United States Department of Agriculture 

Saddle Lakes Timber Sale 

Final Environmental Impact Statement

Forest Service 

Alaska Region

Tongass National Forest 

Ketchikan-Misty Fiords 

Ranger District R10-MB-740a September 2015
Acronyms

ACEP Advisory Council on Environmental 

Preservation

ACHP Advisory Council on Historic Preservation 

ADEC Alaska Department of Environmental 

Conservation

ADF&G Alaska Department of Fish and Game 

ADNR Alaska Department of Natural Resources 

ANILCA Alaska National Interest Lands Conservation 

Act 

APDES Alaska Pollutant Discharge Elimination 

System

ATM Access and Travel Management

BA Biological Assessment

BE Biological Evaluation

BMP Best Management Practice

CEQ Council on Environmental Quality

CFR Code of Federal Regulations

CFS Cubic feet per second

DBH Diameter at breast height

DEIS Draft Environmental Impact Statement

DHC Deer Model Habitat Capability

DOT&PF Department of Transportation & Public 

Facilities

DPS Distinct population segment

DZ Distance Zone

EFH Essential Fish Habitat

EIS Environmental Impact Statement 

EPA Environmental Protection Agency 

ESA Endangered Species Act

FACTS Forest Activities Tracking System

FASTR Financial Analysis Spreadsheet Tool residual 

value; NEPA economic analysis tool

FEIS Final Environmental Impact Statement 

FRPA Forest Resources and Practices Act

FSH Forest Service Handbook 

FSM Forest Service Manual 

FY Fiscal year

GIS Geographical Information System 

GMU Game Management Unit

GPS Global Positioning System

HSI Habitat Suitability Index 

HUC Hydrologic Unit Code

IDT Interdisciplinary team 

IRA Inventoried Roadless Area

LSTA Logging System and Transportation Analysis

LTF Log Transfer Facility

LUD Land Use Designation

LWD Large woody debris

MAF Marine Access Facility

MBF Thousand board feet

MIS Management Indicator Species

ML Maintenance Level 

MMBF Million board feet 

MMI Mass Movement Index

MOA Memorandum of Agreement 

MOU Memorandum of Understanding 

ML Maintenance level

MP Milepost

NEPA National Environmental Policy Act

NFMA National Forest Management Act

NFS National Forest System

NHPA National Historic Preservation Act 

NMBF Net thousand board feet

NMFS National Marine Fisheries Service 

NOA Notice of Availability

NOI Notice of Intent

NRIS Natural Resource Information System

OGR Old-growth reserve 

OHV Off highway vehicle 

OSI Other Species of Interest 

POG Productive old-growth

R10 Region 10 (Alaska Region of Forest Service) 

RAW Reasonable Assurance of Windfirmness 

RCS Road Condition Survey

RMA Riparian Management Area 

RMO Road Management Objectives 

ROD Record of Decision

ROS Recreation Opportunity Spectrum

ROW Right-of-way

S&G Standards and Guidelines (Forest Plan)

SDM Size-density model

SEIS Supplemental Environmental Impact Statement

SHPO State Historic Preservation Officer 

SIO Scenic Integrity Objective

SPCC Spill Prevention, Control and Countermeasure

TES Threatened, Endangered and Sensitive species

TTRA Tongass Timber Reform Act 

USDA United States Department of Agriculture 

USDI United States Department of the Interior 

USFWS United States Fish and Wildlife Service

USGS United States Geological Survey

VAC Visual Absorption Capacity 

VCU Value Comparison Unit 

VPR Visual Priority Route

WAA Wildlife Analysis Area

Cover Photo: Saddle Lake. 

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

Department of

Agriculture

Forest

Service

Alaska Region

Tongass National Forest

648 Mission Street

Ketchikan, AK 99901

Phone: (907) 225-3101

Fax: (907) 228-6215

Caring for the Land and Serving People Printed on Recycled Paper 

File Code: 1950

Date: August 31, 2015 

Dear Interested Stakeholder:

Here is your copy of the Final Environmental Impact Statement (FEIS) for the Saddle Lakes Timber Sale 

Project on the Ketchikan-Misty Fiords Ranger District, Tongass National Forest. In this FEIS, the Forest 

Service analyzed five action alternatives and a No-action Alternative. The action alternatives range from 

17 million board feet (MMBF) to 61 MMBF of timber, and propose up to 21 miles of new National Forest 

System (NFS) road construction, 12 miles of temporary road construction, and 11.1 miles of road 

reconditioning. Conventional and helicopter logging systems would be used. Identified significant issues 

addressed by alternatives include timber economics, timber availability, wildlife habitat and subsistence 

use, and scenery and recreational opportunities. This FEIS also analyzes two non-significant amendments 

to the Forest Plan, which are described in appendices A and B of the draft Record of Decision (draft 

ROD) being made available for review with this FEIS. 

Copies of this FEIS and the draft ROD have been mailed to those who have commented on the project or have 

requested to be on the project mailing list. This FEIS and draft ROD are also available for review at the 

Ketchikan-Misty Fiords Ranger District 3031 Tongass Ave, Ketchikan, AK 99901 or on-line:

http://www.fs.usda.gov/project/?project=38990. 

For additional information, please contact: Daryl Bingham (907)225-2148. Fax (907) 225-8738 

darylabingham@fs.fed.us

M. EARL STEWART

Forest Supervisor, Tongass NF

United States Department of Agriculture

Forest Service Alaska Region 

_________________________________________________________________ 

Lead Agency: USDA Forest Service

Tongass National Forest

Responsible Official: M. Earl Stewart, Forest Supervisor 

Tongass National Forest 

Federal Building 

Ketchikan, Alaska 99901 

For Further Information 

Contact: 

Jeffrey DeFreest, District Ranger

Ketchikan-Misty Fiords Ranger District 

3031 Tongass Ave 

Ketchikan, Alaska 99901 

(907) 225-2148 

_________________________________________________________________ 

Abstract

The Forest Service proposes to harvest timber, build new roads and recondition roads, reconstruct the 

Shelter Cove log transfer facility (LTF), modify a fish passage barrier, and grant a State of Alaska rightof-way (ROW) on National Forest System (NFS) lands in the Saddle Lakes project area. The project 

area is located on Revillagigedo Island about 14 miles northeast of Ketchikan, Alaska, between George 

and Carroll Inlets within the Ketchikan-Misty Fiords Ranger District (KMRD), on the Tongass National 

Forest. 

Saddle Lakes Timber Sale

Final Environmental Impact Statement

Daryl Bingham, District NEPA Planner 

Ketchikan-Misty Fiords Ranger District 

3031 Tongass Avenue 

Ketchikan, Alaska 99901 

(907) 225-2148 

The actions analyzed in this EIS are designed to implement the Tongass Land and Resource

Management Plan (Forest Plan). The EIS describes and analyzes in detail six alternatives that provide

differing outputs and responses to issues identified for this project. The action alternatives propose

timber harvest using conventional (cable and shovel) and helicopter logging systems and either evenaged management (clearcut) or uneven-aged management (single-tree selection with 33 percent basal

area removal) silvicultural systems; road construction and reconditioning; reconstruction of the

Shelter Cove LTF; modification to a natural partial fish barrier at Salt Creek; and authorization of a

State of Alaska ROW on NFS lands for construction, operation and maintenance of a public road. All

newly constructed roads would be closed to motorized use after timber harvest except for the public

road ROW authorized to the State. Forest Plan amendments are proposed to remove visual priority

route designations and to modify the small old-growth reserve. 

Saddle Lakes Timber Sale Final EIS Summary  i 

Summary 

Introduction____________________________________________

The Forest Service has prepared this Final Environmental Impact Statement (FEIS) to evaluate the 

potential impacts of timber harvesting and road construction, fish passage barrier modification for 

fish passage improvement, Shelter Cove log transfer facility (LTF) reconstruction, and a State of 

Alaska right-of-way on National Forest System (NFS) lands in the Saddle Lakes project area. This 

FEIS is in compliance with the National Environmental Policy Act (NEPA) of 1969 as amended, the 

National Forest Management Act (NFMA), and other relevant federal and State laws and regulations.

Project Area ___________________________________________

The project area is located on Revillagigedo Island about 14 miles northeast of Ketchikan, Alaska, 

between George and Carroll Inlets and covers 38,459 acres of National Forest System (NFS) lands 

including 3,557 acres of private lands (non-NFS lands). Three land use designations (LUDs) comprise 

about 91 percent of the project area; these consist of Modified Landscape, Timber Production and 

Old-growth Habitat, Timber Production, in descending order of abundance. A fairly extensive road 

system already exists in the project area.

The project area is located in value comparison units (VCUs) 7460, 7470, and 7530, and includes

portions of the North Revilla (#526) and Carroll (#535) Inventoried Roadless Areas (IRAs). The IRAs 

comprise about 48 percent (18,597 acres) of the project area.

In implementing Forest Plan direction in accordance with the Council on Environmental Quality 

(CEQ) regulations (40 C.F.R. § 1500-1508), this FEIS answers the following eight questions 

(Schmidt 2012, pgs. 74-75):

1 - What action is proposed? _____________________________

The proposed action for the Saddle Lakes Timber Sale is to harvest about 30 MMBF of timber on 

about 2,207 acres of forested lands by offering one or more timber sales, within the roaded land base. 

About 16 miles of NFS and temporary roads would be constructed, and about 11 miles of existing 

roads would be reconditioned. All newly constructed roads would be closed to motorized use after 

timber harvest except for the State of Alaska right-of-way (ROW) on NFS land (proposed NFS Road 

8300280). Harvest would include both conventional (cable and shovel) and helicopter logging 

systems and would include even-aged and uneven-aged (33 percent basal area removal) silvicultural 

systems. 

The proposed action would also reconstruct the Shelter Cove log transfer facility (LTF), modify a 

naturally occurring partial fish barrier, and authorize a 300-foot wide by about 1 mile ROW on NFS 

lands to the State of Alaska for construction, operation and maintenance of a single lane public road.

2 - Why is the project being proposed? _____________________

The Saddle Lakes Timber Sale is proposed at this time to respond to the goals and objectives 

identified by the Forest Plan (USDA 2008b, pp. 2-5 and 2-7) that guide timber management to 

support the local and regional economies of Southeast Alaska, while helping move the project area 

toward the desired conditions in that plan. The Forest Plan includes both forest-wide multiple use 
Summary

ii  Summary Saddle Lakes Timber Sale Final EIS

goals and objectives (USDA Forest Service2008b, Chapter 2) and land use designation (LUD) goals, 

objectives, and desired conditions (USDA Forest Service 2008b, Chapter 3). 

The need for the Saddle Lakes Timber Sale is described in this EIS as the underlying problem or 

opportunity to which the Forest Service is responding with the action. The underlying need for the 

Saddle Lakes Timber Sale comes from the Forest Service’s obligation, subject to applicable law, to 

seek to provide a supply of timber from the Tongass National Forest that meets market demand 

annually and for the planning cycle. Seeking to meet timber demand for the Tongass National Forest 

is required by Section 101 of the 1990 Tongass Timber Reform Act (TTRA). 

Southeast Alaska, including Ketchikan, has experienced a continual decline in timber industry 

employment, with employment dropping sharply in the 1990s following the closure of the region’s 

two pulp mills, and continuing to decrease over the past decade. This decline has been mirrored by a 

decline in regional sawmill production and reduced harvest levels forest-wide. Making available

renewable timber resources would provide Southeast Alaska timber operators with the opportunity to 

generate and support jobs and income in the region (see Issue 1. Timber Economics in Chapter 1 and 

in Chapter 3). 

Given the relevant Forest Plan goals and objectives and based on analysis of existing conditions in the 

project area, the interdisciplinary team (IDT) identified the following opportunities in the Saddle 

Lakes project area:

1. There is an opportunity to provide an economic supply of sawtimber and other wood products to

increase current levels of the wood products industry;

2. There is an opportunity to support employment in the timber and related industries that could

contribute to the local and regional economies of Southeast Alaska;

3. There is an opportunity to improve forest health, growth, and productivity on commercial forest

lands by implementing silvicultural practices that provide for regeneration and establishment of

faster growing, disease and defect free young-growth stands; and

4. There is an opportunity to improve fish habitat.

The Saddle Lakes Timber Sale is proposed at this time to respond to the stated purpose and need

while moving the project area toward the desired conditions described in the Forest Plan. 

The purpose of and need for project action is described in detail in Chapter 1 and in greater detail in 

Appendix A of this document (40 C.F.R. § 1502.13). 

3 - What other action would meet the same need?____________

In addition to the proposed action, five action alternatives, each with differing outputs and responses, 

were designed to meet the need for the Saddle Lakes Timber Sale. A No-action Alternative is also 

included, and while it does not meet the need, it is described and analyzed in detail to provide a 

benchmark for comparing the magnitude of the environmental effects of the action alternatives (see 

40 C.F.R. §§ 1502.14(d), 1508.25(b) (1)). 

The following is a brief discussion of how the action alternatives would meet the need for the Saddle 

Lakes Timber Sale.
Summary

Saddle Lakes Timber Sale Final EIS Summary  iii

Alternative 1 (No Action)

Alternative 1 is the No-action Alternative in the EIS. Under this alternative, no timber harvest or road 

construction would take place at this time. As a result, this alternative would not meet the purpose and 

need for the project. 

Alternative 2 (Proposed Action) 

Alternative 2 would produce about 30 MMBF of timber by harvesting about 2,207 acres of oldgrowth and is projected to support 120 to 144 jobs (annualized jobs-years). 

Alternative 3

Alternative 3 would produce about 17 MMBF of timber by harvesting about 1,012 acres of oldgrowth and is projected to support 68 to 82 jobs (annualized jobs-years). 

Alternative 4 (Preferred Alternative) 

Alternative 4 would produce about 51 MMBF of timber by harvesting about 2,424 acres of oldgrowth and is projected to support 203 to 243 jobs (annualized jobs-years). 

Alternative 5

Alternative 5 would produce about 61 MMBF of timber by harvesting about 2,875 acres of oldgrowth and is projected to support 241 to 290 jobs (annualized jobs-years). 

Alternative 6

Alternative 6 would produce about 40 MMBF of timber by harvesting about 2,138 acres of oldgrowth and is projected to support 161 to 194 jobs (annualized jobs-years). 

A detailed comparison of the action alternatives is summarized in Chapter 2 - Comparison of 

Alternatives, and a full examination of issue comparison by alternative is provided in Chapter 3. 

Affected Environment and Environmental Consequences. 

4 - What would it mean to not meet the need for project action?

