United States Department of Agriculture 

Mitkof Island 

Petersburg Ranger District, Tongass National Forest 

Decision Notice and Finding of No 

Significant Impact 

 Forest Service Tongass National Forest 

 Alaska Region Petersburg Ranger District R10-MB-760b March 2015 
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Mitkof Island 

Decision Notice and Finding of No Significant 

Impact 

___________________________________________ 

Lead Agency: USDA Forest Service 

 Tongass National Forest 

 Petersburg Ranger District 

Responsible Official: Jason Anderson 

 District Ranger 

 PO Box 1328 

 Petersburg, AK 99833 

For More Information Contact: Carey Case 

 Project IDT Leader 

 Petersburg Ranger District 

 PO Box 1328 

 Petersburg, AK 99833 

Abstract 

The responsible official has selected Alternative 2 (the Selected Alternative) to provide units for 

small timber sales (green saw timber, fuelwood offerings and young-growth commercial 

thinning), provide a one-time predominantly helicopter-based offering with a limited number of 

ground-based (cable) harvest units requiring road construction, and support a programmatic 

microsale program on Mitkof Island. Timber harvest and road construction are not located in 

inventoried roadless areas (IRAs). 

The Selected Alternative includes harvesting approximately 28.5 million board feet (MMBF) of 

timber on about 4,117 acres of National Forest System (NFS) land. This volume has been 

delineated into individual units which utilize a variety of silvicultural prescriptions and logging 

systems. Full implementation includes an estimated 1.3 miles of new NFS road construction, 4.7 

miles of temporary road construction and approximately 4.5 miles of road reconditioning. 

DN/FONSI - 1 

Decision Notice and Finding of No Significant 

Impact 

for the 

Mitkof Island 

Environmental Assessment 

USDA Forest Service 

Tongass National Forest 

Petersburg Ranger District 

Introduction____________________________________ 

This Decision Notice (DN) contains a brief summary of the environmental analysis 

completed for the Mitkof Island Environmental Assessment (EA), my decision regarding 

which alternative to implement, and the rationale for that decision. It also contains findings 

required by various laws. The EA completed for this project is incorporated by reference. 

Project Area Location and Description_______________ 

The Mitkof Island project area is in Southeast Alaska approximately 160 miles south of 

Juneau. Mitkof Island is situated between the mainland to the east and Kupreanof Island to 

the west. The community of Petersburg, population 3,200, is located on the northern end of 

Mitkof Island. The project area includes all lands located on Mitkof Island. National Forest 

System (NFS) lands encompass approximately 81 percent of the island (108,887 acres of 

the total 134,156 acres). There are approximately 107 miles of open and 20 miles of closed 

NFS roads within the project area. There are an additional 47 miles of road on Mitkof Island 

on non-NFS land (Figure DN-1). Mitkof Island is comprised of one wildlife analysis area 

(WAA) 2007. 

Decision______________________________________ 

Based upon my review of the analysis, comments from the public, and other documents 

provided for the Mitkof Island EA, I have selected Alternative 2, hereafter the Selected 

Alternative, in its entirety. 

The Selected Alternative provides units for small timber sales (green saw timber, fuelwood 

offerings and young-growth commercial thinning), provides a one-time predominantly 

helicopter-based offering with a limited number of ground-based (cable) harvest units 

requiring road construction, and supports a programmatic microsale program on Mitkof 

Island. Proposed timber harvest and road construction are not located in inventoried 

roadless areas (IRAs). 

The Selected Alternative includes harvesting approximately 28.5 million board feet 

(MMBF) of timber on about 4,117 acres of National Forest System (NFS) land. This 

volume has been delineated into individual units which utilize a variety of silvicultural 
Mitkof Island – Decision Notice and Finding of No Significant Impact 

2 – DN/FONSI 

prescriptions and logging systems (Figure DN-2). Full implementation includes an 

estimated 1.3 miles of new NFS road construction, 4.7 miles of temporary road construction 

and approximately 4.5 miles of road reconditioning. 

Units with basal area retention of 95 percent and above allow for harvest activities ranging 

from individual green tree selection to small openings less than 1.5 acres. Removal of the 

allowable basal area (5 percent) may occur in one or more sales. 

Additionally, the Selected Alternative includes a programmatic microsale program that 

incorporates existing and new NFS road corridors in all permitted land use designations 

(LUDs) (USDA Forest Service 2008a, pp. 4-73 and 4-74) and allows salvage activities in 

the beach fringe (USDA Forest Service 2008a, p. 4-5). These sales will consist of dead and 

down trees up to a total of 50 thousand board feet (MBF) per sale, with no more than 500 

MBF offered each year. Microsales will be identified by prospective purchasers and 

approved by the Forest Service on a case-by-case basis. Microsales proposed in nondevelopment LUDs will need to meet LUD objectives prior to approval. A site-specific 

implementation plan will be completed (see Appendix 1 of the DN/FONSI) for every 

microsale before implementation may occur. 

Harvest systems approved include helicopter, ground-based and cable yarding, and consist 

of even-aged and uneven-aged harvest prescriptions. Onsite milling using small, portable 

mills, such as an Alaska chainsaw mill, may be permitted on a case-by-case basis. All 

activities must meet the standards and guidelines of the Forest Plan. 

The two permitted marine access facilities (MAFs), Woodpecker Cove and Blind Slough, 

may be utilized for this project. 

Decision Rationale______________________________ 

My intention to implement the Selected Alternative considers how best to meet the purpose 

and need for this project, the existing conditions within the project area, environmental 

effects, relevant issues, and public comments. My rationale is based on the project-specific 

environmental analysis included in the EA and corresponding resource reports, as well as a 

review of the record, which shows a thorough analysis using the best available science. 

I have evaluated the trade-off between resource protection and social values, and believe 

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 

intention to implement the Selected Alternative conforms to the Forest Plan and National 

Forest Management Act (NFMA). 

Timber Supply and Economics 

Both the Selected Alternative and Alternative 3 respond to the goals and objectives 

identified by the Forest Plan related to timber harvest, and both are responsive to the need 

for a consistent economic supply of sawtimber on Mitkof Island. The extent to which each 

alternative meets this need is correlated directly to the total volume of timber made 

available, which means the No Action Alternative does not meet the purpose and need for 

this project, and the Selected Alternative best meets the purpose and need. The Selected 
Mitkof Island – Decision Notice and Finding of No Significant Impact 

DN/FONSI - 3 

Alternative provides not only the most volume (28.5 MMBF) of the alternatives considered, 

but also supports more employment opportunities (125-149 direct jobs), and has a greater 

potential to benefit the local and regional economy ($6.6 - $7.0 million estimated total 

income) (EA, pp. 16, 30-32). 

The projected financial present net value1

 is negative for the Selected Alternative and 

Alternative 3; however, current indicated advertised value estimates show a positive 

indicated advertised bid rate for both. The indicated advertised bid rate for the Selected 

Alternative is substantially lower than Alternative 3 because of the higher logging costs 

associated with the helicopter portion, which accounts for approximately 47 percent of the 

volume offered (EA, pp. 30-32). 

The allowance of a one-time helicopter offering (13.4 MMBF) in the Selected Alternative 

provides an opportunity for a regional operator, and does so with minimal effect to wildlife 

by minimizing the need for road construction, and retaining 66 percent of the timber to 

maintain old-growth characteristics in the units after harvest. 

By including an offering attractive to larger-scale regional operators, benefits inherent to 

these larger businesses are passed along to local operators. Operators with a larger operating 

capacity help stabilize the regional timber economy by providing a variety of processing 

capabilities and products, and they have the ability and equipment to build or improve local 

infrastructure. When infrastructure is expanded, it provides opportunities for smaller 

operators who usually cannot afford road building costs associated with a project, or do not 

have the necessary equipment. The maintenance and creation of infrastructure also provides 

an incentive for the establishment, or growth, of new businesses locally. 

The Selected Alternative allows for the most flexibility to respond to a variety of business 

models and processing capacities over fluctuating market conditions. While the NEPA 

process clears a specific amount of volume and number of harvest units, the timber sales are 

packaged during the implementation stage of the project. How they are packaged depends 

on current economics, demand, species composition and the operators interested. The 

quantity of economically viable timber available at project implementation depends on a 

number of factors such as: changes in market values, fuel costs, and location of available 

appraisal points. These factors can dramatically affect stumpage values and logging costs. 

I believe the increased land availability for microsales will provide a better opportunity to 

meet our goal to contribute to the local economy and our objective to support natural 

resource employment. The Petersburg Ranger District has a history of offering microsales in 

the project area and has relied on previously NEPA-cleared areas to provide these sales. In 

the past, NEPA-cleared areas identified specific road segments or sites for microsale 

activity, generally not exceeding 400-500 feet from the road, which limited microsale 

opportunities. The Selected Alternative includes the opportunity to offer microsales along 

all existing and proposed road corridors in the LUDs where allowed by the Forest Plan (pp. 

4-73 and 4-74). Appendix 1 provides the context for how these activities will occur. Since 

each microsale will be approved by the District on a case-by-case basis, no significant 

 

1

 The financial present net value is based on the present value of revenues and the present value of 

financial costs. It is used to identify an above-cost or below-cost program. 
Mitkof Island – Decision Notice and Finding of No Significant Impact 

4 – DN/FONSI 

direct, indirect, or cumulative effects are expected from supporting a programmatic 

microsale program on Mitkof Island. 

Deer Habitat/Deer Subsistence Use 

Three local residents have expressed concerns about potential adverse effects to subsistence 

use due to the cumulative effect of additional deer habitat reduction as a result of timber 

harvest. They specifically requested no further loss of high-volume productive old-growth 

(POG) below 800 feet in elevation on non-north facing slopes and believe project 

implementation, as it was scoped in August 2013, will lead directly to further restrictions to 

subsistence use on Mitkof Island. 

In response to these concerns, the majority of the high value deer winter habitat available 

for harvest in the project area was not proposed for even-aged harvest. Instead, units 

identified as important deer winter range were given retention rates of 66, 95, and 98 

percent, and units considered important for elevational connectivity were dropped from 

consideration. With the use of these silvicultural prescriptions, our analysis shows the direct 

effects of implementing the Selected Alternative results in a 0.9 percent reduction in deer 

habitat capability (DHC) 1 year post-harvest (2015), and a 2.4 percent reduction at stem 

exclusion (2041) within WAA 2007 (EA, p. 36). Cumulative change in deer habitat 

capability (percent of historic habitat capability remaining) could drop 0.6 percent to 56.0 

percent 1 year post-harvest (2015) and 0.9 percent to 55.0 percent at stem exclusion (2041) 

(EA, p. 40, Table 6). 

