Priority na 1 0 1 1 0

Watershed Priority na 119,628 90,952 0 0 0

Roadless Priority na 119,165 19,345 176,468 149,317 0

Community Priority na 0 90,952 0 0 0

Timber Priority na 0 0 47,790 0 0

Development Opportunity

Development LUDs (acres) 82,811 87,007 91,905 95,428 174,154 174,164

Timber Opportunity (Acres Suitable for Harvest)

Old-Growth 13,190 14,171 22,014 23,963 23,964 23,964

Young-Growth 21,524 22,229 22,324 22,298 22,234 22,377

Estimated Harvest over 100 Years (acres)

Old-Growth 2,879 2,679 2,980 2,937 2,883 2,883

Young-Growth 18,326 18,308 18,190 18,161 18,089 17,967

na = not applicable
Appendix E

Communities E-56 Final EIS

Not all acres removed from roadless management would be available for development. The change in 

acres in development LUDs serves as a measure of development potential as it presently exists by 

alternative. Approximately 18 percent (82,800 acres) of the Kake CUA is presently managed in 

development LUDs. This total would increase under all action alternatives, with net gains ranging from 

about 4,200 acres (Alternative 2) to 91,350 acres (Alternatives 5 and 6). 

Suitable old-growth and young-growth acres available for harvest would increase under all action 

alternatives. Estimated net gains in suitable old-growth range from about 1,000 acres (Alternative 2) to 

10,800 acres (Alternatives 4 to 6). Increases in suitable young-growth acres range from about 700 acres 

(Alternative 2) to 850 acres (Alternative 6). 

Total acres harvested are assumed to remain constant across all alternatives. Estimated old-growth harvest 

totals over 100 years in the Kake CUA are less than 3,000 acres under all alternatives, with very little variation 

by alternative. Estimated young-growth harvest is also very similar across all alternatives, ranging from about 

18,000 acres (Alternative 6) to 18,300 acres (Alternatives 1 and 2) (Table E-45).

Subsistence

No significant effect on salmon, other finfish, or invertebrate habitat capability is expected from 

implementation of any alternative. These resources account for 52 percent of the total edible pounds of 

subsistence resources harvested by Kake households (Kruse and Frazier 1988). Marine resources (fish 

and marine invertebrates) accounted for 60 percent of per capita subsistence harvest in Kake in 1996 

(ADF&G 2018). 

The 1988 TRUCS study found that deer accounted for 24 percent of the total edible pounds of 

subsistence resources harvested by Kake households (Kruse and Frazier 1988). Deer accounted for 28 

percent of per capita subsistence harvest by Kake residents in 1996 (ADF&G 2018). 

Five WAAs account for the majority (76 percent) of deer harvest by Kake residents (Table E-46). The 

Kake share ranges from about 11 percent (WAA 1420) to 60 percent (WAA 5132) of the total harvest and 

from 19 percent to 68 percent of the rural hunter harvest in these WAAs. About 35 percent of the 

combined harvest in these WAAs is by non-rural hunters, suggesting that there is a harvest buffer that 

could be restricted, if necessary, before restrictions are placed on rural harvests. 

The 2016 Forest Plan Amendment EIS analysis found that four out of the five WAAs heavily used by 

Kake residents would not be affected under the current Forest Plan. For the other WAA (WAA 1420), the 

2016 analysis estimated that deer habitat capability, which is currently at less than half of 1954 levels, 

would be further reduced by an estimated 5 percent (Table E-46).

Table E-46

Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where Kake 

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest1

WAA

Average Deer Harvest from 2004 to 2013 Deer Habitat Capability3

Kake 

Residents

All Rural 

Hunters2

All 

Hunters 2014

After 100 Years of 

Implementation Change

1420 30 158 276 49% 44% -5%

3940 26 61 75 93% 93% 0%

3939 19 71 105 100% 100% 0%

4041 5 16 19 91% 91% 0%

5132 5 7 8 70% 70% 0% 1 Calculated based on harvest where location is known. 2 The category “All Rural Hunters” includes residents of Southeast Alaska communities, excluding the cities of Juneau and 

Ketchikan.

3 Deer habitat capability in 2014 and after 100 Years of full implementation is expressed as a percent of the 1954 habitat 

capability. Data presented for 100 Years of Implementation are estimates developed for the current Forest Plan in the 2016 

Forest Plan Amendment EIS (USDA Forest Service 2016).

The 2016 Forest Plan Amendment EIS analysis found that use of most subsistence resources by Kake

residents (fish and marine invertebrates) was not expected to be affected under the current Forest Plan. 
Appendix E

Final EIS E-57 Communities

Based on the Deer Availability and Anticipated Demand analysis completed for the 1997 Forest Plan EIS, 

the 2016 analysis found that subsistence use of deer in one of the WAAs hunted by Kake residents may 

be affected to the point that some restriction in hunting might be necessary over the long term, particularly 

for non-rural hunters. The risk of hunting restrictions would be reduced somewhat, through more intensive 

management (e.g., thinning) of the existing and future closed-canopy, young-growth forests in this area. 

Indirect effects associated with increased competition for deer within Kake’s subsistence use areas could 

also occur if hunters from other communities were displaced due to timber harvest activity. Such impacts 

would be relatively low based on the limited accessibility of these areas to non-local hunters. 

There are no suitable old-growth acres in three of the five WAAs heavily used by Kake residents under 

any of the alternatives. Suitable old-growth acres in the other two WAAs would increase relative to 

Alternative 1 under the action alternatives (Table E-47). Projected old-growth harvest is also expected to 

increase relative to Alternative 1 in one of these WAAs (5132), with decreases generally anticipated for 

the other one (WAA 1420) (Table E-48). These relative changes in projected harvest are small in 

absolute terms (i.e., number of acres) and none of the alternatives are expected to affect the findings of 

the 2016 Forest Plan Amendment.

Table E-47

Suitable Old-Growth by WAA and Alternative for the WAAs where Kake Residents 

Obtain Approximately 75 Percent of their Average Annual Deer Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

1420 42,410 3,210 230 390 500 500 500

3940 68,160 - - - - - -

3939 66,460 - - - - - -

4041 55,260 - - - - - -

5132 37,010 1,150 10 1,010 1,010 1,010 1,010

Table E-48

Projected Old-Growth Harvest by WAA and Alternative for the WAAs where Kake

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

1420 42,410 960 (30) (170) (260) (270) (270)

3940 68,160 - - - - - -

3939 66,460 - - - - - -

4041 55,260 - - - - - -

5132 37,010 340 (30) 130 70 60 60

Kasaan

Community Use Area

Kasaan’s CUA encompasses a total of 523,709 acres (Figure E-14). More than three-quarters of this area 

(79 percent) is presently managed as roadless (Table E-49). This share would decrease under all action 

alternatives, dropping to 39 percent under Alternative 5, with no acres managed as roadless under 

Alternative 6. Alternative 4 includes ARA acres that would be managed as Timber Priority and allow 

timber harvest and road building. Timber Priority acres account for 16 percent of the ARA in the Kasaan

CUA. Areas allocated to Roadless Priority would explicitly allow the cutting, utilization, customary trade, 

and removal of trees for the purposes of Alaska Native customary and traditional uses, as well as road 

construction deemed necessary by a federally recognized Tribe for access to Alaska Native cultural sites. 

This type of use would also be allowed in Timber Priority areas, which allow all timber harvest and road 

construction.
Appendix E

Communities E-58 Final EIS

Figure E-14

Kasaan’s Community Use Area

Table E-49

Roadless Areas, ARA Management Categories, and Development Opportunity in 

Kasaan's Community Use Area

Roadless Category (acres)

Alternative

1 2 3 4 5 6

Total Community Use Area 523,709 523,709 523,709 523,709 523,709 523,709

Total Roadless Area 413,187 391,608 367,105 364,378 202,290 0

Roadless Share 79% 75% 70% 70% 39% 0%

ARA Management Categories (acres)

LUD II Priority na 19 0 19 19 0

Watershed Priority na 210,088 17,343 0 0 0

Roadless Priority na 181,501 140,373 305,061 202,271 0

Community Priority na 0 17,343 0 0 0

Timber Priority na 0 0 59,298 0 0

Development Opportunity

Development LUDs (acres) 56,154 75,529 98,307 98,316 238,375 244,314

Timber Opportunity (Acres Suitable for Harvest)

Old-Growth 11,957 16,034 20,664 22,819 23,771 23,771

Young-Growth 15,072 18,004 19,044 19,050 19,123 19,346

Estimated Harvest over 100 Years (acres)

Old-Growth 3,008 3,509 3,651 3,403 3,503 3,503

Young-Growth 12,833 14,828 15,517 15,515 15,495 15,534

na = not applicable
Appendix E

Final EIS E-59 Communities

Not all acres removed from roadless management would be available for development. The change in 

acres in development LUDs serves as a measure of development potential as it presently exists by 

alternative. Approximately 11 percent (56,150 acres) of the Kasaan CUA is presently managed in 

development LUDs. This total would increase under all action alternatives, with net gains ranging from 

about 19,400 acres (Alternative 2) to 188,200 acres (Alternative 6).

Suitable old-growth and young-growth acres available for harvest would increase under all action 

alternatives. Estimated net gains in suitable old-growth range from about 4,100 acres (Alternative 2) to 

11,800 acres (Alternatives 5 and 6). Increases in suitable young-growth acres range from about 2,900 

acres (Alternative 2) to 4,300 acres (Alternative 6), representing a 19 to 28 percent increase relative to 

Alternative 1. 

Total acres harvested are assumed to remain constant across all alternatives. Estimated old-growth 

harvest totals over 100 years in the Kasaan CUA would be similar under all alternatives, ranging from 

3,000 acres (Alternative 1) to 3,500 acres (Alternatives 5 and 6). Young-growth harvest estimates range 

from about 12,800 acres (Alternative 1) to 15,500 acres (Alternatives 3 to 6) (Table E-49). 

Subsistence

No significant effect on salmon, other finfish, or invertebrate habitat capability is expected from 

implementation of any alternative. These resources account for 74 percent of the total edible pounds of 

subsistence resources harvested by Kasaan households (Kruse and Frazier 1988) and 75 percent of per 

capita harvest in 1998 (ADF&G 2018). 

The 1988 TRUCS survey found that deer account for 22 percent of the total edible pounds of subsistence 

resources harvested by Kasaan households (Kruse and Frazier 1988). Deer accounted for 15 percent of 

per capita subsistence harvest by Kasaan residents in 1998 (ADF&G 2018). 

The majority of deer harvest by Kasaan residents takes place near the community on north Prince of 

Wales Island. Residents of Kasaan harvest the majority (87 percent) of their deer from two WAAs (Table 

E-50). The Kasaan portion makes up 2 percent of the total combined harvest and 4 percent of the rural 

hunter harvest in these WAAs. About 42 percent of the combined harvest in these WAA is by non-rural 

hunters, suggesting that there is a harvest buffer that could be restricted, if necessary, before restrictions 

are placed on rural harvests. 

Table E-50

Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where Kasaan 

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest1

WAA

Average Deer Harvest from 2004 to 2013 Deer Habitat Capability3

Kasaan 

Residents

All Rural 

Hunters2

All 

Hunters 2014

After 100 Years of 

Implementation Change

1315 9 201 317 56% 50% -6%

1214 4 120 235 77% 71% -6% 1 Calculated based on harvest where location is known. 2 The category “All Rural Hunters” includes residents of Southeast Alaska communities, excluding the cities of Juneau and 

Ketchikan.

3 Deer habitat capability in 2014 and after 100 Years of full implementation is expressed as a percent of the 1954 habitat 

capability. Data presented for 100 Years of Implementation are estimates developed for the current Forest Plan in the 2016 

Forest Plan Amendment EIS (USDA Forest Service 2016).

Both WAAs are in areas with substantial past timber harvest and, therefore, deer habitat capabilities are 

currently estimated to be considerably below 1954 levels. The 2016 Forest Plan Amendment EIS analysis 

found that additional harvest that could occur under the current Forest Plan would further reduce 

estimated habitat capabilities after 100 years by 6 percent in both areas (Table E-50). 

The 2016 Forest Plan Amendment EIS analysis found that use of most subsistence resources by Kasaan 

residents (fish and marine invertebrates) was not expected to be affected by any of the alternatives. 

Based on the Deer Availability and Anticipated Demand analysis completed for the 1997 Forest Plan EIS, 

the 2016 analysis found that subsistence use of deer may be affected to the point that some restriction in 
Appendix E

Communities E-60 Final EIS

hunting might be necessary over the long term, especially for non-rural hunters. Kasaan is currently 

competing with other communities in their subsistence use areas and this is likely to continue to be the 

case. The risk of hunting restrictions would be reduced somewhat, through more intensive management 

(e.g., thinning) of the existing and future closed-canopy, young-growth forests in this area. Indirect effects 

associated with increased competition for deer within Kasaan’s subsistence use areas could also occur if 

hunters from other communities were displaced due to timber harvest activity. 

Suitable old-growth acres would increase relative to Alternative 1 in both WAAs under all of the action 

alternatives (Table E-51). Projected old-growth harvest is also expected to increase relative to Alternative 

1 in one of these WAAs (1214), with relative decreases anticipated for the other WAA (1315) (Table 

E-52). These relative changes in projected harvest are small in absolute terms (i.e., number of acres) and 

none of the alternatives are expected to affect the findings of the 2016 Forest Plan Amendment.

Table E-51

Suitable Old-Growth by WAA and Alternative for the WAAs where Kasaan Residents 

Obtain Approximately 75 Percent of their Average Annual Deer Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

1315 55,040 3,820 230 1,240 1,240 1,240 1,240

1214 61,680 3,440 1,910 3,190 3,190 3,190 3,190

Table E-52

Projected Old-Growth Harvest by WAA and Alternative for the WAAs where Kasaan

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

1315 55,040 1,140 (40) (30) (180) (200) (200)

1214 61,680 1,030 420 420 230 200 200

Ketchikan (Kicháan)

Community Use Area

Ketchikan’s CUA encompasses a total of 1,968,512 acres (Figure E-15). Almost half of this area (48

percent) is presently managed as roadless (Table E-53). This share would decrease to 32 percent under 

Alternative 5, with no acres managed as roadless under Alternative 6. The removal of LUD II acres under 

Alternative 3 accounts for approximately 39 percent of the decrease in roadless acres under this 

alternative. These areas would retain their congressional protections and continue to be managed in a 

roadless state. Alternative 4 includes ARA acres that would be managed as Timber Priority and allow 

timber harvest and road building. Timber Priority acres account for 13 percent of the ARA in the 

Ketchikan CUA. Areas allocated to Roadless Priority and Community Priority would explicitly allow the 

cutting, utilization, customary trade, and removal of trees for the purposes of Alaska Native customary 

and traditional uses, as well as road construction deemed necessary by a federally recognized Tribe for 

access to Alaska Native cultural sites. This type of use would also be allowed in Timber Priority areas, 

which allow all timber harvest and road construction.
Appendix E

Final EIS E-61 Communities

Figure E-15

Ketchikan’s Community Use Area

Table E-53

Roadless Areas, ARA Management Categories, and Development Opportunity in 

Ketchikan's Community Use Area

Roadless Category 

(acres)

Alternative

1 2 3 4 5 6

Total Community Use Area 1,968,512 1,968,512 1,968,512 1,968,512 1,968,512 1,968,512

Total Roadless Area 951,613 938,575 870,794 897,258 629,605 0

Roadless Share 48% 48% 44% 46% 32% 0%

ARA Management Categories (acres)

LUD II Priority na 31,386 0 31,386 31,384 0

Watershed Priority na 494,679 58,585 0 0 0

Roadless Priority na 412,511 317,685 753,390 598,221 0

Community Priority na 0 58,585 0 0 0

Timber Priority na 0 0 112,482 0 0

Development Opportunity

Development LUDs (acres) 115,243 127,745 160,833 160,844 413,413 413,416

Timber Opportunity (Acres Suitable for Harvest)

Old-Growth 29,744 33,535 45,566 55,120 56,219 56,220

Young-Growth 32,823 34,341 34,760 34,649 35,101 35,454

Estimated Harvest over 100 Years (acres)

Old-Growth 7,080 7,335 7,510 7,959 7,957 7,957

Young-Growth 27,946 28,283 28,322 28,220 28,442 28,467

na = not applicable
Appendix E

Communities E-62 Final EIS

Not all acres removed from roadless management would be available for development. The change in 

acres in development LUDs serves as a measure of development potential as it presently exists by 

alternative. Approximately 6 percent (115,250 acres) of the Ketchikan CUA is presently managed in 

development LUDs. This total would increase under all action alternatives, with net gains ranging from 

about 12,500 acres (Alternative 2) to 298,200 acres (Alternatives 5 and 6). 

Suitable old-growth and young-growth acres available for harvest would increase under all action 

alternatives. Estimated net gains in suitable old-growth range from about 3,800 acres (Alternative 2) to 

26,500 acres (Alternatives 5 and 6). Increases in suitable young-growth acres range from about 1,500 

acres (Alternative 2) to 2,600 acres (Alternative 6).

Total acres harvested are assumed to remain constant across all alternatives. Estimated old-growth harvest 

totals over 100 years in the Ketchikan CUA range from about 7,100 acres (Alternative 1) to 7,950 acres 

(Alternatives 4 to 6). Estimated young-growth totals range from about 27,950 acres (Alternative 1) to about 

28,450 acres (Alternatives 5 and 6) (Table E-53). 

Subsistence

Ketchikan is not classified as a subsistence community; however, many residents use the surrounding 

Tongass National Forest for hunting and fishing. Given the non-subsistence status of the community and 

its large size, no attempt is made here to summarize the WAAs that community residents use to hunt 

deer. However, the majority of deer harvest by Ketchikan residents likely takes place within the 

community’s identified use area (Figure E-15), which is mainly located within GMU 1A and GMU 2. 

The 2016 Forest Plan Amendment EIS analysis found use of most subsistence resources by Ketchikan 

residents (fish and marine invertebrates) was not expected to be affected by the current Forest Plan. 

Based on the Deer Availability and Anticipated Demand analysis completed for the 1997 Forest Plan EIS, 

the 2016 analysis found that there should be sufficient habitat capability for deer hunted by all hunters in 

the short term. However, projected deer harvest in the long term by Ketchikan residents, all rural hunters,

and all hunters exceeded the level that is both sustainable and provides a reasonably high level of hunter 

success for their effort. The Final EIS analysis concluded that if a restriction were necessary, sport 

hunting by Ketchikan residents would be restricted before subsistence hunting by rural hunters is 

restricted. None of the alternatives are expected to affect the findings of the 2016 Forest Plan 

Amendment.

Klawock (Lawáak)

Community Use Area

Klawock’s CUA encompasses a total of 733,670 acres (Figure E-16). More than half of this area (57

percent) is presently managed as roadless (Table E-54). This share would drop to 33 percent under 

Alternatives 3 and 5, with no acres managed as roadless under Alternative 6. The removal of LUD II 

acres under Alternative 3 accounts for approximately 55 percent of the decrease in roadless acres under 

this alternative. These areas would retain their congressional protections and continue to be managed in 

a roadless state. Alternative 4 includes ARA acres that would be managed as Timber Priority and allow 

timber harvest and road building. Timber Priority acres account for 12 percent of the ARA in the Klawock 

CUA. Areas allocated to Roadless Priority would explicitly allow the cutting, utilization, customary trade, 

and removal of trees for the purposes of Alaska Native customary and traditional uses, as well as road 

construction deemed necessary by a federally recognized Tribe for access to Alaska Native cultural sites. 

This type of use would also be allowed in Timber Priority areas, which allow all timber harvest and road 

construction.
Appendix E

Final EIS E-63 Communities

Figure E-16

Klawock’s Community Use Area

Table E-54

Roadless Areas, ARA Management Categories, and Development Opportunity in 

Klawock's Community Use Area 

Roadless Category (acres

Alternative

1 2 3 4 5 6

Total Community Use Area 733,670 733,670 733,670 733,670 733,670 733,670

Total Roadless Area 418,413 396,858 239,678 330,167 240,160 0

Roadless Share 57% 54% 33% 45% 33% 0

ARA Management Categories (acres)

LUD II Priority na 99,731 0 99,731 98,201 0

Watershed Priority na 132,064 29,012 0 0 0

Roadless Priority na 165,063 80,188 192,343 141,960 0

Community Priority na 0 29,012 0 0 0

Timber Priority na 0 0 38,093 0 0

Development Opportunity

Development LUDs (acres) 204,185 225,706 276,493 280,712 375,588 381,527

Timber Opportunity (Acres Suitable for Harvest)

Old-Growth 40,738 46,824 60,255 64,177 65,495 65,495

Young-Growth 72,268 75,911 76,953 76,940 76,995 77,119

Estimated Harvest over 100 Years (acres)

Old-Growth 9,263 9,435 9,613 8,691 8,712 8,712

Young-Growth 61,531 62,519 62,701 62,665 62,388 61,922

na = not applicable
Appendix E

Communities E-64 Final EIS

Not all acres removed from roadless management would be available for development. The change in 

acres in development LUDs serves as a measure of development potential as it presently exists by 

alternative. Approximately 28 percent (204,200 acres) of the Klawock CUA is presently managed in 

development LUDs. This total would increase under all action alternatives, with net gains ranging from 

about 21,500 acres (Alternative 2) to 177,350 acres (Alternative 6). 

Suitable old-growth and young-growth acres available for harvest would increase under all action 

alternatives. Estimated net gains in suitable old-growth range from about 6,100 acres (Alternative 2) to 

24,800 acres (Alternatives 5 and 6). Increases in suitable young-growth acres range from about 3,600 

acres (Alternative 2) to 4,850 acres (Alternative 6). 

Total acres harvested are assumed to remain constant across all alternatives. Estimated old-growth harvest 

totals over 100 years in the Klawock CUA would be similar under all alternatives, ranging from about 8,700 

acres (Alternatives 4 to 6) to 9,600 acres (Alternative 3). This would also be the case with young-growth 

acres, which are estimated to range from about 61,500 acres (Alternative 1) to 62,700 acres (Alternatives 3 

and 4) (Table E-54). 

Subsistence

No significant effect on salmon, other finfish, or invertebrate habitat capability is expected from 

implementation of any alternative. These resources account for 75 percent of the total edible pounds of 

subsistence resources harvested by Klawock households (Kruse and Frazier 1988). Marine resources 

(fish and marine invertebrates) accounted for 71 percent of per capita subsistence harvest in Klawock in 

1997 (ADF&G 2018). 

The 1988 TRUCS study found that deer accounted for 19 percent of the total edible pounds of 

subsistence resources harvested by Klawock households (Kruse and Frazier 1988). Deer accounted for 

15 percent of per capita subsistence harvest by Klawock residents in 1997 (ADF&G 2018). 

Klawock residents mainly harvest deer on north Prince of Wales Island, with the majority (74 percent) of 

their deer obtained from eight WAAs (Table E-55). The Klawock portion represents from about 5 percent 

(WAA 1420) to 34 percent (WAA 1318) of the total harvest and about 9 percent to 42 percent of the rural 

hunter harvest in these WAAs. About 34 percent of the combined harvest in these WAAs is by non-rural 

hunters, suggesting that there is a limited harvest buffer that could be restricted, if necessary, before 

restrictions are placed on rural harvests. 

Table E-55

Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where Klawock 

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest1

WAA

Average Deer Harvest from 2004 to 2013 Deer Habitat Capability3

Klawock 

Residents

All Rural 

Hunters2

All 

Hunters 2014

After 100 Years of 

Implementation Change

1318 67 159 198 90% 84% -6%

1422 65 247 383 57% 50% -7%

1319 28 169 226 74% 69% -5%

1214 26 120 235 77% 71% -6%

1107 22 99 130 99% 99% 0%

1315 21 201 317 56% 50% -6%

1317 19 93 133 58% 56% -2%

1420 15 158 276 49% 44% -5% 1 Calculated based on harvest where location is known. 2 The category “All Rural Hunters” includes residents of Southeast Alaska communities, excluding the cities of Juneau and 

Ketchikan.

3 Deer habitat capability in 2014 and after 100 Years of full implementation is expressed as a percent of the 1954 habitat 

capability. Data presented for 100 Years of Implementation are estimates developed for the current Forest Plan in the 2016

Forest Plan Amendment EIS (USDA Forest Service 2016).

Most of the WAAs identified in Table E-55 occur in areas with substantial past harvest and, therefore, 

deer habitat capabilities are currently estimated to be below 1954 levels. The 2016 Forest Plan 
Appendix E

Final EIS E-65 Communities

Amendment EIS analysis found that additional harvest that could occur under the current Forest Plan 

would further reduce estimated habitat capabilities after 100 years in all of the WAAs except for one 

(WAA 1107) by 2 to 7 percent (Table E-55). 

The 2016 Forest Plan Amendment EIS analysis found that use of most subsistence resources by 

Klawock residents (fish and marine invertebrates) was not expected to be affected by the current Forest 

Plan. Based on the Deer Availability and Anticipated Demand analysis completed for the 1997 Forest 

Plan EIS, the 2016 analysis found that subsistence use of deer may be affected to the point that some 

restriction in hunting might be necessary, especially for non-rural hunters. The risk of hunting restrictions 

would be reduced somewhat, through more intensive management (e.g., thinning) of the existing and 

future closed-canopy, young-growth forests in this area. Indirect effects associated with increased 

competition for deer within the Klawock subsistence use areas could also occur if hunters from other 

communities were displaced due to timber harvest activity. 

Suitable old-growth acres would increase relative to Alternative 1 in all eight WAAs under all of the action 

alternatives, with increases tending to be larger under Alternatives 4 to 6 (Table E-56). Projected oldgrowth harvest would increase in three of the WAAs under most alternatives and decrease in the other 

five (Table E-57). These relative changes in projected harvest are small in absolute terms (i.e., number of 

acres) and none of the alternatives are expected to affect the findings of the 2016 Forest Plan 

Amendment.

Table E-56

Suitable Old-Growth by WAA and Alternative for the WAAs where Klawock Residents 

Obtain Approximately 75 Percent of their Average Annual Deer Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

1318 53,710 1,300 140 1,310 1,410 1,410 1,410

1422 120,280 10,120 350 3,770 3,900 3,900 3,900

1319 103,210 3,250 170 570 600 600 600

1214 61,680 3,440 1,910 3,190 3,190 3,190 3,190

1107 124,050 360 10 80 80 90 90

1315 55,040 3,820 230 1,240 1,240 1,240 1,240

1317 57,220 2,460 730 2,190 2,510 3,380 3,380

1420 42,410 3,210 230 390 500 500 500

Table E-57

Projected Old-Growth Harvest by WAA and Alternative for the WAAs where Klawock

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

1318 53,710 390 - 180 120 110 110

1422 120,280 3,020 (180) 20 (360) (410) (410)

1319 103,210 970 (40) (130) (240) (250) (250)

1214 61,680 1,030 420 420 230 200 200

1107 124,050 110 (10) (10) (30) (30) (30)

1315 55,040 1,140 (40) (30) (180) (200) (200)

1317 57,220 730 130 290 210 360 360

1420 42,410 960 (30) (170) (260) (270) (270)
Appendix E

Communities E-66 Final EIS

Metlakatla

Community Use Area

Metlakatla’s CUA encompasses a total of 1,968,512 acres (Figure E-17). Almost half of this area (48

percent) is presently managed as roadless (Table E-58). This share would drop to 32 percent under 

Alternative 5, with no acres managed as roadless under Alternative 6. The removal of LUD II acres under 

Alternative 3 accounts for approximately 39 percent of the decrease in roadless acres under this 

alternative. These areas would retain their congressional protections and continue to be managed in a 

roadless state. Alternative 4 includes ARA acres that would be managed as Timber Priority and allow 

timber harvest and road building. Timber Priority acres account for 13 percent of the ARA in the 

Metlakatla CUA. Areas allocated to Roadless Priority and Community Priority would explicitly allow the 

cutting, utilization, customary trade, and removal of trees for the purposes of Alaska Native customary 

and traditional uses, as well as road construction deemed necessary by a federally recognized Tribe for 

access to Alaska Native cultural sites. This type of use would also be allowed in Timber Priority areas, 

which allow all timber harvest and road construction.

Figure E-17

Metlakatla’s Community Use Area
Appendix E

Final EIS E-67 Communities

Table E-58

Roadless Areas, ARA Management Categories, and Development Opportunity in 

Metlakatla's Community Use Area 

Roadless Category 

(acres)

Alternative

1 2 3 4 5 6

Total Community Use Area 1,968,512 1,968,512 1,968,512 1,968,512 1,968,512 1,968,512

Total Roadless Area 951,613 938,575 870,794 897,258 629,605 0

Roadless Share 48% 48% 44% 46% 32% 0%

ARA Management Categories (acres)

LUD II Priority na 31,386 0 31,386 31,384 0

Watershed Priority na 494,679 58,585 0 0 0

Roadless Priority na 412,511 317,685 753,390 598,221 0

Community Priority na 0 58,585 0 0 0

Timber Priority na 0 0 112,482 0 0

Development Opportunity

Development LUDs (acres) 115,243 127,745 160,833 160,844 413,413 413,416

Timber Opportunity (Acres Suitable for Harvest)

Old-Growth 29,744 33,535 45,566 55,120 56,219 56,220

Young-Growth 32,823 34,341 34,760 34,649 35,101 35,454

Estimated Harvest over 100 Years (acres)

Old-Growth 7,080 7,335 7,510 7,959 7,957 7,957

Young-Growth 27,946 28,283 28,322 28,220 28,442 28,467

na = not applicable

Not all acres removed from roadless management would be available for development. The change in 

acres in development LUDs serves as a measure of development potential as it presently exists by 

alternative. Approximately 6 percent (115,250 acres) of the Metlakatla CUA is presently managed in 

development LUDs. This total would increase under all action alternatives, with net gains ranging from 

about 12,500 acres (Alternative 2) to 298,200 acres (Alternatives 5 and 6). 

Suitable old-growth and young-growth acres available for harvest would increase under all action 

alternatives. Estimated net gains in suitable old-growth range from about 3,800 acres (Alternative 2) to 

26,500 acres (Alternatives 5 and 6). Increases in suitable young-growth acres range from about 1,500 

acres (Alternative 2) to 2,600 acres (Alternative 6).

Total acres harvested are assumed to remain constant across all alternatives. Estimated old-growth harvest 

totals over 100 years in the Metlakatla CUA range from about 7,100 acres (Alternative 2) to 7,950 acres 

(Alternatives 4 to 6). Estimated young-growth acres range from about 27,950 acres (Alternative 1) to 28,450 

acres (Alternatives 5 and 6) (Table E-58). 

Subsistence

No significant effect on salmon, other finfish, or invertebrate habitat capability is expected from 

implementation of any alternative. These resources account for 75 percent of the total edible pounds of 

subsistence resources harvested by Metlakatla households (Kruse and Frazier 1988). 

The 1988 TRUCS study found that deer account for 15 percent of the total edible pounds of subsistence 

resources harvested by Metlakatla households (Kruse and Frazier 1988). 

The majority (72 percent) of deer harvest by Metlakatla residents takes place in ten WAAs (Table E-59). 

Metlakatla residents account for 1 percent (WAA 1315) to 100 percent (WAAs 0405 and 0406) of the rural 

harvest in these WAAs, and 1 percent (WAAs 1214 and 1315) to 15 percent (WAA 0405) of all harvest. 

About 39 percent of the combined harvest in these WAAs is by non-rural hunters, suggesting that there is 

a harvest buffer that could be restricted, if necessary, before restrictions are placed on rural harvests.
Appendix E

Communities E-68 Final EIS

Table E-59

Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where 

Metlakatla Residents Obtain Approximately 75 Percent of their Average Annual Deer 

Harvest1

WAA

Average Deer Harvest from 2004 to 2013 Deer Habitat Capability3

Metlakatla 

Residents

All Rural 

Hunters2 All Hunters 2014

After 100 Years of 

Implementation Change

1107 8 99 130 99% 99% 0%

1318 7 159 198 90% 84% -6%

1422 6 247 383 57% 50% -7%

405 4 4 25 89% 86% -3%

1214 3 120 235 77% 71% -6%

1421 3 76 102 68% 64% -4%

1315 3 201 317 56% 50% -6%

1210 2 4 31 100% 100% 0%

406 2 2 55 76% 71% -5%

509 2 2 19 95% 93% -2% 1 Calculated based on harvest where location is known. 2 The category “All Rural Hunters” includes residents of Southeast Alaska communities, excluding the cities of Juneau and 

Ketchikan.

3 Deer habitat capability in 2014 and after 100 Years of full implementation is expressed as a percent of the 1954 habitat 

capability. Data presented for 100 Years of Implementation are estimates developed for the current Forest Plan in the 2016 

Forest Plan Amendment EIS (USDA Forest Service 2016).

The WAAs used by Metlakatla residents occur in areas that have been affected to variable degrees by 

past timber harvest and, therefore, deer habitat capabilities are currently estimated at 56 to 100 percent 

of 1954 levels (Table E-59). The 2016 Forest Plan Amendment EIS analysis found that two of the 10 

WAAs (1107 and 1210) used most by Metlakatla residents would not be affected under the current Forest 

Plan (Table E-59). In the remaining eight WAAs, additional harvest that could occur under the current 

Forest Plan was estimated to further reduce habitat capabilities after 100 years by 2 to 7 percent (Table 

E-59). 

The 2016 Forest Plan Amendment EIS analysis found it likely that the current Forest Plan would provide 

sufficient habitat capability for deer hunted by Metlakatla residents, all rural hunters, and all hunters in this 

area over the course of Forest Plan implementation. Suitable old-growth acres are expected to increase 

relative to Alternative 1 under the action alternatives in nine of the 10 WAAs (Table E-60). Projected oldgrowth harvest would increase in four of the WAAs under most alternatives and decrease in the other five 

(Table E-61). These relative changes in projected harvest are small in absolute terms (i.e., number of 

acres) and none of the alternatives are expected to affect the findings of the 2016 Forest Plan 

Amendment.

Table E-60

Suitable Old-Growth by WAA and Alternative for the WAAs where Metlakatla Residents 

Obtain Approximately 75 Percent of their Average Annual Deer Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

1107 124,050 360 10 80 80 90 90

1318 53,710 1,300 140 1,310 1,410 1,410 1,410

1422 120,280 10,120 350 3,770 3,900 3,900 3,900

405 53,400 1,790 170 690 690 690 690

1214 61,680 3,440 1,910 3,190 3,190 3,190 3,190

1421 90,040 2,510 - - 40 110 110

1315 55,040 3,820 230 1,240 1,240 1,240 1,240

1210 86,080 - - - - - -

406 124,730 6,940 2,670 4,830 7,150 7,150 7,150

509 64,970 690 30 280 480 610 610
Appendix E

Final EIS E-69 Communities

Table E-61

Projected Old-Growth Harvest by WAA and Alternative for the WAAs where Metlakatla

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

1107 124,050 110 (10) (10) (30) (30) (30)

1318 53,710 390 - 180 120 110 110

1422 120,280 3,020 (180) 20 (360) (410) (410)

405 53,400 530 - 10 (60) (70) (70)

1214 61,680 1,030 420 420 230 200 200

1421 90,040 750 (70) (200) (270) (260) (260)

1315 55,040 1,140 (40) (30) (180) (200) (200)

1210 86,080 - - - - - -

406 124,730 2,070 530 510 600 550 550

509 64,970 210 (20) - 10 30 30

Naukati Bay

Community Use Area

Naukati Bay’s CUA encompasses a total of 1,076,081 acres (Figure E-18). Half of this area (50 percent) 

is presently managed as roadless (Table E-62). This share would drop to 25 and 34 percent under 

Alternatives 3 and 5, respectively, with no acres managed as roadless under Alternative 6. The removal 

of LUD II acres under Alternative 3 accounts for approximately 71 percent of the decrease in roadless 

acres under this alternative. These areas would retain their congressional protections and continue to be 

managed in a roadless state. Alternative 4 includes ARA acres that would be managed as Timber Priority 

and allow timber harvest and road building. Timber Priority acres account for 8 percent of the ARA in the 

Naukati Bay CUA. Areas allocated to Roadless Priority would explicitly allow the cutting, utilization, 

customary trade, and removal of trees for the purposes of Alaska Native customary and traditional uses, 

as well as road construction deemed necessary by a federally recognized Tribe for access to Alaska 

Native cultural sites. This type of use would also be allowed in Timber Priority areas, which allow all 

timber harvest and road construction.
Appendix E

Communities E-70 Final EIS

Figure E-18

Naukati Bay’s Community Use Area

Table E-62

Roadless Areas, ARA Management Categories, and Development Opportunity in Naukati 

Bay's Community Use Area

Roadless Category (acres)

Alternative

1 2 3 4 5 6

Total Community Use Area 1,076,081 1,076,081 1,076,081 1,076,081 1,076,081 1,076,081

Total Roadless Area 536,424 523,599 268,357 456,204 369,090 0

Roadless Share 50% 49% 25% 42% 34% 0%

ARA Management Categories (acres)

LUD II Priority na 193,281 0 193,281 191,422 0

Watershed Priority na 169,537 6,833 0 0 0

Roadless Priority na 160,781 94,236 225,814 177,668 0

Community Priority na 0 6,833 0 0 0

Timber Priority na 0 0 37,109 0 0

Development Opportunity

Development LUDs (acres) 327,102 340,027 388,390 388,717 484,222 484,229

Timber Opportunity (Acres Suitable for Harvest)

Old-Growth 62,595 65,978 78,593 84,592 85,555 85,555

Young-Growth 127,013 128,256 128,312 128,367 128,398 128,654

Estimated Harvest over 100 Years (acres)

Old-Growth 13,480 12,748 11,837 11,038 10,957 10,957

Young-Growth 108,142 105,630 104,548 104,550 104,040 103,301

na = not applicable
Appendix E

Final EIS E-71 Communities

Not all acres removed from roadless management would be available for development. The change in 

acres in development LUDs serves as a measure of development potential as it presently exists by 

alternative. Approximately 30 percent (327,100 acres) of the Naukati Bay CUA is presently managed in 

development LUDs. This total would increase under all action alternatives, with net gains ranging from 

about 12,900 acres (Alternative 2) to 157,100 acres (Alternatives 5 and 6). 

Suitable old-growth and young-growth acres available for harvest would increase under all action 

alternatives. Estimated net gains in suitable old-growth range from about 3,400 acres (Alternative 2) to 

23,000 acres (Alternatives 5 and 6). Suitable young-growth acres would increase by about 1 percent 

under all of the action alternatives.

Total acres harvested are assumed to remain constant across all alternatives. Estimated old-growth harvest 

totals in the Naukati Bay CUA over 100 years are expected to drop under all of the action alternatives, with 

decreases ranging from about 750 acres (Alternative 2) to about 2,500 acres (Alternatives 5 and 6). This 

would also be the case with estimated young-growth harvest, with decreases estimated to range from about 

2,500 acres (Alternative 2) to 4,850 acres (Alternative 6) (Table E-62). 

Subsistence

No significant effect on salmon, other finfish, or invertebrate habitat capability is expected from 

implementation of any alternative. Marine resources (fish and marine invertebrates) accounted for 73 

percent of per capita subsistence harvest in Naukati Bay in 1998, with deer making up 19 percent of the 

per capita total (ADF&G 2018). 

Residents of Naukati Bay harvest the majority (73 percent) of their deer from three WAAs on north Prince 

of Wales Island (1422, 1531, and 1529). As shown in Table E-63, the Naukati Bay share ranges from 2

percent to 21 percent of the total harvest and from 4 percent to 37 percent of the rural hunter harvest in 

these WAAs. About 40 percent of the combined harvest in these WAAs is by non-rural hunters, 

suggesting that there is a harvest buffer that could be restricted, if necessary, before restrictions are 

placed on rural harvests.

Table E-63

Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where Naukati 

Bay Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest1

WAA

Average Deer Harvest from 2004 to 2013 Deer Habitat Capability3

Naukati Bay 

Residents

All Rural 

Hunters2

All 

Hunters 2014

After 100 Years of 

Implementation Change

1422 30 247 383 57% 50% -7%

1531 8 22 39 64% 63% -1%

1529 3 77 154 68% 66% -2% 1 Calculated based on harvest where location is known. 2 The category “All Rural Hunters” includes residents of Southeast Alaska communities, excluding the cities of Juneau and 

Ketchikan.

3 Deer habitat capability in 2014 and after 100 Years of full implementation is expressed as a percent of the 1954 habitat 

capability. Data presented for 100 Years of Implementation are estimates developed for the current Forest Plan in the 2016 

Forest Plan Amendment EIS (USDA Forest Service 2016).

The three WAAs heavily used by Naukati Bay residents occur in an area with substantial past harvest 

and, therefore, deer habitat capabilities are currently estimated to be considerably below 1954 levels 

(Table E-63). The 2016 Forest Plan Amendment EIS analysis found that additional harvest that could

occur under the current Forest Plan would reduce estimated habitat capabilities after 100 years by a 

further 1 to 7 percent (Table E-63). 

The 2016 Forest Plan Amendment EIS analysis found that use of most subsistence resources by Naukati 

Bay residents (fish and marine invertebrates) was not expected to be affected by the current Forest Plan. 

Based on the Deer Availability and Anticipated Demand analysis completed for the 1997 Forest Plan EIS, 

the 2016 analysis found that subsistence use of deer may be affected to the point that some restriction in 

hunting might be necessary over the long term, especially for non-rural hunters. The risk of hunting 

restrictions would be reduced somewhat, through more intensive management (e.g., thinning) of the 
Appendix E

Communities E-72 Final EIS

existing and future closed-canopy, young-growth forests in this area. Indirect effects associated with 

increased competition for deer within Naukati Bay’s subsistence use areas could also occur if hunters 

from other communities were displaced due to timber harvest activity. 

Suitable old-growth acres would increase relative to Alternative 1 in two of the three WAAs under all of 

the action alternatives (Table E-64). Projected old-growth harvest would, however, decrease in all three of 

the WAAs under most alternatives (Table E-65). These relative changes in projected harvest are small in 

absolute terms (i.e., number of acres) and none of the alternatives are expected to affect the findings of 

the 2016 Forest Plan Amendment EIS.

Table E-64

Suitable Old-Growth by WAA and Alternative for the WAAs where Naukati Bay

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

1422 120,280 10,120 350 3,770 3,900 3,900 3,900

1531 20,540 1,390 - - - - -

1529 67,930 7,610 110 210 3,680 4,250 4,250

Table E-65

Projected Old-Growth Harvest by WAA and Alternative for the WAAs where Naukati 

Bay Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

1422 120,280 3,020 (180) 20 (360) (410) (410)

1531 20,540 420 (40) (120) (160) (160) (160)

1529 67,930 2,270 (180) (560) (130) (70) (70)

Pelican

Community Use Area

Pelican’s CUA encompasses a total of 489,587 acres (Figure E-19). Almost half of this area (49 percent) 

is presently managed as roadless (Table E-66). This share would drop to 13 percent under Alternative 3, 

with no acres managed as roadless under Alternative 6. The removal of LUD II acres under Alternative 3 

accounts for the entire decrease in roadless acres under this alternative. These areas would retain their 

congressional protections and continue to be managed in a roadless state. Alternative 4 includes ARA

acres that would be managed as Timber Priority and allow timber harvest and road building. Timber 

Priority acres account for 1 percent of the ARA in the Pelican CUA. Areas allocated to Roadless Priority 

would explicitly allow the cutting, utilization, customary trade, and removal of trees for the purposes of 

Alaska Native customary and traditional uses, as well as road construction deemed necessary by a 

federally recognized Tribe for access to Alaska Native cultural sites. This type of use would also be 

allowed in Timber Priority areas, which allow all timber harvest and road construction.

Not all acres removed from roadless management would be available for development. The change in 

acres in development LUDs serves as a measure of development potential as it presently exists by 

alternative. None of the Pelican CUA is presently managed in a development LUD. There would be no 

change under Alternatives 2 to 4. Under Alternatives 5 and 6, approximately 2,900 acres would be 

managed as development LUDs (Table E-66). 

There would be no suitable old-growth acres for harvest under any alternative, and no young-growth 

suitable acres for harvest under all alternatives except for Alternative 6, which would have less than 50 

acres considered suitable under the current 2016 Forest Plan. No timber harvest is expected to occur in 

the Pelican CUA (Table E-66). 
Appendix E

Final EIS E-73 Communities

Figure E-19

Pelican’s Community Use Area

Table E-66

Roadless Areas, ARA Management Categories, and Development Opportunity in 

Pelican's Community Use Area

Roadless Category (acres)

Alternative

1 2 3 4 5 6

Total Community Use Area 489,587 489,587 489,587 489,587 489,587 489,587

Total Roadless Area 242,256 242,624 63,545 242,350 234,588 0

Roadless Share 49% 50% 13% 50% 48% 0%

ARA Management Categories (acres)

LUD II Priority na 179,078 0 179,078 178,891 0

Watershed Priority na 20,908 0 0 0 0

Roadless Priority na 42,637 42,637 60,424 55,697 0

Community Priority na 0 0 0 0 0

Timber Priority na 0 0 2,848 0 0

Development Opportunity

Development LUDs (acres) 0 0 0 0 2,855 2,855

Timber Opportunity (Acres Suitable for Harvest)

Old-Growth 0 0 0 0 0 0

Young-Growth 0 0 0 0 0 34

Estimated Harvest over 100 Years (acres)

Old-Growth 0 0 0 0 0 0

Young-Growth 0 0 0 0 0 27

na = not applicable
Appendix E

Communities E-74 Final EIS

Subsistence

No significant effect on salmon, other finfish, or invertebrate habitat capability is expected from 

implementation of any alternative. These resources account for 63 percent of the total edible pounds of 

subsistence resources harvested by Pelican households (Kruse and Frazier 1988). 

The 1988 TRUCS study found that deer account for 30 percent of the total edible pounds of subsistence 

resources harvested by Pelican households (Kruse and Frazier 1988). 

Pelican residents take the majority (94 percent) of their deer from three WAAs on northwestern Chichagof 

Island where deer habitat capability is estimated to be the same as in 1954 (Table E-67). The 2016 

Forest Plan Amendment EIS analysis found that none of these WAAs would be affected under the current 

Forest Plan and there would be no effects to subsistence deer harvest in these areas. This would also be 

the case under all of the alternatives, with no suitable old-growth acres or projected harvest anticipated in 

these WAAs (Tables E-68 and E-69).

Table E-67

Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where Pelican 

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest1

WAA

Average Deer Harvest from 2004 to 2013 Deer Habitat Capability3

Pelican 

Residents

All Rural 

Hunters2

All 

Hunters 2014

After 100 Years of 

Implementation Change

3419 20 23 40 100% 100% 0%

3418 13 18 26 100% 100% 0%

3417 6 60 115 100% 100% 0% 1 Calculated based on harvest where location is known. 2 The category “All Rural Hunters” includes residents of Southeast Alaska communities, excluding the cities of Juneau and 

Ketchikan.

3 Deer habitat capability in 2014 and after 100 Years of full implementation is expressed as a percent of the 1954 habitat 

capability. Data presented for 100 Years of Implementation are estimates developed for the current Forest Plan in the 2016 

Forest Plan Amendment EIS (USDA Forest Service 2016).

Table E-68

Suitable Old-Growth by WAA and Alternative for the WAAs where Pelican Residents 

Obtain Approximately 75 Percent of their Average Annual Deer Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

3419 84,930 - - - - - -

3418 53,510 - - - - - -

3417 134,230 - - - - - -

Table E-69

Projected Old-Growth Harvest by WAA and Alternative for the WAAs where Pelican

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

3419 84,930 - - - - - -

3418 53,510 - - - - - -

3417 134,230 - - - - - -
Appendix E

Final EIS E-75 Communities

Petersburg (Gánti Yaaks Séedi) and Kupreanof

Community Use Area

Petersburg’s CUA encompasses a total of 744,245 acres (Figure E-20). About half of this area (51

percent) is presently managed as roadless (Table E-70). This share would drop to 27 percent under 

Alternative 5, with no acres managed as roadless under Alternative 6. Alternative 4 includes ARA acres 

that would be managed as Timber Priority and allow timber harvest and road building. Timber Priority 

acres account for 22 percent of the ARA in the Petersburg CUA. Areas allocated to Roadless Priority 

would explicitly allow the cutting, utilization, customary trade, and removal of trees for the purposes of 

Alaska Native customary and traditional uses, as well as road construction deemed necessary by a 

federally recognized Tribe for access to Alaska Native cultural sites. This type of use would also be 

allowed in Timber Priority areas, which allow all timber harvest and road construction.

Figure E-20

Petersburg’s Community Use Area
Appendix E

Communities E-76 Final EIS

Table E-70

Roadless Areas, ARA Management Categories, and Development Opportunity in 

Petersburg's Community Use Area

Roadless Category (acres)

Alternative

1 2 3 4 5 6

Total Community Use Area 744,245 744,245 744,245 744,245 744,245 744,245

Total Roadless Area 376,088 358,646 314,109 311,947 198,234 0

Roadless Share 51% 48% 42% 42% 27% 0%

ARA Management Categories (acres)

LUD II Priority na 0 0 0 0 0

Watershed Priority na 102,707 33,081 0 0 0

Roadless Priority na 255,939 178,320 243,875 198,234 0

Community Priority na 0 33,081 0 0 0

Timber Priority na 0 0 68,072 0 0

Development Opportunity

Development LUDs (acres) 109,829 127,063 163,835 164,230 285,390 285,394

Timber Opportunity (Acres Suitable for Harvest)

Old-Growth 26,982 33,049 44,562 53,757 54,423 54,424

Young-Growth 23,143 24,899 24,941 24,936 25,026 25,103

Estimated Harvest over 100 Years (acres)

Old-Growth 6,406 7,164 7,715 8,038 8,004 8,004

Young-Growth 19,705 20,506 20,322 20,310 20,279 20,156

na = not applicable

Not all acres removed from roadless management would be available for development. The change in 

acres in development LUDs serves as a measure of development potential as it presently exists by 

alternative. Approximately 15 percent (109,800 acres) of the Petersburg CUA is presently managed in 

development LUDs. This total would increase under all action alternatives, with net gains ranging from 

about 17,200 acres (Alternative 2) to 175,600 acres (Alternatives 5 and 6). 

Suitable old-growth and young-growth acres available for harvest would increase under all action 

alternatives. Estimated net gains in suitable old-growth range from about 6,100 acres (Alternative 2) to 

27,450 acres (Alternatives 5 and 6). Increases in suitable young-growth acres would be approximately 8 

percent of the existing total under all action alternatives.

Total acres harvested are assumed to remain constant across all alternatives. Estimated old-growth harvest 

totals in the Petersburg CUA over 100 years range from about 6,400 acres (Alternative 1) to about 8,000 

acres (Alternatives 4 to 6). Young-growth harvest is estimated to range from about 19,700 acres (Alternative 

1) to 20,500 acres (Alternative 2) (Table E-70). 

Subsistence

No significant effect on salmon, other finfish, or invertebrate habitat capability is expected from 

implementation of any alternative. These resources account for 52 percent of the total edible pounds of 

subsistence resources harvested by Petersburg households (Kruse and Frazier 1988). Marine resources 

(fish and marine invertebrates) accounted for 86 percent of per capita subsistence harvest in Petersburg 

in 2000 (ADF&G 2018). 

The 1988 TRUCS study found that deer accounted for 21 percent of the total edible pounds of 

subsistence resources harvested by Petersburg households (Kruse and Frazier 1988). Deer accounted 

for 11 percent of per capita subsistence harvest by Petersburg residents in 1987 (ADF&G 2018). 

Seventeen WAAs account for the majority (74 percent) of deer harvest by Petersburg residents. As 

shown in Table E-71, the Petersburg portion ranges from 2 to 100 percent of all hunters and 4 to 100 

percent of all rural hunters in these WAAs and represents the majority or all of rural hunter deer harvest in 

12 of the 17 WAAs. About 30 percent of the combined harvest in these WAAs is by non-rural hunters, 

suggesting that there is a limited harvest buffer that could be restricted, if necessary, before restrictions 

are placed on rural harvests.
Appendix E

Final EIS E-77 Communities

Table E-71

Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where 

Petersburg and Kupreanof Residents Obtain Approximately 75 Percent of their 

Average Annual Deer Harvest1

WAA

Average Deer Harvest from 2004 to 2013 Deer Habitat Capability3

Petersburg 

Residents

All Rural 

Hunters2

All 

Hunters 2014

After 100 Years of 

Implementation Change

5138 56 56 61 80% 72% -8%

2007 43 44 46 75% 71% -4%

3939 42 71 105 100% 100% 0%

3938 30 41 75 100% 100% 0%

3940 30 61 75 93% 93% 0%

1605 24 24 27 77% 74% -3%

1603 18 21 25 94% 94% 0%

1528 18 30 36 78% 78% 0%

1905 16 190 204 73% 67% -6%

1706 14 14 15 100% 100% 0%

1530 12 57 124 61% 57% -4%

1529 10 77 154 68% 66% -2%

5134 9 10 13 89% 89% 0%

5136 9 9 9 84% 77% -7%

1420 7 158 276 49% 44% -5%

5137 7 7 7 100% 100% 0%

5133 6 6 6 98% 98% 0% 1 Calculated based on harvest where location is known. 2 The category “All Rural Hunters” includes residents of Southeast Alaska communities, excluding the cities of Juneau and 

Ketchikan.

3 Deer habitat capability in 2014 and after 100 Years of full implementation is expressed as a percent of the 1954 habitat 

capability. Data presented for 100 Years of Implementation are estimates developed for the current Forest Plan in the 2016 

Forest Plan Amendment EIS (USDA Forest Service 2016).

The 2016 Forest Plan Amendment EIS analysis found that there would be no effect to deer habitat 

capability in nine of the 17 WAAs under the current Forest Plan. In the remaining eight WAAs, all of which 

currently have deer habitat capability below 1954 levels due to prior timber harvest, the 2016 analysis 

estimated that deer habitat capability could be further reduced by 1 to 8 percent (Table E-71). 

The 2016 Forest Plan Amendment EIS analysis found that use of most subsistence resources by 

Petersburg residents (fish and marine invertebrates) was not expected to be affected by any of the 

alternatives. Based on the Deer Availability and Anticipated Demand analysis completed for the 1997 

Forest Plan EIS, the 2016 analysis found that subsistence use of deer in some of the WAAs hunted by 

Petersburg residents may be affected to the point that some restriction in hunting might be necessary

over the long term, especially for non-rural hunters. The risk of hunting restrictions would be reduced 

somewhat, through more intensive management (e.g., thinning) of the existing and future closed-canopy, 

young-growth forests in this area. Indirect effects associated with increased competition for deer within 

Petersburg’s subsistence use areas could also occur if hunters from other communities were displaced 

due to timber harvest activity. 

Suitable old-growth acres would increase relative to Alternative 1 under all of the action alternatives in the 

eight WAAs that were identified as potentially affected in the 2016 Forest Plan Amendment EIS, with 

minor increases also estimated for two other WAAs (Table E-72). Projected old-growth harvest was 

estimated to decrease relative to Alternative 1 in five WAAs under most alternatives, with relative 

increases projected in three others (Table E-73). These relative changes in projected harvest are small in 

absolute terms (i.e., number of acres) and none of the alternatives are expected to affect the findings of 

the 2016 Forest Plan Amendment EIS.
Appendix E

Communities E-78 Final EIS

Table E-72

Suitable Old-Growth by WAA and Alternative for the WAAs where Petersburg and 

Kupreanof Residents Obtain Approximately 75 Percent of their Average Annual Deer 

Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

5138 61,680 3,130 2,150 4,240 6,040 6,390 6,390

2007 109,300 12,020 10 1,150 2,460 2,620 2,620

3939 66,460 - - - - - -

3938 76,970 - - - - - -

3940 68,160 - - - - - -

1605 149,230 2,070 110 2,370 5,440 5,440 5,440

1603 78,380 - - - - - -

1528 24,750 10 - 10 10 10 10

1905 116,400 8,960 910 1,060 3,570 3,660 3,660

1706 98,870 - - - - - -

1530 59,420 4,250 170 330 330 330 330

1529 67,930 7,610 110 210 3,680 4,250 4,250

5134 102,060 - - - - - -

5136 59,910 4,230 1,080 3,160 4,200 4,290 4,290

1420 42,410 3,210 230 390 500 500 500

5137 50,820 - 10 20 30 30 30

5133 108,180 - - - - - -

Table E-73

Projected Old-Growth Harvest by WAA and Alternative for the WAAs where Petersburg

and Kupreanof Residents Obtain Approximately 75 Percent of their Average Annual 

Deer Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

5138 61,680 930 500 690 810 840 840

2007 109,300 3,590 (330) (710) (850) (870) (870)

3939 66,460 - - - - - -

3938 76,970 - - - - - -

3940 68,160 - - - - - -

1605 149,230 620 (30) 350 800 780 780

1603 78,380 - - - - - -

1528 24,750 - - - - - -

1905 116,400 2,670 - (480) (300) (320) (320)

1706 98,870 - - - - - -

1530 59,420 1,270 (70) (270) (400) (420) (420)

1529 67,930 2,270 (180) (560) (130) (70) (70)

5134 102,060 - - - - - -

5136 59,910 1,260 180 360 340 320 320

1420 42,410 960 (30) (170) (260) (270) (270)

5137 50,820 - - 10 - 10 10

5133 108,180 - - - - - -

Point Baker

Community Use Area

Point Baker’s CUA encompasses a total of 805,913 acres (Figure E-21). About half of this area (51

percent) is presently managed as roadless (Table E-74). This share would drop to 25 and 39 percent 

under Alternatives 3 and 5, respectively, with no acres managed as roadless under Alternative 6. The 
Appendix E

Final EIS E-79 Communities

removal of LUD II acres under Alternative 3 accounts for approximately 83 percent of the decrease in 

roadless acres under this alternative. These areas would retain their congressional protections and

continue to be managed in a roadless state. Alternative 4 includes ARA acres that would be managed as 

Timber Priority and allow timber harvest and road building. Timber Priority acres account for 7 percent of 

the ARA in the Point Baker CUA. Areas allocated to Roadless Priority would explicitly allow the cutting, 

utilization, customary trade, and removal of trees for the purposes of Alaska Native customary and 

traditional uses, as well as road construction deemed necessary by a federally recognized Tribe for 

access to Alaska Native cultural sites. This type of use would also be allowed in Timber Priority areas, 

which allow all timber harvest and road construction.