Not meeting the need for the Saddle Lakes Timber Sale would mean that Forest Plan multiple use 

goals and objectives for timber and local and regional economies (USDA 2008b, pp. 2-7 and 2-5) 

would not be achieved in the Saddle Lakes project area. These goals would then have to be achieved

in other areas on the Tongass National Forest (see Appendix A – Reasons for Scheduling the 

Environmental Analysis of the Saddle Lakes Timber Sale).

5 - What are the effects of the project action, and alternative 

actions in comparative format? ___________________________

Chapter 2- Alternatives introduces how the action alternatives meet the purpose and need for the 

project, and compares outputs, objectives and effects of the alternatives in terms of the significant 

issues. Significant environmental issues deserving of study were identified at an early stage, and the 

IDT developed alternatives to the proposed action to address these issues; Chapter 2 of this FEIS

discusses and compares the alternatives by issue. See Table 3- Comparison of Alternatives by Issue. 

In addition to the action alternatives, a No-action Alternative is also described and analyzed in detail 

as a benchmark for comparing the magnitude of the environmental effects of the action alternatives. 
Summary

iv  Summary Saddle Lakes Timber Sale Final EIS

Chapter 3 examines the existing condition and describes and analyzes in detail the effects or 

consequences of the project action and alternative actions on the human environment (40 C.F.R. §§ 

1502.15, 1502.16, 1508.14). Effects are discussed in proportion to their significance in this EIS (40 

C.F.R. § 1502.2 (b)). The following is a summary of effects in relation to the significant issues: 

Issue 1 – Timber Economics and Issue 2 – Timber Availability

Under Alternative 1, there would be no timber volume available for sale through the Saddle Lakes 

Timber Sale. This alternative does not meet the purpose and need. The sale is intended to provide a 

supply of economic timber and designed to include sufficient units and volume to allow the Forest 

Service to adjust future timber sale offerings from the project area to meet fluctuating market 

conditions, to the extent possible.

Each of the five action alternatives responds to the need for a reliable, economic supply of sawtimber 

to meet market demand, support employment and benefit local and regional economies. The extent to 

which each alternative meets this need is correlated directly to the total volume of timber harvest for 

that alternative.

Alternative 5 would produce the most volume of timber, followed by Alternatives 4, 6, 2, and 3, in 

descending order. The volume proposed ranges from 17 million board feet (MMBF) to 61 MMBF. 

Total estimated direct employment ranges from 68-82 jobs (annualized job-years) under Alternative 3 

to 241-290 jobs under Alternative 5, reflecting the relative volumes that would be made available 

under each alternative. The project would also support indirect jobs within the region.

For timber volume to contribute to the stated purpose, it must also be economically viable. Alternative 

6 has the least economic risk under current market conditions, followed by Alternatives 4, 5, 3, and 2. 

The quantity of economically viable timber volume available at project implementation would depend 

on a number of factors. The full economic benefits of a given alternative may not be available under 

poor market conditions.

Issue 3 – Wildlife Habitat and Subsistence Use

Alternative 1 (no action) would have no direct, indirect, or cumulative effects on wildlife or 

subsistence use associated with the Saddle Lakes Timber Sale. All action alternatives would result in 

a decrease in productive old-growth (POG) habitat. Effects vary by wildlife species, but existing 

habitat would be reduced, and historic habitat would be cumulatively reduced. Resulting impacts to 

biodiversity and landscape connectivity (fragmentation) would be greatest under alternatives that 

harvest the most volume using even-aged management (clearcut) harvest prescriptions. Alternative 5 

includes the most clearcut acres followed by Alternatives 4, 6, 2, and 3 in descending order. 

Alternative 5 would reduce POG further by modifying a small old-growth reserve (OGR) and 

relocating the roaded portion of it into an inventoried roadless area (IRA), and making the vacated 

area available for timber management. Modifying the OGR would require a Forest Plan amendment. 

Reductions in POG would reduce habitat available for endemic species, migratory birds, and other 

old-growth associated species. Local reductions in populations may occur for these species, either 

through disturbance, habitat removal, or fragmentation, likely resulting in reduced dispersal and/or 

population isolation under all action alternatives.

Removal of low-elevation POG under all action alternatives would reduce the amount of available 

deer winter habitat. Reductions in deer habitat under the action alternatives may result in local 

declines in the deer population, reducing the number of deer available to wolves, and subsistence and 
Summary

Saddle Lakes Timber Sale Final EIS Summary  v 

sport deer hunters. All action alternatives may have a significant possibility of a significant restriction 

on deer due to changes in access and demand.

All action alternatives would slightly increase road density. Current road densities in the wildlife 

analysis areas (WAAs) coinciding with the project are higher than the Forest Plan recommended 

threshold of 0.7 to 1.0 mile per square mile where wolf mortality has been identified through 

interagency analysis as a concern. Increased road density indirectly affects wolves, as well as other 

harvested species (marten and black bears), by increasing human access which may lead to increased 

harvest rates. 

Currently, modeled deer densities in all ownerships in project area WAAs fall below the Forest Plan 

Standards and Guidelines of 18 deer per square mile considered necessary to maintain sustainable 

wolf populations and meet hunter harvest demands (USDA Forest Service 2008b p. 4-95). 

Issue 4 – Scenery and Recreational Opportunities

Alternative 1 (no action) would have no direct, indirect, or cumulative effects on scenery or 

recreational opportunities.

All action alternatives would result in changes to the scenic integrity in the project area due to timber 

harvest and road construction. Alternative 5 would have the greatest effects to scenery, followed by 

Alternatives 4, 6, 2, and 3, in descending order. Alternatives 4, 5, and 6 would not meet the Forest 

Plan Standards and Guidelines for scenery, or the goal of the Modified Landscape LUD to recognize 

scenic value in the project area. These alternatives would also exceed the recommended thresholds for 

total disturbance in Modified Landscape LUD. A Forest Plan amendment to remove visual priority 

route (VPR) designations in and adjacent to the project area would be needed. For Alternative 4, the 

removal of four VPR designations would change the scenic integrity objectives (SIOs) of 8,270 acres 

of the project area, all to a lower SIO, and harvest 1,285 of those acres. Alternative 5 would remove 

five VPR designations and change the SIOs of 8,750 acres of the project area, all to a lower SIO, and 

harvest 1,642 of those acres. Alternative 6 would remove three VPR designations and change the 

SIOs of 6,810 acres of the project area, all to a lower SIO, and harvest 743 of those acres.

No changes to the existing Recreation Opportunity Spectrum (ROS) classes found in the Saddle 

Lakes project area would occur under Alternatives 2, 3, and 6. Alternatives 4 and 5 would require a 

change to the ROS class boundaries that equates to about a 1 percent decrease to the acres of the 

Semi-Primitive Non-Motorized class, with less than a 1 percent decrease to the acres of SemiPrimitive Motorized class under Alternative 5. Similar to the scenery impacts conclusions, Alternative 

5 would have the greatest impacts to recreation opportunities, followed by Alternatives 4, 2, 6, and 3, 

in descending order. The State of Alaska right-of-way would result in additional miles of open road 

available to recreation users.

6 - What factors will be used when making the decision among 

alternatives? ___________________________________________

Factors influencing the decision among alternatives include design and location of timber harvest, 

road construction - reconditioning, and socioeconomics. See Issues 1 through 4 and other resource 

concerns (also see the section Decision Framework in Chapter 1).
Summary

vi  Summary Saddle Lakes Timber Sale Final EIS

7 - Are there any ways to mitigate adverse effects that might occur 

from the action? ________________________________________

Possible adverse impacts may occur from implementing the actions proposed under each action 

alternative. Resource protection measures, guided by direction in the Forest Plan, have been 

developed to alleviate potential adverse effects of natural or human caused disturbances (see 

Appendix C - Forest Plan Standards and Guidelines, Best Management Practices (BMPs), and 

Mitigation and Monitoring). Potential adverse effects, such as risks from windthrow to standing 

timber after harvest have been evaluated, and ways to minimize windthrow, such as windfirm buffers, 

are incorporated into harvest unit prescriptions, where needed. If any previously undocumented 

goshawk nests are discovered at any time prior to or during the implementation of this project, the 

appropriate protection measures would be used. 

Resource specialists from the IDT used on-the-ground inventories, computer (GIS) data, and aerial 

photographs to prepare unit cards for each harvest unit in the unit pool for the project, and road cards 

for each segment of road (unit and road cards are located in the project record). The cards describe 

resource-specific implementation requirements (i.e., Standards and Guidelines and/or other required 

resource protection measures). 

General mitigation common to all alternatives is described in Chapter 2 - Alternatives. A moredetailed discussion by issue and resource is included in Chapter 3 - Environment and Effects. 

8 - What project monitoring is necessary? __________________

Routine implementation monitoring is part of the administration of a timber sale contract. Reviews by 

resource staff specialists would be performed throughout project implementation. 

A review of BMP implementation and effectiveness is conducted annually by Tongass National Forest 

staff, and may include Saddle Lakes units and roads (USDA 2008b Chapter 6). The results of BMP 

monitoring and other monitoring are summarized in an annual Tongass National Forest Monitoring 

and Evaluation Report. This report provides information about how well the management direction of 

the Tongass National Forest is being carried out, and measures the accomplishment of anticipated 

outputs, activities and effects. 
Summary

Saddle Lakes Timber Sale Final EIS Summary  vii

Changes Between the Draft and Final EIS

All page numbers reference the FEIS.

1. The word “and” was replaced with “including” to correctly state project area acres page i.

2. The Scenery section was modified to correct acreages incorrectly stated in the DEIS page v.

3. The statement “four of five VPRs would be removed” under Alternative 5 was incorrect in the

DEIS. IT was replaced with “Alternative 5 would remove five VPR designations” as stated and

analyzed throughout the remainder of the EIS page v.

4. Language was added describing the Section 7 consultations with NMFS and USFWS pages 12,

13.

5. Clarification was added regarding project compliance with federal and State laws page14.

6. Wildlife units of measure, framework, definitions were clarified to better describe the effects in

the analysis performed for the DEIS, their relevance the wildlife analysis areas, elevational

corridors and how that information was translated into the ROD. These changes were made

throughout the Wildlife and Habitat sections in Chapter 3 of the FEIS.

7. Added a yellow-cedar alternative considered but eliminated from detailed analysis page 26.

8. Lake habitat made available by barrier removal was updated to 139 acres pages 27, and 258.

9. Young-growth stand acres (unavailable for harvest) were modified from 3,747 to 2,986 page 77.

10. Language was added describing the effects of the Ketchikan to Shelter Cove Road and its effects

to old-growth reserves page 84.

11. Language was added that better describes ownership and management of the parcels of land

making up the connection between the small OGR in VCU 7470 and the George Inlet Salt Chuck

pages 84, 88, 109, 121-150, 285, 286.

12. Project area wildlife corridors were clarified pages 87, 88.

13. Three management indicator species; bald eagle, river otter and Vancouver Canada goose were

removed from detailed analysis pages 91-104.

14. Deep-snow winter deer habitat was better defined page 93.

15. Current information on goshawks was provided pages 106, 107.

16. Information regarding the threatened and endangered candidate species status was removed from

the DEIS pages 111, 291.

17. The comparable achievement finding made by the Interagency Review Team with regards to

relocating the small OGR in VCU 7470 was clarified pages 112, 124.

18. ESI data was changed in Table 72, page 190.

19. Scenery effects, scenery integrity objectives, and visual priority route effects were updated for

clarity and to better describe the effects to the scenery resource pages 189-200.

20. Effects to recreation were modified to consider LTF ramp page 210.

21. Language clarifying the status of the yellow-billed loon was added page106.
Summary

viii  Summary Saddle Lakes Timber Sale Final EIS

22. Changes were made in the recreation narrative for the effects common to all alternatives

regarding modifications to LTF pages 209, 210.

23. Text was modified and added regarding unmapped streams page 224.

24. Text was added regarding stream water quality, streamflow and temperature pages 234, 249.

25. A paragraph was added regarding the road condition surveys and road crossings with respect to

fish passage pages 236, 237.

26. Landslide potential acreages with slopes greater than 72 percent were updated pages 243, 248.

27. Text was added regarding water yield page 239.

28. Language was added regarding bark accumulation because of the LTF pages 247, 251, 252.

29. Descriptions for State of Alaska (APDES) permit requirements were added pages 247, 251.

30. Windthrow ratings were updated pages 308, 309.

31. Language updating yellow-cedar decline was added page 311.

32. The APDES permit status for the Shelter Cove LTF was updated page 344.
Saddle Lakes Timber Sale Final EIS Table of Contents  ix

Table of Contents 

Summary ................................................................................................................................................. i

Introduction ......................................................................................................................................... i

Project Area......................................................................................................................................... i

1 - What action is proposed? ............................................................................................................... i

2 - Why is the project being proposed? ............................................................................................... i

3 - What other action would meet the same need? ............................................................................. ii

Alternative 1 (No Action) .............................................................................................................. iii

Alternative 2 (Proposed Action) .................................................................................................... iii

Alternative 3 .................................................................................................................................. iii

Alternative 4 (Preferred Alternative) ............................................................................................. iii

Alternative 5 .................................................................................................................................. iii

Alternative 6 .................................................................................................................................. iii

4 - What would it mean to not meet the need for project action? ..................................................... iii

5 - What are the effects of the project action, and alternative actions in comparative format? ........ iii

Issue 1 – Timber Economics and Issue 2 – Timber Availability ................................................... iv

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

Issue 4 – Scenery and Recreational Opportunities ......................................................................... v

6 - What factors will be used when making the decision among alternatives? .................................. v

7 - Are there any ways to mitigate adverse effects that might occur from the action? ..................... vi

8 - What project monitoring is necessary? ........................................................................................ vi

Changes Between the Draft and Final EIS ........................................................................................... vii

Chapter 1. Purpose of and Need for Action ........................................................................................... 1

Introduction ........................................................................................................................................ 1

Document Organization .................................................................................................................. 1

Location of Project Area .................................................................................................................... 2

Project Background ............................................................................................................................ 5

Purpose and Need for the Action ....................................................................................................... 5

Purpose ........................................................................................................................................... 5

Need ................................................................................................................................................ 6

Proposed Action ................................................................................................................................. 6

Relationship to the Forest Plan .......................................................................................................... 7

Forest Plan Land Use Designations ................................................................................................ 8

Relationship to the Access and Travel Management Plan ............................................................... 10

Decision Framework ........................................................................................................................ 10

Public Involvement .......................................................................................................................... 10

Scoping ......................................................................................................................................... 10

Notice of Intent ............................................................................................................................. 11

