Petersburg Outfitter

and Guide

Management Plan

 Decision Notice and Finding 

of No Significant Impact 

United States 

Department of 

Agriculture 

Tongass 

National Forest 

R10-MB-711 

May 2010 
Crystal Mountain, Mitkof Island. Photograph by Marina Whitacre. 

Cover photo: View from Raven’s Ridge on Mitkof Island. Sukoi Islands in Frederick Sound with the Coast 

Range in the background. Photograph by Marina Whitacre. 
United States 

Department of 

Agriculture 

Forest 

Service 

Dear Planning Participant: 

Alaska Region 

Tongnss National Forest 

Petersburg Ranger District 

P.O. Box 1328 

Petersburg, AI( 99833-1328 

Phone: (907) 772-3871 

Fax: (907) 772-5995 

File Code: 19S0-1 

Date: May 27, 2010 

Enclosed is your copy of the Decision Notice and Finding of No Significant Impact (FONSI) for 

the Petersburg Outfitter and Guide Management Plan, Petersburg Ranger District, Tongass 

National Forest. As District Ranger, I am responsible for this decision. The Decision Notice 

explains my decision to select Alternative 2 and the factors considered in reaching this decision. 

The Petersburg Outfitter and Guide Management Plan Environmental Assessment (EA) was 

distributed for public co=ent on January 7, 2010. The second 3~-day co=ent period ended 

March IS, 2010. The District received co=ents from eight respondents. Excerpts from the 

co=ents, followed by my response, are provided in Appendix A of this document. 

Individuals or non-federal organizations who submitted written co=ents or otherwise 

expressed interest in this particular action during the co=ent period have standing to appeal 

this decision (36 CFR 21S.6). Appeals, including attachments, must be filed within 4S days 

following the date of publication of the legal notice of this decision in the Petersburg Pilot, the 

newspaper of record (36 CFR 21S.7). Ifno appeal is filed, implementation of my decision may 

occur on, but not before, the fifth business day following the close of the appeal-filing period (36 

CFR21S.IS). 

Copies of the EA, Decision Notice, and FONSI may be obtained from the Petersburg Ranger 

District office, located in Petersburg, Alaska, or by calling (907) 772-387l. The documents are 

also available online at 

http://www.fs.fed.us/r 1 O/tongass/proj ects/nepa proj ecL shtml?pro j ect=2 623 9. 

I want to thank those of you who took the time to review and submit co=ents during this 

project's development. Hearing views of the public and other agencies is vital to making an 

informed and reasonable decision. Your interest in the management of the Tongass National 

Forest helps make living in southeast Alaska better for everyone. 

Sincerely, 

C 

District Ranger 

Caring for the Land and Serving People Printed on Recyc!ed Paper .. "" , 
c:/workspace/outfitter/prd_covs/ros/prd_ros_maps/fig_1.mxd M.P. 5/26/09

Study Area Boundary

Water

Petersburg Ranger District

Study Areas

Figure 1

24

PETERSBURG CREEK/

DUNCAN SALT CHUCK

PRINCE

OF WALES ISLAND

KUIU

ISLAND

KUPREANOF

ISLAND

MITKOF

ISLAND

WRANGELL

TEBENKOF

BAY

WOEWODSKI

IS.

12A

8

9

12B

23

1

24

22

21

6

10

11

13

16

14

2

4

7

5

PETERSBURG

FREDERICK SOUND

SUMNER

STRAIT

15

ZAREMBO

ISLAND WRANGELL

IS.

SOUTHEAST ALASKA VICINITY MAP

PROJECT AREA SHOWN IN GRAY

Petersburg

Ketchikan

Juneau
Decision Notice 

and 

Finding of No Significant Impact 

for

Petersburg Outfitter and Guide Management Plan 

Environmental Assessment 

USDA Forest Service 

Petersburg Ranger District, Tongass National Forest 

Petersburg, Alaska 

This Decision Notice contains a brief summary of the environmental analysis completed for 

the Petersburg Outfitter and Guide Management Plan, as well as, my decision regarding 

which alternative to implement and the rationale for my decision. It also contains certain 

Findings required by various laws and information concerning the right to Administrative 

Review of this decision. The Environmental Assessment completed for this project is 

incorporated by reference in this decision document. 

This Decision Notice documents my decision concerning the Environmental Assessment 

(EA) for the Petersburg Outfitter and Guide Management Plan. The EA documents the 

analysis of two action alternatives that examine the potential impacts of outfitter and guide 

use on National Forest System (NFS) lands on the Petersburg Ranger District (Figure 1). The 

EA and a letter indicating a tentative selection of Alternative 2 were sent to interested people 

on January 7, 2010. 

Based on the EA completed for this project, as well as comments received during the two 30-

day public reviews of the document, it is my decision to select Alternative 2. The EA is 

available at the Petersburg Ranger District located in Petersburg, AK, and on the Forest 

Service website at: 

http://www.fs.fed.us/r10/tongass/projects/nepa_project.shtml?project=26239. 

Decision and Rationale 

It is my decision to allocate use to outfitters and guides based on Alternative 2 (the Selected 

Alternative) (Table 1). The Selected Alternative best meets the Purpose and Need identified 

in the EA and Forest Plan objectives and guidelines. Implementing the Selected Alternative 

will: 

 Respond to special use permit applications; 

 Allocate appropriate outfitter and guide use on the District while recognizing the 

special values within the Petersburg Creek-Duncan Salt Chuck, Tebenkof Bay and 

Kuiu Wilderness areas; 

 Manage outfitter and guide use on the District to minimize potential impacts to all 

resources. 

 

Petersburg Outfitter and Guide DN and FONSI 1
Table 1. Summary of actual use (existing condition) and proposed recreation visitor days (RVDs) 

available to outfitters and guides in Alternatives 1 and 2. Existing Condition numbers are the average 

RVDs reported from 2004-2008. RVDs available to outfitters and guides in Alternative 1 (Proposed 

Action) are proportioned out by season; 10 percent in the spring, 65 percent in the summer, 15 

percent in the fall and 10 percent in the winter. RVDs in Alternative 2 are proportioned out by season 

the same way as Alternative 1 except reduced allocations in the spring and fall in study areas 12A 

and 14; 7 percent in the spring, 73 percent in the summer, 10 percent in the fall and 10 percent in the 

winter. 

Study Area Comparison 

Recreation Visitor Days 

Spring 

(April 1 – 

May 31) 

Summer 

(June 1 – 

Aug 30) 

Fall 

(Sept 1 – 

Oct 31) 

Winter 

(Nov 1 – 

Mar 31) 

Total 

Annual1

1 Existing Condition 22 391 16 0 429 

Mitkof Island Proposed Action and 

Alternative 2 1,278 8,308 1,917 1,278 12,781 

2 Existing Condition 4 60 2 0 66 

Duncan Canal – West 

Side 

Proposed Action and 

Alternative 2 112 729 168 112 1,122 

4 Existing Condition 0 0 0 0 0 

Duncan Canal – East 

Side 

Proposed Action and 

Alternative 2 50 324 75 50 499 

5 Existing Condition 0 27 4 0 31 

Wrangell 

Narrows/Woewodski Is 

Proposed Action and 

Alternative 2 175 1,136 262 175 1,747 

6 Existing Condition 6 3492 8 0 363 

Kupreanof Island – 

North Shore 

Proposed Action and 

Alternative 2 45 291 67 45 448 

7 Existing Condition 35 179 14 0 228 

Petersburg Ck/Duncan 

Salt Chuck 

Proposed Action and 

Alternative 2 126 821 189 126 1,263 

8 Existing Condition 11 151 37 8 207 

North Lindenberg 

Peninsula 

Proposed Action and 

Alternative 2 137 892 206 137 1,373 

1

Totals may vary due to rounding. 

2

 This number is higher than proposed allocation; however, 90 percent of the use is from one outfitter and guide in one 

recreation place. The recreation place is a camp located on a hardened site and it does not experience many impacts. There is 

some bear hunting and other use in this study area, but conflict between users has not been reported. 