Figure E-21

Point Baker’s Community Use Area
Appendix E

Communities E-80 Final EIS

Table E-74

Roadless Areas, ARA Management Categories, and Development Opportunity in Point 

Baker's Community Use Area

Roadless Category (acres)

Alternative

1 2 3 4 5 6

Total Community Use Area 805,913 805,913 805,913 805,913 805,913 805,913

Total Roadless Area 414,878 420,428 205,310 368,674 313,422 0

Roadless Share 51% 52% 25% 46% 39% 0%

ARA Management Categories (acres)

LUD II Priority na 176,847 0 176,847 174,800 0

Watershed Priority na 90,101 0 0 0 0

Roadless Priority na 153,480 117,306 166,021 138,622 0

Community Priority na 0 0 0 0 0

Timber Priority na 0 0 25,806 0 0

Development Opportunity

Development LUDs (acres) 212,385 213,558 244,918 252,485 312,447 312,448

Timber Opportunity (Acres Suitable for Harvest)

Old-Growth 38,867 40,834 48,775 54,162 54,774 54,774

Young-Growth 82,427 83,070 83,097 83,217 83,223 83,332

Estimated Harvest over 100 Years (acres)

Old-Growth 9,274 8,723 7,979 7,651 7,618 7,618

Young-Growth 70,180 68,416 67,706 67,777 67,435 66,911

na = not applicable

Not all acres removed from roadless management would be available for development. The change in 

acres in development LUDs serves as a measure of development potential as it presently exists by 

alternative. Approximately 26 percent (212,400 acres) of the Point Baker CUA is presently managed in 

development LUDs. This total would increase under all action alternatives, with net gains ranging from 

about 1,200 acres (Alternative 2) to 100,100 acres (Alternatives 5 and 6). 

Suitable old-growth and young-growth acres available for harvest would increase under all action 

alternatives. Estimated net gains in suitable old-growth range from about 2,000 acres (Alternative 2) to 

15,900 acres (Alternatives 5 and 6). Increases in suitable young-growth acres would be about 1 percent

of the existing total under all action alternatives.

Total acres harvested are assumed to remain constant across all alternatives. Estimated old-growth harvest 

totals over 100 years in the Point Baker CUA range from about 7,600 acres (Alternatives 5 and 6) to 9,300 

acres (Alternative 1). Estimated young-growth harvest ranges from about 66,900 acres (Alternative 6) to 

70,200 acres (Alternative 1) (Table E-74). 

Subsistence

No significant effect on salmon, other finfish, or invertebrate habitat capability is expected from 

implementation of any alternative. These resources account for 59 percent of the total edible pounds of 

subsistence resources harvested by Point Baker households (Kruse and Frazier 1988). Marine resources 

(fish and marine invertebrates) accounted for 79 percent of per capita subsistence harvest in Point Baker 

in 1996 (ADF&G 2018). 

The 1988 TRUCS study found that deer account for 27 percent of the total edible pounds of subsistence 

resources harvested by Point Baker households (Kruse and Frazier 1988). Deer accounted for 16 percent 

of per capita subsistence harvest by Point Baker residents in 1996 (ADF&G 2018). 

Residents of Point Baker harvest the majority (69 percent) of their deer from two WAAs, 1529 and 1527. 

As shown in Table E-75, the Point Baker portion is about 6 percent of the total combined harvest and 12 

percent of the rural hunter harvest in these WAAs. About 48 percent of the combined harvest in these 

WAAs is by non-rural hunters, suggesting that there is a harvest buffer that could be restricted, if 

necessary, before restrictions are placed on rural harvests.
Appendix E

Final EIS E-81 Communities

Table E-75

Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where Point Baker 

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest1

WAA

Average Deer Harvest from 2004 to 20132 Deer Habitat Capability4

Point Baker 

Residents

All Rural 

Hunters3

All 

Hunters 2014

After 100 Years of 

Implementation Change

1529 10 77 154 68% 66% -2%

1527 1 17 27 72% 70% -2% 1 Calculated based on harvest where location is known. 2 Data was not available for Point Baker residents for the 2011 to 2013 hunting seasons.

3

The category “All Rural Hunters” includes residents of Southeast Alaska communities, excluding the cities of Juneau and 

Ketchikan.

4 Deer habitat capability in 2014 and after 100 Years of full implementation is expressed as a percent of the 1954 habitat 

capability. Data presented for 100 Years of Implementation are estimates developed for the current Forest Plan in the 2016 

Forest Plan Amendment EIS (USDA Forest Service 2016).

Both WAAs used most by Point Baker residents occur in an area with substantial past timber harvest and, 

therefore, deer habitat capabilities are currently estimated to be below 1954 levels. The 2016 Forest Plan 

Amendment EIS analysis found that additional harvest that could occur under the current Forest Plan 

would reduce estimated habitat capabilities after 100 years by a further 1 to 4 percent (Table E-75). 

The 2016 Forest Plan Amendment EIS analysis found that use of most subsistence resources by Point 

Baker residents (fish and marine invertebrates) was not expected to be affected under the current Forest 

Pan. Based on the Deer Availability and Anticipated Demand analysis completed for the 1997 Forest Plan 

EIS, the 2016 analysis found that subsistence use of deer on Prince of Wales Island may be affected to 

the point that some restriction in hunting might be necessary over the long term, especially for non-rural 

hunters. The risk of hunting restrictions would be reduced somewhat, through more intensive 

management (e.g., thinning) of the existing and future closed-canopy, young-growth forests in this area. 

Indirect effects associated with increased competition for deer within Point Baker’s subsistence use areas 

on Prince of Wales Island could also occur if hunters from other communities were displaced due to 

timber harvest activity. 

Suitable old-growth acres would increase relative to Alternative 1 in both WAAs under all of the action 

alternatives, with larger increases in WAA 1529 expected under Alternatives 4 to 6 (Table E-76). 

Projected old-growth harvest would, however, decrease in both of these WAAs under most alternatives 

(Table E-77). These relative changes in projected harvest are small in absolute terms (i.e., number of 

acres) and none of the alternatives are expected to affect the findings of the 2016 Forest Plan 

Amendment EIS.

Table E-76

Suitable Old-Growth by WAA and Alternative for the WAAs where Point Baker

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

1529 67,930 7,610 110 210 3,680 4,250 4,250

1527 33,730 2,100 350 350 590 590 590

Table E-77

Projected Old-Growth Harvest by WAA and Alternative for the WAAs where Point Baker

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

1529 67,930 2,270 (180) (560) (130) (70) (70)

1527 33,730 630 30 (90) (120) (130) (130)
Appendix E

Communities E-82 Final EIS

Port Alexander

Community Use Area

Port Alexander’s CUA encompasses a total of 86,850 acres (Figure E-22). More than three-quarters of 

this area (79 percent) is presently managed as roadless (Table E-78). This share would stay the same 

under each alternative except for Alternative 6, where no acres would be managed as roadless. No ARA

acres in the Port Alexander CUA would be managed under any alternative as Timber Priority, which allow 

timber harvest and road building. Areas allocated to Roadless Priority would explicitly allow the cutting, 

utilization, customary trade, and removal of trees for the purposes of Alaska Native customary and 

traditional uses, as well as road construction deemed necessary by a federally recognized Tribe for 

access to Alaska Native cultural sites. 

There are no acres in development LUDs in the Port Alexander CUA under any of the alternatives and no 

acres suitable for harvest, with no estimated harvest over the next 100 years.

Figure E-22

Port Alexander’s Community Use Area
Appendix E

Final EIS E-83 Communities

Table E-78

Roadless Areas, ARA Management Categories, and Development Opportunity in Port 

Alexander's Community Use Area 

Roadless Category (acres)

Alternative

1 2 3 4 5 6

Total Community Use Area 86,850 86,850 86,850 86,850 86,850 86,850

Total Roadless Area 68,884 68,905 68,905 68,884 68,884 0

Roadless Share 79% 79% 79% 79% 79% 0%

ARA Management Categories (acres)

LUD II Priority na 0 0 0 0 0

Watershed Priority na 0 0 0 0 0

Roadless Priority na 68,905 68,905 68,884 68,884 0

Community Priority na 0 0 0 0 0

Timber Priority na 0 0 0 0 0

Development Opportunity

Development LUDs (acres) 0 0 0 0 0 0

Timber Opportunity (Acres Suitable for Harvest)

Old-Growth 0 0 0 0 0 0

Young-Growth 0 0 0 0 0 0

Estimated Harvest over 100 Years (acres)

Old-Growth 0 0 0 0 0 0

Young-Growth 0 0 0 0 0 0

na = not applicable

Subsistence

No significant effect on salmon, other finfish, or invertebrate habitat capability is expected from 

implementation of any alternative. These resources account for 55 percent of the total edible pounds of 

subsistence resources harvested by Port Alexander households (Kruse and Frazier 1988). Deer account 

for 36 percent of the total edible pounds of subsistence resources harvested by Port Alexander households 

(Kruse and Frazier 1988). 

Port Alexander residents take the majority (71 percent) of their deer from one WAA (3734) on the south 

end of Baranof Island where deer habitat capability is estimated to be the same as in 1954 (Table E-79). 

The 2016 Forest Plan Amendment EIS analysis found that this WAA would not be affected under the 

current Forest Plan and there would be no effects to subsistence deer harvest in this area. This would 

also be the case under all of the alternatives, with no suitable old-growth acres or projected harvest 

anticipated in WAA 3734 (Tables E-80 and E-81).

Table E-79

Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where Port 

Alexander Residents Obtain Approximately 75 Percent of their Average Annual Deer 

Harvest1

WAA

Average Deer Harvest from 2004 to 2013 Deer Habitat Capability3

Port 

Alexander 

Residents

All Rural 

Hunters2 All Hunters 2014

After 100 Years of 

Implementation Change

3734 26 59 66 100% 100% 0% 1 Calculated based on harvest where location is known. 2 The category “All Rural Hunters” includes residents of Southeast Alaska communities, excluding the cities of Juneau and 

Ketchikan.

3 Deer habitat capability in 2014 and after 100 Years of full implementation is expressed as a percent of the 1954 habitat 

capability. Data presented for 100 Years of Implementation are estimates developed for the current Forest Plan in the 2016 

Forest Plan Amendment EIS (USDA Forest Service 2016).
Appendix E

Communities E-84 Final EIS

Table E-80

Suitable Old-Growth by WAA and Alternative for the WAAs where Port Alexander

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

3734 - - - - - -

Table E-81

Projected Old-Growth Harvest by WAA and Alternative for the WAAs where Port 

Alexander Residents Obtain Approximately 75 Percent of their Average Annual Deer 

Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

3734 126,070 - - - - - -

Port Protection

Community Use Area

Port Protection’s CUA encompasses a total of 673,746 acres (Figure E-23). About half of this area (54

percent) is presently managed as roadless (Table E-82). This share would drop to 23 and 39 percent 

under Alternatives 3 and 5, respectively, with no acres managed as roadless under Alternative 6. The 

removal of LUD II acres under Alternative 3 accounts for approximately 81 percent of the decrease in 

roadless acres under this alternative. These areas would retain their congressional protections and 

continue to be managed in a roadless state. Alternative 4 includes ARA acres that would be managed as 

Timber Priority and allow timber harvest and road building. Timber Priority acres account for 13 percent of 

the ARA in the Port Protection CUA. Areas allocated to Roadless Priority would explicitly allow the cutting, 

utilization, customary trade, and removal of trees for the purposes of Alaska Native customary and 

traditional uses, as well as road construction deemed necessary by a federally recognized Tribe for 

access to Alaska Native cultural sites. This type of use would also be allowed in Timber Priority areas, 

which allow all timber harvest and road construction.
Appendix E

Final EIS E-85 Communities

Figure E-23

Port Protection’s Community Use Area

Table E-82

Roadless Areas, ARA Management Categories, and Development Opportunity in Port 

Protection's Community Use Area

Roadless Category (acres)

Alternative

1 2 3 4 5 6

Total Community Use Area 673,746 673,746 673,746 673,746 673,746 673,746

Total Roadless Area 363,488 359,761 151,704 320,832 260,826 0

Roadless Share 54% 53% 23% 48% 39% 0%

ARA Management Categories (acres)

LUD II Priority na 173,561 0 173,561 171,702 0

Watershed Priority na 68,235 6,833 0 0 0

Roadless Priority na 117,965 78,733 107,100 89,124 0

Community Priority na 0 6,833 0 0 0

Timber Priority na 0 0 40,171 0 0

Development Opportunity

Development LUDs (acres) 197,454 206,237 234,009 234,011 298,739 298,739

Timber Opportunity (Acres Suitable for Harvest)

Old-Growth 37,367 39,515 47,553 54,129 54,740 54,740

Young-Growth 78,762 79,416 79,444 79,499 79,500 79,610

Estimated Harvest over 100 Years (acres)

Old-Growth 8,799 8,292 7,592 7,307 7,280 7,280

Young-Growth 67,060 65,406 64,730 64,749 64,419 63,922

na = not applicable
Appendix E

Communities E-86 Final EIS

Not all acres removed from roadless management would be available for development. The change in 

acres in development LUDs serves as a measure of development potential as it presently exists by 

alternative. Approximately 29 percent (197,450 acres) of the Port Protection CUA is presently managed in 

development LUDs. This total would increase under all action alternatives, with net gains ranging from 

about 8,800 acres (Alternative 2) to 101,300 acres (Alternatives 5 and 6). 

Suitable old-growth and young-growth acres available for harvest would increase under all action 

alternatives. Estimated net gains in suitable old-growth range from about 2,150 acres (Alternative 2) to 

17,400 acres (Alternatives 5 and 6). Increases in suitable young-growth acres would be about 1 percent 

of the existing total under all action alternatives.

Total acres harvested are assumed to remain constant across all alternatives. Estimated old-growth harvest 

totals in the Port Protection CUA over 100 years range from about 7,300 acres (Alternatives 4 to 6) to 8,800 

acres (Alternative 1). Estimated young-growth harvest ranges from about 63,900 acres (Alternative 6) to 

67,100 acres (Alternative 1) (Table E-82). 

Subsistence

No significant effect on salmon, other finfish, or invertebrate habitat capability is expected from 

implementation of any alternative. Marine resources (fish and marine invertebrates) accounted for 69 

percent of per capita subsistence harvest in Port Protection in 1996, with deer accounting for an 

estimated 21 percent (ADF&G 2018). 

Port Protection residents take the majority (64 percent) of their deer from two WAAs (Table E-83). As 

shown in Table E-83, the Port Protection portion of harvest represents about 3 percent of the total 

combined harvest and about 6 percent of the rural hunter harvest in these WAAs. About 41 percent of the 

harvest in these WAAs is by non-rural hunters, suggesting that there is a harvest buffer that could be 

restricted, if necessary, before restrictions are placed on rural harvests. 

Both WAAs occur in an area with substantial past harvest and, therefore, deer habitat capabilities are 

currently estimated to be considerably below 1954 levels. The 2016 Forest Plan Amendment EIS analysis 

found that additional harvest that could occur under the current Forest Plan could further reduce estimated 

habitat capabilities after 100 years by 2 percent (Table E-83). 

Table E-83

Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where Port 

Protection Residents Obtain Approximately 75 Percent of their Average Annual Deer 

Harvest1

WAA

Average Deer Harvest from 2004 to 2013 Deer Habitat Capability3

Port 

Protection 

Residents

All Rural 

Hunters2

All 

Hunters 2014

After 100 Years of 

Implementation Change

1529 9 77 154 68% 66% -2%

1317 1 93 133 58% 56% -2% 1 Calculated based on harvest where location is known. 2 The category “All Rural Hunters” includes residents of Southeast Alaska communities, excluding the cities of Juneau and 

Ketchikan.

3 Deer habitat capability in 2014 and after 100 Years of full implementation is expressed as a percent of the 1954 habitat 

capability. Data presented for 100 Years of Implementation are estimates developed for the current Forest Plan in the 2016 

Forest Plan Amendment EIS (USDA Forest Service 2016).

The 2016 Forest Plan Amendment EIS analysis found that use of most subsistence resources by Port 

Protection residents (fish and marine invertebrates) was not expected to be affected by the current Forest 

Plan. Based on the Deer Availability and Anticipated Demand analysis completed for the 1997 Forest 

Plan EIS, the 2016 analysis found that subsistence use of deer may be affected to the point that some 

restriction in hunting might be necessary over the long term, especially for non-rural hunters. The risk of 

hunting restrictions would be reduced somewhat, through more intensive management (e.g., thinning) of 

the existing and future closed-canopy, young-growth forests in this area. Indirect effects associated with 
Appendix E

Final EIS E-87 Communities

increased competition for deer within Port Protection’s subsistence use areas could also occur if hunters 

from other communities were displaced due to timber harvest activity. 

Suitable old-growth acres would increase relative to Alternative 1 in both WAAs under all of the action 

alternatives (Table E-84). Projected old-growth harvest would decrease relative to Alternative 1 under all 

of the action alternatives in one of the WAAs and increase in the other (Table E-85). These relative 

changes in projected harvest are small in absolute terms (i.e., number of acres) and none of the 

alternatives are expected to affect the findings of the 2016 Forest Plan Amendment EIS.

Table E-84

Suitable Old-Growth by WAA and Alternative for the WAAs where Port Protection

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

1529 67,930 7,610 110 210 3,680 4,250 4,250

1317 57,220 2,460 730 2,190 2,510 3,380 3,380

Table E-85

Projected Old-Growth Harvest by WAA and Alternative for the WAAs where Port 

Protection Residents Obtain Approximately 75 Percent of their Average Annual Deer 

Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

1529 67,930 2,270 (180) (560) (130) (70) (70)

1317 57,220 730 130 290 210 360 360

Saxman

Community Use Area

Saxman’s CUA encompasses a total of 1,968,512 acres (Figure E-24). Almost half of this area (48

percent) is presently managed as roadless (Table E-86). This share would drop to 32 percent under 

Alternative 5, with no acres managed as roadless under Alternative 6. The removal of LUD II acres under 

Alternative 3 accounts for approximately 39 percent of the decrease in roadless acres under this 

alternative. These areas would retain their congressional protections and continue to be managed in a 

roadless state. Alternative 4 includes ARA acres that would be managed as Timber Priority and allow 

timber harvest and road building. Timber Priority acres account for 13 percent of the ARA in the Saxman 

CUA. Areas allocated to Roadless Priority and Community Priority would explicitly allow the cutting, 

utilization, customary trade, and removal of trees for the purposes of Alaska Native customary and 

traditional uses, as well as road construction deemed necessary by a federally recognized Tribe for 

access to Alaska Native cultural sites. This type of use would also be allowed in Timber Priority areas, 

which allow all timber harvest and road construction.
Appendix E

Communities E-88 Final EIS

Figure E-24

Saxman’s Community Use Area

Table E-86

Roadless Areas, ARA Management Categories, and Development Opportunity in 

Saxman's Community Use Area

Roadless Category (acres)

Alternative

1 2 3 4 5 6

Total Community Use Area 1,968,512 1,968,512 1,968,512 1,968,512 1,968,512 1,968,512

Total Roadless Area 951,613 938,575 870,794 897,258 629,605 0

Roadless Share 48% 48% 44% 46% 32% 0%

ARA Management Categories (acres)

LUD II Priority na 31,386 0 31,386 31,384 0

Watershed Priority na 494,679 58,585 0 0 0

Roadless Priority na 412,511 317,685 753,390 598,221 0

Community Priority na 0 58,585 0 0 0

Timber Priority na 0 0 112,482 0 0

Development Opportunity

Development LUDs (acres) 115,243 127,745 160,833 160,844 413,413 413,416

Timber Opportunity (Acres Suitable for Harvest)

Old-Growth 29,744 33,535 45,566 55,120 56,219 56,220

Young-Growth 32,823 34,341 34,760 34,649 35,101 35,454

Estimated Harvest over 100 Years (acres)

Old-Growth 7,080 7,335 7,510 7,959 7,957 7,957

Young-Growth 27,946 28,283 28,322 28,220 28,442 28,467

na = not applicable
Appendix E

Final EIS E-89 Communities

Not all acres removed from roadless management would be available for development. The change in 

acres in development LUDs serves as a measure of development potential as it presently exists by 

alternative. Approximately 6 percent (115,250 acres) of the Saxman CUA is presently managed in 

development LUDs. This total would increase under all action alternatives, with net gains ranging from 

about 12,500 acres (Alternative 2) to 298,200 acres (Alternatives 5 and 6). 

Suitable old-growth and young-growth acres available for harvest would increase under all action 

alternatives. Estimated net gains in suitable old-growth range from about 3,800 acres (Alternative 2) to 

26,500 acres (Alternatives 5 and 6). Increases in suitable young-growth acres range from an estimated 

1,500 acres (Alternative 2) to about 2,600 acres (Alternative 6).

Total acres harvested are assumed to remain constant across all alternatives. Estimated harvest totals in the 

Saxman CUA over 100 years range from about 7,100 acres (Alternative 2) to 7,950 acres (Alternatives 4 to 

6). Young-growth harvest estimates range from about 27,950 acres (Alternative 1) to 7,950 acres 

(Alternatives 5 and 6) (Table E-86). 

Subsistence

No significant decline in salmon, other finfish, or invertebrate habitat capability is expected from 

implementation of any alternative. These resources account for 68 percent of the total edible pounds of 

subsistence resources harvested by Saxman households (Kruse and Frazier 1988). Marine resources 

(fish and marine invertebrates) accounted for 70 percent of per capita subsistence harvest in Saxman in 

1999 (ADF&G 2018). 

The 1988 TRUCS study found that deer accounted for 19 percent of the total edible pounds of 

subsistence resources harvested by Saxman households (Kruse and Frazier 1988). Deer accounted for 

13 percent of per capita subsistence harvest by Saxman residents in 1999 (ADF&G 2018). Data were not 

provided separately for Saxman in the ADF&G deer harvest reports for 2004 to 2013. The majority of 

deer harvest by Saxman residents likely takes place in GMU 1A. 

The 2016 Forest Plan Amendment EIS analysis found that use of most subsistence resources by Saxman

residents (fish and marine invertebrates) was not expected to be affected by the current Forest Plan.

Based on the Deer Availability and Anticipated Demand analysis completed for the 1997 Forest Plan EIS, 

the 2016 analysis indicated that subsistence use of deer may be affected to the point that some restriction 

in hunting might be necessary over the long term, especially for non-rural hunters. None of the 

alternatives are expected to affect these findings.

Sitka (Sheet’ká)

Community Use Area

Sitka’s CUA encompasses a total of 420,004 acres (Figure E-25). Most of this area (83 percent) is 

presently managed as roadless (Table E-87). This share would decrease to 67 percent under Alternative 

5, with no acres managed as roadless under Alternative 6. Alternative 4 includes ARA acres that would 

be managed as Timber Priority and allow timber harvest and road building. Timber Priority acres account 

for 9 percent of the ARA in the Sitka CUA. Areas allocated to Roadless Priority and Community Priority

would explicitly allow the cutting, utilization, customary trade, and removal of trees for the purposes of 

Alaska Native customary and traditional uses, as well as road construction deemed necessary by a 

federally recognized Tribe for access to Alaska Native cultural sites. This type of use would also be 

allowed in Timber Priority areas, which allow all timber harvest and road construction.
Appendix E

Communities E-90 Final EIS

Figure E-25

Sitka’s Community Use Area

Table E-87

Roadless Areas, ARA Management Categories, and Development Opportunity in 

Sitka's Community Use Area

Roadless Category (acres)

Alternative

1 2 3 4 5 6

Total Community Use Area 420,004 420,004 420,004 420,004 420,004 420,004

Total Roadless Area 348,194 350,192 350,192 346,216 281,941 0

Roadless Share 83% 83% 83% 82% 67% 0%

ARA Management Categories (acres)

LUD II Priority na 0 0 0 0 0

Watershed Priority na 206,073 57,134 0 0 0

Roadless Priority na 144,119 86,985 315,687 281,941 0

Community Priority na 0 57,134 0 0 0

Timber Priority na 0 0 30,528 0 0

Development Opportunity

Development LUDs (acres) 26,073 26,839 26,839 26,840 91,035 91,039

Timber Opportunity (Acres Suitable for Harvest)

Old-Growth 2,329 2,357 2,357 4,870 4,870 4,870

Young-Growth 10,550 10,592 10,601 10,601 10,601 10,648

Estimated Harvest over 100 Years (acres)

Old-Growth 0 0 0 6 5 5

Young-Growth 8,983 8,724 8,638 8,634 8,590 8,549

na = not applicable
Appendix E

Final EIS E-91 Communities

Not all acres removed from roadless management would be available for development. The change in 

acres in development LUDs serves as a measure of development potential as it presently exists by 

alternative. Approximately 6 percent (26,100 acres) of the Sitka CUA is presently managed in 

development LUDs. This total would increase under all action alternatives, with net gains ranging from 

about 800 acres (Alternatives 2 to 4) to 65,000 acres (Alternatives 5 and 6).

Suitable old-growth available for harvest would increase by about 2,550 acres under Alternatives 4 to 6, 

with negligible increases (less than 30 acres) estimated for Alternatives 2 and 3. Increases in suitable 

young-growth acres would be negligible (less than 100 acres) under all action alternatives. No old-growth 

harvest is expected to occur in the Sitka CUA over 100 years under any of the alternatives. Estimated 

young-growth harvest ranges from about 8,550 acres (Alternative 6) to 9,000 acres (Alternative 1) (Table 

E-87).

Subsistence

No significant effect on salmon, other finfish, or invertebrate habitat capability is expected from 

implementation of any alternative. These resources account for 69 percent of the total edible pounds of 

subsistence resources harvested by Sitka households (Kruse and Frazier 1988). Marine resources (fish 

and marine invertebrates) accounted for 68 percent of per capita subsistence harvest in Sitka in 1996 

(ADF&G 2018). 

The 1988 TRUCS study found that deer accounted for 27 percent of the total edible pounds of 

subsistence resources harvested by Sitka households (Kruse and Frazier 1988). Deer accounted for 22 

percent of per capita subsistence harvest by Sitka residents in 1996 (ADF&G 2018). 

Sitka residents mainly harvest deer on Baranof Island. Sixteen WAAs account for the majority (75 

percent) of deer harvested by Sitka residents. As shown in Table E-88, the Sitka portion represents about 

97 percent of the rural hunter harvest and 87 percent of the total harvest in these WAAs. About 11

percent of the combined harvest in these WAAs is by non-rural hunters, suggesting that there is little

harvest buffer that could be restricted, if necessary, before restrictions are placed on rural harvests.

The 2016 Forest Plan Amendment EIS analysis found that of the 16 WAAs used most heavily by Sitka 

residents, only one (WAA 3308) would be affected under the current Forest Plan, with harvest that could 

occur estimated to further reduce deer habitat capability by 1 percent after 100 years of Forest Plan 

implementation (Table E-88). 
Appendix E

Communities E-92 Final EIS

Table E-88

Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where Sitka 

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest1

WAA

Average Deer Harvest from 2004 to 2013 Deer Habitat Capability3

Sitka 

Residents

All Rural 

Hunters2

All 

Hunters 2014

After 100 Years of 

Implementation Change

3001 334 338 361 82% 82% 0%

3002 268 272 299 69% 69% 0%

3003 144 144 152 86% 86% 0%

3314 122 123 136 90% 90% 0%

3311 112 113 127 97% 97% 0%

3313 106 107 125 97% 97% 0%

3310 88 92 100 92% 92% 0%

3207 86 88 94 100% 100% 0%

3104 73 75 84 74% 74% 0%

3416 71 78 88 100% 100% 0%

3309 70 72 81 100% 100% 0%

3733 69 77 81 100% 100% 0%

3312 68 69 76 95% 95% 0%

3206 61 63 68 100% 100% 0%

3105 56 58 68 99% 99% 0%

3308 52 61 107 66% 65% -1% 1 Calculated based on harvest where location is known. 2 The category “All Rural Hunters” includes residents of Southeast Alaska communities, excluding the cities of Juneau and 

Ketchikan.

3 Deer habitat capability in 2014 and after 100 Years of full implementation is expressed as a percent of the 1954 habitat 

capability. Data presented for 100 Years of Implementation are estimates developed for the current Forest Plan in the 2016 

Forest Plan Amendment EIS (USDA Forest Service 2016).

The 2016 Forest Plan Amendment EIS analysis found that use of most subsistence resources by Sitka 

residents (fish and marine invertebrates) was not expected to be affected by any of the alternatives. 

Based on the Deer Availability and Anticipated Demand analysis completed for the 1997 Forest Plan EIS, 

the 2016 analysis found that due to existing circumstances, subsistence use of deer may reach a point 

that some restriction in hunting by Sitka residents, all rural hunters, and all hunters might be necessary

over the long term. The risk of hunting restrictions would be reduced somewhat, through more intensive 

management (e.g., thinning) of the existing and future closed-canopy, young-growth forests in this area. 

Indirect effects associated with increased competition for deer within Sitka’s subsistence, use areas could 

also occur if hunters from other communities were displaced due to timber production activity.

Suitable old-growth acres would increase relative to Alternative 1 under all of the action alternatives in 

WAA 3308, with minor increases also estimated for one other WAA (3003) (Table E-89). Projected oldgrowth harvest was, however, estimated to decrease in WAA 3308 under most of the action alternatives 

(Table E-90). These relative changes in projected harvest are small and none of the alternatives are 

expected to affect the findings of the 2016 Forest Plan Amendment EIS, which anticipated potential 

impacts based on existing circumstances.
Appendix E

Final EIS E-93 Communities

Table E-89

Suitable Old-Growth by WAA and Alternative for the WAAs where Sitka Residents 

Obtain Approximately 75 Percent of their Average Annual Deer Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

3001 79,250 - - - - - -

3002 77,040 - - - - - -

3003 59,150 - - - 80 80 80

3314 41,600 - - - - - -

3311 56,050 - - - - - -

3313 73,870 - - - - - -

3310 58,300 - - - - - -

3207 99,830 - - - - - -

3104 53,710 - - - - - -

3416 65,170 - - - - - -

3309 43,820 - - - - - -

3733 215,330 - - - - - -

3312 19,590 - - - - - -

3206 40,340 - - - - - -

3105 52,840 - - - - - -

3308 100,810 6,500 100 980 2,560 3,510 3,510

Table E-90

Projected Old-Growth Harvest by WAA and Alternative for the WAAs where Sitka

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

3001 79,250 - - - - - -

3002 77,040 - - - - - -

3003 59,150 - - - 10 10 10

3314 41,600 - - - - - -

3311 56,050 - - - - - -

3313 73,870 - - - - - -

3310 58,300 - - - - - -

3207 99,830 - - - - - -

3104 53,710 - - - - - -

3416 65,170 - - - - - -

3309 43,820 - - - - - -

3733 215,330 - - - - - -

3312 19,590 - - - - - -

3206 40,340 - - - - - -

3105 52,840 - - - - - -

3308 100,810 710 - (30) (110) (70) (70)

Skagway

Community Use Area

Skagway’s CUA encompasses a total of 203,461 acres (Figure E-26). Nearly all of this area (99 percent) 

is presently managed as roadless (Table E-91). This share would decrease somewhat under Alternative 5 

to 95 percent, and drop to no acres managed as roadless under Alternative 6. Alternative 4 includes ARA

acres that would be managed as Timber Priority and allow timber harvest and road building. Timber 

Priority acres account for 4 percent of the ARA in the Skagway CUA. Areas allocated to Roadless Priority 

would explicitly allow the cutting, utilization, customary trade, and removal of trees for the purposes of 

Alaska Native customary and traditional uses, as well as road construction deemed necessary by a 
Appendix E

Communities E-94 Final EIS

federally recognized Tribe for access to Alaska Native cultural sites. This type of use would also be 

allowed in Timber Priority areas, which allow all timber harvest and road construction.

Not all acres removed from roadless management would be available for development. The change in 

acres in development LUDs serves as a measure of development potential as it presently exists by 

alternative. None of the lands in Skagway CUA are presently managed in a development LUD. This 

would change under Alternatives 5 and 6, both of which would allocate about 7,200 acres to development 

LUDs. 

There are no suitable old-growth acres for harvest under any of the alternatives, and very limited suitable 

young-growth acres (less than 100 acres in all cases). Correspondingly, no old-growth or young-growth 

harvest is estimated over the next 100 years in the Skagway CUA (Table E-91). 

Figure E-26

Skagway’s Community Use Area
Appendix E

Final EIS E-95 Communities

Table E-91

Roadless Areas, ARA Management Categories, and Development Opportunity in 

Skagway's Community Use Area

Roadless Category 

(acres)

Alternative

1 2 3 4 5 6

Total Community Use Area 203,461 203,461 203,461 203,461 203,461 203,461

Total Roadless Area 200,585 203,461 203,461 200,585 192,490 0

Roadless Share 99% 100% 100% 99% 95% 0%

ARA Management Categories (acres)

LUD II Priority na 0 0 0 0 0

Watershed Priority na 67,481 0 0 0 0

Roadless Priority na 135,979 135,979 193,370 192,490 0

Community Priority na 0 0 0 0 0

Timber Priority na 0 0 7,215 0 0

Development Opportunity

Development LUDs (acres) 0 0 0 0 7,215 7,215

Timber Opportunity (Acres Suitable for Harvest)

Old-Growth 0 0 0 0 0 0

Young-Growth 0 0 0 46 70 70

Estimated Harvest over 100 Years (acres)

Old-Growth 0 0 0 0 0 0

Young-Growth 0 0 0 0 0 0

na = not applicable

Subsistence

No significant effect on salmon, other finfish, or invertebrate habitat capability is expected from 

implementation of any alternative. These resources account for 88 percent of the total edible pounds of 

subsistence resources harvested by Skagway households (Kruse and Frazier 1988). 

The 1988 TRUCS study found that deer account for only a small fraction of the total edible pounds of 

subsistence resources harvested by Skagway households (Kruse and Frazier 1988). 

Skagway residents primarily harvest deer in four WAAs (Table E-92). Skagway residents harvested very 

few deer from 2004 to 2013, with annual average harvests per WAA ranging from two to four deer over 

this period. The 2016 Forest Plan Amendment EIS analysis found that none of these WAAs would be 

affected by the current Forest Plan as no timber harvest is proposed in these areas. Indirect effects could 

occur if hunters from other communities were displaced due to timber harvest activity. 

There are no suitable old-growth acres and no projected old-growth harvest in these WAAs under any of 

the alternatives (Tables E-93 and E-94) and, therefore, no change to the findings of the 2016 Forest Plan 

Amendment EIS.

Table E-92

Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where Skagway 

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest1

WAA

Average Deer Harvest from 2004 to 2013 Deer Habitat Capability3

Skagway 

Residents

All Rural 

Hunters2

All 

Hunters 2014

After 100 Years of 

Implementation Change

3836 4 16 210 100% 100% 0%

2515 2 1 12 100% 100% 0%

2722 2 6 302 100% 100% 0%

4044 2 6 57 88% 88% 0% 1 Calculated based on harvest where location is known. 2 The category “All Rural Hunters” includes residents of Southeast Alaska communities, excluding the cities of Juneau and 

Ketchikan.

3 Deer habitat capability in 2014 and after 100 Years of full implementation is expressed as a percent of the 1954 habitat 

capability. Data presented for 100 Years of Implementation are estimates developed for the current Forest Plan in the 2016 

Forest Plan Amendment EIS (USDA Forest Service 2016).
Appendix E

Communities E-96 Final EIS

Table E-93

Suitable Old-Growth by WAA and Alternative for the WAAs where Skagway Residents 

Obtain Approximately 75 Percent of their Average Annual Deer Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

3836 53,460 - - - - - -

2515 99,410 - - - - - -

2722 25,150 - - - - - -

4044 79,650 - - - - - -

Table E-94

Projected Old-Growth Harvest by WAA and Alternative for the WAAs where Skagway

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

3836 53,460 - - - - - -

2515 99,410 - - - - - -

2722 25,150 - - - - - -

4044 79,650 - - - - - -

Tenakee Springs

Community Use Area

The Tenakee Springs CUA encompasses a total of 195,975 acres (Figure E-27). Over three-quarters of 

this area (78 percent) is presently managed as roadless (Table E-95). This share would drop to 60 and 42 

percent under Alternatives 3 and 5, respectively, with no acres managed as roadless under Alternative 6. 

The removal of LUD II acres under Alternative 3 accounts for all of the decrease in roadless acres under 

this alternative. These areas would retain their congressional protections and continue to be managed in 

a roadless state. Alternative 4 includes ARA acres that would be managed as Timber Priority and allow 

timber harvest and road building. Timber Priority acres account for 21 percent of the ARA in the Tenakee 

Springs CUA. Areas allocated to Roadless Priority would explicitly allow the cutting, utilization, customary 

trade, and removal of trees for the purposes of Alaska Native customary and traditional uses, as well as 

road construction deemed necessary by a federally recognized Tribe for access to Alaska Native cultural 

sites. This type of use would also be allowed in Timber Priority areas, which allow all timber harvest and 

road construction.
Appendix E

Final EIS E-97 Communities

Figure E-27

Tenakee Springs’ Community Use Area

Table E-95

Roadless Areas, ARA Management Categories, and Development Opportunity in 

Tenakee Springs' Community Use Area

Roadless Category (acres)

Alternative

1 2 3 4 5 6

Total Community Use Area 195,975 195,975 195,975 195,975 195,975 195,975

Total Roadless Area 153,343 161,076 118,192 147,140 82,936 0

Roadless Share 78% 82% 60% 75% 42% 0%

ARA Management Categories (acres)

LUD II Priority na 37,972 0 37,972 37,969 0

Watershed Priority na 71,580 0 0 0 0

Roadless Priority na 51,524 46,611 78,533 44,967 0

Community Priority na 0 0 0 0 0

Timber Priority na 0 0 30,635 0 0

Development Opportunity

Development LUDs (acres) 30,954 23,526 26,221 34,719 101,136 101,137

Timber Opportunity (Acres Suitable for Harvest)

Old-Growth 8,492 7,077 8,442 18,807 18,807 18,808

Young-Growth 6,462 6,556 6,556 6,557 6,566 6,599

Estimated Harvest over 100 Years (acres)

Old-Growth 160 160 234 170 163 163

Young-Growth 5,502 5,400 5,342 5,340 5,320 5,299

na = not applicable
Appendix E

Communities E-98 Final EIS

Not all acres removed from roadless management would be available for development. The change in 

acres in development LUDs serves as a measure of development potential as it presently exists by 

alternative. Approximately 16 percent (30,950 acres) of the Tenakee Springs CUA is presently managed 

in development LUDs. This total would decrease under Alternatives 2 and 3, and increase under 

Alternatives 4 to 6, with net gains ranging from about 3,800 acres (Alternative 4) to 70,200 acres 

(Alternatives 5 and 6). 

Suitable old-growth acres available for harvest would decrease under Alternatives 2 and 3, with net gains 

of about 10,300 acres under the other three action alternatives (Alternatives 4 to 6). Estimated increases 

in suitable young-growth acres range from about 100 to 150 acres under all action alternatives. 

Total acres harvested are assumed to remain constant across all alternatives. Less than 200 acres of oldgrowth harvest is estimated to occur in the Tenakee Springs CUA over 100 years under all of the alternatives. 

Young-growth harvest estimates are similar across alternatives, ranging from about 5,300 acres (Alternatives 

3 to 6) to 5,500 acres (Alternative 1) (Table E-95).

Subsistence

No significant effect on salmon, other finfish, or invertebrate habitat capability is expected from implementation 

of any alternative. These resources account for 55 percent of the total edible pounds of subsistence resources 

harvested by Tenakee Springs households, with deer accounting for an estimated 39 percent (Kruse and 

Frazier 1988). 

Tenakee Springs residents take the majority (71 percent) of their deer from six WAAs (Table E-96). As shown 

in Table E-96, the Tenakee Springs portion ranges from about 4 to 31 percent of total harvest and 8 to 90 

percent of all rural deer harvest in these WAAs. About 58 percent of the combined harvest in these WAAs is by 

non-rural hunters, suggesting that there is a harvest buffer that could be restricted, if necessary, before 

restrictions are placed on rural harvests. 

All of the WAAs identified in Table E-96 are in areas with some past timber harvest and, therefore, deer 

habitat capabilities are currently estimated to be below 1954 levels. The 2016 Forest Plan Amendment 

EIS found that additional harvest that could occur under the current Forest Plan would reduce estimated 

habitat capabilities in three of the six WAAs by a further 2 to 4 percent (Table E-96). 

Table E-96

Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where Tenakee 

Springs Residents Obtain Approximately 75 Percent of their Average Annual Deer 

Harvest1

WAA

Average Deer Harvest from 2004 to 2013 Deer Habitat Capability3

Tenakee 

Springs 

Residents

All Rural 

Hunters2

All 

Hunters 2014

After 100 Years of 

Implementation Change

3627 20 25 63 76% 72% -4%

3526 15 28 63 80% 78% -2%

3629 14 23 66 91% 91% 0%

3525 5 56 118 75% 72% -3%

3630 4 6 18 99% 99% 0%

3628 2 2 8 98% 98% 0% 1 Calculated based on harvest where location is known. 2 The category “All Rural Hunters” includes residents of Southeast Alaska communities, excluding the cities of Juneau and 

Ketchikan.

3 Deer habitat capability in 2014 and after 100 Years of full implementation is expressed as a percent of the 1954 habitat 

capability. Data presented for 100 Years of Implementation are estimates developed for the current Forest Plan in the 2016 

Forest Plan Amendment EIS (USDA Forest Service 2016).

The 2016 Forest Plan Amendment EIS analysis found that use of most subsistence resources by 

Tenakee Springs residents (fish and marine invertebrates) was not expected to be affected by the current 

Forest Plan. Based on the Deer Availability and Anticipated Demand analysis completed for the 1997 

Forest Plan EIS, the 2016 analysis found that subsistence use of deer may be affected to the point that 
Appendix E

Final EIS E-99 Communities

some restriction in hunting might be necessary over the long term, especially for non-rural hunters. The 

risk of hunting restrictions would be reduced somewhat, through more intensive management (e.g., 

thinning) of the existing and future closed-canopy, young-growth forests in this area. 

Suitable old-growth acres would increase relative to Alternative 1 in two of the six WAAs under all of the 

action alternatives (Table E-97). However, projected old-growth harvest would decrease relative to 

Alternative 1 in these WAAs under most alternatives, with no suitable acres or projected harvest identified 

for the other four WAAs (Tables E-97 and E-98). These relative changes in projected harvest are small 

and none of the alternatives are expected to affect the findings of the 2016 Forest Plan Amendment EIS.

Table E-97

Suitable Old-Growth by WAA and Alternative for the WAAs where Tenakee Springs

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

3627 27,320 1,420 30 1,100 1,100 1,100 1,100

3526 40,790 230 - - - - -

3629 96,880 - - - - - -

3525 73,120 2,350 40 380 600 610 610

3630 70,770 - - - - - -

3628 34,080 - - - - - -

Table E-98

Projected Old-Growth Harvest by WAA and Alternative for the WAAs where Tenakee 

Springs Residents Obtain Approximately 75 Percent of their Average Annual Deer 

Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

3627 27,320 160 - 70 10 - -

3526 40,790 30 - (10) (10) (20) (20)

3629 96,880 - - - - - -

3525 73,120 260 - (10) (60) (70) (70)

3630 70,770 - - - - - -

3628 34,080 - - - - - -

Thorne Bay

Community Use Area

Thorne Bay’s CUA encompasses a total of 966,427 acres (Figure E-28). Almost half of this area (47

percent) is presently managed as roadless (Table E-99). This share would drop to 27 and 29 percent 

under Alternatives 3 and 5, respectively, with no acres managed as roadless under Alternative 6. The 

removal of LUD II acres under Alternative 3 accounts for approximately 60 percent of the decrease in 

roadless acres under this alternative. These areas would retain their congressional protections and

continue to be managed in a roadless state. Alternative 4 includes ARA acres that would be managed as 

Timber Priority and allow timber harvest and road building. Timber Priority acres account for 13 percent of 

the ARA in the Thorne Bay CUA. Areas allocated to Roadless Priority would explicitly allow the cutting, 

utilization, customary trade, and removal of trees for the purposes of Alaska Native customary and 

traditional uses, as well as road construction deemed necessary by a federally recognized Tribe for 

access to Alaska Native cultural sites. This type of use would also be allowed in Timber Priority areas, 

which allow all timber harvest and road construction.
Appendix E

Communities E-100 Final EIS

Figure E-28

Thorne Bay’s Community Use Area

Table E-99

Roadless Areas, ARA Management Categories, and Development Opportunity in Thorne 

Bay's Community Use Area

Roadless Category (acres)

Alternative

1 2 3 4 5 6

Total Community Use Area 966,427 966,427 966,427 966,427 966,427 966,427

Total Roadless Area 452,295 437,535 257,783 370,574 275,582 0

Roadless Share 47% 45% 27% 38% 29% 0%

ARA Management Categories (acres)

LUD II Priority na 117,791 0 117,791 117,432 0

Watershed Priority na 159,375 6,833 0 0 0

Roadless Priority na 160,369 93,824 206,295 158,149 0

Community Priority na 0 6,833 0 0 0

Timber Priority na 0 0 46,488 0 0

Development Opportunity

Development LUDs (acres) 327,188 340,112 388,475 388,803 493,687 493,694

Timber Opportunity (Acres Suitable for Harvest)

Old-Growth 62,595 65,978 78,593 85,763 86,735 86,735

Young-Growth 127,013 128,256 128,312 128,368 128,398 128,655

Estimated Harvest over 100 Years (acres)

Old-Growth 13,480 12,748 11,837 11,038 10,957 10,957

Young-Growth 108,142 105,630 104,548 104,550 104,040 103,302

na = not applicable
Appendix E

Final EIS E-101 Communities

Not all acres removed from roadless management would be available for development. The change in 

acres in development LUDs serves as a measure of development potential as it presently exists by 

alternative. Approximately 34 percent (327,200 acres) of the Thorne Bay CUA is presently managed in 

development LUDs. This total would increase under all action alternatives, with net gains ranging from 

about 12,900 acres (Alternative 2) to 166,500 acres (Alternatives 5 and 6). 

Suitable old-growth and young-growth acres available for harvest would increase under all action 

alternatives. Estimated net gains in suitable old-growth range from about 3,400 acres (Alternative 2) to 

24,150 acres (Alternatives 5 and 6). Increases in suitable young-growth acres range from about 1,250 

acres (Alternative 2) to 1,650 acres (Alternative 6), about 1 percent of the existing total in all cases.

Total acres harvested are assumed to remain constant across all alternatives. Estimated old-growth harvest 

totals in the Thorne Bay CUA over 100 years range from about 11,000 acres (Alternatives 4 to 6) to 13,500 

acres (Alternative 1). Young-growth harvest estimates range from about 103,300 acres (Alternative 6) to 

108,150 acres (Alternative 1) (Table E-99). 

Subsistence

No significant effect on salmon, other finfish, or invertebrate habitat capability is expected from 

implementation of any alternative. These resources account for 75 percent of the total edible pounds of 

subsistence resources harvested by Thorne Bay households (Kruse and Frazier 1988). Marine resources 

(fish and marine invertebrates) accounted for 54 percent of per capita subsistence harvest in Thorne Bay 

in 1998 (ADF&G 2018). 

The 1988 TRUCS study found that deer accounted for 20 percent of the total edible pounds of subsistence 

resources harvested by Thorne Bay (Kruse and Frazier 1988). Deer accounted for 27 percent of per capita 

subsistence harvest by Throne Bay residents in 1998 (ADF&G 2018). 

Residents of Thorne Bay harvest the majority (70 percent) of their deer from two WAAs in north-central 

Prince of Wales Island (1319 and 1315). As shown in Table E-100, the Thorne Bay portion represents 

about 38 percent and 40 percent of the total harvest and about 59 percent and 53 percent of the rural 

hunter harvest in these WAAs, respectively. About 32 percent of the combined harvest in these WAAs is 

by non-rural hunters, suggesting that there is a limited harvest buffer that could be restricted, if 

necessary, before restrictions are placed on rural harvests. 

WAAs 1319 and 1315 occur in an area with substantial past harvest and, therefore, deer habitat 

capabilities are currently estimated to be below 1954 levels. The 2016 Forest Plan Amendment EIS 

analysis found that additional harvest that could occur under the current Forest Plan would further reduce 

estimated habitat capabilities by 5 to 6 percent (Table E-100). 

Table E-100

Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where Thorne 

Bay Residents Obtain Approximately 75 Percent of their Average Annual Deer 

Harvest1

WAA

Average Deer Harvest from 2004 to 2013 Deer Habitat Capability3

Thorne Bay 

Residents

All Rural 

Hunters2 All Hunters 2014

After 100 Years of 

Implementation Change

1319 119 201 317 74% 69% -5%

1315 90 169 226 56% 50% -6% 1 Calculated based on harvest where location is known. 2 The category “All Rural Hunters” includes residents of Southeast Alaska communities, excluding the cities of Juneau and 

Ketchikan.

3 Deer habitat capability in 2014 and after 100 Years of full implementation is expressed as a percent of the 1954 habitat 

capability. Data presented for 100 Years of Implementation are estimates developed for the current Forest Plan in the 2016 

Forest Plan Amendment EIS (USDA Forest Service 2016).

The 2016 Forest Plan Amendment EIS analysis found that use of most subsistence resources by Thorne 

Bay residents (fish and marine invertebrates) was not expected to be affected by any of the alternatives. 
Appendix E

Communities E-102 Final EIS

Based on the Deer Availability and Anticipated Demand analysis completed for the 1997 Forest Plan EIS, 

the 2016 analysis also found that subsistence use of deer may be affected to the point that some 

restriction in hunting might be necessary over the long term, especially for non-rural hunters. The risk of 

hunting restrictions was found to be reduced somewhat, through more intensive management (e.g., 

thinning) of the existing and future closed-canopy, young-growth forests in this area. Indirect effects 

associated with increased competition for deer within Thorne Bay’s subsistence use areas could also 

occur if hunters from other communities were displaced due to timber harvest activity. 

Suitable old-growth acres would increase relative to Alternative 1 in both of the WAAs under all of the 

action alternatives (Table E-101). However, projected old-growth harvest would decrease relative to 

Alternative 1 in these WAAs under all of the action alternatives (Table E-102). These relative changes in 

projected harvest are small and not expected to affect the findings of the 2016 Forest Plan Amendment 

EIS.

Table E-101

Suitable Old-Growth by WAA and Alternative for the WAAs where Thorne Bay

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

1319 103,210 3,250 170 570 600 600 600

1315 55,040 3,820 230 1,240 1,240 1,240 1,240

1319 103,210 3,250 170 570 600 600 600

Table E-102

Projected Old-Growth Harvest by WAA and Alternative for the WAAs where Thorne Bay

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

1319 103,210 970 (40) (130) (240) (250) (250)

1315 55,040 1,140 (40) (30) (180) (200) (200)

1319 103,210 970 (40) (130) (240) (250) (250)

Whale Pass

Community Use Area

The Whale Pass CUA encompasses a total of 966,427 acres (Figure E-29). Almost half of this area (47

percent) is presently managed as roadless (Table E-103). This share would drop to 27 and 29 percent 

under Alternatives 3 and 5, respectively, with no acres managed as roadless under Alternative 6. The 

removal of LUD II acres under Alternative 3 accounts for approximately 60 percent of the decrease in 

roadless acres under this alternative. These areas would retain their congressional protections and 

continue to be managed in a roadless state. Alternative 4 includes ARA acres that would be managed as 

Timber Priority and allow timber harvest and road building. Timber Priority acres account for 13 percent of 

the ARA in the Whale Pass CUA. Areas allocated to Roadless Priority would explicitly allow the cutting, 

utilization, customary trade, and removal of trees for the purposes of Alaska Native customary and 

traditional uses, as well as road construction deemed necessary by a federally recognized Tribe for 

access to Alaska Native cultural sites. This type of use would also be allowed in Timber Priority areas, 

which allow all timber harvest and road construction.
Appendix E

Final EIS E-103 Communities

Figure E-29

Whale Pass’ Community Use Area

Table E-103

Roadless Areas, ARA Management Categories, and Development Opportunity in Whale 

Pass' Community Use Area

Roadless Category 

(acres)

Alternative

1 2 3 4 5 6

Total Community Use Area 966,427 966,427 966,427 966,427 966,427 966,427

Total Roadless Area 452,295 437,535 257,783 370,574 275,582 0

Roadless Share 47% 45% 27% 38% 29% 0%

ARA Management Categories (acres)

LUD II Priority na 117,791 0 117,791 117,432 0

Watershed Priority na 159,375 6,833 0 0 0

Roadless Priority na 160,369 93,824 206,295 158,149 0

Community Priority na 0 6,833 0 0 0

Timber Priority na 0 0 46,488 0 0

Development Opportunity

Development LUDs (acres) 327,188 340,112 388,475 388,803 493,687 493,694

Timber Opportunity (Acres Suitable for Harvest)

Old-Growth 62,595 65,978 78,593 85,772 86,735 86,735

Young-Growth 127,013 128,256 128,312 128,368 128,398 128,655

Estimated Harvest over 100 Years (acres)

Old-Growth 13,480 12,748 11,837 11,038 10,957 10,957

Young-Growth 108,142 105,630 104,548 104,550 104,040 103,302

na = not applicable
Appendix E

Communities E-104 Final EIS

Not all acres removed from roadless management would be available for development. The change in 

acres in development LUDs serves as a measure of development potential as it presently exists by 

alternative. Approximately 34 percent (327,200 acres) of the Whale Pass CUA is presently managed in 

development LUDs. This total would increase under all action alternatives, with net gains ranging from 

about 12,900 acres (Alternative 2) to 166,500 acres (Alternatives 5 and 6). 

Suitable old-growth and young-growth acres available for harvest would increase under all action 

alternatives. Estimated net gains in suitable old-growth range from about 3,400 acres (Alternative 2) to 

24,150 acres (Alternatives 5 and 6). Increases in suitable young-growth acres range from about 1,250 

acres (Alternative 2) to 1,650 acres (Alternative 6), about 1 percent of the existing total in all cases.

Total acres harvested are assumed to remain constant across all alternatives. Estimated old-growth harvest 

totals in the Whale Pass CUA over 100 years range from about 11,000 acres (Alternatives 4 to 6) to 13,500 

acres (Alternative 1). Young-growth harvest estimates range from about 103,300 acres (Alternative 6) to 

108,150 acres (Alternative 1) (Table E-103). 

Subsistence

No significant effect on salmon, other finfish, or invertebrate habitat capability is expected from 

implementation of any alternative. These resources account for 60 percent of the total edible pounds of 

subsistence resources harvested by Whale Pass households (Kruse and Frazier 1988). Marine resources 

(fish and marine invertebrates) accounted for 61 percent of per capita subsistence harvest in Whale Pass 

in 2012 (ADF&G 2018). 

The 1988 TRUCS study found that deer account for 27 percent of the total edible pounds of subsistence 

resources harvested by Whale Pass households (Kruse and Frazier 1988). Deer accounted for 29 

percent of per capita subsistence harvest by Whale Pass residents in 2012 (ADF&G 2018). 