To address public comments specifically related to the potential loss of high-volume POG 

below 800 feet, a metric was used to assess the project’s effects to deer deep snow habitat 

(i.e., deer habitat important in deep snow winters). Again, the interdisciplinary team (IDT) 

developed project design features which included dropping the majority of units considered 

in this habitat type and established high retention rates for the remaining units. As a result, 

70 acres of high-volume POG are proposed for harvest (from the existing 17,681 acres) in 

the Selected Alternative. This equates to a 1 percent reduction from WAA 2007’s existing 

condition (EA, p. 39, Table 5). 

When considering the cumulative reduction in deer habitat important to deer in deep-snow 

winters, implementation of the Selected Alternative could reduce these acres to 52 percent 

of what was originally present, a 1 percent reduction from the WAA’s existing condition 

(EA, p. 41, Table 8). I believe this cumulative reduction is not significant based on historic 

and current theoretical and empirical literature which suggests deer population trends in 

some parts of Southeast Alaska, including Mitkof Island, may be more heavily influenced 

by predation and severe winters than by the quality and availability of deer winter habitat. 

Based on this information, I conclude the additional minimal habitat reductions that could 

result from project implementation will have a negligible effect on existing Mitkof deer 

populations, and deer subsistence use opportunities. 

Furthermore, the reduction in deer habitat important in deep-snow winters via clearcut 

prescription (26 acres total, see EA, p. 39, Table 5) does not occur in one contiguous area, 

but is spread out over 10 units that range in size from 4.6 to 82.1 acres (289 acres total), 

with no unit comprised solely of this habitat type. Efforts were made by the IDT to avoid 

deer deep snow habitat when proposing management prescriptions; however, because most 
Mitkof Island – Decision Notice and Finding of No Significant Impact 

DN/FONSI - 5 

stands are made up of a mosaic of different habitats (i.e., not contiguous) avoidance was not 

entirely possible. 

I also believe the predicted drop in deer density with the implementation of the Selected 

Alternative will not be a significant impact; deer habitat capability at stem exclusion should 

be more than sufficient to carry the existing deer and, therefore, support the wolf 

population. My rationale is based on the following: 

♦ Considering NFS lands only: deer density 1 year after implementation is expected 

to decline from existing condition by 0.2 deer/mi2

, and 0.4 deer/mi2 at stem 

exclusion (EA, p. 90, Table 22). To put this into a broader context, the projected 

deer density at stem exclusion (14.3 deer/mi2

) is higher than the predicted deer 

density value for WAA 2007 (12 deer/mi2

) after 100+ years and full implementation 

of the 2008 Forest Plan (Dungan 2014b, p. 88). 

♦ Considering both NFS and non-NFS lands: deer density is expected to decline by 

0.1 deer/mi2

 from the existing condition (a reduction from 11.7 deer/mi2 to 11.6 

deer/mi2

) when stem exclusion is reached (EA, p. 92, Table 24). This is equal to the 

deer density predicted on federal lands only in Appendix N12 of the 1997 Forest 

Plan FEIS for WAA 2007 in year 2095 (Dungan 2014b, p. 88-89). 

Another factor I considered in my decision was the output of the Tongass interagency deer 

model for both action alternatives. The 2008 Forest Plan established 18 deer/mi2 as the 

estimated deer density needed to support a sustainable wolf population and human deer 

harvest demands. At project completion, deer density is expected to be lower than the Forest 

Plan guideline in 8 of 11 WAAs in the biogeographic province2

. However, I do not see this 

as a concern for several reasons: 6 of these 11 WAAs did not historically support 18 

deer/mi2

; the Forest Plan recognizes that many areas of the Tongass may have never 

supported this assumed average (USDA Forest Service 2008b, p. 3-283); and WAAs 2008, 

5130 and 5134 with higher deer densities are adjacent to the project area which can help 

support the highly mobile wolf population. Based on this information, the projected 

reduction in deer habitat capability has a low likelihood of resulting in further declines 

which could affect wolves, and indirectly hunters and trappers. 

I have also considered the non-linear relationship of habitat loss in wolf-deer interactions. It 

is evident from the information available, deer populations in GMU 3 have not substantially 

rebounded since the 1960s despite reductions in human pressure (the hunting season was 

closed on Mitkof Island from 1973 to 1991) and climatic pressure (severe winters) when a 

greater percentage of critical habitat was available to deer. In other areas of the Tongass, 

such as GMUs 2 and 4 where habitat alteration is equal to or exceeds conditions on Mitkof 

Island, deer populations generally recovered in as little as 4 to 6 years after a severe winter 

without hunting restrictions. In GMU 2, wolves are present and winters are typically less 

severe. In GMU 4, bears are the primary predator, and winters are typically more severe. 

This leads me to conclude that deep snow winters, combined with heavy wolf predation, are 

the primary influence on GMU 3 deer populations (see Merriam 1970, Smith et al. 1986 and 

ADF&G 2012) and the additional, minimal habitat reductions of the Selected Alternative 

 

2

 Deer habitat capability is considered at the biogeographic province scale when assessing deer as the 

primary prey base for wolves, which are highly mobile. 
Mitkof Island – Decision Notice and Finding of No Significant Impact 

6 – DN/FONSI 

will have a negligible effect on existing Mitkof deer populations, and deer subsistence use 

opportunities. 

The subsistence findings for this project determined the direct effects from the Selected 

Alternative do not present a significant possibility of a significant restriction of subsistence 

uses of deer, black bear, marten, wolf, otter, marine mammals, waterfowl, salmon, other 

finfish, marine invertebrates, and other foods. Conversely, there may be a significant 

possibility of a significant restriction of subsistence use of deer, due to potential effects on 

abundance and distribution, and on competition when any alternative, including the No 

Action, considers past, present, and reasonably foreseeable actions, in a cumulative manner 

(i.e., cumulative effects). This determination assumes an anticipated increase in human 

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

to support deer under the full implementation of the Forest Plan. 

When considering this finding, it is important to review the cumulative effects analysis of 

resource development on subsistence resources included in the 1997 Forest Plan (USDA 

Forest Service 1997b). Based on that analysis, the 2008 Forest Plan ROD (p. 61) concluded 

that full implementation of the Forest Plan “may result in a significant restriction to 

subsistence use of deer due to the potential effects of projects on the abundance and 

distribution of these resources, and on competition for these resources.” In other words, it is 

not possible to substantially reduce timber harvest in one area and concentrate it in others 

without affecting subsistence resources and uses important to one or more rural 

communities (USDA Forest Service 1997a). For this reason, timber sale activities cannot 

completely avoid cumulative landscape effects to subsistence uses. 

I believe the direct effects solely from implementing the Selected Alternative on the 

subsistence use of deer is minimal, with a reduction of less than 1 percent in existing deer 

habitat capability 1 year post-harvest, and less than 3 percent at stem exclusion (EA, p. 36 

and Table 3). However, since this possibility exists regardless of the alternative 

implemented, I cannot conclude that the implementation of the Selected Alternative will 

result in a significant change to Mitkof hunters’ success when seeking a subsistence deer. 

Additionally, the relationship of this project contributing to reduced hunting opportunities in 

portions of GMU 3 due to cumulative habitat loss, is not supported by the available 

literature (see Merriam 1970, Smith et al. 1986 and ADF&G 2012), or regional deer 

population trends. 

Other Resource Considerations 

Several comments were received stating concern about the potential negative effects caused 

by additional stream crossings in the project area, and concern that peak stream flows would 

increase due to road building and harvest activities. As addressed in the aquatics analysis for 

the EA (see Lombard and Whitacre 2014, p. 31), fish passage monitoring results indicate 94 

percent of recently installed stream crossings have met the acceptable passage criteria 

established for Region 10 (USDA Forest Service 2013a, Fish Passage p. 6). Based on this 

information, I believe the risk of potential effects caused by additional stream crossings is 

low. To reduce effects of additional stream crossings, the three stream crossings on Class I 

and II streams will be designed for fish passage and all stream crossing structures on 

temporary roads will be removed following timber harvest (EA, p. 63). The new crossings 

that will remain following harvest activities will be on new NFS and reconditioned roads. 
Mitkof Island – Decision Notice and Finding of No Significant Impact 

DN/FONSI - 7 

As a result, there is the potential for minor negative effects at these sites; however, the 

potential effects are not expected to be significant at the scale of this analysis. 

Peak flow increases may occur as a result of harvest and/or road building activity, but they 

are not expected to be detectable in the project area (EA, p. 62). For this reason, I do not 

consider the effect significant. I also believe it is not significant when the scale of the 

affected environment is considered. Many similar watersheds occur within the project area 

and hundreds occur on islands within the Tongass National Forest, mostly in an old-growth 

forest condition. Individually these catchments are not unique. Should peak flows occur, I 

believe it is not likely to adversely affect the environment. Sediment and turbidity effects 

would be minor and localized, and would not degrade water quality. 

I believe the minimal increase in road density below 1,200 feet in elevation (0.05 mi/mi2) 

due to the addition of 1.3 miles of new NFS road construction with the implementation of 

the Selected Alternative will not adversely affect the hunting and trapping pressures on 

wolves (EA, pp. 91-93). Available information suggests that wolves may be in need of 

additional control measures as proposed by the State of Alaska to meet the State’s deer 

management objectives; however, the project’s effect to wolves is expected to be negligible. 

Finally, I considered the effects of this project on other resources, including soils, wetlands, 

scenery, recreation, rare, sensitive and invasive plants, climate change, inventoried roadless 

areas and heritage. These resources were analyzed for this project, and results can be found 

either in the Mitkof Island EA in the Alternative Comparison table (p. 16, Table 2) or in the 

environmental effects sections. 

To summarize, I believe the Selected Alternative reflects a reasonable balance between the 

projected need for timber from the project area to help meet the Forest Plan, ANILCA, and 

TTRA timber-related objectives, and the continued protection of subsistence uses and 

resources. Impacts on subsistence use have been minimized through the selection and 

design of the individual harvest units and road management objectives. I believe reasonable 

measures to minimize impacts on subsistence have been adopted to the maximum extent 

practicable while still meeting the purpose and need for this project (see the ANILCA 

section in this document for a more detailed discussion). It is my preliminary determination 

that singularly and collectively, the resources affected by the Selected Alternative are not 

likely to be exposed to significant impacts. 

Issues________________________________________ 

I am selecting the Selected Alternative because it best addresses the relevant issues and 

concerns related to this project. Public comments focused primarily on the need for a 

reliable supply of timber volume from Mitkof Island, and concern about impacts to deer 

habitat and subsistence use within the project area. 

