United States Department of Agriculture 

Commercial Harvest 

of Spruce Tips 

Environmental Assessment

Forest Service 

Alaska Region 

 Tongass National Forest 

 Sitka RangerDistrict R10-MB-790 April 2015 
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COVER: PICTURE OF BARANOF ISLAND FROM TOTEM PARK TRAIL. 
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Spruce Tips - Special Forest Products Environmental Assessment 

Need for the Proposal

A request for the commercial harvest of spruce tips from National Forest System Lands (NFS) has been 

received by the Sitka Ranger District. Since this request is proposed for public lands, the Tongass 

National Forest will need to authorize and permit this activity. The USDA Forest Service is authorized to 

permit the commercial harvest of special forest products per 36 CFR 223.1. 

Location 

Commercial spruce tip harvesting activities would be allowed across the Sitka Ranger District on lands 

not otherwise closed to commercial special forest product harvesting. It is expected that most harvest will 

occur in young-growth timber stands accessible by roads. 

Description of Alternatives 

Two alternatives were considered for this analysis: 

No Action: 

The No Action alternative would not allow the commercial harvest of spruce tips on NFS lands on the 

Sitka Ranger District. 

Proposed Action: 

The Proposed Action would: 

 Authorize the commercial harvest of 2,000 pounds of spruce tips from NFS lands, with the potential 

to incrementally increase harvest limits upon annual review, not exceeding 10,000 pounds across the 

Sitka Ranger District. 

 Allow the Forest Service to offer, at its discretion, preferred harvest areas that would not exceed 5 

contiguous acres. Preferred harvest areas would not be available for commercial harvest more than 

once every three years. 

 Require an annual review of effects on subsistence and personal use. 

The Proposed Action would allow commercial entities to apply for a Special Forest Products Permit to 

harvest spruce tips from NFS lands. Permits would authorize the harvest of spruce tips under special 

provisions of the Forest Service. The allowed annual harvest would depend on previous year’s harvest 

and compliance with the permit provisions. 

It was determined that the permit provisions listed below are conservative enough to prevent a negative 

effect to subsistence harvesting through limiting abundance or increasing competition for spruce tips. 

Less than one-sixth of any given tree of at least 10 feet in height would be harvested from for commercial 

purposes. The provisions also ensure that harvest won’t affect tree growth or survival. In order to collect 

more tips, the permit holder will need to harvest from a broader area, thus maintaining the minimal 

impact ensured by the permit provisions. An initial harvest limit of 2,000 pounds would be in effect until 

it could be shown that there was no effect on subsistence availability or tree survival, and opportunities 

would be provided to include the Sitka Tribe of Alaska on any post-harvest monitoring activities. The 

maximum allowable commercial harvest of spruce tips would initially be set at 10,000 pounds district 

wide. The cap was chosen based on the ability of the Forest Service to monitor harvesting activity across 

the district. 

Permit holders would be allowed to authorize individuals or groups to harvest for each permit holder. 

Permit holders would be required to provide harvesters with written authorization and a copy of the 

permit that contains special harvesting provisions, and a list of locations where commercial harvesting is 

not allowed. The Forest Service would provide maps of the Sitka Ranger District and the greater Sitka 
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Spruce Tips - Special Forest Products Environmental Assessment 

vicinity that show where commercial harvest is not allowed. Provisions of the permit will require that 

each authorized harvester document where harvest occurs and how much is harvested. Permits will be 

collected by the Forest Service from the permit holder at the conclusion of the harvest season for review 

and monitoring (see Monitoring section below). Harvest provisions of the permit include: 

 Permit holders or anyone authorized by the permit holder to harvest spruce tips must have a copy of 

the permit in their possession at all times when harvesting. 

 Harvest is allowed between April 1 and June 30. 

 Only trees 10 feet in height or greater may be harvested from. 

 Only the lower 1/3 of the tree’s branches may be collected from. 

 Only half of the limbs within that lower 1/3 may be collected from. 

 Only harvesting by hand or with hand operated tools is allowed. 

