United States Department of Agriculture

Saddle Lakes Timber Sale

Record of Decision – Draft

Forest Service 

Alaska Region

Tongass National Forest 

Ketchikan-Misty Fiords 

Ranger District R10-MB-740b September 2015
Cover Photo: Saddle Lake. 

Photograph by Rob Reeck, former Forest Service Planning Specialist.
United States

Department of

Agriculture

Forest

Service

Tongass National Forest 

Alaska Region

648 Mission Street

Ketchikan, AK 99901 

(907) 225-3101 

Caring for the Land and Serving People Printed on Recycled Paper 

File Code: 1950

 Date: September 8, 2015

Dear Interested Stakeholder:

I am pleased to announce that the draft Record of Decision (ROD) for the Saddle Lakes Timber Sale 

on the Ketchikan-Misty Fiords Ranger District, Tongass National Forest is available for your review. 

This ROD and Appendix B to the ROD, which documents my decision to adopt a Forest Plan 

amendment removing visual priority route and use area designations in the Saddle Lakes project 

area, are subject to the Project-Level, Predecisional Administrative Review Process (Objection 

Process) at 36 CFR 218, subparts A and B. Appendix A to the ROD, which moves the small oldgrowth reserve (OGR) in value comparison unit (VCU) 7470, is subject to the Objection Process for 

forest plans, plan amendments, or plan revisions at 36 CFR Part 219, subpart B. These processes are 

discussed in more detail in the Administrative Review – Opportunity to Object section of this ROD. 

The FEIS and draft ROD are available for review at the Ketchikan Forest Supervisor’s Office and 

Ketchikan-Misty Fiords District Office and online at 

http://www.fs.usda.gov/project/?project=38990. Hardcopies and CDs of the documents are available 

upon request.

The draft ROD documents my intention to select Alternative 5, with modifications, and the facts 

considered in reaching my decision. This decision will make about 47 million board feet of sawlog 

and utility timber available for harvest from about 2,327 acres of commercial forest land on 

Revillagigedo Island. The harvest of this timber will require the construction of about 17.2 new 

miles and the reconditioning of 10.5 miles of National Forest System road, and the construction of 

9.8 miles of temporary road. 

Under the Objection Process at 36 CFR 218, the public will be notified of the availability of the draft 

ROD and Appendix B through a legal notice published in the newspaper of record, the Ketchikan 

Daily News, and the date of that legal notice will initiate a 45-day objection filing period. This legal 

notice will also initiate a 60-day objection filing period for Appendix A pursuant to 36 CFR 

219.56(a). Any objection to Appendix A should be filed separately from an objection to the draft 

ROD and Appendix B filed under 36 CFR 218. 

A copy of the legal notice will also be posted on the Forest Service project website at 

http://www.fs.usda.gov/project/?project=38990. If we receive objections during the established 

objection filing periods, a 45-day review period will begin during which time the Reviewing Officer, 

the Responsible Official, and any objectors may meet in order to resolve concerns, with the goal of 

achieving a better, more-informed decision. I will sign the ROD after any concerns and instructions 

identified by the Reviewing Officer in the objection response(s) have been addressed. A final 

decision on decisions subject to the objection process may occur on, but not before, 5 business days
Copies of this letter have been mailed to those people who expressed interest in the project through 

scoping, comments, consultation, or requests to be on the mailing list. For additional information, 

please contact Jeffrey DeFreest, Ketchikan-Misty Fiords District Ranger, at (907) 225-2148. 

As the Forest Supervisor, I am responsible for this decision. Your interest in the Saddle Lakes 

Timber Sale project and management of the Tongass National Forest is appreciated. 

Sincerely,

M. EARL STEWART 

Forest Supervisor 

from the close of the objection filing period, if no objections are received (36 CFR 218.12(c)(2) and 

36 CFR 219.58(c)). 

2
United States Department of Agriculture

Forest Service Alaska Region 

_________________________________________________________________ 

Lead Agency: USDA Forest Service

Tongass National Forest

Responsible Official: M. Earl Stewart, Forest Supervisor 

Tongass National Forest 

Federal Building 

Ketchikan, Alaska 99901 

For Further Information 

Contact: 

Jeffrey DeFreest, District Ranger

Ketchikan-Misty Fiords Ranger District 

3031 Tongass Ave 

Ketchikan, Alaska 99901 

(907) 225-2148 

_________________________________________________________________ 

Abstract

The Forest Supervisor, M. Earl Stewart, as Responsible Official, intends to select Alternative 5 with 

modifications from the Saddle Lakes Timber Sale Final Environmental Impact Statement. This decision 

will make approximately 47 million board feet of timber available for harvest from approximately 2,327 

acres of old-growth forestlands. 

Saddle Lakes Timber Sale

Record of Decision - Draft

Saddle Lakes Timber Sale Record of Decision - Draft Table of Contents  i 

Table of Contents

Summary of the Intended Decision ......................................................................................................................1

Project Area .....................................................................................................................................................2

Modifications to Alternative 5 for the Selected Alternative ............................................................................4

Reasons for the Decision .................................................................................................................................5

Subsistence ...................................................................................................................................................6

Wildlife ........................................................................................................................................................7

OGR Modification .......................................................................................................................................7

Visual Priority Route Designation Removal and Recreation .......................................................................8

Aquatics and Fish .........................................................................................................................................8

Inventoried Roadless Areas .........................................................................................................................9

Climate Change ............................................................................................................................................9

Effects of the Selected Alternative on Significant Issues ................................................................................9

Issue 1 – Timber Economics ......................................................................................................................12

Issue 2 – Timber Availability .....................................................................................................................12

Issue 3 – Wildlife Habitat and Subsistence Use.........................................................................................13

Issue 4 – Scenery and Recreation Opportunities ........................................................................................22

Other Environmental Consequences ..........................................................................................................22

Alternatives Considered in Detail ..................................................................................................................22

Items Common to All Action Alternatives ................................................................................................22

Alternative 1 - No Action...........................................................................................................................23

Alternative 2 - Proposed Action .................................................................................................................23

Alternative 3 ...............................................................................................................................................23

Alternative 4 ...............................................................................................................................................23

Alternative 5 ...............................................................................................................................................23

Alternative 6 ...............................................................................................................................................24

Environmentally Preferred Alternative ..........................................................................................................24

Alternatives Eliminated From Further Consideration ...................................................................................24

Public Involvement ........................................................................................................................................24

Project Record ...............................................................................................................................................25

Mitigation ......................................................................................................................................................25

Monitoring .....................................................................................................................................................26

Findings Required By Law ............................................................................................................................26

Alaska National Interest Lands Conservation Act (ANILCA) of 1980; Section 810 ................................26

Bald and Golden Eagle Protection Act of 1940 (as amended) ...................................................................28

Clean Air Act of 1970 (as amended) .........................................................................................................28

Clean Water Act (1977, as amended) ........................................................................................................28

Endangered Species Act (ESA) of 1973 (as amended) ..............................................................................28

Federal Cave Resource Protection Act of 1988 .........................................................................................29

Forest Service Transportation Final Administrative Policy (Roads Rule) .................................................29

Magnuson-Stevens Fishery Conservation and Management Act ..............................................................29

Marine Mammal Protection Act of 1972 ...................................................................................................29

National Forest Management Act (NFMA) of 1976 (as amended) ...........................................................30

Forest Plan .................................................................................................................................................30

National Historic Preservation Act (NHPA) of 1966 (as amended) ..........................................................31

Tongass Timber Reform Act (TTRA) of 1990 ..........................................................................................31

Executive Orders ...........................................................................................................................................31

Executive Order 11988 (Floodplains) ........................................................................................................31

Executive Order 11990 (Wetlands) ............................................................................................................31
Table of Contents

ii  Table of Contents Saddle Lakes Timber Sale Record of Decision - Draft

Executive Order 12898 (Environmental Justice) ....................................................................................... 31

Executive Order 12962 (Aquatic Systems, Recreational Fisheries) .......................................................... 32

Executive Order 13007 (Indian Sacred Sites) ........................................................................................... 32

Executive Order 13112 (Invasive Species) ............................................................................................... 32

Executive Order 13175 (Consultation and Coordination with Indian Tribal Governments)..................... 32

Executive Order 13186 (Migratory Birds) ................................................................................................ 32

Executive Order 13443 (Facilitation of Hunting Heritage and Wildlife Conservation) ............................ 33

Federal and State Permits .............................................................................................................................. 33

Implementation Process and Process for Considering Changes and New Information ................................ 33

Administrative Review - Opportunity to Object ........................................................................................... 34

Appendix A - Non-Significant Forest Plan Amendment - Small Old-growth Habitat Reserve Adjustment in 

the Saddle Lakes Timber Sale Area .................................................................................................................. 37

Direction and Process .................................................................................................................................... 37

Forest Plan OGR (IOGR) .......................................................................................................................... 38

Modified OGR for the Selected Alternative .............................................................................................. 38

Timing ........................................................................................................................................................... 39

Location and Size .......................................................................................................................................... 40

Goals, Objectives, and Outputs ..................................................................................................................... 40

Goals and Objectives ................................................................................................................................. 40

Outputs ...................................................................................................................................................... 40

Cumulative Changes ..................................................................................................................................... 41

Conclusion .................................................................................................................................................... 41

Appendix B - Non-Significant Forest Plan Amendment Removing Visual Priority Routes............................. 43

Visual Priority Routes and Use Areas ........................................................................................................... 43

George Inlet and Carroll Inlet Saltwater Use Areas .................................................................................. 44

Harriet Hunt (Ketchikan) to Shelter Cove Road VPR ............................................................................... 44

Saddle Lakes Recreation Area VPR .......................................................................................................... 44

Shelter Cove Boat Ramp ........................................................................................................................... 44

Direction and Process .................................................................................................................................... 46

Timing ....................................................................................................................................................... 46

Location and Size ...................................................................................................................................... 46

Effects of Removing VPR Designations in the Selected Alternative ........................................................ 47

Cumulative Effects ........................................................................................................................................ 48

Conclusion .................................................................................................................................................... 48

List of Tables

Table 1. Harvest units dropped for the Selected Alternative ............................................................................... 4

Table 2. Helicopter Harvest units changed from clearcut to partial harvest silvicultural prescription ............... 5

Table 3. Alternative comparison - Issue 1 ......................................................................................................... 10

Table 4. Cumulative change to average snow deer habitat (POG <1500’) and HPOG on all land ownerships in 

WAAs 406 and WAA 407 ......................................................................................................................... 14

Table 5. Elevational Connectivity in Modified Landscape LUD ...................................................................... 15

Table 6. Reduction of the deer model habitat capability on NFS Lands1/ in WAAs 406 and 407 from the 

existing condition ...................................................................................................................................... 17

Table 7. Cumulative change in the reduction of the deer habitat capability (DHC) on all land ownerships in 

WAAs 406 and 4071/ ................................................................................................................................. 17

Table 8. Cumulative change to deep snow winter habitat\1 on all land ownerships .......................................... 18

Table 9. Issue 3, Cumulative effects on wolves based on deer density and road density on all land ownerships

 ................................................................................................................................................................... 19
Table of Contents

Saddle Lakes Timber Sale Record of Decision - Draft Table of Contents  iii 

Table 10. Alternative comparison - Issue 4 – Scenery and Recreation..............................................................20

Table 11. Unit group information for openings over 100 acres for the Selected Alternative ............................30

Table 12. Comparisons of Forest Plan OGR and the modified OGR ................................................................39

Table 13. Cumulative effect on modifications for OGRs ..................................................................................41

Table 14. Visual priority route designations removed in the Saddle Lakes project area ...................................43

Table 15. Project area acreages and percentages of TNF Lands ........................................................................46

Table 16. Changes in scenic integrity objectives (SIO) due to VPR designation removal and harvest under the 

Selected Alternative ...................................................................................................................................47

Table 17. Effects of VPR designation removal to scenic integrity objectives by harvest type for the Selected 

Alternative ..................................................................................................................................................47

List of Figures

Figure 1. Project area and vicinity map ...............................................................................................................3

Figure 2. VPR designations to be removed for the Saddle Lakes Project .........................................................45
Table of Contents

iv  Table of Contents Saddle Lakes Timber Sale Record of Decision - Draft

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Saddle Lakes Timber Sale Record of Decision - Draft ROD  1 

Record of Decision – Draft

Saddle Lakes Timber Sale

Summary of the Intended Decision

Based upon my review of the Saddle Lakes Timber Sale Final Environmental Impact Statement (FEIS), it is 

my intention to select Alternative 5 from the FEIS with modifications; hereafter referred to as the Selected 

Alternative. This draft Record of Decision (ROD) is being made available for review under the Predecisional 

Administrative Review, or “Objection” processes at 36 CFR 218, subparts A and B, and 36 CFR 219, subpart 

B, as described below under the Administrative Review – Opportunity to Object section of this draft ROD. 

The Selected Alternative will harvest timber from 2,327 old growth acres of commercial forest land to 

contribute approximately 47 million board feet (MMBF) of sawlog and utility timber volume to the Tongass 

National Forest timber sale program. This alternative proposes 1,922 acres of even-aged management 

(clearcut) using conventional (cable and shovel) logging systems, as well as 405 acres of uneven-aged 

management (partial harvest - single-tree selection with 33 percent basal area removal) using cable and 

helicopter logging systems. Helicopter logging would be used on about 18 percent of the acres. For simplicity, 

the terms “clearcut “and “partial harvest” will be used throughout this document instead of referring to the 

exact silviculture terminology. Refer to silvicultural prescriptions for specific unit information. These 

prescriptions are part of this decision. 

The Selected Alternative includes constructing 17.2 miles of new National Forest System (NFS) road and 9.8 

miles of temporary road and reconditioning 10.5 miles of existing NFS roads. Up to 14 new rock quarries 

possibly impacting as much as 80 acres may be developed for the road construction and reconstruction in 

addition to the 33 existing quarries. All NFS roads constructed for timber harvest will be closed and placed in 

to storage. Temporary roads will be decommissioned as part of the timber contract. The Shelter Cove log 

transfer facility (LTF) will be rebuilt and adapted to a ramp instead of the former bulkhead. 

The Selected Alternative will authorize a right-of-way (ROW) about 300 feet wide by about 1 mile long to the 

State of Alaska to construct, operate and maintain a single lane public road on NFS lands. A special use 

authorization will be issued for this. The new road will connect the State’s proposed road with Road 8300300. 

The new road will be constructed by the State of Alaska within the authorized ROW and left open for public 

use. 

The Small Old-growth Reserve (OGR) in value comparison unit (VCU) 7470 will be redesigned to be 

completely within the North Revilla Inventoried Roadless Area and designated as Old-growth Habitat LUD, 

and the roaded portion of the current OGR would be reallocated as Modified Landscape land use designation 

(LUD) where timber harvest is allowed. The decision for this action is outlined through a Forest Plan 

Amendment included in Appendix A of this draft ROD.

The five visual priority routes (VPRs) designations for scenery within and adjacent to the project area as 

analyzed in the FEIS will be removed. This decision for this action is documented in Appendix B of this draft 

ROD. 

A partial barrier to fish passage on Salt Creek will be removed to improve about 5 miles of upstream habitat 

and 139 acres of lake habitat for anadromous fish.
Saddle Lakes Timber Sale 

2  ROD Saddle Lakes Timber Sale Record of Decision - Draft 

Design features of timber harvest units and the road management objectives (RMOs) for ongoing

maintenance and design features of the new NFS roads and the existing NFS roads to be reconstructed in this 

draft decision are described in detail on the unit and road cards. 

Road and unit cards, project specific silvicultural prescriptions, the FEIS and other documents are located in 

the project record, and available for download on the project website at 

http://www.fs.usda.gov/project/?project=38990 or for review at the Ketchikan-Misty Fiords Ranger District 

Office. Hard copies or CD are available upon request. 

Project Area

The 42,016 acre Saddle Lakes project area is located in Southeast Alaska on Revillagigedo Island, about 14 

miles north of the City of Ketchikan. The project area is made up of about 38,459 acres of National Forest 

System lands (NFS) and 3,557 acres of non-NFS lands. The non-NFS lands, which comprise about 9 percent 

of the project area, are owned by the Cape Fox Corporation, State of Alaska, Alaska Mental Health Trust 

Authority, and private landowners. 