Public Mailings ............................................................................................................................. 11

Local News Media ........................................................................................................................ 11

Consultation with Tribal Governments ........................................................................................ 11

Other Federal and State Agency Involvement .............................................................................. 12

Federal and State Permits, Licenses, and Certifications .................................................................. 14

U. S. Army Corps of Engineers (USACE) ................................................................................... 14

U. S. Environmental Protection Agency (EPA) ........................................................................... 15

State of Alaska, Department of Environmental Conservation (ADEC) ....................................... 15

State of Alaska, Department of Natural Resources (ADNR) ....................................................... 15

State of Alaska, Department of Fish and Game, Habitat Division (ADF&G) ............................. 15

Issues ................................................................................................................................................ 15
Table of Contents

x  Table of Contents Saddle Lakes Timber Sale Final EIS

Significant Issues .......................................................................................................................... 16

Issues and Concerns Considered Non-significant ........................................................................ 19

Other Resource Considerations .................................................................................................... 21

Applicable Laws and Executive Orders ........................................................................................... 21

Availability of the Project Record.................................................................................................... 22

Map and Data Disclaimers ............................................................................................................... 22

Chapter 2. Alternatives ......................................................................................................................... 25

Introduction ...................................................................................................................................... 25

Alternative Development ................................................................................................................. 25

Alternatives Considered but Eliminated from Detailed Analysis .................................................... 26

Timber Harvest from Roaded Portion of Roadless Areas ............................................................ 27

Rare and Sensitive Plants Alternative – Pacific Silver Fir ........................................................... 27

Yellow-cedar Alternative ............................................................................................................. 27

Small Sales Alternative ................................................................................................................ 27

Items Common to All Action Alternatives ...................................................................................... 27

Road Management ........................................................................................................................ 28

Windthrow and Reasonable Assurance of Windfirmness Buffers ............................................... 28

Log Transfer Facilities ................................................................................................................. 28

Fish Passage Barrier Modification ............................................................................................... 28

State of Alaska Right-of-Way on NFS Lands .............................................................................. 29

Best Management Practices .......................................................................................................... 29

Alternatives Considered in Detail .................................................................................................... 29

Alternative 1 (No Action) ............................................................................................................. 30

Alternative 2 (Proposed Action) ................................................................................................... 31

Alternative 3 ................................................................................................................................. 31

Alternative 4 – Preferred Alternative ........................................................................................... 31

Alternative 5 ................................................................................................................................. 32

Alternative 6 ................................................................................................................................. 32

Comparison of Alternatives ............................................................................................................. 33

Chapter 3. Affected Environment and Environmental Consequences ................................................. 53

Introduction ...................................................................................................................................... 53

Land Divisions ................................................................................................................................. 53

Land Use Designations ................................................................................................................. 53

Project Area .................................................................................................................................. 53

Value Comparison Units .............................................................................................................. 53

Game Management Units ............................................................................................................. 54

Wildlife Analysis Areas ............................................................................................................... 54

Watersheds ................................................................................................................................... 54

Inventoried Roadless Areas .......................................................................................................... 54

Biogeographic Province ............................................................................................................... 54

Ecological Subsection .................................................................................................................. 54

Analyzing Effects ............................................................................................................................. 54

Assumptions for Analysis ............................................................................................................. 54

How the Effects of the Alternatives Were Evaluated ................................................................... 55

Available Information ...................................................................................................................... 55

Incomplete and Unavailable Information ..................................................................................... 56

Resources Not Present.................................................................................................................. 56

Resources Likely to be Unaffected ............................................................................................... 56

Issue 1: Timber Economics ......................................................................................................... 58

Issue 2. Timber Availability ......................................................................................................... 76

Resources by Significant Issue ........................................................................................................ 58
Table of Contents

Saddle Lakes Timber Sale Final EIS Table of Contents  xi

Issue 3. Wildlife Habitat and Subsistence Use ............................................................................. 79

Issue 3A. Wildlife Habitat ............................................................................................................ 79

Issue 3B. Subsistence Use .......................................................................................................... 173

Issue 4. Scenery and Recreational Opportunities ....................................................................... 180

Issue 4A. Scenery ....................................................................................................................... 180

Issue 4B. Recreational Opportunities ......................................................................................... 201

Other Resources ............................................................................................................................. 218

Air Quality and Climate Change ................................................................................................ 218

Aquatics ...................................................................................................................................... 224

Environmental Justice ................................................................................................................ 257

Heritage Resources ..................................................................................................................... 258

Invasive Plants ............................................................................................................................ 266

Inventoried Roadless Areas ........................................................................................................ 273

Lands and Minerals .................................................................................................................... 288

Plants .......................................................................................................................................... 297

Silviculture ................................................................................................................................. 305

Socioeconomics .......................................................................................................................... 324

Soils ............................................................................................................................................ 336

Transportation ............................................................................................................................ 341

Wetlands ..................................................................................................................................... 356

Other Environmental Considerations ............................................................................................. 360

Unavoidable Adverse Impacts .................................................................................................... 360

Relationship between the Short-term Use of the Environment and the Maintenance of Long-term 

Productivity ................................................................................................................................ 361

Irreversible and/or Irretrievable Commitments of Resources .................................................... 362

Chapter 4. Lists and References ......................................................................................................... 367

Document Contributors .................................................................................................................. 367

Interdisciplinary Team Members ............................................................................................... 367

Other Document Contributors .................................................................................................... 369

State of Alaska Contributors ...................................................................................................... 370

Distribution List ............................................................................................................................. 371

Agencies ..................................................................................................................................... 371

Individuals .................................................................................................................................. 372

George Inlet Landowners ........................................................................................................... 373

Libraries ...................................................................................................................................... 374

Businesses and Organizations .................................................................................................... 374

Cities and Public Officials .......................................................................................................... 375

Tribal IRAs and Tribal Organizations ........................................................................................ 375

References Cited ............................................................................................................................ 376

Appendix A – Reasons for Scheduling the Environmental Analysis of the Saddle Lake Project ...... 411

Introduction .................................................................................................................................... 411

How Does the Saddle Lakes Project Fit into the Tongass Timber Program? How Does the Forest 

Service decide where Timber Harvest Projects are Located? ........................................................ 411

Why is This Project Occurring in This Location?.......................................................................... 412

Why is Timber Volume from the Tongass National Forest Being Offered? ................................. 412

National Legislation ................................................................................................................... 412

Alaska-Specific Legislation ........................................................................................................ 413

Tongass National Forest Land and Resource Management Plan (Forest Plan, as amended) ..... 413

USDA Investment Strategy for Creating Jobs and Healthy Communities in Southeast Alaska 414

Addressing Sustainable Forestry in Southeast Alaska................................................................ 415

How Does the Forest Service Develop Forecasts about Future Timber Market Demand? ............ 416
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xii  Table of Contents Saddle Lakes Timber Sale Final EIS

Market Demand for the Planning Cycle ..................................................................................... 416

Annual Market Demand ............................................................................................................. 418

What Steps Must Be Completed to Prepare a Timber Volume Contract for Offer? ...................... 419

Gate 1 – Initial Planning of Timber Harvest Project .................................................................. 419

Gate 2 – Project Analysis, Design and Decision ........................................................................ 419

Gate 3 – Sale Plan Implementation and Appraisal (Preparation of a Timber Harvest Contract) 420

Gate 4 – Final Package Preparation, Review, Appraisal, and Offering (Advertise a Contract) . 420

Gate 5 – Bid Opening ................................................................................................................. 420

Gate 6 – Award a Contract ......................................................................................................... 420

How Does the Forest Service Maintain an Orderly and Predictable Timber Program? ................ 420

Pools of Timber (Pipeline Volume) ........................................................................................... 420

How Appeals and Litigation Affect the Tongass Timber Program ............................................ 423

How Does The Forest Service Decide Where Timber Harvest Projects Should Be Located? ...... 423

Land Suitability for Timber Harvest .......................................................................................... 423

District-level Planning ................................................................................................................ 424

Conclusion ..................................................................................................................................... 425

References ...................................................................................................................................... 426

Appendix B – Interrelated Projects .................................................................................................... 429

Past Activities ................................................................................................................................ 429

Timber Harvest within or adjacent to project area (1959 to 2014) ............................................. 429

Beaver Falls Hydroelectric Project (FERC P-1922) ................................................................... 430

Swan Lake Hydroelectric Project (FERC P-2911) ..................................................................... 430

Swan Lake Powerline ................................................................................................................. 430

Timber Stand Improvement 5-Year Plan (2002-2007) ............................................................... 431

Timber Stand Improvement 5-Year Plan (2008-2013) ............................................................... 431

Ketchikan-Misty Fiords Ranger District Access and Travel Management Plan ........................ 431

Ketchikan-Misty Fiords Ranger District Outfitter/Guide Management Plan ............................. 431

Timber Stand Improvement (2012) ............................................................................................ 431

Non-NFS Tours and Recreation ................................................................................................. 431

Present Activities ........................................................................................................................... 431

Tongass National Forest Timber Sales (Under Contract)........................................................... 431

Southeast Alaska Timber Sales .................................................................................................. 431

Timber Stand Improvement 5-Year Plan (2013-2018) ............................................................... 432

Whitman Lake Hydroelectric Project (FERC P-11841) ............................................................. 432

NFS Outfitter Guide Permits ...................................................................................................... 432

Non-NFS Tours and Recreation ................................................................................................. 432

Reasonably Foreseeable Future Activities ..................................................................................... 432

Tongass National Forest Five Year Timber Sale Schedule and Contract Plan .......................... 432

Timber Stand Improvement 5-Year Plan (2013-2018) ............................................................... 433

Spit Point Wildlife Habitat Restoration Project ......................................................................... 433

Southeast Alaska Timber Sales (Planned) .................................................................................. 433

Ketchikan to Shelter Cove Road ................................................................................................ 433

Alaska Mental Health Trust Authority Land Exchange ............................................................. 434

Mahoney Lake Hydroelectric Project (FERC P-11393) ............................................................. 434

Swan Lake Hydroelectric Project License Amendment ............................................................. 434

NFS Outfitter Guide Permits ...................................................................................................... 434

Non-NFS Tours and Recreation ................................................................................................. 435

Marble Creek Commercial Hydroponic Greenhouse Farm ........................................................ 435

OceansAlaska Shellfish Nursery ................................................................................................ 435

State Aquatic Permits ................................................................................................................. 435
Table of Contents

Saddle Lakes Timber Sale Final EIS Table of Contents  xiii

Appendix C - Forest Plan Standards and Guidelines, Best Management Practices (BMPs), and 

Mitigation and Monitoring ................................................................................................................. 439

Applicable LUD-specific Standards and Guidelines ..................................................................... 439

Applicable Forest-wide Standards and Guidelines ........................................................................ 440

Applicable Site-Specific Best Management Practices (BMPs) ...................................................... 447

Mitigation Monitoring, and Design Features ................................................................................. 453

Heritage ...................................................................................................................................... 453

Invasive Species ......................................................................................................................... 453

Wildlife ....................................................................................................................................... 453

Transportation ............................................................................................................................ 454

Appendix D – Response to Comments ............................................................................................... 455

Aquatics ......................................................................................................................................... 455

BMPs and Stream Buffers .......................................................................................................... 455

In-water Log Storage Effects ...................................................................................................... 456

Temperature and Sedimentation ................................................................................................. 458

Fish Passage ............................................................................................................................... 459

Clean Water Act ......................................................................................................................... 460

State of Alaska Concurrence ...................................................................................................... 461

Essential Fish Habitat (EFH) ...................................................................................................... 461

Large Wood Recruitment ........................................................................................................... 462

Peak Flows ................................................................................................................................. 462

Road Condition Surveys ............................................................................................................. 462

Water Quality ............................................................................................................................. 463

Watershed Effects Analysis ........................................................................................................ 464

Watershed Data .......................................................................................................................... 464

Botany ........................................................................................................................................ 466

Climate Change .......................................................................................................................... 468

Inventoried Roadless Areas ........................................................................................................ 471

NEPA/Forest Plan/General Analysis ............................................................................................. 472

Alternatives ................................................................................................................................ 472

Consideration of Public Comments and Submitted Literature ................................................... 473

Document Corrections/Map Request.......................................................................................... 474

Insufficient Information/Analysis .............................................................................................. 475

Issues .......................................................................................................................................... 476

Monitoring .................................................................................................................................. 476

NEPA Cumulative Effects Analysis ........................................................................................... 477

Old Growth Reserves (OGRs) .................................................................................................... 479

Purpose and Need ....................................................................................................................... 481

Recreation ...................................................................................................................................... 482

Effects of Logging to Recreation Use ........................................................................................ 482

Scenery ........................................................................................................................................... 484

Effects of Logging to Scenery .................................................................................................... 484

Scenery Analysis ........................................................................................................................ 485

Silviculture ..................................................................................................................................... 485

Justification for Clearcutting ...................................................................................................... 485

Natural Disturbance .................................................................................................................... 486

Opening Size .............................................................................................................................. 488

Pacific Silver Fir ......................................................................................................................... 488

Partial Harvest Prescriptions ...................................................................................................... 489

Transition to Young-growth ....................................................................................................... 491

Alaska Yellow-cedar and Western Redcedar ............................................................................. 493
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xiv  Table of Contents Saddle Lakes Timber Sale Final EIS

Socioeconomics ............................................................................................................................. 496

Ecosystem Services .................................................................................................................... 496

Soils ................................................................................................................................................ 497

Logging on slopes over 72 percent ............................................................................................. 497

Subsistence ..................................................................................................................................... 497

Subsistence Use .......................................................................................................................... 497

Timber ............................................................................................................................................ 499

Competitive Bidding .................................................................................................................. 499

Economics of Helicopter Yarding .............................................................................................. 500

Economics of Small/Isolated Units ............................................................................................ 501

Logging Feasibility ..................................................................................................................... 503

Timber Demand and Export ....................................................................................................... 504

Timber Economics/Jobs ............................................................................................................. 506

Timber Supply and Demand ....................................................................................................... 507

Transportation ................................................................................................................................ 510

ATM ........................................................................................................................................... 510

Road Design ............................................................................................................................... 510

Temporary Roads ....................................................................................................................... 511

Road Maintenance ...................................................................................................................... 512

Road Reconstruction .................................................................................................................. 513

Shelter Cove Road ...................................................................................................................... 513

Wildlife .......................................................................................................................................... 516

Black Bears ................................................................................................................................. 516

Brown Creeper Habitat ............................................................................................................... 518

Carrying Capacity ....................................................................................................................... 519