Residents of Whale Pass harvest the majority (72 percent) of their deer from two WAAs in north Prince of 

Wales Island (1530 and 1527). As shown in Table E-104, the Whale Pass portion represents about 15 

percent and 11 percent of the total harvest and about 32 percent and 18 percent of the rural hunter 

harvest in these WAAs, respectively. About 51 percent of the combined harvest in these WAAs is by nonrural hunters, suggesting that there is a harvest buffer that could be restricted, if necessary, before 

restrictions are placed on rural harvests. 

WAAs 1530 and 1527 occur in an area with substantial past timber harvest and, therefore, deer habitat 

capabilities are currently estimated to be below 1954 levels. The 2016 Forest Plan Amendment EIS 

analysis found that additional harvest that could occur under the current Forest Plan would reduce 

estimated habitat capabilities after 100 years by a further 2 to 4 percent (Table E-104).

Table E-104

Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where Whale 

Pass Residents Obtain Approximately 75 Percent of their Average Annual Deer 

Harvest1

WAA

Average Deer Harvest from 2004 to 2013 Deer Habitat Capability3

Whale Pass 

Residents

All Rural 

Hunters2

All 

Hunters 2014

After 100 Years of 

Implementation Change

1530 18 57 124 61% 57% -4%

1527 3 17 27 72% 70% -2% 1 Calculated based on harvest where location is known. 2 The category “All Rural Hunters” includes residents of Southeast Alaska communities, excluding the cities of Juneau and 

Ketchikan.

3 Deer habitat capability in 2014 and after 100 Years of full implementation is expressed as a percent of the 1954 habitat 

capability. Data presented for 100 Years of Implementation are estimates developed for the current Forest Plan in the 2016 

Forest Plan Amendment EIS (USDA Forest Service 2016).

The 2016 Forest Plan Amendment EIS analysis found that use of most subsistence resources by Whale 

Pass residents (fish and marine invertebrates) was not expected to be affected by any of the alternatives. 
Appendix E

Final EIS E-105 Communities

Based on the Deer Availability and Anticipated Demand analysis completed for the 1997 Forest Plan EIS, 

the 2016 analysis found that subsistence use of deer may be affected to the point that some restriction in 

hunting might be necessary over the long term, especially for non-rural hunters. The risk of hunting 

restrictions would be reduced somewhat, through more intensive management (e.g., thinning) of the 

existing and future closed-canopy, young-growth forests in this area. Indirect effects associated with 

increased competition for deer within the Whale Pass subsistence use areas could also occur if hunters 

from other communities were displaced due to timber harvest activity. 

Suitable old-growth acres would increase relative to Alternative 1 in both of the WAAs under all of the 

action alternatives (Table E-105). However, projected old-growth harvest would decrease relative to 

Alternative 1 in these WAAs under all of the action alternatives (Table E-106). Overall projected harvest 

and relative changes under the action alternatives are small and not expected to affect the findings of the 

2016 Forest Plan Amendment EIS.

Table E-105

Suitable Old-Growth by WAA and Alternative for the WAAs where Whale Pass

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

1530 59,420 4,250 170 330 330 330 330

1527 33,730 2,100 350 350 590 590 590

Table E-106

Projected Old-Growth Harvest by WAA and Alternative for the WAAs where Whale Pass

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

1530 59,420 1,270 (70) (270) (400) (420) (420)

1527 33,730 630 30 (90) (120) (130) (130)

Wrangell (Kaachxana.áak’w)

Community Use Area

Wrangell’s CUA encompasses a total of 824,250 acres (Figure E-30). Approximately 40 percent is 

presently managed as roadless (Table E-107). This share would drop to 15 percent under Alternative 5, 

with no acres managed as roadless under Alternative 6. Alternative 4 includes ARA acres that would be 

managed as Timber Priority and allow timber harvest and road building. Timber Priority acres account for 

21 percent of the ARA in the Wrangell CUA. Areas allocated to Roadless Priority and Community Priority

would explicitly allow the cutting, utilization, customary trade, and removal of trees for the purposes of 

Alaska Native customary and traditional uses, as well as road construction deemed necessary by a 

federally recognized Tribe for access to Alaska Native cultural sites. This type of use would also be 

allowed in Timber Priority areas, which allow all timber harvest and road construction.
Appendix E

Communities E-106 Final EIS

Figure E-30

Wrangell’s Community Use Area

Table E-107

Roadless Areas, ARA Management Categories, and Development Opportunity in 

Wrangell's Community Use Area

Roadless Category 

(acres)

Alternative

1 2 3 4 5 6

Total Community Use Area 824,250 824,250 824,250 824,250 824,250 824,250

Total Roadless Area 327,483 307,283 273,535 273,064 124,798 0

Roadless Share 40% 37% 33% 33% 15% 0%

ARA Management Categories (acres)

LUD II Priority na 5 0 5 5 0

Watershed Priority na 184,944 24,677 0 0 0

Roadless Priority na 122,333 73,877 215,139 124,793 0

Community Priority na 0 24,677 0 0 0

Timber Priority na 0 0 57,919 0 0

Development Opportunity

Development LUDs (acres) 102,384 119,916 146,985 146,987 294,305 294,327

Timber Opportunity (Acres Suitable for Harvest)

Old-Growth 25,607 29,375 39,741 46,595 46,698 46,698

Young-Growth 26,134 27,921 28,094 28,151 28,308 28,736

Estimated Harvest over 100 Years (acres)

Old-Growth 4,793 4,891 4,888 4,929 4,856 4,856

Young-Growth 22,251 22,995 22,891 22,928 22,938 23,073

na = not applicable
Appendix E

Final EIS E-107 Communities

Not all acres removed from roadless management would be available for development. The change in 

acres in development LUDs serves as a measure of development potential as it presently exists by 

alternative. Approximately 12 percent (102,400 acres) of the Wrangell CUA is presently managed in 

development LUDs. This total would increase under all action alternatives, with net gains ranging from 

about 17,500 acres (Alternative 2) to 192,000 acres (Alternatives 5 and 6). 

Suitable old-growth and young-growth acres available for harvest would increase under all action 

alternatives. Estimated net gains in suitable old-growth range from about 3,800 acres (Alternative 2) to 

21,100 acres (Alternatives 5 and 6). Increases in suitable young-growth acres range from about 1,800 

acres (Alternative 2) to 2,600 acres (Alternative 6).

Total acres harvested are assumed to remain constant across all alternatives. Estimated old-growth harvest 

totals in the Wrangell CUA over 100 years are similar for all alternatives, ranging from about 4,800 acres 

(Alternative 1) to 4,950 acres (Alternative 6). Young-growth harvest estimates range from about 22,250 acres 

(Alternative 1) to 23,100 acres (Alternative 6) (Table E-107).

Subsistence

No significant effect on salmon, other finfish, or invertebrate habitat capability is expected from 

implementation of any alternative. These resources account for 52 percent of the total edible pounds of 

subsistence resources harvested by Wrangell households (Kruse and Frazier 1988). Marine resources 

(fish and marine invertebrates) accounted for 71 percent of per capita subsistence harvest in Wrangell in 

2000 (ADF&G 2018). 

The 1988 TRUCS study found that deer account for 21 percent of the total edible pounds of subsistence 

resources harvested by Wrangell households (Kruse and Frazier 1988). Deer accounted for 17 percent of 

per capita subsistence harvest by Wrangell residents in 2000 (ADF&G 2018). 

Deer harvest by Wrangell residents is spread over many WAAs, but the majority (76 percent) of their deer 

are from six WAAs located on Wrangell and surrounding islands. Zarembo Island (WAA 1905) alone 

accounted for 39 percent of the annual average deer harvest by Wrangell residents from 2004 to 2013. 

The Wrangell portion of the harvest in these six WAAs represents about 76 percent of the total harvest 

and about 85 percent of the rural hunter harvest (Table E-108). 

The majority of the WAAs used heavily by Wrangell residents are in areas with substantial past harvest 

and deer habitat capabilities are currently estimated to be considerably below 1954 levels (Table E-108). 

The 2016 Forest Plan Amendment EIS found that additional harvest that could occur under the current 

Forest Plan would further reduce estimated habitat capabilities after 100 years in four of the WAAs by 1 to 

6 percent (Table E-108). 

Table E-108

Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where Wrangell 

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest1

WAA

Average Deer Harvest from 2004 to 2013 Deer Habitat Capability3

Wrangell 

Residents

All Rural 

Hunters2

All 

Hunters 2014

After 100 Years of 

Implementation Change

1905 170 190 204 73% 68% 71%

1903 67 69 72 84% 80% 82%

1901 53 56 62 90% 89% 89%

1003 15 28 44 59% 55% 58%

1528 12 30 36 78% 76% 78%

1904 12 12 14 66% 67% 66% 1 Calculated based on harvest where location is known. 2 The category “All Rural Hunters” includes residents of Southeast Alaska communities, excluding the cities of Juneau and 

Ketchikan.

3 Deer habitat capability in 2014 and after 100 Years of full implementation is expressed as a percent of the 1954 habitat 

capability. Data presented for 100 Years of Implementation are estimates developed for the current Forest Plan in the 2016

Forest Plan Amendment EIS (USDA Forest Service 2016).
Appendix E

Communities E-108 Final EIS

The 2016 Forest Plan Amendment EIS analysis found that use of most subsistence resources by 

Wrangell residents (fish and marine invertebrates) was not expected to be affected by any of the 

alternatives. Based on the Deer Availability and Anticipated Demand analysis completed for the 1997 

Forest Plan EIS, the 2016 analysis found that subsistence use of deer may be affected to the point that 

some restriction on hunting might be necessary over the long term, especially for non-rural hunters. The 

risk of hunting restrictions would be reduced somewhat, through more intensive management (e.g., 

thinning) of the existing and future closed-canopy, young-growth forests in this area. 

Suitable old-growth acres would increase relative to Alternative 1 in four of the six WAAs under all of the 

action alternatives (Table E-109). Projected old-growth harvest would increase relative to Alternative 1 in 

two WAAs under most of the action alternatives, with relative decreases projected for three others (Table 

E-110). These relative changes in projected harvest are small and none of the alternatives are expected 

to affect the findings of the 2016 Forest Plan Amendment EIS.

Table E-109

Suitable Old-Growth by WAA and Alternative for the WAAs where Wrangell Residents 

Obtain Approximately 75 Percent of their Average Annual Deer Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

1905 116,400 8,960 910 1,060 3,570 3,660 3,660

1903 113,540 4,550 1,060 4,010 4,010 4,010 4,010

1901 132,790 2,560 30 1,190 2,520 3,450 3,450

1003 40,620 4,100 140 140 260 260 260

1528 24,750 10 - 10 10 10 10

1904 22,930 440 - - - - -

Table E-110

Projected Old-Growth Harvest by WAA and Alternative for the WAAs where Wrangell

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

1905 116,400 2,670 - (480) (300) (320) (320)

1903 113,540 1,360 160 510 260 230 230

1901 132,790 760 (60) 60 200 360 360

1003 40,620 1,220 (70) (290) (390) (410) (410)

1528 24,750 - - - - - -

1904 22,930 130 (10) (30) (50) (50) (50)

Yakutat (Yaakwdáat)

Community Use Area

Yakutat’s CUA encompasses a total of 249,048 acres (Figure E-31). About half of this area (53 percent) 

is presently managed as roadless (Table E-111). This share would drop to 43 percent under Alternatives 

3 to 5, with no acres managed as roadless under Alternative 6. Alternative 4 includes ARA acres that 

would be managed as Timber Priority and allow timber harvest and road building. Timber Priority acres 

account for 17 percent of the ARA in the Yakutat CUA. Areas allocated to Roadless Priority and 

Community Priority would explicitly allow the cutting, utilization, customary trade, and removal of trees for 

the purposes of Alaska Native customary and traditional uses, as well as road construction deemed 

necessary by a federally recognized Tribe for access to Alaska Native cultural sites. This type of use 

would also be allowed in Timber Priority areas, which allow all timber harvest and road construction.
Appendix E

Final EIS E-109 Communities

Figure E-31

Yakutat’s Community Use Area

Table E-111

Roadless Areas, ARA Management Categories, and Development Opportunity in 

Yakutat's Community Use Area

Roadless Category (acres)

Alternative

1 2 3 4 5 6

Total Community Use Area 249,048 249,048 249,048 249,048 249,048 249,048

Total Roadless Area 132,814 125,945 107,997 107,201 106,669 0

Roadless Share 53% 51% 43% 43% 43% 0%

ARA Management Categories (acres)

LUD II Priority na 35 0 35 35 0

Watershed Priority na 88,239 28,951 0 0 0

Roadless Priority na 37,671 565 88,948 106,634 0

Community Priority na 0 28,951 0 0 0

Timber Priority na 0 0 18,218 0 0

Development Opportunity

Development LUDs (acres) 16,107 18,721 18,721 18,721 37,166 37,166

Timber Opportunity (Acres Suitable for Harvest)

Old-Growth 62 63 63 63 63 63

Young-Growth 3,882 3,905 5,812 5,544 5,383 5,822

Estimated Harvest over 100 Years (acres)

Old-Growth 7 7 6 4 4 4

Young-Growth 3,305 3,216 4,736 4,515 4,362 4,675

na = not applicable
Appendix E

Communities E-110 Final EIS

Not all acres removed from roadless management would be available for development. The change in 

acres in development LUDs serves as a measure of development potential as it presently exists by 

alternative. Approximately 6 percent (16,100 acres) of the Yakutat CUA is presently managed in 

development LUDs. This total would increase under all action alternatives, with net gains ranging from 

about 2,600 acres (Alternatives 2 through 4) to 21,100 acres (Alternatives 5 and 6). 

Suitable old-growth acres available for harvest would remain at current negligible levels (less than 100 

acres) under all alternatives. Estimated increases in suitable young-growth acres range up to about 1,950 

acres (Alternatives 3 and 6). 

Total acres harvested are assumed to remain constant across all alternatives. No old-growth harvest is 

estimated to occur in the Yakutat CUA over 100 years. Young-growth harvest estimates range from about 

3,200 acres (Alternative 2) to 4,700 acres (Alternatives 3 and 6) (Table E-111).

Subsistence

No significant effect on salmon, other finfish, or invertebrate habitat capability is expected from 

implementation of any alternative. These resources account for 82 percent of the total edible pounds of 

subsistence resources harvested by Yakutat households (Kruse and Frazier 1988). Marine resources 

(fish and marine invertebrates) accounted for 74 percent of per capita subsistence harvest in Yakutat in 

2000 (ADF&G 2018).

Moose are more important than deer as a subsistence meat source for Yakutat residents. Moose 

availability would not be significantly affected under any of the alternatives.

The 1988 TRUCS study found that deer account for only a small fraction of the total edible pounds of 

subsistence resources harvested by Yakutat households (Kruse and Frazier 1988). Deer accounted for 1 

percent of per capita subsistence harvest by Yakutat residents in 2000 (ADF&G 2018). 

Yakutat residents harvested an annual average of 36 deer from 2004 to 2013, with four WAAs accounting 

for 76 percent of this annual average (Table E-112). The 2016 Forest Plan Amendment EIS analysis 

found that the estimated habitat capabilities in these WAAs would not be affected by the current Forest 

Plan. 

Table E-112

Deer Harvest and Deer Habitat Capability on NFS Lands for the WAAs where Yakutat 

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest1

WAA

Average Deer Harvest from 2004 to 2013 Deer Habitat Capability3

Yakutat 

Residents

All Rural 

Hunters2

All 

Hunters 2014

After 100 Years of 

Implementation Change

4504 15 15 17 100% 100% 0%

4508 7 7 7 94% 94% 0%

3315 3 38 46 84% 84% 0%

3835 3 5 141 100% 100% 0% 1 Calculated based on harvest where location is known. 2 The category “All Rural Hunters” includes residents of Southeast Alaska communities, excluding the cities of Juneau and 

Ketchikan.

3 Deer habitat capability in 2014 and after 100 Years of full implementation is expressed as a percent of the 1954 habitat 

capability. Data presented for 100 Years of Implementation are estimates developed for the current Forest Plan in the 2016 

Forest Plan Amendment EIS (USDA Forest Service 2016).

The 2016 Forest Plan Amendment EIS analysis found that use of most subsistence resources by 

Wrangell residents (fish and marine invertebrates) was not expected to be affected by any of the 

alternatives. Based on the Deer Availability and Anticipated Demand analysis completed for the 1997 

Forest Plan EIS, the 2016 analysis found that subsistence use of deer may be affected to the point that 

some restriction in hunting might be necessary over the long term, especially for non-rural hunters. The 

risk of hunting restrictions would be reduced somewhat, through more intensive management (e.g., 

thinning) of the existing and future closed-canopy, young-growth forests in this area. 
Appendix E

Final EIS E-111 Communities

Suitable old-growth acres would increase relative to Alternative 1 in one of the four WAAs under all of the 

action alternatives (Table E-113). Projected old-growth harvest would be negligible under all of the 

alternatives and none of the alternatives are expected to affect the findings of the 2016 Forest Plan 

Amendment EIS (Table E-114).

Table E-113

Suitable Old-Growth by WAA and Alternative for the WAAs where Yakutat Residents 

Obtain Approximately 75 Percent of their Average Annual Deer Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

4504 840 - - - - - -

4508 281,260 60 - - - - -

3315 43,580 990 30 30 2,080 2,080 2,080

3835 31,260 - - - - - -

Table E-114

Projected Old-Growth Harvest by WAA and Alternative for the WAAs where Yakutat

Residents Obtain Approximately 75 Percent of their Average Annual Deer Harvest

WAA Total Acres Alt 1

Change from Alternative 1 (Acres)

Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

4504 840 - - - - - -

4508 281,260 10 - - (10) (10) (10)

3315 43,580 110 - (20) 90 80 80

3835 31,260 - - - - - -

References

ADF&G (Alaska Department of Fish and Game). 2018. Community Subsistence Information System. 

Available online at: https://www.adfg.alaska.gov/sb/CSIS/

ADF&G. 2015. Deer Management Report of Survey-Inventory Activities 1 July 2012-30 June 2014. 

Alaska Department of Fish and Game, Species Management Report ADF&G/DWC/SMR-2015-3, 

Juneau. Patricia Harper and Laura A. McCarthy, editors. Available online at: 

http://www.adfg.alaska.gov/index.cfm?adfg=wildliferesearch.smr20153

Alaska DCCED (Department of Commerce, Community, and Economic Development). 2018. Search and 

Database Download Information, Business License Download. Division of Corporations, Business 

and Professional Licensing. Available online at: https://www.commerce.alaska.gov/cbp/main/

Alaska DOL (Department of Labor). 2019a. Alaska Population Estimates by Borough, Census Area, City, 

and Census Designated Place (CDP), 2010 to 2017. Last updated August 14. Available online at: 

http://live.laborstats.alaska.gov/pop/index.cfm

Alaska DOL. 2019b. Alaska and Local Regional Information (ALARI). Industries. Alaska Department of 

Labor and Workforce Development, Research and Analysis. Available online at: 

http://live.laborstats.alaska.gov/alari/

Kruse, J., and R. Frazier. 1988. Reports to the Communities of Southeast Alaska (one per community). 

Tongass Resource Use Cooperative Survey. Institute of Social and Economic Research. 

University of Alaska Anchorage.

U.S. Census Bureau. 2019a. B03002: Hispanic or Latino Origin by Race. 2014-2018 American 

Community Survey 5-Year Estimates. Available online at: https://data.census.gov/cedsci/
Appendix E

Communities E-112 Final EIS

U.S. Census Bureau. 2019b. B19013: Median Household Income in the Past 12 Months (in 2018

Inflation-Adjusted Dollars). 2014-2018 American Community Survey 5-Year Estimates. Available 

online at: https://data.census.gov/cedsci/

U.S. Census Bureau. 2019c. S1701: Poverty Status in the Past 12 Months. 2014-2018 American 

Community Survey 5-Year Estimates. Available online at: https://data.census.gov/cedsci/

USDA Forest Service. 2016. Tongass Land and Resource Management Plan. Final Environmental Impact 

Statement. Plan Amendment. Forest Service Alaska Region. Tongass National Forest. R10-MB769e, f. June. Available online at: 

https://www.fs.usda.gov/detail/tongass/landmanagement/planning/?cid=stelprd3801708

USDA Forest Service. 1997a. Tongass National Forest Land and Resource Management Plan. R10-MB338dd. USDA Forest Service, Alaska Region. 1997.

USDA Forest Service. 1997b. Tongass National Forest Land Management Plan Revision Final 

Environmental Impact Statement and Record of Decision. R10-MB-338a, b, c, e, f, g, h. USDA 

Forest Service, Alaska Region. January 1997.
APPENDIX F

TRADITIONAL TERRITORIES
Appendix F

Final EIS F-1 Traditional Territories

Appendix F

Traditional Territories

Abstract

Completed during 1946 and released during 1947, Goldschmidt and Haas’ federal government landmark 

report titled Possessory Rights of the Natives of Southeastern Alaska was an early and comprehensive 

ethnographic study of Southeast Alaska’s Tlingit and Haida peoples. The report was crafted during a 

period of time in Alaska’s history when commercial interests were working to secure additional lands and 

there was a need to collect evidence of Alaska Native land rights. Responding to the need to understand 

Alaska Native land use and possession, Goldschmidt and Haas carried out ethnographic research, 

qualitative interviews, and onsite observations to determine Southeast Alaska lands possessed by Tlingit 

and Haida peoples as evidenced by actual use and occupancy. In the decades that followed, the 

Goldschmidt and Haas report and associated maps served as the authority on the geographic areas used 

and occupied by Southeast Alaska’s Haida and Tlingit villages – and remains relevant today.

In addition to geographic analysis, Goldschmidt and Haas also made significant anthropological 

contributions regarding Tlingit and Haida culture, society, and patterns of behavior. They concluded 

Tlingit and Haida Indians had continuously used and occupied Southeast from south of the Copper River 

to the southern tip of the Alexander Archipelago. Tlingit and Haida societies were some of the most 

developed and complex indigenous societies in the United States and Canada, rich in ceremony and art 

and complex in social, legal, and political systems. Furthermore, Tlingit and Haida societies had a welldefined system of property ownership with land held by the clan or house group, with joint use extended 

to family. Land title was obtained by inheritance or as legal settlement for damages – not bought and 

sold. Land title was recorded with elaborate ceremonies, which served the purpose of publiclyacknowledging land ownership. Land title and associated rights were also sometimes recorded as 

carvings on totem poles. During 1946, Goldschmidt and Haas compelled Southeast Alaska lands still 

used and occupied by Alaska Natives should be safeguarded without further delay. 

Goldschmidt and Haas’ landmark ethnographic study remains relevant today as a comprehensive and 

historical study of land use, occupancy, and possession by Tlingit and Haida peoples across Southeast 

Alaska. Of noteworthy importance, the Sealaska Heritage Foundation reprinted the original report and 

associated maps during 1998 under the title Haa Aani: Tlingit and Haida Land Rights and Use with 

additional introductory statements, original Alaska Native witness statements, and final reflections by 

Goldschmidt.

Citation 

Goldschmidt, Water R. and Hass, Theodore H. 1946. Possessory Rights of Natives of Southeastern 

Alaska. A Report to the Commissioner of Indian Affairs. Washington, DC. 176 pages, 13 charts and 

maps, 6 photographs, and 2 appendices. 

Goldschmidt, Walter R. and Haas, Theodore H. 1998. Haa Aani, Our Land: Tlingit and Haida Land Rights 

and Use. Seattle, WA: University of Washington Press/Sealaska Heritage Foundation. 
Appendix F

Traditional Territories F-2 Final EIS

Figure F-1

Goldschmidt and Haas associated map depicting the geographic areas used and 

occupied by Southeast Alaska’s Haida and Tlingit villages (1946).
APPENDIX G 

ROADLESS RULE REGULATORY LANGUAGE BY ALTERNATIVE 
Appendix G

Final EIS G-1 Roadless Rules by Alternative

Appendix G

Roadless Rule Regulatory Language by 

Alternative

Introduction 

The following provides representational rule language for Alternatives 2 through 6. Final rule language 

could vary from what is presented in this Appendix based on comments received and other 

considerations. The 2001 Roadless Rule would remain in effect nation-wide except for Alaska, Colorado, 

and Idaho if one of the action alternatives were selected. 

Alternative 1 – No Action 

Subpart B—Protection of Inventoried Roadless Areas as published in the Federal Register on January 

12, 2001 (66 FR 3244) as reinstated by Order of the US District Court for the District of Alaska.

§ 294.10 Purpose.

The purpose of this subpart is to provide, within the context of multiple use management, lasting 

protection for inventoried roadless areas within the National Forest System.

§ 294.11 Definitions.

The following terms and definitions apply to this subpart:

Inventoried roadless areas. Areas identified in a set of inventoried roadless area maps, contained in 

Forest Service Roadless Area Conservation, Final Environmental Impact Statement, Volume 2, dated 

November 2000, which are held at the National headquarters office of the Forest Service, or any 

subsequent update or revision of those maps.

Responsible official. The Forest Service line officer with the authority and responsibility to make decisions 

regarding protection and management of inventoried roadless areas pursuant to this subpart. 

Road. A motor vehicle travelway over 50 inches wide, unless designated and managed as a trail. A road 

may be classified, unclassified, or temporary.

(1) Classified road. A road wholly or partially within or adjacent to National Forest System lands 

that is determined to be needed for long-term motor vehicle access, including State roads, county 

roads, privately owned roads, National Forest System roads, and other roads authorized by the 

Forest Service.

(2) Unclassified road. A road on National Forest System lands that is not managed as part of the 

forest transportation system, such as unplanned roads, abandoned travelways, and off-road 

vehicle tracks that have not been designated and managed as a trail; and those roads that were 

once under permit or other authorization and were not decommissioned upon the termination of 

the authorization.

(3) Temporary road. A road authorized by contract, permit, lease, other written authorization, or 

emergency operation, not intended to be part of the forest transportation system and not 

necessary for long-term resource management.

Road construction. Activity that results in the addition of forest classified or temporary road miles.
Appendix G

Roadless Rules by Alternative G-2 Final EIS

Road maintenance. The ongoing upkeep of a road necessary to retain or restore the road to the approved 

road management objective.

Road reconstruction. Activity that results in improvement or realignment of an existing classified road 

defined as follows:

(1) Road improvement. Activity that results in an increase of an existing road’s traffic service 

level, expansion of its capacity, or a change in its original design function.

(2) Road realignment. Activity that results in a new location of an existing road or portions of an 

existing road, and treatment of the old roadway.

Roadless area characteristics. Resources or features that are often present in and characterize 

inventoried roadless areas, including:

(1) High quality or undisturbed soil, water, and air;

(2) Sources of public drinking water;

(3) Diversity of plant and animal communities;

(4) Habitat for threatened, endangered, proposed, candidate, and sensitive species and for those 

species dependent on large, undisturbed areas of land;

(5) Primitive, semi-primitive nonmotorized and semi-primitive motorized classes of dispersed 

recreation;

(6) Reference landscapes;

(7) Natural appearing landscapes with high scenic quality;

(8) Traditional cultural properties and sacred sites; and

(9) Other locally identified unique characteristics.

§ 294.12 Prohibition on road construction and road reconstruction in inventoried roadless areas.

(a) A road may not be constructed or reconstructed in inventoried roadless areas of the National Forest 

System, except as provided in paragraph (b) of this section.

(b) Notwithstanding the prohibition in paragraph (a) of this section, a road may be constructed or 

reconstructed in an inventoried roadless area if the Responsible Official determines that one of the 

following circumstances exists:

(1) A road is needed to protect public health and safety in cases of an imminent threat of flood, 

fire, or other catastrophic event that, without intervention, would cause the loss of life or property;

(2) A road is needed to conduct a response action under the Comprehensive Environmental 

Response, Compensation, and Liability Act (CERCLA) or to conduct a natural resource 

restoration action under CERCLA, Section 311 of the Clean Water Act, or the Oil Pollution Act;

(3) A road is needed pursuant to reserved or outstanding rights, or as provided for by statute or 

treaty;

(4) Road realignment is needed to prevent irreparable resource damage that arises from the 

design, location, use, or deterioration of a classified road and that cannot be mitigated by road 

maintenance. Road realignment may occur under this paragraph only if the road is deemed 

essential for public or private access, natural resource management, or public health and safety;

(5) Road reconstruction is needed to implement a road safety improvement project on a classified 

road determined to be hazardous on the basis of accident experience or accident potential on 

that road;
Appendix G

Final EIS G-3 Roadless Rules by Alternative

(6) The Secretary of Agriculture determines that a Federal Aid Highway project, authorized 

pursuant to Title 23 of the United States Code, is in the public interest or is consistent with the 

purposes for which the land was reserved or acquired and no other reasonable and prudent 

alternative exists; or

(7) A road is needed in conjunction with the continuation, extension, or renewal of a mineral lease 

on lands that are under lease by the Secretary of the Interior as of January 12, 2001 or for a new 

lease issued immediately upon expiration of an existing lease. Such road construction or 

reconstruction must be conducted in a manner that minimizes effects on surface resources, 

prevents unnecessary or unreasonable surface disturbance, and complies with all applicable 

lease requirements, land and resource management plan direction, regulations, and laws. Roads 

constructed or reconstructed pursuant to this paragraph must be obliterated when no longer 

needed for the purposes of the lease or upon termination or expiration of the lease, whichever is 

sooner.

(c) Maintenance of classified roads is permissible in inventoried roadless areas.

§ 294.13 Prohibition on timber cutting, sale, or removal in inventoried roadless areas.

(a) Timber may not be cut, sold, or removed in inventoried roadless areas of the National Forest System, 

except as provided in paragraph (b) of this section.

(b) Notwithstanding the prohibition in paragraph (a) of this section, timber may be cut, sold, or removed in 

inventoried roadless areas if the Responsible Official determines that one of the following circumstances 

exists. The cutting, sale, or removal of timber in these areas is expected to be infrequent.

(1) The cutting, sale, or removal of generally small diameter timber is needed for one of the 

following purposes and will maintain or improve one or more of the roadless area characteristics 

as defined in § 294.11.

(i) To improve threatened, endangered, proposed, or sensitive species habitat; or

(ii) To maintain or restore the characteristics of ecosystem composition and structure, 

such as to reduce the risk of uncharacteristic wildfire effects, within the range of variability 

that would be expected to occur under natural disturbance regimes of the current climatic 

period;

(2) The cutting, sale, or removal of timber is incidental to the implementation of a management 

activity not otherwise prohibited by this subpart;

(3) The cutting, sale, or removal of timber is needed and appropriate for personal or 

administrative use, as provided for in 36 CFR part 223; or

(4) Roadless characteristics have been substantially altered in a portion of an inventoried 

roadless area due to the construction of a classified road and subsequent timber harvest. Both 

the road construction and subsequent timber harvest must have occurred after the area was 

designated an inventoried roadless area and prior to January 12, 2001. Timber may be cut, sold, 

or removed only in the substantially altered portion of the inventoried roadless area.

§ 294.14 Scope and applicability.

(a) This subpart does not revoke, suspend, or modify any permit, contract, or other legal instrument 

authorizing the occupancy and use of National Forest System land issued prior to January 12, 2001.

(b) This subpart does not compel the amendment or revision of any land and resource management plan.

(c) This subpart does not revoke, suspend, or modify any project or activity decision made prior to 

January 12, 2001.

(d) This subpart does not apply to road construction, reconstruction, or the cutting, sale, or removal of 

timber in inventoried roadless areas on the Tongass National Forest if a notice of availability of a draft 
Appendix G

Roadless Rules by Alternative G-4 Final EIS

environmental impact statement for such activities has been published in the Federal Register prior to 

January 12, 2001.

(e) The prohibitions and restrictions established in this subpart are not subject to reconsideration, 

revision, or rescission in subsequent project decisions or land and resource management plan 

amendments or revisions undertaken pursuant to 36 CFR part 219.

(f) If any provision of the rules in this subpart or its application to any person or to certain circumstances is 

held invalid, the remainder of the regulations in this subpart and their application remain in force.

Table G-1

2001 Inventoried Roadless Area name and approximate acres contained within that are 

subject to the prohibitions and exemptions of Alternative 1 (No Action).

2001 Inventoried Roadless 

Area Name Acres

Aaron 78,700

Anan 36,700

Bay of Pillars 27,500

Behm Islands 4,800

Brabazon Addition 498,700

Bradfield 199,000

Calder 9,900

Camden 36,800

Carroll 11,400

Castle 49,300

Central Wrangell 13,400

Chichagof 555,800

Chilkat-West Lynn Canal 199,700

Christoval 9,100

Cleveland 189,400

Cone 128,400

Crystal 19,000

Dall Island 105,800

Douglas Island 28,100

Duke 45,100

East Kuiu 27,600

East Mitkof 8,800

East Wrangell 7,600

East Zarembo 10,800

El Capitan 26,700

Eudora 195,000

Fake Pass 500

Fanshaw 48,200

Five Mile 19,500

Freshwater Bay 44,900

Frosty 39,900

Game Creek 54,500

Gravina 37,400

Green Rocks 11,100

Greens Creek 27,200

Harding 174,300

Hoonah Sound 79,800

Hydaburg 11,200

Hyder 121,700

Juneau Urban 101,600

Juneau-Skagway Icefield 1,187,100

Kadin 2,000

Karta 52,100

Kasaan 7,600
Appendix G

Final EIS G-5 Roadless Rules by Alternative

Table G-1

2001 Inventoried Roadless Area name and approximate acres contained within that are 

subject to the prohibitions and exemptions of Alternative 1 (No Action).

2001 Inventoried Roadless 

Area Name Acres

Kasaan Bay 7,400

Kashevarof Islands 4,700

Keku 10,900

Kogish 65,200

Kosciusko 64,100

Lindenberg 25,800

Madan 68,500

Mansfield Peninsula 55,000

Manzanita 8,400

McKenzie 83,100

Middle Kruzof 14,700

Missionary 16,700

Mosman 53,500

Neka Bay 7,100

Neka Mountain 6,100

North Baranof 314,000

North Cleveland 105,300

North Etolin 41,000

North Kruzof 33,100

North Kuiu 6,400

North Kupreanof 114,600

North Revilla 215,400

North Wrangell 8,100

Nutkwa 53,700

Outer Islands 99,900

Pavlof-East Point 5,400

Point Augusta 15,500

Point Craven 10,900

Port Alexander 120,700

Quartz 143,000

Ratz 5,300

Redoubt 68,300

Revilla 29,300

Rhine 23,000

Rocky Pass 78,100

Salmon Bay 22,800

Sarkar 51,900

Security 31,400

Sitka Sound 13,500

Sitka Urban 112,000

Soda Bay 78,100

South Etolin 26,300

South Kruzof 55,200

South Kuiu 62,400

South Kupreanof 216,800

South Revilla 52,100

South Wrangell 14,200

South Zarembo 36,300

Southeast Wrangell 18,400

Spires 533,700

Suemez Island 19,900

Sukkwan 44,400

Sullivan 67,300

Taku-Snettisham 664,900

Tenakee Ridge 20,500

Thorne River 73,000
Appendix G

Roadless Rules by Alternative G-6 Final EIS

Table G-1

2001 Inventoried Roadless Area name and approximate acres contained within that are 

subject to the prohibitions and exemptions of Alternative 1 (No Action).

2001 Inventoried Roadless 

Area Name Acres

Trap Bay 13,200

Twelvemile 37,900

Upper Situk 16,800

West Wrangell 10,300

West Zarembo 6,800

Whitestone 5,600

Windham-Port Houghton 161,900

Woewodski 10,100

Woronkofski 11,100

Yakutat Forelands 323,500

Alternative 2

Subpart E – Alaska Roadless Area Management

§294.50 Purpose.

The purpose of this subpart is to provide, in the context of multiple-use management for the conservation 

of roadless areas within the Tongass National Forest while providing for local concerns, including

economic and community development. This subpart sets forth the procedures for management of Alaska 

Roadless Areas.

§294.51 Definitions.

The following terms and definitions apply to this subpart.

Alaska Native. Federally recognized tribes or individuals that are enrolled or eligible to enroll as a 

member of a federally recognized tribe.

Alaska Roadless Areas. Lands within the Tongass National Forest designated pursuant to this subpart 

and identified in a set of maps maintained by the national headquarters office of the Forest Service.

Commercial Old Growth Timber Harvest. Trees, portions of trees, and other forest products originating 

from old growth stands on National Forest System lands that may be sold for the purpose of achieving the 

policies set forth in the Multiple-Use Sustained-Yield Act of 1960, as amended, the Forest and Rangeland 

Renewable Resources Planning Act of 1974, as amended, and the program thereunder. (See 36 CFR 

223.1).

Community utility system. A system that provides a community or communities with services for public 

use or consumption such as municipal water and wastewater systems, biomass heating and energy 

systems, transmission lines, and hydroelectric and other renewable energy projects and related 

infrastructure.

Responsible official. The Forest Service line officer with the authority to make and implement a decision 

on a proposed action.

Road. As defined at 36 CFR 212.1, the term means a motor vehicle route over 50 inches wide, unless 

identified and managed as a trail.

Road construction and reconstruction. As defined at 36 CFR 212.1, the terms mean supervising, 

inspecting, building, and incurrence of all costs incidental to the construction or reconstruction of a road.

Roadless Area Characteristics. Resources or features that are often present in and characterize Alaska 

Roadless Areas, including
Appendix G

Final EIS G-7 Roadless Rules by Alternative

(1) Physical Environment. Roadless areas provide high-quality or undisturbed soil, water, and air.

(2) Water. Roadless areas provide a variety of water resources including public drinking water 

sources, fish and aquatic resources, and hatchery aquatic resources. 

(3) Diversity. Roadless areas support a diversity of plant and animal communities including 

stands of old-growth forests. 

(4) Habitat. Roadless areas are expansive areas where high-quality intact habitat exists and 

ecosystems function with all their native species and components. Roadless areas may serve as 

habitat for threatened, endangered, proposed, candidate, and species of conservation concern, 

and for those species dependent on large, undisturbed areas of land. 

(5) Remoteness. Roadless areas provide rich primitive, semi-primitive motorized, and semiprimitive non-motorized classes of dispersed recreation, which are a source of ecological, social, 

and economic benefits.

(6) Landscape. Roadless areas provide reference landscapes of relatively undisturbed areas that 

serve as a barometer to measure the effects of development on other parts of the landscape.

(7) Scenery. Roadless areas have natural-appearing landscapes with high-scenic qualities that 

people value.

(8) Cultural. Roadless areas often include traditional cultural properties and sacred sites. In 

Alaska, indigenous peoples have been on national forests for more than 10,000 years and the 

forests have cultural significance.

(9) Locally-unique characteristics. Roadless areas represent geographic areas with additional 

locally-unique characteristics specific to Alaska, including: (a) important source of subsistence 

resources including terrestrial wildlife, waterfowl, mammals, fish, and plant-based resources; (b) 

rich habitat that supports multiple species of fish for personal, subsistence, sport, recreation, and 

commercial harvest; and (c) supports diverse economic opportunity that is especially important 

for rural community well-being.

Timber harvest. The cutting, removal, or sale of trees.

§294.52 Alaska Roadless Areas

(a) Designations. All National Forest System lands listed in § 294.57 are hereby designated as Alaska 

Roadless Areas. Alaska Roadless Areas established by this subpart shall constitute the exclusive set of 

National Forest System lands within the Tongass National Forest to which the provisions of this subpart 

shall apply.

(b) Roadless area management designations. Alaska Roadless Areas are subdivided into three roadless 

area management designations: LUD II Priority, Watershed Priority, and Roadless Priority.

§294.53 Road construction and reconstruction in Alaska Roadless Areas. 

(a) A road may not be constructed or reconstructed in Alaska Roadless Areas, except as provided in 

paragraphs (b), (c), (d), and (e) of this section.

(b) Alaska Roadless Areas. Notwithstanding the prohibition in paragraph (a) of this section, road 

construction or reconstruction in any Alaska Roadless Area regardless of the roadless area management 

designation is allowed for the following exceptions:

(1) A mandatory road authorization pursuant to reserved or outstanding rights, or as provided for 

by statute or treaty. Examples of mandatory statutory authorizations include but are not limited to 

roads pursuant to the Alaska National Interest Lands Conservation Act (P.L. 96-487), Section 

4407 of the Safe, Accountable, Flexible, Efficient Transportation Equity Act (P.L. 109-59);and 

General Mining Law of 1872 (as amended);
Appendix G

Roadless Rules by Alternative G-8 Final EIS

(2) A road to conduct a response action under the Comprehensive Environmental Response, 

Compensation, and Liability Act (CERCLA) or to conduct a natural resource restoration action 

under CERCLA, Section 311 of the Clean Water Act, or the Oil Pollution Act;

(3) A Federal Aid Highway project, authorized pursuant to Title 23 of the United States Code;

(4) A road realignment to prevent irreparable resource damage that arises from the design, 

location, use, or deterioration of a road and cannot be mitigated by road maintenance;

(5) A road reconstruction safety improvement project on a classified road; or

(6) A road to protect public health and safety in cases of an imminent threat of flood, fire, or other 

catastrophic event that, without intervention, would cause the loss of life or property.

(c) LUD II Priority. Notwithstanding the prohibition in paragraph (a) of this section, road construction or 

reconstruction in an Alaska Roadless Area designated as LUD II Priority is allowed if consistent with the 

legislated management restrictions established in Section 201 of the Tongass Timber Reform Act.

(d) Watershed Priority. With the exception of the authorities provided in paragraph (b), a road may not be 

constructed or reconstructed in an Alaska Roadless Area designated as Watershed Priority.

(e) Roadless Priority. Notwithstanding the prohibition in paragraph (a) of this section, road construction or 

reconstruction in an Alaska Roadless Area designated as Roadless Priority is allowed for the following 

exceptions:

(1) A road for the construction, expansion, or maintenance of facilities such as airports, marine 

access points, and communication equipment;

(2) A road to provide access to Alaska Native cultural site(s) if requested by an affected federallyrecognized tribe(s); 

(3) A road for transportation needs identified by the State of Alaska’s Southeast Alaska 

Transportation Plan for the connection of communities and development of the regional 

transportation system;

(4) A road within a designated experimental forest for research or administration or to provide 

administrative access to a designated experimental forest;

(5) A road for the construction, expansion, or maintenance of a community utility system; or

(6) A road in conjunction with the construction, expansion, or maintenance of an authorized 

fishway, hatchery, or aquaculture facility.

§294.54 Timber harvest in Alaska Roadless Areas.

(a) Timber harvest is prohibited in Alaska Roadless Areas except as provided in paragraph (b), (c), (d),

and (e) of this section. 

(b) Alaska Roadless Areas. Notwithstanding the prohibition in paragraph (a) of this section, timber harvest

in any Alaska Roadless Area regardless of the roadless area management designation is allowed for the 

following exceptions:

(1) Timber harvest conducted pursuant to reserved or outstanding rights or as provided for by 

statute or treaty,

(2) Timber harvest to protect public health and safety in cases of an imminent threat of flood, fire, 

or other catastrophic event that, without intervention, would cause the loss of life or property, 

including removal of hazard trees; 

(3) Timber harvest for personal or administrative use, as provided for in 36 CFR part 223; or
Appendix G

Final EIS G-9 Roadless Rules by Alternative

(4) Timber harvest incidental to the implementation of a management activity not otherwise 

prohibited by this subpart, including the construction or reconstruction of a road pursuant to 

§294.53 or the construction, expansion, or maintenance of authorized fishways, fish hatcheries, 

and aquaculture facilities.

(c) LUD II Priority. Notwithstanding the prohibition in paragraph (a) of this section, timber harvest in an 

Alaska Roadless Area designated as LUD II Priority is allowed if consistent with the legislated 

management restrictions established in Section 201 of the Tongass Timber Reform Act.

(d) Watershed Priority. Notwithstanding the prohibitions in paragraph (a) of this section, timber harvest in 

an Alaska Roadless Area designated as Watershed Priority is allowed for the following exceptions:

(1) The cutting, customary trade, and removal of trees for the purposes of Alaska Native 

customary and traditional uses that does not degrade water quality, fish habitat, fish production, 

fish passage, aquatic diversity, or soil productivity;

(2) Timber harvest for one of the following purposes that will maintain, restore, or improve one or 

more of the purposes:

(i) To maintain, restore or improve fish and wildlife habitat; or

(ii) To maintain, restore, or improve the characteristics of ecosystem composition,

structure, and processes; or

(3) Timber harvest is incidental to trail or recreation development that does not degrade water 

quality, fish habitat, fish production, fish passage, aquatic biodiversity, or soil productivity.

(e) Roadless Priority. Notwithstanding the prohibition in paragraph (a) of this section, timber harvest in an 

Alaska Roadless Area designated as Roadless Priority is allowed for the following exceptions:

(1) Timber harvest for the cutting, customary trade, and removal of trees for the purposes of 

Alaska Native customary and traditional uses;

(2) Timber harvest for one of the following purposes that will maintain, restore or improve one or 

more of the following purposes:

(i) To maintain, restore, or improve fish and wildlife habitat; or

(ii) To maintain, restore, or improve the characteristics of ecosystem composition, 

structure, and processes;

(3) Timber harvest within a designated experimental forest for research or administration; or

(4) Timber harvest for the construction, expansion, utilization, or maintenance of community utility 

systems; or

(5) Timber harvest is incidental to trail or recreation development that does not degrade water 

quality, fish habitat, fish production, fish passage, aquatic biodiversity, or soil productivity.

§294.55 Corrections and modifications.

Administrative correction or modification of designations made pursuant to this subpart may be made as 

follows:

(a) Administrative corrections to boundaries. The Chief of the Forest Service may issue administrative 

corrections to the boundaries or classifications of an Alaska Roadless Area after a 30-day public notice 

and opportunity to comment period. Administrative corrections are limited to adjustments that remedy 

clerical errors, typographical errors, mapping errors, or improvements in mapping technology. 

(b) Administrative modifications to Classifications and Boundaries. The Chief of the Forest Service may 

issue modifications to the boundaries or classifications of an Alaska Roadless Area after a 45-day public 

notice and opportunity to comment period. 
Appendix G

Roadless Rules by Alternative G-10 Final EIS

§294.56 Scope and applicability.

(a) After [final rule effective date], the Roadless Area Conservation Rule (66 FR 3244) published on 

January 12, 2001, shall have no effect within the Tongass National Forest.

(b) This subpart does not revoke, suspend, or modify any permit, contract, or other legal instrument 

authorizing the occupancy and use of National Forest System land issued prior to the effective date of 

this subpart.

(c) This subpart does not revoke, suspend, or modify any project or activity decision made prior to the 

effective date of this subpart.

(d) The provisions set forth in this subpart shall take precedence over any inconsistent land management 

plan component of the Tongass Land and Resource Management Plan. Land management plan 

components that are not inconsistent with this subpart will continue to provide guidance for projects and 

activities within Alaska Roadless Areas. This subpart does not compel the amendment or revision of any 

land management plan, but the Tongass Forest Supervisor shall issue a ministerial Notice of 

Administrative Change pursuant to 36 CFR 219.13(c) identifying plan changes made in conformance with 

the regulatory determinations of this subpart, including rescission of the portion of the December 9, 2016, 

Record of Decision concerning suitable timber lands attributed exclusively to implementation of the 

January 12, 2001, Roadless Area Conservation Rule (66 FR 3244).

(e) The prohibitions and permissions set forth in this subpart are not subject to reconsideration, revision, 

or rescission in subsequent project decisions or land and resource management plan amendments or 

revisions undertaken pursuant to 36 CFR part 219.

(f) Nothing in this subpart waives any applicable requirements regarding site-specific environmental 

analysis, public involvement, consultation with Tribes and other agencies, or compliance with other 

applicable laws.

(g) If any provision of the rules in this subpart or its application to any person or to certain circumstances 

is held invalid, the remainder of the regulations in this subpart and their application remain in force.

§294.57 List of designated Alaska Roadless Areas Alternative 2.

Table G-2

Alaska Roadless Area name and approximate acres contained within that 

are subject to the prohibitions and exemptions of Alternative 2.

Alaska Roadless Area 

Name LUD II (Acres) Watershed Priority (Acres)

Roadless Priority 

(Acres)

Aaron 58,900 0 20,500

Alaska Roadless Area Islands 10,900 3,500 15,500

Anan 0 37,900 0

Bay of Pillars 5,800 20,300 1,300

Behm Islands 3,200 0 0

Brabazon Addition 0 0 499,900

Bradfield 20,000 0 178,000

Calder 200 8,500 0

Camden 30,100 0 5,800

Carroll 0 0 9,400

Castle 31,100 0 18,800

Central Wrangell 5,000 0 8,100

Chichagof 211,000 237,100 123,100

Chilkat-West Lynn Canal 98,900 0 95,700

Christoval 0 0 8,600

Cleveland 177,700 0 8,600

Cone 0 0 128,000

Crystal 9,800 0 8,700

Dall Island 64,100 0 43,900

Douglas Island 0 0 24,000
Appendix G

Final EIS G-11 Roadless Rules by Alternative

Table G-2

Alaska Roadless Area name and approximate acres contained within that 

are subject to the prohibitions and exemptions of Alternative 2.

Alaska Roadless Area 

Name LUD II (Acres) Watershed Priority (Acres)

Roadless Priority 

(Acres)

Duke 39,200 0 5,900

East Kuiu 32,800 3,100 4,600

East Mitkof 0 0 7,900

East Wrangell 6,100 0 1,200

East Zarembo 0 0 10,300

El Capitan 4,400 7,500 14,100

Eudora 105,500 0 90,700

Fake Pass 0 0 600

Fanshaw 31,700 0 16,700

Five Mile 11,100 0 9,300

Freshwater Bay 0 0 44,300

Frosty 17,000 0 16,800

Game Creek 3,300 0 44,300

Gravina 24,300 0 13,400

Green Rocks 2,600 0 7,100

Greens Creek 0 0 27,200

Harding 138,400 100 36,900

Hoonah Sound 43,000 51,300 0

Hydaburg 7,400 4,600 1,600

Hyder 0 0 122,000

Juneau Urban 66,700 6,200 28,000

Juneau-Skagway Icefield 138,400 39,300 1,028,200

Kadin 0 0 2,000

Karta 7,500 0 40,000

Kasaan 0 0 7,600

Kasaan Bay 0 0 2,700

Kashevarof Islands 0 0 4,700

Keku 0 0 9,000

Kogish 32,600 0 25,900

Kosciusko 3,600 47,600 12,100

Lindenberg 0 0 21,000

Madan 68,200 0 1,300

Mansfield Peninsula 0 0 53,000

Manzanita 0 0 8,300

McKenzie 43,200 0 30,000

Middle Kruzof 7,100 0 7,500

Missionary 0 0 14,500

Mosman 52,300 0 1,400

Neka Bay 4,700 0 2,300

Neka Mountain 3,800 0 4,600

North Baranof 176,000 0 145,500

North Cleveland 75,100 0 34,200

North Etolin 22,300 0 13,000

North Kruzof 20,300 0 11,300

North Kuiu 4,400 0 5,300

North Kupreanof 2,800 0 101,400

North Revilla 77,100 31,400 101,200

North Wrangell 0 0 6,800

Nutkwa 16,200 21,500 4,900

Outer Islands 10,100 74,000 14,900

Pavlof-East Point 0 0 4,800

Point Augusta 0 0 15,300

Point Craven 8,500 0 2,200

Port Alexander 0 0 125,000

Quartz 0 0 146,500

Ratz 4,100 0 1,900
Appendix G

Roadless Rules by Alternative G-12 Final EIS

Table G-2

Alaska Roadless Area name and approximate acres contained within that 

are subject to the prohibitions and exemptions of Alternative 2.

Alaska Roadless Area 

Name LUD II (Acres) Watershed Priority (Acres)

Roadless Priority 

(Acres)

Redoubt 52,500 0 16,100

Revilla 0 0 30,100

Rhine 12,800 0 10,000

Rocky Pass 71,600 100 5,200

Salmon Bay 0 10,200 13,100

Sarkar 16,300 23,900 10,700

Security 24,200 0 6,600

Sitka Sound 7,500 0 5,700

Sitka Urban 20,300 0 92,500

Soda Bay 46,100 0 16,100

South Etolin 7,000 0 19,600

South Kruzof 53,300 0 1,000

South Kuiu 12,900 0 49,400

South Kupreanof 157,500 33,200 14,500

South Revilla 22,300 0 29,700

South Wrangell 4,000 0 10,100

South Zarembo 0 0 28,500

Southeast Wrangell 8,500 0 9,900

Spires 37,700 0 500,700

Suemez Island 16,500 0 7,600

Sukkwan 18,800 28,800 0

Sullivan 16,100 0 49,600

Taku-Snettisham 395,600 0 303,600

Tenakee Ridge 0 0 20,600

Thomas

Thorne River 29,000 19,700 23,100

Trap Bay 0 6,400 6,800

Twelvemile 0 0 27,300

Upper Situk 10,100 0 700

West Wrangell 3,500 0 1,200

West Zarembo 0 0 6,600

Whitestone 0 0 5,900

Windham-Port Houghton 101,500 0 58,600

Woewodski 10,300 0 0

Woronkofski 11,000 0 0

Yakutat Forelands 78,100 137,500 106,900

Alternative 3

Subpart E – Alaska Roadless Area Management

§294.50 Purpose.

The purpose of this subpart is to provide, in the context of multiple-use management for the conservation 

of roadless areas within the Tongass National Forest while providing for local concerns, including

economic and community development. This subpart sets forth the procedures for management of Alaska 

Roadless Areas.

§294.51 Definitions.

The following terms and definitions apply to this subpart.

Alaska Native. Federally recognized tribes or individuals that are enrolled or eligible to enroll as a 

member of a federally recognized tribe.
Appendix G

Final EIS G-13 Roadless Rules by Alternative

Alaska Roadless Areas. Lands within the Tongass National Forest designated pursuant to this subpart 

and identified in a set of maps maintained by the national headquarters office of the Forest Service.

Commercial Old Growth Timber Harvest. Trees, portions of trees, and other forest products originating 

from old growth stands on National Forest System lands that may be sold for the purpose of achieving the 

policies set forth in the Multiple-Use Sustained-Yield Act of 1960 as amended, the Forest and Rangeland 

Renewable Resources Planning Act of 1974 as amended, and the program thereunder. (See 36 CFR 

223.1).

Community utility system. A system that provides a community or communities with services for public 

use or consumption such as municipal water and wastewater systems, biomass heating and energy 

systems, transmission lines, and hydroelectric and other renewable energy projects and related 

infrastructure.

Responsible official. The Forest Service line officer with the authority to make and implement a decision 

on a proposed action.

Road. As defined at 36 CFR 212.1, the term means a motor vehicle route over 50 inches wide, unless 

identified and managed as a trail.

Road construction and reconstruction. As defined at 36 CFR 212.1, the terms mean supervising, 

inspecting, building, and incurrence of all costs incidental to the construction or reconstruction of a road.

Roadless Area Characteristics. Resources or features that are often present in and characterize Alaska 

Roadless Areas, including

(1) Physical Environment. Roadless areas provide high-quality or undisturbed soil, water, and air.

(2) Water. Roadless areas provide a variety of water resources including public drinking water 

sources, fish and aquatic resources, and hatchery aquatic resources. 

(3) Diversity. Roadless areas support a diversity of plant and animal communities including 

stands of old-growth forests. 

(4) Habitat. Roadless areas are expansive areas where high-quality intact habitat exists and 

ecosystems function with all their native species and components. Roadless areas may serve as 

habitat for threatened, endangered, proposed, candidate, and species of conservation concern, 

and for those species dependent on large, undisturbed areas of land.

(5) Remoteness. Roadless areas provide rich primitive, semi-primitive motorized, and semiprimitive non-motorized classes of dispersed recreation, which are a source of ecological, social, 

and economic benefits.

(6) Landscape. Roadless areas provide reference landscapes of relatively undisturbed areas that 

serve as a barometer to measure the effects of development on other parts of the landscape.

(7) Scenery. Roadless areas have natural-appearing landscapes with high-scenic qualities that 

people value.

(8) Cultural. Roadless areas often include traditional cultural properties and sacred sites. In 

Alaska, indigenous peoples have been on national forests for more than 10,000 years and the 

forests have cultural significance.

(9) Locally-unique characteristics. Roadless areas represent geographic areas with additional 

locally-unique characteristics specific to Alaska, including: (a) important source of subsistence 

resources including terrestrial wildlife, waterfowl, mammals, fish, and plant-based resources; (b) 

rich habitat that supports multiple species of fish for personal, subsistence, sport, recreation, and 

commercial harvest; and (c) supports diverse economic opportunity that is especially important 

for rural community well-being.