The project area includes three land use designations: Timber Production LUD, (15,305 acres or 40 percent of 

the project area), Modified Landscape LUD, (16,028 acres or 42 percent of the project area) and Old-Growth 

Habitat LUD, (3,565 acres or 9 percent of the project area) 

A fairly extensive road system (about 53 miles) is present in the project area. This road system is not currently

connected to the Ketchikan road system, but has been proposed and being planned by the State of Alaska in 

cooperation with the US Army Corps of Engineers (USACE). 
Record of Decision

Figure 1. Project area and vicinity map

Saddle Lakes Timber Sale Record of Decision - Draft ROD  3
Saddle Lakes Timber Sale 

4  ROD Saddle Lakes Timber Sale Record of Decision - Draft 

Modifications to Alternative 5 for the Selected Alternative

My intended decision includes the timber harvest units and roads associated with Alternative 5 with the 

modifications as discussed below and displayed on the ROD Selected Alternative map (Figure R-2) (in the 

map packet) and in detail on the unit and road cards. This decision was made based on the considerations 

listed in the Purpose and Need and Decision Framework in Chapter 1 of the FEIS. 

I am making the following modifications to Alternative 5 as described in the FEIS in this decision. 

1. The Selected Alternative removes 63 units analyzed for the FEIS with a reduction in 548 acres from those

analyzed for Alternative 5. Since the DEIS, additional field evaluation has occurred. Several units or

portions within units were found to have low volume and have remote or expensive access. These units

would probably lower the indicated advertised rate of any possible timber harvest contracts and/or make

the contract deficit and therefore, it could not be advertised. These units are listed in Table 1.

2. Because these units are dropped from harvest at this time, construction of 3.4 miles of NFS roads and 2.2

miles of temporary roads are no longer needed for access.

Table 1. Harvest units dropped for the Selected Alternative 

FEIS 

unit Acres FEIS unit Acres FEIS unit Acres FEIS unit Acres

16 22 71-3 9 202 11 310 2 

17 20 73 12 204-3 10 312 3 

20-1 12 77 21 204-4 5 400 5 

21 8 78 22 204-5 7 401 13

26 1 79 17 206 17 402 20

30 11 102 8 209 14 403 16

30-1 1 112 5 211 13 404 18

30-2 3 115 12 212 9 405 9 

30-3 0 116 8 213 28 406 15

32 11 122 6 221 13 407 13

36 3 126 3 224 19 408 51

46-2 5 140 14 231 15 411 12

46-3 7 153 29 235 25 412 12

57 18 156 12 236 16 413 47

71-1 7 157 11 247 8 414 13

71-2 10 158 3 251 4 

3. For all helicopter harvest units proposed in the FEIS for Alternative 5 except for unit 148-1 the clearcut

prescription will be changed to single-tree selection harvest as shown in Table 2. Timber harvest will

result in about 33 percent removal of basal area, similar to the previously proposed partial harvest

management stands in the Selected Alternative. Unit 148-1 will be clearcut as proposed in the FEIS due to

its small size (5 acres), and it being constrained by an adjacent inventoried roadless area.
Record of Decision

ROD  5 

Table 2. Helicopter Harvest units changed from clearcut to partial harvest 

silvicultural prescription

FEIS 

unit Acres FEIS unit Acres FEIS unit Acres FEIS unit Acres

1 10 76-1 24 134-2 6 253 2 

20 13 118 19 149 35 300 23

49 50 123 27 150 16

63 32 134 5 152 6 

76 11 134-1 3 152-1 11

Reasons for the Decision

The best available science was used in the preparation of the Saddle Lakes EIS. The analysis was an 

interdisciplinary and interagency effort by the State of Alaska and other federal agencies that provided input 

into the EIS as well as a thorough review throughout the process. The analysis included more than 460 peer 

reviewed articles and site specific studies. Collaboration included 29 specialists representing 13 resources. For 

each resource, a project specific report was prepared and reviewed to ensure accuracy. In making my 

decision, I considered the objectives to meet the purpose and need for this project as well as the issues and 

concerns that arose during scoping and comments on the DEIS. Supporting and opposing views were 

considered equally for this project. I considered Forest Plan direction relevant to this project and the 

competing interests and values of the public. I considered all viewpoints and incorporated them where 

feasible and consistent with the purpose and need of the project. I evaluated the trade-off between resource 

protection and social values. 

I find that the Selected Alternative provides a beneficial mix of resources for the public, within the framework 

of existing laws, regulations, policies, public needs and desires, and the capabilities of the land, while meeting 

the stated purpose and need for this project. My decision to implement the Selected Alternative conforms to 

the Forest Plan and National Forest Management Act (NFMA). I also find that the Selected Alternative strikes 

a balance between meeting the resource needs of the public and protecting the forest resources.

I considered the need to manage the timber resource on the Tongass National Forest in order to produce an

even flow of sawtimber and other wood products meeting annual demands. Appendix A of the Saddle Lakes 

Timber Sale FEIS describes the process that maintains a steady supply of timber and how each project goes 

through a series of steps before timber can be offered from the National Forest. 

I want to retain the existing logging and milling infrastructure in Southeast Alaska and continue to provide 

support for those jobs that contribute to diversity in the Southeast Alaska job market which is essential to 

economic stability. The old-growth timber program is essential until enough young- growth timber is ready

for commercial harvest. A transition strategy is being developed through a Forest Plan Amendment that allows 

for the industry to adjust, adapt, and develop markets for new products by shifting to the management of 

young-growth forests. Because of this, I also considered how the Selected Alternative provides support for a 

projected 186 to 224 direct annualized jobs and opportunities for the timber and transportation industries. I 

plan to offer a variety of sale sizes appealing to small local operators as well as larger operators in Southeast

Alaska.

This decision should provide approximately 47 MMBF of timber volume necessary for the timber industry as 

part of the transition from a dependence on old-growth timber to a program primarily supported by young 

growth. A gradual, rather than abrupt, shift is vital to keep timber industry jobs in Southeast Alaska and 

Saddle Lakes Timber Sale Record of Decision - Draft
Saddle Lakes Timber Sale 

6  ROD Saddle Lakes Timber Sale Record of Decision - Draft 

sustain local communities. A stable young-growth timber program in the future is only possible through

maintaining the current timber industry’s skills until it can adjust. 

In my decision to drop the lower-value units for the Selected Alternative, I anticipate potential improvement 

to the economic value of this timber sale project while maximizing the volume. Changing the silvicultural 

prescription from clearcut to partial harvest in helicopter-yarded units resulted in roughly a 51 percent 

reduction in helicopter costs in the FASTR analysis. 

I have changed the clearcut prescription in helicopter units to partial harvest for all but one 5-acre helicopter 

unit to further improve the economic value of this timber sale project and also to reduce impacts to scenery 

and wildlife habitat, especially around the Saddle Lakes area, by maintaining more old-growth forest stand 

structure. The additional partial harvest will also mitigate the effects to landscape connectivity important to 

deer and other old-growth associated species. 

I have considered that partial harvest with helicopter logging results in fewer openings in the canopy plus 

minimal ground disturbance and may favor hemlock regeneration over cedar and spruce regeneration. 

However, retaining spruce and cedar advance regeneration where it is present and feasible will help maintain 

stand diversity. 

I have considered the need for expanded access for multiple resources uses and activities such as the Alaska 

Free Use/Personal Use program, subsistence and sport hunting and trapping and recreation. These uses were 

considered in conjunction with the need to facilitate access for short-term forest management activities, such 

as precommercial thinning and microsales and provide resource protection. 

To address concerns related to yellow-cedar I will consider opportunities of enhancing yellow-cedar species 

composition in clearcut units that would be considered suitable for supporting the long-term survival of this 

valuable species. Alaska yellow-cedar can be promoted through planting and precommercial thinning, 

generally on sites at higher elevation with adequate spring snow, or on sites with good drainage that support 

deeper rooting. It is anticipated that the preferred species during thinning operations will continue to be 

Alaska yellow-cedar.

I based my decision to authorize the Ketchikan to Shelter Cove Road ROW to the State of Alaska on the fact 

that this road, if constructed and kept open, will provide roaded access to individuals and industry especially 

from the communities of Ketchikan and Saxman. This allows roaded access, as opposed to boat or air access 

to the Shelter Cove area for subsistence products, increased recreation opportunities, and should decrease 

transportation costs for timber harvest contracts. 

To address the concern about increased roads directly associated with the timber harvest in the project area, 

all NFS roads constructed for the contracts will be closed or stored as described in the project road cards. All

temporary roads will be decommissioned prior to the closure of the timber contract. Closed roads will remain 

available for foot traffic. For the existing roads used for timber harvest, the Selected Alternative will 

implement the 2008 KMRD Access and Travel Management Plan, under which additional road closures 

would occur as funding allows. 

Subsistence

I am aware, based on public comments and the ANILCA 810 Subsistence Hearing, that residents of the 

subsistence community of Saxman and other rural communities use the project area for subsistence deer 

hunting. I recognize that the Saddle Lakes Timber Sale, in conjunction with past, present and foreseeable 

timber harvest actions, will alter the project area’s deer habitat and that may affect the abundance or 

distribution of deer. 
Record of Decision

Also I recognize that there may be increased subsistence and sport hunting in the Saddle Lakes area if an open 

road connection to Ketchikan occurs and that may cause increased competition among hunters. Roads 

constructed for timber harvest will be open to the public for the duration of the project, but closed following 

reforestation certification. Closed roads may result in reduced competition between motorized hunter and 

subsistence use; however competition will not be reduced to pre-project levels due to the remaining 

connection between the communities of Ketchikan and Saxman and the Shelter Cove area. 

There was concern over the effects of harvest to deer habitat for subsistence use. However, comments 

received favored improved access. I have considered the need for public access, potential effects on resources 

and public concerns voiced regarding subsistence use. I think that what I have heard from subsistence users 

support both of my decisions to approve the right-of-way for the State of Alaska and to close NFS roads 

constructed for the Saddle Lakes Timber Sale.

Wildlife 

I considered the effects on wildlife habitat for many species by looking at the amount of reduction of 

productive old growth (POG). This is one of the reasons I decided to increase the use of partial harvest in the 

Selected Alternative. This will mitigate the effects of the timber harvest by providing more structural diversity 

within the partial-harvest units which will help maintain connectivity.

I recognize that timber harvest will affect certain wildlife corridors. These effects have been somewhat 

mitigated by my modifications to Alternative 5 plus I expect that these effects will be short-term in nature as 

the adjacent stands mature and provide alternate routes. 

I considered the fact that the deer model shows that the deer habitat capability is less than 18 deer per square 

mile in WAAs 406 and 407 which is less than Forest Plan Guideline (WILD1.XIV p. 4-95) that states - 

“Provide, where possible, sufficient deer habitat capability to first maintain sustainable wolf populations, and 

then to consider meeting estimated human deer harvest demands. This is generally considered to equate to the 

habitat capability to support 18 deer per square mile (using habitat capability model outputs) in 

biogeographical provinces where deer are the primary prey of wolves.” However, information indicates that 

the wolf population is stable. As indicated elsewhere, both sport and subsistence hunting of deer may increase 

when the project area roads are connected to Ketchikan. 

Although wolf population viability has a high likelihood of being maintained across the Tongass, concerns 

have been expressed on wolf sustainability at a more localized scale. However, through proper management 

of both of the hunting regulations and young-growth stands to provide forage, these efforts should result in an 

adequate deer population for both uses. Since management of hunting regulations is under the jurisdiction of 

the State of Alaska and the Federal Subsistence Board, I have been and will continue to work with other 

federal and State agencies in addressing any concerns about the sustainability of wolf populations. An 

interagency group will continue to evaluate measures such as length of season and harvest limit proposals for 

submission to ADFG Board of Game and Federal Subsistence Boards and road access management in 

conjunction with ADFG. 

About 1,100 acres of young-growth stands have already been precommercial thinned. Another 1,130 acres are 

planned for thinning before 2018. These young-growth treatments can maintain or increase forage for a longer 

period of time compared to unthinned conditions. 

OGR Modification

I have considered whether the modification of the small old-growth reserve in VCU 7470 met the comparable 

achievement of the Old-growth Habitat LUD goals and objectives (Forest Plan, pp. 3-57 and 3-62 and 

Appendix K). Although the 2008 Forest Plan incorporated the biologically preferred design for the small 

Saddle Lakes Timber Sale Record of Decision - Draft ROD  7
Saddle Lakes Timber Sale 

8  ROD Saddle Lakes Timber Sale Record of Decision - Draft 

OGR for VCU 7470, several things have prompted me since then to consider a modification to that design. 

First, when this design was proposed, the Tongass was exempt from the 2001 Roadless Rule and timber 

harvest was anticipated within inventoried roadless areas that now do not allow harvest. This is no longer the 

case. Second, the State of Alaska connection between the Ketchikan and Shelter Cove road systems is more 

imminent than it was during the 2006 Forest Plan Amendment OGR analysis. By modifying the current OGR 

the planned road will not be in an Old-growth Habitat LUD. Third, with the transition to young-growth forest 

management, modifying the OGR will allow access to 173 acres of young-growth stands along the existing 

road system. Although these stands are not currently commercial, they will be part of the future forest 

management land base. 

Therefore, I asked an interagency wildlife biologist team, including representatives from ADFG, USFWS and 

USFS to review the possibility of relocating the small OGR completely within the North Revilla Inventoried 

Roadless Area. I am aware that site-specific conditions of the Selected Alternative modified small OGR 

implemented by this decision will not provide exactly the same physical conditions of kind and like quality to the 

existing condition of the Forest Plan small OGR. Based on the analysis in the FEIS plus the modifications to 

Alternative 5 which specifically changes the silvicultural prescription for unit 300 from clearcut to partial 

harvest, I have decided that the modified OGR does meet comparable achievement of the Old-growth Habitat 

LUD goals and objectives. More discussion on the OGR modification is in Appendix A of this ROD. 

By meeting comparable achievement with the modified OGR, I have determined that the Forest Plan conservation 

strategy would continue to provide extensive areas in old-growth reserves distributed across the Tongass. In 

addition, within matrix lands where timber harvest is allowed; riparian management area, beach and estuary fringe

and other standards and guidelines; would maintain many travel ways, corridors, and connectivity.

Visual Priority Route Designation Removal and Recreation

I considered the effects on scenery and recreation values for forest users from the increased amount of timber 

harvest for this project due to the removal of visual priority route designations (VPRs) for the Selected 

Alternative. I realize that some users expect a more natural environment when visiting the forest even on 

roads that were constructed for access for timber harvest. I also need to consider the balance of uses, and think

that because of the past use of the Saddle Lakes area for timber management and the investment in the 

infrastructure, this continued use is warranted. In making this decision, I took into account the natural areas in 

proximity to the project area including the over 2 million acre Misty Fiords National Monument Wilderness, 

the adjacent Naha LUD II area and various other parcels of non-development LUDs. I also considered that 

there were no submitted comments opposing the removal of VPRs under any scenario. More discussion is in 

Appendix B of this ROD. 

Aquatics and Fish 

I have decided that the modification and removal of the partial barrier to fish passage on Salt Creek will 

benefit the commercial fishing industry, subsistence and sport fishing by opening up about 5 miles of stream 

and 139 acres of lake habitat for adult steelhead and coho adult salmon. 

I recognize that the aquatics effects analysis concludes that some watersheds may experience slight increases 

in peak flows as a result of cumulative harvest and roads associated with implementation of the Selected 

Alternative. The magnitude and duration of peak flow increases would not negatively impact downstream fish 

habitat. Implementation of the Selected Alternative may result in temporary reduction in stream water quality 

from road construction and maintenance activities. Application and monitoring of best management practices 

(BMPs) will ensure the protection of water quality and aquatic habitat. 
Record of Decision

Inventoried Roadless Areas

The Ninth Circuit Court has issued its en banc decision in Organized Village of Kake v. U.S. Dept. of 

Agriculture, 11-35517, upholding the Alaska District Court’s reinstatement of the Roadless Rule, which 

remains in effect and applies to the Tongass. The Selected Alternative does not include any harvest units or 

road building within the inventoried roadless areas as described by the 2001 Roadless Rule, nor did the other 

action alternatives considered in the DEIS, as adequate timber existed to produce a range of alternatives 

meeting the purpose and need outside of inventoried roadless area portions of the project area.

Climate Change

I weighed the effects of climate change on the project, including the near-term effects of the action 

alternatives among the other resource considerations. The FEIS identified difficulties in assessing effects at 

the project scale, largely due to the level of uncertainty. While there is general agreement among scientists 

that the climate is warming, there is considerable uncertainty concerning the exact effects of climate change 

on the forests of Southeast Alaska and how to best deal with possible changes to the many resources on the 

Tongass. Based on the project-level analysis and the state of current knowledge and the uncertainty about 

specific effects of climate change, I have no reason to believe that the Saddle Lakes Timber Sale will 

exacerbate climate change or its effects. The Tongass National Forest will continue to monitor potential 

effects of climate change through the existing Forest Plan monitoring programs and other studies that are 

happening regionally and nationally. If effects from climate change are detected, they will be addressed 

through existing planning procedures to determine whether changes in management are warranted. 

Effects of the Selected Alternative on Significant Issues

Issues identified for the Saddle Lakes Timber Sale through external and internal scoping were addressed by 

five action alternatives and a no-action alternative. 