 Groups shall be limited to 20 individuals during harvest activities. 

 Harvest permits must be returned to the permit holder by June 30. 

 Harvest is not allowed within 1⁄4 mile of the Harbor Mountain road in Sitka on National Forest System 

lands. 

 Harvest activities shall not take place within 500 feet of Forest Service recreation rental cabins to 

maintain privacy for cabin renters. 

 Forest Service mooring buoys are not available to individuals harvesting spruce tips or who are 

engaged in other commercial activities. 

 Motorized travel is restricted to open roads and OHV designated trails as shown on the Sitka Ranger 

District Motor Vehicle Use Map (MVUM). 

Land Use Designation (LUDs) areas closed to commercial harvest under this permit would include: 

 Wilderness Areas such as the South Baranof Wilderness Area and West Chichagof-Yakobi 

Wilderness Area 

 Wild River corridors including the Glacial River that flows into South Arm Kelp Bay on northeast 

Baranof Island, and Kadashan River that flows into Tenakee Inlet 

 Special Interest Areas such as the Mount Edgecombe Geologic Area on Kruzof Island and the Clear 

River watershed on northeast Baranof Island 

 Research Natural Areas such as the Kadashan Research Natural Area 

 Developed Recreation Areas, such as the Starrigavin and Harbor Mountain Recreation Areas, the 

Sawmill Creek Campground, and the Sandy Beach recreation area on Halibut Point Road in Sitka. 

Commercial spruce tip harvest may be allowed in these areas only if it is as a by-product of a planned 

development or vegetation management project. 

Spruce tips must be transported to motorized vehicles by hand, and motorized vehicles used to transport 

spruce tips are only allowed on drivable roads or trails according to current motor vehicle use restrictions. 

Mechanized harvesting or any ground disturbing harvesting technique is not allowed. Roads, trails, and 

ditches must remain free of debris resulting from harvest activities. 

Analysis of the Alternatives 

The environmental effects of the No Action and Proposed Action are described below. The discussion 

focuses on resources most likely to be affected by the alternatives either from access to harvest area, 

additional uses in harvest areas (such as effects on recreation uses), transport of harvested spruce tips, or 

the harvest of spruce tips itself. 

Specialists have analyzed the effects of not allowing commercial harvest (Alternative 1), as well as the 

commercial harvest of spruce tips following permit provisions (Alternative 2). The full analysis for each 

resource, including methods, assumptions and literature, are available as separate reports in the project 

record. Records from this file are available to the public (excepting specific exemptions to protect 
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Spruce Tips - Special Forest Products Environmental Assessment 

sensitive, private, or confidential records under the Federal Freedom of Information Act) upon request at 

the Sitka Ranger District. 

Resources for which the effects of the proposed action were determined to not have an effect and do not 

require additional mitigations or permit conditions include: fisheries, hydrology, soils, wetlands, and 

floodplains, and special uses/lands. 

Archaeology 

No Action – The No Action alternative would not result in any direct, indirect or cumulative effects to 

significant archaeological resources. 

Proposed Action – The proposed action would not result in any potential to cause effects on Historic 

Properties (significant archaeological sites), or have any direct, indirect or cumulative effects to 

significant archaeological resources. Under the implementing regulations for section 106 of the National 

Historic Preservation Act, the agency has no further obligations. 

Vegetation/Timber 

No Action – The No Action Alternative would not result in any effects to the vegetation/timber 

resources because no management activities would take place. 

Proposed Action – The Proposed Action would not result in effects that would damage individual trees 

or stands or otherwise affect a tree’s ability to survive and continue to grow. Effects would be minimized 

by requiring harvesters to follow specific harvest provisions regarding tree selection and harvest 

described in the permit conditions above. 

The direct effect could include slightly reduced growth during the remainder of the current growing 

season on trees that had some tips removed. Commercial harvesting is not expected to have any 

noticeable effects on stand structure and species composition because at least 5/6ths of the tips on any 

given tree will remain after commercial harvesting. 