 

2 Petersburg Outfitter and Guide DN and FONSI
Study Area Comparison 

Recreation Visitor Days 

Spring 

(April 1 – 

May 31)

Summer 

(June 1 – 

Aug 30) 

Fall 

(Sept 1 – 

Oct 31) 

Winter 

(Nov 1 – 

Mar 31) 

Total 

Annual1

9 

Central Kupreanof 

Is/Road System 

Existing Condition 0 8 0 0 8 

Proposed Action and 

Alternative 2 353 2,293 529 353 3,528 

10 Existing Condition 17 365 2 0 384 

Southwest Kupreanof 

Island 

Proposed Action and 

Alternative 2 147 955 220 147 1,469 

11 Existing Condition 26 89 16 1 132 

Rowan Bay/Bay of 

Pillars 

Proposed Action and 

Alternative 2 96 627 145 96 964 

12A Existing Condition 90 308 94 2 494 

Saginaw/Security/Washi

ngton Bays 

Proposed Action 129 839 194 129 1,291 

Alternative 2 90 942 129 129 1,291 

12B Existing Condition 23 66 72 1 162 

Kuiu Island Road 

System 

Proposed Action and 

Alternative 2 213 1,381 319 213 2,125 

13 Existing Condition 54 363 7 2 426 

Tebenkof Bay/Kuiu 

Wilderness 

Proposed Action and 

Alternative 2 289 1,880 434 289 2,893 

14 Existing Condition 45 283 40 3 371 

Keku Strait/Port 

Camden 

Proposed Action 156 1,015 234 156 1,562 

Alternative 2 109 1,140 156 156 1,562 

15 Existing Condition 7 264 0 1 272 

South Kuiu Island Proposed Action and 

Alternative 2 126 816 188 126 1,255 

16 Existing Condition 6 136 1 0 143 

Reid/No Name Bays Proposed Action and 

Alternative 2 112 728 168 112 1,120 

21 Existing Condition 0 134 47 31 212 

Muddy River Area Proposed Action and 

Alternative 2 129 841 194 129 1,294 

1

Totals may vary due to rounding. 

Petersburg Outfitter and Guide DN and FONSI 3
Study Area Comparison 

Recreation Visitor Days

Spring 

(April 1 – 

May 31)

Summer 

(June 1 – 

Aug 30) 

Fall 

(Sept 1 – 

Oct 31) 

Winter 

(Nov 1 – 

Mar 31) 

Total 

Annual1

22 

Thomas Bay/Point 

Vandeput 

Existing Condition 13 239 13 17 282 

Proposed Action and 

Alternative 2 126 820 189 126 1,261 

23 Existing Condition 1 30 1 0 32 

Farragut Bay/Cape 

Fanshaw 

Proposed Action and 

Alternative 2 120 780 180 120 1,200 

24 Existing Condition 1 8 6 0 15 

Baird/Patterson 

Glaciers 

Proposed Action and 

Alternative 2 41 265 61 41 407 

1

Totals may vary due to rounding. 

Public Involvement 

The Petersburg Outfitter and Guide Management Plan EA has been listed quarterly on the 

Schedule of Proposed Activities (SOPA) since April 2008. At that time, it was proposed 

jointly with the Wrangell Ranger District portion of the 1997 Stikine Area Outfitter and 

Guide EA. On May 5, 2008, the Petersburg Ranger District hosted an open house at the 

District office. A second open house was held in Kake on July 8, 2008. Draft study area maps 

were posted for viewing at both locations. 

In June 2008, the Wrangell Ranger District (WRD) attended a Wrangell Cooperative 

Association meeting to consult with the tribe, and presented letters inviting consultation on 

the project. In July 2008, approximately 360 scoping letters were mailed requesting 

comments on the Proposed Action. Based on public comment, it was determined that each 

ranger district would complete separate environmental documents and decisions related to 

outfitter and guide use. 

An EA and letter indicating a tentative selection of Alternative 2 was sent to approximately 

100 interested people on January 7, 2010. On the same day, a News Release was sent to 

Alaska media outlets. The 30-day comment period on the EA began January 7, 2010, with 

the publication of the Notice of Availability in the Petersburg Pilot. Due to requests from the 

public for additional time to review, a second 30-day comment period was initiated on 

February 11, 2010, with a second Notice of Availability published in the Petersburg Pilot. 

The comment period ended on March 15, 2010. 

The Petersburg Ranger District (PRD) received 11 letters/emails/phone calls from eight 

respondents during the two 30-day comment periods. Excerpts from these communications, 

followed by responses from the PRD, are located in Appendix A of this Decision Notice. 

Comments included concerns about high actual use levels in Study Area 6, questions about 

how additional review of commercial use in an area is triggered and ROS class designations, 

4 Petersburg Outfitter and Guide DN and FONSI
concerns about jet boat use and its impacts on Petersburg Creek, and concerns from black 

bear hunting guides about the validity of recreation place locations and the number of 

recreation visitor days (RVDs) available to outfitters and guides. 

Issues 

Two key issues were addressed in the EA: provide stable business opportunities for the 

outfitter and guide industry, and address conflicts within the outfitter and guide industry. 

Alternatives Considered 

In making my decision, I also considered Alternative 1 (Proposed Action). A comparison of 

these alternatives can be found in the EA, pages 2-14 through 2-18 (Tables 2.3 and 2.4). 

Alternative 1 – Proposed Action 

In this alternative the District proposes to allocate outfitter and guides up to 10 percent of the 

capacity within an identified home range and 25 percent outside an identified home range. 

These allocations are proportioned out by season; 10 percent in the spring, 65 percent in the 

summer, 15 percent in the fall and 10 percent in the winter (Table 1). Allocation by season 

puts greater limitations on commercial use in the spring and fall, aims to reduce user conflicts 

by providing more opportunities for solitude and helps indirectly manage outfitter and guide 

recreation use by activity (i.e., spring and fall outfitter and guide use is mostly for guided 

black bear hunting). 

The proposal would authorize up to approximately 39,600 RVDs across the District for use 

by outfitters and guides (3,960 RVDs in the spring, 25,741 RVDs in the summer, 5,939 

RVDs in the fall and 3,960 RVDs in the winter). The use authorized may be temporary in 

nature (less than one year) or could be for multiple years. For those operators who have 

demonstrated satisfactory performance, the District Ranger may issue priority use permits, 

for a period of up to 10 years, in accordance with FSH 2709.11 (EA, Chapter 2, pp. 1-2). 

Alternative 2 – Increased Solitude 

This alternative provides a greater opportunity for recreation experiences with solitude in two 

study areas that have had reported user conflicts. In particular, it is designed to limit conflict 

among black bear hunting guides and between black bear hunting guides and fishing guides 

in the spring and fall. 

RVD allocation is the same as Alternative 1, except that Study Areas 12A 

(Saginaw/Security/Washington Bays) and 14 (Keku Strait/Port Camden) have a smaller 

percentage of use allocated to the spring (7 percent) and fall (10 percent) seasons (Table 1). 

As a result, outfitters and guides use is more restricted in these two study areas in the spring 

and fall (EA, Chapter 2, pp. 4-5). 

Findings Required by Other Laws and Regulations 

2008 Tongass Land and Resource Management Plan Amendment 

This decision to implement the Selected Alternative is consistent with the intent of the 2008 

Forest Plan Amendment's long-term goals and objectives. The project was designed in 

conformance with land and resource management plan standards and incorporates 

appropriate land and resource management plan guidelines. 

Petersburg Outfitter and Guide DN and FONSI 5
ANILCA Section 810, Subsistence Evaluation and Finding 

The effects of this project have been evaluated to determine potential effects on subsistence 

opportunities and resources. There is no documented or reported subsistence use that would 

be restricted as a result of this decision. For this reason, none of the alternatives would result 

in a significant possibility of a significant restriction of subsistence use of wildlife, fish, or 

other foods. This finding completes the Section 810 requirements, i.e., no public subsistence 

hearings are required (FSH 2090.23, Chapter 10). 