Due to the extent of the modifications to Alternative 5, analysis for the key issues relative to the Selected 

Alternative was done by effected resources and is summarized below. Comprehensive data and analysis is 

located in the project record. Due to the decrease of harvest acres and amount of new roads combined with the 

changes of the silvicultural prescriptions, the effects to these resources are assumed to be similar or less for 

the Selected Alternative than those estimated for Alternative 5. 

Saddle Lakes Timber Sale Record of Decision - Draft ROD  9
Saddle Lakes Timber Sale 

10  ROD Saddle Lakes Timber Sale Record of Decision - Draft 

Table 3. Alternative comparison - Issue 1 

Measure Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5 Selected 

Alternative Alternative 6 

Timber Volume by Species Millions of Board Feet (MMBF)

Sitka spruce 0 3.9 2.2 6.6 7.8 6 5.2

Hemlock 0 13.9 7.8 23.4 27.8 21.5 18.6

Western Red-cedar 0 5.8 3.3 9.8 11.6 9 7.8

Alaska Yellow-cedar 0 3.5 2 5.9 7.1 5.5 4.7

Total Sawtimber Volume 0 27.2 15.3 45.7 54.3 42 36.3

Total Utility Volume 0 3.2 1.8 5.3 6.4 4.9 4.2

Total Volume 

(sawtimber and utility) 0 30.3 17.1 51 60.7 46.9 40.5

Logging System Acres

Cable 0 612 524 1,389 1,578 1,394 1,121

Shovel 0 495 292 538 578 522 538

Helicopter 0 1,100 196 497 719 411 479

Total Harvest Acres 0 2,207 1,012 2,424 2,875 2,327 2,138

Road Construction and 

Reconditioning Miles

New NFS Road 0 10.2 6.7 19.6 20.6 17.2 16.3

New Temporary Road 0 5.6 5 9.8 11.7 9.8 8.2

Total New Road Construction 0 15.8 11.7 29.4 32.3 26.9 24.5

Reconditioning of Stored 

NFS Roads 0 10.8 7.7 10.8 11.1 10.9 10.8

Financial Efficiency Analysis (Limited Export Policy & Domestic Processing)

Dollars per Thousand Board Feet (MBF)

Indicated Advertised Rate $0 ($14.05) ($12.08) ($2.00) ($4.66) $3.78 $3.62 

Road and LTF Construction and 

Reconditioning Costs $0 $81 $105 $91 $84 $89 $95 

Logging Costs 

(cost/MBF net removed) $0 $273 $246 $252 $262 $242 $241 
Record of Decision

Saddle Lakes Timber Sale Record of Decision - Draft ROD  11 

Measure Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5 Selected 

Alternative Alternative 6 

Dollars (in millions)

Total Production Costs 

(stump-to-mill, roads, and 

manufacturing costs)

$0 $17.70 $10.00 $29.30 $35.00 $18.64 $23.10 

Financial Efficiency Analysis (Domestic Processing)

Dollars per Thousand Board Feet (MBF)

Indicated Advertised Rate $0 ($70.73) ($104.52) ($95.15) ($97.91) ($77.34) ($89.71)

Road and LTF Construction and 

Reconditioning Costs $0 $81 $105 $91 $84 $89 $95 

Logging Costs 

(cost/MBF net removed) $0 $273 $246 $252 $262 $242 $241 

Dollars (in millions)

Total Production Costs 

(stump-to-mill, roads, and 

manufacturing costs)

$0 $19.87 $11.68 $34.52 $41.22 $19.66 $27.26 

Employment Number of Annualized Jobs Supported

Total Jobs Estimated 

(Current R10 Policy) 0 121 68 203 241 186 161

Limited Export Policy and

Domestic Processing 0 145 81 243 290 224 194
Saddle Lakes Timber Sale 

12  ROD Saddle Lakes Timber Sale Record of Decision - Draft 

Issue 1 – Timber Economics 

The amount of timber available for sale from national forests and a stable supply affects local employment 

and revenues. This issue concerns both the financial efficiency and the salability of the proposed project. It 

also relates to the potential support to local employment and revenues generated for communities in the local 

area. Project design affects the viability of sales and the ability to offer them. Optimizing volume and net 

return on timber harvest will provide for flexibility over the life of the project and the ability to offer 

economically viable timber sales across fluctuating market conditions. It is also critical to match the range in 

the size of sales offered to the range in sizes of industry operators. Operators need economical timber to stay 

in business and loss of those operators would have an adverse impact on local economies. 

The Selected Alternative responds to this issue by providing 47 MMBF for harvest with an indicated 

advertised value of $3.78 per MBF for the export scenario, and $ -77.34 per MBF for the domestic processing 

scenario. Once cleared by this Decision, units from the Selected Alternative may be packaged and sold to a 

variety of different operators locally, throughout Southeast Alaska, and beyond, depending upon market and 

demand at the time of purchase. Specifically, modifications made to Alternative 5 to develop the Selected 

Alternative resulted in an expected increase in the indicated advertised rate of $8.44 per MBF. These changes 

resulted in the most economical of all action alternatives considered in detail followed by Alternatives 6, 4, 5, 

3 and 2. 

About 406 acres of units will be helicopter logged and will be partially harvested to improve economics. This 

is a reduction of about 307 acres from the 719 proposed originally for helicopter logging and clearcut harvest

for Alternative 5, excluding the 6 acre unit 148. The modification to the silviculture prescription for helicopter 

units will improve economics and be less detrimental to wildlife habitat than clearcut units. 

Issue 2 – Timber Availability

Issue 2 addresses concerns about the availability of timber within the project area as described in the 2008 

Forest Plan Amendment FEIS (USDA Forest Service 2008c, p. A-5) as Key Issue 2: “The Tongass National 

Forest needs to seek to provide a sufficient timber supply to meet the market demand and help maintain a 

vibrant economy in Southeast Alaska.” By removing visual priority travel route designations and modifying 

the small OGR reserve, more timber was made available for this project especially in the roaded portion of the 

project area which allowed for more economical harvest this entry and in an area in relative proximity of 

facilities. 

For the Selected Alternative, the relocation of the small old-growth reserve (OGR) into the North Revilla 

Inventoried Roadless Area would provide about 322 acres of additional suitable and available old-growth 

timberlands within the project area. An additional 84 acres of suitable young-growth forest will be available 

in the future as the stands begin to provide a commercial product. This is the same as for Alternative 5 as 

analyzed in the DEIS and FEIS. Alternatives 1, 2, 3, 4 and 6 did not include a proposed modification of the 

OGR. More discussion is in Appendix A of this ROD. 

The second proposed Forest Plan amendment would remove visual priority route (VPR) designations, in order 

to meet less restrictive Forest Plan scenery integrity objectives. As a result, additional even-aged management 

and larger harvest units could be prescribed at this time, thereby increasing the timber harvest volume for this 

project and decreasing scenic quality. The same VPR designations have been removed in this decision as 

proposed for Alternative 5. See discussion under Issue 4 and in Appendix B of this ROD. 
Record of Decision

Issue 3 – Wildlife Habitat and Subsistence Use

Wildlife analysis areas (WAAs) are delineated by ADF&G for wildlife analysis for larger ranging animals. 

Although the project area only includes portions of WAAs 406 and 407, these delineations were used for most 

of the analysis for this issue including the effects on old-growth habitat. 

Most wildlife species on the Tongass inhabit old-growth forest for at least a portion of their life cycles or prey 

on species that inhabit old-growth forests (USDA 2008c, p. 3-220). Therefore, an analysis of productive old 

growth (POG) serves as an indicator for the analysis for many species. The analysis is conservative since it 

considered both clearcut and partial harvest acres as being clearcut even though 66 percent of the overstory 

old-growth trees would remain in the partial harvest units. Removal of POG increases habitat fragmentation 

and reduces interior POG effecting old-growth patch size. 

After harvest, the partial-harvest stands would retain old-growth characteristics and continue to develop 

structural diversity. As shown in Table 4, the Selected Alternative will result in an additional decrease of POG 

in WAAs 406 and 407 of about 2 percent or 1,587 acres. For high-volume productive old growth (HPOG) in 

these two WAAs, which is about 30 percent of the historic condition, the Selected Alternative will result in a 

decrease of about 1 percent from current conditions. High-volume, low-elevation (< 800 feet and on south 

aspect) POG is currently 3,968 acres, which is about a 35 percent reduction from 1954. The Selected 

Alternative will result in a decrease of about 3 percent in these two WAAs from current and 37 percent from 

historic for low elevation, high volume POG on south aspect, which is also considered to be deep-snow deer 

winter habitat. 

Saddle Lakes Timber Sale Record of Decision - Draft ROD  13
Saddle Lakes Timber Sale 

14  ROD Saddle Lakes Timber Sale Record of Decision - Draft 

Table 4. Cumulative change to average snow deer habitat (POG <1500’) and HPOG on all land ownerships in 

WAAs 406 and WAA 407

1954 Current Alt 2 Alt 3 Alt 4 Alt 5 Selected Alt Alt 6

Cumulative change to average snow deer habitat (POG <1500’) on all land ownerships in WAAs 406 and WAA 407\1

WAA 406

54,385 42,506 41,408 42,150 41,281 40,975 41,827 41,459

% change from current -3% -1% -3% -4% -2% -2%

% change from 1954 -22% -24% -23% -24% -25% -23% -24% 

WAA 407

28,932 23,379 22,609 22,914 22,53 22,291 22,471 22,612

% change from current -3% -2% -4% -5% -4% -3%

% change from 1954 -19.2% -22% -21% -22% -23% -22% -22% 

Total- Combined WAAs 

83,317 65,885 64,017 65,064 63,812 63,266 64,298 64,071

% change from current -3% -1% -3% -4% -2% -3%

% change from 1954 -21% -23% -22% -23% -24% -23% -23%

Cumulative change to HPOG all elevations on all land ownerships in WAAs 406 and WAA 407\2

WAA 406

41,994 29,557 29,119 29,459 29,057 28,932 29,523 29,133

% change from current -1% -1% -2% -2% -1% -1%

% change from 1954 -30% -31% -30% -31% -31% -30% -31% 

WAA 407

16,951 11,528 11,111 11,319 11,061 10,900 11,001 11,107

% change from current -4% -2% -4% -5% -5% -4%

% change form 1954 -32% -35% -33% -35% -36% -35% -35% 

WAAs 406 and 407

58,945 41,085 40,230 40,778 40,118 39,832 40,524 40,240

% change from current -30% -2% -1% -2% -3% -1% -2%

% change form 1954 -30% -32% -31% -32% -32% -31% -32%

Cumulative change to HPOG < 800 feet/south aspect on all land ownerships in WAAs 406 and WAA 407\3

WAA 406

4,194 2,775 2,723 2,769 2,729 2,723 2,739 2,741

% change from current -2% -1% -2% -2% -1% -1%

% change form 1954 -34% -35% -34% -35% -35% -35% -35%

WAA 407

1,937 1,193 1,165 1,178 1,134 1,098 1,103 1,134

% change from current -2% -1% -5% -8% -8% -5%

% change form 1954 -38% -40% -39% -42% -43% -43% -41%

WAAs 406 and 407

Total 6,131 3,968 3888 3,947 3,863 3,821 3,842 3,875

% change from current (-2%) (-1%) (-3%) (-4%) (-3%) (-2%)

Total % change -35% -37% -36% -37% -38% -37% -37%

1 - Numbers for other alternatives from changes in deer habitat where Average winter habitat = POG≤1,500 ft. elevation

2 - Numbers for other alternatives from Hairy Woodpecker table high-POG (SD5N, SD5S, and SD67) all elevations.

3 - Numbers for other alternatives from changes in deer habitat where Deep snow winter habitat = high-POG ≤800 ft. elevation on south 

aspect
Record of Decision

Corridors and Connectivity

The following corridors were identified within the Saddle Lakes project area where the Selected Alternative 

would reduce connectivity and limit the ability of land-based species to disperse or migrate. The Selected 

Alternative will affect these corridors less than Alternative 5, but more than Alternatives 2, 4, and 6. 

Alternatives 1 and 3 do not affect these corridors. Therefore the effects to corridors are discussed and 

compared to the effects analyzed under Alternative 5. The corridor numbers correspond to Saddle Lakes 

Timber Sale FEIS, Table 20 and Figure 7. 

Corridor 1 - Medium OGR in VCUs 7470 and 7440 and Naha LUD II: No effect. This corridor is partially 

maintained by the small OGR in 7470 and other old growth outside the harvest units. This maintains the 

landscape connectivity as required by the Forest Plan (Forest Plan p. 4-91and 2008 Forest Plan Amendment 

FEIS, p. D-8). 

Corridor 2- The small OGR in VCU 7470 to George Inlet Salt Chuck: The modification of this small OGR 

would reduce the corridor between Naha LUD II and George Inlet salt chuck. The Selected Alternative will 

clearcut units 301-308 and 310-312 within the corridor thus further reducing the connectivity but will partial 

harvest units 300 and 309 which should help to maintain some connectivity. The Ketchikan to Shelter Cove 

Road would further reduce the value of this corridor (See Figure 2). The width of the riparian management 

area along Salt Creek also helps maintain this corridor. 

Corridor 3- North Island Point Corridor: The Selected Alternative includes units 203, part of 204 and 207. 

Effects have been reduced from Alternative 5 by dropping part of units 204 and 224. 

Corridor 4- Corridor from high elevation to the beach between Gunsight Creek and Shelter Cove: No effect. 

Corridor 5- North Lemon Lake Corridor: The Selected Alternative would reduce this corridor by clearcutting 

units 8 and 9. Effects have been reduced from Alternative 5 by changing the clearcut prescription to partial 

harvest for units 1 and 152 north of this corridor. 

Corridor 6- North Saddle Lakes-Buckhorn Lake Corridor: Effects to this corridor have been mitigated by 

clearcut prescription to partial harvest for units 49 and 123 and dropping unit 122. 

Corridor 7- North Saddle Lakes to George Inlet Corridor: The Selected Alternative would not affect this 

corridor since the road to units 28 and 71 will not be constructed. Unit 71 has been dropped and the road to 

unit 28 has been rerouted. 

Corridor 8- West end of North Saddle Corridor: The Selected Alternative would reduce the corridor by 

clearcutting unit 46. No change from Alternative 5. 

Table 5. Elevational Connectivity in Modified Landscape LUD

Number of identified corridors

Alternative 

1 

Alternative 

2 

Alternative 

3 

Alternative 

4 

Alternative 

5 

Selected 

Alternative 

Alternative 

6 

Maintained in 

current 

condition

8 4 8 3 3 3 3 

Reduced in 

quality 0 4 0 5 5 5 5 

Saddle Lakes Timber Sale Record of Decision - Draft ROD  15
Saddle Lakes Timber Sale 

16  ROD

Modification of Small OGR in VCU 7470

All alternatives except Alternative 5 included the Forest Plan small OGR design for VCU 7470. The Selected

Alternative includes the same design as Alternative 5. 

The small old-growth reserve (OGR) in value comparison unit (VCU) 7470 will be redesigned as part of this 

Decision to be completely within the North Revilla Inventoried Roadless Area and the roaded portion 

currently in the OGR would be reallocated as a development LUD where timber harvest is allowed. The 

modified OGR exceeds the size and acres of POG requirements. Relocation of the OGR would reduce the 

overall acres of lower-elevation wildlife habitat by 173 acres, which is indicative of higher-value wildlife 

habitat. 

Connectivity between the Naha LUD II and George Inlet Salt Chuck would be further reduced by clearcutting 

units 301 through 308 and 310 through 312. Some connectivity will be maintained in both the partial harvest 

units and the Salt Creek stream buffer. Connectivity between the current OGR and the George Inlet Salt 

Chuck is already impacted by the presence of State land. There will be 0.5 miles less of Class I streams within 

the OGR. The modified OGR removes both the acres of young growth and miles of road that were within the 

Forest Plan OGR. The NFS road within the Forest Plan OGR is proposed to be connected to the Ketchikan

road system resulting in an increase of traffic. Relocating this OGR will increase the distance between the 

road and OGR. Relocating the OGR will then maintain an OGR in an area that would be more isolated and 

cause fewer disturbances to wildlife. 

The non-significant amendment to the Forest Plan necessary for the relocation of the small OGR is located in

in Appendix A of this document. 

Wildlife

Management indicator species (MIS) are species whose response to land management activities can be used to 

predict the likely response of other species with similar habitat requirements (Forest Service Manual [FSM] 

2631.3). The effects of the Selected Alternative on the Sitka black-tailed deer and Alexander Archipelago wolf 

are summarized here. The effects of the Selected Alternative to the other MIS is similar though probably less 

than for those effects for Alternative 5 as displayed in the FEIS, Chapter 2, Table 3, and discussed in Chapter 

3, Issue 3. 