Deer Habitat Capability .............................................................................................................. 522

Deer Habitat/Deer Winter Range ............................................................................................... 524

Deer Model ................................................................................................................................. 527

Deer/Wolf Populations ............................................................................................................... 529

Fragmentation and Connectivity ................................................................................................ 533

Goshawks ................................................................................................................................... 535

MIS and Sensitive Species ......................................................................................................... 537

Marten ........................................................................................................................................ 537

Road Density .............................................................................................................................. 538

Size Density Model Data ............................................................................................................ 539

Wolf Effects Analysis................................................................................................................. 541

Letters from Federal, State, and local agencies and elected officials............................................. 544

Ketchikan Gateway Borough ......................................................................................................... 544

United States Environmental Protection Agency Region 10 ......................................................... 545

United States Department of the Interior ....................................................................................... 547

State of Alaska, Department of Natural Resources ........................................................................ 548

Project Description ..................................................................................................................... 548

Timber Economics...................................................................................................................... 548

Fish Passage ............................................................................................................................... 549

Cumulative Watershed Effects ................................................................................................... 549

Harvest on Steep Slopes ............................................................................................................. 550

Scenery and Recreation .............................................................................................................. 550

Shelter Cove Road ...................................................................................................................... 551

Unit and Road Cards .................................................................................................................. 551

Index ................................................................................................................................................... 555
Table of Contents

Saddle Lakes Timber Sale Final EIS Table of Contents  xv

List of Tables

Table 1. Land use designations and non-National Forest acreages and percentages in the Saddle Lakes 

project area ..................................................................................................................................... 8

Table 2. Modifications to the proposed action ..................................................................................... 26

Table 3. Comparison of alternatives by issue ....................................................................................... 34

Table 4. Forest products industry employment in Southeast Alaska, 2002 through 2011 ................... 60

Table 5. Timber financial efficiency analysis for the Saddle Lakes Project Area ................................ 65

Table 6. Estimated project employment and income utilizing R10 export policy1/ ............................. 66

Table 7. Estimated project employment and income utilizing domestic processing1/ .......................... 67

Table 8. Timber volume estimates from the Saddle Lakes Project area by species and alternative .... 67

Table 9. Acres by silvicultural system, prescription, and logging system for the Saddle Lakes Timber 

Sale ............................................................................................................................................... 68

Table 10. Estimated numbers of landings by action alternative and yarding method necessary to 

facilitate yarding ........................................................................................................................... 70

Table 11. Proposed Road construction and reconditioning costs by alternative .................................. 70

Table 12. Estimated Forest Service costs and Revenues by alternative ............................................... 71

Table 13. Suitable timberland acres in the Saddle Lakes project area ................................................. 77

Table 14. Additional suitable timberlands available for harvest due to modification of the small Oldgrowth Reserve ............................................................................................................................. 77

Table 15. Effects of Visual Priority Route designation removal (Alternatives 4, 5 and 6) for the 

Saddle Lakes Timber Sale Project ................................................................................................ 78

Table 16. Size-density model habitat classifications found in the Saddle Lakes project area ............. 83

Table 17. Change in historic acres of POG Saddle Lakes VCUs and WAAs, NFS lands only ........... 83

Table 18. Historic and existing POG patch size for WAAs 406/407 combined, all land ownerships . 86

Table 19. Historic and Existing Interior habitat, all land ownerships, by VCU and WAA.................. 86

Table 20. Corridors in the Saddle Lakes project area ........................................................................... 88

Table 21. Wildlife species selected as management indicator species (MIS) for the Saddle Lakes 

Timber Sale Project ...................................................................................................................... 91

Table 22. Historic and existing deer winter habitat acreages on NFS lands in WAAs 406 and 407 ... 92

Table 23. Historic and existing deer habitat capability (DHC) in WAAs 406 and 407 on NFS lands . 94

Table 24. Historic and original and existing deer densities and road densities on NFS Lands in the 

Saddle Lakes project area ............................................................................................................. 97

Table 25. Existing bear habitat on NFS Lands in WAAs 406 and 407 ................................................ 98

Table 26. Historic and existing mountain goat habitat on NFS Lands in WAAs 406 and 407 ............ 99

Table 27. Historic and existing marten habitat and road densities1/ on NFS Lands by VCU ............. 101

Table 28. Historic and existing brown creeper interior POG on NFS lands, Saddle Lakes project area

 .................................................................................................................................................... 102

Table 29. Historic and existing hairy woodpecker habitat and patch size .......................................... 102

Table 30. Existing red-breasted sapsucker habitat on NFS lands by VCU ........................................ 103

Table 31. Existing red squirrel habitat on NFS lands by VCU .......................................................... 104

Table 32. Selected other species of interest (OSI) in the Saddle Lakes project area......................... 104

Table 33. Threatened, endangered, candidate, and sensitive species occurring in the Saddle Lakes 

project area or nearby vicinity .................................................................................................... 106

Table 34. Changes to POG by alternative and WAA ......................................................................... 108

Table 35. Old Growth Reserve (OGR) Criteria for Small OGR in the Saddle Lakes Project Area ... 110

Table 36. Comparison of Existing Forest Plan OGR and Roadless OGR to Old Growth habitat Goals 

and Objectives/Appendix K and Appendix D. ........................................................................... 113

Table 37. Change in patch size, all ownerships .................................................................................. 116

Table 38. Treatment of corridors under action alternatives in the Saddle Lakes project area ............ 117
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xvi  Table of Contents Saddle Lakes Timber Sale Final EIS

Table 39. Change in deer habitat on NFS Lands in WAAs 406 and 407 ........................................... 120

Table 40. Deer model habitat capability on NFS Lands1/ in WAAs 406 and 407 .............................. 121

Table 41. Cumulative change to deer habitat on all land ownerships in WAAs 406 and 407 ........... 125

Table 42. Cumulative change in deer habitat capability (DHC) on all land ownerships in WAAs 406 

and 4071/ ..................................................................................................................................... 127

Table 43. Effects to wolf on NFS lands1/ in WAAs 406 and 407 ....................................................... 129

Table 44. Cumulative effects on wolves on all land ownerships in WAAs 406 and 407................... 131

Table 45. Deer model densities in the Revilla Island/Cleveland Peninsula Biogeographic Province 

(Province 15) .............................................................................................................................. 133

Table 46. Change in bear habitat on NFS Lands in WAAs 406 and 407 ........................................... 136

Table 47. Cumulative effects to black bear habitat in all land ownerships for WAAs 406 and 407, 

Saddle Lakes project area ........................................................................................................... 138

Table 48. Change in mountain goat habitat1/ on NFS Lands in WAAs 406 and 407 ......................... 140

Table 49. Cumulative change in mountain goat habitat1/ on all land ownerships in WAAs 406 and 407

 .................................................................................................................................................... 141

Table 50. Change in marten habitat on NFS Lands by VCU ............................................................. 143

Table 51. Cumulative change in marten habitat on all land ownerships by VCU and WAA ............ 146

Table 52. Change in marten habitat patch size on all land ownerships in WAAs 406 and407 combined

 .................................................................................................................................................... 148

Table 53. Effect on brown creeper and interior habitat1/ on NFS Lands by VCU.............................. 152

Table 54. Cumulative change in brown creeper/interior habitat1/ on all land ownerships by VCU and 

WAA .......................................................................................................................................... 154

Table 55. Effect on hairy woodpecker high-POG habitat1/ on NFS lands by VCU ........................... 155

Table 56. Effect on hairy woodpecker high-POG habitat on all land ownerships by VCU and WAA

 .................................................................................................................................................... 157

Table 57. Change in hairy woodpecker habitat patch size on all land ownerships in WAAs 406 and 

407 .............................................................................................................................................. 158

Table 58. Effect on red-breasted sapsucker habitat on NFS lands by VCU ....................................... 159

Table 59. Effect on red-breasted sapsucker habitat on all land ownerships by VCU and WAA ....... 160

Table 60. Change in red-breasted sapsucker habitat patch size, all land ownerships WAAs 406 and 

407 .............................................................................................................................................. 161

Table 61. Change in red squirrel habitat1/ on NFS lands by VCU ..................................................... 163

Table 62. Cumulative change in red squirrel habitat1/ on all land ownerships by VCU and WAA .... 164

Table 63. Summary of threatened, endangered, candidate, and sensitive species determinations..... 168

Table 64. Impacts to goshawk habitat on NFS lands by VCU ........................................................... 169

Table 65. Cumulative impact goshawk habitat on all land ownerships by VCU and WAA.............. 171

Table 66. Estimated deer harvest as a percent of deer habitat capability (DHC) by WAA. .............. 177

Table 67. Scenic Integrity Definitions................................................................................................ 182

Table 68. Existing scenic integrity (ESI) and scenery integrity objective (SIO) types in the Saddle 

Lakes project area ....................................................................................................................... 183

Table 69. Visual Priority Routes (VPRs) in and adjacent to the Saddle Lakes project area .............. 183

Table 70. Saddle Lakes Timber Sale activities................................................................................... 189

Table 71. Acres of harvest by existing scenic integrity objective (SIO) for the Saddle Lakes Timber 

Sale Project ................................................................................................................................. 190

Table 72. Miles of proposed roads by alternative and scenic integrity objective (SIO) for the Saddle 

Lakes Timber Sale Project .......................................................................................................... 190

Table 73. Effects of VPR removal (Alternatives 4, 5 and 6) for the Saddle Lakes Timber Sale Project

 .................................................................................................................................................... 190

Table 74. Acres of harvest within Saddle Lakes Recreation Area viewshed1/, by prescription.......... 191

Table 75. Expected cumulative visual disturbance by alternative in the Saddle Lakes project area.. 200

Table 76. ROS class acres1/ by alternative for the Saddle Lakes Timber Sale Project....................... 208
Table of Contents

Saddle Lakes Timber Sale Final EIS Table of Contents  xvii

Table 77. Harvest units of high concern to recreation by alternative (acres1/ and prescription2/) for the 

Saddle Lakes Timber Sale Project .............................................................................................. 209

Table 78. Total carbon storage in the Tongass National Forest ......................................................... 221

Table 79. Affected watersheds in the project area used in the analysis of the Saddle Lakes Timber 

Sale ............................................................................................................................................. 225

Table 80. Past harvest in 7th HUC Watersheds in the Saddle Lakes project area (True Watersheds)

 .................................................................................................................................................... 232

Table 81. Existing roads and road density in True Watersheds ......................................................... 233

Table 82. Stream class, density, and Class I/II lake and pond habitat in affected watersheds........... 235

Table 83. Anadromous and resident fish species known to occur in Saddle Lakes project area 

watersheds .................................................................................................................................. 236

Table 84. Summary of red fish crossings by milepost and associated upstream fish habitat in the 

Saddle Lakes project area ........................................................................................................... 238

Table 85. Logging system and silvicultural system with the least risks to aquatic habitat for the Saddle 

Lakes project area ....................................................................................................................... 240

Table 86. Rain-dominated hydrologic zone scenario. Bolded cells indicate watersheds that reach 2 

percent or more of basin area as roads in a given alternative. Bordered cells indicate watersheds 

that may experience detectable peak flow increase as a result of cumulative roads and harvest 

level. ........................................................................................................................................... 241

Table 87. Road-stream crossings by alternative and stream class in affected watersheds................. 242

Table 88. Percentage of basin area as roads by alternative ................................................................ 245

Table 89. Known Alaska heritage resource sites located within a five-mile radius of the Saddle Lakes 

project area ................................................................................................................................. 260

Table 90. Invasive species known in the Saddle Lakes project area.................................................. 267

Table 91. Existing vegetation types within and near the Saddle Lakes project area and their associated 

habitat vulnerability .................................................................................................................... 268

Table 92. Roadless characteristics and discussion ............................................................................. 277

Table 93. Roadless area acres and roadless acres within the project area for the 2001 Roadless Rule

 .................................................................................................................................................... 277

Table 94. LUD acres in roadless areas............................................................................................... 278

Table 95. Indirect effects of proposed Saddle Lakes Project on the North Revilla Inventoried Roadless 

Area ............................................................................................................................................ 284

Table 96. Indirect Effects of Proposed Saddle Lakes Project on the Carroll Inventoried Roadless Area

 .................................................................................................................................................... 284

Table 97. Lands and minerals ownership in the lands analysis area Saddle Lakes project area .. .... 289

Table 98. U. S. Forest Service, Alaska Region (R10) sensitive plants................ ............................. 298

Table 99. Gross volume/acre by volume strata in the Saddle Lakes Timber Sale project area....... . 307

Table 100. Acres of silvicultural system and prescription by alternative for the Saddle Lakes Timber 

Sale unit pool .............................................................................................................................. 313

Table 101. Unit group information for each opening over 100 acres in size that is proposed under 

Alternative 5 of the Saddle Lakes Timber Sale Project .............................................................. 315

Table 102. Increase in total young-growth stand acreage located on suitable/available forest lands in 

the Saddle Lakes project area under all alternatives ................................................................... 319

Table 103. Average annual employment in the timber industry ........................................................ 326

Table 104. Estimated visitor industry employment, labor income and spending in Southeast Alaska, 

2011 to 2012 ............................................................................................................................... 329

Table 105. Existing roads and trails in the Saddle Lakes project area ............................................... 343

Table 106. Fish stream crossings in the Saddle Lakes project area.................................................... 345

Table 107. Existing and proposed road miles in the Saddle Lakes project area ................................ 347

Table 108. Miles of road by objective maintenance level (OBML) in the Saddle Lakes project area

 .................................................................................................................................................... 347
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xviii  Table of Contents Saddle Lakes Timber Sale Final EIS

Table 109. Estimated transportation related costs and efficiencies for the Saddle Lakes Timber Sale

........................................................................................................................................ ........... 348

Table 110. Unavoidable adverse impacts of resources in the Saddle Lakes project area.................. 360

Table 111. Irreversible and/or irretrievable commitments1/ of resources identified in the proposed 

Saddle Lakes project area ........................................................................................................... 364

Table 112. Tongass National Forest timber volume necessary to supply derived demand for decked 

log volume and chips, in million board feet (MMBF) (Alexander 2008)1/ ................................ 417

Table 113. Accomplishments in gate system and timber pools (MMBF).......................................... 422

Table 114. Timber Volume involved in appeals, objections and/or litigation1/ ................................. 423

Table 115. Past harvest within the Saddle Lakes project area............................................................ 429

Table 116. Summary of Tongass National Forest five year timber sale schedule and contract plan . 433

Table 117. Potential resource interactions among the interrelated projects ....................................... 436

Table 118. Land use designation (LUD) Standards and Guidelines for the Saddle Lakes Timber Sale