Timber harvest. The cutting, removal, or sale of trees.
Appendix G

Roadless Rules by Alternative G-14 Final EIS

§294.52 Alaska Roadless Areas 

(a) Designations. All National Forest System lands listed in § 294.57 are hereby designated as Alaska 

Roadless Areas. Alaska Roadless Areas established by this subpart shall constitute the exclusive set of 

National Forest System lands within the Tongass National Forest to which the provisions of this subpart 

shall apply.

(b) Roadless area management designations. Alaska Roadless Areas are subdivided into three roadless 

area management designations: Watershed Priority, Roadless Priority, and Community Priority.

§294.53 Road construction and reconstruction in Alaska Roadless Areas. 

(a) A road may not be constructed or reconstructed in Alaska Roadless Areas, except as provided in 

paragraphs (b), (c), (d), and (e) of this section.

(b) Alaska Roadless Areas. Notwithstanding the prohibition in paragraph (a) of this section, road 

construction or reconstruction in any Alaska Roadless Area regardless of the roadless area management 

designation is allowed for the following exceptions:

(1) A mandatory road authorization pursuant to reserved or outstanding rights, or as provided for 

by statute or treaty. Examples of mandatory statutory authorizations include but are not limited to 

roads pursuant to the Alaska National Interest Lands Conservation Act (P.L. 96-487), Section 

4407 of the Safe, Accountable, Flexible, Efficient Transportation Equity Act (P.L. 109-59);and 

General Mining Law of 1872 (as amended);

(2) A road to conduct a response action under the Comprehensive Environmental Response, 

Compensation, and Liability Act (CERCLA) or to conduct a natural resource restoration action 

under CERCLA, Section 311 of the Clean Water Act, or the Oil Pollution Act;

(3) A Federal Aid Highway project, authorized pursuant to Title 23 of the United States Code;

(4) A road realignment to prevent irreparable resource damage that arises from the design, 

location, use, or deterioration of a road and cannot be mitigated by road maintenance

(5) A road reconstruction safety improvement project on a classified road; or

(6) A road to protect public health and safety in cases of an imminent threat of flood, fire, or other 

catastrophic event that, without intervention, would cause the loss of life or property.

(c) Watershed Priority. With the exception of the authorities provided in paragraph (b), a road may not be 

constructed or reconstructed in an Alaska Roadless Area designated as Watershed Priority.

(d) Roadless Priority. Roadless Priority. Notwithstanding the prohibition in paragraph (a) of this section, 

road construction or reconstruction in an Alaska Roadless Area designated as Roadless Priority is 

allowed for the following exceptions:

(1) A road for the construction, expansion, or maintenance of facilities such as airports, marine 

access points, and communication equipment;

(2) A road to provide access to Alaska Native cultural site(s) if requested by an affected federallyrecognized tribe(s); 

(3) A road for transportation needs identified by the State of Alaska’s Southeast Alaska 

Transportation Plan for the connection of communities and development of the regional 

transportation system;

(4) A road within a designated experimental forest for research or administration or to provide 

administrative access to a designated experimental forest;

(5) A road for the construction, expansion, or maintenance of a community utility system; or
Appendix G

Final EIS G-15 Roadless Rules by Alternative

(6) A road in conjunction with the construction, expansion, or maintenance of an authorized 

fishway, fish hatchery, or aquaculture facility.

(d) Community Priority. Notwithstanding the prohibition in paragraph (a) of this section, road construction 

or reconstruction in an Alaska Roadless Area designated as Community Priority is allowed for the 

following exceptions:

(1) A road to provide access to Alaska Native cultural site(s) if requested by an affected federallyrecognized tribe(s);

(2) A road for micro sales, salvage sales, and small commercial sales less than one million board 

feet of timber;

(3) A road for the construction, expansion, or maintenance of facilities such as airports, marine 

access points, and communication equipment;

(4) A road for the construction, expansion, or maintenance of a community utility system;

(5) A road in conjunction with the construction, expansion, or maintenance of an authorized 

fishway, fish hatchery, or aquaculture facility; or

(6) A road in conjunction with the construction, expansion, or maintenance of a developed 

recreation site.

§294.54 Timber harvest in Alaska Roadless Areas.

(a) Timber harvest is prohibited in Alaska Roadless Areas except as provided in paragraph (b), (c), (d),

and (e) of this section. Additionally, except as provided in paragraph (d), commercial old-growth timber 

harvest is prohibited on National Forest System lands as depicted in a map maintained by Chief’s Office 

that identifies high priority watersheds that largely coincide with Alaska Roadless Areas, but can extend 

beyond Alaska Roadless Area boundaries.

(b) Alaska Roadless Areas. Notwithstanding the prohibition in paragraph (a) of this section, timber harvest

in any Alaska Roadless Area regardless of the roadless area management designation is allowed for the 

following exceptions:

(1) Timber harvest conducted pursuant to reserved or outstanding rights or as provided for by 

statute or treaty,

(2) Timber harvest to protect public health and safety in cases of an imminent threat of flood, fire, 

or other catastrophic event that, without intervention, would cause the loss of life or property, 

including removal of hazard trees; 

(3) Timber harvest for personal or administrative use, as provided for in 36 CFR part 223; or

(4) Timber harvest incidental to the implementation of a management activity not otherwise 

prohibited by this subpart, including the construction or reconstruction of a road pursuant to 

§294.53 or the construction, expansion, or maintenance of authorized fishways, fish hatcheries, 

and aquaculture facilities.

(d) Watershed Priority. Notwithstanding the prohibitions in paragraph (a) of this section, timber harvest 

may occur in an Alaska Roadless Area designated as Watershed Priority is allowed for the following 

exceptions:

(1) The cutting, customary trade, and removal of trees for the purposes of Alaska Native 

customary and traditional uses that does not degrade water quality, fish habitat, fish production, 

fish passage, aquatic diversity, or soil productivity;

(2) Timber harvest for one of the following purposes that will maintain, restore, or improve one or 

more of the purposes:
Appendix G

Roadless Rules by Alternative G-16 Final EIS

(i) To maintain, restore or improve fish and wildlife habitat; or

(ii) To maintain, restore, or improve the characteristics of ecosystem composition, 

structure, and processes;

(3) Timber harvest is incidental to trail or recreation development that does not degrade water 

quality, fish habitat, fish production, fish passage, aquatic biodiversity, or soil productivity.

(e) Roadless Priority. Notwithstanding the prohibition in paragraph (a) of this section, timber harvest in an 

Alaska Roadless Area designated as Roadless Priority is allowed for the following exceptions:

(1) Timber harvest for the cutting, customary trade, and removal of trees for the purposes of 

Alaska Native customary and traditional uses;

(2) Timber harvest for one of the following purposes that will maintain, restore or improve one or 

more of the following purposes:

(i) To maintain, restore, or improve fish and wildlife habitat; or

(ii) To maintain, restore, or improve the characteristics of ecosystem composition, 

structure, and processes;

(3) Timber harvest within a designated experimental forest for research or administration;

(4) Timber harvest for the construction, expansion, utilization, or maintenance of community utility

systems; or

(5) Timber harvest is incidental to trail or recreation development that does not degrade water 

quality, fish habitat, fish production, fish passage, aquatic biodiversity, or soil productivity.

(d) Community Priority. Notwithstanding the prohibition in paragraph (a) of this section, timber harvest in 

an Alaska Roadless Area designated as Community Priority is allowed for the following exceptions:

(1) The cutting, customary trade, and removal of trees is for the purpose of Alaska Native 

customary and traditional uses;

(2) Timber harvest for micro sales, salvage sales, or small commercial sales less than one million 

board feet of timber;

(3) Timber harvest for one of the following purposes that will maintain, restore or improve one or 

more of the following purposes:

(i) To maintain, restore, or improve fish and wildlife habitat; or

(ii) To maintain, restore, or improve the characteristics of ecosystem composition, 

structure, and processes; or

(4) Timber harvest for the construction, expansion, utilization, or maintenance of a community 

utility system.

§294.55 Corrections and modifications.

Administrative correction or modification of designations made pursuant to this subpart may be made as 

follows:

(a) Administrative corrections to boundaries. The Chief of the Forest Service may issue administrative 

corrections to the boundaries or classifications of an Alaska Roadless Area after a 30-day public notice 

and opportunity to comment period. Administrative corrections are limited to adjustments that remedy 

clerical errors, typographical errors, mapping errors, or improvements in mapping technology. 
Appendix G

Final EIS G-17 Roadless Rules by Alternative

(b) Administrative modifications to Classifications and Boundaries. The Chief of the Forest Service may 

issue modifications to the boundaries or classifications of an Alaska Roadless Area after a 45-day public 

notice and opportunity to comment period. 

§294.56 Scope and applicability.

(a) After [final rule effective date], the Roadless Area Conservation Rule (66 FR 3244) published on 

January 12, 2001, shall have no effect within the Tongass National Forest.

(b) This subpart does not revoke, suspend, or modify any permit, contract, or other legal instrument 

authorizing the occupancy and use of National Forest System land issued prior to the effective date of 

this subpart.

(c) This subpart does not revoke, suspend, or modify any project or activity decision made prior to the 

effective date of this subpart.

(d The provisions set forth in this subpart shall take precedence over any inconsistent land management 

plan component of the Tongass Land and Resource Management Plan. Land management plan 

components that are not inconsistent with this subpart will continue to provide guidance for projects and 

activities within Alaska Roadless Areas. This subpart does not compel the amendment or revision of any 

land management plan, but the Tongass Forest Supervisor shall issue a ministerial Notice of 

Administrative Change pursuant to 36 CFR 219.13(c) identifying plan changes made in conformance with 

the regulatory determinations of this subpart, including rescission of the portion of the December 9, 2016, 

Record of Decision concerning suitable timber lands attributed exclusively to implementation of the 

January 12, 2001, Roadless Area Conservation Rule (66 FR 3244).

(e) The prohibitions and permissions set forth in this subpart are not subject to reconsideration, revision, 

or rescission in subsequent project decisions or land and resource management plan amendments or 

revisions undertaken pursuant to 36 CFR part 219.

(f) Nothing in this subpart waives any applicable requirements regarding site-specific environmental 

analysis, public involvement, consultation with Tribes and other agencies, or compliance with other 

applicable laws.

(g) If any provision of the rules in this subpart or its application to any person or to certain circumstances 

is held invalid, the remainder of the regulations in this subpart and their application remain in force.

§294.57 List of designated Alaska Roadless Areas Alternative 3

Table G-3

Alaska Roadless Area name and approximate acres contained within that are subject 

to the prohibitions and exemptions of Alternative 3.

Alaska Roadless Area 

Name

Watershed Priority 

(acres)

Roadless Priority 

(acres)

Community Priority 

(acres)

Aaron 58,900 20,500 0

Alaska Roadless Area Islands 10,900 15,000 600

Anan 0 0 0

Bay of Pillars 5,800 1,300 0

Behm Islands 3,200 0 0

Brabazon Addition 0 499,900 0

Bradfield 20,000 178,000 0

Calder 100 0 0

Camden 30,100 200 100

Carroll 0 3,700 5,600

Castle 31,100 18,800 0

Central Wrangell 5,000 0 8,100

Chichagof 211,000 114,900 0

Chilkat-West Lynn Canal 98,900 95,700 0

Christoval 0 8,600 0

Cleveland 177,700 8,600 0
Appendix G

Roadless Rules by Alternative G-18 Final EIS

Table G-3

Alaska Roadless Area name and approximate acres contained within that are subject 

to the prohibitions and exemptions of Alternative 3.

Alaska Roadless Area 

Name

Watershed Priority 

(acres)

Roadless Priority 

(acres)

Community Priority 

(acres)

Cone 0 128,000 0

Crystal 9,800 7,400 0

Dall Island 64,100 43,900 0

Douglas Island 0 0 24,000

Duke 39,200 5,900 0

East Kuiu 32,800 4,600 0

East Mitkof 0 7,900 0

East Wrangell 6,100 0 0

East Zarembo 0 10,300 0

El Capitan 4,400 13,500 0

Eudora 105,500 90,200 0

Fake Pass 0 600 0

Fanshaw 31,700 16,700 0

Five Mile 11,100 5,200 0

Freshwater Bay 0 44,300 0

Frosty 15,100 14,900 0

Game Creek 3,300 42,800 0

Gravina 24,300 3,000 10,400

Green Rocks 2,600 6,700 0

Greens Creek 0 27,200 0

Harding 138,400 36,900 0

Hoonah Sound 43,000 0 0

Hydaburg 7,400 1,600 0

Hyder 0 122,000 0

Juneau Urban 66,700 5,500 22,500

Juneau-Skagway Icefield 138,400 1,004,500 23,700

Kadin 0 2,000 0

Karta 7,400 28,500 0

Kasaan 0 7,600 0

Kasaan Bay 0 0 0

Kashevarof Islands 0 4,700 0

Keku 0 2,000 7,000

Kogish 31,500 500 0

Kosciusko 3,600 7,600 0

Lindenberg 0 9,400 0

Madan 68,200 1,300 0

Mansfield Peninsula 0 53,000 0

Manzanita 0 5,700 0

McKenzie 42,500 23,100 900

Middle Kruzof 7,100 7,500 0

Missionary 0 9,100 0

Mosman 52,300 400 0

Neka Bay 4,700 2,300 0

Neka Mountain 3,800 4,600 0

North Baranof 176,000 145,200 300

North Cleveland 75,100 34,200 0

North Etolin 15,100 7,100 0

North Kruzof 20,300 11,300 0

North Kuiu 4,400 5,300 0

North Kupreanof 2,800 13,400 76,600

North Revilla 77,000 70,900 10,400

North Wrangell 0 0 0

Nutkwa 16,200 4,900 0

Outer Islands 10,100 14,900 0

Pavlof-East Point 0 4,500 0

Point Augusta 0 12,400 0
Appendix G

Final EIS G-19 Roadless Rules by Alternative

Table G-3

Alaska Roadless Area name and approximate acres contained within that are subject 

to the prohibitions and exemptions of Alternative 3.

Alaska Roadless Area 

Name

Watershed Priority 

(acres)

Roadless Priority 

(acres)

Community Priority 

(acres)

Point Craven 8,500 2,200 0

Port Alexander 0 125,000 0

Quartz 0 146,500 0

Ratz 4,100 1,900 0

Redoubt 52,500 11,700 4,400

Revilla 0 700 27,100

Rhine 12,800 3,100 6,800

Rocky Pass 71,600 400 4,800

Salmon Bay 0 8,300 0

Sarkar 15,500 9,100 0

Security 24,200 5,000 0

Sitka Sound 7,500 5,700 0

Sitka Urban 20,300 39,900 52,600

Soda Bay 46,100 1,800 12,600

South Etolin 7,000 19,000 0

South Kruzof 53,300 1,000 0

South Kuiu 12,900 49,400 0

South Kupreanof 157,500 12,000 2,400

South Revilla 22,300 11,200 5,000

South Wrangell 4,000 0 10,100

South Zarembo 0 24,900 0

Southeast Wrangell 8,500 0 6,400

Spires 37,700 493,000 0

Suemez Island 16,500 7,600 0

Sukkwan 18,800 0 0

Sullivan 16,100 49,600 0

Taku-Snettisham 395,600 302,600 900

Tenakee Ridge 0 15,500 0

Thomas

Thorne River 29,000 9,200 0

Trap Bay 0 0 0

Twelvemile 0 1,600 17,900

Upper Situk 400 200 0

West Wrangell 700 0 0

West Zarembo 0 6,600 0

Whitestone 0 5,900 0

Windham-Port Houghton 101,500 58,600 0

Woewodski 10,300 0 0

Woronkofski 11,000 0 0

Yakutat Forelands 78,100 64,000 28,700

Alternative 4

Subpart E – Alaska Roadless Area Management

§294.50 Purpose.

The purpose of this subpart is to provide, in the context of multiple-use management for the conservation 

of roadless areas within the Tongass National Forest while providing for local concerns, including

economic and community development. This subpart sets forth the procedures for management of Alaska 

Roadless Areas.

§294.51 Definitions.

The following terms and definitions apply to this subpart.
Appendix G

Roadless Rules by Alternative G-20 Final EIS

Alaska Native. Federally recognized tribes or individuals that are enrolled or eligible to enroll as a 

member of a federally recognized tribe.

Alaska Roadless Areas. Lands within the Tongass National Forest designated pursuant to this subpart 

and identified in a set of maps maintained by the national headquarters office of the Forest Service.

Commercial Old Growth Timber Harvest. Trees, portions of trees, and other forest products originating 

from old growth stands on National Forest System lands that may be sold for the purpose of achieving the 

policies set forth in the Multiple-Use Sustained-Yield Act of 1960, as amended, the Forest and Rangeland 

Renewable Resources Planning Act of 1974, as amended, and the program thereunder. (See 36 CFR 

223.1).

Community utility system. A system that provides a community or communities with services for public 

use or consumption such as municipal water and wastewater systems, biomass heating and energy 

systems, transmission lines, and hydroelectric and other renewable energy projects and related 

infrastructure.

Responsible official. The Forest Service line officer with the authority to make and implement a decision 

on a proposed action.

Road. As defined at 36 CFR 212.1, the term means a motor vehicle route over 50 inches wide, unless 

identified and managed as a trail.

Road construction and reconstruction. As defined at 36 CFR 212.1, the terms mean supervising, 

inspecting, building, and incurrence of all costs incidental to the construction or reconstruction of a road.

Roadless Area Characteristics. Resources or features that are often present in and characterize Alaska 

Roadless Areas, including

(1) Physical Environment. Roadless areas provide high-quality or undisturbed soil, water, and air.

(2) Water. Roadless areas provide a variety of water resources including public drinking water 

sources, fish and aquatic resources, and hatchery aquatic resources. 

(3) Diversity. Roadless areas support a diversity of plant and animal communities including 

stands of old-growth forests. 

(4) Habitat. Roadless areas are expansive areas where high-quality intact habitat exists and 

ecosystems function with all their native species and components. Roadless areas may serve as 

habitat for threatened, endangered, proposed, candidate, and species of conservation concern, 

and for those species dependent on large, undisturbed areas of land.

(5) Remoteness. Roadless areas provide rich primitive, semi-primitive motorized, and semiprimitive non-motorized classes of dispersed recreation, which are a source of ecological, social, 

and economic benefits.

(6) Landscape. Roadless areas provide reference landscapes of relatively undisturbed areas that 

serve as a barometer to measure the effects of development on other parts of the landscape.

(7) Scenery. Roadless areas have natural-appearing landscapes with high-scenic qualities that 

people value.

(8) Cultural. Roadless areas often include traditional cultural properties and sacred sites. In 

Alaska, indigenous peoples have been on national forests for more than 10,000 years and the 

forests have cultural significance.

(9) Locally-unique characteristics. Roadless areas represent geographic areas with additional 

locally-unique characteristics specific to Alaska, including: (a) important source of subsistence 

resources including terrestrial wildlife, waterfowl, mammals, fish, and plant-based resources; (b) 

rich habitat that supports multiple species of fish for personal, subsistence, sport, recreation, and 
Appendix G

Final EIS G-21 Roadless Rules by Alternative

commercial harvest; and (c) supports diverse economic opportunity that is especially important 

for rural community well-being.

Timber harvest. The cutting, removal, or sale of trees.

§294.52 Alaska Roadless Areas

(a) Designations. All National Forest System lands listed in § 294.57 are hereby designated as Alaska 

Roadless Areas. Alaska Roadless Areas established by this subpart shall constitute the exclusive set of 

National Forest System lands within the Tongass National Forest to which the provisions of this subpart 

shall apply.

(b) Roadless area management designations. Alaska Roadless Areas are subdivided into three roadless 

area management designations: LUD II Priority, Roadless Priority, and Timber Priority.

§294.53 Road construction and reconstruction in Alaska Roadless Areas. 

(a) A road may not be constructed or reconstructed in Alaska Roadless Areas, except as provided in 

paragraphs (b), (c), (d), and (e) of this section.

(b) Alaska Roadless Areas. Notwithstanding the prohibition in paragraph (a) of this section, road 

construction or reconstruction in any Alaska Roadless Area regardless of the roadless area management 

designation is allowed for the following exceptions:

(1) A mandatory road authorization pursuant to reserved or outstanding rights, or as provided for 

by statute or treaty. Examples of mandatory statutory authorizations include but are not limited to 

roads pursuant to the Alaska National Interest Lands Conservation Act (P.L. 96-487), Section 

4407 of the Safe, Accountable, Flexible, Efficient Transportation Equity Act (P.L. 109-59);and 

General Mining Law of 1872 (as amended);

(2) A road to conduct a response action under the Comprehensive Environmental Response, 

Compensation, and Liability Act (CERCLA) or to conduct a natural resource restoration action 

under CERCLA, Section 311 of the Clean Water Act, or the Oil Pollution Act;

(3) A Federal Aid Highway project, authorized pursuant to Title 23 of the United States Code;

(4) A road realignment to prevent irreparable resource damage that arises from the design, 

location, use, or deterioration of a road and cannot be mitigated by road maintenance;

(5) A road reconstruction safety improvement project on a classified road; or

(6) A road to protect public health and safety in cases of an imminent threat of flood, fire, or other

catastrophic event that, without intervention, would cause the loss of life or property.

(c) LUD II Priority. Notwithstanding the prohibition in paragraph (a) of this section, road construction or 

reconstruction in an Alaska Roadless Area designated as LUD II Priority is allowed if consistent with the 

legislated management restrictions established in Section 201 of the Tongass Timber Reform Act.

(d) Roadless Priority. Notwithstanding the prohibition in paragraph (a) of this section, road construction or 

reconstruction in an Alaska Roadless Area designated as Roadless Priority is allowed for the following 

exceptions:

(1) A road for the construction, expansion, or maintenance of facilities such as airports, marine 

access points, and communication equipment;

(2) A road to provide access to Alaska Native cultural site(s) if requested by an affected federallyrecognized tribe(s); 

(3) A road for transportation needs identified by the State of Alaska’s Southeast Alaska 

Transportation Plan for the connection of communities and development of the regional 

transportation system;
Appendix G

Roadless Rules by Alternative G-22 Final EIS

(4) A road within a designated experimental forest for research or administration or to provide 

administrative access to a designated experimental forest;

(5) A road for the construction, expansion, or maintenance of a community utility system; or

(6) A road in conjunction with the construction, expansion, or maintenance of an authorized 

fishway, fish hatchery, or aquaculture facility.

(e) Timber Priority. Notwithstanding the prohibition in paragraph (a) of this section, permanent or 

temporary road construction, reconstruction, or maintenance within an Alaska Roadless Area designated 

as Timber Priority is allowed. 

§294.54 Timber harvest in Alaska Roadless Areas.

(a) Timber harvest is prohibited in Alaska Roadless Areas except as provided in paragraph (b), (c), (d), 

and (e) of this section.

(b) Alaska Roadless Areas. Notwithstanding the prohibition in paragraph (a) of this section, timber harvest 

in any Alaska Roadless Area regardless of the roadless area management designation is allowed for the 

following exceptions:

(1) Timber harvest conducted pursuant to reserved or outstanding rights or as provided for by 

statute or treaty;

(2) Timber harvest to protect public health and safety in cases of an imminent threat of flood, fire, 

or other catastrophic event that, without intervention, would cause the loss of life or property, 

including removal of hazard trees; 

(3) Timber harvest for personal or administrative use, as provided for in 36 CFR part 223; or

(4) Timber harvest incidental to the implementation of a management activity not otherwise 

prohibited by this subpart, including the construction or reconstruction of a road pursuant to 

§294.53 or the construction, expansion, or maintenance of authorized fishways, fish hatcheries, 

and aquaculture facilities.

(c) LUD II Priority. Notwithstanding the prohibition in paragraph (a) of this section, timber harvest in an 

Alaska Roadless Area designated as LUD II Priority is allowed if consistent with the legislated 

management restrictions established in Section 201 of the Tongass Timber Reform Act.

(d) Roadless Priority. Notwithstanding the prohibition in paragraph (a) of this section, timber harvest in an 

Alaska Roadless Area designated as Roadless Priority is allowed for the following exceptions:

(1) Timber harvest for the cutting, customary trade, and removal of trees for the purposes of 

Alaska Native customary and traditional uses;

(2) Timber harvest for one of the following purposes that will maintain, restore or improve one or 

more of the following purposes:

(i) To maintain, restore, or improve fish and wildlife habitat; or

(ii) To maintain, restore, or improve the characteristics of ecosystem composition, 

structure, and processes;

(3) Timber harvest within a designated experimental forest for research or administration;

(4) Timber harvest for the construction, expansion, utilization, or maintenance of community utility

systems; or

(5) Timber harvest is incidental to trail or recreation development that does not degrade water 

quality, fish habitat, fish production, fish passage, aquatic biodiversity, or soil productivity.
Appendix G

Final EIS G-23 Roadless Rules by Alternative

(e) Timber Priority. Notwithstanding the prohibition in paragraph (a) of this section, timber harvest in an 

Alaska Roadless Area designated as Timber Priority is allowed.

§294.55 Corrections and modifications.

Administrative correction or modification of designations made pursuant to this subpart may be made as 

follows:

(a) Administrative corrections to boundaries. The Chief of the Forest Service may issue administrative 

corrections to the boundaries or classifications of an Alaska Roadless Area after a 30-day public notice 

and opportunity to comment period. Administrative corrections are limited to adjustments that remedy 

clerical errors, typographical errors, mapping errors, or improvements in mapping technology. 

(b) Administrative modifications to Classifications and Boundaries. The Chief of the Forest Service may 

issue modifications to the boundaries or classifications of an Alaska Roadless Area after a 45-day public 

notice and opportunity to comment period.

§294.56 Scope and applicability.

(a) After [final rule effective date], the Roadless Area Conservation Rule (66 FR 3244) published on 

January 12, 2001, shall have no effect within the Tongass National Forest.

(b) This subpart does not revoke, suspend, or modify any permit, contract, or other legal instrument 

authorizing the occupancy and use of National Forest System land issued prior to the effective date of 

this subpart.

(c) This subpart does not revoke, suspend, or modify any project or activity decision made prior to the 

effective date of this subpart.

(d) The provisions set forth in this subpart shall take precedence over any inconsistent land management 

plan component of the Tongass Land and Resource Management Plan. Land management plan 

components that are not inconsistent with this subpart will continue to provide guidance for projects and 

activities within Alaska Roadless Areas. This subpart does not compel the amendment or revision of any 

land management plan, but the Tongass Forest Supervisor shall issue a ministerial Notice of 

Administrative Change pursuant to 36 CFR 219.13(c) identifying plan changes made in conformance with 

the regulatory determinations of this subpart, including rescission of the portion of the December 9, 2016, 

Record of Decision concerning suitable timber lands attributed exclusively to implementation of the 

January 12, 2001, Roadless Area Conservation Rule (66 FR 3244).

(e) The prohibitions and permissions set forth in this subpart are not subject to reconsideration, revision, 

or rescission in subsequent project decisions or land and resource management plan amendments or 

revisions undertaken pursuant to 36 CFR part 219.

f) Nothing in this subpart waives any applicable requirements regarding site-specific environmental 

analysis, public involvement, consultation with Tribes and other agencies, or compliance with other 

applicable laws.

(g) If any provision of the rules in this subpart or its application to any person or to certain circumstances 

is held invalid, the remainder of the regulations in this subpart and their application remain in force.

§294.57 List of designated Alaska Roadless Areas Alternative 4

Table G-4

Alaska Roadless Area name and approximate acres contained within that are 

subject to the prohibitions and exemptions of Alternative 4.

Alaska Roadless Area 

Name

LUD II Priority 

(acres)

Roadless Priority 

(acres)

Timber Priority 

(acres)

Aaron 0 79,400 0

Alaska Roadless Area Islands 3,500 0 0

Anan 37,900 0 0
Appendix G

Roadless Rules by Alternative G-24 Final EIS

Table G-4

Alaska Roadless Area name and approximate acres contained within that are 

subject to the prohibitions and exemptions of Alternative 4.

Alaska Roadless Area 

Name

LUD II Priority 

(acres)

Roadless Priority 

(acres)

Timber Priority 

(acres)

Bay of Pillars 20,300 7,000 0

Behm Islands 0 3,200 0

Brabazon Addition 0 499,900 0

Bradfield 0 91,800 106,300

Calder 8,500 100 0

Camden 0 30,400 0

Carroll 0 0 9,400

Castle 0 40,300 9,600

Central Wrangell 0 6,400 6,700

Chichagof 237,100 259,200 50,600

Chilkat-West Lynn Canal 0 179,200 15,400

Christoval 0 7,600 1,000

Cleveland 0 186,300 0

Cone 0 128,000 0

Crystal 0 11,600 5,500

Dall Island 0 104,600 3,400

Douglas Island 0 24,000 0

Duke 0 45,100 0

East Kuiu 3,100 22,100 1,500

East Mitkof 0 4,000 3,900

East Wrangell 0 5,000 1,100

East Zarembo 0 2,200 8,100

El Capitan 7,500 7,600 10,300

Eudora 0 156,100 39,300

Fake Pass 0 600 0

Fanshaw 0 45,500 2,800

Five Mile 0 12,600 2,400

Freshwater Bay 0 25,700 18,100

Frosty 0 22,500 7,500

Game Creek 0 16,900 29,200

Gravina 0 34,700 3,000

Green Rocks 0 9,200 200

Greens Creek 0 27,200 0

Harding 100 155,800 19,500

Hoonah Sound 51,300 27,500 0

Hydaburg 4,600 6,500 0

Hyder 0 122,000 0

Juneau Urban 6,200 94,700 0

Juneau-Skagway Icefield 39,300 1,143,800 19,900

Kadin 0 2,000 0

Karta 0 17,900 18,000

Kasaan 0 7,600 0

Kasaan Bay 0 0 0

Kashevarof Islands 0 4,700 0

Keku 0 3,500 5,500

Kogish 0 31,800 200

Kosciusko 47,600 4,700 6,600

Lindenberg 0 1,100 7,900

Madan 0 69,600 0

Mansfield Peninsula 0 53,000 0

Manzanita 0 1,400 4,300

McKenzie 0 54,300 12,100

Middle Kruzof 0 8,300 6,300

Missionary 0 5,800 3,300

Mosman 0 52,700 0

Neka Bay 0 6,900 0
Appendix G

Final EIS G-25 Roadless Rules by Alternative

Table G-4

Alaska Roadless Area name and approximate acres contained within that are 

subject to the prohibitions and exemptions of Alternative 4.

Alaska Roadless Area 

Name

LUD II Priority 

(acres)

Roadless Priority 

(acres)

Timber Priority 

(acres)

Neka Mountain 0 5,100 1,000

North Baranof 0 296,600 16,900

North Cleveland 0 109,300 0

North Etolin 0 21,800 300

North Kruzof 0 28,100 3,500

North Kuiu 0 5,400 800

North Kupreanof 0 51,700 41,100

North Revilla 31,400 112,000 46,300

North Wrangell 0 0 0

Nutkwa 21,500 16,200 4,900

Outer Islands 74,000 25,100 0

Pavlof-East Point 0 4,500 0

Point Augusta 0 10,100 2,300

Point Craven 0 10,700 0

Port Alexander 0 125,000 0

Quartz 0 146,500 0

Ratz 0 3,900 1,200

Redoubt 0 62,400 5,200

Revilla 0 25,400 2,400

Rhine 0 22,700 0

Rocky Pass 100 75,900 900

Salmon Bay 10,200 1,800 6,500

Sarkar 23,900 24,200 300

Security 0 24,500 4,700

Sitka Sound 0 13,200 0

Sitka Urban 0 97,200 15,600

Soda Bay 0 54,100 6,400

South Etolin 0 12,000 14,100

South Kruzof 0 54,300 0

South Kuiu 0 62,300 0

South Kupreanof 33,200 159,400 12,500

South Revilla 0 37,100 1,400

South Wrangell 0 4,000 10,100

South Zarembo 0 13,500 11,300

Southeast Wrangell 0 14,800 0

Spires 0 507,900 22,800

Suemez Island 0 15,500 3,900

Sukkwan 28,800 18,800 0

Sullivan 0 62,000 3,600

Taku-Snettisham 0 696,100 0

Tenakee Ridge 0 6,400 9,100

Thomas

Thorne River 19,700 36,900 1,200

Trap Bay 6,400 0 0

Twelvemile 0 16,700 2,900

Upper Situk 0 600 0

West Wrangell 0 700 0

West Zarembo 0 6,100 600

Whitestone 0 3,200 2,700

Windham-Port Houghton 0 115,900 44,100

Woewodski 0 10,300 0

Woronkofski 0 11,000 0

Yakutat Forelands 137,500 152,500 18,200
Appendix G

Roadless Rules by Alternative G-26 Final EIS

Alternative 5

Subpart E – Alaska Roadless Area Management

§294.50 Purpose.

The purpose of this subpart is to provide, in the context of multiple-use management for the conservation 

of roadless areas within the Tongass National Forest while providing for local concerns, including

economic and community development. This subpart sets forth the procedures for management of Alaska 

Roadless Areas.

§294.51 Definitions.

The following terms and definitions apply to this subpart.

Alaska Native. Federally recognized tribes or individuals that are enrolled or eligible to enroll as a 

member of a federally recognized tribe.

Alaska Roadless Areas. Lands within the Tongass National Forest designated pursuant to this subpart 

and identified in a set of maps maintained by the national headquarters office of the Forest Service.

Commercial Old Growth Timber Harvest. Trees, portions of trees, and other forest products originating 

from old growth stands on National Forest System lands that may be sold for the purpose of achieving the 

policies set forth in the Multiple-Use Sustained-Yield Act of 1960, as amended, the Forest and Rangeland 

Renewable Resources Planning Act of 1974, as amended, and the program thereunder. (See 36 CFR 

223.1).

Log transfer facility. The site and structures used for moving logs and timber products from land-based 

transportation forms to water-based transportation forms or vice-versa.

Community utility system. A system that provides a community or communities with services for public 

use or consumption such as municipal water and wastewater systems, biomass heating and energy 

systems, transmission lines, and hydroelectric and other renewable energy projects and related 

infrastructure.

Responsible official. The Forest Service line officer with the authority to make and implement a decision 

on a proposed action.

Road. As defined at 36 CFR 212.1, the term means a motor vehicle route over 50 inches wide, unless 

identified and managed as a trail.

Road construction and reconstruction. As defined at 36 CFR 212.1, the terms mean supervising, 

inspecting, actual building, and incurrence of all costs incidental to the construction or reconstruction of a 

road.

Roadless Area Characteristics. Resources or features that are often present in and characterize Alaska 

Roadless Areas, including

(1) Physical Environment. Roadless areas provide high-quality or undisturbed soil, water, and air.

(2) Water. Roadless areas provide a variety of water resources including public drinking water 

sources, fish and aquatic resources, and hatchery aquatic resources. 

(3) Diversity. Roadless areas support a diversity of plant and animal communities including 

stands of old-growth forests. 

(4) Habitat. Roadless areas are expansive areas where high-quality intact habitat exists and 

ecosystems function with all their native species and components. Roadless areas may serve as 

habitat for threatened, endangered, proposed, candidate, and species of conservation concern, 

and for those species dependent on large, undisturbed areas of land.
Appendix G

Final EIS G-27 Roadless Rules by Alternative

(5) Remoteness. Roadless areas provide rich primitive, semi-primitive motorized, and semiprimitive non-motorized classes of dispersed recreation, which are a source of ecological, social, 

and economic benefits..

(6) Landscape. Roadless areas provide reference landscapes of relatively undisturbed areas that 

serve as a barometer to measure the effects of development on other parts of the landscape.

(7) Scenery. Roadless areas have natural-appearing landscapes with high-scenic qualities that 

people value.

(8) Cultural. Roadless areas often include traditional cultural properties and sacred sites. In 

Alaska, indigenous peoples have been on national forests for more than 10,000 years and the 

forests have cultural significance.

(9) Locally-unique characteristics. Roadless areas represent geographic areas with additional 

locally-unique characteristics specific to Alaska, including: (a) important source of subsistence 

resources including terrestrial wildlife, waterfowl, mammals, fish, and plant-based resources; (b) 

rich habitat that supports multiple species of fish for personal, subsistence, sport, recreation, and 

commercial harvest; and (c) supports diverse economic opportunity that is especially important 

for rural community well-being.

Timber harvest. The cutting, removal, or sale of trees.

§294.52 Alaska Roadless Areas

(a) Designations. All National Forest System lands listed in § 294.57 are hereby designated as Alaska 

Roadless Areas. Alaska Roadless Areas established by this subpart shall constitute the exclusive set of 

National Forest System lands within the Tongass National Forest to which the provisions of this subpart 

shall apply.

(b) Roadless area management designations. Alaska Roadless Areas are subdivided into two roadless 

area management categories: LUD II Priority and Roadless Priority.

§294.53 Road construction and reconstruction in Alaska Roadless Areas. 

(a) A road may not be constructed or reconstructed in Alaska Roadless Areas, except as provided in 

paragraphs (b), (c), (d), and (e) of this section.

(b) Alaska Roadless Areas. Notwithstanding the prohibition in paragraph (a) of this section, road 

construction or reconstruction in any Alaska Roadless Area regardless of the roadless area management 

designation is allowed for the following exceptions:

(1) A mandatory road authorization pursuant to reserved or outstanding rights, or as provided for 

by statute or treaty. Examples of mandatory statutory authorizations include but are not limited to 

roads pursuant to the Alaska National Interest Lands Conservation Act (P.L. 96-487), Section 

4407 of the Safe, Accountable, Flexible, Efficient Transportation Equity Act (P.L. 109-59);and 

General Mining Law of 1872 (as amended);

(2) A road to conduct a response action under the Comprehensive Environmental Response, 

Compensation, and Liability Act (CERCLA) or to conduct a natural resource restoration action 

under CERCLA, Section 311 of the Clean Water Act, or the Oil Pollution Act;

(3) A Federal Aid Highway project, authorized pursuant to Title 23 of the United States Code;

(4) A road realignment to prevent irreparable resource damage that arises from the design, 

location, use, or deterioration of a road and cannot be mitigated by road maintenance;

(5) A road reconstruction safety improvement project on a classified road; or

(6) A road to protect public health and safety in cases of an imminent threat of flood, fire, or other 

catastrophic event that, without intervention, would cause the loss of life or property.
Appendix G

Roadless Rules by Alternative G-28 Final EIS

(c) LUD II Priority. Notwithstanding the prohibition in paragraph (a) of this section, road construction or 

reconstruction in an Alaska Roadless Area designated as LUD II Priority is allowed if consistent with the 

legislated management restrictions established in Section 201 of the Tongass Timber Reform Act.

(d) Roadless Priority. Notwithstanding the prohibition in paragraph (a) of this section, road construction 

and reconstruction in an Alaska Roadless Area designated as Roadless Priority is allowed for the 

following exceptions:

(1) A road for the construction, expansion, or maintenance of facilities such as airports, marine 

access points, and communication equipment;

(2) A road to provide access to Alaska Native cultural site(s) if requested by an affected federallyrecognized tribe(s); 

(3) A road for transportation needs identified by the State of Alaska’s Southeast Alaska 

Transportation Plan for the connection of communities and development of the regional 

transportation system;

(4) A road within a designated experimental forest for research or administration or to provide 

administrative access to a designated experimental forest;

(5) A road for the construction, expansion, or maintenance of a community utility system; or

(6) A road in conjunction with the construction, expansion, or maintenance of an authorized 

fishway, fish hatchery, or aquaculture facility.

§294.54 Timber harvest in Alaska Roadless Areas.

(a) Timber harvest is prohibited in Alaska Roadless Areas except as provided in paragraphs (b), (c), and 

(d) of this section.

(b) Alaska Roadless Areas. Notwithstanding the prohibition in paragraph (a) of this section, timber harvest 

in any Alaska Roadless Area regardless of the roadless area management designation is allowed for the 

following exceptions:

(1) Timber harvest conducted pursuant to reserved or outstanding rights or as provided for by 

statute or treaty,

(2) Timber harvest to protect public health and safety in cases of an imminent threat of flood, fire, 

or other catastrophic event that, without intervention, would cause the loss of life or property, 

including removal of hazard trees; 

(3) Timber harvest for personal or administrative use, as provided for in 36 CFR part 223; or

(4) Timber harvest incidental to the implementation of a management activity not otherwise 

prohibited by this subpart, including the construction or reconstruction of a road pursuant to 

§294.53 or the construction, expansion, or maintenance of authorized fishways, fish hatcheries, 

and aquaculture facilities.

(c) LUD II Priority. Notwithstanding the prohibition in paragraph (a) of this section, timber harvest in an 

Alaska Roadless Area designated as LUD II Priority is allowed if consistent with the legislated 

management restrictions established in Section 201 of the Tongass Timber Reform Act.

(d) Roadless Priority. Notwithstanding the prohibition in paragraph (a) of this section, timber harvest in an 

Alaska Roadless Area designated as Roadless Priority is allowed for the following exceptions:

(1) Timber harvest for the cutting, customary trade, and removal of trees for the purposes of 

Alaska Native customary and traditional uses;

(2) Timber harvest for one of the following purposes that will maintain, restore or improve one or 

more of the following purposes:
Appendix G

Final EIS G-29 Roadless Rules by Alternative

(i) To maintain, restore, or improve fish and wildlife habitat; or

(ii) To maintain, restore, or improve the characteristics of ecosystem composition, 

structure, and processes;

(3) Timber harvest within a designated experimental forest for research or administration;

(4) Timber harvest for the construction, expansion, utilization, or maintenance of community utility

systems; or

(5) Timber harvest is incidental to trail or recreation development that does not degrade water 

quality, fish habitat, fish production, fish passage, aquatic biodiversity, or soil productivity.

§294.55 Corrections and modifications.

Administrative correction or modification of designations made pursuant to this subpart may be made as 

follows:

(a) Administrative corrections to boundaries. The Chief of the Forest Service may issue administrative 

corrections to the boundaries or classifications of an Alaska Roadless Area after a 30-day public notice 

and opportunity to comment period. Administrative corrections are limited to adjustments that remedy 

clerical errors, typographical errors, mapping errors, or improvements in mapping technology. 

(b) Administrative modifications to Classifications and Boundaries. The Chief of the Forest Service may 

issue modifications to the boundaries or classifications of an Alaska Roadless Area after a 45-day public 

notice and opportunity to comment period. 

§294.56 Scope and applicability.

(a) After [final rule effective date], the Roadless Area Conservation Rule (66 FR 3244) published on 

January 12, 2001, shall have no effect within the Tongass National Forest.

(b) This subpart does not revoke, suspend, or modify any permit, contract, or other legal instrument 

authorizing the occupancy and use of National Forest System land issued prior to the effective date of 

this subpart.

(c) This subpart does not revoke, suspend, or modify any project or activity decision made prior to the 

effective date of this subpart.

(d) The provisions set forth in this subpart shall take precedence over any inconsistent land management 

plan component of the Tongass Land and Resource Management Plan. Land management plan 

components that are not inconsistent with this subpart will continue to provide guidance for projects and 

activities within Alaska Roadless Areas. This subpart does not compel the amendment or revision of any 

land management plan, but the Tongass Forest Supervisor shall issue a ministerial Notice of 

Administrative Change pursuant to 36 CFR 219.13(c) identifying plan changes made in conformance with 

the regulatory determinations of this subpart, including rescission of the portion of the December 9, 2016, 

Record of Decision concerning suitable timber lands attributed exclusively to implementation of the 

January 12, 2001, Roadless Area Conservation Rule (66 FR 3244).

(e) The prohibitions and permissions set forth in this subpart are not subject to reconsideration, revision, 

or rescission in subsequent project decisions or land and resource management plan amendments or 

revisions undertaken pursuant to 36 CFR part 219.

(f) Nothing in this subpart waives any applicable requirements regarding site-specific environmental 

analysis, public involvement, consultation with Tribes and other agencies, or compliance with other 

applicable laws.

(g) If any provision of the rules in this subpart or its application to any person or to certain circumstances 

is held invalid, the remainder of the regulations in this subpart and their application remain in force.

§294.57 List of designated Alaska Roadless Areas Alternative 5.
Appendix G

Roadless Rules by Alternative G-30 Final EIS

Table G-5

Alaska Roadless Area name and approximate acres 

contained within that are subject to the prohibitions and 

exemptions of Alternative 5.

Alaska Roadless Area 

Name

LUD II Priority 

(acres)

Roadless Priority 

(acres)

Aaron 0 72,000

Alaska Roadless Area 

Islands 0 0

Anan 37,900 0

Bay of Pillars 20,300 7,000

Behm Islands 0 3,200

Brabazon Addition 0 499,900

Bradfield 0 74,400

Calder 8,500 100

Camden 0 6,500

Carroll 0 0

Castle 0 27,000

Central Wrangell 0 6,400

Chichagof 237,100 155,400

Chilkat-West Lynn Canal 0 151,700

Christoval 0 7,600

Cleveland 0 103,100

Cone 0 128,000

Crystal 0 7,200

Dall Island 0 95,800

Douglas Island 0 23,000

Duke 0 45,100

East Kuiu 3,100 11,200

East Mitkof 0 4,000

East Wrangell 0 0

East Zarembo 0 2,100

El Capitan 7,500 2,900

Eudora 0 106,000

Fake Pass 0 600

Fanshaw 0 16,200

Five Mile 0 3,500

Freshwater Bay 0 25,700

Frosty 0 9,100

Game Creek 0 16,900

Gravina 0 21,200

Green Rocks 0 9,300

Greens Creek 0 25,600

Harding 100 146,000

Hoonah Sound 51,200 6,500

Hydaburg 4,600 6,500

Hyder 0 82,800

Juneau Urban 6,200 49,500

Juneau-Skagway Icefield 39,300 1,134,900

Kadin 0 2,000

Karta 0 16,000

Kasaan 0 7,600

Kasaan Bay 0 0

Kashevarof Islands 0 4,700

Keku 0 3,500

Kogish 0 25,700

Kosciusko 47,600 2,700

Lindenberg 0 2,300

Madan 0 14,200

Mansfield Peninsula 0 41,500

Manzanita 0 1,400
Appendix G

Final EIS G-31 Roadless Rules by Alternative

Table G-5

Alaska Roadless Area name and approximate acres 

contained within that are subject to the prohibitions and 

exemptions of Alternative 5.

Alaska Roadless Area 

Name

LUD II Priority 

(acres)

Roadless Priority 

(acres)

McKenzie 0 27,200

Middle Kruzof 0 2,900

Missionary 0 5,200

Mosman 0 25,500

Neka Bay 0 6,900

Neka Mountain 0 4,300

North Baranof 0 241,300

North Cleveland 0 108,400

North Etolin 0 16,100

North Kruzof 0 21,700

North Kuiu 0 3,300

North Kupreanof 0 52,900

North Revilla 31,400 102,300

North Wrangell 0 1,700

Nutkwa 21,500 6,800

Outer Islands 74,000 22,000

Pavlof-East Point 0 4,100

Point Augusta 0 10,800

Point Craven 0 9,500

Port Alexander 0 125,000

Quartz 0 146,500

Ratz 0 1,300

Redoubt 0 56,100

Revilla 0 25,400

Rhine 0 3,900

Rocky Pass 100 70,900

Salmon Bay 10,200 3,300

Sarkar 23,900 21,300

Security 0 24,300

Sitka Sound 0 13,200

Sitka Urban 0 93,300

Soda Bay 0 30,300

South Etolin 0 5,500

South Kruzof 0 50,300

South Kuiu 0 62,300

South Kupreanof 33,200 38,400

South Revilla 0 28,400

South Wrangell 0 300

South Zarembo 0 13,700

Southeast Wrangell 0 7,900

Spires 0 494,600

Suemez Island 0 8,500

Sukkwan 25,700 12,500

Sullivan 0 52,100

Taku-Snettisham 0 630,400

Tenakee Ridge 0 6,400

Thomas

Thorne River 19,700 33,100

Trap Bay 6,400 3,200

Twelvemile 0 17,500

Upper Situk 0 10,800

West Wrangell 0 1,900

West Zarembo 0 6,100

Whitestone 0 2,200

Windham-Port Houghton 0 41,800
Appendix G

Roadless Rules by Alternative G-32 Final EIS

Table G-5

Alaska Roadless Area name and approximate acres 

contained within that are subject to the prohibitions and 

exemptions of Alternative 5.

Alaska Roadless Area 

Name

LUD II Priority 

(acres)

Roadless Priority 

(acres)

Woewodski 0 0

Woronkofski 0 2,200

Yakutat Forelands 137,500 166,100

Alternative 6 – Preferred Alternative

Subpart E – Alaska Roadless Area Management

§294.50 Tongass National Forest.

(a) The 2001 Roadless Area Conservation Rule as published in the Federal Register on January 12, 2001 

(66 FR 3244) shall not apply to the Tongass National Forest. 

§294.51 Transition.

(a) The Tongass Forest Supervisor shall issue a ministerial Notice of Administrative Change pursuant to 

36 CFR 219.13(c) identifying plan changes made in conformance with the regulatory determinations of 

this subpart; including rescission of the portion of the December 9, 2016, Record of Decision concerning 

suitable timber lands attributed exclusively to implementation of the January 12, 2001, Roadless Area 

Conservation Rule (66 FR 3244).
APPENDIX H

RESPONSE TO COMMENTS
Appendix H

Final EIS H-i Response to Comments

Appendix H

Response to Comments

CONTENTS

Tribal Engagement/Cooperating Agencies............................................................................................ H-1

ANILCA/Subsistence ............................................................................................................................. H-3

Citizen Advisory Committee................................................................................................................. H-11

National Forest Management and the Tongass Forest Plan............................................................... H-12

Chugach National Forest ..................................................................................................................... H-16

Purpose and Need............................................................................................................................... H-17

Public Involvement............................................................................................................................... H-18

Alternatives .......................................................................................................................................... H-21

Rationale.............................................................................................................................................. H-26

Roadless Areas and Mapping.............................................................................................................. H-27

Effects Analysis - Other ....................................................................................................................... H-28

Economic and Social Environment ...................................................................................................... H-32

Cultural Resources .............................................................................................................................. H-39

Environmental Justice.......................................................................................................................... H-40

Recreation and Tourism....................................................................................................................... H-41

Transportation and Roads ................................................................................................................... H-42

General Analysis and Editorial............................................................................................................. H-43

Energy and Utilities .............................................................................................................................. H-44

Minerals ............................................................................................................................................... H-45

Wildlife and Biological Diversity ........................................................................................................... H-46

Watershed and Fish............................................................................................................................. H-57

Climate and Air .................................................................................................................................... H-62

Timber and Logging............................................................................................................................. H-66

Roadless and Wilderness .................................................................................................................... H-68

Out of Scope ........................................................................................................................................ H-69
Appendix H

Final EIS H-1 Response to Comments

Appendix H

Response to Comments

Tribal Engagement/Cooperating Agencies

Comment 001: There was concern that the consultation with Alaska Native tribes and corporations on 

the Alaska Roadless Rule was inadequate, and that this may lead to impaired agency performance of its 

responsibility to consult and coordinate with Tribes regarding any future plan or project for the Tongass. 

Response 001: In 2018, the Forest Service sent letters to the 32 federally recognized tribes and 

27 Alaska Native corporations in Southeast and Southcentral Alaska to invite government-togovernment and government-to-corporation consultation. The in-region consultation invitation 

was continuous throughout the rulemaking process.

The Alaska Region and the Tongass National Forest have an ongoing government-togovernment relationship with all federally recognized tribes in southeast Alaska. The agency will 

continue to meet its responsibility to consult with federally recognized tribes and Alaska Native 

corporations through government-to-government and government-to-corporation consultation on 

all topics. In addition to district rangers, Regional Office staff also met with tribes, tribal 

cooperators, and other interested parties to answer questions and provide information as 

requested when feasible. Forest and Regional Office staff provided briefings, information 

meetings, supported formal consultations, and formal public hearings in or within the vicinity of 

communities throughout southeast Alaska. Most tribal governments took advantage of these 

opportunities. To date, twelve government-to-government consultations have occurred in 

association with this rulemaking effort.

Comment 002: There was concern that government-to-government consultation was inadequate 

because tribal governments were not consulted prior to the Secretary of Agriculture acceptance of the 

State of Alaska’s petition for rulemaking. Commenters said tribal concerns had been inadequately 

addressed and requests for government-to-government consultation were not responded to in a timely 

manner. 

Response 002: The decision when to initiate government-to-government consultation is 

subjective. The Department did not think it was most advantageous to initiate consultation before 

it had an opportunity to explore development of a new policy and gain an understanding of the 

issues surrounding the proposal. 

In July 2018, the Forest Service sent letters to the 32 federally recognized tribes and 27 Alaska 

Native corporations in Southeast and Southcentral Alaska to invite government-to-government 

and government-to-corporation consultation. This was less than four months after the Secretary 

accepted the petition and less than two months after the Secretary directed the Forest Service to 

begin the rulemaking process.

All in-region government-to-government consultation requests occurred as well as one 

consultation with the Department in which the Secretary delegated consultation to the 

Undersecretary, due to multitude of responsibilities at the Departmental level. All requests for 

government-to-government consultation with the local line officers occurred within weeks of the 

request. However, requests for government-to-government consultation with the Secretary’s 

office took longer to coordinate and occur.

Comment 003: Commenters said the DEIS should have included an alternative providing Tribal Nations 

with a more meaningful role in management decisions affecting land in the Tongass National Forest 

within their traditional territory.
Appendix H

Response to Comments H-2 Final EIS

Response 003: Co-management of the Tongass National Forest along with tribal partners was 

considered as an alternative but was eliminated from detailed study because it does not comport 

with existing legal authorities. Alternatives, including this one, that were considered and 

eliminated from detailed analysis were described in Chapter 2 of the DEIS, along with the 

rationale for their elimination.

Comment 004: Commenters were concerned that Alternative 6 was identified as the preferred alternative 

after all six tribal cooperating agencies indicated opposition for a full exemption from the 2001 Roadless 

Rule. Further, there was concern about the Forest Service relationship with cooperating agencies 

because suggestions for how to improve the analysis did not seem to be taken into consideration and 

community use area maps were not adjusted. 

Response 004: The Department has heard from a wide variety of individuals and groups and 

understands that opinions and preferences vary regarding how roadless areas with the Tongass 

National Forest should be managed and conserved. The Forest Service has been working with its 

cooperating agencies, as part of the Memorandums of Understanding to which all parties agreed. 

USDA and the Forest Service will continue to listen to all views and perspectives in reaching a 

final decision. The cooperating agencies, public input, and other considerations will inform that 

decision. 

The agency considered in the development of the DEIS the use of the Alaska Native Tribe’s 

traditional use area for the community use analysis boundaries, as suggested by the tribal 

cooperating agencies. The agency did not utilize the traditional use areas for the impact analysis 

because they are considerably larger than the community use areas. The use of larger analysis 

areas diffuses the impacts and the agency wanted impacts to be focused by community. The 

agency added an appendix displaying the traditional use areas to recognize the importance of the 

traditional use areas to the Alaska Native Tribes. 

The agency revisited the analysis boundary issue between draft and final. The agency solicited 

from the State of Alaska subsistence use data by community. Alaska Department of Fish and 

Game provided updated survey information from six communities regarding areas of subsistence 

gathering. Data indicates Southeast Alaskans are traveling farther for subsistence gathering, 

meaning the community use areas are larger. For example, latest data indicate some people from 

the city of Yakutat are utilizing Prince of Wales Island for subsistence gathering. Again, the larger 

area would diffuse the impacts if the Yakutat community use area were to be considered Prince 

of Wales Island and north, which would be three-quarters of Southeast Alaska. The agency 

determined this would not be an improvement to the impact analysis and would make it more 

difficult to the reader to determine the impacts to people living in the city of Yakutat.

Comment 005: Commenters expressed concern that the process had not respected the sovereignty of 

tribal governments and its citizens and that tribal governments were not included as full cooperating 

agency partners in the decision-making process but rather were brought in after decisions were already 

made.

Response 005: Government-to-government consultation and cooperating agency participation 

provide avenues for input into analysis and to inform the decision-maker, but does not provide for 

decision-making. The sole decision-maker in the Alaska rulemaking process is the Secretary of 

Agriculture. 

Comment 006: Commenters were concerned that exemption from the rule may impair tribal dependent 

resources and sought to have the rule kept intact for the protection and preservation of these and other 

reserved rights and to safeguard the health, livelihood and well-being of tribal citizens.

Response 006: It is the policy of the USDA to provide for the continuation of the opportunity for 

subsistence uses by rural Alaskan residents, both Native and non-Native. The policy also 

includes maintaining reasonable access to subsistence resources as required by ANILCA. 

Potential effects on subsistence and other resources are described in Chapter 3 of this FEIS. The 
Appendix H

Final EIS H-3 Response to Comments

FEIS includes alternatives that provide varying levels of long-term protection to traditional use 

areas on the Tongass.