Theoretical Deer Habitat Capability

Deer are an important sport and subsistence species in Southeast Alaska and the primary prey of wolves. 

Because populations are difficult to quantify due to the dense forest and harsh terrain in Southeast Alaska, a 

deer model was developed to estimate the theoretical deer winter habitat capability (DHC) based on four 

habitat conditions - quantity of old growth, elevation, estimated snow level, and aspect. Generally, low 

elevation (< 800 feet) and low snow (<10 inches), with southern aspects is considered to be most important 

for deer. Other indicators; deep snow, average snow, and non-winter habitat; were also analyzed since deer 

use all habitats. Reducing habitat capability may lead to a decline in the deer population and overall health, 

particularly following severe winters where deep snow persists. Deep, persistent snow is uncommon in the 

project area. Overall, the southern portion of Southeast Alaska is classified as receiving intermediate snow 

and generally mild winters. 

Saddle Lakes Timber Sale Record of Decision - Draft 
Record of Decision

Table 6. Reduction of the deer model habitat capability on NFS Lands1/ in WAAs 406 and 407 from the existing 

condition

Stand 

Age

Deer Habitat 

Capability 

(reduction

from historic) 

Deer Habitat Capability (% reduction from existing)

Historic Existing\ 

Alt. 1 Alt. 2 Alt. 3 Alt. 4 Alt. 5 Selected

Alternative Alt. 6

WAA 406

0 to 25 

years2/

3,276 2,521

(-23%)

2,482

(-2%)

2,505

(-1%)

2,479

(-2%)

2,472

(-2%)

2,481

(-2%)

2,485

(-1%)

26 to 200 

years3/

2,396

(-5%)

2,433

(-4%)

2,391

(-5%)

2,378

(-6%)

2396

(-5%)

2,400

(-5%)

WAA 407

0 to 25 

years2/

1,158 1,042

(-10%)

1,014

(-3%)

1,027

(-1%)

1,010

(-3%)

997

(-4%)

1,001

(-4%)

1,011

(-3%)

26 to 200 

years3/

978

(-6%)

995

(-5%)

971

(-7%)

954

(-8%)

960

(-9%)

974

(-7%)

Source: USFS, Tongass National Forest GIS. 

1 - NFS lands only. Partial harvest was modeled as clearcut. Habitat capability does not represent the actual deer population; it is used 

as a tool to compare Alternatives. 

2 - 0 – 25 years represents the initial effect of timber harvest.

3 - 26 – 200 years represents the effect of canopy closure (stem exclusion). 

Table 7. Cumulative change in the reduction of the deer habitat capability (DHC) on all land ownerships in WAAs 

406 and 4071/

Historic

Existing\ 

Alt. 1 Alt. 2 Alt. 3 Alt. 4 Alt. 5 Selected

Alternative Alt. 6

Deer Habitat Capability (% reduction from historic)

WAA 406

0 to 25 

years2/

3,568

2,521

(-29%)

2,482

(-30%)

2,505

(-30%)

2,479

(-31%)

2,472

(-31%)

2,481

(-31%)

2,485

(-30%)

26 to 200 

years3/

2,446

(-31%)

2,396

(-33%)

2,433

(-32%)

2,391

(-33%)

2,378

(-33%)

2,396

(-34%)

2,400

(-33%)

WAA 407

0 to 25 

years2/

2,465

1,042

(-58%)

1,014

(-60%)

1,027

(-58%)

1,010

(-59%)

997

(-60%)

1,001

(-59%)

1,011

(-59%)

26 to 200 

years3/

1,019

(-59%)

978

(-60%)

995

(-60%)

971

(-61%)

954

(-61%)

960

(-61%)

974

(-61%)

Source: USFS Tongass National Forest GIS.

1 - Historic capability was reconstructed for all ownerships using the best information available. Non-NFS lands were given zero current 

habitat capability per current model direction. Partial harvest was modeled as clearcut. Habitat capability does not equal actual deer; it is 

used as a tool to compare alternatives. 

2 - 0 – 25 years represents the initial effect of timber harvest

3 - 26 – 200 years represents the effect of canopy closure (stem exclusion). 

The effects on deer habitat capability of the Selected Alternative as modeled would occur immediately after 

timber harvest with clearcut areas producing forage but lacking snow interception, and partial-harvest stands 

having areas of forage interspersed with areas of snow interception. These conditions would change after 

Saddle Lakes Timber Sale Record of Decision - Draft ROD  17
Saddle Lakes Timber Sale 

18  ROD

about 25 years as the tree canopy cover closes diminishing light to the understory and reducing forage for 

deer in the clearcuts. Since the model has no coefficients for partial harvest, all planned units were considered 

as clearcuts.

The deer model estimates for WAAs 406 and 407 under the all alternatives and considering National Forest 

System lands only is shown in Table 5. Cumulative effects for those scenarios is shown in Table 6. 

Table 8. Cumulative change to deep snow winter habitat\1 on all land ownerships

Measure Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Selected 

Alternative Alt 6

Historic Percent Reduction From Historic Acres

WAA 406 - 

4,194 acres -34% -35% -34% -35% -35% -35% -35% 

WAA 407 - 

1,937 acres -38% -40% -39% -42% -43% -43% -42% 

1 - High-POG ≤800’ on south aspect

Wolves

Due to lack of actual population data, the deer model has been used to assess the ability of an area to support 

deer populations capable of maintaining sustainable wolf populations and meeting human harvest demands. 

No statistically reliable population estimates are available for GMU 1A, which includes the Saddle Lakes

project area, but ADF&G states that the wolf population in GMU 1A appears to be stable at this point. 

Deer Density 

In order to analyze land management scenarios and rank alternatives in terms of effects, relative changes in 

deer habitat capability are converted to a theoretical number of deer per square mile which can be summed to 

represent the total capability of a specific land area. The ‘deer multiplier’ model value is multiplied by a value 

analogous to deer carrying capacity scaled to density per square mile. Model-defined deer densities (deer/mi2

) 

analyzed do not represent actual populations and are not related to wolf viability, but represent the functioning 

of the predator-prey system dynamic (USDA 2008c, p. 3-282). 

Forest Plan Standards and Guidelines state to “Provide, where possible, of sufficient deer habitat capability to 

first maintain sustainable wolf populations, and then to consider meeting estimated human-deer harvest 

demands. This is generally considered to equate to the habitat capability to support a minimum of 18 deer per 

square mile. However, other factors (e.g., local knowledge) are considered by the biologist as well, rather than 

solely relying upon model outputs.” 

In 1954, estimates indicated that on National Forest System lands WAA 406 had the capability of supporting 

about 18 deer per square mile and WAA 407 about 17 deer per square mile. Currently WAA 406 supports an 

estimated 13 deer per square mile and WAA 407 about 16 deer per square mile. As a result of implementing

the Selected Alternative the density on National Forest System lands in WAA 406 is expected to remain at 

about 13 deer per square mile and in WAA 407 to decline to about 15 deer per square mile. At stem exclusion, 

deer in WAA 406 are estimated to decline to 12 deer per square mile and in WAA 407 to remain at 15 deer per 

square mile. 

On lands in all ownerships the 1954 estimated deer density in WAA 406 was about 18 deer per square mile 

and in WAA 407 about 24 deer per square mile. Currently, on all lands there are about 12 deer per square mile 

in WAA 406 and 10 deer per square mile in WAA 407. As a result of the Selected Alternative and at stem 

Saddle Lakes Timber Sale Record of Decision - Draft 
Record of Decision

ROD  19 

exclusion, the density on all lands in WAA 406 is expected to remain near 12 deer per square mile. As a result 

of the Selected Alternative, the deer density will remain the same in WAA 407 but drop to about 9 deer per 

square mile at stem exclusion.

Effects to wolves from reductions in deer habitat capability may occur under the Selected Alternative since 

the indicated deer density is less than 18 deer per square mile in the project area WAAs according to the

estimated deer model habitat capability. On both National Forest System lands and lands in all ownership, the

Selected Alternative will reduce the deer model habitat capability in the project area WAAs. The estimated 

reduction will be about 1 per deer square mile or less. Accordingly, there may some reduction in the ability of 

the project area WAAs to maintain both a sustainable wolf population and meet hunter demand based on the 

deer habitat capability alone. Reductions due to forest succession in previously harvested stands also have the 

potential to reduce the prey base (deer) for wolves. 

Roads

All action alternatives involve the construction of roads and will result in a temporary increase in road 

density. Roads associated with timber harvest may also increase the risk of hunting- and trapping-related wolf 

mortality by increasing human access. Road density effect on wolf mortality has not been an issue in WAAs 

406 and 407 in the past due to the lack of road connection to any community. However, since the project area 

may be road accessible from Ketchikan and Saxman in the near future, road densities below 1,200 feet in 

elevations were calculated to determine the effects of road access on potential wolf harvest. With the 

exception of the State’s proposed Ketchikan to Shelter Cove Road, all roads will be closed or 

decommissioned once timber harvest is complete. Public access will be allowed on these systems roads until 

they are stored. 

Table 9 compares the effects to deer density of the Selected Alternative with the alternatives in the FEIS. 

Table 9. Issue 3, Cumulative effects on wolves based on deer density and road density on all land ownerships

1954 Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Selected 

Alternative Alt 6 

Deer Density at stem exclusion

WAA 406 18 12 12 12 12 12 12 12

WAA 407 24 10 9 10 9 9 9 9

Total Road Density (mi/mi2) 

WAA 406 0 1.5 1.6 1.5 1.6 1.6 1.5 1.6

WAA 407 0 2 2.1 2.1 2.1 2.2 2.1 2.1

Subsistence 

See ANILCA section under findings for specific information on subsistence issues related to the Saddle 

Lakes Project.

Conclusion

The Selected Alternative has the second highest effects to wildlife habitat of all alternatives. Alternative 1 

ranks the highest overall in terms of least effects since it would maintain all current old-growth deer habitat. 

Of the action alternatives, Alternative 3 ranks highest in terms of least effects to deer habitat and populations 

followed by Alternatives 2, 6, and 4. Alternative 5 would have the greatest impact on wildlife habitat. 

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20  ROD

Table 10. Alternative comparison - Issue 4 – Scenery and Recreation 

Measure Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Selected 

Alternative Alt 6

Scenery

Silvicultural Method Acres of Harvest in High SIO1

Even-aged Management 0 0 0 0 173 146 0 

Uneven-aged management 0 0 0 0 4 26 0 

Silvicultural Method Acres of Harvest in Moderate SIO1

Even-aged Management 0 129 171 774 921 683 530

Uneven-aged management 0 589 27 148 61 140 185

SIO Miles of Road Construction

High 0 0 0.1 0.2 0.2 0.8 0.2

Moderate 0 3.8 3.5 11.9 12.2 9.7 9.7

Silvicultural Method Acres of Harvest in the Proposed

Saddle Lakes Recreation Area Viewshed1

Even-aged Management 0 6 0 462 526 396 215

Uneven-aged Management 0 400 32 109 62 108 132

Total Harvest 0 406 32 571 588 504 347

Effects of (VPR) Designation 

Removal Acres

Harvest in Areas that 

decreases in Scenic Integrity 

Objective (SIO)

0 0 0 1,285 1,642 1,246 743

Even-aged Management 0 0 0 1090 1494 1117 664

Uneven-aged Management 0 0 0 195 148 209 79 

Harvest in Areas with no 

change in Scenic Integrity 

Objective (SIO)

0 2,207 1,012 1,139 1,233 1,081 1,395

Even-aged Management 0 1055 816 1023 1100 785 989

Uneven-aged Management 0 1152 196 116 107 215 406 

Project Area that decreases in 

Scenic Integrity Objective (SIO) 0 0 0 8,270 8,750 8,705 6,810

Greater George/

Carroll Inlet Area 0 0 0 13,920 14,930 14,930 10,900

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Saddle Lakes Timber Sale Record of Decision - Draft ROD  21 

Measure Alt 1 Alt 2 Alt 3 Alt 4 Alt 5 Selected 

Alternative Alt 6

Recreational Opportunities

ROS Class Change in ROS Acres from Existing

Semi-Primitive Non-Motorized 0 0 0 -70 -70 0 0 

Semi-Primitive Motorized 0 0 0 0 -41 0 0 

Roaded Modified 0 0 0 70 111 0 0 

1 - The sum of harvest acres within high and moderate SIOs and within the proposed Saddle Lakes Recreation Area viewshed do not equal total harvest acres by alternative because 

some of these categories overlap. There is also additional harvest in other SIOs not represented in this table.
Saddle Lakes Timber Sale 

22  ROD

Issue 4 – Scenery and Recreation Opportunities

Scenery and recreational opportunities are considered together because scenic quality has a direct relationship 

with outdoor recreation opportunities. There are five visual priority routes (VPR)s in and adjacent to the 

Saddle Lakes project area including: Saddle Lakes Recreation Area, Harriet Hunt to Shelter Cove Connection 

Road, Shelter Cove Boat Ramp, Carroll Inlet, and George Inlet which were used for the scenery analysis. As 

part of this decision, all of these VPR designations will be removed through a non-significant Forest Plan 

Amendment, Appendix B of this document. 

Among action alternatives, the Selected Alternative would have the second greatest impacts to scenery and 

recreation opportunities with Alternative 5 having the most. Alternative 3 has the least effect followed by 2, 6 

and 4. The harvest proposed in the Selected Alternative does not meet Forest Plan Scenery Standards and 

Guidelines without a Forest Plan amendment to remove 5 VPRs. It is expected that 1,246 acres of harvest will 

take place in areas where the scenery integrity objectives (SIOs) are lowered as a result of the VPR 

designation removal and 8,750 acres of the project area will have a change in SIO. Lowering SIOs for an area 

means that more visual change is allowed. The Selected Alternative includes about 27 miles of road 

construction to access timber harvest units. After completion of harvest activities, these roads would be 

available for non-motorized activities such as hiking. The modification to the small OGR along Road 

8300000 will reduce opportunities for access to recreational activities within 173 acres of old-growth forest. 

Because of the change in silvicultural prescription from clearcut to 33 percent removal in units 149 and 300, 

there is not expected to be any effects to the recreation opportunity spectrum, which portrays the combination 

of recreation activities, settings and experience expectations in the project area. 

The comparison between alternatives affecting recreation and scenery (Issue 4), including the Selected 

Alternative is shown in Table 10. 

Other Environmental Consequences

All resources were evaluated for the effects of the Selected Alternative. Analyses of the effects on other 

resources for the Selected Alternative, including the cumulative effects with other projects, are summarized in 

the FEIS with additional information in the project record.

Alternatives Considered in Detail 

Six alternatives were considered in detail in the DEIS. All alternatives, with the exception of Alternative 1, the 

no-action alternative, respond to the purpose and need. All action alternatives respond to the issues identified 

in varying degrees as discussed in the Saddle Lakes Timber Sale FEIS. A brief summary of each of the 

alternatives analyzed in detail in the FEIS and how it equates to the Selected Alternative is discussed below. 

More specific details, such as acres by silvicultural system, logging system and road constructed for timber 

harvest access is in Chapter 2 of the FEIS. 

Items Common to All Action Alternatives

The following items are common to all action alternatives including the Selected Alternative. 

• Reconstruction of the Shelter Cove LTF

• Fish barrier modification on lower Salt Creek

• Authorization of the State of Alaska right-of-way on NFS roads for the Ketchikan to Shelter Cove Road

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Record of Decision

Alternative 1 - No Action

This alternative proposed no new Forest Service timber harvest or road construction in the project area. It 

does not preclude timber harvest from other areas or from the project area in the future. Council on 

Environmental Quality (CEQ) regulations [40 CFR 1502.14(d)] require that a no-action alternative be 

analyzed in every EIS.

This alternative represents the existing condition serving as a baseline for comparing the action alternatives 

for resources. This alternative does not meet the purpose and need of supplying timber. 

Alternative 2 - Proposed Action

The emphasis of Alternative 2 was to equally address the issues identified for the project. Silvicultural 

prescriptions were developed to meet scenic integrity objectives (SIOs) for the project area to avoid removal 

of VPR designations. Design and locations of proposed units were designed and located to minimize or avoid 

the effects to wildlife corridors and avoiding units with the lesser round leaf orchid populations. Alternative 2 

harvests the second-least amount of timber and build the second-least amount of road of the action 

alternatives. 