 .................................................................................................................................................... 439

Table 119. Forest-wide Standards and Guidelines for the Saddle Lakes Timber Sale ....................... 441

Table 120. Best Management Practices for the Saddle Lakes Timber Sale ....................................... 448

List of Figures 

Figure 1. Vicinity map of the Saddle Lakes project area ....................................................................... 3

Figure 2. Value comparison units and inventoried roadless areas in the Saddle Lakes project area ...... 4

Figure 3. Land use designations in the Saddle Lakes project area ......................................................... 9

Figure 4. Comparison of logging systems by alternative ..................................................................... 30

Figure 5. Comparison of silvicultural system by alternative ................................................................ 30

Figure 6. Interior productive old-growth (POG) diagram .................................................................... 87

Figure 7. Saddle Lakes project area wildlife connectivity corridors .................................................... 89

Figure 8. Variation in partial cutting removal patterns ...................................................................... 119

Figure 9. Saddle Lakes Project Area visual priority routes (VPRs) ................................................... 185

Figure 10. Scenic integrity objective (SIO) current condition for the Saddle Lakes project area ...... 187

Figure 11. Photo point 101 location map, Saddle Lakes Recreation Area ......................................... 195

Figure 12. (Photo point 101) existing view looking from North Saddle Lake (Saddle Lakes Recreation 

Area), southeast to northwest ..................................................................................................... 196

Figure 13. (Photo point 101), with proposed Alternative 5 units shown as an overlay over Figure 12 

above .......................................................................................................................................... 196

Figure 14. Existing Recreation Opportunity Spectrum classes in the Saddle Lakes Project Area ..... 203

Figure 15. Hydrologic unit code (HUC) 6th-level watersheds, stream classes, and locations of red 

pipes (red fish crossings) in the Saddle Lakes project area ........................................................ 227

Figure 16. Hydrologic unit code (HUC) 7th-level watersheds, stream classes, and locations of red 

pipes (red fish crossings) in the Saddle Lakes project area ........................................................ 229

Figure 17. Inventoried Roadless Areas in the Saddle Lakes project area .......................................... 275

Figure 18. Lands and minerals analysis area ...................................................................................... 291

Figure 19. Land classifications and acreages in the Saddle Lakes Timber Sale ................................ 308

Figure 20. Tongass timber harvest, fiscal years 2001 to 2014 ........................................................... 414

Figure 21. Tongass National Forest suitability analysis ..................................................................... 424
Chapter 1

Purpose of and Need for 

Action

Saddle Lakes Timber Sale Final EIS Purpose and Need for Action - Chapter 1  1 

Chapter 1. Purpose of and Need for Action

Introduction____________________________________________

The Saddle Lakes Timber Sale Final Environmental Impact Statement (FEIS) describes the 

anticipated effects of, and alternatives to, a proposed timber sale or sales on Revillagigedo Island (see 

Figure 1). It describes the “No-Action Alternative” (Alternative 1), the “Proposed Action” 

(Alternative 2), and four action alternatives for harvesting timber and constructing associated roads. 

The 2008 Tongass National Forest Land and Resource Management Plan (hereafter referred to as the 

Forest Plan) together with applicable environmental laws and regulations provides direction for this 

project. The Forest Plan includes a glossary of key terms consistent with terms used in this document 

(USDA Forest Service 2008b, Chapter 7). The Saddle Lakes Timber Sale proposes to move the 

project area from the existing condition to the desired condition as identified in the Forest Plan for 

land use designations that allow timber harvest.

The planning interdisciplinary team (IDT) used a systematic approach for analyzing the proposed 

project and alternatives to it, estimating the environmental effects, and preparing this FEIS. The 

planning process complies with the National Environmental Policy Act (NEPA) and the Council on 

Environmental Quality (CEQ) regulations. Planning was coordinated with the appropriate federal, 

State, and local agencies, and local federally recognized tribes. The public, agencies, and tribes were 

involved in the planning process through meetings, letters, and personal conversations. 

The best available science is used in preparation of this FEIS. However, what constitutes best 

available science might vary over time and across scientific disciplines. This FEIS and the 

accompanying project record identify methods used, reference scientific and peer reviewed sources, 

discuss opposing views, and disclose incomplete or unavailable information, scientific uncertainty, 

and risk (see 40 C.F.R. §§ 1502.9(b), 1502.22, 1502.24). 

The project record references the scientific information considered: papers, reports, literature 

reviews, review citations, academic peer reviews, science consistency reviews, and results of groundbased observations to validate best available science. This FEIS incorporates by reference (as per 40 

C.F.R. § 1502.21) information contained in the project record, including specialist reports, unit and 

road cards, and other technical documentation. This FEIS also tiers to the 1997 Forest Plan Final 

Environmental Impact Statement (FEIS) and 2008 Forest Plan Amendment FEIS. Information from 

specialist reports has been summarized in Chapter 3. Affected Environment and Environmental 

Consequences. The project record is located at the Ketchikan-Misty Fiords Ranger District Office in 

Ketchikan, Alaska.

Document Organization

This FEIS describes the purpose and need, the identified alternatives, the environmental 

consequences of implementing the proposed action, a list of the IDT and references, and additional 

information on specific aspects of the proposed project. 

Chapter 1 - Purpose and Need

Chapter 1 explains the purpose and need for the proposed action, discusses how the Saddle Lakes 

Timber Sale relates to the Forest Plan, and identifies the significant issues driving the FEIS analysis. 

Chapter 1 also describes public involvement, and the required federal and State permits, licenses, and 
1 Purpose and Need for Action

2  Chapter 1 – Purpose and Need for Action Saddle Lakes Timber Sale Final EIS

certifications needed to implement the project, as well as applicable laws and executive orders that 

pertain to this project.

Chapter 2 - Alternatives

Chapter 2 describes the proposed action, compares alternatives to the proposed action including a Noaction Alternative, and summarizes the environmental consequences by issue.

Chapter 3 – Affected Environment and Environmental Consequences

Chapter 3 describes the affected environment and evaluates the potential direct, indirect and 

cumulative environmental consequences of the proposed action and each management alternative 

likely to occur.

Chapter 4 - References and Lists

Chapter 4 contains the list of preparers, the FEIS distribution list, literature cited, and an index. 

Appendices

Appendices A, B and C provide additional information on specific aspects of the project. Appendix A 

of this document provides information on how this project relates to the overall Tongass Timber Sale 

Program, and why the project is being scheduled at this time. Appendix B contains information on 

interrelated projects, which have been grouped as past, present, and reasonably foreseeable future 

actions which have been considered in the cumulative effects analysis. Appendix C is a list of 

applicable Forest Plan Standards and Guidelines, a description of applicable best management 

practices (BMPs), and mitigation and monitoring. 

Location of Project Area _________________________________ 

The project area is located on Revillagigedo Island, and is within the Ketchikan-Misty Fiords Ranger 

District, about 14 air miles northeast of Ketchikan, Alaska between George and Carroll Inlets. The 

Saddle Lakes project area encompasses 38,459 acres and includes National Forest System (NFS) and 

non-NFS land. Non-NFS lands are owned by the Cape Fox Corporation, State of Alaska Department 

of Natural Resources (ADNR), State of Alaska Mental Health Trust Authority (hereafter referred to as 

the Trust), and private landowners. The project area is partially roaded due to previous timber harvest.

Elevation ranges from sea level to over 2,500 feet. Most of the Saddle Lakes project area is within 

value comparison units (VCUs) 7460, 7470 and 7530 (Figure 1). VCUs are comparable to large 

watersheds and generally follow major topographic divides. Portions of wildlife analysis areas 

(WAAs) 406 and 407 are found within the project area. WAAs are divisions of land used by the 

Alaska Department of Fish and Game (ADF&G) for wildlife analysis.

There are about 53 miles of existing NFS roads and about 14 miles of decommissioned1

 temporary 

roads within the project area. 

1 Road decommissioning is defined as: “Activities that result in the stabilization and restoration of unneeded 

roads to a more natural state.”
Purpose and Need for Action 1

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Figure 1. Vicinity map of the Saddle Lakes project area
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4  Chapter 1 – Purpose and Need for Action Saddle Lakes Timber Sale Final EIS

Figure 2. Value comparison units and inventoried roadless areas in the Saddle Lakes project area
Purpose and Need for Action 1

Saddle Lakes Timber Sale Final EIS Purpose and Need for Action - Chapter 1  5

Project Background

The Saddle Lakes project area was selected because timber harvest is allowed in Timber Production 

and Modified Landscape LUDs, and suitable timber is currently available for harvest. Further, the 

project area has an existing road infrastructure which would help to reduce the costs for accessing 

some of the proposed timber harvest units. The need to meet the demand for timber supply is 

explained in further detail in Chapter 3 and Appendix A of this FEIS.

Purpose and Need for the Action

CEQ regulations (40 C.F.R. §1502.13) state that the document shall briefly specify the underlying 

purpose and need to which the agency is responding. The PURPOSE is the goal or objective that the 

Forest Service is trying to achieve. The NEED is the underlying problem or opportunity to which the 

Forest Service is responding with the action.

Purpose

The purpose of the Saddle Lakes Timber Sale is to respond to the goals and objectives identified by 

the Forest Plan (USDA Forest Service 2008b) that guide timber management to support the local and 

regional economies of Southeast Alaska. Forest-wide multiple-use goals and objectives that apply to 

this project include, but are not limited to:

Timber—Goals and Objectives (USDA Forest Service 2008b, pg. 2-7): 

• Goal: Provide for the continuation of timber uses and resources by the timber industry and

Alaska residents.

• Goal: Manage the timber resource for production of saw timber and other wood products from

suitable forest lands made available for timber harvest, on an even-flow, long-term sustained

yield basis and in an economically efficient manner.

• Objective: Seek to provide an economic timber2 supply sufficient to meet the annual market

demand for Tongass National Forest timber, and the market demand for the planning cycle, up to

a ceiling of [the Forest Plan’s] allowable sale quantity (ASQ), which is 2.67 billion board feet in

the first decade.

• Objective: Provide 2 to 3 years supply of volume under contract to local mills and then establish

shelf volume [sale projects with completed NEPA and field work – ready to offer] to maintain

flexibility and stability in the sale program.

• Objective: Review the timber sale program and work with state and other partners to implement

changes that keep an “economic timber” perspective throughout the process and monitor the

implementation of these reforms to ensure they are consistently employed across the Forest.

Local and Regional Economy—Goals and Objectives (USDA Forest Service 2008b, pg. 2 -5): 

• Goal: Provide a diversity of opportunities for resource uses that contribute to the local and

regional economies of Southeast Alaska.

• Objective: Support a wide range of natural resource employment opportunities within Southeast

Alaska communities.

2 Economic timber is defined as a sale of timber where the average purchaser can meet all contractual obligations, harvest 

and transport the timber to the purchaser’s site, and have a reasonable certainty of realizing a profit from the sale.
1 Purpose and Need for Action

6  Chapter 1 – Purpose and Need for Action Saddle Lakes Timber Sale Final EIS

Consistent with the forest-wide multiple-use goals and objectives, the Forest Plan also includes areaspecific management prescriptions called land use designations (LUDs), each with its own goals and 

objectives, and specific standards and guidelines (USDA Forest Service 2008b, Chapter 3). The 

project area includes Timber Production, Modified Landscape, and Old-growth Habitat LUDs.

The Tongass National Forest must comply with Section 101 of the Tongass Timber Reform Act 

(TTRA) which states:

...the Secretary [of Agriculture] 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 market demand from such 

forest for each planning cycle.

Need

The need for the Saddle Lakes Timber Sale comes from the Forest Service’s obligation under the 

TTRA. Forest-dependent communities in Southeast Alaska are facing social, economic, and 

environmental challenges. As the predominant land manager in Southeast Alaska, the Forest Service 

plays a critical role in the economic vitality of communities. Local residents rely heavily on natural 

resource-based industries. The region has experienced a significant decline in harvest levels, which 

has led to a decline in timber manufacturing and employment. 

The Saddle Lakes Timber Sale is proposed at this time to respond to the need for a stable supply of 

timber from the Tongass National Forest. The Saddle Lakes Timber Sale is essential to providing an 

orderly flow of timber from suitable timber lands to purchasers of both large and small timber sales; 

sawmill operators, and value-added wood product industries in Southeast Alaska. These businesses 

contribute to the local and regional economies. Furthermore, the sale would provide “bridge” timber 

to help sustain current industry infrastructure and jobs in Southeast Alaska while the Tongass National 

Forest transitions to a young-growth based timber program (USDA Forest Service 2013). 

Using relevant Forest Plan goals and objectives, the Interdisciplinary Team (IDT) assessed the 

existing conditions in the Saddle Lakes project area. In comparing the existing conditions to the 

desired conditions, the IDT identified several opportunities: 

1. There is an opportunity to provide a reliable economic supply of sawtimber and other wood

products to increase and diversify current levels of the wood products industry;

2. There is an opportunity to provide for resource uses increasing natural resource employment

opportunities that would contribute to the local and regional economies of Southeast Alaska;

3. There is an opportunity to improve forest stand health, growth and productivity on commercial

forest lands by removing overmature stands and replacing them with faster growing, disease and

defect free, young stands; and

4. There is an opportunity to improve fish habitat.

Proposed Action________________________________________

The proposed action3 is defined early in the planning process. It serves as a starting point for the 

environmental analysis, and gives the public and other agencies specific information on which to 

3 The proposed action is a proposal made by the Forest Service to authorize, recommend, or implement an action to meet a 

specific purpose and need (FSH 1909.15 Chapter 10). 
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Saddle Lakes Timber Sale Final EIS Purpose and Need for Action - Chapter 1  7

focus comments. Using these comments and information from preliminary analysis and scoping (see 

discussion of Significant Issues later in the chapter), the IDT develops alternatives to the proposed 

action. The alternatives are discussed in detail in Chapter 2.

The Responsible Official can modify a proposed action or alternatives as the analysis progresses 

as long as the analysis is done collaboratively and it is clear and obvious to anyone interested. It 

must also be properly documented (36 C.F.R. § 220.5 (e) (1)). Modifications to the proposed 

action are discussed and documented in Chapter 2. 

The Saddle Lakes Timber Sale would establish a trend toward the desired conditions as described in 

the Forest Plan. This would be accomplished by responding to the underlying purpose and need (40 

C.F.R. § 1502.13) with the following activities: 

• Harvest about 30 million board feet (MMBF) of timber from about 2,207 acres of harvest units,

using conventional (cable and shovel) and helicopter logging systems, and a combination of evenaged (1,055 acres; 100 percent basal area removal) and uneven-aged (1,152 acres; 33 percent

basal area removal) silvicultural systems.