Comment 007: There was concern that exempting the Tongass National Forest may be a human rights 

issue and racially motivated. Commenters saw exemption from the rule as a violation of indigenous rights 

that would contribute to the ongoing genocide of Indigenous Peoples whose identities, cultures, and 

livelihoods are integral to the forest.

Response 007: A civil rights impact analysis (CRIA) was prepared for the preferred alternative 

for the Alaska Roadless Rule, corresponding to Alternative 6 in the DEIS. The analysis considers 

the proposed rule and demographic data of Tongass National Forest users and beneficiaries in 

the affected region of Alaska. The CRIA analysis evaluates whether there are potential adverse 

or disproportionate impacts from the Alaska Roadless Rule on those specific populations 

identified in USDA Departmental Regulation (DR) 4300-4 and 5600-002. This analysis was 

undertaken to evaluate how the American public could be affected by the Alaska Roadless Rule, 

particularly whether populations including (but not limited to) ethnic and racial minorities, people 

with disabilities, and women could receive potential adverse or disproportionate impacts from the 

proposed rule. The proposed rule is not projected to exclude, limit, or otherwise disadvantage any 

group or class of persons from using or benefiting from resources on the Tongass National 

Forest. 

The proposed rule issues no requirements related to eligibility, benefits of, and services to, 

protected classes, nor is there a purpose or effect of treating any class of people differently than 

the public at large. 

Comment 008: The State of Alaska and others requested edits (additions/deletions) be incorporated into 

the FEIS. 

Response 008: As a cooperating agency the State of Alaska, as well as, our other cooperating 

agencies, worked with the Forest Service to adjust and change the EIS and the rule language. 

Changes were made between the draft and final EIS in response to input. 

ANILCA/Subsistence

Comment 009: Commenters disagree with the Forest Service’s conclusion in the DEIS that "[a]n ANILCA 

Section 810 evaluation and determination is not required for the Alaska Roadless Rule because it is a 

programmatic level decision and not a determination whether to “withdraw, reserve, lease, or otherwise 

permit the use, occupancy, or disposition of National Forest System lands.” Commenters said this 

conclusion is inconsistent with the other facts reported in the DEIS. Others said that because the finding 

was not made in the DEIS, the subsequent notice and hearings were out of order and therefore prevents 

the USDA from making a legal Section 810 determination for subsistence. 

Commenters said the Forest Service violated the Alaska National Interest Lands Conservation Act 

(ANILCA), National Forest Management Act (NFMA), and National Environmental Policy Act (NEPA) by 

failing to make a subsistence finding and analyze factors necessary to make the finding.

Response 009: The Alaska Roadless Rule is not subject to Section 810 of ANILCA because a 

state-specific Roadless Rule does not withdraw, reserve, lease, or otherwise permit the use, 

occupancy, or disposition of public lands.

“Withdraw” is the removal of lands from certain legal rights, as an example, a mineral 

withdrawal precludes location, entry, and patent under the United States mining laws. 

The proposed Alaska roadless rule does not propose any such withdrawal.

“Reserve” is to legally set aside something for a specified purpose. The proposed Alaska 

roadless rule does not propose to set aside any specific lands for a specific purpose. 

“Lease” is an agreement between the government and another party to access property. For 

example, an oil lease is a legal contract between the government and an oil company to 
Appendix H

Response to Comments H-4 Final EIS

have access to oil minerals. The proposed Alaska roadless rule does not propose to 

lease any federal rights to any entity.

“Permit” is to allow the “use or occupancy” of public lands or to authorize certain activities to 

occur on public lands. The proposed Alaska roadless rule does not propose to authorize 

any activities on NFS lands. Ongoing authorized uses are allowed to continue.

“Disposition of public lands” is the sale, exchange, or purchase of lands. The proposed 

Alaska roadless rule does not propose any of these activities.

While the Alaska Roadless Rule is not subject to Section 810 of ANILCA, the EIS did analyze the 

potential effects on subsistence uses, subsistence hearings were held in 18 Southeast Alaska 

communities (Angoon, Craig, Ketchikan, Petersburg, Sitka, Tenakee Springs, Wrangell, Yakutat, 

Point Baker, Hoonah, Skagway, Gustavus, Haines, Thorne Bay, Kake, Kasaan, Hydaburg, and 

Pelican) during the public comment period on the DEIS, and the Forest Service committed to 

including a Section 810 determination in the final decision for the Alaska Roadless Rule. The 

analysis in the EIS focused on the three factors related to subsistence uses specifically identified 

by ANILCA: 1) resource distribution and abundance, 2) access to resources, and 3) competition 

for the use of resources. The Responsible Official will consider the analysis in the EIS, the 

valuable input received during the subsistence hearings, input from the cooperating agencies, 

and other information in the record in making his final determination with regard to Section 810 of 

ANILCA and subsistence uses and activities on the Tongass National Forest.

Comment 010: Title VIII, Section 810 of ANILCA requires federal agencies having jurisdiction over lands 

in Alaska to evaluate the potential impacts of proposed actions on subsistence uses and needs. 

Commenters were concerned that the analysis of the proposed change does not adequately account for 

the impacts on Native peoples.

Response 010: As discussed above, the Alaska Roadless Rule is not subject to Section 810 of 

ANILCA because a state-specific Roadless Rule does not withdraw, reserve, lease, or otherwise 

permit the use, occupancy, or disposition of public lands. While the Alaska Roadless Rule is not 

subject to Section 810 of ANILCA, the EIS did analyze the potential effects on subsistence uses, 

subsistence hearings were held in 18 Southeast Alaska communities (Angoon, Craig, Ketchikan, 

Petersburg, Sitka, Tenakee Springs, Wrangell, Yakutat, Point Baker, Hoonah, Skagway, 

Gustavus, Haines, Thorne Bay, Kake, Kasaan, Hydaburg, and Pelican) during the public 

comment period on the DEIS, and the Forest Service has committed to including a Section 810 

determination in the final decision for the Alaska Roadless Rule.

In addition, government-to-government consultation between the Forest Service and potentially 

affected federally recognized tribes is ongoing, and the Forest Service continues to consider 

information obtained from the tribes through this consultation. All of the information and input 

received to date has been considered and, as appropriate, incorporated into the EIS; it will all be 

used to inform the Secretary of Agriculture for his final decision on the Alaska Roadless Rule.

Comment 011: The Forest Service's failure to provide site-specific subsistence information and consider 

the Organized Village of Kake's use map in February 2019 violates ANILCA and NEPA.

Response 011: The EIS provides a programmatic assessment of the potential impacts that may 

result from the alternatives considered for a proposed Alaska Roadless Rule. This assessment 

and the alternatives are programmatic, meaning that they establish direction and allowable 

activities for broad land areas, rather than schedule specific activities in specific locations. This 

makes it difficult to predict effects on individual communities. The EIS discloses the types of 

activities that could occur and where they could occur; however, specific information about actual 

actions is not available sufficient to provide informed, site-specific subsistence information. This is 

consistent with the recent decision and order (District Court of Alaska 1:19-cv-00006-SLG) on 

the Prince of Wales Landscape Level Analysis Project. 

The Forest Service used the Community Use Areas in Appendix E because they are a consistent 

data set for the entire Tongass National Forest. These community use areas are an analysis tool 
Appendix H

Final EIS H-5 Response to Comments

to differentiate the effects of the alternatives by community and are not a record of traditional 

territories. The community use areas represent the general area commonly used or related to by 

many of the community’s residents in their local day-to-day work, recreational use, and 

subsistence activities. In addition, the Sitka black-tailed deer habitat capability model output was 

analyzed for the Wildlife Analysis Areas (WAAs) where each community obtains approximately 75 

percent of their average annual deer harvest. WAAs are a division of land used by the Alaska 

Department of Fish and Game (ADF&G) for wildlife analysis. Appendix E in the FEIS has been

revised to include an assessment of potential subsistence impacts at the community level and the 

findings of the 2016 analysis are included as part of this analysis. Potential impacts by alternative 

and community are considered in the context of projected impacts following 100 years of 

implementation of the current Forest Plan. 

The FEIS includes a discussion of the differences between the Forest Service analysis tool of 

Community Use Areas, the Alaska Roadless Area Community Priority, and the Traditional 

territories of the Alaska Native peoples throughout Southeast Alaska.

Comment 012: The Forest Service violated ANILCA and NEPA by refusing to consider mitigation 

measures proposed by Kake to protect all remaining, intact old-growth habitat in Kake's traditional use 

area, updating the Tongass roadless inventory to capture all roadless lands important to Kake, and 

allowing an improved role in management of lands in Kake's traditional territory.

Response 012: The roadless inventories were updated and additional areas were included in 

Alternatives 2 and 3 as designated Alaska Roadless Areas. All unroaded areas were reviewed 

and some areas identified in the 2003 and 2008 roadless analyses associated with Tongass 

forest planning efforts were included. In addition, small islands previously excluded from roadless 

designation were included if not substantially altered. 

Mitigations such as identifying specific road segments, selling carbon credits, and workforce 

development are outside the scope of the Alaska roadless rulemaking, which is programmatic 

and does not evaluate projects or partnerships.

Co-management of the Tongass National Forest with tribal partners was considered as an 

alternative but eliminated from detailed analysis as it does not comport with existing legal 

authorities. 

Comment 013: The Langdon and Sanderson (2009) publication should be used as a resource to define 

the K’iis Xaadas territory discussed in Appendices E and F of the Alaska Roadless Rule DEIS, and Table 

E-12 of the DEIS should reflect the corrected traditional territory. This area may be smaller than the 

“Community Use Area” currently defined in the DEIS, however the K’iis Xaadas traditional territory is more 

widely recognized and is still the currently recognized traditional use area for Hydaburg.

Response 013: The Community Use Areas in Appendix E were used for the analysis in the EIS 

because they are a consistent data set for the entire Tongass National Forest. These community 

use areas are an analysis tool to differentiate the effects of the alternatives by community, and 

not a record of traditional territories. The community use areas represent the general area 

commonly used or related to by many of the community’s residents in their local day-to-day work, 

recreational, and subsistence activities. In addition, the Sitka black-tailed deer habitat capability 

model output was analyzed for the Wildlife Analysis Areas (WAAs) where data indicate that each 

community obtains approximately 75 percent of their average annual deer harvest. This analysis 

was originally prepared for the 1997 Forest Plan FEIS and was updated for the 2016 Forest Plan 

FEIS. WAAs are a division of land used by ADF&G for wildlife analysis.

Haa Aani: Tlingit and Haida Land Rights and Use (Goldschmidt and Haas 1998) was used for the 

mapping of traditional territories in the EIS, and the Forest Service recognizes that several tribes 

have been refining these maps of traditional territories. 

The FEIS includes a discussion of the differences between the analysis tool used in the EIS 

(Community Use Areas), the Alaska Roadless Area Community Priority management category, 
Appendix H

Response to Comments H-6 Final EIS

and the maps and other information about the traditional territories of the native peoples around 

Southeast Alaska. 

Comment 014: There was concern that the traditional knowledge was not incorporated into the DEIS. 

The subsistence economy for residents of Southeast Alaska is strong, and the reliance upon fishing, 

hunting and gathering takes an understanding of the available habitat and environment.

Response 014: The EIS evaluates the effects of the alternatives relative to subsistence at the 

programmatic level. The EIS, including Appendix E, discusses the potential effects of the 

proposed Alaska Roadless Rule, including six alternatives, on 32 communities in Southeast 

Alaska. Appendix E in the FEIS has been revised to include an assessment of potential 

subsistence impacts at the community level. The subsistence economy is discussed in the 

Subsistence section of the FEIS. The Forest Service values the knowledge of the cooperating 

agencies and other Alaska Native tribes, and also the public input received at the public meetings 

and hearings. The Forest Service held public meetings in 19 communities throughout Southeast 

Alaska, plus Anchorage and Washington, D.C.

In addition, government-to-government consultation between the Forest Service and potentially 

affected federally recognized tribes is ongoing, and the Forest Service continues to consider 

information obtained from the tribes through this consultation. All of the information and input 

received to date has been considered and, as appropriate, incorporated into the EIS; it will all be 

used to inform the Secretary of Agriculture for his final decision on the Alaska Roadless Rule.

Comment 015: Commenters expressed concern that a rule change would have ripple effects across all 

communities regionally no matter the specific geographic extent of the changes. For example, if logging is 

introduced in one area, subsistence users will be displaced to other areas potentially increasing 

competition for resources in those areas.

Response 015: As discussed in the EIS, timber program output levels are expected to remain 

constant and involve a similar number of acres under all alternatives, varying only by the location 

of timber harvest. This assessment and the proposed alternatives are programmatic, meaning that 

they establish direction and allowable activities for broad land areas, rather than schedule specific 

activities, such as timber harvest, in specific locations. None of the alternatives authorize any sitespecific projects or other ground-disturbing activities. Specific projects that include timber harvest, 

road construction, and/or road reconstruction will undergo site-specific environmental analysis 

when they are proposed in compliance with NEPA. Potential impacts to subsistence, such as 

increased competition from displaced subsistence users, will be assessed at the project-level. 

Project-level analyses require a subsistence evaluation and finding in accordance with ANILCA 

Section 810. 

Comment 016: Commenters sought tabulations of the existing abundance conditions of local flora and 

fauna that would represent the current status of populations, for example, the amount of old-growth red 

cedars existing in the Tongass currently, counts of pinto abalone, herring, deer populations, etc. 

Commenters questioned how the impacts of historical logging or future impacts of the changed rule could 

be tabulated properly without baseline estimates.

Commenters sought effect analysis for specific impacts to the comprehensive elements of the traditional 

subsistence diet which can include deer, seal, salmon, king salmon, dog salmon, halibut, crab, oysters, 

herring, pinto abalone, berries, beach asparagus, beach greens, sea vegetables, shrimp, rockfish, 

fiddlehead ferns, mushrooms, seaweed, medicinals (sundews, usnea, devil’s club, yew berries, golden 

thread), and fresh water.

Response 016: The Alaska Roadless Rule assessment presented in this EIS is a rulemaking 

process and programmatic-level decision. None of the alternatives authorize any site-specific 

projects or other ground-disturbing activities. Inventorying and counting individual populations of 

subsistence resources is outside the scope of this analysis. Similarly, assessing impacts for 

different elements of the traditional subsistence diet is not possible at the programmatic level. 

However, specific projects that include timber harvest, road construction, and/or road 
Appendix H

Final EIS H-7 Response to Comments

reconstruction will undergo site-specific environmental analysis when they are proposed to 

comply with NEPA. Potential impacts to subsistence resources and users will be assessed as 

part of these project-level analyses, which require a subsistence evaluation and finding in 

accordance with ANILCA Section 810.

Site-specific information typically used in project-level analyses includes identification of 

subsistence resources that occur in the project area and may be affected and levels of use in the 

project area by subsistence and non-subsistence users, with subsistence users provided the 

opportunity to provide input with respect to their use of local resources and potential projectrelated impacts.

Comment 017: Comments sought additional analysis about how future needs will change regionally due 

to changes in population growth and distribution.

Response 017: Potential effects to subsistence are assessed at the Forest-level in the EIS in 

terms of the following factors: 1) resource distribution and abundance, 2) access to resources, 

and 3) competition for the use of resources (see the Subsistence section). 

Appendix E in the FEIS has been revised to include an assessment of potential subsistence 

impacts at the community level. The findings of the 2016 Forest Plan Amendment EIS analysis 

are included as part of this analysis and potential impacts by alternative and community are 

considered in the context of projected impacts following 100 years of implementation of the 

current Forest Plan. 

Comment 018: Commenters consider the proposed change in the Roadless Rule as a direct threat and 

attack on the subsistence way of life due to the extreme cumulative impacts the change would have on 

local communities, culture, native landscapes, self-reliance, food security, shelter, fuel, handicrafts, native 

medicines, emotional and psychological health, spiritual wellbeing, and future generations. Commenters 

said that removing the Tongass from the Roadless Rule would produce both existential, profound, and 

generational impacts on local native populations.

Response 018: As discussed in the EIS, timber program output levels are expected to remain 

constant and involve a similar number of acres under all alternatives, varying only by the location 

of timber harvest. This assessment and the proposed alternatives are programmatic, meaning that 

they establish direction and allowable activities for broad land areas, rather than schedule specific 

activities, such as timber harvest, in specific locations. None of the alternatives authorize any sitespecific projects or other ground-disturbing activities. Specific projects that include timber harvest, 

road construction, and/or road reconstruction will undergo site-specific environmental analysis 

when they are proposed to comply with NEPA. Potential impacts to subsistence resources and 

users will be assessed as part of these project-level analyses, which will require a subsistence 

evaluation and finding in accordance with ANILCA Section 810.

Comment 019: Commenters said that the subsistence economy is not just about food, but also includes 

customary trade. Residents are entitled to this local economic tradition and changing the Roadless Rule 

would negatively impact resources involved in the practice.

Response 019: The section of the EIS that discusses the subsistence economy has been 

revised to include a discussion of the importance of sharing and trade of wild resources as a 

traditional practice across the region (see the Subsistence section in Chapter 3). Potential 

impacts to wildlife and fish are assessed in the Key Issue 3 in the EIS. Impacts to subsistence are 

assessed at the Forest-level in the Subsistence section, with potential impacts addressed by 

community in Appendix E.

Comment 020: Commenters explained that the role of subsistence and potential lack of access or 

abundance is extreme for local island community members. Subsistence is considered the only viable 

option for many people, therefore socioeconomic conditions are highly tied to local healthy ecosystems, 

and the potential impacts of the rule change are amplified due to a basic lack of connectivity. 
Appendix H

Response to Comments H-8 Final EIS

Response 020: The importance of subsistence to local economies is discussed in the section of 

the EIS that addresses the subsistence economy (see the Subsistence section in Chapter 3). 

Potential impacts are assessed by community in Appendix E, which considers potential impacts 

to 32 Southeast Alaska CUAs using four primary measures by alternative: 1) acres by Alaska 

Roadless Area (ARA) management category and change in acres managed as roadless; 2) 

change in acres in development Land Use Designations (LUDs); 3) change in suitable old-growth 

acres available for harvest, and 4) changes in estimated harvest over 100 years. Impacts are also 

considered for the WAAs where each community obtains approximately 75 percent of their 

average annual deer harvest.

Comment 021: Commenters found the term "subsistence" derogatory and that it implies a lack of 

creativity in utilization of resources. Local people refer to it as their “way of life”. The proposed rule 

change demonstrates a lack of understanding about the way of life in its historical and cultural context. 

Living off the land is not only essential and economical, it is fulfilling and exhausting.

Response 021: The use of the term subsistence is consistent with the definition provided in 

ANILCA Section 803 and is not meant to be derogatory or to imply a lack of creativity in the use 

of resources. A number of people providing testimony during the subsistence hearings held for 

this rulemaking stated a preference for the term “way of life,” rather than subsistence. This 

information has been added to the beginning of the Subsistence section in the EIS.

Comment 022: Commenters sought effects analysis considering how those reliant on the subsistence 

lifestyle are particularly sensitive to change in ecological health as it impacts their own human health in a 

myriad of ways. 

Response 022: The EIS recognizes the important role that subsistence plays in Southeast 

Alaska communities. Potential impacts to subsistence are considered at the Forest-level (see the 

Subsistence section) and in community-specific discussions provided as part of Appendix E.

Comment 023: Commenters sought further effects analysis of the cumulative socioeconomic impact of 

the loss of deer, fish, and other resources to subsistence communities over time.

Response 023: The 2016 Forest Plan Amendment EIS considered the cumulative effects of 

timber harvest on deer habitat capability at the Forest-level and also for the WAAs where each 

community obtains approximately 75 percent of their average annual deer harvest. Appendix E in 

the FEIS has been revised to include an assessment of potential subsistence impacts at the 

community level. The findings of the 2016 analysis are included as part of this analysis. Forestwide cumulative effects to subsistence are considered in the Subsistence section of the EIS, with 

further cumulative effects discussion provided in Appendix B. 

Comment 024: Commenters stated that the United States has specific and enforceable fiduciary 

responsibilities to protect and refrain from impairing tribal dependent resources. These commenters 

believe that the Forest Service should keep the Roadless Rule intact to ensure the protection and 

preservation of these and other reserved rights, resources and habitats, and to safeguard the health, 

livelihood and well-being of tribal citizens of Alaska. Commenters said that, because the State of Alaska 

does not recognize subsistence rights, the federal priority to protect resources for subsistence users is 

even more crucial as a last line of defense. 

Response 024: The Alaska Roadless Rule, developed in response to the State of Alaska's 

petition, was designed to provide for the continued conservation of roadless areas while 

accommodating timber harvest and road construction/reconstruction activities that are determined 

to be needed for forest management, economic development opportunities, and the exercise of 

valid existing rights or other non-discretionary legal authorities. No site-specific projects or 

ground-disturbing activities are authorized in the final rule. Any such projects would undergo 

environmental analysis in compliance with NEPA, and the final rule does not waive any applicable 

requirements regarding environmental analysis, public involvement, consultation with federally 

recognized tribes, Alaska Native Corporations, or other agencies, compliance with other laws, 

and/or compliance with the current Forest Plan.
Appendix H

Final EIS H-9 Response to Comments

Comment 025: Commenters said that Alaska’s constitution mandates that preserving resources for 

subsistence use be prioritized over any commercial uses and that changing the Roadless Rule would 

therefore be unconstitutional because it only benefits large-scale commercial logging while negatively 

impacting subsistence resources.

Response 025: The Alaska Roadless Rule, developed in response to the State of Alaska's 

petition, was designed to provide for the continued conservation of roadless areas while 

accommodating timber harvest and road construction/reconstruction activities that are determined 

to be needed for forest management, economic development opportunities, and the exercise of 

valid existing rights or other non-discretionary legal authorities. Potential impacts to subsistence 

are evaluated in the Subsistence section of the FEIS and Appendix E, which has been revised to 

include community-level subsistence assessments. 

Comment 026: Commenters state that the proposed change to the Roadless Rule will directly impact 

both where and when subsistence communities may be able to hunt and search for food. As changes 

impact locations of subsistence access, these areas may be further and further from home which is a 

huge burden on these communities. Having to fish or hunt off-island or further from home presents a 

physical danger to subsistence communities. As changes impact timing of subsistence access, locals

must go out during more dangerous times of year related to weather, ice, snow, and predators.

There was concern that increased roads and loss of habitat due to changes in the rule would mean that 

more subsistence users will be forced to use smaller and smaller areas of land which will make living the 

way of life even harder.

Commenters were concerned that changing the rule to increase areas open for logging would increase 

competition with loggers for subsistence resources that are already dwindling.

Commenters were concerned that changing the Roadless Rule would further decrease access to logging 

areas for locals. Existing logging areas available to local communities have already been whittled down 

due to prior logging activities by multiple entities. Corporate logging is profit-driven, however local logging 

is for subsistence needs such as firewood, canoe, home, and longhouse construction.

Response 026: As discussed in the EIS, timber program output levels are expected to remain 

constant and involve a similar number of acres under all alternatives, varying only by the location 

of timber harvest. This assessment and the proposed alternatives are programmatic, meaning that 

they establish direction and allowable activities for broad land areas, rather than schedule specific 

activities, such as timber harvest, in specific locations. None of the alternatives authorize any sitespecific projects or other ground-disturbing activities. However, potential impacts to communities 

are assessed for 32 Southeast Alaskan communities in Appendix E using four primary measures 

by alternative: 1) acres by ARA management category and change in acres managed as 

roadless; 2) change in acres in development LUDs; 3) change in suitable old-growth acres 

available for harvest, and 4) changes in estimated harvest over 100 years. Impacts are also 

considered for the WAAs where each community obtains approximately 75 percent of their 

average annual deer harvest.

Specific projects that include timber harvest, road construction, and/or road reconstruction will 

undergo site-specific environmental analysis when they are proposed in compliance with NEPA. 

Potential impacts to subsistence resources and users will be assessed as part of these projectlevel analyses. Project-level analyses require a subsistence evaluation and finding in accordance 

with ANILCA Section 810, which specifically address potential impacts in terms of: 1) resource 

distribution and abundance, 2) access to resources, and 3) competition for the use of resources.

Comment 027: Commenters expressed concern that the DEIS does not consider how exporting logs 

drains socioeconomic resources from the local area and subsistence communities.

Response 027: The Region 10 Limited Export Shipment Policy is discussed in the EIS (see the 

R10 Limited Export Shipment Policy subsection included in Chapter 3 as part of the Key Issue 2 

discussion). Reviewed on an annual basis, the Limited Export Policy is intended to boost 

appraised timber values and provide economic sale opportunities by providing additional 
Appendix H

Response to Comments H-10 Final EIS

processing options for purchasers. The share of harvest exported over time is shown in Figure 

3.2-6 in the EIS. In 2018, 46 percent (9.2 million board feet [MMBF]) of the total harvested (20.0 

MMBF) was exported. As with local processing, timber harvested for export provides local 

socioeconomic benefits by supporting local jobs, including logging jobs and jobs in transportation 

and other services. Timber harvested for commercial purposes is no longer available for other 

uses, including subsistence, regardless of whether it is processed locally or harvested for export. 

The potential impacts of the proposed alternatives on the natural and human environment are 

assessed at the programmatic level in the EIS. Specific projects that include timber harvest, road 

construction, and/or road reconstruction will undergo site-specific environmental analysis when 

they are proposed in compliance with NEPA.

Comment 028: Commenters were concerned that the DEIS does not properly capture the timeline and 

processes of ecological succession associated with old-growth forests in the Tongass. For example, 

clear-cuts from previous logging activities are now in the “stem exclusive” phase which means there is 

limited understory and still no good habitat for deer to return to. Stem exclusion lasts some 50-150 years, 

with old-growth forests not returning to climax communities again for 200-300 years. The impact of this 

timeline on deer habitats and populations is multi-generational on both deer and the subsistence 

communities who rely on them. 

Response 028: The 2016 Forest Plan Amendment EIS considered the cumulative effects of 

timber harvest on deer habitat capability at the Forest-level and also for the WAAs where each 

community obtains approximately 75 percent of their average annual deer harvest. Potential 

impacts were projected by alternative for 100 years of Forest Plan implementation. Appendix E in 

the FEIS has been revised to include an assessment of potential subsistence impacts at the 

community level. The findings of the 2016 analysis are included as part of this analysis and 

potential impacts by alternative and community are considered in the context of projected impacts 

following 100 years of implementation of the current Forest Plan. 

Comment 029: Commenters said that deer cannot be found in clear-cuts; therefore, hunters lose access 

to deer populations when they move out of the area to avoid clear-cuts from logging activities.

Commenters were concerned with low deer populations due to over-hunting, rather than climate change 

or impacts from timber industries. Commenters said that hunting in clear-cuts is easier than hunting in 

old-growth forests and that changing the Roadless Rule will have a limited effect on deer hunting.

Response 029: The potential impact of clear-cuts on subsistence hunting is discussed at the 

Forest-level in terms of access (see the Subsistence section of the EIS). As noted in this 

discussion, subsistence hunters have varying opinions on the effects of clear-cut harvest on 

hunting success, with some saying that clear-cuts are productive for some years after harvest, 

while others prefer not to use clear-cuts.

Comment 030: Commenters sought effects analysis disclosing how the proposed rule change would 

directly and indirectly impact subsistence users and harvesters in the Tongass National Forest. Effects 

analysis should consider changes in subsistence distribution resulting from climate change.

Response 030: Potential direct and indirect impacts to subsistence users are evaluated at the 

Forest-level in the FEIS (see the Subsistence section). Impacts to individual communities are 

assessed in Appendix E. Climate change is considered as part of the cumulative effects analysis 

presented in Appendix B. 

Comment 031: Commenters expressed concern with the adequacy of the analysis of effects of 

roadbuilding on subsistence resources. Commenters also requested the use of more current data rather 

than relying on the data used in the 2016 Forest Plan Amendment EIS. 

Response 031: The impacts of roads on fish and wildlife resources are discussed under Key 

Issue 3 in the EIS. The subsistence information presented in the EIS is the most current data 

available. Much of this data, including community level survey information compiled from ADF&G 

and existing deer harvest levels by WAA, has not been updated since 2016. Appendix E in the 
Appendix H

Final EIS H-11 Response to Comments

FEIS has been revised to include an assessment of potential subsistence impacts at the 

community level. 

Citizen Advisory Committee

Comment 032: There was concern that the Citizen Advisory Committee (CAC) membership was not 

representative of all stakeholders and that the CAC lacked procedural safeguards, an understanding of 

the 2001 Roadless Rule, sufficient to make informed recommendations.

Response 032: The committee was developed by the State of Alaska under an Administrative 

Order issued by Governor Walker in September 2018. The committee was charged with providing 

recommendations to assist the State of Alaska in fulfilling its role as a cooperating agency. The 

thirteen committee members were selected by Governor Walker, and the USDA and Forest 

Service had no part in the selection. The Forest Service provided an individual to participate on 

the committee as a non-voting member to provide procedural and technical information to the

committee. The thirteen committee members were selected by Governor Walker to represent a 

diversity of perspectives, including Alaska Native corporations and tribes, fishing, timber, 

conservation, tourism, utilities, mining, transportation, local government, and the Alaska Division 

of Forestry. The Committee met for three in-person meetings in the fall of 2018 (October 2-3 in 

Juneau; October 24-26 in Ketchikan; and November 6-8 in Sitka). Meetings were open to the 

public, and each meeting included an opportunity for public comment. A final report was produced 

with options for the State of Alaska to consider, and the State included this report as part of their 

Cooperating Agency comments to the Forest Service. 

Comment 033: Commenters were concerned that CAC recommendations did not appear to be 

considered and/or reflected in the DEIS and that the action alternatives lacked language proposed by 

CAC including the new road and timber cutting exceptions.

Response 033: The CAC recommendations that were provided to the Forest Service through the 

State of Alaska were considered by the Alaska Roadless Rule interdisciplinary team, along with 

all of the information the team received from the public, the other cooperating agencies, and 

through consultation with affected federally recognized tribes. USDA believes the 

recommendations were incorporated into one or more of the action alternatives. The CAC’s 

recommendations for Alaska-specific roadless area characteristics were considered and partially 

incorporated by considering, and in some instances combining, the intent of the recommended 

language with the 2001 Roadless Rule language. The Forest Service often utilizes the roadless 

area characteristics as a means of assessing impacts for projects on roadless area values. Much 

of the CAC’s recommendations did not lend themselves to this. Table 3.1-1 in the FEIS compares 

the CAC’s recommended roadless area characteristics with the proposed Alaska roadless area 

characteristics.

In addition, the CAC recommended a variety of changes and/or additions to the exceptions 

language compared to the 2001 Roadless Rule. The exceptions language for Alternatives 2-5 has 

been modified to better align with the CAC’s recommendations and the State of Alaska’s input as 

a cooperating agency.

Comment 034: Commenters expressed concern that granting funds to the State of Alaska to support the 

State’s involvement in the Alaska Roadless Rulemaking process violated the Federal Advisory Committee 

Act, was a misuse of congressional appropriations, and created a conflict of interest.

Response 034: The agency provided the State of Alaska’s Forestry Division with $2 million from 

the fiscal year 2018 Consolidated Program Grant (CPG), Modification 2, utilizing the State Fire 

Assistance budget line item as the source code. The modification discussed the specific use of 

the funding, which could be used for: convening and facilitating a group with a diverse mix of 

state-specific interests to inform the State’s input as a cooperating agency, public meetings, 

cooperating agency support, economic analysis and planning, and to coordinate the proposed 

state rule with existing land management planning efforts in progress within the State of Alaska. A 

subsequent modification has been executed utilizing $1.3 million of the funding to undertake 
Appendix H

Response to Comments H-12 Final EIS

wildland fire risk reduction projects in several Alaska communities, primarily construction of fuel 

breaks and maintenance of established fuel breaks.

The committee does not meet the definition of an advisory committee as defined by the FACA (41 

CFR 102-3.25). The committee was established under state law by the Governor of Alaska. The 

committee reported directly to the Governor who submitted the committee’s report to the USDA 

as part of the State’s participation as a cooperating agency. Intergovernmental coordination with 

the Governor or his appointees is not subject to FACA. In any event, the USDA and Forest 

Service did not manage or control the committee’s operation and did not utilize its work within the 

meaning of FACA. USDA’s involvement with the committee was limited to non-voting 

participation, providing technical assistance. The committee did not have undue influence over 

the rulemaking process.

National Forest Management and the Tongass Forest Plan

Comment 035: Commenters express concern about the Forest Service’s ability to manage forests, as 

they do not have the staff nor the budget to adequately enforce management of the forest.

Commenters provided examples of land management best practices for logging not being followed 

regionally and concern that expanding areas available for logging would only spread the implementation 

of harmful practices.

Response 035: While the successful achievement of the goals of Alaska Roadless Rulemaking 

is ultimately dependent on investments and funding decisions made by Congress, the Forest 

Service remains committed to allocating staff and financial resources to planning and 

implementing projects that are important to the communities of Southeast Alaska, and to the 

American public. Land management activities would continue to be managed in accordance with 

the 2016 Forest Plan under all the alternatives considered in this EIS. Specific issues related to 

best management practices are Forest Plan-related issues and are beyond the scope of this EIS. 

This EIS does not authorize logging or set annual limits on logging or establish specific 

silvicultural or logging practices or prescriptions.

Comment 036: Commenters were concerned that Alternative 6 is in direct conflict with the Tongass Land 

Management Plan (Forest Plan), and that moving forward with the proposed rule would negate the Forest 

Plan, requiring it to be updated. Commenters said that the Forest Plan should be updated before making 

any changes to the Roadless Rule’s protections. 

Response 036: Chapter 2 of this FEIS describes the relationship of Alaska Roadless Rulemaking 

to the 2016 Tongass Forest Plan. Except for the administrative change to the timber land 

suitability determinations discussed below, none of the alternatives would make any changes to 

the goals and objectives, land use designations or management prescriptions, forest-wide 

standards and guidelines, projected timber sale quantity, projected wood sale quantity, or the 

young-growth transition strategy of the Tongass Forest Plan. 

An administrative change would apply to lands that were deemed unsuitable solely due to 

inventoried roadless area designation in the 2016 Tongass Forest Plan. However, no site-specific 

projects or ground-disturbing activities are authorized in the final rule. Any such projects would 

undergo environmental analysis in compliance with NEPA, and the final rule does not waive any 

applicable requirements regarding environmental analysis, public involvement, consultation with 

federally recognized tribes, Alaska Native Corporations, or other agencies, compliance with other 

laws, and/or compliance with the Tongass Forest Plan.

Comment 037: Commenters expressed concern about changes to the Forest Plan, saying that any 

substantial changes to suitable timber designations were not significantly raised during scoping and any 

substantial changes to suitable timber designations following the exemption of the Tongass National 

Forest from the Roadless Rule would require following the rulemaking guidance for Special Areas, Forest 

Plan Amendment Revisions, and the Administrative Procedures Act before the Forest Service could 

authorize any road construction, reconstruction, or timber harvest in those areas. The 2016 Forest Plan 
Appendix H

Final EIS H-13 Response to Comments

does not address the impacts that changing timber suitability designations would have on roadless areas, 

which is required. The proposed changes would modify the Forest Plan as amended, including 

determinations that the Forest Plan is in alignment with Tongass Conservation Strategy and Recreation 

Opportunity Spectrum guidance.

Response 037: The Secretary has extensive authority governing forest management and the 

development, amendment, or revision of land management plans, and new laws and regulations 

can supersede land management plan direction. The administrative change regarding timber 

suitability would only apply to lands that were deemed unsuitable solely due to inventoried 

roadless area designation in the 2016 Tongass Forest Plan. However, no site-specific projects or 

ground-disturbing activities are authorized in the final rule. Any such projects in these areas 

would undergo environmental analysis in compliance with NEPA, and the final rule does not 

waive any applicable requirements regarding environmental analysis, public involvement, 

consultation with federally recognized tribes, Alaska Native Corporations, or other agencies, 

compliance with other laws, and/or compliance with the Tongass Forest Plan.

Even the full exemption alternative would still result in full alignment of the Forest Plan with the 

Old Growth Habitat Conservation Strategy as that strategy, developed for the 1997 Forest Plan 

Revision, was developed in the absence of the Roadless Rule, which had not been enacted at 

that date. In addition, the current Forest Plan, without the Roadless Rule, is even more 

conservative of old-growth habitat than was the 1997 Forest Plan. 

Comment 038: Commenters were concerned that if a Roadless Rule exemption occurs, the Forest 

Service will then revise or amend the 2016 Forest Plan. They believe a forest plan revision or amendment 

is reasonably foreseeable since the State of Alaska's petition specifically requested changes to the 

Tongass Forest Plan and the commenter(s) believe that rebuilding the timber industry in Southeast 

Alaska is the purpose of the Alaska Roadless Rule.

Response 038: The proposed Alaska Roadless Rule, developed in response to the State of 

Alaska's petition, establishes a land classification system that conserves roadless area 

characteristics while analyzing alternatives that would accommodate timber harvest and road 

construction/reconstruction activities that are determined to be needed for forest management, 

economic development opportunities, and the exercise of valid existing rights or other nondiscretionary legal authorities. As stated above, no site-specific projects or ground-disturbing 

activities are authorized in the final rule. With the exception of the administrative change to timber 

suitability discussed above, no other changes to the Tongass forest plan are included in the rule. 

Any future forest plan amendments or revision would undergo forest planning in compliance with 

NFMA and the 2012 Planning Rule and environmental analysis in compliance with NEPA, and the 

final rule does not waive any applicable requirements regarding environmental analysis, public 

involvement, consultation with federally recognized tribes, Alaska Native Corporations, or other 

agencies, compliance with other laws, regulation, or policy.

Comment 039: The Forest Service cannot administratively change the designation of lands suitable for 

logging because only a forest plan revision or amendment can be used to change a "plan component.” 

Response 039: The Secretary has extensive authority governing forest management and the 

development, amendment, or revision of land management plans, and new laws and regulations 

can supersede land management plan direction. The 2012 Planning Rule recognizes this 

authority and provides for administrative changes to forest plans to conform to new statutory or 

regulatory requirements. While timber suitability is a forest plan component that would normally 

be addressed through the development, amendment, or revision of a forest plan, the Planning 

Rule recognizes that forest plan components may be changed administratively under certain 

circumstances, as noted above (36 CFR 219.13(a), (c)).

Comment 040: Commenters supported changes to the Forest Plan for increased timber harvest, 

including old growth. Some suggested the Forest Plan be revised to eliminate the transition to a 

predominantly young-growth timber program.
Appendix H

Response to Comments H-14 Final EIS

Response 040: Changes to the young growth transition strategy of the Tongass Forest Plan are 

outside the scope of this rulemaking effort. With the exception of the administrative change to 

timber suitability discussed above, no other changes to the Tongass Forest Plan are included in 

the rule.

Comment 041: There was concern that adjustments to timber suitability or old growth harvest acres by 

the proposed rule and alternatives would require amending or revising the Forest Plan to modify desired 

conditions and land suitability decisions to include IRAs. Commenters said there is no demonstrated 

urgent need for changing the Roadless Rule and that any Forest Plan revision should occur as a parallel 

process with the Roadless Rule change. Further, there was concern that the Timber Priority Area 

management category, as presented in Alternative 4, is not a narrowly focused exception to roadless 

area desired conditions.

Response 041: The Secretary has extensive authority governing forest management and the 

development, amendment, or revision of land management plans, and new laws and regulations 

can supersede land management plan direction. The 2012 Planning Rule recognizes this 

authority and provides for administrative changes to forest plans to conform to new statutory or 

regulatory requirements. While timber suitability is a forest plan component that would normally 

be addressed through the development, amendment, or revision of a forest plan, the Planning 

Rule recognizes that forest plan components may be changed administratively under certain 

circumstances (36 CFR 219.13(a), (c)).

No other changes to the Tongass Forest Plan are included in the rule. Any future forest plan 

amendments or revision would undergo forest planning in compliance with NFMA and the 2012 

Planning Rule and environmental analysis in compliance with NEPA. 

With regard to the Timber Priority Alaska roadless area land management category (included in 

Alternative 4), this category would apply to approximately 856,000 acres under that alternative. 

While there would be no regulatory prohibitions on timber harvest or road construction or 

reconstruction for the areas in this category, Forest Plan goals and objectives, standards and 

guidelines, and other forest plan components would remain in place and would help conserve 

roadless area characteristics and values. 

Comment 042: Commenters were concerned that the use of the administrative change procedure to 

reclassify vast tracts of pristine old-growth forest to facilitate logging without amending the Forest Plan is 

not consistent with the intent of the administrative change provision in the 2012 Planning Rule. There was 

concern that this issue was not sufficiently identified or discussed by USDA or the Forest Service during 

scoping.

Response 042: The administrative change provision at 36 CFR 219.13(c) states that an 

administrative change includes changes to conform to new regulatory requirements. Although the 

provision was not expressly included in the proposed action during scoping, it was highlighted in 

the DEIS and conforms to the requirements of the NEPA implementing regulations.

Comment 043: Commenters were concerned that an exemption would undermine the collaborative work

that went in to developing the Forest Plan. In the development of the Forest Plan, the collaborative group 

recommended phasing out large-scale old-growth logging over a 16-year period, easing standards and 

guidelines to allow increased access to young-growth timber as a way of encouraging the transition away 

from old-growth logging, and protecting important areas from future logging, including roadless areas, the 

Tongass 77 (T77) watersheds, and The Nature Conservancy (TNC)/Audubon Conservation Priority 

Areas. The expectation of the Forest Plan collaborative group was that its recommendations be taken as 

a whole and not adopted partially or in a piecemeal manner.

Response 043: No aspect of the Forest Plan is being changed, with the exception of the 

administrative change relating to lands that would be suitable were it not for roadless status (see 

previous comment response). The removal (or addition in some cases) of roadless designations 

is not directly related to the Forest Plan. Phasing out large-scale old-growth logging over a 16-

year period and easing standards and guidelines to allow increased access to young-growth 
Appendix H

Final EIS H-15 Response to Comments

timber as a way of encouraging the transition away from old-growth logging is still "in play" under 

all alternatives. Current protections for Tongass 77 watersheds and the TNC/Audubon 

Conservation Priority Areas also remain in place.

Comment 044: Commenters request that the forest be managed by the Forest Service to meet the 

agency mission and for multiple use and the health of the forest.

Response 044: This is a Forest Plan issue and is therefore beyond the scope of this EIS. 

Nonetheless, the sustained health of the Forest is of primary concern to Tongass National Forest 

managers.

Comment 045: Commenters said that control/management of the Tongass National Forest should be 

given back to the State of Alaska.

Response 045: This comment is beyond the scope of this EIS because this EIS is only analyzing 

prohibition of timber harvest and road construction within designated roadless areas.

Comment 046: Commenters were concerned that activities in old-growth stands would lead to a loss of 

opportunity to inventory, study and to further understand the aerosols, pheromones, and chemicals that 

occur with the oldest and largest trees of each species and subspecies of tree.

Response 046: Comment noted. 

Comment 047: Commenters referred to how clearcut old-growth forests do not ever grow back in the 

same way, particularly due to the impacts of a changing climate on how these ecosystems and vegetation 

are able to respond. 

Response 047: This comment is beyond the scope of this EIS because the Alaska Roadless 

Rulemaking EIS is programmatic and does not evaluate the site specific impacts of timber 

harvest.

The analyses in the FEIS are a generalized review which the Council on Environmental Quality 

recognizes as appropriate for any broad or high-level NEPA review of proposed policies, plans, 

programs, or projects. It is reasonable and efficient to limit detailed site-specific impact analyses 

to when specific proposals are brought before the agency. Locations of potential timber harvest 

and road construction are not known at this time. It is not known if, when, or specifically where 

they would occur. When specific timber harvest or other projects are proposed, site-specific 

NEPA analysis and required pubic involvement would be conducted at that time. No on-theground actions are authorized by the final rule.

Comment 048: The Forest Service’s proposal for exemption and claim that it will not cause direct harm, 

without explanation, contradicts its own findings from 2001 that logging, development, and roads have 

direct correlations with harm to National Forests.

Response 048: The USDA does not dispute that timber harvesting and road construction impact 

roadless area values and characteristics. However, the impact analyses in the Rulemaking for 

Alaska Roadless Areas FEIS do not analyze the effects of harvesting timber and constructing 

roads in a specific roadless area or location. Rather the FEIS analyzes the difference in effects 

under the 2001 Roadless Rule, the current Tongass Forest Plan, and the other action 

alternatives.

The programmatic impacts of logging, development, and roads are discussed throughout the 

FEIS, which presents analysis to document the conclusions. The commenter should be reminded 

that the effects of the alternatives with more acres of exemption are generally presented as 

higher, even though the overall effects are not substantially different because the overall level of 

harvest is expected to be similar.

Comment 049: Commenters asked whether the Chicken Creek area on the north end of Chichagof 

Island which is presently managed under the Old-Growth Habitat LUD would remain protected under the 

full exemption alternative (Alternative 6).
Appendix H

Response to Comments H-16 Final EIS

Response 049: Under the current Forest Plan, the Chicken Creek area is allocated to the OldGrowth Habitat LUD. The area would continue to be managed in accordance with the Old-Growth 

Habitat LUD under all of the alternatives. 

Comment 050: Commenters sought a Forest Plan amendment to include updates to the suitable lands 

designation and timber transition strategies in consideration of the economic viability of the timber 

industry.

Response 050: Forest Plan amendments are outside of the scope of this analysis. The 

alternatives do include an administrative change regarding timber suitability that would only apply 

to lands that were deemed unsuitable solely due to inventoried roadless area designation in the 

2016 Tongass Forest Plan.

Comment 051: Commenters are concerned that the project will reduce scenery standards and values on 

NFS and adjacent lands by allowing additional clearcutting, namely through Forest Plan Amendment.

Response 051: Any future forest plan amendments or revision would undergo forest planning in 

compliance with NFMA and the 2012 Planning Rule and environmental analysis in compliance 

with NEPA, and the final rule does not waive any applicable requirements regarding 

environmental analysis, public involvement, consultation with Alaska tribes, Native Corporations, 

or other agencies, compliance with other laws, regulation, or policy.

Comment 052: Commenters were concerned that projecting over 25 years is not appropriate because 

Forest Plans should be revised every 10-15 years.

Response 052: The forests of Southeast Alaska are very long-lived ecosystems. Stands of trees 

do not begin to gain old-growth characteristics until they are 150 to 250 years old. Some 

commenters wanted us to project for 250 years. Projecting for only 25 years would allow only 

relatively short-term effects to be quantitatively addressed. The 100-year projection was used to 

be able to consider the long-term effects of decisions that are made today and that last for well 

over 100 years. The 100-year projection has been used for many resources on the Tongass in 

the NEPA evaluations for all Forest Plan revisions and amendments over the past 25 years, so 

consistency allows comparisons.

Comment 053: Commenters stated that the Change to Timber Land Suitability acres should be updated 

to remove the Alaska Roadless Areas and LUD II Priority lands and reflect that timber production will not 

occur in these areas. Designated Alaska Roadless Areas and LUD II Priority lands are not suitable for 

timber production, since timber production and road construction are inconsistent with Roadless Area and 

LUD II desired conditions.

Response 053: For each of alternatives 2 through 5, the Tongass Forest Supervisor would issue 

a ministerial Notice of Administrative Change pursuant to 36 CFR 219.13(c) identifying plan 

changes made in conformance with the selected alternative.

Chugach National Forest

Comment 054: Commenters were concerned with the proposed provisions that allow changes to 

designations within the Chugach National Forest. Commenters felt the provisions were too broad and not 

specific enough and could lead to additional logging and associated impacts in the Chugach. 

Commenters sought clarity as to the definition and scope of modifications and classifications for Chugach 

NF proposal, and sought a more thorough discussion of the Chugach in the EIS. Some commenters were 

concerned that the administrative boundary provisions for the Chugach National Forest were not part of 

the State’s petition and not responsive to the purpose and need, and thus felt it should be removed.

Response 054: Based on public comments, consultation(s), and discussions with cooperating 

agencies, the provisions described in the draft environmental impact study relating to inventoried 

roadless areas on the Chugach and the allowance for administrative boundary modifications and 

corrections have been removed from all alternatives. No aspects of the Final Rule will have an 

effect of the inventoried roadless areas within the Chugach National Forest. 
Appendix H

Final EIS H-17 Response to Comments

Comment 055: Commenters suggest the Forest Service extend the exemption from the Roadless Rule to 

the Chugach National Forest to improve access for hydropower development.

Response 055: The State’s petition for an exemption from the 2001 Roadless Rule only 

requested it for the Tongass National Forest and not the Chugach National Forest. Therefore, the 

agency did not extend the exemption to the Chugach. However, hydropower development is not 

an activity prohibited by the 2001 Roadless Rule and thus hydropower development could occur 

on the Chugach National Forest.

Purpose and Need

Comment 056: The State of Alaska’s petition does not reflect the national importance (described in the 

2001 Roadless Rule) of the Tongass National Forest roadless areas and gives preference to the State of 

Alaska's desires for local timber production.

Response 056: The FEIS acknowledges the importance of roadless areas for wildlife and fish 

habitat, recreation values, multiple economic sectors, traditional properties and sacred sites for 

local indigenous people, inherent passive use values, and the ecosystem services values they 

provide for all Americans (see Chapter 1). The Alaska Roadless Rule, developed in response to 

the State of Alaska's petition, was designed to provide for the continued conservation of these 

areas while accommodating timber harvest and road construction/reconstruction activities that 

are determined to be needed for forest management, economic development opportunities, and 

the exercise of valid existing rights or other non-discretionary legal authorities. 

Comment 057: Commenters asked how changes to the Roadless Rule would help the agency meet its 

responsibilities for sustaining health, diversity, and productivity of forests to meet the needs of present 

and future generations. 

Response 057: Changes to the Roadless Rule do not have a direct effect on the mission of the 

Forest Service, which is to sustain the health, diversity, and productivity of the nation's forests 

and grasslands to meet the needs of present and future generations. These issues may be 

directly affected by projects that are permitted in the areas affected by changes to the Roadless 

Rule, but these projects are subject to their own NEPA review.

Comment 058: Commenters question the need for project because the 2001 Roadless Rule already 

provides flexibility and natural resource extraction through exemptions.

Response 058: The Alaska Roadless Rule, developed in response to the State of Alaska's 

petition, is designed to provide for the continued conservation of roadless areas while 

accommodating timber harvest and road construction/reconstruction activities that are determined 

to be needed for forest management, economic development opportunities, and the exercise of 

valid existing rights or other non-discretionary legal authorities. The Tongass National Forest is 

unique from other national forests in respect to the size of the forest, the large percentage of 

roadless areas that comprise it, the degree of dependency of local communities on the forest, and 

forest-specific statutory considerations. While the 2001 Roadless Rule included some exceptions 

that allow activities that accommodate the biological, social, and economic situation of 

communities in Southeast Alaska, additional exceptions were added to the alternatives 

considered for the Alaska Roadless Rule to improve overall clarity and to respond to specific 

Southeast Alaska needs not anticipated by or provided for in the 2001 Roadless Rule. For 

example, the 2001 Roadless Rule does not allow roads to be built for new leasable mineral 

projects such as geothermal.

Comment 059: Commenters question the need for the exception that allows for timber harvest to 

improve, restore or maintain fish and wildlife habitat. 

Response 059: The exception to the prohibition on timber harvest that would allow timber 

harvest in Alaska roadless areas to maintain, restore, or improve fish and wildlife habitat is 

included in Alternatives 2-5 of the Rulemaking for Alaska Roadless Areas DEIS. Alternative 1, the 

No-Action Alternative (which would retain the 2001 Roadless Rule on the Tongass National 
Appendix H

Response to Comments H-18 Final EIS

Forest) includes a similar exception that allows timber harvest to improve threatened, 

endangered, proposed, or sensitive species habitat or to maintain or restore the characteristics of 

ecosystem composition and structure (36 CFR 294.13(b)(1)(i), (ii)). The harvest of timber under 

this exception would provide for habitat patches, connectivity, structural diversity, and stream 

conditions determined, through project-specific analyses, to be needed for the improvement of 

fish and wildlife habitat on the forest. 

Comment 060: The purpose and need statement is vague and confusing and lacks meaningful criteria 

for formulation and comparison of alternatives. 

Response 060: The purpose and need statement is a brief statement as to what underlying 

purpose the agency is responding to in the proposed action and alternatives. It is not necessarily 

a means of providing meaningful criteria for formulation and comparison of alternatives. The key 

issues were identified to assist in the formulation and comparison of alternatives.

Comment 061: The proposed rule gives preference to the State of Alaska's idea of local timber 

production desires and does not support the national need to protect roadless areas within the Tongass 

National Forest.

Response 061: The Notice of Proposed Rulemaking (84 FR 55523) states the USDA gave 

“substantial weight to the State’s policy preferences,” which is not the same as giving preference 

to the State’s desires on local timber production. The State’s desire to emphasize rural economic 

development opportunities is consistent with the Department’s desires to support rural economic 

development. In addition, the majority of the areas considered for exemption from the 2001 

Roadless Rule would not be available for timber harvest due to Forest Plan direction.

Comment 062: Commenters are concerned about the rationale used to support and demonstrate need.

Response 062: As stated in the Notice of Proposed Rulemaking, the Alaska Roadless Rule 

reflects a different policy perspective on the roadless management issue rather than a change in 

the underlying facts and circumstances. This administration believes the states have valuable 

insight in understanding the balance between rural economic development and environmental 

protection, and that overall reduction in federal regulations is good for the American public due to 

reduced burden to the taxpayer and reduced burden to business. 

Comment 063: Commenters stated that exempting 9.2 million acres of inventoried roadless acres 

(Alternative 6) would not resolve controversy with regards to managing roadless areas and does not 

adequately meet the purpose and need.

Response 063: History highlights that Roadless Rulemaking has been controversial and often 

litigated since promulgation of the 2001 Roadless Rule. Since that time, several states requested 

state-specific rulemaking in order to develop a Roadless Rule that best fits the circumstances of 

the state, its geography, and public interests. With regard to Alaska specifically, the Secretary is 

aware of the ongoing controversy related to the 2001 Roadless Rule and to management of 

roadless areas on the Tongass National Forest in general. Roadless rulemaking is a 

programmatic-level decision with broad authority given to the Secretary, and, after considering 

the ongoing controversy related to roadless areas on the Tongass, he has prioritized economic 

opportunity, federal deregulation, and the expressed positions of statewide-elected officials in 

selecting an alternative he believes best responds to the overall purpose of the project. 

Public Involvement

Comment 064: Commenters state that the Roadless Rule should reinforce the Tongass Advisory 

Committee (TAC) recommendations in the 2016 Forest Plan by protecting the Tongass 77 watersheds 

and TNC/Audubon Conservation Priority Areas. The TAC can serve as a roadmap for incorporating public 

interest and economic realities into an Alaska Roadless Rule.

Response 064: The 2016 Tongass Forest Plan is based on the recommendations of the 

Tongass Advisory Committee (TAC). Except for the administrative change to the timber land 
Appendix H

Final EIS H-19 Response to Comments

suitability determinations discussed above, none of the alternatives considered for the Alaska 

Roadless Rule would make any changes to the goals and objectives, land use designations or 

management prescriptions, forest-wide standards and guidelines, projected timber sale quantity, 

projected wood sale quantity, or the young-growth transition strategy of the Tongass Forest Plan. 

This includes all forest plan direction applicable to the T77 Watersheds and TNC/Audubon 

Conservation Priority Areas. Therefore, these areas would continue to receive the protections 

outlined in the 2016 Tongass Forest Plan, which includes no old growth harvest in these areas, 

as recommended by the TAC.

Comment 065: Commenters were concerned with the adequacy of public involvement efforts, such as, 

length of the public comment period, requests for additional public meetings (including outside Alaska), 

opportunities for oral testimony at public meetings, and scoping being initiated late in the process. 

Commenters felt that decisions of this magnitude should be discussed and decided over a longer period 

of time. Some commenters believe USDA and the Forest Service are in violation of the 1st Amendment 

by not allowing oral testimony. Another commenter felt that public hearings should allow for anonymous 

statements from community members who are not comfortable stating their names for the record.

Commenters requested community education workshops on the 2001 Roadless Rule. 

Response 065: The Forest Service conducted two cycles of public comment: the first was a 45-

day scoping period from August 30, 2018, to October 15, 2018, in which about 144,000 comment 

letters were received; and the second was a 60-day comment period on the proposed rule and 

DEIS from October 18, 2019, to December 17, 2019, which resulted in about 267,000 comment 

letters. During the scoping period 17 public meetings were held and during the comment period 

21 public meetings were held throughout southeast AK, Anchorage, AK, and Washington, DC. 

The USDA recognizes that many would have desired long scoping and comment periods. The 

length of the scoping and comment periods are standard for both the rulemaking and EIS 

processes. The robust meeting attendance and the 411,000 total comments received indicates 

the timing and length were adequate.