Alternative 3

Alternative 3 addresses Issue 3 (Wildlife Habitat and Subsistence Use) and Issue 4 (Scenic Integrity and 

Recreational Opportunities) while allowing for a lower level of timber harvest than the other action 

alternatives. Under this alternative, impacts to wildlife were minimized by selecting logging system and 

silviculture prescriptions that would result in less old growth removal and less road construction. Old-growth 

landscape connectivity corridors are maintained and wildlife elevational corridors are retained within the 

Modified Landscape LUD. Lesser round leaf orchid are present in units proposed for harvest under this 

alternative. The prescriptions chosen for Alternative 3 also reduce impacts to scenery, which minimizes 

effects on current and future recreational opportunities in the project area and meet scenic integrity objectives 

(SIOs) for Modified Landscape LUDs. Alternative 3 harvests the least amount of timber and builds the least 

amount of road of the action alternatives.

Alternative 4

Alternative 4 addresses Issue 1 (Timber Economics) and Issue 2 (Timber Availability). This alternative was 

designed to identify the maximized timber harvest with a focus on achieving the highest economic value. 

Removal of four out of five VPR designations was proposed to increase the amount of timber harvest at this 

time for this project. Alternative 4 avoids units with lesser round leaf orchid populations and has the same 

effects as Alternative 2. Alternative 4 harvests the second-highest volume of timber and builds the secondhighest miles of road of the action alternatives. This was identified as the preferred alternative for the DEIS, 

but based on further review, analysis and public comment, it was not selected for the intended decision. 

Alternative 5 

Alternative 5 was designed to maximize timber harvest in the Timber Production and Modified Landscape 

LUDs designed to address primarily Issue 2 (Timber Availability) and also Issue 1 (Timber Economics). To 

maximize the timber volume, various approaches were incorporated. Low-volume units meeting suitable 

forest criteria were included. The small OGR in VCU 7470 was proposed to be modified completely within 

the North Revilla IRA so that the roaded portion could be reallocated as Modified Landscape LUD allowing 

timber harvest. Removal of all VPR designations was proposed to increase the amount of timber harvest for 

this project. Modifications to the OGR increase effects to lesser round leaf orchid as populations are known in 

units 111, 307 and 311. Also Alternative 5 maximized the amount of conventional (cable and shovel) logging 

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24  ROD

systems and the use of even-aged management (clearcut). Alternative 5 harvests the most timber and builds 

the most road of the action alternatives. 

Alternative 6 

Alternative 6 was designed to address Issue 1 (Timber Economics), Issue 2 (Timber Availability) and Issue 4 

(Scenic Integrity and Recreational Opportunities). The objectives were to reduce the effects to the dispersed 

camping and other activities adjacent to the dispersed Saddle Lakes Recreation Area while trying to maintain 

the most economic timber harvest. Removal of three of five VPR designations was proposed to increase the 

amount of timber harvest for this project. VPR designations for Saddle Lakes Recreation Area and Shelter 

Cove boat ramp were maintained to reduce the effects to scenery and recreation. This alternative avoids units 

with the lesser round leaf orchid populations and has the same effects as Alternative 2. Alternative 6 harvests 

an intermediate volume of timber and builds the median miles of road of the action alternatives. 

Environmentally Preferred Alternative

Alternative 1, the no-action alternative, would result in no environmental disturbance and is therefore the 

environmentally preferred alternative. Of the action alternatives, Alternative 3 is the environmentally 

preferred alternative for the project area and was designed to minimize impacts to wildlife, habitat and 

scenery resources. This alternative retains the most POG, has the lowest increase in total road density, and 

would cause the least amount of soil disturbance. 

Alternatives Eliminated From Further Consideration

Several additional alternatives were proposed internally or by the public during scoping and review of the 

Saddle Lakes Timber Sale FEIS. These alternatives, while considered, were not carried forward for detailed 

analysis and included small sales only alternative, an alternative that proposed harvest in roaded portions of 

inventoried roadless areas, an alternative to not harvest Pacific silver fir, and an alternative to not harvest 

healthy yellow-cedar. More discussion of these alternatives is located in Chapter 2 (p.24) of the FEIS, 

Alternatives Considered but Eliminated from Detailed Study. 

Public Involvement

Public involvement is a key component of the planning process; it has been instrumental in identifying issues 

and developing alternatives for the Saddle Lakes Timber Sale. Public meetings, Federal Register notices, 

newspaper ads, government-to-government consultation, group and individual meetings, and the Tongass 

National Forest Schedule of Proposed Actions (SOPA) were used to seek input for this project. 

Since project initiation in 2012, informal meetings were held with members of the public and stakeholder 

groups. Meetings, reviews, and professional dialogue also occurred with other federal and State agencies 

during this period. Government-to-government consultation with federally recognized tribal governments and 

tribal corporations are ongoing through monthly project updates. 

A complete list of all members of the public, groups, and agencies that received a copy of the DEIS is located 

in Chapter 4 (p.465) of the DEIS. The responses to comments are printed in Appendix D of the FEIS. 

Submitted literature and opposing viewpoints are available in the project record and online. Documentation of 

the subsistence hearings is located in the project record. Chapter 1 of the Saddle Lakes Timber Sale FEIS 

provides more detailed information concerning public involvement as well as the timing of public 

involvement activities that occurred prior to the Notice of Availability and release of the DEIS.

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Record of Decision

The Notice of Availability for the DEIS was published in the Federal Register on September 12, 2014, starting 

the 45-day public comment period. A legal notice was published on September 12, 2014 in the Ketchikan 

Daily News, the official newspaper of record. 

A project open house and formal subsistence hearings were held in Ketchikan on 16 October 2014. This 

meeting was announced via intergovernmental communication with local tribal governments, on the radio, 

published in the Ketchikan Daily News and notices were posted in prominent locations along the length of the 

main corridor throughout the populated portion of Revillagigedo Island. 

From 2012 to 2014, informal meetings were held regarding the project with members of the public and 

stakeholder groups. During the same period, government-to-government consultation including monthly 

updates on the project was conducted with federally recognized tribal governments and tribal corporations. 

Meetings, reviews, and professional dialogue also occurred with other federal and State agencies during this 

period. 

Project Record

The project record includes the FEIS, materials produced or used during the environmental analysis of this 

project, such as relevant references, data and analysis plus all material incorporated by reference, such as the 

Forest Plan and supporting documentation. The project record is available for review at the Ketchikan-Misty 

Fiords Ranger District Office and available electronically upon request. 

Mitigation

The analysis documented in the FEIS discloses the possible adverse effects of implementing the actions 

proposed under each alternative. Forest Plan Standards and Guidelines were formulated to mitigate or reduce 

these effects. This direction was applied in the development of the project alternatives, including the Selected 

Alternative, and in the design of the harvest units and roads. The Saddle Lakes FEIS, Appendix C and unit 

and road cards discuss specific mitigation measures for the project. 

As part of my decision, I have included the following mitigation measures for the Selected Alternative. 

To reduce the potential of the spread of invasive plant species:

1. Require contractors to access rock material that is free of any high priority invasive plants (see Appendix

A in Invasive Plant Risk Assessment for list of species) from existing quarries prior to constructing new

roads. All rock and fill sources would be inspected by certified personnel.

a. If any rock sources become contaminated with high-priority species and certification cannot be

attained without treatment or avoidance methods, consider the use of weed infested rock for reconstructing existing roads only.

b. Rock material free from high-priority species would be required on all new road constructions

and new landings.

2. Monitor the newly constructed roads, the active quarries, and the project area for at least 3 years after the

project for new invasive plant introductions.

3. Eradicate or control any newly introduced high-priority invasive plant species not currently in the project

area after the project completion, and prior to closing temporary roads as part of the District 5-year

program of work for invasive species management. Prioritize controlling any new populations relative to

other populations of high-priority species needing treatment on the District. This recommendation could

change if the road from Ketchikan is completed, as eradication may be impossible for some species once

the road is connected.

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26  ROD

4. Washing of off-road equipment and road brushers brought to the LTF from other locations will be

required until completion (or imminent completion) of the State road connecting the City of Ketchikan

and Shelter Cove Road System.

To mitigate the disturbance on known black bear dens: 

1. Three active black bear dens were found within units during field reconnaissance of the project area. As a

protection measure, two unit boundaries, units 64 and 123 in the Selected Alternative will be adjusted to

avoid known active bear dens with a 300-foot buffer. Unit 116 containing the third den site was removed

under the Selected Alternative modifications.

Monitoring

Monitoring involves gathering data and information and observing the results of management activities. 

Monitoring activities can be divided into project-specific and Forest Plan monitoring and is required under 

NFMA to evaluate Forest Plans (36 CFR 219.110). Chapter 6 of the Forest Plan includes monitoring activities 

to be conducted as part of Forest Plan implementation. Monitoring of the Selected Alternative will be done 

during implementation and as part of the Forest Plan monitoring program. Monitoring items that apply to the 

Selected Alternative are part of this decision and will be implemented as documented in the Forest Plan. 

Log rafting activities will be monitored periodically by Forest Service archaeologists and sale administrators 

throughout the duration of the project to ensure protection of the fish trap. Log rafting and storage will be 

allowed at approved locations and positioned away from the fish trap. Activities will be monitored to ensure 

they do not affect cultural resources or historic properties through soil disturbance, rutting, compaction, and 

erosion. Monitoring will address issues of additional use that may increase the potential for deliberate looting 

or inadvertent disturbance of fragile sites in or near the project area.

Findings Required By Law

Alaska National Interest Lands Conservation Act (ANILCA) of 1980; Section 810

Section 810 (a)(3) of ANILCA requires that when a use, occupancy, or disposition of public lands may result 

in a significant possibility of a significant restriction, a determination must be made whether (1) such a 

restriction is necessary, consistent with sound management principles for the utilization of public lands, (2) 

the proposed activity involves the minimum amount of public lands necessary to accomplish the purposes of 

the use, and (3) reasonable steps will be taken to minimize adverse impacts on subsistence uses and resources 

resulting from the actions. Using the information described in the FEIS and ROD, the alternatives were 

evaluated for potential effects on subsistence uses and needs.

Subsistence Evaluation and Findings

Consistent with Section 810 of ANILCA, the Saddle Lakes project area was evaluated for potential effects on 

subsistence. ANILCA 810 subsistence hearings were conducted in Ketchikan on 16 October, 2014. Based on 

the evaluation hearings, and findings in the 2008 Forest Plan, the Saddle Lakes project may have a significant 

possibility of a significant restriction of subsistence uses on deer due to changes in abundance and distribution 

and/or competition. If constructed, the Ketchikan to Shelter Cove Road would increase access to deer possibly 

affecting hunter demand by both subsistence and sport hunters and/or the amount of competition in the 

Saddle Lakes project area. Because of these reasons, I have determined that the Selected Alternative may 

result in a significant possibility of a significant restriction of subsistence uses of deer, due to potential 

effects on abundance, distribution, and on competition. This determination is based on an anticipated increase 

in human population, an associated increase in subsistence activities, and the capability of the habitat to 

produce deer. 

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Record of Decision

Based upon community use information and other resource analysis, the Selected Alternative will not result in 

a significant possibility of a significant restriction of bear, furbearers, marine mammals, waterfowl, salmon, 

other finfish, shellfish and plant foods such as roots and berries.

As a result of this finding, the Forest Service will notify the appropriate State agencies, local communities, the 

Southeast Alaska Federal Subsistence Regional Advisory Council, and State Fish and Game Advisory 

Committees.

Necessary and Consistent with Sound Management of Public Lands

The Selected Alternative has been reviewed to determine whether it is necessary and consistent with sound 

management of public lands. In this regard, the National Forest Management Act, the Alaska National Interest 

Lands Conservation Act (ANILCA), the Tongass Timber Reform Act, the Wilderness Act, the Tongass Land 

and Resource Management Plan, and the Alaska State Forest Resources and Practices Act have been 

considered. 

ANILCA placed an emphasis on the maintenance of subsistence resources and lifestyles. However, this Act 

also required the Forest Service to make timber available for harvest from the Tongass National Forest. The 

Forest Plan determined which uses are suitable for various areas of land within the Forest through land use 

designation (LUD) and management prescriptions. 

The Forest Plan allocated many important subsistence use areas to LUDs that do not allow timber harvest. 

The Forest Plan has determined that the Saddle Lakes project area should be managed mostly for varying 

levels of timber production (Timber Production LUD and Modified Landscape LUD) but with recognition of 

the other resource uses (see Forest Plan, Chapter 3). The Selected Alternative will help achieve some of these 

multiple-use management objectives in the Forest Plan. 

Based on the analysis presented in the Saddle Lakes FEIS, the findings in this ROD and the analysis for 

the Forest Plan, I have determined that the Saddle Lakes project is necessary and consistent with sound 

management principles for the utilization of public lands. 

Amount of Public Land Necessary to Accomplish the Proposed Action

I have determined that the amount of land necessary to implement the Selected Alternative, considering 

sound multiple-use management of public lands, is the minimum necessary to accomplish the purpose of 

this project. The entire forested portion of the Tongass is used by at least one rural community for 

subsistence deer hunting, at a minimum. It is not possible to avoid all of these areas in implementing 

resource use activities, such as timber harvesting and road construction, and attempting to reduce effects in 

some areas can mean increasing the use of others. 

The current Forest-wide Standards and Guidelines and LUD prescriptions provide for management or limit 

activities in many of the areas that are most important for subsistence uses, such as beaches and estuaries, and 

areas with high fish and wildlife habitat values. 

Reasonable Steps to Minimize Adverse Impacts to Subsistence Uses and Resources

Subsistence use is addressed specifically in a Forest-wide Standard and Guideline, and subsistence resources 

are covered by the Forest Plan Standards and Guidelines for wildlife, fish, riparian areas, and biological 

diversity, among others. Fish and wildlife habitat productivity will be maintained at the highest level possible 

for the Selected Alternative, consistent with the overall multiple-use goals and improved protection of the 

Forest Plan. The extent and location of the subsistence use in the project area make it impossible to 

completely avoid subsistence areas during timber harvest. However, large areas of deer habitat are protected 

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28  ROD

in old-growth habitat reserves, riparian, beach buffers and other non-development LUDs. Fish habitat is 

protected in each alternative through the application of Forest Plan Standards and Guidelines. 

Bald and Golden Eagle Protection Act of 1940 (as amended) 

In conjunction with the National Bald Eagle Guidelines, the USFWS Alaska Region (USFWS 2009a) has 

identified step-by-step guidelines to assist in determining if activity near an eagle nest is likely to “take” or 

disturb bald eagles. 

Analysis concluded that no activities are proposed within disturbance avoidance zones listed in the USFWS 

conservation measures for avoiding take, under any alternative. Therefore, I have determined that there 

would be no direct or indirect effects on bald eagle habitat or bald eagles under the Selected Alternative

with required timing restrictions. Because there are no direct or indirect effects to eagles, there will be no 

take and a permit will not be necessary as described in 50 CFR § 22.26.

Clean Air Act of 1970 (as amended) 

I have determined that emissions from the implementation of the Selected Alternative will be of short 

duration and are not expected to exceed State of Alaska ambient air quality standards (18 AAC 50). 

Clean Water Act (1977, as amended) 

I have determined that the Selected Alternative will comply with the Clean Water Act and meet the goals of 

Alaska’s water quality standards. Clean Water Act Sections 208 and 319 address nonpoint source pollution 

caused by activities such as timber harvest. The site-specific application of best management practices 

(BMPs), with a monitoring and feedback mechanism, is the approved strategy for controlling nonpoint 

source pollution as defined by Alaska’s Nonpoint Source Pollution Control Strategy. In 1997, the State of 

Alaska approved the BMPs in the Forest Service’s Soil and Water Conservation Handbook as consistent 

with the Alaska Forest Resources and Practices Regulations. The BMPs are incorporated into the Tongass 

Land Management Plan. 

The Forest Service recently issued National Core BMPs. Directives for using these BMPs are currently in

development. The Saddle Lakes project will implement the most up-to-date BMP guidance. Appendix C of 

the FEIS includes a crosswalk that displays the relationship between the Alaska Region BMPs and the 

National Core BMPs. 

Forest roads, as defined by US Army Corps of Engineers guidance, are exempt from Clean Water Act Section 

404 permitting requirements only if they are constructed and maintained in accordance with best management 

practices to assure that flow and circulation patterns and chemical and biological characteristics of the waters 

are not impaired (404)(f)(1)(E). The BMPs are specified in 33 Code of Federal Regulations (CFR) 323. These 

specific BMPs have been incorporated into the Forest Service’s BMP 12.5.

Endangered Species Act (ESA) of 1973 (as amended) 

A Biological Assessment/Biological Evaluation (BA/BE) was prepared for the Saddle Lakes project as 

required under Section 7 of the Endangered Species Act (ESA), as amended, and the USDA Forest Service 

(USFS) threatened, endangered, and sensitive plant and animal species policy (FSM 2670). Threatened, 

endangered, and candidate species potentially occurring in the project area were identified through 

consultation with the U.S. Fish and Wildlife Service (USFWS) and the National Marine Fisheries Service 

(NMFS). Confirmation of the threatened and endangered species list was received from NMFS on June 07, 

2013. Humpback whales are the only federally listed species known to occur near the project area.

The BA/BE was sent to the U.S. Fish and Wildlife Service (USFWS) and National Marine Fisheries 

Service (NMFS) as part of the Section 7 consultation under the Endangered Species Act on July 23, 2014. 