Coastal Zone Management Act of 1972 (as amended) and the Alaska Coastal Zone 

Management Program (ACMP) 

Under the Coastal Zone Management Act (CZMA) of 1972, activities conducted by the 

Forest Service that affect the coastal zone must be consistent, to the maximum extent 

practicable, with the enforceable policies of the Alaska Coastal Management Program 

(ACMP). In addition, activities affecting the coastal zone that are conducted by non-federal 

parties under a Forest Service permit must also be consistent with the ACMP. The types of 

Forest Service permits that the State of Alaska and the Forest Service have agreed are likely 

to affect the coastal zone—and therefore require ACMP consistency review of the permit 

applicant's proposal—are listed in section 302 of the Memorandum of Understanding (MOU) 

between the State and the Forest Service on CZMA/ACMP consistency reviews. The types of 

special use permits that will be authorized for issuance by this decision are not among those 

listed in the MOU as requiring ACMP review. 

Endangered Species Act of 1973 

Biological Evaluations have been completed for this action, which indicate that no federally 

listed threatened or endangered species will be affected by this activity. 

National Historic Preservation Act of 1966 

The Forest Service program for compliance with the National Historic Preservation Act 

(NHPA) includes locating, inventorying and evaluating the National Register of Historic 

Places eligibility of historic and archeological sites that may be directly or indirectly affected 

by scheduled activities. Regulations (36 CFR 800) implementing Section 106 of the NHPA 

require Federal agencies to consider the effects of their actions on sites that are determined 

eligible for inclusion in or are listed in the National Register of Historic Places (termed 

"historic properties"). The Alaska Region of the USDA Forest Service, the Alaska State 

Historic Preservation Officer, and the Advisory Council on Historic Preservation have 

established streamlined Section 106 review guidelines and stipulations in a Programmatic 

Agreement (USDA 2002). 

Outfitter and guide use is not expected to result in the discovery or disturbance of human 

remains. However, if human remains are discovered, they will fall under the inadvertent 

discovery provisions of the Native American Graves Protection and Repatriation Act 

(NAGPRA). 

Outfitter and guide use is also not expected to restrict Alaska Native access to traditional 

religious or spiritual sites that are protected under the American Indian Religious Freedom 

Act (AIRFA) and Forest Service standards and guidelines for the treatment of sacred sites 

(USDA 2008, p. 4-19). 

6 Petersburg Outfitter and Guide DN and FONSI
A Forest Service archeologist has reviewed this project and made a determination of No 

Historic Properties Affected in the area of potential effect for the proposed project. 

Obligations using modified procedures of the 36 CFR 800 review process, as defined in the 

Programmatic Agreement, have been met. 

Floodplain Management (Executive Order 11988) 

No outfitter and guide permits will be issued that allow permanent development in 

floodplains within the Petersburg Ranger District. It is expected that none of the outfitter and 

guide activities will affect velocity or location of flows or width and depth of water. 

Therefore, no measurable short or long-term effects for floodplains are anticipated under any 

alternative. 

Protection of Wetlands (Executive Order 11990) 

No outfitter or guide activities that result in long-term impacts (filling, dredging, etc.) to 

wetlands will be permitted under this document (USDA Forest Service Manual 2527.01-04). 

Recreational Fisheries (Executive Order 12962) 

Federal agencies are required, to the extent permitted by law and where practicable, and in 

cooperation with States and Tribes, to improve the quantity, function, sustainable 

productivity, and distribution of U.S. aquatic resources for increased recreational fishing 

opportunities. As required by this Order, I have evaluated the effects of this action on aquatic 

systems and recreational fisheries and documented those effects relative to the purpose of 

this order. Since there are no effects to fisheries resources within the project area, there will 

be no direct, indirect or cumulative impacts related to this Order. 

Environmental Justice/Civil Rights (Executive Order 12898) 

I have determined that in accordance with Executive Order 12898 this project does not have 

disproportionately high and adverse human health or environmental effects on minority 

populations and low-income populations. 

Magnuson-Stevens Fishery Conservation Act of 1996 

Essential Fish Habitat (EFH) is the water and substrate necessary for fish spawning, 

breeding, feeding, or growth to maturity. The marine EFH in Alaska includes estuarine and 

marine areas from tidally submerged habitat to the 200-mile exclusive economic zone (EEZ). 

The freshwater EFH includes streams, rivers, lakes, ponds, wetlands, and other bodies of 

water currently and historically accessible to salmon. EFH for Pacific salmon recognizes six 

critical life history stages: (1) spawning and incubation of eggs, (2) juvenile rearing, (3) 

winter and summer rearing during freshwater residency, (4) juvenile migration between 

freshwater and estuarine rearing habitats, (5) marine residency of immature and maturing 

adults, and (6) adult spawning migration. Habitat requirements within these periods can 

differ significantly and any modification of the habitat within these periods can adversely 

affect EFH. 

Section 305(b)(2) of the Magnuson-Stevens Fishery Conservation and Management Act 

states that all federal agencies must consult the National Marine Fisheries Service (NMFS) 

for actions or proposed actions that may adversely affect Essential Fish Habitat. The Act 

promotes the protection of EFH through review, assessment, and mitigation of activities that 

Petersburg Outfitter and Guide DN and FONSI 7
may adversely affect these habitats. On August 25, 2000, the Forest Service, Alaska Region, 

and NMFS came to an agreement on how consultation will be accomplished in Alaska. 

The Petersburg Outfitter and Guide Management Plan EA satisfies the consultation 

requirements. It provides a description and assessment of EFH in the project area, a 

description of the Petersburg Outfitter and Guide Management Plan and its potential impacts 

on these habitats, and a description of the mitigation measures that would be implemented to 

protect these habitats. 

The analysis area provides a large amount of EFH and includes all of the freshwaters on the 

Petersburg Ranger District. Since Marine Access Facilities would only have occasional use 

and solely for the purposes of road system access, there would be no anticipated effect to 

marine resources and therefore are not analyzed further as part of this assessment. 

This decision will authorize a variety of outfitted and guided activities around the Petersburg 

Ranger District. The Aquatic Resources section of the EA specifically examines the effects 

of outfitted and guided sport fishing, which is the primary activity that would affect EFH, on 

the aquatic resources around the District. 

The Forest Service believes that the Petersburg Outfitter and Guide Management Plan EA 

may adversely affect EFH. However, the effects, as described in the EA, will be minimal or 

virtually immeasurable. By implementing Forest Plan Standards and Guidelines, Best 

Management Practices, and Outfitter and Guide permit stipulations, effects to EFH should 

not occur. Additional impacts to EFH may occur only from unforeseen events. 

National Forest Management Act 

All project alternatives fully comply with the Forest Plan. This project incorporates all 

applicable Forest Plan Standards and Guidelines and management area prescriptions as they 

apply to the project area, and complies with Forest Plan goals and objectives. All required 

interagency review and coordination has been accomplished; new or revised measures 

resulting from this review have been incorporated. 

The Forest Plan complies with all resource integration and management requirements of 36 

CFR 219 (219.14 through 219.27). Application of Forest Plan direction for the Petersburg 

Outfitter and Guide Management Plan ensures compliance at the project level. 

Bald and Golden Eagle Protection Act 

This law provides for the protection of the bald eagle and the golden eagle by prohibiting, 

except under certain specified conditions, the taking, possession and commerce of such birds. 

Bald eagle habitat will be managed in accordance with the Interagency Agreement 

established with U.S. Fish and Wildlife Service to maintain habitat to support the long-term 

nesting, perching, and winter roosting habitat capability. 

Bald eagle nests are protected under agreement with the U.S. Fish and Wildlife Service. 

Currently, a 330-foot radius protective habitat management zone surrounds all identified bald 

eagle nest trees (USDI 2002) and a 1,000 foot beach buffer is maintained along the shoreline 

(USDA 2008, p. 3-239). Activities of outfitters and guides in all alternatives will be restricted 

away from nest trees through the permitting process. 