I believe the Selected Alternative provides many protections to deer habitat while balancing 

the need to make a reasonable amount of volume available to meet the needs of local and 

regional operators. The implementation of any of the alternatives by itself does not present a 

significant possibility of a significant restriction to the current level of subsistence use of 

deer, because the majority of deer winter range available for harvest in the project area was 

dropped from consideration or given a high-retention silvicultural prescription during 

project design. 
Mitkof Island – Decision Notice and Finding of No Significant Impact 

8 – DN/FONSI 

Alternatives Considered_________________________ 

Three alternatives are presented in the EA: a No Action Alternative, the Proposed Action 

(the Selected Alternative) and Alternative 3. The two action alternatives were developed to 

respond to the scoping comments received (see the section in the EA, How were the 

alternatives developed?, p. 12). A comparison of alternatives is presented in Table 2 of the 

EA (pp. 16-21). 

Public and Agency Involvement____________________ 

Public involvement is a key component of the planning process. The following is a 

summary of the reports and meetings that occurred during project planning: 

July 2, 2009: Project first listed on Schedule of Proposed Actions for the Petersburg Ranger 

District. This document is available on the internet at: http://www.fs.fed.us/sopa/forestlevel.php?111005. 

July 14, 2011: Presentation about the Mitkof Island project was given by the project IDT 

Forester to a group of small mill operators in Wrangell, Alaska. 

March 8, 2012: Open house was held at the Petersburg Ranger District. An existing 

condition map of Mitkof Island was on display. The District Ranger and various IDT 

members were available to answer questions. 

May 3, 11, 23; June 28; July 12 and September 27, 2012: Lindenberg Peninsula/Mitkof 

Island Stewardship Public Meetings: A series of workshops and presentations that served as 

a public forum to discuss what the public wants from Tongass National Forest lands that 

most immediately surround them. More information at: 

http://www.fs.usda.gov/detail/tongass/home/?cid=stelprdb5392431. 

February 21, 2013: A scoping package describing the existing condition of Mitkof Island 

was delivered to 33 groups and individuals electronically and to 339 groups and individuals 

through the US Postal Service. Letters accompanying the scoping package were also sent to 

six tribal groups. Seven responses were received. The scoping report can be accessed from 

the project webpage: http://www.fs.usda.gov/project/?project=29099. 

August 29, 2013: A scoping package describing the Proposed Action, the No Action 

Alternative, and Alternative 3 was delivered electronically or through the US Postal Service 

to 196 individuals and groups. Letters accompanying the scoping package were also sent to 

six tribal groups. The legal notice was published in the Petersburg Pilot, the newspaper of 

record, on September 5, 2013, which started the 30-day comment period. Eight groups and 

individuals submitted comments. All public comments can be accessed at: 

https://cara.ecosystem-management.org/Public//ReadingRoom?Project=29099. The IDT’s 

response to these comments is located on the project webpage: 

http://www.fs.usda.gov/project/?project=29099. 

October 21 and November 12, 2013: A series of local timber operator meetings hosted by 

the Petersburg Economic Development Council (PEDC). Local mill owners from Petersburg 

and Wrangell attended, along with the Petersburg District Ranger, interdisciplinary team 

forester, and sale administrator. Discussions were focused on current mill capacities, future 
Mitkof Island – Decision Notice and Finding of No Significant Impact 

DN/FONSI - 9 

supply scenarios, frustrations with past timber supply, and a general discussion of the 

Mitkof Island EA and alternatives. 

April 23, 2014: An ANILCA 810 Subsistence hearing was held in Petersburg. The District 

Ranger gave an update on the Mitkof Island EA and Tonka Stewardship contract activities, 

which was followed by public subsistence testimony. Notice of the subsistence hearing was 

provided to the public through KFSK public radio and publication of public notices in the 

Petersburg Pilot on April 3, April 10 and April 17, 2014; notifications were sent to the 

members of the Petersburg Fish and Game Advisory Committee, Southeast Alaska Regional 

Subsistence Advisory Committee, and the local Alaska Fish and Game wildlife biologist. 

Seven members of the public attended. Three provided oral testimony related to their use of 

subsistence resources in the project area. The District also received three additional 

(written) testimonies after the hearing. 

Finding of No Significant Impact____________________ 

The Finding of No Significant Impact (FONSI) is prepared based on information presented 

in the environmental assessment (EA) to briefly present the reasons why an action will not 

have a significant effect on the human environment. If it is determined the proposed action 

may have a significant effect on the quality of the human environment, an environmental 

impact statement (EIS) will be prepared (CFR Title 40, Chapter V, Part 1508.13). 

The FONSI considers the context of the proposed action to the affected environment in 

which it would occur and its intensity, or the severity of the impact. The intensity of the 

action is considered by addressing 10 factors and their expected impacts (see CFR Title 40, 

Chapter V, Part 1508.27). 

In preparing the FONSI, I have determined that the Selected Alternative will not have a 

significant effect on the quality of the human environment; therefore, the preparation of an 

EIS is not needed. As presented in the following sections, I considered the context and 

intensity of the Selected Alternative based on what is disclosed in the Mitkof Island EA. 

Context 

Context refers to the affected environment in which the proposed action would occur. This 

means the significance of an action must be analyzed in several contexts, such as society as 

a whole (human, national), the affected region, the affected interests, and the locality. 

Significance varies with the setting of the proposed action. For instance, in the case of a 

site-specific action, significance usually depends upon the effects in the locale rather than in 

the world as a whole (40 CFR 1508.27(a)). Both short- and long-term effects are relevant. 

The Mitkof Island project is site-specific action that would take place within the project area 

of Mitkof Island, 134,156 acres in size (EA, p. 1). 79,024 of the island’s acres are allocated 

to land use designations (LUDs) that allow for timber harvest. The Selected Alternative 

includes harvesting approximately 28.5 MMBF of timber on about 4,117 acres of National 

Forest System (NFS) land within the project area (EA, p. 3). This volume has been 

delineated into individual units which utilize a variety of silvicultural prescriptions and 

logging systems. 
Mitkof Island – Decision Notice and Finding of No Significant Impact 

10 – DN/FONSI 

Eighty-three (83) percent of the acres (3,422 out of 4,117) are assigned silvicultural 

prescriptions that retain 50 percent or more of the total basal area of each stand. Six hundred 

ninety-five (695) acres in the project acres (16 percent of the total acres proposed for 

harvest) are prescribed for even-aged, or two-aged harvest with 15 percent retention where 

all, or the majority of the stand, will be removed (EA, p. 13). 

The discussion of the significance criteria that follows applies to the proposed action and is 

within the context of local importance. The Mitkof Island EA details the effects of the 

proposed action. None of the effects identified, including direct, indirect and cumulative 

effects, are considered to be significant, and all resources meet or exceed their respective 

Forest Plan Standards and Guidelines. 

Intensity 

Intensity refers to the severity of impact. The following ten factors and their expected 

impacts are considered in evaluating intensity. 

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

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

The predicted beneficial effects of the Selected Alternative, which are primarily economic, 

did not bias my finding of no significant environmental impacts (FONSI). None of the 

environmental effects summarized in the Mitkof Island EA and discussed in detail in 

specialist resource reports are considered significant. How I considered both the beneficial 

and adverse effects of this action are outlined in my Decision Rationale (DN/FONSI, pp. 2 

to 7). 

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

I have determined that public health and safety would not be affected by the implementation 

of the Selected Alternative. The Selected Alternative is comparable to other timber harvest 

projects within the project area that have occurred with no unusual health or safety 

concerns. Project operations could cause temporary traffic delays or congestion to users of 

the road system (EA, pp. 53, 77, 79). The Forest Service will use standard safety measures, 

such as signing, to ensure public safety during these times (Burke 2014, p. 7 and 13). 

Unique characteristics of the geographic areas such as proximity to historic or cultural 

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

critical areas. 

I have determined there will be no significant effects on any unique characteristics of the 

area. No historic properties, park lands or farmlands are located within the area of potential 

effects (EA, pp. 73-74). There are no designated Wild and Scenic Rivers, or Recreational 

Rivers in the project area. The Selected Alternative would not affect the eligibility of any 

segments recommended for either Wild and Scenic River System or Recreational River 

designation, and no unique wetlands and high-vulnerability karst would be affected by 

project implementation (Reynolds 2014, pp. 37-38 and 54). 

 
Mitkof Island – Decision Notice and Finding of No Significant Impact 

DN/FONSI - 11 

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

highly controversial. 

I have reviewed all comments received during the two comment periods for this project, the 

analysis documented in the EA, and the project record. Based on the level of public 

outreach, the limited and localized response, and the lack of scientific controversy over the 

impacts of this project, I have determined it is unlikely the effects to the human environment 

from implementing the Selected Alternative will be highly controversial. 

The management of publicly-owned forest land can be controversial in nature; however, the 

project area is not ecologically unique, and the management of publicly-owned forest is 

seldom controversial from a scientific perspective. The interdisciplinary team developed the 

Selected Alternative in response to increasing public requests for the Forest Service to 

develop a proposal to consolidate a variety of harvest activities into one environmental 

analysis, and produce a more efficient and cost-effective supply of timber. The Selected 

Alternative was also developed to meet the project purpose and need, considering all 

relevant Forest Plan objectives, goals and standards. 

During the project’s public scoping process, several commenters offered general support 

regarding the proposal for a reliable and consistent supply of timber from the project area, 

while others supported the small and microsale component of the project, but not the 

inclusion of a separate helicopter offering. One organization submitted the majority of the 

comments during both comment periods3

. The concerns ranged from NEPA compliance, to 

issues regarding wildlife, subsistence, soils, and watershed degradation. Public comments 

have been addressed in the analysis presented in the EA, or within the response to 

comments located on the project webpage at: 

http://www.fs.usda.gov/project/?project=29099. 

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

involve unique or unknown risks. 

Based on the analysis, I believe the possible effects on the human environment are not 

highly uncertain and do not involve unique or unknown risks. Therefore, I have determined 

no significant impacts would occur that adversely affect the human environment. 

The Mitkof Island EA discloses the direct, indirect and cumulative effects of the Selected 

Alternative (see the Environmental Consequences sections for all the resources in the 

Mitkof Island EA and individual resource reports in the project record). Those effects, along 

with those documented in the Biological Assessments/Evaluations do not indicate uncertain, 

unique or unknown risks (see Lombard and Dungan 2014 and Whitacre 2014a). 

The Forest Service has experience implementing the types of activities planned in the 

Mitkof Island EA, and has found the effects from similar actions in similar areas to be 

reasonably predictable and well-understood. Monitoring of past activities and projects 

support the predicted effects disclosed in this analysis. Tongass monitoring reports can be 

accessed online at: http://www.fs.usda.gov/main/tongass/landmanagement/planning. 

 

3

 Public comments on the Mitkof Island project can be viewed online at: https://cara.ecosystemmanagement.org/Public//ReadingRoom?Project=29099. 
Mitkof Island – Decision Notice and Finding of No Significant Impact 

12 – DN/FONSI 

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

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

I have determined the Selected Alternative does not establish a precedent for future actions 

with significant effects. All identified effects related to subsistence restrictions within the 

project area were anticipated by the 1997 Forest Plan, adopted by the 2008 Forest Plan, and 

are in accordance with ANILCA 810 subsistence regulations and Forest Service Handbook 

(FSH 2090.20) direction. 