The USDA values the comments received, and the concerns expressed during the rulemaking 

process. The USDA considered public comments received, the range of alternatives examined in 

the DEIS and FEIS, and input from cooperating agencies and elected officials. Public comments 

were utilized to craft the range of alternatives examined in the DEIS and FEIS. The NEPA and 

rulemaking public comment process are not vote-counting processes. Every comment has value, 

whether expressed by one individual or thousands. The public comment process considers the 

substance of each individual comment rather than the number received. No interest group’s 

views, or comments are given preferential treatment or consideration, and comments are 

considered without regard to their origin, commenter’s affiliation, or number received. The 

information the Forest Service received was also used to inform the Responsible Official for the 

Alaska Roadless Rulemaking effort, the Secretary of Agriculture.

Comment 066: There was concern that the rulemaking processes contributed to a practice of 

discrimination by minimizing or eliminating the voices of marginalized and low-income communities.

Response 066: The Alaska Roadless Rulemaking effort provided opportunity for meaningful 

engagement by tribes, other government agencies, stakeholder groups, communities, and the 

general public. The public participation process employed for the Project is described in Chapter 

1 of the EIS in the Public Participation section.

An analysis was conducted of the Alaska Roadless Rule alternatives and documented in the Civil 

Rights Impact Analysis. The analysis concluded that the final rule is not projected to exclude, 

limit, or otherwise disadvantage any group or class of persons from using or benefiting from 

resources on the Tongass National Forest. In addition, the analysis found the final rule would not 

create any barriers to equal program participation nor access to benefits available to all affected 

populations.

Additionally please refer to our responses to comment 007.
Appendix H

Response to Comments H-20 Final EIS

Comment 067: Commenters expressed concern that Native Tribes, organizations, and people are not 

properly supported, represented, heard, or understood when it comes to these kinds of regulatory 

changes and that involvement processes are not effective.

Response 067: The Forest Service has worked hard to involve Native tribes and the public 

through participation as cooperating agencies, holding 17 public scoping meetings and 21 public 

meetings during the DEIS comment period, and holding numerous government-to-government 

consultation meetings. As a result of the input gathered through these meetings and 

consultations, many changes have been made to the alternatives. However, the Forest Service is 

open to and continually seeks improvement in our Native tribe and public involvement processes.

Comment 068: Commenters expressed concern that the agency does not heed the will of the public 

majority when it comes to action on public lands and that results in consequences, such as increased 

logging with effects like habitat destruction, patchworks of roads, clear cuts and wide-reaching negative 

impacts. 

Response 068: Please refer to our responses to other comments under Public Involvement.

Comment 069: Commenters questioned how and whether public opinion would influence decision 

making. In addition, given challenges with attending hearings in-person (distance, access, obligations, 

scheduling), commenters suggested that public opinion counts should be weighted to reflect that those 

unable to attend likely agreed with the majority present.

Response 069: Information received from the public during public scoping, the public comment 

period for the DEIS, during public meetings and subsistence hearings following publication of the 

DEIS, and at other times during the rulemaking process highlighted the issues important to the 

communities in Southeast Alaska and to the national public and was used to inform the proposed 

alternatives and analysis of potential impacts in the EIS. This information will be used to inform 

the Responsible Official for the Alaska Roadless Rulemaking effort, the Secretary of Agriculture.

Public comments on the DEIS are summarized and responses to the summarized comments are 

provided in Appendix H of this FEIS. In addition, all public comments are available as part of the 

project record. 

The Forest Service appreciates the participation of those people who were able to attend public 

meetings and the subsistence hearings in person. Other opportunities to provide input are also 

available for those unable to attend meetings in person and all input provided is considered 

equally regardless of whether it is provided in person or written form. The Forest Service does not 

compile counts of public opinion.

Comment 070: Commenters sought public outreach about Alternative 6 to reduce opposition through 

education by clarifying that concern about environmental effects of large-scale clearcutting is based upon 

inaccurate information and not supported by USDA rules governing timber sales.

Response 070: Public outreach and involvement activities conducted as part of the Alaska 

Roadless Rulemaking process are summarized in the Public Participation section of Chapter 1 of 

the EIS. The potential impacts of the alternatives are evaluated by resource in the EIS. Public 

comments on the DEIS, including concerns regarding the impacts of timber harvest and 

Alternative 6, are addressed in this appendix. No additional targeted outreach of the type 

described in the comment is proposed or considered necessary as part of this rulemaking 

process. 

Comment 071: Resolutions were received from local governments in support and opposition of 

exempting Roadless Rule protections for the Tongass National Forest.

Response 071: The Forest Service values the input received, and the concerns expressed, 

during the rulemaking process to date. They have highlighted the issues important to both the 

communities in Southeast Alaska and to the national public, which were used to develop 

alternatives that provided a range of management options. The range of management options 
Appendix H

Final EIS H-21 Response to Comments

analyzed in the EIS range from Alternative 1 representing continued application of the 2001 

Roadless Rule and Alternative 6 representing a full exemption from the 2001 Roadless Rule while 

Alternatives 2 through 5 fall between those two. Effects for those alternatives are described in the 

EIS.

The information the Forest Service received was also used to inform the Responsible Official for 

the Alaska Roadless Rulemaking effort, the Secretary of Agriculture.

Comment 072: Comments and resolutions were provided in support of the Southeast Alaska electrical 

intertie and transportation corridor projects to promote regional economic development.

Response 072: The 2001 Roadless Rule (Alternative 1) does not prohibit the construction or 

maintenance of electrical transmission lines that do not require road construction or 

reconstruction. Temporary or permanent roads are not currently permitted in IRAs, with 

exceptions, though temporary linear construction zones can be authorized. However, Alternatives 

2 through 5 added an exception to most ARA categories that would allow road construction for 

electrical interties and other utility systems. 

The 2001 Roadless Rule also provides exceptions to allow construction, reconstruction, or 

realignment of a Federal Aid Highway in IRAs and road construction or reconstruction pursuant to 

reserved or outstanding rights, or as provided by statute or treaty. This includes the State of 

Alaska’s rights under Section 4407 of Public Law 109-59, as amended. Alternatives 2 through 5 

include additional exceptions for road construction in response to transportation needs identified 

by the cooperating agencies and through public and tribal input. 

Comment 073: Commenters sought disclosure of public opinion about the proposed exemption.

Response 073: Public comments are summarized and responses to the summarized comments 

are provided in Appendix H of this EIS. In addition, all public comments are available as part of 

the project record.

Alternatives

Comment 074: Respondents said that the DEIS should have included an alternative that updates the 

roadless inventory to include all roadless areas that were not included as inventoried roadless areas 

under the 2001 Roadless Rule. 

Response 074: The starting point for the Alaska Roadless Areas was the Inventoried Roadless 

Areas from the 2001 Roadless Rule. Alternatives 2 and 3 both include areas outside of these 

inventoried roadless areas. These areas are identified in the 2003 and 2008 roadless analyses 

conducted as part of forest planning efforts. Further, Alternatives 2 and 3 include small islands 

excluded from all three previous inventories/analyses.

Comment 075: Commenters suggested modification of some alternatives by including components of 

another alternative (mixing and matching). An example of this would be modifying Alternative 2 by adding 

the proposed regulatory prohibition of old-growth harvest in T77 Watersheds and TNC/Audubon 

Conservation Priority Areas outside of roadless areas (similar to the Forest Plan) that is part of Alternative 

3.

Response 075: Mixing and matching various components of an alternative is always an option 

for the Responsible Official, as long as the effects are within the range of effects disclosed in the 

EIS. The effects of adding the regulatory prohibition (as opposed to a Forest Plan prohibition) on 

old-growth harvest in T77 Watersheds and TNC/Audubon Conservation Priority Areas outside of 

roadless areas is the same for both Alternatives 2 and 3. The difference between Alternatives 2 

and 3 for this particular issue is that in Alternative 2 the prohibition on old-growth harvest in those 

watersheds is provided for through the Forest Plan, which could be changed through a revision or 

amendment, and in Alternative 3 it would be provided for through regulation, which could only be 

changed through additional rulemaking.
Appendix H

Response to Comments H-22 Final EIS

Comment 076: Commenters expressed concern that the DEIS did not satisfy the requirements of NEPA. 

There was concern that DEIS does not present a range of reasonable alternatives and that the 

alternatives presented were contradictory with arbitrary differences in roadless acreage and logging.

Response 076: The alternatives in the EIS were developed in an effort to respond, in different 

ways, to the issues identified during scoping, particularly the key issues discussed in Chapter 1 of 

the EIS. 

Comment 077: The Forest Service does not explain the differences between the administrative boundary 

correction and modification provisions proposed for Alaska and prior similar provisions. 

Response 077: Based on public comments, consultation(s), and discussions with cooperating 

agencies, the provisions described in the DEIS and proposed rule relating to inventoried roadless 

areas on the Chugach and the allowance for administrative boundary modifications and 

corrections have been removed from all alternatives, including the preferred alternative. No 

aspects of the Final Rule will have an effect on the inventoried roadless areas within the Chugach 

National Forest. In addition, the Forest Service official to approve corrections on the Tongass 

National Forest has been changed from the Regional Forester to the Chief of the Forest Service

in Alternatives 2-5.

Comment 078: Commenters express concern regarding the existing regulatory language which was 

retained from the 2001 Roadless Rule.

Response 078: The regulatory language for all action alternatives has been modified in response 

to the comments received on the DEIS and in response to cooperating agency input.

Comment 079: Commenters expressed preference for Alternative 1 and then provided secondary 

preferences. Individuals listing Alternative 2 as a secondary preference did so because there would not 

be a significant net change in acres protected. Commenters expressed that each national forest belongs 

to all Americans and should be protected by the Roadless Rule.

Response 079: Comment noted. 

Comment 080: Commenters requested that the Forest Service select an alternative that balances 

environmental protections with economic development.

Response 080: Each alternative balances environmental protections with economic development 

to varying degrees.

Comment 081: Commenters expressed opposition to both Alternatives 4 and 5 as they would convert 

inventoried roadless areas into roadless priority areas, reducing protections for these designated areas.

Response 081: Comment noted.

Comment 082: Commenters supported providing regulatory protection of areas identified in the 2016 

Forest Plan as T77 watersheds and TNC/Audubon Conservation Priority Areas (high-priority watershed 

areas) that are outside of designated roadless. Specifically, old-growth timber harvest would be 

prohibited, as is proposed as a component of Alternative 3.

Response 082: The current Forest Plan prohibits old-growth harvest within these areas.

Comment 083: Commenters request the Forest Service reinstate the Transportation Utility System Land 

Use Designation (TUS LUD) that had been removed in the 2016 Tongass Forest Plan. This would allow 

access for renewable energy projects that would have climate change benefits and benefit the local 

community.

Response 083: This is outside of the scope of the Alaska Roadless Rule analysis. However, 

Roadless Priority, Community Use Priority, and Timber Priority designations provide exceptions 

or otherwise allow tree cutting and road building for utility systems. 
Appendix H

Final EIS H-23 Response to Comments

Comment 084: Commenters sought an alternative that broadly protects fish habitat, continues the phaseout of industrial scale old-growth clear-cutting, and prioritizes the restoration of degraded watersheds and 

streams.

Response 084: None of the alternatives would change the ongoing transition away from oldgrowth harvest. Protections to fish habitat and watershed restoration projects would continue 

under all alternatives. There is variation between the alternatives in the degree of protection 

afforded T77 Watersheds and TNC/Audubon Conservation Priority Areas, as described in 

Chapter 2.

Comment 085: Commenters sought protections in addition to what is offered by the existing rule. For 

example, minimizing additional clearcutting and adding lands set aside for specific cultural significance 

(e.g. old-growth trees like red cedar required for canoes, etc.).

Response 085: A broad range of alternatives was analyzed in the EIS. Please refer to the

discussion in Chapter 2 about development of alternatives. Most of the alternatives include 

specific roadless designations, which provide for a range of protections and exceptions to 

address a range of issues. The Roadless and Community Priority ARAs provide for access to and 

harvest of trees for cultural purposes while at the same time prohibiting commercial timber 

harvest. The issue of restricting clearcutting vs. other types of silvicultural prescriptions is a 

Forest Plan issue and beyond the scope of this EIS.

Comment 086: Commenters express support for designating specific areas in the Tongass as managed 

tree farming zones.

Response 086: This request is outside of the scope of the Alaska Roadless Rule analysis.

Comment 087: Commenters express support for designating the Tongass as a national monument and 

others supported designation as a National Park to increase protections.

Response 087: These requests are outside of the scope of the Alaska Roadless Rule analysis 

and beyond the authority of the Secretary of Agriculture. Designating the Tongass National Forest 

as a National Park would take an act of Congress. National monuments may only be established 

through legislation enacted by the U.S. Congress or proclamation of the President.

Comment 088: Commenters expressed support for expanding the Roadless protections in the State of 

Alaska, so additional lands would be designated as off-limits to development. Commenters also 

specifically requested expanded protections for T77 Watersheds and TNC/Audubon Conservation Areas 

outside of current roadless areas.

Response 088: Alternative 3 provides new regulatory protections for T77 Watersheds and 

TNC/Audubon Conservation Areas outside of current roadless areas.

Comment 089: Commenters requested that projects already allowed to be permitted in roadless areas 

should be expressly provided for in any new Alaska Roadless Rule, including the powerline corridor to 

Takatz Lake, Blue Lake, or Glacier Lake licensing or relicensing or additional generational capacity, and 

corridors for road connections.

Response 089: The rule does not affect existing permits or authorizations for occupancy or use 

of National Forest System Lands. Any proposed modifications or future licensing would have to 

be addressed on a case-by-case basis including public participation and preparation of project 

specific analyses.

Comment 090: Commenters request protection for specific watersheds or areas that have been identified 

as the most important to their community, notably but not limited to encompass culturally and traditionally 

important sockeye salmon systems. In many areas within these watersheds, the 2001 Roadless Rule are 

the only protections that apply. Further, the Watershed Priority management category applied to 

TNC/Audubon Conservation Priority Areas and Tongass 77 Watersheds does not add any additional 

protections for these areas as these watersheds were not included on the lists of those areas.
Appendix H

Response to Comments H-24 Final EIS

Response 090: The Forest Service reviewed the specific areas suggested for protection. In 

some cases, no change was made because the areas were already affected by or adjacent to 

existing roads or harvested areas. However, based on comments and input from tribal 

cooperating agencies, Alternatives 2 and 3 were evaluated and changed, where appropriate, to 

minimize effects to high priority sockeye watersheds. See Chapter 1, Changes Between the DEIS 

and FEIS.

However, watershed protection is well provided for even without the 2001 Roadless Rule. Large 

tracts of undeveloped lands and watershed protections are provided by existing statutory and 

forest plan direction, including lands in designated Wildernesses and National Monuments. In 

addition, the TTRA (Pub. L. 101-626, Title II, Section 201) and the National Defense Authorization 

Act for Fiscal Year 2015 (Pub. L. 113-291, 128 Stat. 3729, Section 3720(f)) designated 

approximately 856,000 acres as LUD II areas, which are managed in a roadless state to retain 

their wildland character. Approximately 3.6 million acres in key watersheds (defined in the Forest 

Plan as Tongass 77 Watersheds and The Nature Conservancy/Audubon Conservation Areas) are 

managed for no old-growth timber harvest, thus minimizing adverse impacts to fisheries. 

Management direction of LUD II areas and key watersheds would remain unaffected with the final 

rule.”

Comment 091: Commenters sought preservation of key wetland areas in the Tongass, such as the T77 

Watersheds and TNC/Audubon Conservation Priority Areas. 

Response 091: Alternatives 2 and 3 provided additional protections for the T77 Watersheds and 

TNC/Audubon Conservation Priority Areas. T77 Watersheds and TNC/Audubon Conservation 

Priority Areas are protected from old-growth timber harvest under all alternatives.

Comment 092: Commenters provided input in both support and opposition of each Alternative.

Response 092: A broad range of alternatives was analyzed in the EIS. Please refer to the 

discussion in Chapter 2 about development of alternatives. 

The Forest Service values the input received, and the concerns expressed, during the rulemaking 

process to date. They have highlighted the issues important to the communities in Southeast 

Alaska and to the national public, which were used to develop alternatives that provided a range 

of management options. The range of management options analyzed in the EIS range from 

Alternative 1, representing continued application of the 2001 Roadless Rule, to Alternative 6, 

representing a full exemption from the 2001 Roadless Rule, while Alternatives 2-5 fall between 

those two. Effects for those alternatives are described in the EIS.

The information the Forest Service received was also used to inform the Responsible Official for 

the Alaska Roadless Rulemaking effort, the Secretary of Agriculture.

Comment 093: Commenters expressed opposition to changing the Roadless Rule protections for the 

Tongass and Chugach National Forests. Rationale for maintaining the current rule (Alternative 1) include 

preserving old-growth habitat and avoiding habitat fragmentation. Commenters expressed belief that 

reducing protections would result in an increase in timber harvest and road building that, in turn, would 

result in increased adverse impacts to multiple resources (e.g., habitat, watersheds, subsistence). 

Commenters were generally opposed to exemption because they believed it would result in harm to the 

environment and to tribal dependent resources. Many generally objected to resource extraction by private 

industry. Many supported Alternative 1 over exemption because it was more protective of natural 

resources and still provided economic development.

Response 093: The conservation of aquatic and terrestrial habitat was identified as a key issue 

for the Alaska Roadless Rule EIS, and the EIS addressed the potential effects of each alternative 

on that key issue. While there would be more acres potentially available for harvest of productive 

old growth with each of the Alaska Roadless Rule action alternatives, there would be no change 

in the projected harvest amount from Alternative 1. Table 3.3-8 has been added to the FEIS and 

displays the estimated percent of original high-volume productive old growth (POG) remaining 
Appendix H

Final EIS H-25 Response to Comments

after 100 years (total and within non-development LUDs). Under all alternatives, this would be 

about 85 percent of total and the percent within non-development LUDs would be about 62.

All elements of the proposed Alaska Roadless Rule that would apply to the Chugach National

Forest have been removed.

Comment 095: Commenters expressed opposition to changes of the Roadless Rule protections for the 

Tongass and Chugach National Forests because they felt this process disregarded local input, 

collaboration, and the public interest. Commenters stated support for local decision-making for forest 

projects, activities, and rules.

Response 095: Alternative 1 represents continued application of the 2001 Roadless Rule. 

Regarding local input, collaboration, and the public interest, the Forest Service values the 

comments that have been received, and the concerns expressed, during the rulemaking process 

to date. They have highlighted the issues important to both the communities in Southeast Alaska 

and to the national public, which were used to develop alternatives that provided a range of 

management options as displayed in the Final Environmental Impact Statement.

Comment 096: Commenters expressed support for changes to the Roadless Rule, including the full 

exemption, because they believe the 2001 Roadless Rule (Alternative 1) is too restrictive. Commenters 

believe the Roadless Rule does not provide flexibility for timber and mining industries, forest treatment to 

prevent fires or manage for grazing, and impedes renewable energy and other development. 

Response 096: As stated above, the EIS includes a range of alternatives that were developed in 

response to the key issues identified for the Alaska Roadless Rulemaking project.

Comment 097: Commenters expressed concern about the phrasing of the proposed action changing 

between publishing the Notice of Intent and the 2019 publication of the Notice of Availability of the DEIS 

for comment.

Response 097: As part of the Forest Service effort to improve environmental analysis and 

decision making, proposed actions are more iterative. As additional information is gathered and 

analysis occurs, the proposed action is refined.

Comment 098: Commenters explained that adding the suitable timber lands proposed in the exemption 

would provide the necessary flexibility in selection to allow the Forest Service to offer economic timber 

sales that meet the needs of the timber industry and provides for other development on the Tongass that 

contributes to rural economies.

Response 098: Each alternative varies in the amount of suitable timber lands available for 

harvest and the exceptions allowing for other development.

Comment 099: Commenters expressed that the proposed rule will lead to the extraction of natural 

resources, which will bring jobs to the area, reduce demand for select imports, and stimulate the 

economy. Additional roads and rights of way for utilities are necessary for economic development, 

particularly for the 29 of 32 communities in the region that are not connected to the nation’s highway 

system and are typically surrounded by marine waters and undeveloped Forest land. Exemption will 

support local communities that live, work, hunt, and fish in the Tongass.

Response 099: Potential impacts to the social and economic environment are addressed in the 

Issue 2 section of Chapter 3 of the EIS and in other detailed sections.

Comment 100: LUD II Priority and Roadless protections should overlap to ensure the greatest restriction 

on road construction. One of the strongest combinations of protecting National Forest System lands from 

degradation is overlapping special area designations. These overlapping designations provide a 

complimentary framework for a high-level of protection from overuse and development of federal lands.

Response 100: Alaska Roadless Rulemaking has presented the opportunity to resolve long-time 

errors in roadless boundaries, clarify points of confusion, and develop a straightforward approach 

to managing Tongass National Forest roadless areas. The overlap in statutory (and Tongass 
Appendix H

Response to Comments H-26 Final EIS

Forest Plan) management direction for the LUD II land use designation and roadless regulatory 

provisions (under the 2001 Roadless Rule) for the roadless portions of those LUD II areas makes 

it more difficult to determine which direction has primacy over the other for policy makers, land 

managers, and the public. While the statutory direction is similar to roadless area direction, there 

are some differences and this has created confusion for land managers and the public. Under 

Alternatives 2, 4, and 5, LUD II areas would be designated as LUD II Priority ARAs, which would 

be managed in accordance with applicable statutory direction. Specifically, these lands will 

continue to be managed in a roadless state to retain their wildland character as defined in the 

Tongass Timber Reform Act (TTRA; Title II, Section 201) and the National Defense Authorization 

Act for Fiscal Year 2015 (Public Law 113-291, 128 Stat. 3729, Section 3720(f)). Under Alternative 

3, the roadless designation is removed from these LUD II areas, but the statutory direction would 

continue to apply to these areas.

Rationale

Comment 101: The rationale for Alternative 6 as the proposed rule is not supported by the facts. The 

DEIS projects minimal beneficial effect on the forest product industry and thus does not support the 

assertion that eliminating the Roadless Rule will support rural economic development. The assertion that 

the Tongass should be managed locally ignores the Forest Service's 2001 conclusion that national 

rulemaking was needed to protect roadless areas. The DEIS recognizes that logging is most likely to be 

economically efficient in areas where there are already roads which is contrary to the assertion that 

opening roadless areas will result in more economic timber sales.

Response 101: As stated in the Notice of Proposed Rulemaking, the Alaska Roadless Rule 

reflects a different policy perspective on the roadless management issue rather than a change in 

the underlying facts and circumstances. This administration believes the states have valuable 

insight in understanding the balance between rural economic development and environmental 

protection and that overall reduction in federal regulations is good for the American public due to 

reduced burden to the taxpayer and reduced burden to business. 

Comment 102: The NPRM provides no justification to support any additional exceptions. The 2001 

Roadless Rule already provides for access to hydroelectric projects, construction of communication 

infrastructure, construction of transmission lines, access for locatable minerals, development of energy 

projects, and regional transportation projects. Although the 2001 Roadless Rule prohibits building roads 

for leasable minerals, the DEIS states there is no current or anticipated demand for leasable minerals on 

the Tongass.

Response 102: The proposed rule to exempt the Tongass National Forest from the provisions of 

the 2001 Roadless Rule does not include exceptions. However, many of the exceptions proposed 

in Alternatives 2 through 5 were developed to respond to comments from the public, Alaska 

tribes, and cooperating agencies. 

Comment 103: Commenters perceived impropriety associated with how this proposed Alaska Roadless 

Rule came about between the Governor of the State of Alaska and the President. There was concern that 

the State’s petition to initiate this rulemaking process was filed under false pretenses and did not involve 

any public scoping. Further, they are concerned that this change is motivated by politics and outdated 

timber-specific economics rather than being informed by the best available science. 

Response 103: The APA and USDA’s implementing regulation (7 CFR 1.28) allows any 

interested person to petition the Secretary to change a regulation. There is no prescribed process 

for developing or responding to a petition other than that it must be given prompt consideration 

and the petitioner will be notified promptly of the disposition made of their petition. The Secretary 

has no control over the underlying motivations or data offered in support of a petition. However, 

once a petition is accepted, a rulemaking in response to a petition will be conducted in 

compliance with applicable law and regulations. The USDA has conducted this rulemaking in 

compliance with all applicable law and carefully considered the information provided by all those 

who participated in the various public meetings and comment periods. The Department has 

drawn its own conclusions based on the information provided by all parties and its own analysis.
Appendix H

Final EIS H-27 Response to Comments

Comment 104: Commenters were concerned that there was inadequate reasoning given for the selection 

of the preferred alternative in the DEIS, and that it was politically influenced, arbitrary and capricious. 

There was concern that selection of Alternative 6 as the preferred polarized the discussion, making 

nuanced conversation difficult.

Response 104: Development of federal policy is often inherently political. In this case, USDA 

gave substantial weight to the State’s policy preferences, which is within the discretion of the 

Secretary. The Secretary considered a multitude of factors when selecting the preferred 

alternative, including the effects disclosed in the DEIS; input from the public, tribes, and 

cooperating agencies; overall changes in policy preferences by this administration; divergent 

views on roadless policy; as well as political considerations. These are all factors that a 

responsible official can consider when making new policy. The Notice of Proposed Rulemaking 

outlined how the Secretary considered the various aspects related to management of roadless 

areas on the Tongass National Forest. The selection of the full exemption as the proposed rule 

considered the important aspects related to the roadless policy question and the impacts outlined 

in the EIS and was not arbitrary and capricious. 

Comment 105: The proposed rule is unlawful because it fails to provide a rational explanation for 

changing the Forest Service's roadless policy in the Tongass.

Response 105: The preferred alternative removes a discretionary federal regulation and returns 

the regulatory landscape back to what it was prior to promulgation of the 2001 Rule. Returning 

roadless management on the Tongass National Forest to USDA’s traditional, unit-based, land 

management regime is unquestionably permissible under the relevant statutes. The incoming 

State Petition and USDA’s consideration of present conditions and various alternative rulemaking 

approaches indicates that there are good reasons to consider adjusting the regulatory landscape. 

USDA’s final assessment and rationale concerning roadless management on the Tongass 

National Forest will be discussed in the record of decision.

Comment 106: The effects disclosed in the DEIS are based on the premise that the proposed rule will fail 

because the proposal will not increase mining, development of leasable mineral, energy projects, 

infrastructure, timber output, and jobs.

Response 106: The effects analyses are based on the baseline conditions presented in the EIS, 

application of current management practices under the Forest Plan, and the changes that may 

occur in response to the Alaska Roadless Rule alternatives, including exemption.

Comment 107: Commenters expressed that including the Timber Priority LUD within the ARA boundary 

is confusing and inappropriate. They felt that timber production is incompatible with protecting roadless 

area values. 

Response 107: The Timber Priority ARA allows timber harvest, road construction, and road 

reconstruction to facilitate timber management and provide economic opportunity. It is only 

included in Alternative 4 and would apply to approximately 757,000 acres. While management of 

lands in this ARA management designation would not be subject to any regulatory prohibitions on 

timber harvest or road construction, retaining them in roadless designation is one way to 

acknowledge the roadless values of these lands to ensure appropriate consideration in future, 

site-specific project planning and analysis.

Roadless Areas and Mapping

Comment 108: Commenters sought a baseline that includes an accurate accounting of roadless areas 

that still have roadless characteristics, rather than inventoried roadless areas.

Response 108: We are not exactly sure what is meant by the comment, but the 2003 

Supplemental EIS evaluating roadless areas for Wilderness recommendations included an 

extensive description and accounting of the current conditions including all roadless area 

characteristics of each Tongass roadless area (see Appendix C).
Appendix H

Response to Comments H-28 Final EIS

Comment 109: Commenters were concerned that prior to the October 2019 DEIS release, the Forest 

Service deleted all young growth age-class data from their public portal, making it impossible for the 

public to consider the high-production of young growth timber.

Response 109: It is difficult to know which young growth data and which portal the commenter 

was referring to. However, young growth age-class data are part of the Tongass Young Growth 

inventory, which is separate from the Alaska Roadless Rule project. All young growth data and 

information related to that inventory are available to the public now and were available during the 

comment period.

Comment 110: There was concern that the DEIS did not use the most current roadless inventory. This 

would include roadless areas in the Keex' Kwaan traditional area that were not included in the 1996 

inventory used as the basis for the 2001 Roadless Rule, specifically critical lands in Three-mile Arm, 

Seclusion Harbor, and No Name, Alvin, and Reid Bays. Commenters urged the Forest Service to update 

the 2001 Roadless Rule to apply it to all Tongass Inventoried Roadless Areas, particularly those 

important to Keex' Kwaan.

Response 110: The inventoried roadless areas subject to Alternatives 2 and 3 include Alaska 

Roadless Areas outside of the 2001 Roadless Rule’s inventoried roadless areas. Some of these 

were identified in the 2003 and 2008 roadless analyses for the Tongass forest planning efforts. 

Further, Alternatives 2 and 3 include small islands previously excluded from any roadless 

inventory or analysis.

Effects Analysis - Other

Comment 111: Commenters believed that the DEIS unlawfully postpones analysis of key impacts. 

Response 111: Timber harvests, road building, and other developments are expected to occur 

under all alternatives with little variation. The locations of these activities and associated roads 

may change under the various alternatives, but these locations are not known at this 

programmatic level of analysis and required pubic involvement. When specific timber harvest or 

other projects are proposed, site-specific NEPA analyses would be conducted at that time. No onthe-ground actions are authorized by the final rule.

Comment 112: There was concern that deferring analyses of localized effects (community scale 

analyses) to subsequent site-specific proposals would place undue burden on local communities, 

particularly low income and marginalized communities that may lack resources necessary to conduct 

these analyses.

Response 112: The Forest Service recognizes the challenge this presents; however, the 

locations of timber harvests and associated road building are not known at this time. While the 

locations of other developments like regional energy or transportation projects may be more 

predictable, based on published information, it is not known if or when they will occur. When 

specific timber harvest or other projects are proposed, site-specific NEPA analysis and required 

pubic involvement would be conducted at that time. No on-the-ground actions are authorized by 

the final rule.

Comment 113: The DEIS does not recognize the environmental effects of potential road construction and 

reconstruction in non-development LUDs that may occur to access the development LUDs within 

roadless.

Response 113: Road construction and reconstruction needs are estimated in the FEIS, 

independent of which LUD they occur in. In addition, there would be very few instances where 

roads would have to be developed through non-development LUDs to access a development 

LUD that was removed from roadless. Development LUDs were mapped with access to road 

systems or to potential marine terminals. Furthermore, the most isolated development LUDs on 

the Tongass continue to be off-limits to logging even though they may have their roadless 

designations removed, because they are in Phases 2 and 3 of the Tongass Timber Sale Program 

Adaptive Management Strategy, which will continue to be not suitable for timber production.
Appendix H

Final EIS H-29 Response to Comments

Comment 114: Commenters expressed concern at the perception of a conflict between the Forest 

Service position that the proposed rule will not lead to more logging and the State of Alaska’s petition, 

comments from Alaska’s elected officials, and industry proponents demonstrating that the purpose of the 

proposed rule is to revitalize and expand the failing old-growth logging industry.

Response 114: The proposed action does not adjust the Projected Timber Sale Quantity (PTSQ) 

identified in the Forest Plan. Current harvest levels are well below the PTSQ and, although it is 

possible that actual harvest levels will increase as a result of opening up roadless areas by 

increasing options for economic sales, it is not anticipated that harvest levels will reach or exceed 

the PTSQ on average. However, analyses in this EIS, as well as in the 2016 Forest Plan EIS, 

assume that harvest levels do reach the PTSQ and remain there over the planning horizon (100 

years). Tongass timber sale levels for the last 3 years have averaged 15 MMBF per year, or 

about 1/3 of the PTSQ.

Comment 115: Commenters sought analysis of direct and indirect effects to the qualities of the 

Biosphere Reserve, particularly Glacier Bay National Park and Preserve – Admiralty Island.

Response 115: Existing roadless areas within the Admiralty Island National Monument would 

retain their roadless designation under Alternatives 1 through 5. Under Alternative 6, roadless 

designation would be removed; however, the Monument would still be managed in compliance

with ANILCA and the Forest Plan. Figure 1-1 was added to the EIS, showing such areas within 

the Tongass. Based on recent trends, it is reasonable to assume that most harvests will occur in 

the southern ranger districts, further away from the Biosphere Reserve.

Comment 116: Commenters questioned the effects disclosed for inventoried roadless areas with 

Developmental Land Use Designations (Development LUDs), and sought clarification that the alternatives 

identify both prohibitions and permissions for land use such as timber production and road construction.

Response 116: Development LUDs within inventoried roadless areas are subject to the 

"prohibitions and permissions" identified for the development LUD in the Forest Plan, in addition 

to the restrictions provided by the roadless area designation under the 2001 Roadless Rule (for 

Alternative 1) or the new Alaska Roadless Area designation (for Alternatives 2-5). The former are 

found in the Forest Plan Management Prescriptions for each LUD, as well as the Forest-wide 

Standards and Guidelines, and the latter are shown in Appendix G and Tables 2-2 and 2-3 of this 

FEIS.

Comment 117: The impact analysis fails to accurately identify differences among the range of 

alternatives and minimizes the impact of even the most extractive alternative. Such an approach grossly 

misrepresents the impact of the preferred alternative and ignores a key requirement under the National 

Environmental Policy Act. The lack of impact analysis sets a dangerous precedent for future proposed 

rulemakings impacting our public lands, parks and forests.

Response 117: The effects of each alternative have been quantified extensively. Differences 

among the alternatives are limited due to the fact that no changes in the PTSQ are associated 

with the proposed action or any alternatives. For all alternatives, we assumed that the PTSQ was 

fully harvested over the 100-year planning horizon, just as was done for the 2016 Forest Plan 

Amendment EIS.

Comment 118: Commenters were concerned that the impacts analysis for alternatives was flawed 

because the basis for estimating volume of forest harvested and the assumed definition of “detrimental 

impacts” illustrated a misunderstanding of the local resources and ecosystems. For example, a 

geographic information system analysis conducted by a member of the Kake community found that over 6 

million acres of key ecologically important areas would be impacted from the proposed change, which is 

quite different from what the Forest Service produced in the DEIS.

Response 118: The impact analyses in the EIS assume that timber harvest levels would remain 

the same for all alternatives, with similar or only slightly different miles of road construction and 

reconstruction also anticipated. The Record of Decision for the 2016 Forest Plan estimated that a 

total of approximately 24,000 old-growth acres would be harvested Forest-wide after 25 years, 
Appendix H

Response to Comments H-30 Final EIS

with a total of 42,500 old-growth acres harvested after 100 years. These estimates represent an 

approximate upper ceiling of the number of roadless acres that could be potentially harvested 

under any of the alternatives. It is unclear why the commenter believes that this projected level of 

harvest would affect 6 million acres.

Comment 119: Comments sought additional discussion in the DEIS of logging industry impacts which 

can include poor culvert construction and maintenance, poor trash management, excess forest debris, 

and clear-cuts being left impassable for 30-50 years. 

Response 119: Specific issues related to best management practices are Forest Plan-related 

issues and are beyond the scope of this EIS. This EIS does not authorize logging or set annual 

limits on logging or establish specific silvicultural or logging practices or prescriptions.

Comment 120: The DEIS is insufficient and misleading because it underreports or fails to disclose the 

many, potentially significant, environmental impacts of removing the Roadless Rule protections from the 

Tongass. This misrepresentation makes it impossible for the public and decision-makers to assess the 

exemption’s adverse effects on the economy and ecosystems.

Response 120: This action is programmatic and therefore, does not include specific locations of 

natural resource extraction. When projects are proposed, site-specific NEPA analysis will be 

conducted. Potential impacts are described throughout Chapter 3, including economic and 

ecosystem effects. Quantification of impacts is more extensive in the FEIS.

Comment 121: The Forest Service’s proposal for exemption and claim that it will not cause direct harm, 

without explanation, contradicts its own findings from 2001 that logging, development, and roads have 

direct correlations with harm to National Forests. The DEIS seems to disregard information in its impact 

analysis about impacts of clear-cutting old growth forests. This leads to DEIS conclusions that are in 

disagreement with the FEIS generated in 2000 when the Roadless Rule was created which clearly 

documented the negative cumulative impacts the Tongass would be subject to.

Response 121: The effects of timber harvest are not disregarded in the effects analysis of this 

EIS. However, the question of how much logging is to take place and what type of prescription 

should be used is a Forest Plan issue and was decided in 2016 with a major Forest Plan 

Amendment, which developed a young-growth transition strategy to move the industry away from 

old-growth clearcutting, and old-growth harvest in general. That strategy is currently being 

implemented. The average timber volume sold per year over the last 3 years has been 15 MMBF 

including only 4 MMBF of old growth. It should also be noted that in 2000, the allowable timber 

sale quantity (ASQ) and the level of old-growth clearcutting on the Tongass were substantially 

higher than the current level (by a factor of more than 10) and substantially higher than the PTSQ 

of the current Forest Plan.

Comment 122: The Roadless Rule has been in effect on the Tongass for 20 years and removing it would 

cause adverse and irreparable harm.

Response 122: The EIS addresses the effects of removing or modifying the Roadless Rule for 

the Tongass in detail. It should be noted that, although the rule was implemented beginning in 

2001, the Tongass was exempt from the Rule between 2003 and 2011, so the Rule has actually 

only been in effect on the Tongass for about 11 years. 

Comment 123: Commenters expressed concern with effects analysis, saying that the definition of “old 

growth” is oversimplified and that by discussing effects in terms of acres of old- or second growth lost 

does not account for total roadless acreage impacted.

Response 123: Impact evaluations in the EIS cover far more than acreage impacted. For 

example, habitat impacts evaluations that are associated with harvest and roads do not only 

address the footprint of the direct impacts, but also address the fragmentation of adjacent 

habitats and the associated landscape connectivity. Detailed analyses of fragmentation and 

connectivity, however, cannot be conducted until site-specific proposals are evaluated. As 

another example, the evaluation of impacts on outfitters and guides considers areas proximal to 
Appendix H

Final EIS H-31 Response to Comments

harvest and roads. Finally, the scenery analysis evaluates entire viewsheds, using the harvest 

acres as measures of the degree of disturbance.

Comment 124: Commenters sought effects analysis, with more detail about the location and 

consideration of long-term secondary impacts, of natural resource extraction, including clear-cutting or 

development activities. Commenters further sought analysis showing the amount of forest fragmentation 

expected; documenting the amount of contiguous productive old-growth and contiguous large tree oldgrowth currently remaining; and disclosing effects on maintaining viable, well distributed populations of 

yellow cedar. Commenters sought studies to determine harvest data, especially old-growth harvest data, 

for yellow cedar, detailed mapping of climate envelope maps for yellow cedar for the next 400 years, and 

analysis of range shifts.

Response 124: This action is programmatic and therefore does not include specific locations of 

natural resource extraction. When projects are proposed, site-specific NEPA analysis will be 

conducted. Forest fragmentation is analyzed in a general way through evaluating the number of 

intact watersheds, but detailed analysis is not possible without site-specific project information. 

The amounts of POG, high-volume POG, and large-tree POG remaining now and after 100 years 

are presented for each alternative in Tables 3.3-7, 3.3-8, and 3.3-9 for NFS lands and in Tables 

3.3-10, 3.3-11, and 3.3-12 for all lands including non-NFS lands. Evaluating effects on yellow 

cedar is done on a site-specific and at the Forest Plan level and is beyond the scope of this EIS, 

which does not change the PTSQ.

Comment 125: Commenters sought information about adaptive risk management, including monitoring 

and mitigation, for all action alternatives. 

Response 125: Monitoring occurs at the Forest-level. The Tongass National Forest implements 

its plan monitoring program in accordance with 36 CFR 219.19. This process is a quality control 

tool for implementation of the Tongass Forest Plan, which will continue regardless of the Alaska 

Roadless Rule. It provides the public, the Forest Service, and other involved resource agencies 

with information on the progress and results of Forest Plan implementation. As such, monitoring, 

along with the evaluation of that monitoring, comprise an essential feedback mechanism within an 

adaptive management framework to keep the Forest Plan dynamic and responsive to changing 

conditions. 

Comment 126: Commenters said that using the same LUD categories for the action alternatives that are 

found in the Forest Plan would allow for better integration of the rule direction and plan components. 

Response 126: The analysis and data used in the EIS considered all underlying Forest Plan LUD 

designations, standards and guidelines and other Forest Plan Direction. Assigning different 

roadless categories based on underlying LUD would have unnecessarily complicated the 

analysis..

Comment 127: Commenters expressed concern that greater human access through additional road 

construction would lead to increased potential for invasion by pests such as hemlock woolly adelgid, 

emerald ash borer, and Douglas-fir beetle and other exotic invasive species and pathogens.

Response 127: We agree that more road construction in more isolated areas will create corridors 

for expansion of invasive species and other pests into more remote areas. This is disclosed in the 

FEIS (see Sensitive and Invasive Plants section).

Comment 128: The only portion of the DEIS that discloses impacts in development LUDs within roadless 

areas is the outfitter/guide uses section which demonstrates the Forest Service could have provided more 

detailed analysis for every other resource.

Response 128: For the most part, there is no reason to break down the impacts by development 

LUDs vs. non-development LUDs. The vast majority of the timber harvest and road construction 

will be conducted in development LUDs. Road development for state transportation corridors or 

energy projects may occur anywhere, but would be infrequent. Table 2-12 presents the acres of 

development LUDs protected by roadless areas for each alternative.
Appendix H

Response to Comments H-32 Final EIS

Economic and Social Environment

Comment 129: Commenters sought effects analysis disclosing how the proposed rule will directly and 

indirectly impact ecosystem services in the region including economic cost and benefits related to impacts 

on ecosystem services. There was concern that exemption from the rule could lead to removal of trees 

and damage to ecosystems which can negatively impact ecosystem services.

Response 129: Ecosystem services are discussed in the EIS in the Key Issue 1 section of 

Chapter 3. As discussed in this section, under the 2016 Forest Plan, timber management 

activities are governed by a number of laws, regulations and Forest Plan direction designed to 

protect or mitigate adverse impacts to natural resources that provide ecosystem services. The 

effects of the alternatives on these types of services are assessed in the sections of this FEIS 

that address fisheries, wildlife and subsistence use, and timber and vegetation, among others. 

Monetary values are not assigned to these services, but this does not lessen their importance in 

the decision-making process. Additional discussion related to ecosystem services has been 

added to the separate Regulatory Impact Assessment prepared in support of this Project. 

Comment 130: Commenters expressed concern that exempting the Tongass from the Roadless Rule 

could lead to disturbance, development, or logging resulting in the damage or loss of ecosystem services 

in sensitive or pristine ecosystems including oxygen production, filtration of air, water and soil, as well as 

loss of fisheries and game populations.

Response 130: See response to the comment above.

Comment 131: Commenters expressed concern about the cost-benefit analysis using changes in 

suitable old-growth and young-growth acres as an indicator for potential displacement of recreationists 

interested in primitive recreation experiences. There was concern about the methodology used to 

measure adverse visitor impacts. Commenters also sought consideration of scenic values in the costbenefit analysis.

Commenters sought a full cost-benefit economic analysis that uses best available science to assess 

socioeconomic impacts of each alternative as well as analysis of the socioeconomic value and impact on 

fisheries, ecotourism, special use permits, recreation, game populations, and subsistence resources.

Response 131: The EIS does not include a cost-benefit analysis. The cost-benefit analysis 

referred to in the comment is part of the separate Regulatory Impact Assessment and CostBenefit Assessment (Regulatory Impact Assessment) prepared for the Project (USDA Forest 

Service 2020). This comment and other concerns about that analysis are discussed in the 

preamble to the final rule and many comments are addressed in the final version of the 

Regulatory Impact Assessment.

Comment 132: The recreation-related assessment provided in the separate Regulatory Impact 

Assessment and Cost-Benefit Assessment prepared for the Project (USDA Forest Service 2020) 

understates potential impacts to the visitor industry because it considers only changes in suitable timber 

acres and does not address indirect effects to adjacent areas. Timber harvest and road building activities 

have the potential to affect much larger areas than the area that is logged.

Concern was expressed that the Forest Service did not analyze the corresponding effects on rural 

communities from the displacement of outfitters, guides, and tour operators. 

Response 132: These comments pertain to the analysis in the separate Regulatory Impact 

Assessment prepared for the project, not the DEIS. These comments and related concerns are 

discussed in the preamble to the final rule and many comments are addressed in the final version 

of the Regulatory Impact Assessment.

Comment 133: Commenters seek to keep any profits from timber harvesting in the local economy. 

Response 133: The sawmills currently operating in Southeast Alaska are all locally owned, as 

are the logging firms that operate in the region. Timber harvested and processed locally supports 

local jobs in logging and sawmills, as well as local employment in transportation and other 
Appendix H

Final EIS H-33 Response to Comments

services, which include: water transportation, independent trucking, stevedoring, scaling, and 

export marking and sort yard employment for export volume; and water transportation, scaling, 

and independent trucking for locally sawn volume.

Comment 134: There was concern that any economic benefit from exempting the Tongass National 

Forest from the Roadless Rule would not last long and would benefit only a small group of individuals and 

minority of industries while the long-term impacts would be substantial and negatively impact a larger 

group of individuals and a majority of industries.

Response 134: Potential impacts to natural resource-based industries, including forest products, 

recreation and tourism, salmon harvesting and processing, and mining and mineral development, 

are assessed in the EIS. None of the alternatives are expected to result in substantial, negative 

impacts to natural resource-based industries in the short or long term based on the existing 

Forest Plan. Similarly, no substantial, long-term, negative impacts have been identified to groups 

of individuals. 

Comment 135: Commenters requested that any profits made from logging should be paid back to 

taxpayers to relieve the federal deficit.

Response 135: The distribution of revenues received from timber sales on the NFS lands is 

outside the scope of this analysis. However, the analysis in support of the final rule included the 

Regulatory Flexibility Analysis which includes discussion of returns to the U.S. Treasury from 

revenue producing Forest Service activities such as timber sales in the section Information 

Relevant to Small Governments.

Comment 136: Commenters were concerned with the adequacy of economic analysis and whether the 

analysis incorporated the best available science. Further, there was concern that issues about economic 

analysis were brought forward during scoping but not adequately addressed in the DEIS. 

Response 136: As noted in above responses, potential impacts to natural resource-based 

industries, including forest products, recreation and tourism, salmon harvesting and processing, 

and mining and mineral development, are assessed in the EIS. 

With respect to comments provided during scoping, the Forest Service values the comments that 

have been received, and the concerns expressed, during the rulemaking process to date. They 

have highlighted the issues important to both the communities in Southeast Alaska and to the 

national public, which were used to develop alternatives that provided a range of management 

options as displayed in the FEIS. The information the Forest Service received was also used to 

inform the Responsible Official for the Alaska Roadless Rulemaking effort, the Secretary of 

Agriculture.

Many of the specific concerns identified by this commenter related to the economic analysis 

presented in the separate Regulatory Impact Assessment prepared in support of this Project. 

These concerns are addressed in the preamble to the final rule and many comments are 

addressed in the final version of that document. Other specific comments raised by the 

commenter that also relate to the analysis in the DEIS are addressed in this comment response 

appendix.

Comment 137: Commenters asked that the EIS affected environment section include historical numbers 

(used in the Regulatory Impact Assessment) of timber harvest and road density during/through/after the 

temporary exemption period.

Response 137: The EIS includes detailed information on the Forest Products sector in the Key 

Issue 2 section of Chapter 3. This includes information on past harvest and timber production. 

The cost-benefit analysis provided in the separate Regulatory Impact Assessment prepared for 

the Project (USDA Forest Service 2020) has been updated. Information related to that analysis 

and supporting materials are included in the updated Regulatory Impact Assessment document 

and/or planning record for the Alaska Roadless Rulemaking project. 
Appendix H

Response to Comments H-34 Final EIS

Comment 138: Commenters sought cost data for road building and maintenance (per mile) in the areas 

considered for exemption from the rule. 

Response 138: Estimated cost data per mile for road maintenance is incorporated into the 

updated Regulatory Impact Assessment prepared for the project. Potential effects to NFS and 

non-system roads on the Tongass are discussed in the Transportation, Energy, Communications, 

and Infrastructure section of the EIS. This discussion has been updated for the FEIS and includes 

projections of road miles by alternative.

Comment 139: Commenters sought comparison of respective socioeconomic contributions of timber sale 

purchasers and the visitor industry. They requested that analysis of effect include more current 

information and changes in assumptions to better consider the regional scale of the visitor industry. 

Response 139: The DEIS summarized employment and income by industry using data from 

2017, the most current available at the time of preparation. This discussion has been updated in 

the FEIS to incorporate information from 2018, which has become available since the DEIS was 

prepared. Both the wood products and recreation and tourism industries are discussed in detail in 

the DEIS and FEIS documents. 

Comment 140: Commenters expressed concern that exempting the Tongass from the Roadless Rule 

would cause economic harm to Southeast Alaska residents by threatening tourism, commercial fishing, 

sport fishing, and subsistence economies. They requested that these impacts be accounted for in the 

rulemaking process and countered with mitigation efforts. Commenters also noted that economic 

concerns extend to Washington State where the commercial fishing and cruise industries are directly 

affected by what occurs in Alaska.

Response 140: Impacts to the recreation and tourism and commercial fishing sectors are 

discussed under Key Issue 2 in the EIS. Impacts to subsistence are assessed in the Subsistence

section. The analysis presented in the EIS focuses on the regional economy, but the Forest 

Service recognizes that impacts to resource-based industries in Southeast Alaska have potential 

economic implications for other regions, including Washington State, as noted in the comment. 

This includes the forest products sector as well as the commercial fishing and visitor industries. 

Comment 141: Commenters were concerned that the action alternatives would not have an economic 

impact in terms of regional jobs/employment and would only benefit timber sale purchasers. 

Response 141: As discussed in the EIS, timber program output levels are expected to remain

constant and involve a similar number of acres under all alternatives, varying only by the location 

of timber harvest. The proportion of cutting activity occurring within versus outside of roadless 

areas would vary by alternative, but overall regional economic impacts (jobs and employment) 

are assumed to remain constant across all alternatives. The action alternatives would allow the 

Forest Service greater flexibility in the selection of future timber sale areas, as well as the 

potential for more flexibility in sale design, depending on the project areas selected. This 

improved flexibility could, in turn, potentially improve the Forest Service’s ability to offer economic 

sales that meet the needs of industry. In addition, the Forest Service believes that the action 

alternatives would provide for other types of development that would contribute to rural 

economies.

Comment 142: Commenters were concerned that opening more areas to logging would lead to an 

increase in timber sales that are not economically viable. 

Commenters questioned the need for changing the Roadless Rule considering examples of recent timber 

offerings that failed to sell and others that sold at a loss. 

Commenters expressed concern that changes to the Roadless Rule to allow logging access would not 

improve outcomes for a dying timber industry. Commenters indicated that any large-scale timber industry 

locally would be unsustainable, even if properly managed. There was concern about the industry’s failure 

to modernize and innovate and most areas in the Tongass not being profitable for logging.
Appendix H

Final EIS H-35 Response to Comments

Commenters said that small-scale logging practices would be more beneficial to local economies, that 

switching focus to special and value-added forest products would allow the forest to be more selfsustaining and would not require any new roads. Therefore, exempting the Tongass from the Roadless 

Rule is not necessary to revitalize a sustainable local timber-based economy.

Response 142: As discussed in the DEIS, the Record of Decision for the 2016 Forest Plan 

estimated that a total of approximately 24,000 old-growth acres would be harvested Forest-wide 

after 25 years, with a total of 42,500 old-growth acres harvested after 100 years. These estimates 

represent an approximate number of roadless acres that could be potentially harvested under any 

of the alternatives. The conversion of previously identified unsuitable lands to suitable old-growth 

lands that would be available for harvest is expected to improve the Forest Service’s ability to 

offer economic sales. None of the alternatives are expected to affect the total number of oldgrowth acres harvested. This is discussed further in Chapter 3 of the EIS in the section that 

addresses Key Issue 2. Under current legislation, all timber sales need to appraise positive. 

The transition to young growth guided by the 2016 Forest Plan would be unchanged by the 

Alaska Roadless Rule alternatives, with transition to a young growth-based timber program 

anticipated in 10 to 15 years. Old-growth volume offered is projected to decrease until it reaches 

5 MMBF per year (expected to occur about Year 16), at which point it is to be stabilized, with an 

average volume of 5 MMBF per year offered to support small operators and specialty products 

such as wood for musical instruments.

Comment 143: Commenters expressed that fishing and tourism industries should be supported over 

logging because those industries are sustainable and more important to the area economy. Commenters 

note that the existing Roadless Rule protects the environmental quality on which these industries rely.

Response 143: The DEIS provides an overview of the regional economy in the Key Issue 2 

section of Chapter 3. This information has been updated for the FEIS in cases where new annual 

data has become available since the DEIS was prepared. This discussion shows the relative 

importance of the various natural resource-based industries in southeast Alaska. In addition, the 

2016 Forest Plan supports and provides protections for the fishing and tourism industries. 

Potential impacts to the commercial fishing and recreation tourism industries are discussed in the 

Key Issue 2 section of Chapter 3.

Comment 144: Commenters said that tourism and outdoor recreation are major driving economic forces 

for the Alaskan economy and worth more than the timber industry (four times as many jobs in the state as 

oil & gas, mining & logging combined). Commenters are concerned that changes to the rule will impact 

recreation and tourism because currently, visitors travel to Alaska for pristine wilderness, clean air, water, 

wildlife habitat, scenic values and primitive and semi-primitive recreation opportunities. There is concern 

that these impacts will be experienced on 165,000 acres directly and thousands of acres indirectly plus 

more acres pending changes to the Forest Plan that would occur following a rule change.

Response 144: The DEIS provides an overview of the regional economy in the Key Issue 2 

section of Chapter 3. This information has been updated for the FEIS in cases where new annual 

data has become available since the DEIS was prepared. This discussion shows the relative 

importance of the various natural resource-based industries in Southeast Alaska. Potential 

impacts to natural resource-based industries, including recreation and tourism, are assessed in 

the EIS. 

As discussed in the DEIS, the Record of Decision for the 2016 Forest Plan estimated that a total 

of approximately 24,000 old-growth acres would be harvested Forest-wide after 25 years, with a 

total of 42,500 old-growth acres harvested after 100 years. These estimates represent an 

approximate upper ceiling of the number of roadless acres that could be potentially harvested 

under any of the alternatives. Removal of roadless protections under the action alternatives would 

revert areas of previously identified unsuitable lands to suitable old-growth lands that would be 

available for harvest. Increases in suitable old-growth acres would range from 20,000 acres 

(Alternative 2) to 168,000 acres (Alternatives 5 and 6). Projected increases in suitable old-growth 

acres could potentially improve the Forest Service’s ability to offer economic sales but are not 
Appendix H

Response to Comments H-36 Final EIS

expected to affect the total number of old-growth acres harvested, with a maximum of 42,500 

acres expected to be harvested over 100 years. This is discussed further in the EIS in the Key 

Issue 2 section of Chapter 3.

Comment 145: Commenters were concerned that jobs provided by the tourism industry are insufficient to 

support local communities and, therefore, not a reason to consider keeping the Roadless Rule in place. 

Response 145: None of the alternatives are expected to result in substantial impacts to the 

recreation and tourism industry. This is discussed further in the EIS in the Key Issue 2 section of 

Chapter 3.

Comment 146: Commenters said that the ecotourism industry is not carbon neutral and that should be 

considered when weighing it against activities that may occur following a change to the Roadless Rule. 

Response 146: This proposed action does not change the PTSQ for the Tongass. Therefore, no 

significant change in timber harvest is expected, although the distribution of harvest may be 

different under each alternative. There could be some additional mineral extraction and/or 

renewable energy projects under some alternatives, especially Alternatives 4, 5, and 6, but 

increases are expected to be minor. As noted above, none of the alternatives are expected to 

result in substantial impacts to the recreation and tourism industry. 

Comment 147: The tourism industry is projected to increase to over 2.4 million visitors to the area. The 

Forest Service is not ready for this increase, and no plan is in place to prepare for this increase. Large 

group sites and trails are underdeveloped, and the Forest Service must focus on preparing for an 

increase in tourism, rather than support logging.

Response 147: Management of the Tongass National Forest is, in part, dependent on 

investments and funding decisions made by Congress. The Forest Service remains committed to 

allocating staff and financial resources to planning and implementing projects that are important 

to the communities of Southeast Alaska, and to the American public. If needed, later proposals 

for changes in the recreation program would be addressed in appropriate analysis.