• Construct about 10 miles of NFS road to access timber harvest units which would be stored (i.e.,

closed) after timber harvest activities are completed.

• Construct about 6 miles of temporary road which would be decommissioned after timber harvest

activities are completed.

• Recondition (i.e., re-opening and maintaining closed roads) up to 11 miles of existing NFS road

which would be stored after timber harvest activities are completed.

• Reconstruct the Shelter Cove log transfer facility (LTF) by replacing the existing native log

bulkhead.

• Modify a naturally occurring partial fish barrier in lower Salt Creek. Explosives would be used to

modify the barrier to create a series of low steps and resting pools. All in-channel work would be

agreed upon with ADF&G – Division of Habitat.

• Authorize a 300-foot wide by 1 mile long Ketchikan to Shelter Cove right-of-way (ROW)

easement on NFS lands to the State of Alaska for construction, operation and maintenance of a

14-foot wide public road (proposed NFS Road 8300280). This road would remain open to

motorized use after timber harvest.

Relationship to the Forest Plan ___________________________

The Forest Plan is based on an extensive forest-level analysis (USDA Forest Service 2008c) and 

provides management direction for the Tongass National Forest. The Saddle Lakes Timber Sale 

analysis and subsequent implementation is designed to achieve the management direction of the 

Forest Plan as outlined in the purpose and need statement.

Project-level planning provides an additional opportunity (beyond development of the Forest Plan) 

for public participation. The Saddle Lakes Timber Sale FEIS is a project-level analysis; its scope is 

confined to addressing the significant issues and disclosing the possible environmental effects of the 

project. The Saddle Lakes Timber Sale FEIS does not attempt to address Forest Plan decisions. 

However, the FEIS is consistent with applicable direction provided in the Forest Plan. 
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8  Chapter 1 – Purpose and Need for Action Saddle Lakes Timber Sale Final EIS

Forest Plan Land Use Designations

The Forest Plan uses land use designations (LUDs) to guide management of the NFS lands within the 

Tongass National Forest. Each LUD provides for a unique combination of activities, practices and 

uses. The Saddle Lakes project area includes three LUDs: Timber Production, Modified Landscape, 

and Old-growth Habitat (see Figure 3). Goals, objectives and desired conditions of each LUD are 

summarized below. The Forest Plan contains a detailed description of each LUD (USDA Forest 

Service 2008b, Chapter 3). The Saddle Lakes project area also includes non-NFS lands (lands in 

State or private ownership). No Forest Service harvest or road building activities would occur on 

these lands. However, past and present and reasonably foreseeable future activities known on these 

lands are considered in the cumulative effects analysis (see Appendix B). 

Table 1 summarizes the acreages and percentages of each LUD, and non-NFS lands (lands in State or 

private ownership) found within the Saddle Lakes project area.

Table 1. Land use designations and non-National Forest acreages and percentages in the Saddle Lakes 

project area

Measure

Timber 

Production 

LUD

Modified 

Landscape 

LUD

Old-growth 

Habitat LUD

Non-National 

Forest Total

Project Area 

Acres 15,305 16,028 3,565 3,557 38,455 

Project Area 

Percent 40% 42% 9% 9% 100% 

Source: Tongass National Forest GIS, 2013. Numbers may not add up due to rounding.

Timber Production LUD

The focus of the Timber Production LUD is to emphasize sustained, long-term timber production. 

Timber harvest activities are located and designed to meet timber objectives.

Modified Landscape LUD

Management within Modified Landscape LUD emphasizes sustained, long-term timber production 

while minimizing the visibility of development in the foreground distance zone, and moderating the 

effects of development in the middle and background distance zones. This recognizes the scenic 

values of forested lands as viewed from identified Visual Priority Travel Routes and Use Areas 

(Forest Plan, Appendix F) and provides for modifying timber harvest practices accordingly by 

reducing the effects to scenery.

Old-Growth Habitat LUD

The focus of this LUD as related to this project is to maintain areas of old-growth forests and their 

associated natural ecological processes to provide habitat for old-growth associated resources. Timber 

harvest for timber management objectives is not compatible with this LUD.
Purpose and Need for Action 1

Saddle Lakes Timber Sale Final EIS Purpose and Need for Action - Chapter 1  9

Figure 3. Land use designations in the Saddle Lakes project area
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10  Chapter 1 – Purpose and Need for Action Saddle Lakes Timber Sale Final EIS

Relationship to the Access and Travel Management Plan ______

The Saddle Lakes FEIS incorporates by reference the decision of the Environmental Assessment (EA) 

for the KMRD Access and Travel Management Plan (ATM) (USDA Forest Service 2008g). The 

KMRD ATM considered road management objectives (RMOs) for existing roads on the District. The 

RMOs of existing NFS roads within the Saddle Lakes project area were determined in the KMRD 

ATM. Newly constructed NFS roads and temporary roads are analyzed in this document.

Decision Framework ____________________________________

The Responsible Official for the decision on this project is the Forest Supervisor of the Tongass 

National Forest. Based on the environmental analysis in this EIS, the Forest Supervisor will decide 

whether and how to make timber available from the Saddle Lakes project area in accordance with

Forest Plan goals, objectives and desired conditions. The Forest Supervisor will consider public 

comments, applicable laws, regulations and policies, and state his rationale in the Record of Decision.

The decision will include the following: 

• The estimated timber volume to make available from the project, as well as the location, design,

and scheduling of timber harvest, road construction and reconditioning, reconstruction of the

Shelter Cove LTF, and silvicultural practices to be used;

• Access management measures, including authorizing the State of Alaska ROW on NFS lands;

• Mitigation measures and monitoring requirements;

• Whether or not to modify a small old-growth reserve (OGR) within the project area, which would

require a Forest Plan amendment;

• Whether or not to remove visual priority routes (VPR) designations within the project area, which

would require a Forest Plan amendment;

• Whether there may be a significant restriction on subsistence uses; and

• Whether to modify a natural fish barrier on Salt Creek.

Public Involvement______________________________________

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

the public involvement activities that have occurred for the project area analysis.

Scoping

The Council on Environmental Quality (CEQ) defines scoping as “[a]n early and open process for 

determining the scope of issues to be addressed and for identifying the significant issues related to a 

proposed action'' (40 C.F.R. § 1501.7). Among other things, the scoping process is used to invite 

public participation, to help identify public issues, and to obtain public comment at various stages of 

the EIS process. The intent of scoping is to focus the analysis on significant issues and reasonable 

alternatives. Although scoping is to begin early, it is really a process that continues until a decision is 

made.

The Saddle Lakes Timber Sale has been listed on the Tongass National Forest 5-Year Timber Sale 

Action Plan since June 2008, the Tongass National Forest public webpage since April 2012, and 

included in the Tongass National Forest Schedule of Proposed Actions since July 2012. These 

documents are available online (http://www.fs.usda.gov/tongass/).
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Saddle Lakes Timber Sale Final EIS Purpose and Need for Action - Chapter 1  11

Notice of Intent

A Notice of Intent (NOI) for the Saddle Lakes Timber Sale DEIS was published in the Federal 

Register (FR) on May 8, 2012 (77 FR 27013-27015). The 30-day comment period ended on June 7, 

2012. 

A corrected NOI was published on June 17, 2013 (78 FR 36164 – 36165). The corrected NOI was 

published because of the length of time that passed since the first Saddle Lakes Timber Sale NOI was 

published, and changes in the dates that the Draft and Final Environmental Impact Statements were

expected. Additionally, the United States Department of Agriculture published a final rule on March 

27, 2013 (78 FR 18481-18504) to establish a new process by which the public may file objections 

seeking predecisional administrative review of proposed projects and activities implementing land 

management plans documented with a Record of Decision or Decision Notice (reference 36 C.F.R. § 

218). This new process replaces the administrative appeals process at 36 C.F.R. § 215.

Public Mailings

On May 2, 2012, a scoping notice seeking public comment on the proposed action for the Saddle 

Lakes Timber Sale was mailed to 89 individuals and groups that had previously shown interest in 

Forest Service projects in Southeast Alaska. This included federal and State agencies; Alaska Native 

organizations; municipal offices; businesses; interest groups; and individuals. A total of seven 

responses to this mailing were received. The comments are filed in the project record. 

On June 7, 2013, an update letter was sent to the respondents who previously commented during the 

initial scoping of the NOI. The letter indicated the changes in the dates that the Draft and Final EIS 

are expected. The letter also indicated that the EIS was subject to the new objections process (36 

C.F.R. § 218) rather than the former administrative appeals process (36 C.F.R. § 215). 

On April 4, 2014, an update letter was sent to the respondents who previously commented during the 

initial scoping of the NOI to share some modifications the Responsible Official made to the proposed 

action, as well as to provide an update on the anticipated DEIS Notice of Availability (NOA). The 

Responsible Official can modify a proposed action or alternatives as the analysis progresses as long 

as the analysis is done collaboratively and it is clear and obvious to anyone interested. It must also be 

properly documented (36 C.F.R. § 220.5 (e) (1)).

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

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

the Ketchikan Daily News, the official newspaper of record. The DEIS was mailed to federal and 

State agencies, native and municipal offices, and to others who requested it. A list of recipients is 

included in Chapter 4 of the DEIS. The DEIS was also available at the Ketchikan Misty Fiords 

Ranger District, in public libraries throughout Southeast Alaska and on the internet at 

http://www.fs.fed.us/r10/tongass/projects/projects.shtml. 

Local News Media

A news article about the Saddle Lakes project was printed in the Ketchikan Daily News on May 7, 

2012. 

Consultation with Tribal Governments

Executive Orders 13084 and 13175 require that federal agencies consult with tribes during planning 

activities. Government-to-government consultation with federally recognized tribal governments and 

meetings with traditional tribal governments have taken place as follows:
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12  Chapter 1 – Purpose and Need for Action Saddle Lakes Timber Sale Final EIS

• Prior to January 2012, the Ketchikan-Misty Fiords District Ranger and/or District staff

periodically emailed or met with tribal committees of the Ketchikan Indian Community,

Metlakatla Indian Community, and Organized Village of Saxman and provided information on the

Saddle Lakes Timber Sale.

• Since January 2012, the Ketchikan-Misty Fiords District Ranger and/or District staff have met

monthly with tribal councils of the Ketchikan Indian Community, Metlakatla Indian Community,

and Organized Village of Saxman and provided information and project updates on the Saddle

Lakes Timber Sale.

Other Federal and State Agency Involvement

The Forest Service is committed to working closely with other federal and State agencies at all stages 

of planning, and is responsible for coordinating project reviews by other agencies. In some cases, the 

reviews are required because another agency has the authority to issue permits for a specific activity 

proposed by the Forest Service. In other cases, the reviews provide a time for dialogue with agencies 

responsible for ensuring that certain environmental conditions are met, such as clean water or healthy 

wildlife populations. In many cases, an ongoing professional dialogue is maintained between agencies 

throughout the planning process. 

U.S. Environmental Protection Agency

The U.S. Environmental Protection Agency (EPA) provides a general review in accordance with their 

responsibilities under NEPA, Section 309 of the Clean Air Act, and Section 402 of the Clean Water 

Act.

National Marine Fisheries Service

The National Marine Fisheries Service (NMFS) has authority for fisheries management, species 

protection, and habitat conservation activities derived primarily from the Magnuson-Stevens Fishery 

Conservation and Management Act, Marine Mammal Protection Act, and Endangered Species Act 

(ESA). This includes all marine life, anadromous salmon, and Essential Fish Habitat. The Forest 

Service consults with NMFS concerning possible effects to these species.

U.S. Army Corps of Engineers

The U.S. Army Corps of Engineers (USACE) is responsible for approving proposals to dredge or 

place fill materials in the coastal waters of the United States under Section 404 of the Clean Water 

Act. The USACE also has administrative authority over activities associated with wetlands. Any road 

construction in wetlands, or any fill or removal of material from streams, wetland, or marine 

environment is of interest to USACE, and the Forest Service must consider and reduce effects on 

those areas.

U.S. Fish and Wildlife Service

The U.S. Fish and Wildlife Service (USFWS) has legal jurisdiction over a host of federal legal 

mandates including the Endangered Species Act, Federal Water Pollution Control Act ("Clean Water 

Act"), Migratory Bird Treaty Act, Bald Eagle Act, and Rivers and Harbors Act. The Forest Service 

has ongoing consultation with the USFWS to determine if the proposed project will affect threatened 

or endangered species.

A Biological Assessment/Biological Evaluation (BA/BE) was prepared for the Saddle Lakes project 

as required under Section 7 of the Endangered Species Act (ESA), as amended, and the USDA Forest 

Service (USFS) threatened, endangered, and sensitive plant and animal species policy (FSM 2670). 
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Saddle Lakes Timber Sale Final EIS Purpose and Need for Action - Chapter 1  13

Threatened, endangered, and candidate species potentially occurring in the project area were 

identified through consultation with the U.S. Fish and Wildlife Service (USFWS) and the National 

Marine Fisheries Service (NMFS). Confirmation of the threatened and endangered species list was 

received from NMFS on June 07, 2013. Humpback whales are the only federally listed species known 

to occur near the project area.

The BA/BE was sent to the U.S. Fish and Wildlife Service (USFWS) and National Marine Fisheries

Service (NMFS) as part of the Section 7 consultation under the Endangered Species Act[db1] . A final 

determination of “Not likely to adversely affect” was made for humpback whales and “may adversely 

impact individuals, but not likely to cause a trend to federal listing or a loss of viability in the 

Planning Area nor cause a trend toward federal listing” for goshawks. Other species analyzed had a 

determination of no effect or no impact. 

State of Alaska

The State of Alaska was involved in the development of the Forest Plan and the Memorandum of 

Understanding (MOU) for Economic Timber Sales. 

Several departments in the State of Alaska were invited to participate in the planning of this project. 

They provided general comments and suggestions, as well as specific reviews. These departments 

include: 

Alaska Department of Environmental Conservation

The Alaska Department of Environmental Conservation (ADEC) is part of the interagency team to 

review OGRs and participates in cooperative water quality management through Section 319 of the 

Clean Water Act and a Memorandum of Agreement with the Forest Service. ADEC also issues a 

certificate of compliance with Alaska Water Quality Standards under Section 401 of the Clean Water 

Act for log transfer facilities (LTFs).