Any future action(s) not covered by this proposal will consider all relevant scientific, sitespecific information available at that time and be subject to the appropriate NEPA analysis 

that will consider the direct and indirect effects and cumulative effects of all other past, 

present, and reasonably foreseeable actions. The Mitkof Island project does not include 

future connected actions. 

The effects of the Selected Alternative were considered by the interdisciplinary team within 

the context of past, present, and reasonably foreseeable future actions (see the cumulative 

effects sections for all resources in the Mitkof Island EA). The decision is within the scope 

of the 2008 Forest Plan and is not expected to establish a precedent for future actions. 

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

cumulatively significant impacts. 

I have determined, based on project design, available scientific information and public 

testimony that the Selected Alternative is not related to other actions with individually 

insignificant but cumulatively significant impacts. 

My rationale for these determinations can be found in the Deer Habitat/Subsistence Use 

section (above), and is summarized below. 

The public expressed concerns about the current deer habitat capability on Mitkof Island. 

They feel further loss of high-volume POG below 800 feet (deep snow habitat for deer) 

could affect the subsistence use of deer, as the Selected Alternative could result in a 

cumulative reduction of this habitat to 52 percent of what was originally present, a 1 percent 

reduction from the WAA’s existing condition (EA, p. 41, Table 8). 

In order to respond to the dual public concern of further loss of deer winter (deep snow) 

habitat affecting deer populations, and subsistence use in the project area, the majority of 

the high value deer winter habitat available for harvest in the project area was not proposed 

for even-aged harvest. 

Furthermore, the reduction in deer deep snow winter habitat via a clearcut prescription (26 

acres total, Table 5) does not occur in one contiguous area, but is spread out over 10 units 

ranging from 4.6 to 82.1 acres in size (289 acres total), with no one unit comprised solely of 

this habitat type. Efforts were made to avoid deer deep snow habitat types when proposing 

management prescriptions; however, because most stands are made up of a mosaic of 

different habitats (i.e., not contiguous), this was not always possible. 

Historic and current theoretical and empirical literature suggests in some parts of Southeast 

Alaska, including Mitkof Island, trends in deer populations may be more heavily influenced 
Mitkof Island – Decision Notice and Finding of No Significant Impact 

DN/FONSI - 13 

by predation and severe winters, and secondly by the quality and availability of deer winter 

habitat. Therefore, I conclude the additional, minimal habitat reductions of the Selected 

Alternative will have a negligible effect on existing deer populations, and deer subsistence 

use opportunities on Mitkof Island. 

The expected end result is that the cumulative change in deer habitat capability (percent of 

historic habitat capability remaining) could drop by 0.6 percent to 56.0 percent 1 year postharvest (2015) and by 0.9 percent to 55.0 percent at stem exclusion (2041) (EA, p. 40, Table 

6). However, these cumulative changes to deer habitat capability are not expected to 

significantly affect the current deer population in the project area. 

Also, our analysis finds that deer density at stem exclusion (14.3 deer/mi2) is higher than 

the predicted deer density value for WAA 2007 (12 deer/mi2) after 100+ years and full 

implementation of the 2008 Forest Plan (Dungan 2014b, p. 88). 

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

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

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

I have determined that a finding of No Historic Properties Affected is appropriate for this 

project. This project meets the provisions stipulated in the Programmatic Agreement 

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

and the State Historic Preservation Officer. I also determined that no significant impacts 

would occur that adversely affect districts, sites, highways, structures, or objects listed in or 

eligible for listing in the National Register of Historic Places or cause loss or destruction of 

significant scientific, cultural, or historical resources (EA, pp. 73 and 74). 

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

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

1973. 

I have determined no significant impacts would occur that adversely affect an endangered or 

threatened species or its critical habitat. 

A Biological Assessment (BA) for fish and wildlife was completed for the Mitkof Island EA 

(Lombard and Dungan 2014). It was determined there are no known endangered or 

threatened species or critical habitat in the project area; therefore, project activities are not 

likely to adversely affect any federally listed wildlife and fish species known or suspected to 

occur in the vicinity of the Petersburg Ranger District. The National Marine Fisheries 

Service (NMFS) concurred with the Forest Service’s determination regarding ESA-listed 

species under NFMS’s authority (NSDC 2015). 

No plants federally listed or proposed by the U.S. Fish and Wildlife Service are known or 

expected to occur in the Alaska Region; therefore, the proposed activities will not affect 

endangered or threatened plant populations or habitat (Whitacre 2014a). 

 
Mitkof Island – Decision Notice and Finding of No Significant Impact 

14 – DN/FONSI 

Whether the action threatens a violation of federal, state, or local law or requirements 

imposed for the protection of the environment. 

The following findings show the actions do not violate federal, State, or local law 

requirements imposed for the protection of the environment and have been reviewed by 

federal and State agencies. The action is consistent with the Forest Plan. 

Findings Required by Other Laws and Regulations_____ 

Many federal laws and executive orders pertain to project-specific planning and 

environmental analysis on federal lands. While most of the laws and executive orders listed 

below pertain to all federal lands, some of the laws are specific to Alaska. 

Several of the laws and executive orders listed below require project-specific findings or 

other disclosures. These apply to federal land management projects and activities and are 

included here and in any future Decision Notice. They apply to all alternatives considered in 

the Mitkof Island EA. 

Alaska National Interest Lands Conservation Act (ANILCA) of 

1980; Section 810 

Per Forest Service Handbook direction (FSH 2090.20 Section 21(3)), which states if, during 

the EA process, the responsible official perceives a finding of a significant possibility of a 

significant restriction on subsistence uses for a proposed action is likely to occur, a 

justification will be prepared and submitted to the Regional Forester for concurrence. The 

Regional Forester reviewed the subsistence findings of the Mitkof Island EA, concurred 

with the findings on March 20, 2014, and determined the project is justified as proposed. 

This concurrence triggered FSH 2090.23 Section 13 Notice and Hearings. In accordance 

with this direction, an ANILCA 810 subsistence hearing was held on April 23, 2014. Seven 

members of the public attended with three providing oral testimony related to their use of 

subsistence resources in the project area. Following the hearing, three additional written 

testimonies were received. 

For more information regarding the ANILCA 810 subsistence analysis, findings and 

determinations for this project, see the Issue 2 (Deer Habitat/Deer Subsistence Use) section 

in the EA, p. 42, and the remainder of this ANILCA section. 

Subsistence Evaluation and Findings 

The rural communities most impacted by potential changes to subsistence resources are 

Petersburg and Kupreanof. Currently, portions of GMU 3, including Mitkof Island, have a 

restricted Sitka black-tailed deer hunting season. 

The direct effects from the alternatives in the Mitkof Island EA do not present a significant 

possibility of a significant restriction of subsistence uses of deer, black bear, marten, wolf, 

otter, marine mammals, waterfowl, salmon, other finfish, marine invertebrates, and other 

foods. Analysis does indicate that cumulatively (under full implementation of the Forest 

Plan) there may be a significant possibility of a significant restriction of subsistence use of 

deer for all of the alternatives including the No Action Alternative. Since there is a 

possibility of a significant restriction regardless of whether or not the project is 
Mitkof Island – Decision Notice and Finding of No Significant Impact 

DN/FONSI - 15 

implemented, as the responsible official, I have determined the cumulative effect of the 

Mitkof Island project on deer habitat, access and competition are minor and will not cause 

further restrictions to subsistence uses. Based on this rationale, the human environment will 

not be adversely affect and the project’s effect the subsistence use of deer is not considered 

significant. 

This restriction, if it occurs, could be a result of: 

1. A cumulative decrease in habitat capability when existing young-growth forest stands 

mature and shade out forage that could decrease the abundance or distribution of deer; 

2. A very severe winter, which occurs periodically, causing high deer mortality as 

happened in the late 1960s; 

3. An increase of predator populations, especially wolves, due to less aggressive predator 

harvests; and 

4. Anticipated human population growth with its associated increase in subsistence hunter 

demand when compared to the habitat capability to produce deer. 

The Selected Alternative involves less than 4 percent of Mitkof Island’s NFS land and meets 

the economic needs of the public while minimizing impacts on subsistence use through the 

selection and design of the individual harvest units (i.e., use of high-retention silvicultural 

prescriptions) and road management objectives. 

The direct effects solely from the Selected Alternative on subsistence use would result in a 

reduction of less than 1 percent in deer habitat capability 1 year post-harvest, and less than 3 

percent at stem exclusion (EA, p. 43). 

In considering this information in conjunction with public testimony, I have determined that 

choosing a different alternative, including the No Action, or locating harvest in another 

location on Mitkof Island would not avoid or substantially lessen the risk to subsistence use 

in the future, and that reasonable measures to minimize impacts on subsistence have been 

adopted to the maximum extent practicable while still meeting the purpose and need for this 

project. I believe the Selected Alternative reflects a reasonable balance between the 

projected need for timber from the project area to help meet the Forest Plan, ANILCA, and 

TTRA timber-related objectives, and the continued protection of subsistence uses and 

resources. 

Subsistence Determinations 

The 1997 Forest Plan (USDA Forest Service 1997b) included a cumulative effects analysis 

of resource development on subsistence resources. Based on that analysis, the Forest Plan 

ROD (USDA Forest Service 1997a, p. 36) concluded that full implementation of the Forest 

Plan “may result in a significant restriction to subsistence use of deer due to the potential 

effects of projects on the abundance and distribution of these resources, and on competition 

for these resources.” It is not possible to substantially reduce timber harvest in one area and 

concentrate it in other areas without affecting subsistence resources and uses important to 

one or more rural communities (USDA Forest Service 1997a). 

For this reason, timber sale activities cannot completely avoid cumulative landscape effects 

to subsistence uses. Based on this evaluation and ANILCA definitions of significance, it was 
Mitkof Island – Decision Notice and Finding of No Significant Impact 

16 – DN/FONSI 

determined that, in combination with other past, present and reasonably foreseeable future 

actions, all of the alternatives (if implemented through project-level decisions and actions) 

may result in a significant restriction of subsistence uses of deer, due to potential effects on 

abundance and 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. As a result of this finding, the Forest 

Service held a subsistence hearing in April 2014 and in the process notified the appropriate 

state agencies, local communities, the Southeast Alaska Federal Subsistence Regional 

Advisory Council, and State Fish and Game Advisory Committees. 

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. 

Necessary and Consistent with Sound Management of Public Lands 

The Selected Alternative has been examined 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, the Tongass Timber 

Reform Act (TTRA), the Wilderness Act, the 2008 Forest Plan Amendment Final EIS, as 

amended, and the Alaska State Forest Resources and Practices Act have been considered.