Comment 148: Commenters said that the local economy needs logging and fishing industries to grow 

and that a rule change would have a positive impact on growing those industries which would improve 

local economies. Even a small number of new jobs would have a large impact on these small, isolated 

communities. Similarly, taxes from the timber industry can help local schools improve, and local wood 

manufacturing jobs could be created for products potentially.

Response 148: As discussed in the EIS, timber program output levels are expected to remain 

constant and involve a similar number of acres under all alternatives, varying only by the location 

of timber harvest. The proportion of cutting activity occurring within versus outside of roadless 

areas would vary by alternative, but overall regional economic impacts are assumed to remain 

constant. As a result, all alternatives are assumed to support a similar level of timber-related 

economic activity and a similar range of direct jobs and income. None of the alternatives are 

expected to affect the commercial fishing industry.

Comment 149: Commenters sought agency support for rural economic development through supporting 

local fishing and tourism industries, investing in recreational infrastructure, and streamlining permitting 

processes for community projects.

Response 149: As noted above, management of the Tongass National Forest is, in part, 

dependent on investments and funding decisions made by Congress. The Forest Service remains 

committed to allocating staff and financial resources to planning and implementing projects that 

are important to the communities of Southeast Alaska, and to the American public. Streamlining 

or adjusting existing permitting processes is outside the scope of this rulemaking effort. However, 

the Forest Service believes that the action alternatives would provide for other types of 

development that would contribute to rural economies.
Appendix H

Final EIS H-37 Response to Comments

Comment 150: There was concern that timber in the Tongass is primarily exported overseas to European 

and Asian countries. This helps other countries’ economies while negatively impacting the Alaskan 

economy.

Response 150: Old-growth timber harvested on the Tongass is not primarily exported. The 

Region 10 Limited Export Shipment Policy is discussed in the EIS (see the R10 Limited Export 

Shipment Policy subsection included in Chapter 3 as part of the Key Issue 2 discussion). 

Reviewed on an annual basis, the Limited Export Policy is intended to boost appraised timber 

values and provide economic sale opportunities by providing additional processing options for 

purchasers. The share of harvest exported over time is shown in Figure 3.2-6 in the EIS. In 2018, 

46 percent (9.2 MMBF) of the total harvested (20.0 MMBF) was exported. As with local 

processing, timber harvested for export supports local jobs, including logging jobs and jobs in 

transportation and other services.

Comment 151: The NPRM states the proposed rule is a deregulatory action and would create an 

incremental reduction in the cost of conducting compliance reviews, thus reducing expenditure of 

taxpayer dollars. Neither the DEIS nor the NPRM attempt to quantify this potential reduction and reviews 

for projects in roadless areas do not impose a significant burden, as demonstrated by the 50 projects 

approved in roadless areas on the Tongass. In addition, the incremental saving for reviewing projects 

would be far outweighed by the additional expense taxpayers would incur from expanding the Tongass 

timber project into roadless areas.

Commenters expressed concern that the Forest Service had not adequately evaluated the costs of this 

proposed rule, stating that the proposed rule has a total cost greater than zero, making it a "new 

regulatory action," not a "deregulatory action" under Executive Order 13771.

Response 151: Agency costs under the rule and the requirements of Executive Order 13771 are 

considered and discussed in the separate Regulatory Impact Assessment prepared for the 

Project (see the Agency Costs including Control of Regulatory Costs subsection in that 

document). This subsection provides detail on costs to the agency of environmental analysis, sale 

preparation, sale administration, and engineering support of treatment projects and timber sales 

on the Tongass. In addition, language has been added to the Regulatory Impact Assessment 

qualitatively addressing the incremental reduction in cost associated with conducting compliance 

reviews, alongside other costs to the agency. An “EO 13771 deregulatory action” is an action that 

has been finalized and has total costs less than zero. As presented in the Regulatory Impact 

Assessment, the upper bound estimate of net benefits for the final rule are positive.

Comment 152: Commenters disagreed with the cumulative effects discussion about timber program 

decline over the past century, saying instead, that the timber industry has been sustainably operating and 

that the average market prices of Tongass timber have been rising.

Response 152: There is no question that the timber industry in Southeast Alaska has declined 

over the past 30 years and is continuing to decline, by almost any measure. Timber industry 

employment in Southeast Alaska peaked at the end of the 1980s, before decreasing sharply in 

the 1990s. Much of this job loss was associated with closure of the large pulp mills in Sitka (1993) 

and Ketchikan (1997). Timber employment has continued to decline since the 1990s, falling from

a high of 561 jobs in 2003 to 193 jobs in 2018 (Table 3.2-2; Figure 3.2-4). Similarly, timber 

harvest in Southeast Alaska has declined from 191 MMBF in 2002 to 96 MMBF in 2018 (Table 

3.2-3). Likewise, sawmill production for surveyed mills declined from 87 MMBF in 2000 to 15 

MMBF in 2018.

Comment 153: Commenters were concerned that the DEIS did not quantify the reduction in expenses 

from exempting the Tongass from the Roadless Rule.

Response 153: Agency costs under the rule are considered and discussed in the final version of 

the separate Regulatory Impact Assessment prepared for this project (see the Agency Costs 

including Control of Regulatory Costs subsection in that document). 
Appendix H

Response to Comments H-38 Final EIS

Comment 154: Commenters sought analysis showing potential financial returns from future projects 

involving opening roadless areas and actual return from timber including a full inventory of economically 

viable old growth timber.

Response 154: This DEIS provides a programmatic assessment of the potential impacts that 

may result from the alternatives considered for a proposed Alaska Roadless Rule. This 

assessment and the proposed alternatives are programmatic, meaning that they establish direction 

and allowable activities for broad land areas, rather than schedule specific activities in specific 

locations. None of the alternatives authorize any site-specific projects or other ground-disturbing 

activities and, therefore, it is not possible to estimate potential financial returns from future 

projects. The projected distributions of old-growth and young-growth harvest under the proposed 

alternatives have, however, been updated in the FEIS. These proposed distributions are 

projections based on the best available information at this time and provide a general indication of 

where future harvest could be expected to occur. Future timber sales will undergo site-specific 

environmental analysis when they are proposed to comply with NEPA, with economic and 

financial analyses conducted at that time, as appropriate.

Comment 155. Commenters disagreed with the assertion that the proposed rule would not increase 

agency costs because it would not increase timber harvest levels and sought a more comprehensive 

estimate of anticipated agency costs and losses from below-cost timber sales. The Regulatory Impact 

Assessment and DEIS violate NEPA by failing to account for significant costs to taxpayers as a result ofbelow cost Tongass timber sales.

Response 155: Below cost timber sales is an issue that was eliminated from detailed 

consideration in the DEIS. This is discussed further in Chapter 1 of the EIS. Agency costs under 

the rule are considered and discussed in the final version of the separate Regulatory Impact 

Assessment prepared for this project (see the Agency Costs including Control of Regulatory 

Costs subsection in that document). This section provides detail on costs to the agency of 

environmental analysis, sale preparation, sale administration, and engineering support of 

treatment projects and timber sales on the Tongass National Forest.

Comment 156: Commenters wrote that timber sale projections used in the 2016 Forest Plan exceed the 

industry needs and that timber available for harvest with the Roadless Rule in place satisfies the current 

market demand. Commenters referred to recent research showing that merchantable volumes for sites 

open to timber harvests surpass past and future old-growth sale volumes.

Response 156: As discussed in the EIS (see, for example, the Key Issue 2 section of Chapter 3), 

under the current Forest Plan, there are an estimated 227,000 acres of suitable old growth 

available for harvest, almost 10 times the area expected to be harvested over the next 25 years. 

None of the alternatives are expected to affect the total number of old-growth acres harvested, 

but the conversion of previously identified unsuitable lands to suitable old-growth lands that would 

be available for harvest may improve the Forest Service’s ability to offer economic sales. 

Comment 157: Commenters expressed a concern that exempting the Tongass from the Roadless Rule 

may lead to more federal funds spent on timber subsidies and that losses incurred for administration of 

the timber program illustrate making more lands available to the program would not be prudent. Further, 

that high production costs and distance to market would make this timber unprofitable. Commenters 

wrote that reforming timber sale administration on the Forest prior to development of a rule would better 

align the agency's management priorities and responsibilities with the needs of the local and indigenous 

communities.

Response 157: Below cost timber sales is an issue that was eliminated from detailed 

consideration in the DEIS. This is discussed further in Chapter 1 of the EIS. Under current 

legislation, all timber sales need to appraise positive and this would be the case under all the 

alternatives evaluated in the EIS. Reform of timber sale administration is outside the scope of this 

rulemaking effort.
Appendix H

Final EIS H-39 Response to Comments

Cultural Resources

Comment 158: Commenters expressed concern about the removal of trees and harm to the old-growth 

ecosystems that provide mental, spiritual, and physical well-being to people. Removal of old-growth trees 

and secondary development would result in degradation of the environment and loss of the wilderness 

that will not recover quickly, leading to spiritual and cultural loss for many generations. The negative 

mental, spiritual, and physical impacts resulting from loss of the old-growth forests would be magnified for 

those who witness it directly.

Response 158: This EIS does not establish the amount of old growth to be harvested. The PTSQ 

for the Tongass is established by the Forest Plan and this EIS does not change the PTSQ. 

Therefore, it is not expected to affect the amount of timber harvest, but it may affect where timber 

is harvested. In addition, this Roadless EIS is programmatic and individual timber sale projects 

are subject to their own NEPA evaluation and public involvement.

Comment 159: Commenters were concerned about negative impacts to the quality of the total 

environment and subsequent negative impacts to human health and well-being because the quality of the 

total environment (soil, air, water, and food) is intrinsically connected to human health and survival.

Response 159: Potential impacts to the physical and social and economic environment are 

assessed in the EIS. 

Comment 160: Because changes to Roadless Rule protections may lead to natural resource extraction 

and developmental activities, commenters expressed concern that cultural traditions would be affected, 

could stop and would not be taught to future generations.

Response 160: As discussed in the EIS, natural resource extraction and development activities 

are not expected to vary substantially among the action alternatives. Potential impacts to natural 

resources are evaluated in detail in the EIS, with limited differences identified by alternative. 

Therefore, potential effects to cultural traditions are also not expected to vary by alternative. In 

addition, this Roadless EIS is programmatic and individual development projects are subject to 

their own NEPA evaluation and public involvement. 

Comment 161: Commenters expressed concern that the historical and cultural context of local 

communities being tied to specific geographies is not appreciated or understood by outside parties like 

the Federal Government. Damage to communities as a result of exempting the Tongass from the 

Roadless Rule has not been adequately or critically explored in this context. There are key archeological 

and ancient tribal lands, unsettled traditional lands, sacred sites, and the cultural significance of specific 

practices such as being the caretakers of the land which cannot simply be relocated geographically.

Response 161: Issues related to local community concerns were extensively considered in the 

development of the alternatives for the Alaska Roadless Rule EIS and in the evaluation of effects, 

as shown by the following measures:

• Alternative 3 established Community Priority ARAs, based on community input, around 

seven Southeast Alaska communities. 

• Appendix E, Communities, provided individual community profiles and analyzed impacts

to communities, followed by the development of individual community assessments for all 

Southeast Alaska communities. Additional analyses were added to Appendix E.

• Appendix F provided the traditional territories map developed by Goldschmidt and Haas’ 

federal government landmark report titled Possessory Rights of the Natives of 

Southeastern Alaska (1946). Overall effects were summarized in the EIS. 

• The Forest Service conducted 17 public meetings to hear local concerns during the 

scoping period, including meetings in communities throughout Southeast Alaska –

Angoon, Craig, Gustavus, Hoonah, Kake, Ketchikan, Petersburg, Point Baker, Sitka, 

Tenakee Springs, Thorne Bay, Wrangell, Yakutat, and two meetings in Juneau. 
Appendix H

Response to Comments H-40 Final EIS

• During the 60-day comment period, the Forest Service conducted 21 public meetings 

including Southeast Alaska communities – Angoon, Craig, Gustavus, Haines, Hoonah, 

Hydaburg, Juneau, Kake, Kasaan, Ketchikan, Pelican, Petersburg, Point Baker, Sitka, 

Skagway, Tenakee Springs, Thorne Bay, Wrangell, and Yakutat.

Comment 162: Commenters expressed concerns that the EIS violates NHPA because cultural and 

historic resources exist within the project area and cultural surveys have not been conducted in 

coordination with Alaska Native Tribes.

Response 162: See Chapter 1, Issues Eliminated from Detailed Analysis. The Forest Service 

consulted with the State of Alaska Department of Natural Resources, Division of Parks and 

Outdoor Recreation, and the Office of History and Archaeology, resulting in a letter (10/08/2018) 

from the State Historic Preservation Officer concurring with the Forest Service’s determination 

that changes in management direction for designated roadless areas on the Tongass does not 

meet the definition of an undertaking, as defined in 36 CFR 800.16(y). Although road construction 

and/or timber harvest could potentially increase within some designated roadless areas, impacts 

under the NHPA would be based on site-specific proposals, which are currently unknown, and 

would be addressed in subsequent project environmental analyses. 

Environmental Justice

Comment 163: Commenters said that environmental justice concerns for the proposed rule should be 

considered as effects on culture, not solely based on race designations.

Response 163: The Environmental Justice assessment in the EIS was prepared in accordance 

with Executive Order 12898 and considers impacts to all populations.

Comment 164: There was concern that compliance with Executive Order 12898, Federal Actions to 

Address Environmental Justice in Minority Populations and Low-Income Populations, was insufficiently 

analyzed because Organized Village of Kake tribal citizens rely on the surrounding intact habitat provided 

by inventoried roadless areas for our food security, cultural practices and traditional way of life. Therefore, 

tribal communities would be disproportionately impacted by proposed regulatory changes which would be 

a potential violation of regulations concerning environmental justice.

Response 164: The Environmental Justice section in the DEIS notes that the potential effects of 

the alternatives on the economic and social environment of Southeast Alaska include those 

associated with changes in the timber industry and recreation and tourism. The section also notes 

that there could also be potential effects upon subsistence use and heritage resources that have 

particular significance for Alaska Native populations. The effects of the alternatives on 

communities are discussed by community in Appendix E, with changes in roadless management 

and acres estimated for each community use area. Impacts to subsistence are discussed in the 

Subsistence section of the EIS.

Comment 165: Commenters were concerned that the impacts of climate change that would result from 

increased development authorized by a full exemption from the 2001 Roadless Rule stand to 

disproportionately affect minority communities, especially rural Alaska Natives communities in Southeast 

Alaska.

Response 165: Potential impacts with respect to climate and carbon are discussed in the 

Climate and Carbon section of the EIS. As discussed in this section, there would be only 

negligible differences among the alternatives because timber program output levels are expected 

to remain constant and involve a similar number of acres under all alternatives, varying only by 

the location of timber harvest. As a result, the alternatives would not differ in regard to their 

contributions to GHG emissions, changes in forest carbon stocks, carbon sequestration, or global 

climate change. Therefore, none of the alternatives are expected to result in climate changerelated impacts that could disproportionately affect minority or low-income populations.

Comment 166: Commenters said that the Tongass National Forest is critical to Native Alaskans and the 

general southeastern Alaskan communities for various subsistence activities such fishing for salmon, 
Appendix H

Final EIS H-41 Response to Comments

hunting for moose, and foraging for wild foods. Low-income families require subsistence to keep a stable 

food supply.

Response 166: The effects of the alternatives on communities are discussed by community in 

Appendix E, with changes in roadless management and acres estimated for each community use 

area. Impacts to subsistence are discussed in the Subsistence section.

Recreation and Tourism

Comment 167: Commenters sought site-specific information showing whether guided visitors are now 

using areas classified as "Roaded Natural" or other more developed settings and further effects analysis 

to describe the impacts of displacement and congestion on outfitter/guides.

The outfitter/guide analysis is inadequate because it does not disclose the locations where future logging 

is likely to occur. Rather, the analysis simply shows the number of suitable acres added in large 

geographic areas.

Response 167: The outfitter/guide analysis provided in the Recreation and Tourism section of 

the DEIS provides a detailed look at the potential impacts of the alternatives on outfitter/guide use 

using data provided by outfitter/guides as part of their permit requirements. The analysis identifies 

areas where the potential for conflict exists based on existing patterns of use and changes in the 

suitable land base and provides a qualitative assessment of potential impacts by location and 

alternative. 

As explained in the DEIS and discussed elsewhere in this comment response document, this EIS 

provides a programmatic assessment of the potential impacts that may result from the 

alternatives considered for a proposed Alaska Roadless Rule. This assessment and the proposed 

alternatives are programmatic, meaning that they establish direction and allowable activities for 

broad land areas, rather than schedule specific activities in specific locations. When specific timber 

harvest or other projects are proposed, site-specific NEPA analysis and required pubic 

involvement would be conducted at that time. No on-the-ground actions are authorized by the 

final rule.

The potential spatial distribution of old-growth and young-growth harvest across the Tongass 

under the proposed alternatives has, however, been updated in the FEIS. These proposed 

distributions are projections based on the best available information at this time and provide a 

general indication of where future harvest could be expected to occur based on the relative 

distribution of suitable acres. Estimates were developed by outfitter/guide use area and the 

outfitter/guide impact analysis has been updated in the FEIS to include this information.

While the Forest Service cannot predict where future timber sales will occur, several map sets 

provided in the EIS show where timber exists that could be harvested (this is suitable timber). 

Forest-wide maps showing areas with suitable timber are in Maps 7-12 and suitable timber by 

alternative for each community are in Appendix D. In addition, areas in development LUDs 

without roadless designations are shown for the six alternatives in Figures 3.10-5 to 3.10-10, 

which also highlight the 15 outfitter/guide use areas that are assessed in detail in the EIS. More 

detailed maps showing suitable old-growth and young-growth acres available for harvest for each 

alternative and outfitter/guide use area are provided as Maps 13 to 18 (on thumb drive or 

website).

Comment 168: Commenters provided opposing views about the impacts of logging on the tourism 

industry, some saying it does impact the industry and others saying it does not. 

Response 168: The EIS evaluates the potential impacts of the alternatives on recreation and 

tourism in the Recreation and Tourism section. Impacts to the recreation and tourism industry are 

discussed under Issue 2.
Appendix H

Response to Comments H-42 Final EIS

Comment 169: The outfitter/guide analysis is inadequate because it only assesses the impacts of acres 

considered suitable under the current Forest Plan and not all IRA acres that are in development LUDs 

and could be designated suitable for timber under future Forest Plan amendments

Response 169: As discussed elsewhere in this comment response volume, with the exception of 

the administrative change to timber suitability discussed in the EIS, no other changes to the 

Tongass Forest Plan are included in the rule. This is reflected in the analyses presented 

throughout the document, including the outfitter/guide analysis. Any future forest plan 

amendments or revision would undergo forest planning in compliance with NFMA and the 2012 

Planning Rule and environmental analysis in compliance with NEPA, and the final rule does not 

waive any applicable requirements regarding environmental analysis, public involvement, 

consultation with Alaska tribes, Native Corporations, or other agencies, compliance with other 

laws, regulation, or policy.

Transportation and Roads

Comment 170: Commenters were concerned with road access. Some expressed concern about the 

unmet need for access under the current rule, as well as seeking to get and retain public access to newly 

constructed roads built for timber sales and other projects. Commenters said that removing Roadless 

Rule protections would allow more roads to be built which would decrease traffic congestion and allow 

locals better access to hunting grounds. Others expressed concern that increased access would lead to 

resource degradation. Commenters were concerned that increased development of roads would lead to 

increased commercialization in the area.

Response 170: Access Travel Management plans are completed at the island, district, or project 

levels to allow for more localized analysis of road densities in relation to resource concerns and 

which roads are needed to access areas for resource management (or those that are not needed 

which can be closed). In addition, road closures are prioritized based on financial constraints in 

addition to resource concerns. While there may be some new road access under all alternatives 

in the long run, nearly all new roads constructed under the alternatives would be closed following 

harvest, based on current practices

Comment 171: Commenters opposed language in the exceptions under Alternatives 2 through 5 that 

would require the Responsible Official to decide whether a road is needed. Commenters consider this an 

unnecessary requirement that impedes development because the decision is made without any criteria 

and development projects are sufficiently regulated by meeting requirements for complex federal, state 

and local permitting, and complying with the Forest Plan and other requirements. 

Response 171: The Forest Service retains the authority to review individual project needs for 

road(s). The language for the exceptions under each alternative were modified between draft and 

final in part due to the concerns expressed in this comment. 

Comment 172: Commenters expressed concern that the DEIS understates the impacts because it does 

not recognize that shifting timber production from roaded areas to roadless areas would result in more 

road building, causing greater environmental impact.

Response 172: The FEIS provides estimates of the mileage of new roads, roads over 

decommissioned road beds, and reconstructed roads that would be developed under each 

alternative. Estimates of the increase in new road building have been added to the EIS, showing 

an increase ranging up to about 50 miles over 100 years (Table 3.3-21) and estimated road 

densities were added (Table 3.3-15).

Comment 173: Road building is not cost-effective and is a waste of taxpayer money, while damaging the 

fragile and unique forest.

Response 173: Estimates of the increase in road building within roadless areas have been 

added to the EIS, showing a range of about 50 miles over 100 years (Table 3.3-21) between the 

alternatives. 
Appendix H

Final EIS H-43 Response to Comments

Comment 174: Commenters expressed support for building additional roads.

Response 174: Comment noted.

Comment 175: Commenters said that additional access roads are not needed for timber harvests 

because the existing roads are sufficient.

Response 175: Existing roads are often sufficient for harvest of young growth because of past 

road construction (although these roads often need to be reconstructed), and in some cases they 

may be sufficient for harvesting old-growth units along existing roads. But existing roads are not 

sufficient for harvesting old-growth units that are not adjacent to existing roads (unless close 

enough to an existing road to be economically yarded by helicopter).

Comment 176: Commenters expressed concern that the DEIS did not accurately describe the current 

limitations on the construction, operation, and maintenance of roads and utilities connecting the 

communities of Southeast Alaska.

Response 176: Limitations to regional transportation and energy system projects under the 2001 

Roadless Rule were added to the FEIS. 

General Analysis and Editorial

Comment 177: Commenters sought a comparative summary format in Chapter 1 for Water Quantity and 

Quality, Air Quality, General Vegetation, General Wildlife Species/Habitat, and General Aquatics. The 

general discussion for impacts to Wetlands in Chapter I, Purpose and Need for the Action (p. 1-9), was 

suggested as an example of a comparative summary among the alternatives.

Response 177: In response to this comment, the comparative summary in the Water Quantity 

and Quality, Air Quality, General Vegetation, General Wildlife Species/Habitat, and General 

Aquatics sections of Chapter 1 have been expanded.

Comment 178: Commenters were concerned that maps did not provide an accurate picture of existing 

protections that cover much of the Tongass. As an example, maps did not clearly identify the various 

protective land use designations for the Tongass, such as areas designated as Wilderness, LUD II, and 

National Monument lands.

Response 178: The requested map was added to Chapter 1.

Comment 179: Commenters sought clarification on the process for subsequent NEPA analyses for future 

ground-disturbing activities and how future site-specific NEPA analyses relate to this EIS as well as the 

2016 Forest Plan Final EIS. Commenters sought a graphic display, such as a flow chart, to better explain 

the process and the relationship to other NEPA documents.

Response 179: When a future project is proposed, either by Forest Service or another party, the 

Forest Service will evaluate the need for the project and determine its consistency with the Forest 

Plan and other laws and regulations. Based on the anticipated scale of effects, the Forest would 

conduct NEPA analysis, which is often an Environmental Assessment or Environmental Impact 

Statement. For each of these, the Forest Service is required to offer opportunities for public 

involvement. Future projects would have to be consistent with both the Forest Plan and the 

Alaska Roadless Rule. 

Comment 180: Commenters sought a summary of the effects for each of the various impacts from the 

2016 Forest Plan Amendment Final EIS to reduce the need for the reader to search for the summary 

findings in the 2016 Forest Plan Amendment Final EIS.

Response 180: In response to this comment and others, this EIS has been updated to better 

incorporate the analysis directly. 

Comment 181: The exemption does not set a maximum limit on logging, which increases risk of 

significant environmental damage. The Projected Timber Sale Quantity is insufficient to determine 
Appendix H

Response to Comments H-44 Final EIS

maximum limits to logging because it only determines maximum harvest by a suitable yield limit, which 

could increase with exemption by increasing the total amount of suitable forestland.

Response 181: The Tongass Forest Plan will continue to guide timber harvest, and the PTSQ 

and Forest Service market demand estimates will continue to inform the harvest levels under the 

Plan. The TTRA directs the Forest Service to seek to meet timber demand on both the longerterm planning cycle and an annual basis, subject to appropriations, other applicable law, and the 

requirements of the National Forest Management Act and consistent with providing for the 

multiple use and sustained yield of all renewable forest resources. Through peer-reviewed 

methods, best available information, and observed current industry conditions, estimates of 

timber harvest are developed on an annual basis. These projections guide timber harvest and do 

not provide an upper limit or a lower limit. The TTRA envisions not an inflexible harvest level, but 

a balancing of the market, the law, and other uses, including preservation. TTRA’s demand 

projection requirements operate not as a mandate, but rather as an instruction to assure 

consideration of timber demand together with other goals in managing the Forest. 

Comment 182: Commenters were concerned that the DEIS improperly relied on the 2016 Tongass

Forest Plan Amendment EIS as an excuse for not disclosing environmental effects. For example, in the 

issues dismissed section the Forest Service dismisses soils, yet Alternative 6 opens the amount of land in

"high hazard" soils to commercial logging by 38 percent but the DEIS denies that further analysis is 

needed.

Response 182: As stated in the EIS, issues that are not significant or that have been covered by 

prior environmental review were eliminated from detailed analysis. Many of the issues dismissed 

are anticipated to have similar resource effects for each of the various alternatives as those 

effects disclosed in the 2016 Forest Plan Amendment EIS. This is because implementation of 

Forest Plan standards and guidelines would be the same for all alternatives and none of the 

alternatives predict a PTSQ greater than the amount disclosed in the 2016 Forest Plan 

Amendment EIS. 

Comment 183: Comments suggested "remoteness” as defined in the EIS should be replaced with 

desired Recreation Opportunity Spectrum (ROS) descriptions and that the EIS should describe that, 

"Primitive, semi-primitive non-motorized, and semi-primitive motorized Recreation Opportunity Spectrum 

class settings have a natural or natural-appearing environment. These ROS settings are not suitable for 

timber production."

Response 183: Remoteness was retained as an Alaska Roadless area characteristic. Total 

suitable acres are presented in the EIS as a relative measure of timber opportunity by ROS 

setting to differentiate between alternatives.

Energy and Utilities

Comment 184: Commenters sought inclusion of effects analysis for the renewable energy sector; how 

would the proposed rule change the facilitation of renewable energy development including hydropower, 

geothermal, and wind.

Response 184: Renewable Energy projects are addressed in Chapter 3, Transportation, Energy, 

Communications, and Infrastructure. Roadless Priority, Community Use Priority, and Timber 

Priority land management designations provide exceptions or otherwise allow community utility 

systems. 

Comment 185: Commenters were concerned with the lack of mention of the federal power site 

classification and Southeast Intertie, its authorization in the Public Law, and its support from the 

Southeastern Alaskan communities. Only Alternative 6 permits or recognizes the legal standing of the US 

federal power site classification on select hydropower resources. Commenters asked that the 

contradiction between Public Law 106-511, Title VI, and the Roadless Rule be addressed.
Appendix H

Final EIS H-45 Response to Comments

Response 185: The FEIS, Appendix G, provides revised proposed rule language for each 

alternative, which includes exemptions to the prohibition of timber harvest and road construction 

when conducted pursuant to reserved or outstanding rights or as provided for by statute or treaty. 

Comment 186: Commenters were concerned about long-term financial impacts from lack of access for 

maintaining transmission lines. Rights of way must be maintained and continually brushed and structures 

must be inspected on an annual basis.

Response 186: In the final proposed rule language, exceptions to the prohibition of road building 

have been added to Roadless Priority and Community Priority ARA designations for community 

utility systems. The positive effects of maintenance access have been added to the FEIS.

Minerals

Comment 187: Commenters sought effects analysis for mining projects that may occur following a rule 

change. 

Response 187: See Chapter 3, Minerals. There would be minimal effects on locatable mining 

projects, as those are allowable under the 1872 Mining Law and the 2001 Roadless Rule 

recognizes that statutory right. While roads for access to valid mining claims are not currently 

prohibited in roadless areas, each of the ARA action alternatives would add reference to this law 

as an example of a road authorization pursuant to reserved or outstanding rights, or as provided 

for by statute or treaty (see Table 2-2 and Appendix G). This may be a benefit by reducing 

regulatory uncertainty in mining and other projects. Any future proposed mining projects would 

undergo appropriate site-specific analysis.

Comment 188: Commenters said that changing the Roadless Rule for mineral access is unnecessary as 

the Mining Act of 1872 ensures access to minerals, transportation, and energy development needs in the

Tongass National Forest.

Response 188: While roads are not currently prohibited in roadless areas, each of the ARA 

action alternatives would add reference to this law as an example of a road authorization 

pursuant to reserved or outstanding rights, or as provided for by statute or treaty (see Table 2-2 

and Appendix G). Other commenters have expressed that this would be a benefit by reducing 

regulatory uncertainty in mining and other projects.

Comment 189: Commenters said that the 2001 Roadless Rule inhibits access to new leases for 

minerals, including geothermal resources, and that it inhibits mining and other mining related activities 

that are protected by U.S. mining laws. Discovering economic mineralization requires exploration to 

determine size and grade, which is not feasible without roads. The Roadless Rule also inhibits mining 

because it does not allow cutting and removal of trees associated with mining exploration and 

development. Exploration requires an ever-increasing level of investigation to add certainty to 

resource/reserve information to support financing in public markets

Response 189: Leasable minerals are discussed under the Minerals section in Chapter 3 of the 

EIS. The commenter is correct that the Roadless Rule restricts roaded access to new 

authorizations for leasable minerals. Roads for geothermal projects providing community power 

could be constructed under exceptions provided for community utility systems in Alaska Roadless 

Rule Roadless Priority (Alternatives 2 through 5) and Community Priority (Alternative 3) 

designations. Roads could also be developed in Timber Priority (Alternative 4) areas. The 

Roadless Rule does not prohibit access to locatable minerals. See responses to other Minerals 

comments.

Comment 190: Natural resource extraction like mining is environmentally safe and has a small, 

temporary footprint. Regulations by permits require that mines including the roads, infrastructure and 

surface impacts are reclaimed upon the end of mine life.

Response 190: Comment noted.
Appendix H

Response to Comments H-46 Final EIS

Wildlife and Biological Diversity

Comment 191: Commenters sought keeping the Roadless Rule in place because exemption could lead 

to disturbances in sensitive habitat that would negatively impact both plant and animal communities and 

cause decreased biodiversity in the Tongass.

Response 191: As noted previously, fragmentation can be caused by timber harvest, road 

building, and powerline and facility development. Under any of the action alternatives, there could 

be some change in the distribution of timber harvest, roads, and other facilities relative to 

Alternative 1. Alternatives 4, 5, and 6 would increase roads and timber harvest farther into 

currently roadless areas than under Alternatives 1, 2, or 3, resulting in a greater degree of 

fragmentation. However, regardless of the selected alternative, the overall protection due to the 

degree of protections provided by the underlying Forest Plan LUDs and Forest Plan standards 

and guidelines would not change.

Comment 192: Commenters sought keeping the Roadless Rule intact to protect the old-growth habitats 

which provides sensitive habitat for over 30 endemic species.

Response 192: The Forest Plan included a review of the most recent information available during 

the current Forest Plan process due to the fact that endemic species tied to island archipelagos 

are more sensitive to human activities. The Forest Plan standards and guidelines for endemic 

mammals direct the Forest to “maintain habitat to support viable populations and improve 

knowledge of habitat relationships of rare or endemic terrestrial mammals that may represent 

unique populations with restricted ranges. Because this decision does not authorize site-specific 

harvest, additional endemic species could be addressed in detail considering site-specific

landscape characteristics and species of greatest conservation need at the project level. 

However, it is agreed that Alternative 1 would provide the highest degree of protection for 

endemic species, although differences among the alternatives are slight because the PTSQ 

remains the same.

Comment 193: Commenters were concerned that activities would accelerate mass extinction. Changes 

to Roadless Rule protections could lead to natural resource extraction and developmental activities, 

reducing the acreage of suitable undisturbed habitat for sensitive species. This loss of habitat would 

reduce population sizes of sensitive species and increase their risk of extinction.

Response 193: Energy, transportation, or other projects that may become permissible in new 

areas could affect various wildlife species and their habitat through direct disturbance or through 

removal or modification of habitats. These effects would be evaluated at the project level. The 

Forest-wide standards and guidelines would minimize overall impacts to wildlife and their habitats 

during project construction and operation.

Comment 194: Commenters were concerned that exempting the Tongass National Forest will lead to 

activities that would harm the survival of the Prince of Wales flying squirrel, both a keystone and indicator 

species that is endemic to the area. 

Response 194: Potential impacts to the Prince of Wales (POW) flying squirrel is addressed in the 

Wildlife section. Under all alternatives, old-growth timber harvest implemented under the Forest 

Plan could reduce the quality and quantity of flying squirrel nesting, foraging, and denning habitat.

However, the Old-growth Habitat Conservation Strategy would continue to maintain suitable oldgrowth habitat and provide landscape connectivity for flying squirrels. In addition, the Legacy 

Forest Structure and other standards and guidelines that retain POG forest in harvested areas 

(e.g., beach and estuary fringe, RMAs, and Scenic Integrity Objectives) would also ensure the 

maintenance of a functional and interconnected old-growth ecosystem on the Tongass. 

Comment 195: Commenters were concerned that the proposed rule would violate the Endangered 

Species Act (ESA) for various ESA listed species such as the marbled murrelet, short tailed albatross, 

humpback whale, and Eskimo curlew. Commenters asked that the EIS identify all the listed species that 
Appendix H

Final EIS H-47 Response to Comments

may be present and affected in the action areas and questioned findings showing minimal consequences 

on the survival of the species as well as the lack of a biological assessment.

Response 195: The Forest Service requested lists of threatened and endangered species from 

both NOAA and FWS and considered these species in the analysis. These T&E species are 

identified in the wildlife and fish sections of the EIS and included in the project record (FEIS 3-91 

to 92 and 3-133 to 134). The analysis presented in the FEIS and project record clarifies the 

findings related to anticipated effects to threatened or endangered species and clarifies that due 

to the determination of ‘no effect’ for threatened and endangered species that consultation is not 

necessary. 

Comment 196: The DEIS does not discuss the impact of environmental issues that it claims to address 

and instead references the 2016 Tongass Forest Plan Amendment EIS. The DEIS must be changed to 

discuss significant environmental impacts rather than simply incorporating them by reference. The 

majority of this DEIS relies on the biological assessments (BA) conducted by the National Marine 

Fisheries Service (NOAA) for the 2016 Forest Plan. However, the new Forest Service plan is 

fundamentally different to that introduced in 2016. The new plan aims to open areas for logging that will 

no longer be protected by the Roadless rule.

Response 196: The Alaska Roadless Rule EIS extensively addresses the effects of the 

proposed action and the alternatives on the environmental issues. It does reference the 2016 

Forest Plan Amendment EIS, where appropriate. However, the FEIS for the Alaska Roadless 

Rule, more extensively quantifies the effects of the alternatives by conducting new analyses of 

effects and presenting many new tables documenting baseline conditions and effects.

Effects to listed wildlife and fish were considered in the 2016 Forest Plan Amendment FEIS, 

which included preparing a biological assessment and informal consultation and NMFS 

concurrence with effects determination that the selected Forest Plan’s management regime would 

not adversely affect listed species or critical habitat. That consultation established the baseline of 

effects to be considered in subsequent consultations. The biological analysis for the Alaska 

Roadless Rule Final EIS also includes a separate analysis for threatened and endangered 

species, however developing a biological assessment for NOAA-NMFS/FWS or engaging in 

informal consultation with NOAA-NMFS/FWS was not necessary since it was determined that a 

decision regarding an action alternative on the roadless rule would have no effect to listed 

species or designated critical habitat and the FEIS itself is the functional equivalent of a biological 

assessment. In addition, when future projects that could be implemented are defined, they would 

still be required to adhere to Forest Plan requirements and would be subject to ESA consultation, 

as well as NEPA review, when site-specific information is available.

See the response to Comment 274 concerning changes to suitable acreage.

Comment 197: Commenters sought consideration of the science of the impacts of island ecology as key 

regions for sustaining the evolutionary processes related to diversification.

Response 197: The Old-Growth Conservation Strategy addressed the importance of the islands 

that make up the Archipelago and further broke out the Tongass into biogeographic providences 

(see Biodiversity Section. Further the Forest Plan protects all small islands of 1,000 acres or less. 

The percentages of original POG, high-volume POG, and large-tree POG would result under all 

of the other actions alternatives as well (Tables 3.3-10, 3.3-11, and 3.3-12); however, harvest 

associated with all action alternatives would contribute slightly to the cumulative reduction in POG 

and associated increase in fragmentation and loss of connectivity, which has the potential to 

reduce biological diversity. 

Comment 198: Commenters sought information on plans to restore or maintain the diversity of 

ecosystems and habitat types within the planning area including large-tree old growth and old-growth 

cedar stands. 

Response 198: From a biological diversity standpoint, high-volume POG and large tree POG are 

thought to have the highest importance for diversity. High-volume POG is defined as the grouping 
Appendix H

Response to Comments H-48 Final EIS

of the three tree size and density classes that represent the highest volume strata—SD5S, SD5N, 

and SD67 types. Large-tree POG is defined as the SD67 class, representing the most productive 

of the POG types, and typically containing the highest density of large trees.

There are approximately 5 million acres of POG forest on the Tongass. Of this, approximately 42 

percent is high-volume POG (SD5S, 5N, and 67 types) with approximately 11 percent classified 

as Large-tree POG (SD67 type). See Tables 3.3-3 and 3.4-4, 3.4-8 and 3.4-9 which shows the 

distribution of existing POG forest by biogeographic province and POG type and amount 

remaining. Transition to predominantly young-growth harvest over time would enhance biological 

diversity and the functioning of the Old-growth Habitat Conservation Strategy over the long-term.

Comment 199: There was concern about the adequacy of effects analysis for Old-growth Habitat. 

Commenters referred to the ‘Old-growth Habitat Conservation Strategy’ as outdated and were concerned 

that the DEIS does not consider the impact of high grading, habitat connectivity, climate change, and road 

effects. Determining the impact of exemption on old-growth trees requires mapping the quantity, age, and 

species of old-growth trees in the Tongass, taking inventory of champion trees, and preserving the 

genetics of old-growth trees. The DEIS also needs to consider and document the aerosols, pheromones, 

and chemicals that the oldest and largest trees of each species and subspecies of tree in the Tongass 

produce.

Response 199: The Conservation Strategy was implemented in 1997 as an overall conservation 

framework for wildlife. It provides for the diversity of plant and animal communities as required by 

NFMA. Redesigning the very large Old-Growth Habitat reserves, one component of the 

Conservation Strategy, is outside the scope of this EIS. Under all of the alternatives, long-term 

protection of POG would continue to occur under the Old-growth Habitat Conservation Strategy. 

In addition, the substantially less old-growth harvest relative to the analysis for the 1997 Forest 

Plan (under which the Old-growth Habitat Conservation Strategy was developed) would enhance 

biological diversity and the functioning of the Old-growth Habitat Conservation Strategy over the 

long-term. No changes to these Forest Plan features are proposed under any of the alternatives.

Comment 200: Commenters sought disclosure of deficiencies of the Old-growth Habitat Conservation 

Strategy for conserving goshawks.

Response 200: The history of the development of the Old-growth Habitat Conservation Plan is 

discussed in the EIS along with the viability assessments that were conducted prior to 

implementation. All action alternatives retain a very high rating in terms of the likelihood of 

maintaining viable, well-distributed populations after 100 years. The Queen Charlotte goshawk is 

a wide-ranging species that seems to prefer mature and old-growth forest habitats for nesting and 

foraging. Impacts to goshawks are assessed in terms of the reduction in total and high-volume 

POG, which provides potential high-quality nesting and foraging habitat. This species would be 

affected under all alternatives; effects would generally be similar among the alternatives but 

slightly higher for Alternatives 4, 5, and 6 because of longer and more road developments and 

associated fragmentation expected under these alternatives relative to Alternatives 1, 2, and 3. 

The transition to young growth guided by the 2016 Forest Plan, unchanged by the Alaska 

Roadless Rule alternatives, is likely to benefit goshawks by reducing the amount of POG harvest 

that would occur over the planning horizon, thereby maintaining more old-growth forest that 

provides potential foraging, nesting, and post-fledging habitat. Individual projects would be 

required to conduct goshawk surveys and implement the goshawk standards and guidelines 

which would minimize impacts to this species at the project level. The Old-growth Habitat 

Conservation Strategy predicted highly likely viability for the goshawk under a much more 

intensive harvest regime than has been conducted over the past two decades and that will be 

conducted over the long-term future. Thus, the Old-growth Habitat Conservation Strategy was 

developed to maintain viable populations for a worst-case scenario that will never occur.

Comment 201: There was concern that the temporal scales used in the DEIS rationale for maintaining 

viable, well-distributed wildlife populations are not correct for projecting the loss of old-growth habitat and 
Appendix H

Final EIS H-49 Response to Comments

its impact on species. The analyses refer to 100-year projections, yet it takes at least 250 years for 

Tongass forest lands to reflect characteristics of old-growth forest structure. The population viability 

analyses should include a time horizon of at least 250 years.

Response 201: The history of the development of the Old-growth Habitat Conservation Plan is 

discussed in the EIS along with the viability assessments that were conducted prior to the 1997, 

2008, and 2016 Forest Plan revisions and amendments. All action alternatives in this EIS retain a 

very high rating in terms of the likelihood of maintaining viable, well-distributed populations after 

100 years. The vast majority of productive old growth stands on the Tongass are older than 250 

years and, with the transition to young growth, harvest of these old-growth stands in the distant 

future is expected to be very minimal (i.e., 5 MMBF or less per year). The Old-growth Habitat 

Conservation Strategy was developed under the assumption that logging of old growth would be 

conducted at a much more intensive pace and that a much higher proportion of the Tongass 

would be under intensive management after 100 years than is currently planned (including the 

inventoried roadless areas). In other words, the future footprint representing managed stands will 

be much smaller after 100 years than was anticipated, so viability concerns are reduced 

compared to what was expected in 1997 and 2008, and comparable to what was expected in 

2016. 

Comment 202: Commenters sought analysis of the effects of roads on air, light, sound, endangered 

species, wildlife, wildlife habitat, wildlife habitat connectivity and movement corridors within the project 

area as well as on and between nearby National Park Service (NPS)-managed lands. Commenters 

requested the analysis include impact to night skies, natural sounds, air quality, and landscape 

composition on NPS lands, as well as fish and the natural flow and character of waterways such as the 

Skagway River.

Response 202: New road construction and road density would be similar under all alternatives 

because roads on the Tongass are largely developed in support of timber harvesting, and the 

PTSQ under the 2016 Forest Plan does not vary among the alternatives. Estimates of existing 

road conditions in 2016 included about 5,000 miles of existing roads on NFS lands (from the 2016 

Forest Plan FEIS, see Table 3.3-21.4-6 of this EIS). The projection over the next hundred years 

was modeled to include an additional 1,000 miles of new roads of new roads after 100 years. This 

would be an increase of nearly about 20 percent over existing conditions in 2016. In addition to 

new roads, roads would be constructed over decommissioned roadbeds or reconstructed. The 

number of new road miles estimated beyond the current forest plan (Alternative 1) would range 

from 0 to 49 miles total for the action alternatives (see Transportation section). It is important to 

recognize that this is a programmatic action and that potential effects will be addressed under 

separate project-specific NEPA analyses. However, most timber harvest and associated road 

building are expected to occur on the southern ranger districts, furthest from NPS lands and the 

Skagway River.

Comment 203: Commenters sought effects analysis for Alexander Archipelago wolves, that provides 

site-specific baseline information on impacts to wolf populations, survival and viability. Commenters were 

concerned with the effects analysis for wolf due to reduced deer habitat capability, road density, 

development, habitat fragmentation, den disturbance, and impacts to reproductive success. Commenters 

sought analysis of effects associated with how opening previously inaccessible acres to roadbuilding 

would increase wolf harvest from legal and illegal hunting and trapping.

Response 203: Although this EIS does not analyze site specific areas, the alternatives would be 

similar in terms of overall harvest levels. However, Alternatives 4, 5, and 6 may result in the larger 

adverse effects on these species because of greater road lengths, penetration into remote 

roadless areas, and habitat fragmentation that they would produce relative to Alternatives 1, 2, 

and 3. Any Alaska Roadless Rule decision would not result in on-the-ground effects.

Comment 204: Commenters sought cumulative effects analysis for bears and bear habitat associated 

with future logging or roadbuilding that could occur if areas were exempted from the Roadless Rule. 
Appendix H

Response to Comments H-50 Final EIS

Response 204: The EIS discusses potential impacts to bears from timber harvest, roads and 

other human developments and that these activities increase the opportunity for human-induced 

mortality of bears through legal hunting, defense of life or property kills, and illegal killing. Roads 

can affect water quality and productivity of salmon streams. It should be noted that black bear 

harvest risk has not been linked to a particular road density level. Cumulative effects to wildlife, 

including bears, is provided in the Wildlife section of the EIS.

Comment 205: Commenters were concerned with analysis of the impacts on endemic terrestrial 

mammals (examples included ermine, flying squirrel, Pacific marten, and wolves) and the findings of a 

moderate to high probability of maintaining viable, well distributed wildlife populations for all species 

identified for the DEIS. Commenters questioned whether scientific rationale was used or scientific 

analyses beyond referral to the Habitat Conservation Strategy in the 2016 Tongass Plan. There was 

concern that many of the species, including endemic mammals and Management Indicator Species such 

as the American marten, illustrate declines on the Tongass since large-scale, industrial logging began in 

the 1950s. 

Response 205: The analysis in the EIS relied on existing information and the landscape 

protection efforts outlined in the Conservation Strategy. The Tongass Old-Growth Conservation 

Strategy was designed through a collaborative effort by a broad range of scientists, Alaska 

Department of Fish and Game, and U.S. Fish and Wildlife Service, and the strategy underwent 

intensive peer review prior to it being established as part of the 1997 plan revision process. The 

Tongass Conservation Strategy was developed to maintain a functional and interconnected oldgrowth forest ecosystem on the Tongass by retaining intact, largely undisturbed habitat. Outside 

of reserves, components of the old-growth ecosystem are maintained by standards and 

guidelines to protect important areas and provide old-growth forest habitat connectivity. A series 

of expert risk assessment panels prepared viability risk assessments based on this framework. 

Using the panels’ assessments, the Forest Service determined that there was a moderate to very 

high probability of maintaining sufficient habitat to maintain viable populations of wildlife species 

on the Tongass under the 1997 Plan. It is worth noting that the Conservation Strategy was 

developed prior to the Roadless Rule. In addition, the Forest Service believes those probability 

estimates are very conservative because the panels of experts assumed timber harvest at 267 

MMBF annually for 100 consecutive years, with no change in applicable Standards and 

Guidelines. 

Comment 206: Commenters sought effects analysis for marbled murrelet.

Response 206: Marbled murrelets are addressed in the EIS. Because they nest in structurally 

complex old-growth forest stands, timber harvesting and road construction within POG forest 

stands (especially high-volume POG) can remove nest trees or disturb nesting birds. Indirectly, 

timber harvest and road building increase fragmentation, reducing the effectiveness of interior 

forest habitat and creating habitat edges, which may result in increased rates of nest predation by 

avian predators. Under all alternatives, marbled murrelet nesting habitat would be protected by 

the Old-growth Conservation Strategy. Legacy Forest Structure standards and guidelines are 

intended to maintain old-growth structure in areas that are already highly fragmented, as well as 

areas that will experience increased harvest levels over the life of the Forest Plan. Large trees 

may provide nesting habitat for marbled murrelets. Differences in effects among the alternatives 

would be very slight because of the lack of differences in harvest volumes. Potential impacts to 

marbled murrelet will also be addressed at the project level.

Comment 207: Commenters sought effects analysis for road construction or other activities that would 

pose environmental risks to marine wildlife and marine habitat.

Response 207: Effects to marine wildlife and fish, including listed species, were considered in 

this EIS for the Alaska Roadless Rule alternatives. In addition, the 2016 Forest Plan Amendment 

FEIS addressed these species and it included informal consultation and NMFS concurrence with 

effects determinations on listed marine-associated species. Implementation of any projects under 

the Alaska Roadless Rule alternatives would follow the Forest Plan standards and guidelines and 

Biological Assessments prepared for the Forest Plan, and their determinations, represent the 
Appendix H

Final EIS H-51 Response to Comments

baseline condition (no action). While there would be more acres potentially available for harvest 

with each of the Alaska Roadless Rule action alternatives, there would be no change in the 

projected harvest amount, and these changes are not expected to affect the BAs conclusions for 

any of the listed species. Future projects that could be implemented would still be required to 

adhere to Forest Plan direction and would be subject to ESA consultation when site-specific 

information are available, as well as NEPA review.

Comment 208: Commenters requested that the best available information be used in analyzing effects 

for Prince of Wales ermine. 

Response 208: Endemic mammals in general were addressed in the EIS and are expected to 

maintain a moderate to high likelihood of maintaining viable, well distributed populations where 

present. New information on the POW ermine may be incorporated at the project-level; however, 

this decision would not authorize site-specific harvest, and additional endemic species could be 

addressed in detail considering site-specific landscape characteristics and species of greatest 

conservation need at the project level. The 2016 Forest Plan standards and guidelines for 

endemic mammals direct the Forest to “maintain habitat to support viable populations and 

improve knowledge of habitat relationships of rare or endemic terrestrial mammals that may 

represent unique populations with restricted ranges. 

Comment 209: Commenters sought cumulative effects analysis to determine if exemption threatens 

viability of the Queen Charlotte goshawk including location specific information showing where 

inventoried roadless areas provide habitat features for Queen Charlotte goshawk nest sites and foraging 

habitat, especially on Prince of Wales Island. 

Response 209: The locations of timber harvest and associated activities may change under the 

various alternatives, but these are not known at this programmatic level of evaluation. When 

specific timber harvest or other projects are proposed, site-specific NEPA analysis would be 

conducted at that time. For these reasons, the Roadless Rule (all alternatives considered) would 

not result in affects above what was analyzed for the 2016 Forest Plan Amendment FEIS. It 

should be recognized that under the current Forest Plan, far more goshawk habitat will be 

preserved than was anticipated by the Old-Growth Conservation Strategy, because of the 

substantially lower old-growth harvest rate and the full transition to young-growth management.

Comment 210: There was concern that the specific wooded areas which represent prime timberharvesting land are also the same areas which represent prime habitats for deer, bear, wolves, and 

salmon. This conflict means that changing the Roadless Rule will directly impact the most crucial habitats 

for many species and the cumulative effects will be dramatic on both ecosystems and communities which 

rely on those ecosystems and species.

Response 210: The 2016 Forest Plan Amendment specifically and extensively addressed this 

issue by adopting a strategy for transitioning away from a timber industry based primarily on oldgrowth harvesting to a young-growth based timber industry. That strategy is currently being 

implemented. The average timber volume sold per year over the last 3 years has been 15 MMBF 

including only 4 MMBF of old growth. This is a dramatic decrease from harvest levels of just 10 or 

20 years ago. As noted in Tables 3.3-7 and 3.3-8 of the EIS, after 100 years under any of the 

alternatives, assuming the current Forest Plan is still being implemented, 91 percent of the 

original old growth that was present in 1954 and 85 percent of the original high-volume old growth 

that was present in 1954 will remain. These percentages are within 1 percent of the current 

percentages (existing condition).

Comment 211: Commenters sought separate effects analysis for two species of marten present on the 

Tongass National Forest due to one having an extremely limited range. American marten and Pacific 

marten are both found on the Tongass National Forest.

Response 211: Pacific marten is addressed under endemics and although the Forest Service 

understands the limited range of Pacific marten, the overall affects analyzed in the EIS for 
Appendix H

Response to Comments H-52 Final EIS

American marten would apply, as well as the specific standards and guidelines since both 

species use the same habitat and prey base. Impacts would be analyzed at the project-level.

Comment 212: Commenters identified Sitka black-tailed deer as the most important land mammal 

species for traditional and customary use by indigenous peoples of Prince of Wales Island. Commenters 

were concerned that deer populations have already decreased due to environmental pressures such as 

timber harvest and development and because they expect changes to the Roadless Rule would lead to 

natural resource extraction and developmental activities, there was concern about adverse impacts and 

cumulative effects on deer habitat. Other respondents anticipated improved deer population numbers for

hunters as outlined in the Quality Deer Management Association methods.

Commenters sought effects and cumulative effects analysis for Sitka black-tailed deer and deer winter 

range including an evaluation of the size of deer populations in roadless areas, annual harvest of deer for 

subsistence, and the percent of deer using roadless areas versus those using previously harvested areas 

in the winter months. 

Commenters are concerned that removing roadless protections would negate the larger Tongass 

conservation strategy and that analysis is needed to either a) prove otherwise; b) conclude that the 

conservation strategy without roadless is adequate; or c) result in a change in program direction to fully 

ensure that there is a viable and robust population of Sitka black-tailed deer across the landscape that 

can survive winters with heavy snow. 

Area-specific requests were also made for inclusion within the analysis, which includes Duffield 

Peninsula. 

Concerns that old-growth timber harvest at higher elevations will create bottlenecks restricting movement 

of deer were expressed. Concerns that restrictions on altitudinal migration and movement will lead to 

starvation and death, negatively impacting total deer populations were expressed. 

Additionally, concerns were expressed about young-growth forests growing thicker and reducing sunlight 

to the understory. The reduced light source prevents vegetative growth in the understory that provides 

important food sources for deer. 

Commenters sought assessment of the stability of deer populations as a function of deer habitat and 

commented that the removal of lower elevation productive old-growth forest habitats is a key factor in 

determining the effects of an action on the species. 

Commenters sought analysis regarding the potential effects of the removal of essential deer habitat in 

areas where unfragmented habitat still exists. Commenters said that deer depend on old-growth forest 

habitat for foraging and refuge from severe weather. Commenters were concerned that deer populations 

have already decreased due to environmental pressures such as timber harvest and development. 

Commenters discussed effects of clear-cuts on deer habitat. There was concern about losses to deer 

populations due to their avoidance of clear-cut areas and there was discussion about those clear-cut 

areas serving as a continued food source because they serve as moose habitat instead of deer habitat. 

Response 212: Impacts to deer and their habitat are discussed in detail in the 2016 Forest Plan 

Amendment FEIS and summarized in the Wildlife section of this EIS. Based on habitat capability 

modeling, 89 percent of the original deer habitat capability on NFS lands of the Tongass is 

currently supported and 78 percent of the original habitat capability on all lands (NFS and nonNFS) is still present. Cumulative effects analyses show that modeled deer habitat capability 

would maintain 78 percent of the original level in 25 years and at 100 years for all lands. WAAs 

with the greatest impacts under the alternatives are located in GMU 2 (Prince of Wales and 

surrounding islands) where concentrated past timber harvest has occurred. Harvest associated 

with all alternatives would contribute to the cumulative reduction in POG and associated increase 

in fragmentation and loss of connectivity, which has the potential to reduce biological diversity. 

Potential impacts to deer would be analyzed at the project level for all future projects. Improved 

deer population numbers are possible with mild winters (which may be more frequent). Improved 

numbers may also occur in local areas where closed-canopy young growth is harvested and 
Appendix H

Final EIS H-53 Response to Comments

productive forage is produced for 15-25 years; it can also occur in older young-growth areas 

where stands move out of the closed-canopy stage, but this requires many years. However, on 

average across the Tongass, improved deer population numbers are not expected.

An ANILCA Section 810 evaluation and finding is required for any action to withdraw, reserve, 

lease, or otherwise permit the use, occupancy, or disposition of public lands in Alaska. The initial 

evaluation assesses the expected effect of the proposed action on subsistence uses and needs 

and concludes with a finding that the proposed action would or would not have a significant 

possibility of a significant restriction on subsistence use. If the evaluation results in the finding of a 

significant possibility of a significant restriction of subsistence uses, a subsistence hearing would 

be held. This evaluation and hearing would allow for site specific information to be used in the 

analysis such as what subsistence resources occur in the project area and may be affected, what 

levels of use occur in the project area by subsistence and non-subsistence users, and for 

subsistence users of the project area to tell managers what impacts the project may have on 

them. Subsistence uses would be given preference over non-subsistence uses if any restrictions 

are determined necessary. The 2016 Forest Plan determined an overall possible risk while 

project-level subsistence evaluations better identify specific impacts to abundance and 

distribution, access to resources, and competition with non-rural users.