The indirect effects may include a slight increase in susceptibility to disease and pests due to the creation 

of points of entry during the removal of the tips. This effect is negligible due to the minimal total number 

of trees that will be impacted across the landscape and the low likelihood of actual infection. Studies of 

the effects of removing only spruce tips from branches do not seem to exist. In the absence of directly 

related research, a paper studying the effects of pruning branches from Sitka spruce trees was considered. 

The study found that pruning, a more extreme harvesting technique than tip removal, resulted in the 

generation of additional small branches (epicormic shoots) and was not detrimental to overall tree growth. 

(Deal et al 2003). 

The minimal direct and indirect effects combined with the harvest only once every three years in Forest 

Service designated areas restriction will lead to negligible cumulative impacts on the environment. These 

effects will not result in any degradation of the forest stands where designated collection takes place. 

Botany 

No Action – The No Action alternative would not result in any direct, indirect or cumulative effects to 

Sensitive plant species. 

Proposed Action – The Proposed Action would not result in any direct, indirect or cumulative effects 

to Sensitive plant species. 

Wildlife 

No Action – The No Action Alternative would not result in any effects to wildlife habitat resources 

because no management activities would take place. 

Proposed Action –The Proposed Action could result in a short term direct effect during collection 

periods, in the form of avoidance behavior, by a few individuals within wildlife populations found in the 
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Spruce Tips - Special Forest Products Environmental Assessment 

collection areas. However, collection events will be short-term in duration (a few hours to a day) and 

therefore this direct effect will be negligible. The methods prescribed for collecting spruce tips will 

maintain the health of the stands and therefore there will be no effects to wildlife or their habitat of 

Management Indicator Species (MIS) or Threatened or Endangered Species (TES). 

There will be no negative indirect or cumulative effect from this project. 

Recreation 

No Action – The No Action Alternative would not affect the recreation resource. Existing levels and 

uses would continue. 

Proposed Action – The Proposed Action may result in brief interactions between commercial 

harvesters and dispersed recreation users. These interactions are not expected to result in prolonged 

recreational user dissatisfaction due to the nature of the harvest activities and the fact that collection 

events will be short-term in duration (a few hours to a day in any given locale) and limited to 

approximately one month per year. 

Subsistence 

No Action - The No Action Alternative would not affect subsistence resources. Existing abundance and 

distribution, as well as access and competition for subsistence resources would continue at current levels. 

Proposed Action - The Proposed Action will have negligible effects on the abundance of spruce tips 

available for subsistence uses, as well as negligible changes to competition for spruce tips. There would 

be no effect on the distribution of spruce tips, or access to spruce tips or other subsistence resources. 

Spruce tips are considered an important subsistence resource for medicinal or consumptive purposes 

(Kayaani Commission, 2006) and the Forest Service recognizes that abundance, distribution, access, and 

competition must be provided for before personal and commercial uses are allowed. The conditions that 

would be set forth in any harvest permit described above, and the adaptive management strategy outlined 

in the monitoring plan, are designed to ensure that the abundance and distribution of spruce tips, and 

competition for spruce tips, does not change significantly. 

The Proposed Action will have negligible direct effects on the abundance and competition for spruce tips. 

Commercial harvest would only be allowed to remove spruce tips from half of the lowest third from any 

single tree over 10 feet in height or greater. Therefore, while abundance would be decreased slightly in 

certain areas, and competition could increase slightly in those areas, spruce tips should remain abundant 

for subsistence purposes and neither abundance nor competition would change significantly. 

The Proposed Action will also not have any indirect effects on the abundance and distribution of, access 

to, or competition for spruce tips. Harvesting spruce tips has not been shown to affect spruce tree viability 

or growth (see Timber and Vegetation Resource Report) and will remain abundant and widely distributed 

for the foreseeable future. Access will not be changed as a result of the Proposed Action. Commercially 

harvesting spruce tips will also not indirectly affect competition for spruce tips or other resources. 

The Proposed Action will also not result in any cumulative effects to the availability, distribution, access 

to, or competition for spruce tips. 