National Forest land management plans are required by the National Forest Management 

Act and must provide for the multiple-use and sustained yield of renewable forest resources 

in accordance with the Multiple-Use Sustained Yield Act of 1960. Multiple-use is defined as 

“the management of all the various renewable surface resources of the National Forest 

System so that they are utilized in the combination that will best meets the needs of the 

American people” (36 CFR 219.3). The alternatives presented in the EA represent different 

ways of managing the resources to meet these needs. Each provides a different mix of 

resource uses and opportunities, and each has some potential to affect subsistence uses. 

Given the framework and emphasis of the Selected Alternative, the possibility of a 

restriction is necessary and consistent with sound management of public land. 

ANILCA Title VIII places an emphasis on the maintenance of subsistence resources and 

lifestyles. However, the Act also provides for adequate opportunity for satisfaction of the 

economic and social needs of the State of Alaska and its people and recognizes that public 

lands are necessary and appropriate for more intensive uses. The Act also required the 

Forest Service to make available 4.5 billion board feet per decade from the Tongass 

National Forest. The TTRA removed the 4.5 billion board foot requirement, but directs the 

Forest Service to seek to meet market demand for timber to the extent consistent with 

providing for the multiple-use and sustained yield of all renewable forest resources, and 

subject to applicable law. 

The timber volume for this project was designed to provide a flexible supply of volume over 

a period of several years to offer a variety of sales intended for regional and local timber 

operators of varying sizes. The Selected Alternative can help meet the Forest Plan and 
Mitkof Island – Decision Notice and Finding of No Significant Impact 

DN/FONSI - 17 

TTRA objectives, while also providing reasonable protection measures for forest resources, 

especially for subsistence. It is consistent with the Forest Plan, laws, regulations, policies, 

public needs, and the capabilities of the land. 

Amount of Public Land Necessary to Accomplish the Proposed Action 

Considering sound multiple-use management of public lands, I have determined the amount 

of land necessary to implement the Selected Alternative is the minimum necessary to 

accomplish its purpose. The majority of the forested portions of the Tongass are used by at 

least one rural community for subsistence purposes for, at a minimum, deer hunting. It is not 

possible to avoid all of these areas in implementing resource use activities, such as timber 

harvesting and road construction, under any alternative, 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 most important for subsistence uses, such as beaches and estuaries, and areas with 

high fish and wildlife habitat values. 

Partial-harvest treatments using two-aged and uneven-aged silvicultural systems are 

prescribed for 82 of the 99 proposed units. Specifically, 17 units are proposed for clearcut 

prescription; 13 units are proposed for 15 percent retention; 27 units are proposed for 95 

percent retention; 12 units are proposed for 98 percent retention; 24 units are proposed for 

66 percent retention; and 8 young-growth stands are proposed for 50 percent retention. 

Because a partial-harvest unit removes less timber than a traditional clearcutting unit of the 

same size, the effects for many resources will be less than the effects from clearcutting. In 

addition to mitigation through the silvicultural prescriptions listed above, 14 units were 

dropped to protect deer winter range and/or travel corridors. Additional units were dropped 

for other reasons (e.g., goshawk buffers, scenery issues and watershed concerns). 

Past harvest practices of clearcutting in the Mitkof Island EA project area will also affect 

future deer habitat capability (DHC). By the year 2041, if the Selected Alternative is 

implemented, the predicted DHC is 45 percent of pre-large-scale timber harvest conditions. 

This decline will occur when the existing young-growth stands reach complete canopy 

closure, which will result in reduced forage for deer. The use of partial harvest, as designed 

for the Mitkof Island EA project, will not create the large openings created by past 

clearcutting; therefore, future changes in DHC will not be as great. 

Management activities cannot completely avoid all subsistence areas, which are broadly 

distributed across the Forest. Other areas that could be harvested may be limited by 

additional resource concerns such as soil and water protection, high-value wildlife habitat, 

economics, scenic quality, or unfeasible unit and road design. The impact of viable timber 

harvest projects usually includes the alteration of old-growth habitat which reduces habitat 

capability for old-growth associated species. 

Reasonable Steps to Minimize Adverse Impacts upon Subsistence Uses and 

Resources 

The Forest Plan took considerable steps to minimize adverse impacts to subsistence uses 

and resources. Forest Plan Standards and Guidelines protect important deer winter habitat. 

Other reasonable steps to minimize adverse impacts to subsistence resources include: the 

Forest Plan land use designation (LUD) strategy, the old-growth habitat reserve strategy, 
Mitkof Island – Decision Notice and Finding of No Significant Impact 

18 – DN/FONSI 

travel and access management planning, Forest Plan Standards and Guidelines for stream, 

beach and estuary buffers, and the use of silvicultural systems that maintain components of 

overstory tree canopy, such as two-aged and uneven-aged management. 

In 1995, during the analysis for the Mitkof Landscape Design, small habitat conservation 

areas that encompassed important wildlife habitat were recommended for Mitkof Island. 

These were later incorporated into the Forest Plan (1997, as amended) as small old-growth 

habitat reserves. Much deliberation occurred during the Mitkof Landscape Design analysis 

and the environmental analysis for the Mitkof Island project to minimize impacts to high 

value deer habitat on Mitkof Island. 

Selecting the Selected Alternative would approve construction of 1.3 miles of new NFS 

road. New roads would be seasonally open. All temporary roads would be closed after 

timber harvest. The action alternatives will maintain a road density of 1.07 miles per square 

mile for Mitkof Island after project completion and after completion of cumulative 

activities. Therefore, the current level of access to subsistence species will be maintained. 

Most of the high-value deer winter habitat available for harvest is not proposed for 

clearcutting. During internal scoping, the IDT identified and acknowledged reduction of 

deer habitat, in particular deer winter range and its possible effects on subsistence users, 

would be an issue. This was acknowledged in the public scoping letter. With this in mind, 

the IDT developed alternatives to minimize the reduction of deer winter range while still 

providing small sale opportunities in a few areas. Units identified as important deer winter 

range were given retention rates of 66, 95 and 98 percent, and units considered important 

for elevational connectivity were dropped from consideration. 

The risk of increased hunting restrictions may be reduced somewhat, through moreintensive management (e.g., thinning) of the existing and future closed-canopy, younggrowth forests in this area. Between 1979 and 2009, 8,395 acres of young-growth on Mitkof 

Island have been thinned. An additional 1,038 acres of young-growth will be treated in 

2014, including 281 acres to address wildlife habitat enhancement needs (e.g., gaps, unthinned travel corridors and pruning). In 2015 and 2016, the District proposes to treat up to 

870 acres, including 219 acres managed by the State of Alaska, specifically to benefit deer 

(ecological thinning). 

2008 Tongass Land and Resource Management Plan (Forest Plan) 

This decision is consistent and all project alternatives comply with the Forest Plan. This 

project incorporates all applicable Forest Plan Standards and Guidelines and management 

prescriptions, and complies with Forest Plan goals and objectives. The Forest Plan complies 

with all resource integration and management requirements of 36 CFR 219 (219.14 through 

219.27). Application of Forest Plan direction ensures compliance at the project level; 

therefore, the Selected Alternative is consistent with the Forest Plan. 

Even-aged Management as the Optimal Method of Harvesting 

The Forest Plan (USDA Forest Service 2008a, pp. 4-71 to 4-72) gives guidance on when to 

use even-aged management. Even-aged management will be used in this project to: 

♦ Achieve timber production objectives; 
Mitkof Island – Decision Notice and Finding of No Significant Impact 

DN/FONSI - 19 

♦ Preclude and minimize the occurrence of, and the potential adverse impacts from, 

windthrow; and 

♦ Provide for the establishment and growth of desired trees. 

Harvest Openings over 100 Acres in Size 

There are no harvest openings over 100 acres proposed for this project. Therefore, the 

Selected Alternative is consistent with the Forest Plan and FSM 2410.3, R10 Supp. 2400-

2002-1 and consequently complies with the National Forest Management Act. 

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

The Bald and Golden Eagle Protection Act provides for the protection of the bald eagle and 

the golden eagle by prohibiting, except under certain specified conditions, the taking, 

possession and commerce of such birds. One known bald eagle nest is within 660 feet of a 

harvest unit, and timing restrictions for harvest will be implemented if the nest is found to 

be active to comply with the Bald and Golden Eagle Protection Act. Should an active nest 

be found adjacent to any activity, appropriate nest site buffers and timing restrictions will be 

implemented. Bald eagles are managed by the USFWS under the National Bald and Golden 

Eagle Protection Act and through the Bald Eagle Take Permit Program (USDI Fish and 

Wildlife Service 2007).

Clean Air Act of 1970 (as amended) 

Emissions from the implementation of the Selected Alternative would be of short duration 

and are not expected to exceed State of Alaska ambient air quality standards (18 AAC 50). 

Clean Water Act of 1977 (as amended) 

Project activities meet all applicable State of Alaska Water Quality Standards. Congress 

intended the Clean Water Act of 1972 (Public Law 92-500) as amended in 1977 (Public Law 

95-217) and 1987 (Public Law 100-4) to protect and improve the quality of water resources 

and maintain their beneficial uses. Section 313 of the Clean Water Act and Executive Order 

12088 of January 23, 1987 addresses federal agency compliance and consistency with water 

pollution control mandates. Agencies must be consistent with requirements that apply to 

“any governmental entity” or private person. Compliance is to be in line with “all Federal, 

State, interstate, and local requirements, administrative authority, and process and sanctions 

respecting the control and abatement of water pollution.” 

Sections 208 and 319 recognized the need for control strategies for nonpoint source 

pollution caused by activities such as timber harvest. The National Nonpoint Source Policy 

(December 12, 1984), the Forest Service Nonpoint Strategy (January 29, 1985), and the 

USDA Nonpoint Source Water Quality Policy (December 5, 1986) provide a protection and 

improvement emphasis for soil and water resources and water-related beneficial uses. Soil 

and water conservation practices (BMPs) are recognized as the primary control mechanisms 

for nonpoint source pollution on National Forest System lands. The EPA supports this 

perspective in their guidance, “Nonpoint Source Controls and Water Quality Standards” 

(August 19, 1987). 

The Forest Service must apply BMPs that are consistent with the Alaska Forest Resources 

and Practices Act (AFRPA) to achieve Alaska Water Quality Standards. The site-specific 
Mitkof Island – Decision Notice and Finding of No Significant Impact 

20 – DN/FONSI 

application of 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 (2007). In 1997, the State approved the BMPs in the Forest Service Soil 

and Water Conservation Handbook (FSH 2509.22, July 2006) as consistent with AFRPA. 

This handbook is incorporated by reference into the Forest Plan and this project. 

The Forest Service recently issued National Core BMPs (USDA Forest Service 2012). The 

Mitkof Island project would implement the most recent BMP guidance. The list of key 

BMPs that would be implemented as part of this project is included in the unit cards, located 

on the project webpage: http://www.fs.usda.gov/project/?project=29099.