Alaska Department of Fish and Game

The Forest Service and Alaska Department of Fish and Game (ADF&G) have responsibilities to 

cooperate in the common stewardship of fish and wildlife and their habitats on NFS lands. ADF&G is 

especially interested in instream activities and other fish, wildlife, and subsistence issues.

ADF&G and the Forest Service have a MOU to protect fish habitat and fish passage, and reach

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

before any work occurs below the ordinary high water for fish-bearing water bodies that may use, 

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

Discussions on wildlife habitat in regards to this project have occurred between representatives from 

ADF&G Wildlife Conservation and Habitat Divisions and the Forest Service. Further, ADF&G 

Wildlife Conservation has taken part in field reviews with Forest Service personnel of units and 

habitat within the Saddle Lakes project area.

There is a MOU between the State of Alaska and the Forest Service for implementing the Tongass 

Forest Plan and environmental analyses. An ADF&G habitat biologist works with Forest Service 

IDTs in the design and/or review of old-growth and young-growth commercial timber sales.
1 Purpose and Need for Action

14  Chapter 1 – Purpose and Need for Action Saddle Lakes Timber Sale Final EIS

Alaska Department of Natural Resources

The Alaska Department of Natural Resources (ADNR) manages all State-owned land, water and 

natural resources, except for fish and game, on behalf of the people of Alaska. Within ADNR are 

several divisions and offices that reflect its major programs.

Division of Forestry

The Division of Forestry (DOF) manages forests for multiple uses and the sustained yield of 

renewable resources for the State of Alaska. The DOF is also involved in a MOU between the State of 

Alaska and the Forest Service for implementing the Tongass Forest Plan and environmental analyses.

A State forester also works with Forest Service planning IDTs in the design and/or review of oldgrowth and young-growth commercial timber sales. The DOF assisted in reconnaissance of the 

Saddle Lakes project area, and consultation with the IDT regarding economic timber harvest.

Division of Mining, Land, and Water

The Division of Mining, Land, and Water (DMLW) issues tideland permits and the lease or easement 

necessary for the log transfer facility (LTF) sites.

Office of Project Management and Permitting

The Office of Project Management and Permitting (OPMP) provides overall coordination for the 

State’s comments for federal projects in the State of Alaska. Because of the complexity and potential 

impact of these projects on multiple divisions or offices, OPMP acts as a single primary point of 

contact. OPMP has a coordinator who acts as single primary point of contact for Tongass National 

Forest projects. 

Division of Parks and Outdoor Recreation

Alaska Office of History and Archeology

The Alaska Office of History and Archeology carries out the responsibilities of the State Historic 

Preservation Officer (SHPO). The SHPO is responsible for participating in the review of federal, 

State, and local undertakings that may affect historic properties. 

Under the terms of the existing Programmatic Agreement with the SHPO and the Advisory Council 

on Historic Preservation (USDA Forest Service 2010d), it was determined by the Forest Service 

archeologist on September 18, 2013, with concurrence by the SHPO on September 30, 2013, that no 

historic properties would be affected by any of the proposed alternatives.

Federal and State Permits, Licenses, and Certifications _______

Various permits are required before implementation of the project. The permits that may be needed 

and authorizing agencies are listed below: 

U. S. Army Corps of Engineers (USACE)

• Discharge approval of dredged or fill material into waters of the United States (Section 404 of the

Clean Water Act of 1977, as amended). 

• Approval of construction of structures or work in navigable waters of the United States (Section

10 of the Rivers and Harbors Act of 1899).

• For road construction a 404 permit from the USACE is not necessary because roads constructed

as part of this project are for silvicultural purposes and follow the 33 C.F.R. § 323 guidelines and

best management practices (BMPs) to avoid and minimize impacts to wetlands.
Purpose and Need for Action 1

Saddle Lakes Timber Sale Final EIS Purpose and Need for Action - Chapter 1  15

U. S. Environmental Protection Agency (EPA)

• The National Pollutant Discharge Elimination System (NPDES) Program originated under

Section 402 of the Clean Water Act, which requires that pollutant discharges to surface water be 

authorized by permit. The U.S. Environmental Protection Agency (EPA) administered the 

program in Alaska until permitting authority was transferred to the State, through the Department 

of Environmental Conservation (DEC) Alaska Pollutant Discharge Elimination System (APDES) 

Program.

State of Alaska, Department of Environmental Conservation (ADEC)

• Certification of compliance with Alaska Water Quality Standards (Section 401 Certification). In

accordance with Section 401 of the Clean Water Act (CWA) any applicant for a federal license or 

permit to conduct an activity that might result in a discharge into waters of the U.S. must also 

apply for and obtain certification from ADEC that the discharge will comply with the CWA, the 

Alaska Water Quality Standards (WQS, 18 AAC 70), and other applicable State laws. By 

agreement between the U.S. Army Corps of Engineers (USACE) and ADEC, an application for a 

USACE permit to discharge dredged and/or fill material into waters of the U.S. under Section 404 

of the CWA may also serve as an application for ADEC 401 water quality certification. After 

reviewing the USACE public notice, ADEC may certify there is a reasonable assurance the 

activity, and any discharge that might result, will comply with the CWA, the Alaska WQS, and 

other applicable State laws.

• Solid Waste Disposal Permit (ADEC Division of Environmental Health - Solid Waste Program).

• Renewal of an Alaska Pollutant Discharge Elimination System (APDES) general permit AKG-70-

1000 allowing for the discharge of bark and wood debris associated with in-water log transfer and

log storage.

State of Alaska, Department of Natural Resources (ADNR)

• Authorization for occupancy and use of tidelands and submerged lands at Shelter Cove.

State of Alaska, Department of Fish and Game, Habitat Division (ADF&G)

• A Title 16 concurrence must be reached before any instream work occurs below the ordinary high

water of any fish-bearing water bodies. This includes culvert replacement or removal and 

instream fish barrier modification. 

Issues ________________________________________________

The Council on Environmental Quality (CEQ) explains that issues may be identified through scoping, 

and that only significant issues must be the focus of the environmental document (40 C.F.R. §§ 

1501.7(a)(2), 1501.7(a)(3), 1502.1, and 1502.2(b)). Issues for the Saddle Lakes Timber Sale were 

identified through internal Forest Service staff and externally through public scoping with interested 

and affected members of the public, federal and State agencies, tribal governments, and organizations. 

Issues are best identified during scoping early in the process to help set the scope of the actions, 

alternatives, and effects to consider. Due to the iterative nature of the NEPA process, additional issues 

may come to light at any time.

For the purpose of Forest Service NEPA analysis, an “issue” is a point of disagreement, debate, or 

dispute with a proposed action based on some anticipated environmental effect. An issue is more than 

just a position statement, such as disagreement with timber harvest on NFS lands. An issue:
1 Purpose and Need for Action

16  Chapter 1 – Purpose and Need for Action Saddle Lakes Timber Sale Final EIS

• has a cause and effect relationship with the proposed action or alternatives;

• is within the scope of the analysis;

• has not been decided by law, regulation, or previous decision; and

• is agreeable to scientific analysis rather than conjecture.

The IDT used a systematic process to analyze all comments received during scoping to identify 

issues. Both internal and external scoping comments received were considered for this project. The 

Forest Service received seven scoping response letters, from which 177 individual comments were 

generated. Each comment or issue was discussed and evaluated to determine whether the comment or 

issue is:

• addressed by Forest Plan LUDs;

• addressed through implementation of Forest Plan Standards and Guidelines and best management

practices (BMPs);

• addressed through implementation of project-specific mitigation measures;

• addressed during processes or analyses routinely conducted by the IDT;

• addressed through spatial location of actions during alternative design;

• used to drive or partially drive an alternative;

• beyond the scope of the project; and

• other requests or comments.

The issues identified were categorized as either significant or non-significant. This process was used 

to ensure that all significant issues were identified, and that all other issues and concerns were 

meaningfully considered in this analysis. Similar issues were combined into one statement where 

appropriate. Results of the IDT issue identification process and a summary of all scoping comments 

are available in the project record.

Significant Issues

Significant issues are those related to significant or potentially significant effects caused directly or 

indirectly by implementing the proposed action. The term “significant issues” is used when there may 

be a cause-effect relationship between a proposed action and a significant effect, and the disclosure of 

that effect is documented in an EIS (FSH 1909.15 Chapter 10, Section 12.41). 

The following issues were determined to be significant and within the scope of the project decision.

Significant issues were used to highlight significant effects or unintended consequences that may 

occur from the modified proposed action, providing opportunities during the analysis to explore 

alternative ways to meet the purpose and need while reducing adverse effects. Chapter 2 of this FEIS

discusses and compares these alternatives in terms of the significant issues. 

Units of measure are defined to identify how each alternative responds to a significant issue. The 

measures chosen were quantitative where possible, predictable, responsive to the issue, and linked to 

cause-effect relationships. These measures describe how the alternative affects the resource or 

resources central to the issue.
Purpose and Need for Action 1

Saddle Lakes Timber Sale Final EIS Purpose and Need for Action - Chapter 1  17

Issue 1. Timber Economics

Issue Statement: An economical timber sale would support the local and regional 

economies of Southeast Alaska.

Lack of a steady supply of economic timber can adversely affect the viability of Southeast Alaska’s 

forest products industry and the ability of the industry to contribute to the diversity and stability of 

local and regional economies. The Saddle Lakes project is one component of this supply. To compare 

the alternatives, analyses included the quantity and quality of timber offered costs of road 

construction, reconstruction and maintenance, and costs associated with logging systems and 

silvicultural prescriptions. A broader discussion about the Tongass National Forest timber program is 

in Appendix A of this EIS. 

Units of Measure:

• Indicated advertised rate (dollars per MBF)

• Acres by logging system (shovel, cable, helicopter)

• Volume of timber by species (net sawlog and net utility wood, in MBF and MMBF)

• Road construction/reconditioning costs and LTF costs (dollars per MBF)

• Logging costs (dollars per net MBF removed, without utility)

• Total production costs (stump-to-mill, roads, and manufacturing costs in millions of dollars)

• Employment supported by the project (number of annualized jobs)

Issue 2. Timber Availability

Issue Statement: Availability of timber within the project area that is allowed to be harvested 

under the Forest Plan affects a stable supply of timber to meet local and regional timber 

demand.

Issue 2 addresses concerns about the availability of timber within the project area. This was most 

recently described in the 2008 Forest Plan Amendment FEIS (USDA 2008c, p. A-5) as Key Issue 2: 

“The Tongass National Forest needs to seek to provide a sufficient timber supply to meet the market 

demand and help maintain a vibrant economy in Southeast Alaska.” 

This project proposes two amendments to the 2008 Forest Plan. One involves relocating a portion of 

small old-growth habitat reserve LUD into the North Revilla Inventoried Roadless Area. This action 

would provide additional suitable timberlands (USDA Forest Service 2008b, p. A-1) within the 

project area. The other proposed amendment would remove visual priority route (VPR) designations, 

in order to meet less-restrictive Forest Plan Standards and Guidelines. As a result, additional evenaged management and larger harvest units could be prescribed at this time, thereby increasing the 

timber harvest volume for this project. 

Units of Measure:

• Changes in acres of suitable timberlands due to modification of the small old-growth reserve

• Changes in acres by scenic integrity objective levels
1 Purpose and Need for Action

18  Chapter 1 – Purpose and Need for Action Saddle Lakes Timber Sale Final EIS

Issue 3. Wildlife Habitat and Subsistence Use

Issue Statement: Timber harvest and road construction, combined with past management 

activities, would affect wildlife habitat and could affect subsistence use. 

Public and agency comments, as well as internal scoping, expressed concerns about project effects on 

wildlife and wildlife habitat and old-growth connectivity, and subsistence use in the project area. Of 

special concern are project effects on deer because of their importance to wolves and subsistence 

users. The project area includes low-elevation (less than 1,500 feet), old-growth habitat important for 

old-growth dependent wildlife species. Removing old-growth habitat fragments wildlife habitat and 

leads to a loss of old-growth connectivity. 

Because of its proximity to the residents of Ketchikan and Saxman, the Saddle Lakes project area is 

considered an important deer hunting area for these communities. The cumulative effects on oldgrowth habitat associated with additional harvest, combined with past harvest and increasing road 

density were noted concerns. 

Units of Measure (Issue 3A: Wildlife Habitat): 

• Percent reduction from historic and existing acres of habitat by wildlife species (using sizedensity model [SDM] habitat classifications) at the value comparison unit (VCU), and/or wildlife 

analysis area (WAA) scale, biogeographic province, Revillagigedo Island and game management 

unit (GMU)

• Wolf analysis also done at the biogeographic province scale

• Connectivity/Fragmentation in the project area by alternative (corridor analysis, reduction of

POG acres, change in patch size)

• Open and total road density (miles per square mile) at analysis scales specific to wolf and marten

requirements

• Deer model habitat capability (DHC) and density

Unit of Measure (Issue 3B: Subsistence Use): 

• Deer abundance and competition estimated by hunter demand as a percent of DHC

Issue 4. Scenery and Recreational Opportunities

Issue Statement: Timber harvest and road construction could affect the scenery and 

recreational opportunities in the Saddle Lakes project area.

Internal concerns were expressed regarding the effects that timber harvest would have on areas visible 

from visual priority routes and use areas (VPRs). The five VPRs in or adjacent to the project area 

include: planned Saddle Lakes Recreation Area (see Figure 9), Harriet Hunt (Ketchikan) to Shelter 

Cove Connection Road, Shelter Cove Boat Ramp, Carroll Inlet, and George Inlet. Changes to 

recreational opportunities may occur because of road construction and timber harvest. 

Internal concerns were expressed regarding the planned Saddle Lakes Recreation Area, which is the 

most likely place in the project area for dispersed camping, kayaking and canoeing. The proposed 

easement would provide the needed link across National Forest System lands to allow the State to 

connect the community of Ketchikan to the Shelter Cove LTF and the opportunities for recreation in 

that area.
Purpose and Need for Action 1

Saddle Lakes Timber Sale Final EIS Purpose and Need for Action - Chapter 1  19

Units of Measure (Scenery):

• Acres of timber harvest by silvicultural prescription within areas of high and moderate scenic

integrity objective (SIO)

• Miles of road construction within project areas of high and moderate SIO

• Acres of timber harvest by silvicultural prescription within the planned Saddle Lakes Recreation

Area viewshed

• Project area acres that will change SIO if visual priority routes (VPR) designations are removed

Unit of Measure (Recreation):

• Changes to recreation opportunity spectrum (ROS) system classification (acres)

In addition to these units of measure, a qualitative discussion of the project’s effects on the 

recreational opportunities and experience in the project area is included. 