I concur with the final determination of “Not likely to adversely affect” made for humpback whales and

Saddle Lakes Timber Sale Record of Decision - Draft 
Record of Decision

“may adversely impact individuals, but not likely to cause a trend to federal listing or a loss of viability in 

the Planning Area nor cause a trend toward federal listing” for goshawks. Other species analyzed had a 

determination of no effect or no impact. 

On April 10, 2015, the U.S. Fish and Wildlife Service announced its 90-day finding on a petition to list 

yellow-cedar as endangered or threatened under the Endangered Species Act. Based on its review, the Service 

finds that the petition, dated June 24, 2014, presents substantial information indicating that listing this species 

may be warranted. The Service is seeking scientific and commercial data and other information on the status 

of and threats facing the yellow-cedar throughout all of its range through a 60-day public information period 

which will assist in a future status review.

Based on the results of the status review, the Service will issue a 12-month finding on the petition, which will 

address whether listing the species as threatened or endangered is warranted, as provided in section 4(b)(3)(B) 

of the Endangered Species Act. 

Federal Cave Resource Protection Act of 1988 

There are no known caves located in the project area. 

Forest Service Transportation Final Administrative Policy (Roads Rule) 

The FEIS and this ROD are prepared to be consistent with the Forest Service Transportation Final 

Administrative Policy and the Tongass National Forest Level Roads Analysis (2003), KMRD Access and 

Travel Management (2008) and the Saddle Lakes Timber Sale project level analysis (2013). I have determined 

that the proposed road system is “the minimum road system needed for safe and efficient travel and for 

administration, utilization, and protection of National Forest System lands" (36 CFR 212.5). 

Magnuson-Stevens Fishery Conservation and Management Act 

The potential effects of the project on Essential Fish Habitat (EFH) were included in Chapter 3 of the DEIS

and the FEIS. This discussion includes reference to the Magnuson-Stevens Fisheries Conservation Act that 

requires the Forest Service to consult with the National Marine Fisheries Service (NMFS) on projects that 

may affect EFH. It also includes a description of EFH in the project area, a description of the proposed 

activities, an analysis of the potential adverse effects of the actions on EFH and the managed species, 

Forest Service conclusions on the effects of the action on EFH and a description of the measures that will 

protect these essential habitats. 

I have reviewed the potential effects of the project on EFH discussed in the FEIS Chapter 3 and I have 

determined that this project may adversely affect EFH (FEIS p. 255).

The DEIS was provided to the NMFS on 12 September 2014 to formally initiate the consultation process

according to the agreement dated June 26, 2007 between the Forest Service and the National Marine Fisheries 

Service. As of 26 March, 2015, (197 days) no response from NMFS was received. According to the June 2007 

agreement (EFH Consultation Process, Item 5) on p. 4; if NMFS does not respond within the established 

comment period [45 days for an EIS] without a FS-approved time extension, consultation is ended and no 

further correspondence is necessary. NMFS has chosen not to comment on the Saddle Lakes Timber Sale 

project concluding the consultation. 

Marine Mammal Protection Act of 1972 

Actions authorized in the Selected Alternative will not have a direct, indirect, or cumulative effect on 

marine mammals. Marine mammal viewing guidelines administered by the National Marine Fisheries 

Service (NMFS) and enforced by the Coast Guard are sufficient for their protection. Contractors, purchasers 

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30  ROD

National Forest Management Act (NFMA) of 1976 (as amended) 

The National Forest Management Act (NFMA) requires specific determinations in the ROD: consistency with 

existing Forest Plans, a determination of clearcutting as the optimal method of harvesting, if used, and 

specific authorizations to create openings over 100 acres in size. 

Information and rationale used to develop unit prescriptions is shown on unit cards located in the project 

record. 

Forest Plan

The Saddle Lakes Timber Sale FEIS is tiered to the 2008 Forest Plan Amendment FEIS in accordance with 40 

CFR §1508.28. The decision for the Forest Plan was signed on January 23, 2008. This Plan was developed 

under the 1982 planning rule. A Forest Plan amendment is currently being analyzed but a DEIS is not has not 

been released at this time. The Saddle Lakes Timber Sale is a Category 3 project “Timber sale projects for 

which a Draft Environmental Impact Statement has not been released for public comment before the effective 

date of the Forest Plan”. These projects shall be based on the amended Plan and will be consistent with all 

applicable management direction (Forest Plan ROD, p. 70). 

I have determined that this decision, the Saddle Lakes Timber Sale FEIS, and all analysis for the FEIS are 

consistent with the Forest Plan. Non-significant Forest Plan Amendments, as described on page 5-3 of the 

Forest Plan, are attached to this ROD for the modification to the small OGR in VCU 7470 and the removal of 

VPR designations. Both of these actions are allowed by the Forest Plan direction. 

Clearcutting as the Optimal Method of Harvesting:

The Forest Plan (pp. 4-71 to 4-72) and 1997 Forest Plan EIS (Appendix G, pp. G-7 to G-9) give guidance on 

when to use even-aged management. Clearcutting is used to preclude or minimize the occurrence of

potentially adverse impacts such as to remove or reduce mistletoe infestations, logging damage or other

factors affecting forest health. Specific information and rationale for use of this prescription is shown in the 

silvicultural prescriptions and unit cards (both located in the project record) and in Chapter 3 of the FEIS. I 

have determined that where used, this prescription is the optimal method of harvesting related to sitespecific considerations as described above. 

Harvest Openings over 100 Acres in Size:

The Selected Alternative includes two harvest openings that exceed 100 acres in size. Each group of units 

contains unit designs that best utilize topography and available logging systems to avoid isolation of suitable 

timber and have the greatest impact on forest health. These openings also reduce the overall costs of harvest 

activities over unit block designs that limit opening sizes to 100 acres or less. This complies with the direction 

in the Forest Plan pages 4-72 and FSM 2400-2002-1. Effects of created openings were considered in the 

analysis for Alternative 5. The unit groups and overall acreages are shown in Table 11. 

Table 11. Unit group information for openings over 100 acres for the Selected Alternative

Unit Group Total Opening Size (acres)

31, 33, 39, 40, 41, 113, 114 126

111, 301, 302, 303, 305, 306, 307, 308, 311 128

Saddle Lakes Timber Sale Record of Decision - Draft 

and employees will be required to follow provisions on Marine Wildlife Guidelines, including special prohibitions 

on approaching humpback whales in Alaska as defined in 50 CFR 224.103. 
Record of Decision

National Historic Preservation Act (NHPA) of 1966 (as amended) 

Heritage resource surveys of various intensities were conducted in the analysis area in accordance with the 

Regional Inventory Strategy. A finding of “no historic properties affected” was recommended on 30 

September 2013 for all alternatives for the Saddle Lakes project. I have determined that, under the terms of 

the existing programmatic agreement with the Alaska State Historic Preservation Officer and the Advisory 

Council on Historic Preservation (USDA 2002, as amended 2010), “the Forest may proceed with the 

undertaking in lieu of a consensus determination of eligibility pursuant to 36 CFR 800.4.” 

Tongass Timber Reform Act (TTRA) of 1990 

Section 103 of the TTRA along with Forest Plan Riparian Standards and Guidelines and best management

practices (BMPs) apply to the Selected Alternative for the protection of all stream classes. No commercial

timber harvest will occur within 100 feet of any Class I stream or any Class II stream flowing directly into 

a Class I stream. I have determined that this project is in compliance with relevant provisions of TTRA.

Timber harvested under the Selected Alternative will provide part of the timber supply to the Tongass 

National Forest’s timber program as stated in Section 101 of TTRA “... the Secretary shall, to the extent 

consistent with providing for the multiple use and sustained yield of all renewable forest resources, seek to 

provide a supply of timber from the Tongass National Forest which (1) meets the annual market demand for 

timber from such forest and (2) meets the annual market demand from such forest for each planning cycle.” 

Executive Orders 

Executive Order 11988 (Floodplains) 

Executive Order 11988 directs federal agencies to take action to avoid, to the extent possible, the long- and 

short-term adverse effects associated with the occupancy and modification of floodplains. 

The Selected Alternative does not involve floodplain occupancy. Floodplains are excluded from harvest units 

under Forest Plan Riparian Standards. 

The amount of road in floodplains will be minimized but cannot be completely avoided. Roads crossing 

floodplains have been designed to pass floods in accordance with BMP 14.17 (FSH 2509.22). Road cards 

provide site specific details. 

Executive Order 11990 (Wetlands) 

Executive Order 11990 requires federal agencies to avoid, to the extent possible, the long and short-term 

adverse effects associated with the destruction or modification of wetlands. Road construction through 

wetlands is avoided to the extent practicable. Where wetlands cannot be avoided, road construction will 

adhere to State-approved BMPs, which include at a minimum the federal baseline provisions in 33 Code of 

Federal Regulation (CFR) 323. 

About 31 acres of wetlands will be lost due to road construction under the Selected Alternative. In some areas, 

soil moisture regime and vegetation composition or structure may be altered due to road construction; 

however, adjacent acres will still be classified as wetlands and function as wetlands in the ecosystem. 

Executive Order 12898 (Environmental Justice) 

Executive Order 12898 directs federal agencies to address whether a disproportionately high and adverse 

human health or environmental impact on minority populations, low-income populations, or Indian tribes is 

likely to result from the proposed action and any alternatives. This order also directs agencies to consider 

patterns of subsistence hunting and fishing when an agency action may affect fish or wildlife. 

Saddle Lakes Timber Sale Record of Decision - Draft ROD  31
Saddle Lakes Timber Sale 

32  ROD

None of the alternatives are expected to have a disproportionately high and adverse effect on the health or 

well-being of the minority or low-income populations that use the project area. Any changes in consumption 

patterns and wild food resources, as well as other project effects, would be equally applicable to the general 

population. 

Executive Order 12962 (Aquatic Systems, Recreational Fisheries) 

Executive Order 12962 requires federal agencies to evaluate the effects of proposed activities on aquatic 

systems and recreational fisheries. 

The Selected Alternative minimizes the effects on aquatic systems through project design, application of 

standards and guidelines, BMPs, and site-specific mitigation measures. Recreational fishing opportunities will 

remain essentially the same as the current condition. 

Executive Order 13007 (Indian Sacred Sites) 

Executive Order 13007, Indian Sacred Sites, provides presidential direction to federal agencies to give 

consideration to the protection of American Indian sacred sites and allow access where feasible. 

Tribal governments or their authorized representatives have not identified any specific sacred site locations in 

the project area. 

Executive Order 13112 (Invasive Species) 

Executive Order 13112 requires federal agencies (in part) to evaluate whether the proposed activities will 

affect the status of invasive species, and to not carry out activities that promote the introduction or spread of 

invasive species unless it has determined that the benefits of such action outweigh the potential harm caused 

by invasive species, and that all feasible and prudent measure to minimize risk of harm will be taken in 

conjunction with the actions. 

The Selected Alternative implements specific measures to minimize the introduction and spread of invasive 

species. 

Executive Order 13175 (Consultation and Coordination with Indian Tribal 

Governments) 

Executive Order 13175 directs federal agencies to respect tribal self-government, sovereignty, and tribal 

rights, and to engage in regular and meaningful government-to-government consultation with tribes on 

proposed actions with tribal implications. 

Throughout the span of the Saddle Lakes project, the Ketchikan-Misty Fiords District Ranger has

communicated monthly through newsletters, council meetings and informal discussions with the Ketchikan 

Indian Community, Organized Village of Saxman, and Metlakatla Indian Community, described in Chapter 1 

of the FEIS. Tribal consultation does not imply that the tribes endorse the Selected Alternative or any of the 

alternatives. 

Executive Order 13186 (Migratory Birds) 

The Migratory Bird Treaty Act of 1918 (amended in 1936 and 1972) prohibits the taking of migratory birds, 

unless authorized by the Secretary of Interior. 

The decision will not have a significant direct, indirect, or cumulative effect on any migratory bird species in 

the project area. 

Saddle Lakes Timber Sale Record of Decision - Draft 
Record of Decision

ROD  33 

Executive Order 13443 (Facilitation of Hunting Heritage and Wildlife Conservation) 

Executive Order 13443 directs federal agencies to facilitate the expansion and enhancement of hunting 

opportunities and the management of game species and their habitat. The analysis considered and disclosed 

the effects on hunting activities. 

The Selected Alternative will maintain the current hunting opportunities by adhering to the Forest Plan 

Standards and Guidelines that maintain habitat for hunted species. 

Federal and State Permits 

Federal and State permits necessary to implement the authorized activities are listed at the end of Chapter 1 in 

the FEIS. 

Implementation Process and Process for Considering Changes and New 

Information 

Unit and road cards are an integral part of the decision as they document specific resource concerns, 

management objectives, and mitigation measures to govern the layout of the harvest units and construction of 

roads. These cards are used during implementation process to ensure that applicable standards and guidelines 

are met and that resource effects are not greater than those described in the FEIS. 

Minor changes are expected during implementation to better meet on-site resource protection objectives and 

improve logging system efficiency. This will usually entail adjusting the boundary to coincide with logical 

logging setting boundaries. Proposed changes to the authorized project actions will be subject to NEPA, 

NFMA, and other laws concerning such changes. 

The changes will be within the direction in Forest Service Manual (FSM) 2430 and Forest Service Handbook 

FSH 2409.18. This direction provides a link between project planning and implementation. This ensures the 

proper execution of the decision, while meeting environmental standards, and mitigations approved by this 

decision. 

Changes made during implementation will be reviewed, documented, and approved by the Responsible 

Official through the Tongass Change Analysis process described in FSH 1909.15-2009-1. 

I will determine whether the proposed change is a substantially different than the Selected Alternative as 

approved, and whether the change is relevant to environmental concerns. Cumulative impacts of proposed 

changes will also be considered. 

The implementation unit and road cards are incorporated into the contract. Sale administrators and road 

inspectors enforce contract requirements with the operators. 

The implementation record for this project will display: 

• Each harvest unit, transportation facility, and other project components as actually implemented,

• Any proposed changes to the design, location, standards and guidelines, or other mitigation measures for

the project, and

• Authorization of the proposed changes.

Implementation of all activities authorized by the Record of Decision will be monitored to ensure that they are 

carried out as planned and described in the FEIS.

Saddle Lakes Timber Sale Record of Decision - Draft
Saddle Lakes Timber Sale 

34  ROD

Administrative Review - Opportunity to Object

At this time, I am releasing a DRAFT decision (instead of a “final” decision), and will publish a legal notice 

in the Ketchikan Daily News initiating the objection filing periods discussed below. 

This draft ROD and my decision to remove the five VPRs in the project area, as documented in Appendix B 

to the draft ROD, are subject to the project-level, predecisional administrative review process pursuant to 

Title 36 CFR Part 218, subparts A and B. Individuals or organizations who submitted specific, written 

comments regarding the proposed project either during scoping or other designated opportunity for public 

comment in accordance with 36 CFR 218.5(a) may file objections to the draft ROD and Appendix B. 

Written objections, including attachments, must meet the content requirements at 36 CFR 218.8(d) and be 

filed (regular mail, fax, email, hand delivery, or express delivery) with the Reviewing Officer at the correct 

location within 45 calendar days of the date that the legal notification of the opportunity to object to this draft 

decision is published in the Ketchikan Daily News, the official newspaper of record. 

My decision to adopt the Forest Plan amendment to move the small OGR in VCU 7470, as documented in 

Appendix A to the draft ROD, is subject to the predecisional administrative review process at 36 CFR Part 

219, subpart B. Individuals or organizations who submitted substantive formal comments regarding the 

proposed plan amendment during the designated opportunities for public comment may file objections to the 

plan amendment in accordance with 36 CFR 219.53(a). Written objections, including attachments, must meet

the content requirements at 36 CFR 219.54(c) and be filed (regular mail, fax, email, hand delivery, or express 

delivery) with the Reviewing Officer at the correct location within 60 calendar days of the date that the legal

notice discussed above is published in the Ketchikan Daily News. 

The publication date in the newspaper of record is the exclusive means for calculating the time to file an

objection under either 36 CFR 218, subparts A and B or 36 CFR 219, subpart B. Those wishing to submit 

objections to this draft decision and Appendix B, or Appendix A, should not rely upon dates or timeframe 

information provided by any other source. The regulations prohibit extending the time to file an objection. 

A copy of the legal notice will also be posted on the Forest Service project website at: 

http://www.fs.fed.us/nepa/nepa_project_exp.php?project=38990. 