A discharge of dredge or fill material from normal silvicultural activities such as harvesting 

for the production of forest products is exempt from Section 404 permitting requirements in 

waters of the United States, including wetlands (404)(f)(1)(A). Forest roads qualify for this 

exemption only if they are constructed and maintained in accordance with Baseline 

Provisions to assure that flow and circulation patterns and chemical and biological 

characteristics of the waters are not impaired (404)(f)(1)(E). The Baseline Provisions that 

must be followed are specified in 33 CFR 323.4(a). These specific BMPs are incorporated 

into the Soil and Water Conservation Handbook under BMP 12.5. All necessary Clean 

Water Act permits will be obtained before project implementation, including, if necessary, 

any discharge permits under Section 402 of the Clean Water Act. 

The design of harvest units for the project was guided by standards, guidelines and direction 

in the Forest Plan and applicable Forest Service Manuals and Handbooks. The projects unit 

cards contain specific details on practices prescribed to prevent or reduce nonpoint sediment 

sources. 

Endangered Species Act of 1973 (as amended) 

A biological assessment was completed for the project activities, which indicates it is “Not 

Likely to Adversely Affect” any federally listed threatened or endangered species. On 

March 6, 2015, NMFS concurred with the finding of “not likely to adversely affect” the 

federally listed species under their authority (NSDC 2015). The biological assessment and 

NOAA’s concurrence are included in the project record. 

Federal Cave Resource Protection Act of 1988 

Field reconnaissance and a GIS review found no signs of karst features (sink holes or caves) 

on Mitkof Island. 

Forest Service Transportation Final Administrative Policy (Roads 

Rule) 

This decision and the EA have been prepared to be consistent with the Forest Service 

Transportation Final Administrative Policy (2005) and the Petersburg Access Travel 

Management EA (2009). 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). 
Mitkof Island – Decision Notice and Finding of No Significant Impact 

DN/FONSI - 21 

Magnuson-Stevens Fishery Conservation and Management Act 

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

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

for actions or proposed actions that may adversely affect essential fish habitat (EFH). The 

Act promotes the protection of essential fish habitat through review, assessment, and 

mitigation of activities that may adversely affect these habitats. Consultation procedures 

have been documented in an attachment to a June 26, 2007 NMFS letter to the Regional 

Forester. Although this Consultation Procedures document expired on June 28, 2012, 

consultation is still required under the Act and the 2007 procedures remain applicable and 

have been followed for this project. 

The EFH determination in the EA found that the Selected Alternative may adversely affect 

EFH because the project entails ground-disturbing actions in watersheds that contain 

anadromous species, and log hauling would occur on new and existing roads that cross 

anadromous streams. In addition, the project would authorize the use of marine access 

facilities (MAFs). Effects to EFH will be minimized by following the standards and 

guidelines in the Forest Plan and implementing the BMPs specified in the unit cards. 

Additional adverse impacts would likely occur only as a result of unforeseen circumstances. 

Formal consultation was initiated when the EA containing the full EFH determination was 

received by NMFS. 

Marine Mammal Protection Act of 1972 

Actions proposed in the Selected Alternative are “not likely to adversely affect” marine 

mammals (Lombard and Dungan 2014, NSDC 2015). Marine mammal viewing guidelines 

administered by the NMFS and enforced by the Coast Guard are sufficient for their 

protection. Contractors, purchasers 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. NMFS administers the Marine Mammal Protection 

Act (MMPA), which prohibits the “take” of all marine mammal species in U.S. waters. 

“Take” is defined as “to harass, hunt, capture, or kill, or attempt to harass, hunt, capture, or 

kill any marine mammal.” Harassment is defined in the MMPA as “any act of pursuit, 

torment, or annoyance which has the potential to injure a marine mammal or marine 

mammal stock in the wild; or has the potential to disturb a marine mammal stock in the wild 

by causing disruption of behavior patterns, including, but not limited to, migration, 

breathing, nursing, breeding, feeding, or sheltering.” 

Multiple-Use Sustained-Yield Act of 1960 

Authorizes the Secretary of Agriculture to: administer National Forest System lands for 

outdoor recreation, range, timber, watershed, and wildlife and fish purposes; to develop the 

surface renewable resources for multiple-use and sustained-yield of several products and 

services to be obtained from these lands, without impairment of the productivity of the land; 

and, to cooperate with interested state and local governmental agencies and others in the 

development and management of the national forests. The Act also recognizes and clarifies 

Forest Service authority and responsibility to manage wildlife and fish on national forests. 

The Mitkof Island project meets the requirements of this law.
Mitkof Island – Decision Notice and Finding of No Significant Impact 

22 – DN/FONSI 

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

The National Forest Management Act (NFMA) requires specific determinations in the 

Decision Notice: consistency with existing Forest Plan, 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 are in 

Section 2.1 of the EA, and the project record. 

National Historic Preservation Act of 1966 (as amended) 

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

includes locating, inventorying and nominating all cultural sites that may be directly or 

indirectly affected by scheduled activities. This activity has been reviewed by a qualified 

archeologist and a determination was made that no known cultural resources are present in 

the project area. 

Tongass Timber Reform Act (TTRA) of 1990 

The Tongass Timber Reform Act (TTRA) prohibits commercial timber harvest within 100 

feet on either side of Class I streams and Class II streams that flow directly into Class I 

streams. TTRA also requires the use of BMPs. The Forest-wide Riparian Standards and 

Guidelines in the Forest Plan incorporate the requirements of TTRA. 

Timber harvested as proposed in the Selected Alternative would 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 Order 11988 (Floodplain Management) 

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 would not affect floodplain 

occupancy. Forest Plan Standards and Guidelines limit riparian harvest to the extent feasible 

to facilitate road construction and logging operations. The amount of road in floodplains 

will be minimized whenever possible as stated in the BMPs. Roads may be constructed in or 

through floodplains subject to BMPs, which minimize floodplain modification. 

Executive Order 11990 (Protection of Wetlands) 

Executive Order 11990 requires federal agencies to avoid, to the extent possible, the longand short-term adverse effects associated with the destruction or modification of wetlands. 

There would be minimal loss of wetlands from the implementation of the Selected 

Alternative, primarily due to road construction. In some areas, soil moisture regime and 

vegetation composition or structure may be altered by timber harvest; however, these altered 

acres would still be classified as wetlands and function as wetlands in the ecosystem. 

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. 
Mitkof Island – Decision Notice and Finding of No Significant Impact 

DN/FONSI - 23 

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 any of the alternatives. 

The community of Petersburg has low-income and minority households, although no 

disproportional adverse effects are expected to occur solely to those people due to 

implementation of the Selected Alternative. Efforts were made during the public 

participation process to inform the community as a whole of the project and the possible 

effects through notices in local papers, local meetings, and tribal government 

correspondence (see the Public and Agency Involvement section). Also, based on public 

input, efforts were made during the planning process to lessen impacts to important 

subsistence species, and specifically Sitka black-tailed deer. 

Effects to wildlife and subsistence resources are addressed in the Deer Habitat/Deer 

Subsistence Use section of the Mitkof Island EA (pp. 35-41), and the Sitka Black-tailed 

Deer Subsistence Use section (p. 42), and in the project’s subsistence report (Dungan 

2014a). 

The direct effects from the alternatives in the Mitkof Island EA do not present a significant 

possibility of a significant restriction of subsistence uses of deer, black bear, marten, wolf, 

otter, marine mammals, waterfowl, salmon, other finfish, marine invertebrates, and other 

foods. Analysis does indicate that cumulatively (under full implementation of the Forest 

Plan) there may be a significant possibility of a significant restriction of subsistence use of 

deer for all of the alternatives including the No Action Alternative. Since there is a 

possibility of a significant restriction regardless of whether or not the project is 

implemented, it was determined that the cumulative effect of the Mitkof Island project on 

deer habitat, access and competition are minor and will not cause further restrictions to 

subsistence deer users, regardless of economic status. 

Executive Order 12962 (Aquatic Systems, Recreational Fisheries) 

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

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

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

opportunities. The Selected Alternative minimizes the effects on aquatic systems through 

project design, application of standards and guidelines, BMPs, and site-specific mitigation 

measures. In the Selected Alternative, recreational fishing opportunities would remain 

essentially the same as the current condition because aquatic habitats are protected through 

implementation of BMPs and riparian buffers. 

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. In a government-to-government relationship, the tribal government is 

responsible for notifying the agency of the existence of a sacred site. A sacred site is defined 

as a site that has sacred significance due to established religious beliefs or ceremonial uses, 

and which has a specific, discrete, and delineated location that has been identified by the 
Mitkof Island – Decision Notice and Finding of No Significant Impact 

24 – DN/FONSI 

tribe. 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. An invasive plant risk assessment was completed for this project which determined 

project activities are not expected to significantly increase the distribution of weeds within 

the project area (Whitacre 2014b). Invasive plants should remain primarily along road 

corridors4

 with implementation of mitigation measures and soil BMPs. 

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-togovernment consultation with federally recognized tribes on proposed actions with tribal 

implications. 

Throughout the span of the Mitkof Island project, the District Ranger and archaeologists 

communicated with the Organized Village of Kake, Petersburg Indian Association, Wrangell 

Cooperative Association, and Tlingit/Haida Central Council (federally recognized tribes), as 

well as the native corporations Sealaska and Kake Tribal as described in Public and Agency 

Involvement section of the Decision Notice. Tribal consultation does not imply the tribes 

endorse the preliminary selected action 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 law provides the primary 

mechanism to regulate waterfowl hunting seasons and bag limits, but its scope is not just 

limited to waterfowl. The migratory species that may stay in the area utilize most, if not all, 

of the habitats described in the analysis for breeding, nesting, and raising their young. The 

effects on these habitats were analyzed for this project. 

The decision will not have a significant direct, indirect, or cumulative effect on any 

migratory bird species in the project area (Dungan 2014b, pp. 93 and 94). There may be 

direct moderate effects on individuals or small groups and their nests from the harvest of 

timber or the disturbance caused by harvest and related activities. 

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 

 

4

 Road corridors include the actual road and the adjacent land affected by its construction. 
Mitkof Island – Decision Notice and Finding of No Significant Impact 

DN/FONSI - 25 

analysis considered and disclosed the effects on hunting activities. The Selected Alternative 

is expected to maintain the current hunting opportunities by adhering to the Forest Plan 

Standards and Guidelines that maintain habitat for hunted species. 

Required Permits and Concurrence_________________ 

Prior to implementation of the timber sale, various permits and concurrence are required 

from other federal and State agencies. Some permits are already in place for the project; 

others will need to be obtained. 