8 Petersburg Outfitter and Guide DN and FONSI
Federal Cave Resource Protection Act 

No known significant caves in the project area will be directly or indirectly affected by 

project activities. Forest Plan Karst and Caves Standards and Guidelines are applied to areas 

known or suspected to contain karst resources. 

Clean Water Act

This decision does not authorize any ground disturbance, or use of or discharge of potential 

pollutants. Implementation will not result in non-point or point sources of pollution; 

therefore, the project is fully compliant with the Clean Water Act. 

Clean Air Act 

Minimal emissions are anticipated from the implementation of either project alternative; 

therefore, the State of Alaska ambient air quality standards (18 AAC 50) will not be 

exceeded. 

Executive Order 11593 

Executive Order 11593 directs federal agencies to provide leadership in preserving, restoring 

and maintaining the historic and cultural environment of the Nation. The work accomplished 

in accordance with Section 106 of the National Historic Preservation Act for the Petersburg 

Outfitter and Guide Management Plan meets the intent of this Executive Order. 

Executive Order 12962 

With the application of Forest Plan Standards and Guidelines, including those for riparian 

areas, no significant adverse effects to freshwater or marine resources will occur. 

Effects on Prime Farm Land, Range Land, and Forest Land 

No prime farm land or range land exists in the project area. Forest land will maintain its 

productivity. 

Threatened, Endangered and Sensitive Species (TES) 

A biological evaluation was completed for TES plants. A biological evaluation/assessment 

was completed for TES vertebrates. Consultation with the U.S. Fish and Wildlife Service and 

National Marine Fisheries Service to review the effects of this project on threatened, 

endangered, and proposed species is not required. ESA does not require consultation for “no 

effect” determinations. Standards and guidelines have been applied as needed to ensure that 

any listed threatened or endangered species or its habitat will not be adversely affected. The 

Forest Plan contains standards and guidelines for each designated sensitive species, and these 

are incorporated into the project as applicable. 

Wild and Scenic Rivers Act 

No alternative will affect rivers eligible for Wild and Scenic River designation. 

Federal and State Permits, Licenses, and Certifications 

No permits, licenses, or certifications were required for this project. 

 

Petersburg Outfitter and Guide DN and FONSI 9
Finding of No Significant Impact 

I have reviewed the Environmental Assessment for this project using criteria identified in 

implementing regulations for the National Environmental Policy Act (40 CFR 1508.27). 

Based on the Environmental Assessment and the findings displayed above, I have determined 

that this is not a major action that will have a significant effect on the human environment 

and therefore does not require the preparation of an Environmental Impact Statement. I base 

my finding on the following: 

1) Impacts that may be both beneficial and adverse. A significant effect may exist even if the 

Federal agency believes that on balance the effect will be beneficial. 

Chapter 3 of the EA describes effects that are both beneficial and adverse. Regardless of the 

beneficial effects, no adverse effects were identified that would cross the threshold of NEPA 

significance or otherwise warrant the preparation of an EIS for this project. 

2) The degree to which the proposed action affects public health or safety. 

This action does not pose a substantial question of significant effect upon public health or 

safety. Similar past forest management activities (allocation of commercial and noncommercial use on the NFS lands for the project area) have not resulted in significant effects 

upon public health or safety. All applicable Federal and State laws pertaining to public health 

and safety would be followed. 

3) Unique characteristics of the geographic area such as proximity to historic or cultural 

resources, park lands, prime farmlands, wetlands, wild and scenic rivers, or ecologically 

critical areas. 

There are no known significant effects to historic or cultural resources, park lands, prime 

farmlands, wetlands, wild and scenic rivers, wilderness, or ecologically critical areas (EA, 

Chapter 3). 

4) The degree to which the effects on the quality of the human environment are likely to be 

highly controversial. 

The effects on the quality of the human environment are not likely to be highly controversial.

5) The degree to which the possible effects on the human environment are highly uncertain 

or involve unique or unknown risks. 

There are no known effects on the human environment that are highly uncertain or involve 

unique or unknown risks. The mitigations and other features of this decision are either 

commonly used and/or present known risks (EA, Chapter 2, pp. 5-11 and Table 2.2, pp. 7-8). 

6) The degree to which the action may establish a precedent for future actions with 

significant effects or represents a decision in principle about a future consideration. 

The proposed action does not set a precedent for any future actions with significant effects 

nor does it represent a decision in principle about a future consideration. This decision only 

pertains to potential impacts of outfitter and guide use on NFS lands for the Petersburg 

Ranger District. Proposals for development received through the application process for 

special uses are not addressed with this decision document. Development proposals, 

authorized under different Forest Service authorities, are beyond the scope of this analysis 

10 Petersburg Outfitter and Guide DN and FONSI
(EA, Chapter 1, p. 2). Any future decisions will need to consider relevant scientific and sitespecific information available at that time. 

7) Whether the action is related to other actions with individually insignificant but 

cumulatively significant impacts. Significance exists if it is reasonable to anticipate a 

cumulatively significant impact on the environment. Significance cannot be avoided by 

terming an action temporary or by breaking it down into small component parts. 

There are no known significant cumulative effects resulting from this project and other 

projects implemented or planned in the areas surrounding the project area. Cumulative 

effects were analyzed and disclosed in Chapter 3 of the EA. The project record contains the 

detailed analyses of individual resources supporting this judgment. 

8) The degree to which the action may adversely affect districts, sites, highways, structures, 

or objects listed in or eligible for listing in the National Register of Historic Places or may 

cause loss or destruction of significant scientific, cultural, or historical resources. 

This action would not cause the loss or destruction of significant scientific, cultural, or 

historical resources. There are no known cultural resource sites that would be affected by this 

project. We have determined that no known historic properties will be affected by project 

implementation (EA, Chapter 3, pp. 9-11). 

9) The degree to which the action may adversely affect an endangered or threatened species 

or its habitat that has been determined to be critical under the Endangered Species Act of 

1973. 

No threatened, endangered, or sensitive species or their critical habitats are affected by this 

decision. The project record contains the Biological Evaluations supporting this judgment 

(EA, Chapter 3, pp. 7-9 and 30-34; Appendix C). 

10) Whether the action threatens a violation of Federal, State, or local law or requirements 

imposed for the protection of the environment. 

This action does not violate Federal, State, or local law requirements imposed for the 

protection of the environment, and has been reviewed by Federal and State agencies (EA, 

Chapter 1, pp. 10-11). There are no known significant effects on civil rights, women or 

minorities (EA, Chapter 3, p. 38). 

Implementation Date 

This decision made by the Petersburg District Ranger is subject to appeal pursuant to 36 CFR 

Part 215. If no appeals are filed within the 45-day time period, implementation of the 

decision may begin on, but not before, the fifth business day following the close of the 

appeal-filing period (36 CFR 215.15). 

 

Petersburg Outfitter and Guide DN and FONSI 11
12 

Right to Appeal or Administrative Review 

This decision is subject to administrative review (appeal) pursuant to 36 CFR Part 215. 

Individuals or non-federal organizations who submitted written comments or otherwise 

expressed interest in this particular action dUring the comment period have standing to appeal 

this decision (36 CFR 215.6). The notice of appeal must be in writing, and meet the appeal 

content requirements at 36 CFR 215.14. The appeal must be filed (regular mail, fax, email, 

hand-delivery, or express delivery) with the Appeal Deciding Officer: 

Forrest Cole 

Forest Supervisor USDA Forest Service 

Tongass National Forest 

Federal Building 648 Mission Street 

Ketchlkan, AK 99901 

Fax: 907-228-6125 

The office business hours for those submitting hand-delivered appeals are: 8:00 am to 4:30 

pm Monday through Friday, excluding holidays. Electronic appeals must be submitted to 

appcals-alaska-tongass@fs.fed.us. In cases where no identifiable name is attached to an 

electronic message, a verification of identity will be required. A scanned signature is one way 

to provide verification. 