Comment 213: When road systems are connected to communities, commenters sought road density 

limits (no greater than 0.7 mile of open roads per square mile of forest) to reduce impacts associated with 

overharvest of important game and furbearing species in the area.

Response 213: Road densities were analyzed at varying scales including WAAs, 6th Field subwatersheds, elevations below 1,200 feet, and estimated average road density on the Tongass NF 

over 100 years. Although slightly more road miles may be developed under the action 

alternatives, the average road densities on NFS lands and the percent of WAAs with road density 

less than 0.7 miles per square mile are expected to be similar to that predicted under the Forest 

Plan (See Table 2-12). 

Comment 214: There was an expectation that changes to Roadless Rule protections would lead to 

natural resource extraction and developmental activities that would negatively impact the viability of apex 

predators, including bears, which are important for regulating populations of herbivores such as moose, 

elk, caribou and provide economic, social, and cultural benefits. 

Response 214: While there would be more acres potentially available for harvest of productive 

old growth with each of the Alaska Roadless Rule action alternatives, there would be no change 

in the projected harvest amount from Alternative 1. Some other natural resource development 

projects (e.g. hydropower, transmission lines, and mining) and certain transportation projects, are 

already allowable in roadless areas. As such, The Forest Service does not anticipate a great 

increase in natural resource extraction and developmental activities under any of the alternatives 

that would affect the viability of apex predators.

Comment 215: Commenters were concerned that the wildlife viability assessments conducted for the 

Forest Plan to determine viability risk for 30 endemic species had flaws with the calculations, which 

resulted in substantially underestimated viability risks for wildlife.

Response 215: The analysis for the 2016 Forest Plan Amendment included a review of the most 

recent information available during the current Forest Plan process due to the fact that endemic 

species ties to island archipelagos are more sensitive to human activities. The Forest Plan 

standards and guidelines for endemic mammals direct the Forest to “maintain habitat to support 

viable populations and improve knowledge of habitat relationships of rare or endemic terrestrial 

mammals that may represent unique populations with restricted ranges. Because this decision 

does not authorize timber harvest, additional endemic species could be addressed in detail 

considering site-specific landscape characteristics and species of greatest conservation need at 

the project level. 
Appendix H

Response to Comments H-54 Final EIS

Comment 216: Commenters said that the Roadless Rule protects habitat for the Prince of Wales spruce 

grouse and the northern goshawk, which are environmentally and culturally important. There is concern 

that roadbuilding and development activities may decrease nesting and foraging habitat and increase 

mortality rates.

Response 216: The 2016 Forest Plan does include standards and guidelines for endemics and 

goshawk. The Roadless Rule EIS discusses the potential impacts to both of these species; 

however, species and their habitat would remain protected regardless of the alternative chosen. 

Despite the potential for localized effects, the transition to young growth guided by the 2016 

Forest Plan, unchanged by the Alaska Roadless Rule alternatives, is likely to benefit both spruce 

grouse and goshawks by reducing the amount of POG harvest that would occur over the planning 

horizon, thereby maintaining more old-growth forest that provides potential foraging, nesting, and 

post-fledging habitat.

Comment 217: There was concern that natural resource extraction and development, that could occur 

throughout the Forest should there be an exemption to the rule, would fragment habitat and destroy 

landscape connectivity.

Response 217: Energy, transportation, or other projects that may become permissible in new 

areas could affect various wildlife species and their habitat through direct disturbance or through 

removal or modification of habitats. These effects would be evaluated at the project level. The 

Forest-wide standards and guidelines would minimize overall impacts to wildlife and their habitats 

during project construction and operation.

Comment 218: Commenters sought additional analysis on causes and impact of decreased biodiversity 

associated with the clear-cutting and timber industry activities that changing the Roadless Rule would 

allow, taking a wholistic view of the ecosystem and understanding the full cycle of ecosystem wellbeing 

and biodiversity as an invaluable resource. Commenters sought analysis of effects to the rainforest 

ecosystem that includes specifics such as: impact of habitat fragmentation, capturing the true life cycle of 

ecosystem succession and the length of time required to re-establish climax communities.

Response 218: The issues raised are Forest Plan issues and are beyond the scope of this 

programmatic EIS. However, this EIS does include extensive analysis and projections of effects 

based on modeled future disturbances. The projects that produce these disturbances are all 

subject to future NEPA review.

Comment 219: Commenters sought effects analysis considering habitat contiguity to provide refuge for 

wildlife impacted by climate change. Habitat connectivity facilitates wildlife adaptation by allowing wildlife 

to adjust their home ranges and movement patterns.

Response 219: The Forest Plan Old-growth Habitat Conservation Strategy was designed to 

maintain a resilient old-growth forest ecosystem in the face of this uncertainty. The potential for 

contributions to climate change from continued old-growth timber harvest on the Tongass, which 

could indirectly affect wildlife species is addressed in the Biodiversity, Wildlife, and Climate and 

Carbon sections of the EIS. It is clear that climate change may also contribute to cumulative 

effects. Warmer temperatures and increased precipitation are anticipated to result in changes to 

vegetation and thus, the suitability of wildlife habitat, among other impacts (Haufler et al. 2010, 

Shanley et al. 2015; see the Climate and Carbon section). Although many species may benefit 

(e.g., greater overwinter survival of deer, and thus a greater prey base for wolves, resulting from 

warmer winter temperatures during normal years), habitat changes resulting from a longer 

growing season, wind, fires, insect infestations, and disease would have variable effects on 

others. The greatest concerns for wildlife populations in relation to climate change, however, are 

the weather extremes that can be expected to occur periodically (Haufler et al. 2010).

Comment 220: Commenters sought additional effects analysis considering the cumulative impacts of 

deforestation and climate change and changing the Roadless Rule on the existing and future declines for 

deer population and the required minimum deer population capabilities of existing ecosystems. 
Appendix H

Final EIS H-55 Response to Comments

Response 220: Climate change is considered in Chapter 3, Climate and Carbon. It should be 

noted that deforestation involves removal of all trees on forested land to convert it to other land 

uses. Since the mid-1950s, changes in land use have been minor in the Tongass. Development 

pressure for land use conversion in Southeast Alaska has been slight. This is true for the nonNFS lands as well. Also see responses to Climate and Air comments and the comment above.

Comment 221: Commenters said that the Roadless Rule was enacted, in part, to improve wildlife 

conditions, therefore a change to the Roadless Rule would negatively impact the strides made in 

conservation regionally.

Response 221: This may be true in other national forests, which have been extensively roaded, 

harvested, and developed, but changing the Roadless Rule on the Tongass would not have a 

direct effect on regional wildlife conservation and the potential for significant indirect effects is 

very slight. The Tongass National Forest developed a protective Forest Plan in 1997, prior to the 

2001 Roadless Rule. This Plan allocated the majority of the Forest to non-development LUDs, 

which severely restrict timber harvest and road development. These reserves along with 

standards and guidelines implemented within the development LUDs, such as beach and estuary 

fringe buffers and riparian buffers, comprise the Old-growth Habitat Conservation Strategy. In 

2008, the geographical extent of the reserves in this strategy was effectively expanded by the 

Timber Sale Program Adaptive Management Strategy, which restricted all future harvest to Phase 

1 and eliminated all harvest in Phases 2 and 3 (which are mostly roadless areas), unless harvest 

levels reach an established threshold (which they have not come close to). In 2016, the Younggrowth Transition Strategy was adopted, which established a much lower harvest rate for oldgrowth, while transitioning to predominantly a young-growth timber industry. Since 2016, oldgrowth timber sales have been well below the 2016 reduced level. Therefore, the Tongass has 

moved strongly in the direction of wildlife conservation, with or without the Roadless Rule, which 

has only applied to the Tongass for about half of the time it has existed (the Tongass was exempt 

from 2003 to 2011).

Comment 222: Commenters were concerned that removing Roadless Rule protections could lead to 

increases in human-wildlife conflict, threatening the well-being of humans and wildlife.

Response 222: Human-wildlife encounters can occur throughout much of the Forest. In some 

instances, that may pose a risk. In many cases, that is a desirable experience for residents and 

tourist. We believe the opportunity for human-wildlife encounters is similar between alternatives.

Comment 223: Roadless Rule protections could lead to natural resource extraction and developmental 

activities that resulting in displacement of wildlife and have detrimental effects on functional behaviors 

such as breeding and movement, that are essential for functional, healthy wildlife populations.

Response 223: Energy, transportation, or other projects that may become permissible in new 

areas could affect various wildlife species and their habitat through direct disturbance or through 

removal or modification of habitats. These effects would be evaluated at the project level. The 

Forest-wide standards and guidelines would minimize overall impacts to wildlife and their habitats 

during project construction and operation.

Comment 224: Commenters stated that wildlife use roads and may be affected by road development.

Response 224: Forest Plan requirements would still apply regardless of the alternative selected; 

however, there would still only be a slight potential increase in roads and essentially no change in 

harvest amount, so effects to wildlife and their habitat would be nearly identical to current plan 

conditions over the Tongass. The Transportation Forest-wide standards and guidelines that 

require travel access road objectives to be developed for all roads and would not be affected by 

any Alaska Roadless Rule alternative.

Comment 225: Commenters said that Roadless Rule protections helped maintain salmon populations 

which helps preserve the food source for bears, sustaining their population numbers. 
Appendix H

Response to Comments H-56 Final EIS

Response 225: Current information on commercial salmon harvest has been added to the FEIS 

(see Figures 3.3-3 and 3.3-4). The effects of timber harvest, resource extraction and related 

actions at the forest-planning level are summarized in the included text. Effects of these actions 

on fish resources and their habitat are address in the 2016 Forest Plan Amendment EIS, which 

has been cited as the source for type and magnitude of effects. That document sufficiently 

addresses the issues raised in the comment relative to important fish resources at the planning 

level. Relative changes between alternatives that could affect fish resources and habitat are 

presented. Additional detail on differences between the alternatives concerning potential changes 

in quantity of roads (including road densities by sub-watershed) and timber harvest have been 

added, including changes to fish resources from those presented in the 2016 Forest Plan 

Amendment EIS. It is important to recognize that this is a programmatic action and that potential 

site-specific effects will be addressed under separate project-specific NEPA analyses, as this 

assessment will not authorize any site-specific actions.

Alternative 6 would be less protective to fish resources within T77 watersheds and TNC/Audubon 

Conservation Priority Areas than Alternatives 2, 3, and 4 because it does not restrict timber 

harvest and road building in these areas, removing all regulatory roadless designations. Forest 

Plan requirements would still apply, including the prohibition on old-growth harvests within these 

areas. However, there would still only be a slight potential increase in roads and essentially no 

change in harvest amount, so effects to fish and their habitat would be nearly identical to current 

plan conditions over the Tongass.

Comment 226: Changes to Roadless Rule protections could lead to natural resource extraction and 

developmental activities resulting in activities that negatively impact rare and endangered species.

Response 226: Energy, transportation, or other projects that may become permissible in new 

areas could affect various wildlife species and their habitat through direct disturbance or through 

removal or modification of habitats. These effects would be evaluated at the project level. The 

Forest-wide standards and guidelines would minimize overall impacts to wildlife and their habitats 

during project construction and operation.

Comment 227: Commenters sought disclosure of how the agency would restore or maintain the diversity 

of ecosystems and habitat types within the area affected by the proposed changes to the Roadless Rule 

and that large-tree old growth be considered a distinct habitat type. Commenters described large-tree old 

growth and old-growth cedar stands as being at risk of being eliminated on northern Prince of Wales 

Island and other bio-geographic areas on the Tongass. There was concern that reductions in these forest 

communities would lead to a reduction in Sitka black-tailed deer populations and Alexander Archipelago 

wolf populations on Prince of Wales.

Response 227: From a biological diversity standpoint, high-volume POG and large tree POG are 

thought to have the highest importance for diversity. High-volume POG is defined as the grouping 

of the three tree size and density classes that represent the highest volume strata—SD5S, SD5N, 

and SD67 types. Large-tree POG is defined as the SD67 class, representing the most productive 

of the POG types, and typically containing the highest density of large trees.

There are approximately 5 million acres of POG forest on the Tongass. Of this, approximately 42 

percent is high-volume POG (SD5S, 5N, and 67 types) with approximately 11 percent classified 

as Large-tree POG (SD67 type). See Tables 3.3-3 and 3.4-4, 3.4-8 and 3.4-9 which shows the 

distribution of existing POG forest by biogeographic province and POG type and amount 

remaining. Transition to predominantly young-growth harvest over time would enhance biological 

diversity and the functioning of the Old-growth Habitat Conservation Strategy over the long-term.

Comment 228: The DEIS relies on outdated and inadequate monitoring data for goshawks and other 

wildlife in order to support its conclusions. The agency has not presented the limited wildlife survey data 

conducted in connection with timber sales or explain how these monitoring data have helped inform the 

DEIS.
Appendix H

Final EIS H-57 Response to Comments

Response 228: The information used in the development of the Forest Plan is sufficient for the 

analysis of this EIS. As none of the alternatives authorize any site-specific projects or other 

ground-disturbing activities, the most current site-specific data will be used during project-level 

reviews.

Comment 229: The DEIS fails to rationally assess impacts to migratory birds.

Response 229: Migratory birds are assessed in the Wildlife section. Impacts and measures to 

avoid/minimize impacts would be addressed at the project level. 

Comment 230: The Forest Service must reinitiate ESA consultation before adopting the proposed rule. 

The Service cannot forgo additional consultation because the prediction that logging will not increase if 

roadless areas are opened to new development is unsubstantiated. 

Response 230: None of the alternatives authorize any site-specific projects or other grounddisturbing activities. Specific projects that include timber harvest, road construction, and/or road 

reconstruction must undergo site-specific environmental analysis when they are proposed to 

comply with NEPA. None of the alternatives considered in this FEIS waive any applicable 

requirements regarding site-specific environmental analysis, public involvement, or consultation 

with the Services, or compliance with other applicable laws.

Watershed and Fish

Comment 231: Commenters disagreed with DEIS findings and expressed concern about effects analysis 

for fish and the region's commercial, sport, subsistence and ursine fisheries. Commenters requested the 

use of more current baseline data, including consideration of climate change, in this analysis. 

Commenters sought analysis for anadromous fish streams, salmon (including coho and pink) habitat and 

survival. In analyzing effects for fish, commenters sought use of data that incudes current harvest data or 

information about project area salmon populations.

Response 231: Current information on commercial salmon harvest has been added to the EIS 

(see Figures 3.3-3 and 3.3-4). The effects of timber harvest, resource extraction and related 

actions at the forest-planning level are summarized in the included text. Effects of these actions 

on fish resources and their habitat are address in the 2016 Forest Plan Amendment EIS, which 

has been cited as the source for type and magnitude of effects. That document sufficiently 

addresses the issues raised in the comment relative to important fish resources at the planning 

level. Relative changes between alternatives that could affect fish resources and habitat are 

presented. Additional detail on differences between the alternatives concerning potential changes 

in quantity of roads (including road densities by sub-watershed) and timber harvest have been 

added, including changes to fish resources from those presented in the 2016 Forest Plan 

Amendment EIS. It is important to recognize that this is a programmatic action and that potential 

site-specific effects will be addressed under separate project-specific NEPA analyses, as this 

assessment will not authorize any site-specific actions. 

Comment 232: Because there was concern that changes to Roadless Rule protections would lead to 

natural resource extraction and developmental activities, commenters sought consideration of effects to 

fish, Dungeness crabs, wetlands and watershed ecosystems including soil erosion and sedimentation, 

edge effects on windthrow or blowdown, mass erosion and channel erosion resulting from hydrologic 

changes caused by logging, the effects of roads altering hydrology and erosion processes, and alteration 

of groundwater temperature by logging. Commenters sought analysis of cumulative effects to salmon 

streams and salmonid habitat associated with future road system expansion. Commenters questioned the 

effectiveness of mitigations discussed in the DEIS. 

Response 232: See response to above comment under Watershed and Fish. Additionally, Forest 

Plan level effects are addressed in the 2016 Forest Plan Amendment EIS which addresses the 

effects on the issues noted in the comment including resource extraction and nearshore marine 

habitat. Actions that may affect marine environment such as beach fringe harvest and log transfer 

facilities would be similar among all alternatives and effects are addressed in the 2016 Forest 
Appendix H

Response to Comments H-58 Final EIS

Plan Amendment EIS. This document addresses only how the Alaska Roadless Rule alternatives 

would change those effects at the planning level. Fishery and habitat-related issues not 

presented in more detail would not vary substantially among alternatives and would be the similar 

to those discussed for the existing management actions in the 2016 Forest Plan Amendment EIS.

Comment 233: There was concern that changes to Roadless Rule protections would lead to natural 

resource extraction and developmental activities that would accelerate acidification of water bodies; 

reducing the survival of calcifying species such as oysters, clams, corals, urchins, and certain 

phytoplankton which are food sources for humans and other wildlife. The loss of these species could 

have substantial consequences on the ecosystem structure, food systems, and subsequently negatively 

impact the economy.

Response 233: See responses to two comments above under Watershed and Fish. The 

proposed action and the alternatives do not expand levels of timber harvest and current/future 

timber harvest levels are low relative to historic levels. The acidification of water bodies is not a 

current issue nor is it expected to result from future actions. In particular, effects on marine 

species are expected to be very minor. Specific timber sale projects, mineral projects, energy 

projects, and other road project proposals are all subject to individual NEPA analysis and 

mitigation of effects.

Comment 234: The DEIS fails to substantively and accurately address fisheries and watershed effects, 

such as windthrow/blowdown, mass erosion, channel erosion, roads, erosion processes, alteration of 

groundwater temperature, post-logging fluvial erosion, gullying and channel expansion, and 

sedimentation. The assumption in the DEIS that road building and logging can occur in currently roadless 

watersheds with no risk to aquatic habitat and fisheries is not supported by available scientific literature. 

Commenters were concerned that impacts of the rule change on aquatic ecosystems (both freshwater 

and saltwater) are not adequately analyzed in the DEIS.

Response 234: See other responses to the two previous comments. The general types of effect 

from timber harvest and related actions (e.g. road building) identified in the above comment are 

summarized in this EIS document with further reference to the 2016 Forest Plan Amendment EIS, 

which provides details of the type and potential magnitude of these effects. When specific timber 

harvest or other projects are proposed, site-specific NEPA analysis and required pubic 

involvement would be conducted at that time. No on-the-ground actions are authorized by the 

final rule.

Comment 235: Concern was expressed that the DEIS fails to adequately assess the current status of 

fish and fish habitat on the Tongass, discuss how the current status relates to historic abundance, and to 

analyze how the proposed action will affect fisheries, fish habitat, and the important waters that support 

these resources. Underlying the DEIS and made explicit by various statements of Forest Service officials 

at public meetings, is the misguided belief that expanding logging and logging roads into roadless areas 

will have no effect on fish and fish habitat.

Response 235: The EIS summarizes the main factors of logging-related actions that affect 

fisheries resources, especially as they relate to roads. More analysis was supplied in the FEIS 

assessing effect of each specific alternative on number of roads and road density in Tongass 

watersheds which indicate nearly identical conditions among all alternative to Alternative 1. 

Additionally, more details on the current fisheries and fish habitat, related water quality and 

quantity, and the effect of currently approved actions on these resources are provided in the 2016 

Forest Plan Amendment EIS, which is referenced as suppling this information. As discussed in 

the DEIS, the current Forest Plan direction include measures to reduce potential impacts to fish 

and their habitat that will remain in place under all of the Roadless Rule alternatives. Also as 

noted in the EIS, none of the alternatives substantially change the number of road miles, harvest 

acres, type of harvest, harvest of old growth, or harvest in T77 Watersheds and TNC/Audubon 

Conservation Priority Areas and, as a result, potential effects to important fish and fish resources 

would be similar across all alternatives. As noted elsewhere in the comment response document, 

it is important to recognize that this is a programmatic action and that potential site-specific 
Appendix H

Final EIS H-59 Response to Comments

effects will be addressed under separate project-specific NEPA analyses, as this assessment will 

not authorize any site-specific actions.

Comment 236: There was concern expressed that the analysis assumed that logging can occur in 

roadless areas without harm to fish resources.

Response 236: As noted in the analysis, future timber on the Tongass would be managed under 

the current Forest Plan, which includes specified BMPs for harvest, vegetative buffers, and other 

measures designed to reduce potential impacts to fish. These measures would be implemented 

in newly opened roadless areas in the same way as they are in areas where harvest is presently 

allowed. Under these conditions, it was concluded that logging and road building can be done 

without substantial adverse effects to fish habitat and fish resources. The assessment in the 2016 

Forest Plan evaluation included consideration of building new roads and harvesting old growth 

timber, both of which could be part of the any Alaska Roadless Rule alternative. Site-specific 

concerns would be evaluated in a separate process prior to any on the ground disturbing actions.

Comment 237: Concern was expressed that the proposed plans have not designated what protections 

would occur in T77 Watersheds and TNC/Audubon Conservation Priority Areas relative to new road 

building. Also, that the proposed plan will result in significant entry into roadless areas to access adjacent 

timber that is not part of these protected watersheds.

Response 237: No old-growth harvest would occur in the T77 watersheds or TNC/Audubon 

Areas under any alternative due to Forest Plan requirements. Within ARAs, roads would be 

prohibited unless they meet the exceptions, varying by ARA designation, provided in the rule (see 

appendix G and Table 2-2 in the EIS. A limited increase in young-growth harvest could occur in 

these areas. However, nearly all young growth is found where roads are already present, which 

greatly limits the need for new road construction in these watersheds. Site-specific future actions 

will be evaluated when specific actions are proposed. 

Comment 238: Commenters expressed concern that the DEIS analysis, which concluded that logging 

and road building in roadless areas would not have substantial adverse effects to soil, water quality, water 

quantity, and riparian conditions due to the implementation of current Forest Plan BMPs and other 

requirements is not valid. Concerns were related to the effects from logging and road building on high 

hazard soils, stream buffer effects on windthrow, effects of roads on hydrology and erosion, related 

effects to sediment in stream channels and stream channel stability, and upslope clearing effects to 

stream temperature.

Response 238: These issues were fully addressed in 2016 Forest Plan Amendment EIS, 

primarily in the Water section. Many of these parameters are presented in the updated Fish 

analysis in the FEIS. The literature reviewed in the 2016 Forest Plan EIS assessment that 

addressed these potential effects emphasized Tongass monitoring results, which are most 

relevant to addressing these issues as they include measured effects of implementation of 

current BMPs. While there is some level of risk with increased roads and logging, effects to fish 

and fish habitat that may occur under the current Forest Plan were not considered to be 

substantial in the evaluation in the 2016 Forest Plan EIS. The estimated amount and type of 

harvest and roads would be similar to the current Forest Plan under all of the proposed Roadless 

Rule alternatives with similar effects to water quantity and quality and harvest and road-related 

parameters. Estimated miles of road construction and reconstruction have been added to the 

FEIS for each alternative. These estimates consider road miles over the next 100 years of Project 

implementation. 

Comment 239: Commenters noted that the DEIS did not include most recent status of Pink and Coho

salmon numbers especially recent decreases in abundance.

Response 239: Current information on commercial salmon harvest has been added to the EIS 

(see Figures 3.3-3 and 3.3-4). The reasons for recent declines have not been fully developed but 

recent changes are more likely due to adverse ocean conditions that have been reducing ocean 

salmon survival (Heinl et al. 2017) and non-harvest related drought conditions that have also 
Appendix H

Response to Comments H-60 Final EIS

adversely affected both Pink and Coho salmon in streams than the result of recent harvest 

practices.

Comment 240: Commenters noted that declines of pink salmon appear worse in the northern inside 

areas of Southeast Alaska and on Prince of Wales Island. There is concern that timber harvest in these 

areas is a major contributing factor. 

Response 240: Timber harvest has occurred for decades in many of these areas and was much 

more intensive prior to 1990 in the most productive areas (riparian and flood plain areas). These 

areas have received more protections over the last three decades and rates of timber harvest 

have been greatly reduced. Recent changes in Pink salmon numbers are more likely due to 

ocean effects and non-harvest related drought conditions that affect spawning and rearing fish in 

freshwater than the result of recent harvest practices. 

Comment 241: Commenters noted that low harvest number of coho salmon in 2018 and 2019 may be 

related to timber harvest practices including a lack of buffers on small streams and culvert blockages of 

fish passages.

Response 241: While small streams were not well buffered in the past and culverts were not 

always properly installed, these practices have changed. For over three decades, all fish bearing 

streams have been buffered and many others that are not fish bearing have also had buffers 

included during timber harvest. Additionally, all newly installed culverts are required to meet fish 

passage criteria. While some past culverts still block some fish areas, less than 0.5 percent of all 

anadromous stream length on the Tongass has some blockage. In addition, anadromous fish 

were found above culverts with passage issues in more than half of these streams. The reasons 

for recent declines in Coho salmon have not been fully developed but recent changes are more 

likely due to adverse ocean conditions that have been reducing ocean salmon survival (Heinl et 

al. 2017) and non-harvest related drought conditions that have also adversely affected both Pink 

and Coho salmon in streams than the result of recent harvest practices.

Comment 242: Commenters expressed concern that fish populations and stocks are already declining 

due to existing regional logging and mining activities, which would be exacerbated by a change in the 

Roadless Rule. For example, deforestation results in decreased stream shading and increased water 

temperatures. A specific example of already declining fish populations are the Dog salmon.

Response 242: Although commercial salmon harvest numbers have been trending downward for 

the past 5 years or so, there are many factors at play, and there is no evidence that existing 

regional logging and mining activities are the cause. The highest total salmon catch in history for 

Southeast Alaska took place only 7 years ago, in 2013 (Figure 3.3-4 of the EIS). Timber harvest 

levels have been declining on the Tongass for many years; during the last 3 years only an 

average of 15 MMBF of timber have been sold, including only 4 MMBF of old growth. Establishing 

timber harvest levels, authorizing timber sales, and permitting mining activities are all covered by 

separate NEPA review that is independent of the Roadless Rule EIS. 

Comment 243: Commenters said that fish populations are already low in many fisheries and asked if fish 

populations completely disappear due to changes in the Roadless Rule, who would be responsible for 

replenishing fish stocks. 

Response 243: Please see the response to the previous comment. Implementing the Alaska 

Roadless Rule would not directly affect fish populations. The Tongass Forest Plan includes an 

extensive array of standards and guidelines that protect fish habitat and specific development 

projects would be subject to separate NEPA reviews. The disappearance of fish populations on 

the Tongass as a result of Tongass forest management is not a realistic scenario. 

Comment 244: Because the region is prone to windthrow, commenters sought buffer zones to be half a 

mile wide to adequately protect streams from the heat exposure and sedimentation that is detrimental to 

fish populations. Current policies only require a 100-foot stream buffer, which logging companies often 

ignore and harvest timber to the water’s edge. Changing the Roadless Rule would expose more miles of 

important fish habitat to these destructive practices.
Appendix H

Final EIS H-61 Response to Comments

Response 244: The current Forest Plan requires a minimum of a 100-foot stream buffer on fish 

streams. Most streams are given buffers wider than that following a set of prescriptions outlined in 

the Forest Plan, including the requirement of assurance of windfirmness. Logging activities are 

inspected and logging companies are required to comply with the established buffers on NFS 

lands. The buffers on non-NFS lands are not as restrictive. 

Comment 245: Concern was expressed that roadless areas supply unique areas for protection of fish 

and fish habitat and this was not properly assessed in the analysis in the DEIS. Areas with limited roads 

often have healthier fish resources. 

Response 245: The 2016 Forest Service Plan BMPs are intended to help protect fish habitat and 

would be implemented in newly opened roadless areas in the same way as they are in areas 

where harvest is presently allowed. The alternatives evaluated in this EIS consider similar levels 

of harvest and road building, with relatively small variations in miles of road construction and 

reconstruction anticipated over the next 100 years. As noted in the DEIS, with this in mind, 

moving where harvest and roads would occur is not expected to result in substantial changes at 

the planning level. When specific timber harvest or other projects are proposed, site-specific 

NEPA analysis and required pubic involvement would be conducted at that time, including 

evaluation of changes in the amount of road miles and road density. No on-the-ground actions 

are authorized by the final rule.

Comment 246: Concern was expressed that pending DEISs on Prince of Wales Island that propose 

increased timber harvest, road building, and stream crossings have delayed final analysis until the 

Roadless Rule proposal is finalized. The concern is that these projects would greatly expand harvest into 

areas currently not accessible due to current Roadless Rule prohibitions and that if this rule is 

implemented these plans would then be finalized with these expansions included, which would damage 

fish and fish habitat. 

Response 246: No site-specific projects or ground-disturbing activities are authorized in the final 

rule and the amount of old-growth timber harvest is not expected to vary by alternative, with 

effects to fishery resources expected to be similar to those evaluated in the 2016 Forest Plan 

Amendment EIS in all cases. Any projects that include timber harvest or road construction will 

undergo environmental analysis in compliance with NEPA, including those currently proposed or 

in process.

Comment 247: Commenters expressed that the protected T77 Watersheds and TNC/Audubon 

Conservation Priority Areas watersheds are a small portion of the major fish producing watersheds on the 

Tongass and protections for these areas alone will not protect overall fish production in the Tongass and 

will also result in the concentration of fisheries in some areas and lack of fisheries in other areas. 

Response 247: The T77 Watersheds and TNC/Audubon Conservation Priority Areas were 

determined to be priority areas by special interest groups and environmental organizations 

including Trout Unlimited. While the Forest Service does supply extra protections for these areas, 

the Tongass National Forest has a variety of projections from LUDs that exclude most types of 

development, including timber harvest, to major BMPs that will be implemented in areas where 

harvest is permitted and will adequately protect fisheries resources including commercially 

harvestable stocks of salmon. When specific timber harvest or other projects are proposed, sitespecific NEPA analysis and required pubic involvement would be conducted at that time. No onthe-ground actions are authorized by the final rule. The standard BMPs and site-specific actions 

that will be determined during a separate process will be designed to protect fish resources of 

concern. 

Comment 248: Past analysis of roadless areas concluded that logging related practices have the risk of 

affecting fish habitat and fish populations. Current analysis cannot now be justified in saying that allowing 

harvest and related actions in these areas can now occur without adverse effects to fish. Also, the current 

analysis relies on the 2016 Forest Plan analysis that concluded actions could be taken and result in 

minimal harm to fish resources. This analysis cannot be used to justify the conclusion of no adverse 
Appendix H

Response to Comments H-62 Final EIS

effects to changes in the Roadless Rule. Some adverse effects would be expected with even the best 

planned or implemented actions. 

Response 248: The current analysis is not substantially different than the 2016 Forest Plan 

analysis. The amount and type of areas that would be disturbed by harvest and roads would be 

similar to those considered in the 2016 Forest Plan EIS under all alternatives. The relative 

changes are discussed in the DEIS for this Project and noted in more detail in the FEIS. While 

there are low, long-term risks to fish habitat from the relatively low amount of proposed harvest 

and associated construction and reconstruction of roads, the 2016 Forest Plan analysis indicated 

that with riparian protections in place there would be no substantial adverse effects to fish. 

Because changes in the main parameters that would be affected by implementation of the 

changes in the Roadless rule under all alternatives (e.g. acres of harvest, new and rebuilt road 

miles, likely number and type of stream crossings), the conclusions at this planning level are 

similar to that of the Forest Planning level analysis of 2016.

Comment 249: Commenters expressed that many existing barrier culverts in the Tongass have not been 

repaired and continue to block suitable fish habitat. Construction of more roads in currently roadless 

areas will add more barriers and add to the backlog of culverts that are not repaired reducing further 

available habitat. There was concern about the Forest's road maintenance backlog.

Response 249: Many culverts that were constructed in the initial logging years were not 

adequate for fish passage. Current requirements are that all new culverts meet fish passage 

requirements. While some existing culverts have not been repaired and some new culverts may 

have passage issues, the relative effect to Tongass anadromous stream habitat is very low. As 

estimated in 2016 Forest Plan culverts have partly blocked about 0.5 percent of total Tongass 

anadromous habitat. However, most of the stream habitat indicated to have limited access to 

anadromous fish have fish upstream of these culverts. As a result, no substantial loss of 

anadromous fish habitat is expected to occur from new culvert installation under any of the 

proposed alternatives.

Comment 250: Commenters sought more full consideration of the effects of climate change in both the 

ocean and freshwater on salmon stocks. Commenters also noted that Roadless Areas may supply better 

fish habitat than other Tongass Forest areas after climate change effects occur.

Response 250: There are many potential effects of climate change that would affect logged and 

unlogged areas and streams and estuaries. Some may be positive in some areas and negative in 

others. The range of these effects are discussed in detail in the EIS. While roadless areas may 

have some benefit, it cannot be reasonably estimated that overall differences in effects to fish 

resources would occur with or without the changes in roadless areas considered in the proposed 

alternatives. 

Comment 251: Because changes to Roadless Rule protections may lead to natural resource extraction 

and developmental activities, commenters expressed concern about soil erosion and hydrology. This 

included concerns about effects such as landslides, river channelization, flow patterns, streamflow, 

snowmelt, wetlands, changing water chemistry, and flooding. Commenters were concerned that leaving 

unlogged riparian forests is insufficient to mitigate for the effects of upland logging on streams.

Response 251: See responses above under Watershed and Fish. The proposed action and the 

alternatives do not expand levels of timber harvest and current/future timber harvest levels are 

low relative to historic levels. Specific timber sale project, mineral project, energy project, and 

other road project proposals are all subject to individual NEPA analysis and mitigation of effects.

Climate and Air

Comment 252: Commenters expressed concern that exempting the Tongass National Forest from the 

Roadless Rule may lead to the removal of trees which would impact air quality. Removing protections can 

lead to indirect effects that may increase air toxic emissions, further reducing air quality. Negative impacts 

to air quality from the removal of trees and secondary effects would exacerbate or worsen pre-existing 
Appendix H

Final EIS H-63 Response to Comments

conditions and disease risk. An increase in disease risk could lead to increases in health care costs, 

creating a reinforcing feedback loop where limitations to health care access further worsen health 

outcomes.

Response 252: The Roadless Rule would not directly lead to the removal of trees. Under all 

alternatives, the PTSQ for the Tongass, remains the same. Therefore, it would affect where trees 

are harvested, but would have little effect on how many trees are harvested. None of the action 

alternatives propose specific actions that would alter air quality. Impacts to air quality would be 

based on site-specific proposals. No increase in disease risk or health care costs are expected as 

a direct result of any of the alternatives.

Comment 253: There was concern that exempting the Tongass National Forest from the Roadless Rule 

protections would lead to climate change and the subsequent long-term economic impacts of climate 

change would significantly outweigh any short-term economic benefits from natural resource extraction 

and development. Investing in the development of sustainable and innovative resource management can 

mitigate climate change effects, while providing jobs for Alaskans.

Response 253: Refer to the analysis presented in the Climate and Carbon section and to the 

response to the previous comment. Implementation of any of the alternatives would be similar to 

how the Forest is managed today and would not convert additional forest land to non-forest uses. 

The largest source of GHG emissions in the forestry sector globally and within the United States 

is deforestation, defined as the removal of all trees on forested land to convert it other land uses. 

This EIS does not authorize more or less timber harvest. The PTSQ for the Tongass is 

established by the Forest Plan. This action does not change the PTSQ. Therefore, it is not 

expected to affect the amount of timber harvest, but it will affect where timber is harvested. In 

addition, the amount of timber harvest expected over the next 100 years is low by historical 

standards.

Comment 254: There was concern that developmental activities exacerbate climate change effects and 

will lead to communities being displaced.

Response 254: See previous two responses. The level of development on the Tongass is 

controlled by the Forest Plan and development projects require their own NEPA analysis prior to 

implementation.

Comment 255: Commenters were concerned that global loss of forests to deforestation and wildfires 

have made large intact forests increasingly rare. Exempting the Tongass National Forest can result in 

further loss in intact ecosystems that have global importance for sustaining life.

Response 255: As noted in previous responses (see the previous three responses), the PTSQ 

for the Tongass is established by the Forest Plan. This action does not change the PTSQ. 

Therefore, it is not expected to affect the amount of timber harvest, but it will affect where timber 

is harvested. In addition, the amount of timber harvest expected over the next 100 years is low by 

historical standards. 

Comment 256: There was concern that exempting the Tongass National Forest from the Roadless Rule 

protections would lead to natural extraction and developmental activities that would exacerbate uncertain 

and extreme weather events that can have catastrophic consequences such as increases in the 

incidence of flooding, fires, drought, landslides, as well as intensified hurricanes. Increased incidence and 

severity of natural disasters can have profound economic and public safety consequences by putting 

human health, infrastructure, and natural resources at risk. 

Response 256: As noted in previous responses (see the previous four responses), the PTSQ for 

the Tongass is established by the Forest Plan. This action does not change the PTSQ. Therefore, 

it is not expected to affect the amount of timber harvest, but it will affect where timber is 

harvested. In addition, the amount of timber harvest expected over the next 100 years is low by 

historical standards. Differences among the alternatives may result in some changes in mineral 

extraction or energy production, but these differences are expected to be minor.
Appendix H

Response to Comments H-64 Final EIS

Comment 257: There was concern that exempting the Tongass National Forest from the Roadless Rule 

protections could lead to lead to developmental activities that increase the release of greenhouse gas 

emissions. Atmospheric concentrations of greenhouse gases (water vapor, nitrous oxide, carbon dioxide, 

methane, and chlorofluorocarbons) have changed with increases of emissions from human activities such 

as deforestation, burning of fossil fuels, production of energy, land use changes, landfill waste 

decomposition, as well as industrial and agricultural practices. Increases in these natural occurring 

greenhouse gases reinforce the trapping of heat from the Sun on Earth. Increases in temperature can 

create reinforcing feedback loops that can further increase greenhouse gases in the atmosphere, 

examples include increased water vaporization, demand for heating and cooling, as well as increased 

releases of methane and carbon dioxide from thawing ice stores and permafrost.

Response 257: Please see the previous four responses.

Comment 258: Commenters said that by keeping the Roadless Rule protections in place, a considerable 

amount of carbon sequestration can occur that will contribute to climate change mitigation, while 

maintaining critical habitat. There was concern that exemption from the rule would lead to logging, in 

which case, the Forest would release considerable carbon reserves in addition to the loss of the carbon 

sequestration capabilities, contributing to the acceleration of climate change. Because old-growth trees 

sequester more carbon than new growth, the carbon sequestration capabilities cannot be recovered 

following logging on a time scale sufficient for the mitigation demand. Removal of trees and secondary 

development activities (logging, road construction, resource extraction) that damage the old-growth 

ecosystem will impact the capacity of other flora to sequester carbon. Climatic changes disrupt normal 

environmental parameters such as environmental fluid dynamics, ambient air temperature, water 

temperature, rainfall, and water acidity, which can have detrimental impacts on ecosystem services and 

natural resource availability.

Response 258: Please see the previous responses under Climate and Air. As noted, this action 

does not change the PTSQ for the Tongass. Therefore, no significant change in timber harvest is 

expected, although the distribution of harvest may be different under each alternative.

Comment 259: Commenters were concerned about the impact of the carbon footprint from shipping 

timber overseas, asking that it be properly accounted for as an additional impact on climate change.

Response 259: Please see the previous responses under Climate and Air. As noted, this action 

does not change the PTSQ for the Tongass, nor does it affect the level of exported timber. 

Therefore, no significant change in timber harvest or export is expected, although the distribution 

of harvest on the landscape may vary by alternative. 

Comment 260: Commenters said that exempting Tongass National Forest from the Roadless Rule 

protections will lead to natural extraction and developmental activities that would accelerate climate 

change effects negatively impacting human health and survival.

Response 260: Please see previous responses under Climate and Air. As noted, this action does 

not change the PTSQ for the Tongass. Therefore, no significant change in timber harvest is 

expected, although the distribution of harvest may be different under each alternative. There 

could be some additional mineral extraction and/or renewable energy projects under some 

alternatives, especially Alternatives 4, 5, and 6, but increases are expected to be minor.

Comment 261: Commenters sought effects analysis disclosing how the proposed rule change will directly 

and indirectly impact carbon stores and sequestration, as well as the resulting environmental and 

economic effects from climate change associated with the rule change. Commenters sought analysis of 

either the potential value of carbon storage on the Tongass or the socioeconomic costs of carbon 

emissions and associated climate effects. 

Commenters were concerned that there was a lack of analysis associated with increased road 

construction, logging, and mining with the comprehensive cumulative impacts that would occur in both the 

near and far term in the face of a changing climate. For example, deforestation leads to increased heat 

energy to the land surface due to lack of canopy which impacts both water temperatures and snowmelt, 

both of which will be amplified due to climate change.
Appendix H

Final EIS H-65 Response to Comments

Response 261: Please see previous responses under Climate and Air. As noted, this action does 

not change the PTSQ for the Tongass. Therefore, average timber harvest is not expected to 

exceed the PTSQ level, although the distribution of harvest may be different under each 

alternative. Therefore, the proposed rule change will not significantly affect carbon stores and 

sequestration, nor will it result in environmental and economic effects from climate change.

Comment 262: Commenters disagreed that logging in the Tongass National Forest could lead to 

reductions of greenhouse gases.

Response 262: The EIS does not state that logging would lead to reductions of greenhouse 

gases. Rather, the EIS states the following. "The effects of implementing the Forest Plan under 

the nationwide Roadless Rule (i.e., the No Action Alternative) and the action alternatives on GHG 

emissions and climate change would likely be small though there is considerable uncertainty 

regarding these effects. For instance, there is uncertainty regarding long-term carbon release 

particularly because of the importance of how the wood is used (durable or nondurable products), 

the regrowth of young forests, and market dynamics related to substitution. Considering the 

alternatives in a global atmospheric carbon dioxide context, treatment levels would have a small 

contribution to GHG emissions and therefore would have a negligible effect on climate change."

Comment 263: The DEIS inadequately analyzes and unlawfully discounts the proposed rule's potential 

climate impacts. The DEIS unlawfully discards in silence the Forest Service's earlier conclusions that 

logging on the Tongass can cause significant greenhouse gas emissions.

Response 263: The EIS does not state that logging would not increase greenhouse gases. As 

stated in other responses above, this EIS does not affect the PTSQ. The Forest Plan is the 

process that identifies the level of harvest; this process only identifies the land base where 

harvest can take place. As noted above, the EIS states: “Considering the alternatives in a global 

atmospheric carbon dioxide context, treatment levels would have a small contribution to GHG 

emissions and therefore would have a negligible effect on climate change. There would be only 

negligible differences among the alternatives because the harvest levels and the mix of old 

growth and young growth to be harvested are expected to be very similar, and thus unaffected by 

implementation of the Alaska Roadless Rule. As a result, the alternatives would not differ in 

regard to their contributions to GHG emissions, changes in forest carbon stocks, carbon 

sequestration, or global climate change. Given the level of uncertainty in parameters related to 

the net contribution of GHGs, an attempt to quantify the evaluation would not provide a clearer 

understanding of potential effects.”

Comment 264: The Forest Service violated NEPA and NFMA requirements to use high quality, accurate, 

scientific information by failing to recognize the global importance of the Tongass for carbon storage; use 

of an inappropriate analysis scale to understate the value of the Tongass; and analyze that old growth 

forests in roadless areas store substantially more carbon than saw logs and young growth.

Response 264: Please see previous responses under Climate and Air. As noted, this action does 

not change the PTSQ for the Tongass. Therefore, average timber harvest is not expected to 

exceed the PTSQ level, although the distribution of harvest may be different under each 

alternative. This comment is relevant to a Forest Plan analysis where the PTSQ is under 

evaluation, which is not the case with this action.

Comment 265: The DEIS failed to disclose the economic value of roadless areas of the Tongass on the 

carbon markets and the social cost of carbon emissions resulting from logging.

Response 265: Please see previous responses under Climate and Air. As noted, this action does 

not change the PTSQ for the Tongass. Therefore, average timber harvest is not expected to 

exceed the PTSQ level, although the distribution of harvest may be different under each 

alternative. This comment is relevant to a Forest Plan analysis where the PTSQ is under 

evaluation, which is not the case with this action.
Appendix H

Response to Comments H-66 Final EIS

Comment 266: When the Forest Plan was originally developed it was based on the best available 

information; however, new information is available regarding the impacts of climate change on the area 

that should be incorporated into the Forest Plan.

Response 266: The climate change and carbon analysis presented in this EIS was based on 

extensive new information since the 2016 Forest Plan Amendment FEIS. The references cited in 

the Climate and Carbon section that were not available in 2016 include: Birdsey et al. (2019), 

Domke (2018), EPA (2019), Hayward et al. (2017), IPCC (2018), Markon et al. (2018), Sealaska 

(2018), and Smith et al. (2019).

Comment 267: The Forest Service failed to disclose and analyze the cumulative effects of expected 

climate change, road development, and logging on watersheds considered “safe havens”, refugia, or core 

areas for conservation of salmonid and other sensitive fish species. The analysis also fails adequately 

detail these areas importance to vulnerability and resilience on freshwater habitats and the fish 

populations’ dependent upon them.

Response 267: The vast majority of Tongass watersheds considered “safe havens”, refugia, or 

core areas for conservation of salmonid and other sensitive fish species are within Wilderness, 

National Monument, LUD II and other non-development LUDs, which do not permit logging or 

road development (with minor exceptions), and within T77 watersheds and TNC/Audubon 

Conservation Areas and Conservation Core Areas, which do not permit old-growth logging and 

associated road development. Furthermore, the Forest Plan prohibits old-growth logging in 

Phases 2 and 3 of the Timber Sale Program Adaptive Management Strategy, which includes a 

large portion of the Tongass National Forest development LUDs. The actions proposed in this 

analysis do not significantly affect timber harvest levels, which will remain at or below the PTSQ 

established by the Forest Plan.

Comment 268: Roadless Rule changes affect the opportunity, or lack, for renewable energy 

development (ex. Southeast Alaska Intertie) which has climate change impacts.

Response 268: The differences among the alternatives in terms of renewable energy 

development are expected to be minor to insignificant.

Timber and Logging

Comment 269: Commenters sought expanded regulations to ensure that timber industries are restricted 

from logging in any old-growth and rainforest habitats.

Response 269: This EIS does not authorize nor prohibit the harvest of old-growth timber. The 

PTSQ for the Tongass is established by the analysis for the Forest Plan. This EIS does not 

change the PTSQ nor does it change the composition of the PTSQ (i.e., the portion that is made 

up of old growth or young growth). Therefore, it is not expected to significantly affect the amount 

of timber harvest, nor the portion that is old growth or young growth, but it may affect where 

timber is harvested.

Comment 270: Commenters sought more site-specific analyses.as they believe the assumption used in 

the DEIS for even distribution of logging is arbitrary and the EIS needs to make a reasonable projection of 

likely areas of logging. The Forest Service should provide this analysis based on VCUs.

Response 270: In response to this comment and internal concerns, a model was developed to 

allocate the old-growth harvest acres in a more realistic pattern based on current assumptions. 

This model incorporated three factors: 1) it dropped the lowest volume areas; 2) it dropped the 

poorest economic VCUs based on old-growth timber values from 2007; and 3) it assumed that 

the vast majority of the harvest would take place in the southern part of the Tongass south of 

Frederick Sound where the majority of the infrastructure and the most economic timber are 

located. In addition, a model for predicting road mileage was developed and many additional 

project-specific analyses were conducted.
Appendix H

Final EIS H-67 Response to Comments

Comment 271: Commenters said that virgin old growth forests may have future research potential and 

resources that could lead to new medicines and medical treatments.

Response 271: Under all alternatives the percent of productive old growth (POG) remaining on 

the Tongass after 100 years will be 91 percent of the original POG (in 1954) (see Table 3.3-7). 

Similarly, see Table 3.3-8 and 3.3-9 for the percent of the original high-volume POG and the 

original large-tree POG.

Comment 272: The assumption that the Roadless Rule will not result in additional logging is arbitrary and 

capricious because the PTSQ is not a limitation on harvest as described in the DEIS and increased 

harvest is reasonably foreseeable. The exemption does not set a maximum limit on logging, which 

increases risk of significant environmental damage. The PTSQ is insufficient to determine maximum limits 

to logging because it only determines maximum harvest by a suitable yield limit, which could increase 

with exemption by increasing the total amount of suitable forestland.

Response 272: This EIS does not affect the limits on acres or volume to be harvested. The 

sustained yield limit (SYL), the PTSQ, and the projected wood sale quantity are established by 

Forest Plan analyses and these were established for the Tongass based on the 2016 Forest Plan 

Amendment EIS. No changes would occur in any of these components as a result of this EIS. 

Although the PTSQ is not a cap, it is the projected amount of timber to be sold that meets 

applicable utilization standards and is consistent with all plan components and the fiscal capability 

of the planning unit. Therefore, it is unlikely to be exceeded for any length of time, otherwise it 

would become inconsistent with other plan components and/or not be sustainable in terms of the 

fiscal capability of the Tongass. As a result, the Forest Plan would need to be amended or 

revised. 

The PTSQ for the Tongass is far below the SYL for the Tongass. It was established at a level that 

was far below the capability of the 2016 suitable timber base, which is the SYL. Therefore, if the 

suitable timber base should increase as a result of the Alaska Roadless Rule EIS, it is highly 

unlikely that there would be pressure to increase the PTSQ (which was already far below the 

SYL). 

Current harvest levels are well below the PTSQ and, although it is possible that actual harvest 

levels will increase as a result of opening up roadless areas by increasing options for economic 

sales, it is not anticipated that harvest levels will reach or exceed the PTSQ on average. 

However, analyses in this EIS, as well as in the 2016 Forest Plan EIS, assume that harvest levels 

do reach the PTSQ and remain there over the planning horizon (100 years) – a very conservative 

assumption based on current conditions. Also see response to following comment.

Comment 273: Commenters were concerned that the assumption that harvest levels would be equal 

across the action alternatives was flawed. The Forest Service fails to provide any support for its claim that 

the proposed rule will not increase logging in the Tongass.

Response 273: Effects throughout the EIS were analyzed assuming harvest at the PTSQ level 

for 100 years. Current levels of timber sales on the Tongass are far below the PTSQ level. Total 

volumes sold were 30.9 MMBF in 2017, 9.3 MMBF in 2018 and 5.6 MMBF in 2019 (from the 

PTSAR Report), while the current PTSQ is 46 MMBF. Thus, the average has been 15 MMBF or 

1/3 of the PTSQ for the first 3 years of implementation of the 2016 Forest Plan. On average about 

11 MMBF has been young growth and only 4 MMBF has been old growth. The largest problem 

with recent sales has been economics. It is likely that sales would increase above current levels 

with selection of one of the action alternatives, because of a greater number of options for putting 

together economic sales. However, it is not anticipated that harvest levels would reach or exceed 

the PTSQ on average. It should also be noted that the PTSQ would remain the same for all 

alternatives. Also, see the response to the previous comment, which explains why the PTSQ 

would not be exceeded for any length of time.

Comment 274: The assumption that changing the Roadless Rule will not lead to changing the forest plan 

and, subsequently, subject more than 165,000 additional acres to logging is flawed.
Appendix H

Response to Comments H-68 Final EIS

Response 274: Increasing the number of suitable acres does not mean that harvest levels need 

to increase. This may have been true 20 years ago or so, but it is no longer true. If this were true, 

then the current PTSQ would be much higher because the current sustained yield limit (SYL) is 

248 MMBF. Although the PTSQ will increase in future decades as young-growth stands become 

mature enough to harvest, it never exceeds half of the SYL. Therefore, it is not reasonable to 

assume that, just because the suitable timber base increases the harvest level will increase as 

well. The Forest Service is committed to the young-growth transition strategy developed for the 

2016 Forest Plan Amendment.

Comment 275: Commenters expressed concern and sought effects analysis that considered the potential 

increased quantity of roads and acreage impacted to harvest the same amount of timber from younggrowth, at 65 years of age, instead of waiting until the timber was at its maximum growth potential of 90–

100. Commenters also sought information about reforestation plans for projects that may occur following 

an exemption to the rule.

Response 275: The issues raised in this concern are Forest Plan issues and are beyond the 

scope of this EIS.

Comment 276: Commenters provided input about logging practices in Alaska and logging in roadless 

areas. Some said that logging either enhances, or does not harm, watershed ecosystems and others 

expressed support for a second growth timber management strategy and still others were concerned with 

the sustainability of current harvest practices. There was concern that logging in roadless areas would 

impact a greater area and cost more than areas with roads and that logging old-growth also requires 

building more roads than logging young-growth. There was support for logging and forest treatment 

practices that are sustainable and protective of ecosystems and communities.

Response 276: The proposed action does not adjust the PTSQ identified in the Forest Plan. 

Current harvest levels are well below the PTSQ and, although it is possible that actual harvest 

levels will increase as a result of opening up roadless areas by increasing options for economic 

sales, it is not anticipated that harvest levels will reach or exceed the PTSQ on average. 

However, analyses in this EIS, as well as in the 2016 Forest Plan EIS, assume that harvest levels 

do reach the PTSQ and remain there over the planning horizon (100 years).

Comment 277: Commenters sought a discussion in the EIS considering young-growth as a sustainable 

supply when compared to old-growth and a productivity comparison of young- and old-growth.

Response 277: This is a Forest Plan issue and is beyond the scope of this EIS.

Comment 278: Commenters were concerned about the cost and necessity of logging old-growth and 

intact forests when compared to the costs for other timber resources available for harvest that are more 

sustainable and cost efficient.

Response 278: This is a Forest Plan issue and is beyond the scope of this EIS.

Roadless and Wilderness

Comment 279: Commenters sought consideration for changing the roadless areas to Wilderness.

Response 279: A full evaluation of all roadless areas on the Tongass for Wilderness 

recommendations was conducted by the Forest Service in 2003. A range of alternatives with a 

range of recommendations was developed, but the no action alternative was selected. This was 

documented in: USDA Forest Service. 2003. Tongass Land Management Plan Revision. 

Roadless Area Evaluation for Wilderness Recommendations. Final SEIS. USDA Forest Service 

Alaska Region, R10-MB-481.

Comment 280: Commenters sought effects analysis for changes in roadless status of Tongass National 

Forest lands adjacent to National Park Service-managed wilderness and how they may affect wilderness 

qualities, viewshed, and visitor experience within the Glacier Bay National Park Wilderness.
Appendix H

Final EIS H-69 Response to Comments

Response 280: This concern is addressed in the FEIS under Key Issue 1 - Roadless Area 

Conservation.

Comment 281: Commenters expressed concern that the Forest Plan does not protect roadless area 

values in Development LUDs and that removing roadless area protections provided by the "not suitable 

for timber production" plan component would lead to degradation of unroaded area values.

Response 281: It is true that removal of roadless designations for development LUDs may result 

in timber harvest and road construction when the roadless designation is removed. Timber 

harvest is not expected to increase significantly overall, but the more roadless designations that 

are removed, the more roadless area degradation is likely.

Comment 282: Commenters were concerned that removing the Roadless Rule in Alaska could lead to 

the precedent of removing Roadless Rule protections in other areas which could lead to a precedent of 

excessive logging and road construction in forests across the United States.

Response 282: Currently only the State of Utah has a petition for a state-specific Roadless rule 

and the Secretary of Agriculture has yet to accept their petition. The State of Utah’s petition does 

not ask for a full exemption, rather it petitions for greater flexibility to respond to climate change, 

drought, disease, historic suppression of natural wildfires, insect infestations, and other 

challenges facing the state. If the Utah petition is accepted or other states petitions the Secretary 

for a state-specific Roadless rule, each rulemaking effort would consider the petition based on the 

merits of the request in context of issues, resource conditions, and economic conditions of each 

individual state. 

Out of Scope

Comment 283: Comment letters included introductory narrative and other information that was reviewed 

and noted with no further response required. 

Response 283: Examples of comments for which no further response will be provided are those 

unrelated to the decision being made, already decided by law, policy or regulation, beyond the 

scope of the proposal, conjectural in nature or not supported by scientific evidence, general in 

nature or position statements.

Comment 284: Commenters expressed general opposition for logging in the Tongass and Chugach 

National Forests. 

Response 284: This comment is beyond the scope of this EIS because this EIS is only analyzing 

prohibition of timber harvest and road construction within designated roadless areas.

Comment 285: An assessment of Alaska's potential energy production contribution on NFS lands should 

be considered in the Roadless Rule issues under analysis since the rule does not adequately address 

other forms of renewable energy outside of hydropower and wind.

Response 285: An assessment of Alaska's potential energy production contribution on NFS 

lands is outside of the scope of this analysis.
Appendix H

Response to Comments H-70 Final EIS

This page is intentionally left blank.