♦ All new road construction planned for this project is for silvicultural purposes and 

will be located and designed to meet State approved BMPs and 33 CFR 323 

guidelines regarding permits for discharges of dredged or fill material into waters of 

the United States as discussed in Section 404 of the Clean Water Act (CWA) (33 

U.S.C. 1344); therefore, new road construction through wetlands will not require a 

404 permit. 

♦ A storm water discharge permit will be acquired by the timber sale contractor. A 

permit for Alaska Pollutant Discharge Elimination System (Section 402 of the 

Clean Water Act) is held by the Forest Service. Both of these permits are required 

for the Blind Slough and Woodpecker Cove LTF(s). 

♦ Permits will be needed from the US Army Corps of Engineers and the State of 

Alaska if large amounts of fuel are stored in the project area for helicopter yarding. 

The timber sale contractor will acquire these permits. 

♦ ADF&G and the Forest Service have a MOU to reach concurrence prior to 

conducting any instream activities. A Title 16 concurrence must be reached before 

any work occurs below ordinary high water for fish-bearing water bodies that will 

use, divert, obstruct, pollute, or change the natural flow or bed of water bodies. 

♦ It was determined by the Forest Service archaeologist that no historic properties will 

be affected by any of the proposed alternatives. Under the terms of the existing 

Programmatic Agreement with the Alaska State Historic Preservation officer and 

the Advisory Council on Historic Preservation (USDA Forest Service 2010) “the 

Forest may proceed with the undertaking in lieu of a consensus determination of 

eligibility pursuant to 36 CFR 800.4.” 

♦ On March 6, 2015, NMFS concurred with the Forest Service’s finding of “not likely 

to adversely affect” ESA-listed species under their authority (NSDC 2015). 

Process for Considering New Information_________ 

In the event there is new information or changed direction for any resource during the 

implementation of the Mitkof Island decision, the following Forest Service direction from 

Forest Service Handbook (FSH) 1909.15, section 18.1 will be used to evaluate the previous 

analysis: 

♦ If new information or changed circumstances relating to the environmental impacts 

of a proposed action come to the attention of the responsible official after a decision 

has been made and prior to completion of the approved program or project, the 

responsible official should review the information carefully to determine its 
Mitkof Island – Decision Notice and Finding of No Significant Impact 

26 – DN/FONSI 

importance. Consideration should be given to whether or not the new information or 

changed circumstances are within the scope and range of effects considered in the 

original analysis. 

Based on further direction in FSH 1909.15 section 18, after interdisciplinary review and 

consideration of the changed circumstances or the new information, the responsible official 

may determine whether or not a correction, supplement, or revision to the EA is necessary. 

If a supplemented or revised EA and FONSI is completed, a new decision notice would be 

issued, or, documentation that the original decision is to remain in effect and unchanged, 

following direction in FSH 1909, Chapter 40. 

Distribution____________________________________ 

The Mitkof Island Decision Notice, FONSI, and EA are available on the internet at 

http://www.fs.usda.gov/project/?project=29099. Notification of the availability of this 

decision was sent to those on the project mailing list including State and federal agencies, 

anyone commenting on the project, and anyone requesting a copy. 

The project mailing list is available in the project record. The Decision Notice is also 

available in hard copy or on CD, upon request. 

Implementation Date_____________________________ 

The objection period ended on September 22, 2014. Three objections were filed; however, 

one objection was set aside from review due to untimely scoping comments. Both 

qualifying objectors declined offers to meet to discuss an objection resolution. 

The Forest Supervisor issued responses to the objectors’ objections on November 6, 2014 

following his review pursuant to 36 CFR 218.11(b)(1). He supports the project and 

concluded it is in compliance with environmental laws, regulations and policies, and the 

Forest Plan. In addition, he provided instructions in a letter issued to me on November 13, 

2014 that outlined requirements that needed to be addressed before the decision could be 

signed. 

I have addressed the reviewing officer’s instructions and have incorporated the required 

clarifications into this decision. 

The project can be implemented immediately upon my signing of this Decision Notice 

pursuant to 36 CRF 218.12. 

Mitkof Island – Decision Notice and Finding of No Significant Impact 

28 – DN/FONSI 

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DN/FONSI - 29 

References____________________________________ 

Burke, R. 2014. Unpublished Report. Mitkof Island Environmental Assessment. 

Transportation Report. Petersburg, AK: USDA Forest Service, Tongass National 

Forest, Petersburg Ranger District. 

Dungan, J. 2014a. Unpublished Report. Subsistence Report, Mitkof Island EA. Petersburg, 

AK: USDA Forest Service, Tongass National Forest, Petersburg Ranger District. 

Dungan, J. 2014b. Unpublished Report. Wildlife Resource Report, Mitkof Island EA. 

Petersburg, AK: USDA Forest Service, Tongass National Forest, Petersburg Ranger 

District. 

Lombard, H. and J. Dungan. 2014. Unpublished Report. Biological Evaluation for the 

Mitkof Island Environmental Assess (EA) Project. USDA Forest Service: Alaska 

Region, Tongass National Forest, Petersburg Ranger District. 48 pp. 

National Archives and Records Administration. 2005. Department of Agriculture. Forest 

Service. 36 CFR Parts 212, 251, 261 and 295. Travel Management; Designated 

Routes and Areas for Motor Vehicle Use; Final Rule. Federal Register, Vol. 70, No. 

216. November 9, 2005. Rule and Regulations: pp. 68264-68291. 

Reynolds, B. 2014. Unpublished Report. Mitkof Island EA. Geology, Minerals, Karst, Soils, 

and Wetlands. Craig, AK: USDA Forest Service, Craig Ranger District. 

USDA Forest Service. 2012. National Best Management Practices for Water Quality 

Management on National Forest System Lands. FS-990. April 12. 

USDA Forest Service. 2010. Third Amended Programmatic Agreement among the USDA 

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

the Alaska State Historic Preservation Officer regarding Heritage Program 

Management on National Forests in the State of Alaska. Manuscript on file, USDA 

Forest Service, Tongass National Forest, Petersburg Ranger District, Petersburg, 

Alaska. 

USDA Forest Service. 2009. Petersburg Ranger District Access Travel Management Plan. 

Environmental Assessment. Decision Notice and Finding of No Significant Impact. 

Petersburg, AK: USDA Forest Service, Tongass National Forest, Petersburg Ranger 

District. 

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

Environmental Impact Statement, Plan Amendment, Volume I. Management 

Bulletin. R10-MB-603c. Juneau, AK: USDA Forest Service, Alaska Region, 

Tongass National Forest. 

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

Environmental Impact Statement, Plan Amendment, Volume II - Appendices. 

Management Bulletin. R10-MB-603d. Juneau, AK: USDA Forest Service, Alaska 

Region, Tongass National Forest. 
Mitkof Island – Decision Notice and Finding of No Significant Impact 

30 – DN/FONSI 

USDA Forest Service. 1997a. Tongass Land and Resource Management Plan revision. 

Record of Decision. Management Bulletin. R10-MB-338a. Juneau, AK: USDA 

Forest Service, Alaska Region, Tongass National Forest. 

USDA Forest Service. 1997b. Tongass Land and Resource Management Plan revision. Final 

Environmental Impact Statement. Management Bulletin. R10-MB-338b. Juneau, 

AK: USDA Forest Service, Alaska Region, Tongass National Forest. 

USDC National Oceanic and Atmospheric Administration. 2015. Proposed Mitkof Island 

Forest Plan [sic], PCTS# AKR-2015-9421. March 6, 2015. 28 pp. 

USDI Fish and Wildlife Service. 2007. National Bald Eagle Management Guidelines. May 

2007. 25 pp. 

Whitacre, M. 2014a. Unpublished Report. Biological Evaluation for Plants for the Mitkof 

Island Project EA. Petersburg, AK: USDA Forest Service, Tongass National Forest, 

Petersburg Ranger District. 

Whitacre, M. 2014b. Unpublished Report. Risk Assessment for Invasive Plants for the 

Mitkof Island Project EA. Petersburg, AK: USDA Forest Service, Tongass National 

Forest, Petersburg Ranger District.
Mitkof Island – Decision Notice and Finding of No Significant Impact 

DN/FONSI - 31 

 
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APPENDIX 1 

MICROSALE IMPLEMENTATION PLAN 

 

 
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Appendix 1 -1 

Appendix 1. Microsale Implementation Plan 

Introduction 

This implementation plan provides direction for documenting and approving microsales. While 

green tree sales are restricted to units that have been analyzed for commercial harvest within the 

Mitkof Island EA (95 and 98 percent retention units) and will not need a subsequent 

environmental review prior to approval, proposed microsales may occur along all existing and 

proposed road corridors in all land use designations (LUDs) where the Forest Plan allows (USDA 

Forest Service 2008c, pp. 4-73 and 4-74), and a site-specific environmental review will be 

required. 

Microsales consist of dead and down trees up to a total of 50 thousand board feet (MBF) per sale, 

with up to 500 MBF allowable for offer each year. Each microsale would be identified by a 

prospective purchaser and approved by the Forest Service on a case-by-case basis. Microsales 

proposed in non-development LUDs would need to meet LUD goals and objectives. A sitespecific implementation plan would be completed for each microsale prior to implementation (see 

Exhibit 1). All proposed microsale activities would meet the standards and guidelines of the 

Forest Plan. 

On-site log processing using small, portable mills may be permitted on a case-by-case basis. 

Monitoring will be conducted using the Forest Plan Monitoring and Evaluation Plan (USDA 

Forest Service 2008c, Chapter 6). 

Environmental Review 

An interdisciplinary environmental review will be done for all proposed microsales. The 

Petersburg District Ranger, the deciding officer, will determine the level of environmental review 

necessary. 

The effects of proposed microsales to various resources can be reduced or avoided through the 

use of Forest Plan Standards and Guidelines including the best management practices (BMPs) 

which meet the requirements of the Clean Water Act. Additional mitigation measures may be 

identified during the environmental review. If any resource concern cannot be successfully 

mitigated or does not conform to the Forest Plan Standards and Guidelines, the proposed 

microsale will not be implemented under the Mitkof Island EA, and a separate NEPA analysis 

will be required. 

The environmental review of microsale proposals may include the following, if applicable. 

Silviculture 

The appropriate harvest method will be assessed to minimize ground and vegetation disturbance. 

Transportation 

Roads not open to the public through the District Access and Travel Management Plan (USDA 

Forest Service 2009) may be authorized by a permit for management associated with an 

individual timber sale (CFR Title 36 Section 212). Harvest activities will be designed to avoid 

impacting the public and to limit impacts to the road surface and drainage structures. 
Mitkof Island – Appendix 1. Microsale Implementation Plan 

2 – Appendix 1 

Wildlife 

The most current information on management indicator species (MIS), raptor and heron nests, 

seabird rookeries, waterfowl habitat, and wolf dens within the project area will be assessed, and 

appropriate timing restrictions and/or buffers will be implemented where applicable, as directed 

by the Forest Plan. 