Appeals, including attachments, must be filed within 45 days from the publication date of the 

legal notice of this decision in the Petersburg Pilot, the newspaper of record. Attachments 

received after the 45-day appeal period will not be considered. The publication date in the 

Petersburg Pilot is the exclusive means for calculating the time to file an appeal. Those 

wishing to appeal this decision should not rely upon dates or timeframe information provided 

by any other source. 

For additional information, contact Christopher S. Savage, District Ranger, or Russell Beers, 

Special Use Administrator, at 907- 772-3871. 

Date 

District Ranger 

Petersburg Outfitter and Guide DN and FONSI 
References

USDA Forest Service. 2002. Second Amended Programmatic Agreement among the USDA 

Forest Service, Alaska Region, the Advisory Council on Historic Preservation, and 

the Alaska State Historic Preservation Officer regarding the Heritage Resource 

Management of National Forests in the State of Alaska. Agreement # 02MU-111001-

076. Manuscript on file, USDA Forest Service, Tongass National Forest, Petersburg 

Supervisor's Office, Petersburg, AK. 

USDA Forest Service. 2008. Tongass Land and Resource Management Plan. Tongass 

National Forest. R10-MB-603b. USDA Forest Service, Alaska Region, Juneau. 

USDI Fish and Wildlife Service. 2002. Memorandum of Understanding between the USDA 

Forest Service, Alaska Region and the USDI Fish and Wildlife Service, Alaska 

Region. 6 pp. 

Duncan Salt Chuck Creek, Kupreanof Island. Photograph by Heath Whitacre.

Petersburg Outfitter and Guide DN and FONSI 13
Forest Service road in the Kadake watershed on Kuiu Island. Photograph by 

Heath Whitacre.

14 Petersburg Outfitter and Guide DN and FONSI
Appendix A 

Petersburg Outfitter and Guide Management Plan EA 

Response to Comments 

The Petersburg Ranger District (PRD) received 11 letters/emails/phone calls from eight 

respondents during two 30-day comment periods for the Petersburg Outfitter and Guide 

Management Plan EA. Excerpts from these communications, followed by responses from the 

PRD, are below. Two of the responses we received (Kyle Smith, Alaska Department of 

Natural Resources and Susan Magee, State of Alaska) did not require a response. 

Complete records of all comments are located in the project record and are available upon 

request. 

Note: Unless a comment was submitted by phone, they appear as they were submitted in their 

respective letter or email. 

Alaska Professional Hunter’s Association 

Comments from email submitted on February 4, 2010 

APHA 1: On behalf of the Alaska Professional Hunters Association (APHA), we request that 

the comment period for the Petersburg Outfitter and Guide Management Plan Environmental 

Assessment be extended until March 8. 

Response: Petersburg Ranger District ran a second 30-day comment period that ended on 

March 15, 2010, to provide the public more time to comment. 

Joel Hanson (The Boat Company) 

Comments from phone conversation with Marina Whitacre, project team leader, on 

February 5, 2010 

JH 1: I am concerned that Study Area 6 is above capacity at this time. This is an area I would 

like to use. Why isn’t there an effort to reduce use in Study Area 6? 

Response: There has been a decline in use in Study Area 6, which is expected to continue. 

2006 was an exception when actual use exceeded suggested allocated use (Table 3.2, p. 3-19 

of the EA). Approximately 90 percent of the use in Study Area 6 is from one outfitter and 

guide in one recreation place. Use is concentrated at a campsite during the summer, and 

occupation is sporadic with low impacts since the camp is on a hardened site. Based on these 

factors, the amount of use hasn’t been a concern for the Ranger, who is open to allowing 

additional use in other recreation places within the study area. This scenario is a good 

example of how the Petersburg Outfitter and Guide Management Plan is simply a guide for 

determining allocated use. The Ranger ultimately has the responsibility of assessing each 

situation, with the EA as a guide, to determine whether or not more use is available. 

JH 2: In the EA on pages 1-5 to 1-6 under Decision Framework it is stated, “In order to 

maintain a quality recreation experience and a balance between guided and unguided use, 

the District Ranger will also decide what level of guided use will trigger additional review by 

Petersburg Outfitter and Guide DN and FONSI 15
study area.” What is the framework used by the Ranger to determine if additional review is 

needed? This is unclear. 

Response: If we are at capacity and receive a request for additional use there will be several 

factors to consider: 

1) At present, what type of use (guided and unguided) is in the area? 

2) What type of new use is being proposed? 

3) What is the conflict potential if a new outfitter/guide is allocated user days? 

4) If there are potential conflicts, are they anticipated to be between guided and 

unguided users, or between guided users? 

5) Do any of the District’s resource specialists have resource concerns regarding 

increased use in the area? 

The Ranger relies heavily on feedback from the current guided (or although more difficult to 

come by - unguided) users to get a sense of whether or not the area can handle more use. The 

Ranger also receives information from the District’s recreation crew who monitor use at 

recreation sites. 

It is important to note that our final capacity calculations are guidelines only. If it is decided 

that an area cannot handle more guided use, we will go to a prospectus where users compete 

for user days. 

JH 3: Along the shoreline of the Tebenkof Wilderness, the ROS class is Primitive. How can 

this be an accurate classification since there is a trolling fleet that anchors up at Table Bay? 

What are the factors that differentiate a Primitive and Semi-primitive ROS class? 

Response: Your point is well-taken. There is often a trolling fleet working in lower Chatham; 

however, the Forest Service does not have jurisdiction over the activities that take place 

offshore, even if they impact user-experience onshore. 

Relative to most of the Tongass, southwest Kuiu Island has very low levels of use or 

development on the uplands and low levels of motorized use offshore. This is true for the 

wilderness in Tebenkof Bay, as well in the non-wilderness at Table Bay. As directed in the 

Tongass National Forest Land and Resource Management Plan (p. 3-18), the standard for 

Recreation Use Administration is to emphasize wilderness and to manage for a Primitive 

Recreation Opportunity Spectrum (ROS) setting. The Primitive ROS helps to emphasize 

primitive recreation on a sustained basis and to protect the wilderness character. 

ROS classifications are determined by land-based management designations, specifically 

Land Use Designations (LUDs), where a defined area of land specific to a management 

direction is applied. The LUDs on the south end of Kuiu include Wilderness and Semiremote Recreation. There are also seven elements considered in the determination of 

recreation settings (scenic quality, access, remoteness, visitor management, on-site recreation 

development, social encounters and visitor impacts) (Forest Plan FEIS pp 3-368 to 3-369, 

Table 13.5-2) (see the next two pages). 

16 Petersburg Outfitter and Guide DN and FONSI
3 Environment and Effects

Recreation and Tourism 3-368 Final EIS

Table 3.15-2 

Comparison of ROS Classes

Urban (U) Rural (R) Roaded Modified (RM) Roaded Natural (RN)

Scenic 

Quality 

Alterations to landform 

and vegetation 

dominate landscape; 

nonrecreational 

activities not to exceed 

Low SIO - FG; Very 

Low SIO - MG. 

Alterations to landform 

and vegetation dominate 

landscape; 

nonrecreational activities 

not to exceed Low SIO - 

FG; Very Low SIO - MG. 

Alterations dominate 

the landscape; 

nonrecreational 

activities/structures 

evident, but do not 

exceed Very Low SIO. 

Alterations to 

landscape 

subordinate; 

nonrecreational 

activities not to 

exceed Low SIO 

though typically 

Moderate SIO. 

Access1 Access and travel 

facilities are highly 

intense, motorized, 

and often with mass 

transit supplements. 

All methods of access 

and travel may occur, but 

subject to formal 

regulation. 

All methods of access 

and travel when 

needed and compatible 

with intended activities. 

All methods of 

access and travel 

may occur when 

compatible with 

intended activities; 

zones of nonmotorized use. 

Remoteness Remoteness from sites 

and sounds of human 

activity not available or 

important. 