Issues raised in objections must be based on previously submitted, timely, specific written comments 

regarding the proposed project unless based on new information arising after previous designated comment 

opportunities (36 CFR 218.8(c) and 36 CFR 219.53(a)). 

Pursuant to 36 CFR 218.12 and 36 CFR 219.58 (a), I may not sign the Record of Decision until the 

Reviewing Officer has responded in writing to all pending objections. Based on the discussions and findings 

in that review, I will issue a final decision. My decision will be consistent with the final review on the project 

and proposed plan amendments. The project and plan amendments may be implemented after my final 

decision. No appeal period will be provided after the final decision is made. If no objections are received, I 

may sign the Record of Decision five (5) business days after the close of the objection filing periods. 

Implementation may begin immediately after the Record of Decision is signed.

Individual members of organizations must have submitted their own comments to meet the requirements of 

eligibility as an individual; objections received on behalf of an organization are considered as those of the 

organization only. If an objection is submitted on behalf of a number of individuals or organizations, each 

individual or organization listed must meet the eligibility requirement of having previously submitted 

comments on the project (36 CFR 218.7 and 36 CFR 219.53). Names and addresses of objectors will become 

part of the public record. 

Saddle Lakes Timber Sale Record of Decision - Draft 

Incorporation of documents by reference in the objection is permitted only as provided for at 36 CFR 

218.8(b) and 36 CFR 219.54 (b). 
Record of Decision

Objections must be filed with the Reviewing Officer:

Beth Pendleton, Regional Forester 

USDA Forest Service, Alaska Region

709 W. 9th Street 

P.O. Box 21628 

Juneau, AK 99802-1628 

Email address: objections-alaska-regional-office@fs.fed.us

Fax: (907) 586-7840 

Phone: (907-586-8863 

Hand-delivered written objections will be accepted at the Regional Office during normal business hours (8:00 

am through 4:30 pm) Monday through Friday, excluding holidays. Electronic objections must be submitted in 

a format such as an email message, portable document format (.pdf), plain text (.txt), rich text format (.rtf), 

and Word (.doc or .docx). It is the responsibility of objectors to ensure their objection is received in a timely 

manner (36 CFR 218.9 and 36 CFR 219.56). All objections are available for public inspection during and 

after the objection process.

If objections are received, there is a 45-day objection review period for the draft ROD and Appendix B, 

and a 90-day objection review period for Appendix A, in which the Responsible Official, the Reviewing 

Officer, and the objectors may meet to attempt to resolve issues. At the end of the 45-day review period

(36 CFR 218.11(b)), and the 90 day review period (36 CFR 219.57(b)), the Reviewing Officer will issue 

a written response detailing how the objections have been addressed, which may also include instructions 

to the Responsible Official. 

A final decision on projects and plan amendments subject to the objection process may occur on, but not 

before, 5 business days from the close of the objection filing period, if no objections are received (36 CFR 

218.12(c)(2) and 36 CFR 219.58 (c)). 

If objections are received, the final decision will not be signed until all concerns and instructions identified by 

the Reviewing Officer in the objection response have been addressed by the Responsible Official (36 CFR 

218.12(b) and 36 CFR 219.58 (a)). 

Implementation of decisions and plan amendments subject to the objection process may commence 

immediately after a final decision is signed. There is not a requirement to publish notification of the decision. 

For additional information concerning this draft decision, contact Jeff DeFreest, District Ranger, KetchikanMisty Fiords Ranger District, 3031 Tongass Ave, Ketchikan, AK 99901, or call (907) 225-2148. 

M. EARL STEWART 

Forest Supervisor

Saddle Lakes Timber Sale Record of Decision - Draft ROD  35

Implementation Date

Contact Information

Responsible Official
Saddle Lakes Timber Sale 

36  ROD Saddle Lakes Timber Sale Record of Decision - Draft 

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Appendix A

Non-significant Forest Plan 

Amendment - Small Old-growth 

Habitat Reserve Adjustment in 

the Saddle Lakes Timber Sale 

Area

Small OGR Adjustment - Appendix A  37 

Appendix A - Non-Significant Forest Plan Amendment - 

Small Old-growth Habitat Reserve Adjustment in the 

Saddle Lakes Timber Sale Area 

The Saddle Lakes Timber Sale ROD includes a modification to the small old-growth reserve (OGR) in VCU 

7470. The purpose of the modification is to allocate the portion of the current OGR that contains existing 

roads and past harvest units to within the North Revilla Inventoried Roadless Area (IRA 526). The Selected 

Alternative proposes removing the roaded southwest corner of the OGR, and replacing these acres with 

adjacent IRA acres. The modifications proposed for this OGR retains the entire portion of the existing OGR 

currently within the designated IRA. The acres removed from the OGR under this decision would be 

reallocated to Modified Landscape, based on the adjacent LUD. The acres added to the OGR from the 

inventoried roadless area will be allocated into the non-development Old-growth Habitat LUD. 

This amendment, as part of the Selected Alternative is being prepared per 36 CFR 219.17 (b)(2) and (b)(3) 

which allows plan amendments initiated prior to May 9 2012 to be completed and approved under the 1982 

planning rule regulations. The administrative review process will be under the 36 CFR 218 objection 

regulations. The objection period for this amendment will be 60 days from the date of the legal notice in the 

Ketchikan Daily News and must be filed separately from objections related to the draft ROD. 

The following section explains the OGR in the Selected Alternative, the review process and application of 

direction in the Old-growth Habitat LUD goals and objectives and Appendix K of the Forest Plan, and 

Appendix D of the Forest Plan FEIS. The analysis displays the comparison of the modifications to the Forest

Plan OGR which was also the interagency biologically preferred design to the modified design. The amount 

of suitable forest land impacted by the modified OGR was also analyzed. 

Direction and Process

The 2008 Forest Plan, Appendix K states that under limited circumstances; a line officer may decide to 

modify the size and location of an OGR. This modification will require either a significant or non-significant 

Forest Plan amendment. The significance for a Forest Plan amendment for the 1982 planning rule is to be 

“[b]ased on an analysis of the objectives, guidelines, and other contents of the forest plan” (36 CFR 

219.10(f)).The Forest Service has issued guidance under the National Forest Management Act (NFMA) in 

Forest Service Manual (FSM) 1926.51, which is incorporated in the Forest Plan, Chapter 5. In addition to 

FSM direction, four factors were used in determining significance: 1) timing; 2) location and size; 3) goals, 

objectives, and outputs; and 4) management prescriptions. Discussion of these factors is included in this 

appendix. Based on the analysis under these four criteria, the proposed OGR modification will result in a nonsignificant Forest Plan amendment. 

As described in the Old-growth Habitat LUD Standards and Guidelines (p. 3-62), the Forest Plan, Appendix 

K provides the procedures and criteria for changing the boundaries of old-growth reserves at the project level. 

In addition to the criteria for size and amount of productive old growth, Appendix K includes a review of the 

additional OGR design criteria provided in 2008 Forest Plan Amendment FEIS Appendix D (USDA Forest 

Service 2008b). Two project-specific criteria were added: including POG at low elevation (less than or equal 

to 800 feet in elevation), and on south facing slopes; and providing a corridor between the small OGR to the 

state lands adjacent to George Inlet Salt Chuck. Appendix D also discusses parameters that were used to 

ensure OGRs maintained landscape connectivity and states that there is no requirement to ensure connectivity 

between small OGRs or between small OGRs and other non-development LUDs. Based on the Forest Plan 

criteria, the ROD then made a determination on whether the modified OGR provides a comparable 

achievement of the Old-growth Habitat LUD goals and objectives. This comparable achievement 

Saddle Lakes Timber Sale Record of Decision - Draft
Appendix A

38  Appendix A - Small OGR Adjustment

determination used qualitative factors, site-specific knowledge, and quantitative factors such as the changes in 

acreages. 

Proposing an OGR modification requires an interagency review by the USDA Forest Service (USFS), U.S.

Fish and Wildlife Service (USFWS), and Alaska Department of Fish and Game (ADF&G) biologists to jointly

evaluate the location and habitat composition of the OGRs. An Interagency Review Team (IRT) comprised of 

wildlife biologists was formed and met in Ketchikan on March 12, 2013 to review the OGR modification 

proposal for the Saddle Lakes project. Since the IRT’s purpose is to develop a biologically preferred

interagency OGR (IOGR) location and the decision on the Forest Plan incorporated the biologically preferred 

OGR for VCU 7470 designed by the 2006 IRT, this was already accomplished. The 2013 IRT agreed that the 

Forest Plan design was still the biologically preferred design. 

The 2013 IRT also designed three options for modifications to be considered for the Saddle Lakes project. 

Four OGR configurations were evaluated by the IRT to meet the OG LUD goals and objectives: the Forest

Plan 7470 IOGR, an OGR entirely in roadless, and two hybrid OGRs partly in roadless. The Forest Plan 

OGR was incorporated into the Saddle Lake Timber Sale Alternatives 1, 2, 3, 4, and 6. The OGR that was 

completely within the roadless area was incorporated in Alternative 5. Only those two OGR designs were 

presented to the public for review in the DEIS and carried forward in the FEIS. The “Saddle Lakes 

Interagency Old Growth Reserve Review Report” (July 13, 2013) documents the process and the analysis for

all the proposed OGR options. 

Forest Plan OGR (IOGR)

The 2008 Forest Plan adopted the IOGR for VCU 7470. This Forest Plan OGR provides habitat connectivity 

between Naha LUD II and the State lands around George Inlet salt chuck, includes part of the largest block of 

POG within VCU, maintains 864 acres of south-facing POG at low elevations (less than 800 feet), and 

includes 5.6 miles of Class I stream habitat. One of the project specific criteria taken into consideration when 

determining the location of the IOGR was to try to provide connectivity between Naha LUD II and State 

lands adjacent to the George Inlet salt chuck. 

This OGR contains two units harvested in 1995 and two units harvested in 2000. One of the 1995 units has 

been precommercially thinned and the other is planned for thinning. 

Modified OGR for the Selected Alternative

The relocated OGR (called the roadless OGR in the FEIS) is generally in the same vicinity as the Forest Plan

OGR and is within the same large POG block within VCU 7470. The modification moves the OGR entirely

within the 2001 Roadless Rule inventoried roadless area identified as the North Revilla Inventoried Roadless 

Area (IRA 526). While the roadless OGR reduces the amount of acres and habitat included in the 2008 

Forest Plan IOGR it does still contains all necessary features of an OGR, except for protection of known 

R10 sensitive plant populations. Sensitive plant surveys have not been conducted in the IRA so it is 

unknown whether populations exist in this OGR. 

And while the modified OGR does result in reductions to sensitive plant habitat acres, there are no actual size 

or acreage requirements listed in the Forest Plan for these units of measure. The modified OGR still includes 

part of the largest block of POG within VCU 7470, maintains 657 acres of south-facing POG at low 

elevations (< 800 feet), includes 4.9 miles of Class I stream habitat, and includes rare features such as 149 

acres of large tree habitat. No known populations of the lesser round leaf orchid (a R10 Sensitive plant) are 

within this OGR; however, no surveys have been done. In addition, this OGR removes the early seral habitat 

acres (previously harvested young-growth stands) and road miles which responds to the Forest Plan criteria to 

minimize these features within an OGR. 

Saddle Lakes Timber Sale Record of Decision - Draft 
Appendix A

Table 12 compares the effects of the proposed modified OGR to the current OGR. 

Table 12. Comparisons of Forest Plan OGR and the modified OGR

Forest Plan Appendix K Criteria Forest Plan OGR Modified OGR

Minimum Required OGR acres1 2,534

Minimum Required POG acres2 1,267

OGR Total acres 3,225 2,852

POG acres 2,182 1,941

Acreage requirements met? Exceeds Exceeds

2008 Forest Plan Amendment FEIS 

Appendix D General Design Criteria 

Circular to maximize interior habitat and 

minimize fragmentation effects Y Y 

Minimizes roads (total miles)3 2.6 0 

Minimizes early seral habitat (acres) 80 0 

Riparian/beach/estuary habitats 

(Class I stream miles) 5.6 mi 4.9 mi 

Includes largest remaining block of 

POG in VCU? Y Y 

Rare/Underrepresented features 

(# rare or sensitive plant locations)4 1 known Unknown – no surveys 

done within IRA 

Important deer winter habitat (acres)5 864 657

Important marten habitat (acres)6 1,248 1,086

Goshawk nesting habitat (acres)7 989 794

Murrelet nesting habitat (acres)8 

(Large tree habitat) 174 149

Other Considerations for the project

Low elevation POG (acres)9 1,360 1,059

1. Small OGRs are a contiguous landscape of at least 16 percent of the National Forest System land area of each VCU.

2. At least 50 percent of the small OGR should be productive old growth.

3. 1.8 miles of current mainline and planned State ADOT Ketchikan Shelter Cove Road system within or adjacent to OGR

4. Contains R10 sensitive plants, State rare plants, and/or largest tree (VC7) stands.

5. High-POG <800 feet elevation.

6. High-POG <1,500 feet elevation.

7. High-POG <1,000 feet elevation.

8. Large tree habitat (SD67 from the Size Density Model)

9. POG ≤ 800 ft. elevation on south-facing slopes

Timing 

The timing factor takes into account when, during the life of the Forest Plan, the proposed change is to take 

place. Generally, the later the change in the life of the Plan, the less likely it is to be significant. The Forest 

Plan revision was completed in 2008, so this change is proposed 7 years into the life of the Plan. The intent 

of the Forest Plan was for project-level environmental analysis to evaluate the size, spacing, and habitat 

composition of mapped reserves, for project areas that include or are adjacent to mapped old-growth habitat 

reserves.

Saddle Lakes Timber Sale Record of Decision - Draft Small OGR Adjustment - Appendix A  39
Appendix A

40  Appendix A - Small OGR Adjustment

Based on the Forest Plan implementation to date, I determined that the cumulative adjustments to land use 

designations, in particular those made to adjust small OGRs, were anticipated by the Forest Plan and are 

relatively small in comparison to the overall land base. Although this modification to the Forest Plan OGR 

decreases the number of acres in the OGR, this modification will still maintain the number of acres of OGR 

required for VCU 7470. For these reasons, I have determined that these changes relevant to timing are not

considered significant. 

Location and Size 

This factor takes into account location and size of the area involved in the change and the affected area’s 

relationship to the overall planning area. Generally, the smaller the area affected, the less likely the change is 

to be significant. 

The area of the OGR impacted by existing roads and harvest units was reallocated to an area to the northeast 

within an inventoried roadless area. The modified OGR in the Selected Alternative would exceed the 

minimum Forest Plan acreage requirements for total acres by 318 acres or 12 percent and productive oldgrowth acres by 674 acres or by 53 percent. From the Forest Plan OGR, total size would be reduced by 373 

acres and total acres of productive old growth would be reduced by 241 acres. 

Goals, Objectives, and Outputs 

This factor examines whether the change alters long-term relationships between the levels of goods and 

services projected by the Forest Plan. In most cases, changes in outputs are not likely to be a significant 

change in the Forest Plan unless the change would forego the opportunity to achieve an output in later years. 

Goals and Objectives 

The Forest Plan goal for biodiversity is to maintain healthy forest ecosystems and to maintain a mix of 

habitats at different spatial scales (i.e., site, watershed, island, province, and forest) capable of supporting the 

full range of naturally occurring flora, fauna, and ecological processes native to Southeast Alaska. While the

modified OGR varies from the Forest Plan alternative, the adjustment to these reserves is consistent with the 

goals of the Forest Plan. 

The Forest Plan objectives are to maintain a Forest-wide system of old-growth forest habitat, known as the 

Conservation Strategy, to sustain old-growth associated species and resources and to ensure that the reserve 

system meets the minimum size, spacing, and composition criteria described in Appendix K of the Forest 

Plan. While the modified OGR does not provide the exact same achievement as compared to the existing 

condition, a comparable achievement of the goals and objectives of the Old-growth Habitat LUD are still met 

and the adjustments to these reserves are designed to meet overall Forest Plan Objectives. 

Outputs 

Adjustment of this OGR will have a relatively minor effect on the Forest Plan outputs on a Forest-wide basis, 

primarily because the change in the acres of LUDs that allow scheduled timber harvest is relatively small. 

There is a net increase of 322 acres of forest lands classified as suitable for timber production which is about

2 percent of the lands classified as timber production or modified landscape in the Saddle Lakes project area. 

However, these acres are along a NFS system road and will affect the economic viability of any future 

contract offerings. 

Saddle Lakes Timber Sale Record of Decision - Draft
Cumulative Changes 

Table 13 displays changes in LUD acres resulting from modifications of OGRs across the Tongass National 

Forest. The net change in suitable acres represents less than one percent of the suitable land base in the project

area. This is the second amendment to modify small OGRs since the 2008 decision on the Forest Plan. The 

acres proposed to move from development LUD to OGR is a decrease of acres, and reduce the amount of 

POG.