Monitoring 

Forest Service personnel will collect permits and review the locations and amount of harvest from each 

location and verify that harvesting followed provisions of the permit. Monitoring will occur at the end of 

each harvest season as soon as practical after harvesting is completed and near the end of the growing 

season. Any permitted commercial entity will be responsible for documenting and ensuring that the 

permitted harvest from Forest Service lands does not exceed the allowed weight for that year and that all 

provisions of the permit are followed. Positive monitoring results would allow for the incremental 

increase of harvest limits for that permit holder in following years. If harvest in any area is determined to 
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Spruce Tips - Special Forest Products Environmental Assessment 

exceed the conditions of the permit that area may be closed to commercial harvest and the permit holder 

may have reduced harvest limits the following year or that permit may be cancelled. 

Compliance with Other Laws and Regulations 

ANILCA Section 810, Subsistence Evaluation and Finding - The effects of this project have 

been evaluated to determine potential effects on subsistence opportunities and resources. Spruce tips are 

known to be important to subsistence and personal uses and the Forest Service recognizes that those uses 

must be met before commercial harvest can occur. Based on permit requirements for this project the 

availability of spruce tips for subsistence or personal use will not be affected. 

National Historic Preservation Act of 1966 - The Forest Service program for compliance with the 

National Historic Preservation Act includes locating, inventorying and nominating all cultural sites that 

may be directly or indirectly affected by scheduled activities. This activity has been determined to have 

no potential to effect historic properties. 

Executive Order 13007 - This order directs federal agencies to accommodate access to and ceremonial 

use of American Indian sacred sites by Indian religious practitioners and to avoid adversely affecting the 

physical integrity of such sacred sites. The proposed action will not limit access to or ceremonial use of 

sacred sites by Indian religious practitioners and will not adversely affect the integrity of such sites. 

E.O. 13175 (Consultation and Coordination with Indian Tribal Governments) – The 

following federally recognized tribal governments and organizations were contacted via the scoping 

letter. In addition, the Sitka Tribe of Alaska was briefed by the District Ranger during monthly 

coordination meetings. 

 Sitka Tribe of Alaska 

 Angoon Community Association 

 Organized Village of Kake 

 Central Council Tlingit and Haida 

Agencies and Persons Contacted 

The Sitka Ranger District mailed or emailed scoping letters to 79 individuals, businesses, tribal 

governments, tribal corporations, and local and state governments. Tribal governments and organizations 

were mailed scoping letters on December 11, 2014. Public and local governments were mailed scoping 

letters on Jan 2, 2015. Personnel from the Sitka Ranger District also updated the Sitka Tribe of Alaska at 

their monthly meetings, and met with the Kayaani Commission to describe the project on January 16, 

2015. 

Two comments were received during the scoping process: 

One comment was received by the Sitka Tribe of Alaska expressing concern over the amount of spruce 

tips that could be authorized for commercial harvest and concern over the commercial use of raw 

products. They suggested a maximum commercial harvest of 3,000 pounds, with a joint review after the 

first annual monitoring. Permit provisions were established to mitigate the effect of spruce tip removal on 

all trees available to subsistence users in the community. Opportunities will be provided for jointly 

reviewing the monitoring results. 

Another comment was received by the general public expressing support for the harvest of renewable 

resources, and concern about a Sealaska heritage site that may be within the locations allowed under the 

permit. It was determined that the property was not National Forest System land and therefore 

commercial harvest would not be authorized for that location. 

Literature Cited 

USDA Forest Service, 2008. 2008 Land and Resource Management Plan, Tongass National Forest. 
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Spruce Tips - Special Forest Products Environmental Assessment 

Deal, R.L., R.J. Barbour, M.H. McClellan, D. L. Parry. 2003. Development of epicormic sprouts in Sitka 

spruce following thinning and pruning in south-east Alaska. Forestry, Vol 76, No. 4, p. 402-412. 

Kayaani Commission, 2006, Ethnobotany field guide to selected plants found in Sitka, Alaska. Published 

by Sitka Tribe of Alaska.