Remoteness from sites 

and sounds of human 

activity not available or 

important. 

Remoteness from 

continuous sounds of 

human activity is 

expected. 

Remoteness from 

continuous sounds 

of human activity is 

of moderate 

importance. 

Visitor 

Management 

Intensive on-site 

controls are numerous 

and obvious. 

On-site regimentation 

and control is obvious. 

On-site regimentation 

and controls are few. 

On-site 

regimentation and 

control is obvious. 

On-site 

Recreation 

Development 

Recreation structures 

and facilities readily 

evident, but 

appropriate for setting; 

designed for high use 

levels. Information 

and interpretive 

facilities may be large 

and complex. 

Recreation structures 

and facilities readily 

evident, but appropriate 

for setting, designed for 

high use levels. 

Information and 

interpretive facilities may 

be large and complex. 

Recreation structures 

and facilities may be 

present, but are 

provided primarily for 

protection of the 

resource rather than 

user convenience. 

Facilities are rustic and 

harmonize with a 

backcountry setting. 

Recreation 

structures and 

facilities provided 

for site protection 

and user 

convenience. 

Facilities are 

contemporary but of 

rustic design and 

harmonize with 

natural setting. 

Social 

Encounters 

High concentrations of 

people at one time. 

Moderate to high 

concentrations of people 

at one time. 

Moderate 

concentration of users 

on roads and little 

evidence of others or 

interactions at 

campsites. 

Interactions with 

others may be 

moderate to high. 

Moderate 

concentrations of 

people, especially 

on trails and in 

dispersed areas. 

Visitor 

Impacts 

Very noticeable, but 

managed to prevent 

physical resource 

degradation. 

Very noticeable, but 

managed to prevent 

physical resource 

degradation. 

Human use noticeable, 

but not degrading to 

resources. Site 

hardening dominates 

campsites, parking 

areas. 

Visitor use 

noticeable, but not 

degrading to 

resources; 

established SIOs. 

Petersburg Outfitter and Guide DN and FONSI 17
Environment and Effects 3 

Final EIS 3-369 Recreation and Tourism 

Table 3.15-2 (continued) 

Comparison of ROS Classes

Semi-Primitive Motorized 

(SPM) 

Semi-Primitive NonMotorized (SPNM) Primitive (P) 

Scenic Quality Alterations few and subordinate 

to landscape; designed and 

located to not exceed Moderate 

SIO. 

Alterations few and 

subordinate to 

landscape; 

nonrecreational activities 

and structures designed 

not to exceed High SIO. 

Alterations to landscape 

not evident; structures do 

not exceed High SIO. 

Access1 Travel on trails designed 

for/open to motor vehicles; 

roads maintained for high 

clearance vehicles; motorboats 

operating on waterways; may 

establish zones of non-motor 

use for facility/resource 

protection. 

Trails closed to 

motorized use; 

nonmotorized boats used 

on freshwater lakes and 

streams. 

Trails closed to motorized 

use; non-motorized boats 

used on freshwater lakes 

and streams. 

Remoteness Nearby sights and sounds of 

human activity are rare; distant 

sounds may occur. 

Nearby sounds of human 

activity are rare; distant 

sounds may occur. 

Sounds of human activity 

are very infrequent to 

nonexistent. 

Visitor 

Management 

On-site regimentation and 

controls are few. 

On-site regimentation 

and controls are rare. 

On-site regimentation and 

controls are very rare. 

On-site 

Recreation 

Development 

Recreation structures and 

facilities may be present, 

provided primarily for protection 

of site rather than user 

convenience. Facilities, when 

present, are rustic and 

harmonize with natural setting. 

Recreation structures 

and facilities may be 

present but provided 

primarily for protection of 

site. Facilities, when 

present, are rustic and 

harmonize with natural 

setting. 

Recreation structures are 

rarely present, provided 

primarily for the protection 

of the site. Facilities, 

when present, are rustic 

and harmonize with 

natural setting. 

Social 

Encounters 

Low interaction between users. 

Campsites seldom within sight 

or sound of another group 

except during peak periods. 

Low interaction between 

users. Campsites 

seldom within sight or 

sound of another group 

except during peak 

periods. 

Very low interaction 

between users and no 

other groups in sight or 

sound of overnight camps. 

Visitor Impacts Human use noticeable, but not 

degrading to resource or 

backcountry setting. 

Human use noticeable, 

but not degrading to 

resource elements. 

Human use essentially 

unnoticeable. Site 

hardening—boardwalks, 

boat moorings, food 

caches. 1 Subject to ANILCA provisions. 

Note: SIO = Scenic Integrity Objective, FG = Foreground, MG = Middleground 

Source: USDA Forest Service 1997a (Table 3-30). 

18 Petersburg Outfitter and Guide DN and FONSI
Mike Stainbrook 

Comments from phone conversation with Marina Whitacre, project team leader, on 

February 19, 2010 

MS 1: As a property owner along Petersburg Creek, I am concerned about the negative 

effects of jet boats on the Creek’s steelhead redds. I suggest Forest Service signage to inform 

jet boat users of its impacts on the Creek and to possibly restrict use during critical time 

periods for the redds. Maintaining good habitat in Petersburg Creek for steelhead is very 

important to me. 

Response: Most of the activity up Petersburg Creek is local, unguided use. The appropriate 

place for site specific restrictions on outfitter and guide use is within their special use 

permits. Since there is not a permitting process for unguided users, the District has no direct 

authority on their use. Also see responses MS 3 and MS 4. 

Comments from phone conversation with Marina Whitacre, project team leader, on 

February 22, 2010 

MS 2: Is there any way of knowing the number of people using Petersburg Creek? 

Response: District aquatics and recreation personnel are developing a proposal to monitor 

use on Petersburg Creek. The District is interested in quantifying use by watercraft (kayak, 

jet boat and outboard) and establishing a baseline for subsequent monitoring. 

Comments from email/letter submitted on February 28, 2010 

MS 3: I support the Petersburg Ranger District proposal to allocate no more than 10% of the 

capacity for outfitter guide usage. I also agree with the proposed mitigation for boat usage 

by outfitters and guides to not be permitted above the log jam (Chapter 2, page 8, Table 2.2). 

I also feel this should be extended to all users of motorized boats. 

Response: For the general public, passage beyond the log jam is discouraged. However, 

access shall not be facilitated by use of a chainsaw (chainsaw use is illegal in Wilderness). 

The District is interested in pursuing closure above the log jam to all jet boat users and has 

had conversations with the State and the Alaska Board of Fisheries in regards to jet boat 

impacts on fish habitat. Our intention is to continue these discussions. 

MS 4: The concerns of noise in the wilderness and impact of boat wakes on stream banks, 

from motorized boats, are also my concerns. 

Response: Noise from motorized boats is addressed in the EA in Chapter 2, p. 8. Outfitters 

and guides on Petersburg Creek are encouraged to minimize motorized boat use above the 

high tide trailhead and are not permitted above the log jam (1.8 miles upstream from the 

Wilderness boundary). 

A sound monitoring program is now being tested in the Misty Fiords National Monument 

Wilderness to help managers and the public understand current audio conditions there and 

how those conditions are changing over time. If this program proves to be successful and 

economical, it may be implemented on Petersburg Creek to establish a baseline. 

The District recognizes the need to quantify the effects of increasing jet boat use on 

Petersburg Creek. An additional element of the study mentioned in response MS 2 is to 

complete stream bank surveys to monitor and mitigate accelerated erosion. The District is 

Petersburg Outfitter and Guide DN and FONSI 19
also interested in monitoring steelhead habitat and turbidity in Petersburg Creek to better 

understand the impacts of current and increased use levels. 

MS 5: There are other concerns that additionally need to be addressed and mitigated and 

these include: 

1) Safety issues – between motor boats (especially jet boats) and kayakers and in 

stream fishermen. 

2) Turbidity issues as a result of jet boats in low water conditions on spawning fish 

and streambed spawning habitat. 