Table 13. Cumulative effect on modifications for OGRs

Project VCU(s) Date of 

Decision

OG LUD to 

Development 

(acres)

Development to OG 

LUD (acres) 

Suitable and 

Available OG

(acres)

Big 

Thorne

5790, 5800, 5810, 

5820, 5830, 5850, 

and 5950

6/13/2013 +645 -645 +543

Saddle 

Lakes 7470 TBA +322

0 

(OG LUD moved to 

Roadless)

+322

Total +967 -645 +865

Conclusion 

I have followed the process and direction for project-level review and in doing so, considered the criteria 

contained in Appendix K of the Forest Plan and Appendix D of the Forest Plan FEIS. Following the LUDspecific Wildlife Standards and Guidelines for the Old-growth Habitat LUD (Forest Plan p. 3-62 WILD1 B2), 

I have determined that the modified OGR for the Selected Alternative achieves a comparable achievement of 

the Old-growth Habitat LUD goals and objectives (Forest Plan 3-57). 

This amendment will not significantly alter the long-term relationship between levels of multiple-use goods 

and services originally projected in the Forest Plan; and is consistent with the 1982 Planning Rule 

Regulations, requirements of Forest Service Manual 1926.5 and the Saddle Lakes Timber Sale FEIS and 

ROD.

I have considered the effect of this action at the scale of the VCU (7470) and relative to the purpose and need 

of the project. I have further considered their role in the Forest Plan Conservation Strategy and associated 

direction in the Forest Plan. I find this decision has very limited risk to old growth-associated species in the 

project area or the integrity of the conservation strategy. 

The signature date of this amendment will coincide with the signature of the Saddle Lakes Timber Sale ROD. 

M. EARL STEWART 

Forest Supervisor 

Saddle Lakes Timber Sale Record of Decision - Draft Small OGR Adjustment - Appendix A  41

Responsible Official 

Appendix A
Appendix A

42  Appendix A - Small OGR Adjustment Saddle Lakes Timber Sale Record of Decision - Draft 

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Appendix B 

Non-significant Forest Plan 

Amendment Removing Visual 

Priority Routes

Removing VPRs - Appendix B  43 

Appendix B - Non-Significant Forest Plan Amendment 

Removing Visual Priority Routes

The Saddle Lakes Record of Decision (ROD) and Final Environmental Impact Statement (FEIS) analyzed 

removal of the five visual priority route and use area (VPR) designations listed in Table 14. This amendment 

is a result of that analysis.

Removing VPR designations and relaxing the scenic integrity objectives (SIOs) in this amendment applies 

only to the Saddle Lakes Record of Decision (ROD) as analyzed in the Saddle Lakes Timber Sale EIS and not 

to future projects, or modification of existing projects. Removing the VPR designations in this amendment 

was fully analyzed in Alternative 5 of the DEIS which was released for a 45-day public review period on 

September 12, 2014. This amendment, as part of the Selected Alternative is being prepared per 36 CFR 

219.17 (b)(2) and (b)(3) which allows plan amendments initiated prior to May 9, 2012 to be completed and 

approved under the 1982 planning rule regulations. The administrative review process will be under the 36 

CFR 218 objection regulations. The objection period for this amendment will be 45 days from the date of the 

legal notice in the Ketchikan Daily News. 

The Selected Alternative, which is a modification of Alternative 5, reduces the effects from that analysis by 

dropping 63 units, leaving 548 acres uncut and changing 293 acres from clearcut harvest to partial harvest 

which will retain 66 percent of the trees. The modifications also reduce road construction by 5.6 miles. 

The EIS and the accompanying project record identify methods used, discuss opposing views, and disclose 

incomplete or unavailable information, scientific uncertainty, and risk (see 40 C.F.R. §§ 1502.9(b), 1502.22, 

1502.24). This FEIS also tiers to the 1997 Forest Plan Final Environmental Impact Statement (FEIS) and 

2008 Forest Plan Amendment FEIS. 

Visual Priority Routes and Use Areas

VPRs are existing or known major points from which people view the forest and are used to identify seen and 

seldom seen areas and to map SIOs. They are a component of the scenic management system utilized in the 

Forest Plan to analyze and manage the scenic resource on the Tongass National Forest. VPRs were established 

in the 1979 Forest Plan and updated in 2006 and incorporated into Appendix F of the 2008 Forest Plan. 

Forest wide, there are five VPRs designated as “Routes not constructed or NEPA Cleared: Planned or 

Opportunities” (Planned VPRs). Planned VPRs subject to this amendment include: Saddle Lakes Recreation 

Area, Harriet Hunt (Ketchikan) to Shelter Cove Connection Road, and Shelter Cove Boat Ramp. 

Table 14. Visual priority route designations removed in the Saddle Lakes project area

VPR VPR Type

George Inlet Saltwater Use Areas

Carroll Inlet

Harriet Hunt to Shelter Cove Road

Saddle Lakes Recreation Area Routes not constructed or NEPA Cleared: Planned or Opportunities

Shelter Cove Boat Ramp

Source: USFS Tongass National Forest GIS; USDA Forest Service 2008b, Appendix F, pp. F-22 –F-24.

George Inlet and Carroll Inlet VPRs are identified in the Forest Plan, Appendix F as saltwater use areas

(Appendix F). Use areas are places where the public uses a large area not easily defined by a specific route or 

Saddle Lakes Timber Sale Record of Decision - Draft
Appendix B

44  Removing VPRs - Appendix B

line on a map. Uses include sport fishing, scuba diving, beachcombing, sightseeing and general boating. 

Tour operators may provide excursions into George and Carroll Inlets, but are not under Forest Service 

permit, nor is use recorded. 

George Inlet and Carroll Inlet Saltwater Use Areas

George and Carroll Inlets are VPRs that have a viewshed much larger than the Saddle Lakes project area. 

George Inlet is approximately 14 miles in length, and Carroll Inlet is approximately 26 miles in length. 

Removing the VPR designations as proposed will result in greater visible impact than if the VPRs are kept,

but it will not drastically change the visual experience of either George or Carroll Inlet since both show 

evidence of past timber harvest. Some lands are Timber Production LUD, in which the SIOs enable a larger 

impact from projects, and some are private and State of Alaska lands, which do not fall under the Forest Plan 

Standards and Guidelines. 

Harriet Hunt (Ketchikan) to Shelter Cove Road VPR

The Harriet Hunt to Shelter Cove Road VPR passes areas where evidence of timber harvest is already 

noticeable. The road analyzed as a VPR in this project is approximately 8 miles long; when the road from 

Ketchikan is built, the VPR will continue along the entire road corridor from Harriet Hunt Lake to Shelter 

Cove. 

Removing the VPR designation would mean that timber harvest would be seen along the road. The Harriet 

Hunt to Shelter Cove Road VPR passes through the area considered as the planned Saddle Lakes Recreation 

Area VPR.

Saddle Lakes Recreation Area VPR

The Saddle Lakes Recreation Area VPR viewshed is currently all high and very high existing scenic integrity

(ESI), meaning that most of the land visible from the lakes does not appear to be visibly altered. This 

viewshed, approximately 1,800 acres in size, is where the largest impacts of harvest will be visible. The 

Saddle Lakes Recreation VPR is approximately 500 acres, much of which is the two lakes. Removing this 

VPR designation would change this area to very low SIO, and after project completion, timber harvest 

activities would be obvious. 

Shelter Cove Boat Ramp

The Shelter Cove boat ramp is at the end of the Shelter Cove Road near the Shelter Cove LTF. The lands 

visible from this VPR are also visible from the Harriet Hunt-Shelter Cove Road VPR and include areas 

previously harvested on both sides of Carroll Inlet. None of the units proposed for harvest are visible from 

the Shelter Cove boat ramp. 

Saddle Lakes Timber Sale Record of Decision - Draft 
Appendix B

Figure 2. VPR designations to be removed for the Saddle Lakes Project

Saddle Lakes Timber Sale Record of Decision - Draft Removing VPRs - Appendix B  45
Appendix B

Direction and Process

The Forest Plan states that as part of the planning for major land-disturbing activities, consider whether 

changes to the VPR list are necessary (Forest Plan p. 4-56). The interdisciplinary planning process for the 

Saddle Lakes Timber Sale FEIS and ROD considered removing VPRs within the project area in several 

alternatives and conducted the necessary analysis.

The Forest Service issued guidance under the National Forest Management Act (NFMA) in Forest Service 

Manual (FSM) 1926.51, which is incorporated in the Forest Plan in Chapter 5. In addition to FSM direction, 

two conditions are evaluated in determining significance: 1) Timing, and 2) Location and Size. Discussion of 

these factors is included below. 

Timing 

The timing factor takes into account when, during the life of the Forest Plan, the proposed change is to take 

place. Generally, the later the change in the life of the Plan, the less likely it is to be significant. Amendments 

provide a means to keep the Plan current with changing conditions. 

Visual priority routes and use areas were identified and designated in the 1997 Forest Plan, 18 years ago, and 

included the adopted SIOs. Since that time, analysis for several projects showed that meeting the more 

restrictive SIOs adopted for VPRs has resulted in less economical timber harvest projects, sometimes to the 

extent that they could not be offered due to being deficit. Because of this, alternatives for Saddle Lakes were 

developed to see how the economics could be improved by removing the VPR designations in the Saddle 

Lakes project area which lowers the associated SIOs. 

The outcome of this combined with the modifications for the Selected Alternative described in the ROD was 

improved financial efficiency. The analysis for the Selected Alternative shows that the project may appraise 

positive under the current export policy. This increases the possibility that a timber harvest contract can be 

offered from the Saddle Lakes project at this time which would help support or maintain the timber industry 

as it transitions to a young-growth forest management industry. For this reason, I have decided that removing 

the VPR designations for the Saddle Lakes Timber Sale project is warranted at this time.

Location and Size 

This factor takes into account location and size of the area involved in the change and the affected area’s 

relationship to the overall planning area. Generally, the smaller the area affected, the less likely the change is 

to be significant. 

The project area totals about 38,459 acres and lies about 18 air miles northeast of Ketchikan. Access is by 

float plane or by water via Carroll Inlet (about 27 miles) near the Shelter Cove LTF or through George Inlet 

(about 24 miles). The Selected Alternative will harvest about 2,327 acres of old-growth commercial forest. 

Harvest will include about 1,922 acres of clearcuts within the project area. 

Table 15. Project area acreages and percentages of TNF Lands

Tongass NF Acres Project 

Acres

Total Harvest

Acres

Total Clearcut

Acres

16,800,000

38,459 2,327 1,922

0.229% 0.014% 0.011%

46  Removing VPRs - Appendix B Saddle Lakes Timber Sale Record of Decision - Draft 
Appendix B

Saddle Lakes Timber Sale Record of Decision - Draft

Removing the VPR designations in the Selected Alternative reduces the SIO from moderate or low to 

very low on 14,930 acres (0.089 percent of the Tongass), spread over the eight VCUs that make up the 

George and Carroll Inlet viewshed. 

The western boundary of the 2.3 million acre Misty Fiords National Monument Wilderness protected area 

is about 4 miles west of the project area. The majority of flightseeing and waterborne tours in the region 

visits the Behm Canal, which bisects the monument about 13 miles east of the project area.

The southern and western boundaries of the project area are occupied by non-federal landowners and include 

lands from the project area boundary to the shoreline of George Inlet including the western shoreline of the 

inlet with some parcels inter-mixed within the project area boundary (Figure 2). 

Currently, the project area is not connected to the Ketchikan road system, but may be connected within 2

years. Changes to the management of the areas can have impacts on a number of people based on existing 

traditional uses. These impacts could be positive or negative depending on the specific use or users view. 

Recreational use in the area proposed for the Saddle Lakes Recreation Area is currently very low due to 

limited accessibility in the absence of a connection road. Plans for the Saddle Lakes Recreation Area identify 

the need for a connection road to include use via passenger vehicles, RVs, buses and commercial vehicles for 

a broad range of uses including recreation, subsistence, and commercial uses.

Effects of Removing VPR Designations in the Selected Alternative 

There is no change in suitable and available forest land for timber resources, only the opportunity for a more 

economical timber harvest at this time. This is the only amendment to date that removes VPR designations. 

Impacts from the VPR will be noticeable, but not drastically change the visual experience along George Inlet 

and Carroll Inlet and some sections of the connection road where forest visitors may view landscapes where 

harvest activities are allowed to dominate the scenery. The visual impact will be less than within the proposed 

Saddle Lakes Recreation Area because the connection road, George Inlet and Carroll Inlet have existing 

clearcuts already noticeable to the casual observer. The impacts to the proposed Saddle Lakes Recreation Area

viewshed will be very visible. The landscape, which is currently visually intact, will be visually dominated by 

timber harvest as a direct result of the removal of the Saddle Lakes Recreation Area and Harriet Hunt – 

Shelter Cove Road VPR designations. 

Table 16. Changes in scenic integrity objectives (SIO) due to VPR designation removal and harvest under the 

Selected Alternative

Scenic Integrity Objective Level Existing Forest Plan Selected Alternative

Acres % of Project Area Acres % of Project Area

High 3,565 10% 3,15719%

Moderate 5,041 14% 0 0%

Low 6,,048 17% 2,746 8%

Very Low 20,245 59% 28,994 83%

1 High SIO is the result of OGR modification (See Appendix A). With VPR removal the change was from Moderate SIO to Low or Very 

Low SIO. Source: USFS Tongass National Forest GIS. Note: Numbers may not add due to rounding.

Table 17. Effects of VPR designation removal to scenic integrity objectives by harvest type for the Selected 

Alternative 

Effects of VPR Designation Removal Total Acres Clearcut Acres Partial Cut Acres

Harvest in areas that decreases SIO 1,246 1,045 201

Harvest in areas with no change in SIO 1,081 857 224

Removing VPRs - Appendix B  47
Appendix B

48  Removing VPRs - Appendix B 

Cumulative Effects

Cumulative effects are the result of incremental impacts of the action when added to other past, present, and 

reasonably foreseeable future actions regardless of what agency or person undertakes such other actions (40 

CFR § 1508.7). Cumulative effects are considered in detail in the Saddle Lakes Timber Sale FEIS. Changes 

under this amendment are specific to this Saddle Lakes Timber Sale and do not authorize future timber 

harvest, utility corridor expansions and recreation developments. 

Projects analyzed as having cumulative effects, to scenery and recreation include the existing Swan-Tyee 

Intertie transmission line corridor, the proposed State of Alaska Ketchikan-Shelter Cove Road, and the 

proposed Alaska Mental Health Trust Association (AMHT) land exchange. 

Clearing of the Swan-Tyee Intertie corridor began in 2003. Analysis for the Swan-Tyee Intertie Project 

began prior to the 1997 Forest Plan Revision FEIS. The scenery analysis indicated that it would meet the 

proposed adopted Forest Plan SIO. Removal of VPRs under this amendment does not apply to the corridor. 

The State of Alaska Ketchikan-Shelter Cove Road is expected to go to bid in the fall of 2015. The road would 

allow for a wider range of visitors to access the project area. An increase in road use is projected, but the 

effects are not yet known and remain in compliance with the Forest Plan. 

The cumulative effects analysis for the AMHT land exchange states that the proposed exchange is likely to 

affect recreation opportunities; current AMHT public use policy is non-commercial, non-motorized, and 

day use only which would be a change from what is currently allowed by the Forest Service. 

Conclusion 

I have considered the effect of this action relative to the purpose and need of the project and at the scale of 

Tongass National Forest as a whole. I find this decision has very limited risk to the scenery resources on the 

Tongass. This amendment will not significantly alter the long-term relationship between levels of multipleuse goods and services originally projected in the 2008 Forest Plan and is consistent with the 1982 Planning 

Rule Regulations, requirements of Forest Service Manual 1926.5 and the Saddle Lakes Timber Sale FEIS and 

ROD. This amendment applies only to activities to be approved in the Saddle Lakes ROD.

Removing the VPR designations for the purposes of the Saddle Lakes project will allow the project area to 

continue to provide multiple uses as well as provide economical timber to forest product industries while the 

transition to young growth management occurs. Any authorization of occupancy and use made before this 

plan amendment remains unchanged. 

The signature date of this amendment will coincide with the signature of the Saddle Lakes Timber Sale ROD.

Saddle Lakes Timber Sale Record of Decision - Draft 

M. EARL STEWART 

Forest Supervisor 

Responsible Official 
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Record of Decision

Saddle Lakes Timber Sale 

Even-aged 0% Retention

Uneven-aged 33% Removal

Project Area Boundary

Old-growth Reserve

Non-NFS Lands

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Lakes

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[Draft]

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