Additionally, survey information within development and non-development LUDs for federally 

listed endangered, threatened, proposed, and candidate species; and Alaska Region sensitive 

species, and other species (e.g., migratory birds) identified for protection in the Forest Plan will 

be assessed. 

The most current versions of the Alaska Region sensitive species list and Tongass National Forest 

MIS list will be used in the assessment. 

During project implementation, repeated helicopter flights within 1⁄4 mile of active bald eagle 

nests, particularly with large helicopters used for yarding timber, should be avoided to minimize 

activities to bald eagles. Furthermore, timber harvesting operations, including road construction 

and chain saw and yarding operations, should be avoided within 660 feet of active nests during 

the breeding season (March 1st to October 31st). 

Following harvest activities, a Forest Service biologist will visit a sample of harvest areas to 

assess the nature of effects on wildlife species. 

Subsistence 

Areas that are heavily used for subsistence hunting of deer should be identified to ensure that 

hunter and operator safety is considered during timber harvest. 

Aquatics 

All streams will be identified by stream class and channel type during onsite inspections or using 

field-verified GIS data. Any additional streams found that are not in GIS will be added to the sitespecific implementation plan following the 2008 Forest Plan, Riparian Buffer Standards and 

Guidelines – Appendix D. Riparian management areas consisting of no-harvest and RAW buffers 

will follow Forest Plan Standards and Guidelines (USDA Forest Service 2008c, pp. 4-50 to 4-54). 

See also FSH 2090.21 (2001) Chapter 10, Section 12. 

Sensitive, Rare and Invasive Plants 

The most current information on sensitive, rare and invasive plants will be used to assess the need 

for additional avoidance or mitigation measures. This includes the most current versions of the 

Alaska Region sensitive species list, the Tongass National Forest rare plant list, and the Tongass 

National Forest high priority invasive plant species list. 

Any occurrence of previously undiscovered rare or sensitive plants before or during 

implementation will be evaluated to assess the need for additional avoidance or mitigation 

measures. 

Timber sale contracts will include site-specific practices to prevent the introduction and spread of 

invasive plants. This will include road maintenance activities associated with individual sales. 

Management considerations and mitigation will be noted on the unit card narrative. However, on 

a site-specific basis, other species may be of concern and warrant prevention practices. 
Mitkof Island – Appendix 1. Microsale Implementation Plan 

Appendix 1 - 3 

The 2008 Tongass Forest Plan Invasive Species Standards and Guidelines (USDA Forest Service 

2008c, p. 4-22) and 2011 Invasive Species Management manual direction (FSM 2900) provide 

policy for minimizing spread of invasive species. The Tongass National Forest has a standard 

seed mix and fertilizer application rate compatible with invasive plant policy. 

For mitigation measures designed to reduce potential adverse effects from project activities see 

the Wrangell-Petersburg Weed Management Project EA (USDA Forest Service 2013, pp. 42-43). 

Heritage 

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

includes locating, inventorying and evaluating the National Register of Historic Places eligibility 

of historic and archeological sites that may be directly or indirectly affected by scheduled 

activities. Regulations (36 CFR 800) implementing Section 106 of the NHPA require federal 

agencies to consider the effects of their actions on sites that are determined eligible for inclusion 

in or are listed in the National Register of Historic Places (termed "historic properties"). A Forest 

Service archeologist will conduct a cultural resource survey in the area of potential effect and 

conduct a files review for any proposed microsales to ensure compliance with NHPA and ensure 

that no historic properties will be affected. 

Recreation 

Recommendations to minimize the effects of microsale harvest on recreation users and to 

increase safe operations may include additional signing, prohibition of operational work on 

weekends or during certain times of the year, and notification through public service 

announcements on KFSK (local radio station),and public notices in the Petersburg Pilot (local 

newspaper). 

The possibility of temporary wood processing on-site will be determined. If proposed work has 

the potential to disrupt users at a recreation use area through dust and/or noise, alternate sites will 

be identified. 

In identifying microsale proposals, there may be instances when removing trees can improve the 

safety of a recreation site or travel route by targeting hazard trees and trees that limit sight 

distance along a road. These opportunities should be coordinated with the recreation management 

staff. 

Scenery 

For all locations with a High Scenic Integrity Objective, the Forest Plan Scenery Standards and 

Guidelines specifications for Corridor Treatment (Scenery Preparation II/A/2/b) will be applied. 

Applicable measures will specify roadside cleanup of ground disturbance, as well as other 

specific scenery mitigation measures, such as lopping and scattering of tree tops and limbs, flush 

cutting stumps to ground height and angling slash away from the road. These measures will be 

incorporated into the microsale contracts. 

Soils 

During field review, if any slopes are over 72 percent, a soil scientist will conduct an on-site 

evaluation to determine if the slopes are stable for the proposed harvest prior to implementation 

(USDA Forest Service 2008c, p. 4-65). 
Mitkof Island – Appendix 1. Microsale Implementation Plan 

4 – Appendix 1 

Appropriate mitigation and design measures will be applied to avoid significant adverse effects to 

the soil resources. Seeding may be used if erosion is a concern to ensure that ground cover is 

established in a timely manner. If seeding cannot be completed prior to September 15, or appears 

unsuccessful by that time, other erosion control measures must be applied to disturbed areas near 

surface waters before heavy autumn rains and frost. The current Tongass National Forest erosion 

control seed mix will be used. 

Appropriate logging systems will be required to ensure harvest will meet Region 10 Soil Quality 

Standards. National and Regional BMPs also will be applied. 

Wetlands 

Using field review and GIS soils information, wetlands requiring protection will be identified on 

the unit cards with appropriate protection measures to avoid adverse effects, in accordance with 

the Forest Plan Wetlands Standards and Guidelines, page 4-88. National and Regional BMPs will 

be applied in all proposed management areas. Contract provisions may include: 

Trees felled into muskegs or other non-forested (non-commercial) wetlands shall be removed 

by suspension cable or other low-impact yarding systems. 

In forested wetlands, shovel or other logging/yarding equipment will be supported by slash to 

minimize disturbance. Material used to construct mats for equipment operation will be 

dispersed after use. 

Prior to discharging material into wetlands, the site will be approved to ensure that wetland 

functions are protected. 
Mitkof Island – Appendix 1. Microsale Implementation Plan 

Appendix 1 - 5 

Exhibit 1. Example narrative for a microsale unit card. More information may be needed depending 

on the proposal. 

TIMBER SALE PROJECT PROPOSAL 

Petersburg Ranger District 

FY 20XX 

<Name of Timber Sale>

<Location – which island>

Plan to be Offered: Sold: Y / N Purchaser: 

LUD: Type of Sale:

Commercial Fuelwood (Green / Dead), 

Microsale, or Salvage Sawtimber 

Total Unit Acres: Net Harvest Volume

(MBF):

VCU:

TM Compartment:

Logging Systems: Harvest Acres: Species:

Stand Number(s): Photo Number:    

SILVICULTURE:

Existing Stand Condition: Describe stand species composition of overstory trees and advanced regeneration, quantity of 

advanced regeneration, residual tree windfirmness, and physical health and condition of residual trees (any insect and 

diseases, blowdown, etc.). 

Silvicultural Prescription: Complete RX needs to be prepared by a certified silviculturist and placed in the sale folder. 

Reference: Forest Plan Standards and Guidelines p. 4-15 

HARVEST SYSTEM:

The method of planned timber removal or how it will be yarded from the harvest unit. 

TRANSPORTATION/ACCESS:

What roads will be used for access? Note LTF, if needed. What is status of road according to the Petersburg Ranger District 

Access Travel Management Plan? Is a permit required in accordance with CFR Title 36 Section 212? Road construction and 

reconditioning shall follow applicable BMPs (including National Core BMPs) during layout and construction work, in 

particular: 12.17, 13.11, 14.2, 14.3, 14.5, 14.6, 14.7, 14.8, 14.9, 14.10, 14.12, 14.17, and 14.18. 

Reference: Forest Plan Standards and Guidelines p. 4-80 

FISH/WATERSHED: Describe any streams and protection needed as shown on the map. (GIS stream 

layer) 

The following Best Management Practices (BMPs) shall be applied to protect water quality in the project 

area as specified in the Forest Plan (pages C-1 to C-3): BMPs 12.6, 12.6a, 13.14, 13.16, and 13.9, and 

National Core BMPs AqEco-2 and 4, Plan-2 and 3, Road-7, and Veg-2 and Veg-3. 

Reference: Forest Plan Standards and Guidelines p. 4-9 (fish) 

WILDLIFE: Were any raptor nests known or observed? Any raptors seen in the area? 

GIS data, or information gathered from persons familiar with the harvest area. 

Reference: Forest Plan Standards and Guidelines p. 4-89 (wildlife) and p. 4-68 (subsistence) 
Mitkof Island – Appendix 1. Microsale Implementation Plan 

6 – Appendix 1 

<Name of Timber Sale>

<Location – which island>

Plan to be Offered: Sold: Y / N Purchaser: 

LUD: Type of Sale:

Commercial Fuelwood (Green / Dead), 

Microsale, or Salvage Sawtimber 

Total Unit Acres: Net Harvest Volume

(MBF):

VCU:

TM Compartment:

Logging Systems: Harvest Acres: Species:

Stand Number(s): Photo Number:    

SOILS/WETLANDS: Presence of slopes >72%. Presence of wetland soils. (GIS wetland layer, Site visit) 

Reference: Forest Plan Standards and Guidelines p. 4-64 (soils) and p. 4-88 (wetlands) 

RECREATION: Is sale located near on the route to an inventoried recreation site? (Recreation Sites GIS layer, Mitkof Island

Map) 

Reference: Forest Plan Standards and Guidelines p. 4-43 

SCENERY: Is sale located along a Visual Travel Priority Route? (Forest Plan, Appendix F) 

Reference: Forest Plan Standards and Guidelines p. 4-56 

HERITAGE RESOURCES: Contact archaeologist. 

Reference: Forest Plan Standards and Guidelines p. 4-16 

LANDS: Is the sale adjacent to other owner ship? Any SUPs nearby? Powerline? 

Reference: Forest Plan Standards and Guidelines p. 4-27 

GEOLOGY/KARST: Any karst known in the area? 

Reference: Forest Plan Standards and Guidelines p. 4-23 

BOTANY: Any sensitive, rare or invasive plants known in the area? (GIS botany layers) 

Reference: Forest Plan Standards and Guidelines p. 4-41 (plants) and p. 4-22 (invasive species) 

 
Mitkof Island – Appendix 1. Microsale Implementation Plan 

Appendix 1 - 7 

<Insert Sale Area Map> 

Map needs to include: 

unit boundary 

roads and road numbers 

streams by stream class 

north arrow 

legend 

scale 

date 

 
Mitkof Island – Appendix 1. Microsale Implementation Plan 

8 – Appendix 1 

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