Response: Yes, safety of all users is a concern, but it is not an issue addressed at the 

programmatic document level. For outfitters and guides that use the Creek, general safety 

expectations are stated in the permit. PRD aquatics specialists are interested in collecting 

turbidity data in Petersburg Creek. Also see response MS 4. 

MS 6: I would strongly suggest including language for non-paid guide usage on weekends 

and Federal and State Holidays in recognition of the increased use by Petersburg Residents 

at these times. 

Response: There are weekend and holiday closures on guided fishing at three popular 

recreation areas on the District – Kah Sheets, Kadake and Castle creeks. Guided use up 

Petersburg Creek is currently so low that a weekend and holiday closure would not create a 

noticeable decrease on the amount of use during these times. 

MS 7: Systematic, across time, scientific data needs to be collected on recreational use of the 

creek (both guided and non-guided). It is important to establish valid figures of how the 

creek is used.

Response: See response MS 2. 

MS 8: There seems to be an increased number of trips in this area that may well increase 

both because of demand from the lower 48 and the economy of Southeast Alaska moving 

people into guiding. It is important to monitor guiding activity annually and have the ability 

to make timely adjustments to adequately protect the land resources and the recreational 

experience for all users. 

Response: The monitoring mentioned in responses MS 2 and MS 4 will help the District 

understand the trend of use and its impacts on Petersburg Creek. Additional information is 

collected annually from outfitters and guides who are required to report their client numbers, 

dates of use, activities, locations used and time spent on the National Forest. From these use 

reports, authorized use levels can be adjusted from year to year, if necessary. At a broader 

level, the Carrying Capacity Report and Outfitter and Guide Management Plan are updated 

periodically to account for the growth of the outfitter and guide industry and policy changes 

in the Agency. To read more about the history of the project see Chapter 1, pp. 2-4 of the EA. 

 

20 Petersburg Outfitter and Guide DN and FONSI
Brad Dennison (Alaska Coastal Outfitters) 

Comments from phone conversation with Marina Whitacre, project team leader, on 

January 28, 2010 

BD 1: I expected the scoping comments to be published and responded to in the EA. 

Response: The scoping comments were discussed and addressed in a team meeting, but it 

was never intended for them to be published. Comments on an EA are sometimes published 

in the DN/FONSI, but it is not required by Forest Service or Council on Environmental 

regulations. It is a decision left up to the Ranger. All comments received during the life of the 

project are filed in the project record and are available upon request. 

BD 2: I, along with other hunters I’ve talked to, still feel the methodology is “all wrong”. 

Response: The District recognizes that there is no one method of calculating recreation use 

capacity that can capture and address everything. It is, however, a process that is amenable to 

updating and improving, which has been done twice since its inception. For instance, in the 

latest revision of the recreation capacity report, the District revised the study area boundaries 

to group similar recreation uses within a study area. Another change has been to examine use 

seasonally rather than annually. Both changes help us better manage use in time with more 

specificity – namely in study areas 12A and 14 during the fall and spring seasons. Reported 

recreation visitor days (RVDs) associated with day use by all boat-based hunting operations 

was also revised to account for the sensitivity of these users to encounters with others. To 

address this, a multiplier of three was factored into the all reported boat-based day-use 

hunting that occurred on NFS lands to artificially increase actual use and lessen the gap 

between actual and allocated use. The result is significantly less additional use available 

during the spring and fall in these areas. The multiplier is reflected in the 5-year (2004-2008) 

actual use RVD average. 

BD 3: I am concerned because the allowable total RVDs by season are still between 10 and 

20 times that of Actual Use (existing condition). 

Response: Yes, this is true when looking at RVDs available District-wide; however, for study 

areas 12A and 14 (Table 2.3 on p. 2-16 of the EA) where guide use and tensions are highest, 

available use in spring and fall are very close to actual use. In 12A spring use is at 100 

percent of capacity, and fall use is at 73 percent. In Study Area 14 available spring use is at 

41 percent of capacity and fall use is at 26 percent. These reduced capacities, coupled with a 

cap on guided black bear hunts on the PRD (see March 24, 2008 letter from the Tongass 

Forest Supervisor), do not allow for an increase in guided bear hunts in these areas, 

regardless of remaining available use. Estimated available use is only intended to be a 

guideline. See response to BD 5. 

BD 4: I found the following paragraph confusing because it moves back and forth when 

talking about Kuiu and PRD. I am also not aware of any ongoing discussions between the FS 

and ADF&G regarding the number of black bear hunts. The terminology for quantifying use 

is confusing – this paragraph is talking about number of hunts and the EA talks about RVDs. 

What is the number that “this number” in the second to last paragraph referring to? 

Currently on the Petersburg Ranger District, commercially guided black 

bear hunts are capped at 188 hunts. The total number of black bear hunts 

that take place on Kuiu Island (commercial and non-commercial) is an 

Petersburg Outfitter and Guide DN and FONSI 21
ongoing discussion between the Forest Service and the State Department 

of Fish and Game. For the foreseeable future, this number of commercial 

hunts authorized on Kuiu will not increase. If the demand in hunter use 

continues to rise, a prospectus will be used to allocate future hunts. 

Response: The Petersburg District Ranger and Rich Lowell at ADF&G communicate 

regularly regarding the number of black bear hunts on the District. Both agencies are 

concerned about black bear numbers and have been working cooperatively to manage the 

resource responsibly. Regarding the second to last sentence in the paragraph above, we 

apologize for the error. It should read, “For the foreseeable future, this number of 

commercial hunts authorized on the Petersburg Ranger District will not increase.” 

BD 5: I am concerned about use that’s still available and how if more permits are 

administered, it will negatively affect the current commercial hunting guides. How can the 

Ranger make a decision to not administer more permits if there are RVDs available – could 

the FS get sued by an outfitter and guide and then be required to administer a permit? I am 

worried that if this were to happen my business would be negatively affected. 

Response: This Outfitter and Guide Management Plan EA is a programmatic document that 

provides sideboards on managing outfitter and guide use on the District. The Ranger has the 

flexibility to work within these sideboards. If an area is showing signs of too much use, or if 

there are reported conflicts either between guides or between guided and unguided users, the 

Ranger is responsible for making area-specific management changes or mitigations that 

address the concern. These changes may include a cap on use regardless of the availability of 

RVDs as determined by the carrying capacity report and selected alternative. 

Comments from email/letter submitted on March 8, 2010 

BD 6: The first thing I would like to comment on is that it would be extremely helpful if 

public input to the development of this plan was more thoroughly discussed in the plan. One 

[sic] both occasions when public input to the Petersburg Carrying Capacity Report was 

solicited I went to the effort to provide comments which I felt were important to the 

development of a meaningful analysis. I can find no mention of the issues I raised in either 

letter in the EA, other than the general observation that guides think there are user conflicts. 

The specific concern that I expressed both times about improper methodology, which is my 

primary concern, is not discussed anywhere in the EA. If my math is correct, based upon the 

short section in the EA having to do with the January 2009 scoping letter solicitation on page 

9 of chapter 1, there were only 2 letters received from existing permit holders actively 

engaged on the PRD, mine and one other. It seems to me that it would not take an 

unreasonable amount of effort to discuss those 2 letters and respond to those concerns. 

Response: To clarify, the Petersburg Carrying Capacity Report did not go out for public 

review until it was published as an Appendix in the EA (Appendix A). It is an internal 

document used to develop alternatives 1 and 2 presented in the EA. You did, however, 

submit comments to two scoping letters regarding the project and the development of the 

carrying capacity report. In Chapter 1, on page 8 of the EA, there are 10 bulleted statements 

listing the comments received on the July 2008 scoping letter. In addition to mentioning 

conflict between users, suggestions from respondents include authorizing different permitted 

uses at different times, assigning priority hunts, and going to prospectus. The concerns and 

feedback received resulted in conversations with some of the commercial bear hunting 

22 Petersburg Outfitter and Guide DN and FONSI
operators during the development of this EA. It also resulted in three changes that included a 

revised proposed action. At this point it was decided to analyze Petersburg and Wrangell 

Ranger Districts separately since the July 2008 scoping response demonstrated different 

issues on each District that require different alternatives. For PRD the proposed action was 

revised to manage outfitter and guide use on a seasonal rather than annual basis. PRD also 

revised the reported RVDs associated with day use hunting operations as described in 

response to BD 2. 

BD 7: Along that line I would like to request that in the final EA you list the concerns of each 

respondent to the current comment solicitation and that you address these concerns in the 

final EA on a point by point basis. 

Response: Comments received regarding the EA were discussed by project team members 

and the Ranger. Responses have been compiled here in Appendix A of the Petersburg 

Outfitter and Guide Management Plan Decision Notice and FONSI. 

BD 8: In many places in the EA you have noted that you have addressed the concern of user 

conflicts by shifting some of the spring and fall use to the summer season and by allowing 

some additional visitor day credit for guided hunts. While it is true that you have made those 

allowances, the implication that you have addressed our concerns in any significant way is 

entirely misleading. A careful look at your carrying capacity numbers will confirm that. 

Response: See response to BD 2. We regret that you think Forest Service efforts are 

misleading. 

BD 9: In the final EA I would very much like to see a careful explanation of the thought 

process you have used to conclude that slight changes to the spring and fall visitor day 

balance have adequately addressed the user conflict issue despite a 1,000% increase to the 

spring commercial pool and a 2,000% increase to the fall commercial pool (ref: Chapter 2, 

page 18). The notion that the EA effectively addresses the social overcrowding issue during 

the spring and fall seasons is, for lack of a better word, absurd when considering the 

numbers in the table. 

Response: See response to BD 2. The premise of calculating proposed RVDs by season was 

to reduce conflict between guided bear hunts in study areas 12A and 14 in the spring and fall. 

A concerted effort was not made to bring actual commercial use closer to allocated 

commercial use in the other study areas since the need was not there. 

BD 10: Shown as green circles are those areas that can be utilized in the fall by commercial 

operators (see Figure 2). These are stream corridors that have populations of spawning 

salmon. The only commercial users in the fall are either bear hunting guides (the vast 

majority of use) or charter guides (a smaller commercial group, many of which are not 

properly licensed and permitted). Both groups utilize only those streams with reasonable 

numbers of spawning salmon. Many of the streams in Study Area 14 are devoid of 

salmon....At most, the usable area available to commercial guides each fall is 636 + 327 

acres, or 963 acres. Because of the width of the stream corridor that I used this is probably 

about twice the actual area that can be effectively utilized. Even using the wider corridor, the 

actual usable area is only 9.6% of the area assumed in the model. An error of that size can 

not [sic] be “tweaked” into reality by making slight adjustments. 

Petersburg Outfitter and Guide DN and FONSI 23
Figure 2. Map provided by Brad Dennison in his March 8, 2010, comment letter on the Petersburg 

Outfitter and Guide Management Plan EA. 

24 Petersburg Outfitter and Guide DN and FONSI
Response: We appreciate the time you put into comparing the District’s designated recreation 

places with those areas used by fall commercial operators. You have provided use locations 

of which we were not previously aware. We would like to reiterate that the recreation places 

designated by the District also consider non-commercial users, as well as commercial users 

other than bear hunting and fishing services. We feel that we have minimized the amount of 

“excess use” available in the fall and spring in study areas 12A and 14 by allocating use by 

season. 

During the current analysis we have taken time to review recreation places and their 

boundaries; they are not static. In our latest analysis recreation place boundaries changed due 

to land status changes, a re-evaluation of recreation attractors, new information and the most 

recent use data. As a result there are 70,976 fewer recreation place acres today than in 2004. 

Also see responses to BD 2, BD 3, DA 1, and DA 2. 

Scott McLeod, Alaska Ravenguides 

Comments from email submitted on February 4, 2010 

SM 1: After reading the draft on environmental assessment for the setting of carrying 

capacities on the Petersburg Ranger District, it was alarming that it indicated roughly 10 

times the carrying capacity for future allocations. There is a cap for nonresident hunters set 

by the fish & game at 120 Bears. There are 10 guides working on Kuiu. Scott McLeod, James 

Boyce, Bruce Parker, Eric Swanson, Brad Dennison, Dale Adams, Eli Lucas, Chuck Wagner, 

Jim Rosenbrook & Alisha Rosenbrook . This makes Kuiu FULLY ALLOCATED. This does 

not include nonguided transporters as we do not know how many there are. This adds to the 

impact on the resource. We are at capacity. I believe the bears are stressed to the maximum. 

Added stress would only compound the problem. Please consider GMU4 Shoreline EIS & 

carry this over to Petersburg Ranger District. As a guide with a [sic] unsure future on Kuiu, 

instead of adding hunts, Decrease the # of hunts. Less Encounters & greater outdoor 

experience [sic]. 

Response: The District agrees that Kuiu is fully allocated for guided black bear hunters. See 

response to BD 3. The District has very little data on unguided transporter use since they are 

not required to report use to the agency. We agree that they have an influence on recreational 

use for guided and unguided users. 

Dale Adams, Master Guide 

Comments from email/letter submitted on March 10, 2010 

DA 1: Whoever came up with the selection of the recreation places did not keep in mind 

there is a major difference between places that can be used by recreational kayakers for 

example, versus places that provide opportunities for Outfitter/Guides to conduct a viable 

business that can support a family and contribute to the local economy of Southeast Alaska. 

As examples, let’s look at a couple of recreational places in study area 14, a guide use area 

where I am very familiar. Place no. 21060- Horseshoe Island, 21061- Entrance Island, 

21122- North Rocky Pass. This area, one that was used to determine the amount of 

commercial use has very little commercial use value to offer to the public. There are no 

Petersburg Outfitter and Guide DN and FONSI 25
lakes, no fish, no streams, no waterfalls, no tideflats, not even bears in the spring let alone in 

the fall when the bears are up the creek eating fish. Nothing special other than maybe a camp 

spot of which very little is done as 95% of guided trips of any kind take place aboard 

liveaboard boats. 

Response: You are correct, some recreation places1 do not correlate with guided black bear 

hunting; however, in this analysis the District is considering all commercial and noncommercial recreational activities. Some of the areas you mention have been used for 

camping by unguided recreation users. PRD’s use records show outfitter/guide day use at 

Horseshoe Island. 

It is important to note that recreation places are not solely used to determine the District’s 

recreation use carrying capacity, since they are also used for other planning efforts. They are 

reviewed by recreation specialists during project planning to analyze a project’s potential 

effects on recreation. 

Recreation places on PRD were identified by recreation resource specialists using their local 

knowledge to determine probable use areas and from field surveys that revealed areas used 

for recreation. Actual use reports submitted by outfitters and guides also provide the District 

information about places that get used for recreation activities. 

In order to provide a better opportunity to capture input on recreation places in the future, we 

will consider including the most recent existing conditions cards and maps (see Appendix A, 

Part II of the EA) with our project scoping letter. 

DA 2: Recreation place 21074- Port Camden Anchorage. What does this spot have to offer 

than a place to camp of which little to none is done spring or fall? Remember, 2 out of 3 

seasons, spring and fall are primarily and historically used for guided hunters which 

primarily use boats as the base of operations for the nonresident paying client. 

Response: You make a valid point. This recreation place was put in the database in the late 

1980s and no longer appears valid. The place will be deleted from the database. It will not 

affect this document, but it will affect future planning projects. 

 

 

1

 Recreation places are areas determined to be important for recreation use. They include a recreation attractor, 

such as a trail, a lake, a dispersed campsite, a fish stream, a cave, unique geology, a beach or an anchorage. 

26 Petersburg Outfitter and Guide DN and FONSI
Full moon over logging transport facility at Kake Portage, Alaska. Kake is located on the northwest 

side of Kupreanof Island. Photograph by Heath Whitacre. 

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