Issues and Concerns Considered Non-significant

While many issues may arise during scoping, not all of the issues raised warrant analysis in an EIS. 

NEPA documents must concentrate on the issues truly significant to the action in question, rather than 

amassing needless detail (40 C.F.R. § 1500.1(b)). This ensures that the analysis and documentation is 

focused primarily on the issues related to significant or potentially significant effects and the decision 

to be made. 

The CEQ regulations direct the Forest Service to identify and eliminate from detailed study the issues 

which are not significant or which have been covered by prior environmental review (1506.3), 

narrowing the discussion of these issues in the statement to a brief presentation of why they will not 

have a significant effect on the human environment or providing a reference to their coverage 

elsewhere (40 C.F.R. § 1501.7(a) (3)). 

The following issues and concerns were discussed and evaluated, but determined to be nonsignificant and were not used to drive alternatives. The rationale for why these issues were 

determined to be non-significant is included below.

Aquatic Habitat (Fisheries/Hydrology/Watersheds)

External concerns were expressed that the cumulative effects of past and proposed harvest and 

existing and proposed roads in the project area may increase sedimentation and stream temperatures, 

and impact aquatic habitat. The project area includes a number of streams and lakes, and contains 

high quality anadromous and resident fish habitat. Concerns regarding protection of water resources 

will be addressed through implementation of Forest Plan Standards and Guidelines and best 

management practices (BMPs) (see Appendix C) and during processes or analyses routinely 

conducted by the IDT. See the Aquatics section in Chapter 3.

Sensitive and Rare Plants – Pacific Silver Fir

One external comment requested that units containing Pacific silver fir (Abies amabilis) should not be 

harvested. During internal scoping for this project, effects of timber harvest on Pacific silver fir was

initially considered as a significant issue due to the fact that the project area is the northern extent of 

its range in the Pacific Northwest. Specifically, regeneration of Pacific silver fir was the central issue.

This issue was addressed during alternative design and after analysis (see rare plant resource report, 

Dillman 2014) was dropped from further consideration. The proposed action was designed to 
1 Purpose and Need for Action

20  Chapter 1 – Purpose and Need for Action Saddle Lakes Timber Sale Final EIS

minimize impacts to Pacific silver fir by including uneven-aged management (33 percent basal area 

removal) silvicultural systems. 

After vegetation field surveys for the occurrence of Pacific silver fir in the project area and its overall 

distribution forest-wide, it was determined that implementation of Forest Plan Standards and 

Guidelines would address the regeneration concerns raised during internal scoping. Forest Plan 

Standards and Guidelines direct the Forest Service to “avoid, minimize, or mitigate adverse effects to 

rare plant populations (PLA1, III.C. pg. 4-41).” While this conifer is designated “rare” according to 

Alaska Natural Heritage Program (ANHP) database, it is officially designated as “rare or uncommon 

in the state” and is “demonstrably secure globally.”

Clearcutting

One external comment expressed concerns regarding clearcutting that economic considerations alone 

do not justify clearcut prescriptions. Other external commenters expressed concerns that clearcutting 

was necessary for sale economics. The Forest Service will seek to reduce clearcutting when other 

harvest cutting methods will meet land management objectives per Forest Plan LUD objectives.

When clearcutting is determined to be the appropriate logging system, justification will be provided.

The Silviculture section in Chapter 3 provides a discussion about the justification for clearcutting. 

Climate Change

External comments expressed concerns about the uncertainties of climate change, including climate 

change effects on the natural regeneration of yellow-cedar, and greenhouse gas emissions resulting 

from project activities. One external respondent asked that the Forest Service follow the updated 

(June 2012) CEQ Federal Greenhouse Gas Accounting and Reporting Guidance (part of President 

Obama's Executive Order 13514) that establishes requirements for federal agencies in calculating and 

reporting GHG emissions associated with agency operations. Upon review of this CEQ guidance, 

GHG emissions resulting from the Saddle Lakes Timber Sale are considered Scope 3 GHG emissions.

As stated in this guidance, “While agencies are not required to report emissions related to their 

vendors and contractors at this time, agencies may Voluntarily begin to identify their vendor and 

contractor (supply chain) emissions.” Currently the Agency does not have an accepted tool for 

analyzing all GHG emissions.

This issue was addressed during processes or analyses routinely conducted by the IDT. In January 

2009, national guidance was developed for the Forest Service to address climate change in projectlevel NEPA analyses. Complete quantifiable information about project effects on global climate 

change is not currently possible and is not essential to a reasoned choice among alternatives (USDA 

2009a), but a qualitative analysis of climate change is provided in the Air Quality and Climate 

Change section in Chapter 3. 

Deferred Road Maintenance

External concerns were expressed that within the Saddle Lakes project area there are deferred road 

maintenance and culvert issues, and repair should be included as part of the project. Road 

reconditioning is heavier maintenance of an existing (Maintenance Level 1) road, in storage to restore 

the road to the original constructed standard for use during timber harvest operations. Road 

reconditioning is included on up to 11.1 miles of existing National Forest System road in the project 

area and may include culvert replacement, surface rock replacement and subgrade repair. Additional 

maintenance of NFS roads in the project area may occur before, during, and after this project analysis. 

The Forest Service Maintenance Management System provides a systematic process for field units to 

effectively and efficiently manage their road maintenance programs. Road maintenance of existing 
Purpose and Need for Action 1

Saddle Lakes Timber Sale Final EIS Purpose and Need for Action - Chapter 1  21

NFS roads is an ongoing process that occurs on a periodic basis. The Tongass National Forest 

prepares an annual road maintenance plan (FSM 7732.11) that establishes priorities to ensure that 

available funding is directed to the highest priority work. Normally this type of work is determined to 

fit the category of routine repair and maintenance of roads that do not individually or cumulatively 

have a significant effect on the quality of the human environment and may be categorically excluded 

(FSH 1909.15, 32.1.12). Any effects from ongoing road maintenance work are included in the effects 

analysis for this project. Road maintenance is discussed in the Transportation section in Chapter 3. 

Soils and Slope Stability

External comments expressed concerns regarding proposed timber harvest and road building on steep 

slopes, especially as it pertains to slope stability, erodible soils and potential increased sedimentation 

(see Aquatic Habitat above), and windfirmness of stands. These concerns will be addressed through

implementation of Forest Plan Standards and Guidelines and BMPs (see Appendix C). This issue was 

addressed during analyses routinely conducted by the IDT. The effects of timber harvest and road 

construction on the soils resource is analyzed in the Soils section in Chapter 3 of this FEIS. 

Other Resource Considerations

Other resource concerns are important, but were not used to drive the development of alternatives. 

Other resource considerations in this analysis are listed below. A detailed discussion of the effects to 

various other resources and protection measures can be found in the individual resource reports 

located in the project planning record. These resource considerations are summarized in Chapter 3 of 

this FEIS and include the following: 

• Air Quality and Climate Change

• Aquatic Resources

• Environmental Justice

• Heritage Resources

• Invasive Plants

• Inventoried Roadless Areas

• Lands and Minerals

• Plants

• Silviculture

• Socioeconomics

• Soils

• Transportation

• Wetlands

Applicable Laws and Executive Orders _____________________

Shown below is a partial list of federal laws and executive orders pertaining to project-specific 

planning and environmental analysis on federal lands. While most pertain to all federal lands, some of 

the laws are specific to Alaska. Disclosures and findings required by these laws and orders are 

contained in Chapter 3 of this FEIS. 

• Alaska Native Claims Settlement Act

(ANCSA) of 1971;

• Alaska National Interest Lands

Conservation Act (ANILCA) of 1980;

• American Indian Religious Freedom Act

of 1978;

• Archeological Resource Protection Act of

1979;

• Bald and Golden Eagle Protection Act of

1940 (as amended);

• Clean Air Act of 1970 (as amended);

• Clean Water Act (CWA) of 1977 (as

amended);

• Endangered Species Act (ESA) of 1973

(as amended);

• Executive Order 11593 (Cultural

Resources);

• Executive Order 11988 (Floodplains);

• Executive Order 11990 (Wetlands);
1 Purpose and Need for Action

22  Chapter 1 – Purpose and Need for Action Saddle Lakes Timber Sale Final EIS

• Executive Order 12898 (Environmental

Justice);

• Executive Order 12962 (Aquatic Systems

and Recreational Fisheries);

• Executive Order 13007 (Indian Sacred

Sites);

• Executive Order 13175 (Government-toGovernment Consultation);

• Executive Order 13443 (Facilitation of

Hunting Heritage and Wildlife

Conservation);

• Forest and Rangeland Renewable

Resources Planning Act (RPA) of 1974 (as

amended);

• Magnuson-Stevens Fishery Conservation

and Management Act of 1996;

• Marine Mammal Protection Act of 1972;

• Migratory Bird Treaty Act of 1918 (as

amended);

• Multiple-Use Sustained-Yield Act

(MUSYA) of 1960;

• Native American Graves Protection and

Repatriation Act (NAGPRA) of 1990;

• National Environmental Policy Act

(NEPA) of 1969 (as amended);

• National Forest Management Act (NFMA)

of 1976 (as amended);

• National Historic Preservation Act

(NHPA) of 1966 (as amended);

• National Transportation Policy (2001);

• Organic Act of 1897;

• Rivers and Harbors Act of 1899;

• Tongass Timber Reform Act (TTRA) of

1990 

Availability of the Project Record __________________________

An important consideration in preparing this FEIS is the reduction of paperwork specified in 40 

C.F.R. § 1500.4. This FEIS provides sufficient site-specific information to demonstrate a reasoned 

consideration of the environmental impacts of the alternatives and ways to mitigate the impacts. The 

project record contains documentation of the NEPA process, and analysis of the effects of the project.

The FEIS is available online at http://www.fs.fed.us/r10/tongass/projects/projects.shtml or copies of 

this FEIS may be obtained from the Ketchikan-Misty Fiords Ranger District. Additional 

documentation, including more detailed analyses of project-area resources, may be found in the 

project planning record located at the Ketchikan-Misty Fiords Ranger District office in Ketchikan, 

Alaska.

Reference documents, such as the Forest Plan and the Forest Plan FEIS are available for review at 

Forest Service offices throughout Southeast Alaska, including the Forest Supervisor’s office in 

Ketchikan. The Forest Plan is available on-line (see Tongass National Forest website).

Map and Data Disclaimers________________________________

All map products in this document are reproduced from geospatial information prepared by the 

USDA Forest Service. Maps are intended to depict physical features as they generally appear on the 

ground and may not be used to determine title, ownership, legal boundaries, legal jurisdiction, 

including jurisdiction over roads or trails, or access restrictions that may be in place on either public 

or private land. Permission should be obtained before entering private lands, and check with 

appropriate government offices for restrictions that may apply to public lands. Lands, and roads and 

trails within the boundaries of the National Forest may be subject to restrictions on motor vehicle use.

To obtain a Ketchikan-Misty Fiords Ranger District Motor Vehicle Use Map (MVUM), inquire at the 
Purpose and Need for Action 1

Saddle Lakes Timber Sale Final EIS 

local Forest Service Office. Natural hazards may or may not be depicted on the map, and land users 

should exercise due caution. Maps are not suitable for navigational use.

Geographic information system (GIS) data and product accuracy may vary. Combining GIS layers 

during project analysis often creates polygons less than 1 acre in size; therefore, acreages may vary 

slightly. The USDA Forest Service makes no warranty, expressed or implied, including the warranties 

of merchantability and fitness for a particular purpose, nor assumes any legal liability or 

responsibility for the accuracy, reliability, completeness or utility of these geospatial data, or for the 

improper or incorrect use of these geospatial data. These geospatial data and related maps or graphics 

are not legal documents and are not intended to be used as such. The data are dynamic and may 

change over time. The user is responsible to verify the limitations of the geospatial data and to use the 

data accordingly.

Using GIS products for purposes other than those for which they were created may yield inaccurate or 

misleading results. The Forest Service reserves the right to correct, update, modify or replace GIS 

products without notification. To ensure distribution of the most current public information, please 

refer requests for data or products to the USDA Forest Service, Tongass National Forest, Ketchikan, 

Alaska.

Purpose and Need for Action - Chapter 1  23
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Chapter 2 

Alternatives

Saddle Lakes Timber Sale Final EIS Alternatives - Chapter 2  25

Chapter 2. Alternatives

Introduction____________________________________________

This chapter describes and compares the alternatives considered by the Forest Service for the Saddle 

Lakes Timber Sale. The chapter includes a discussion of how the alternatives were developed, 

monitoring and other features common to all action alternatives, a description and map of each 

alternative considered in detail, and a comparison of these alternatives focusing on the significant 

issues identified in the interdisciplinary process. Alternative 4 is identified as the Preferred 

Alternative. 

NEPA directs the Forest Service to “study, develop, and describe appropriate alternatives to 

recommended courses of action in any proposal that involves unresolved conflicts concerning 

alternative uses of available resources...” (42 U.S.C. § 4332). In addition, the CEQ regulations

require agencies to “rigorously explore and objectively evaluate all reasonable alternatives...” as well 

as those other alternatives, which are eliminated from detailed study with a brief discussion of the 

reasons for eliminating them. (40 C.F.R. § 1502.14 (a)). 

Based on the information and analysis described in the Affected Environment and Environmental 

Consequences sections in Chapter 3, Chapter 2 presents the environmental impacts of the proposal 

and alternatives in comparative form. This comparison is intended to sharply define the issues and 

provide a clear basis for choice among options by the decision maker and the public (40 C.F.R. § 

1502.14). 

Alternative Development _________________________________ 

An alternative is a set of activities designed to meet the purpose and need for the project as described 

in Chapter 1. The purpose and need statement helps define the range of alternatives. The range of 

alternatives explores alternative means of meeting the purpose and need for this project. 

The proposed action (Alternative 2) is one approach to meeting the purpose and need for the project

and was developed during the early planning phase of this project. The planning phase included 

completing a logging system and transportation analysis (LSTA) for the project area (USDA Forest 

Service 2007). During and after the 2007 analysis, the suitable and available timber in the project area 

was divided into logical harvest settings. These groups of settings were used to create the harvest unit 

pool. In addition, the roads needed to access the harvest unit pool were identified. Survey of these 

units and the roads is ongoing. A number of units and roads were dropped because they were 

determined to be uneconomical or inconsistent with Forest Plan direction. 

Alternative 2 was modified based on: scoping comments, internal comments from the IDT and 

Responsible Official, additional field verification, storm damage to the Shelter Cove log transfer 

facility (LTF), and ongoing collaboration between the Forest Service and the State of Alaska 

regarding the proposed Ketchikan to Shelter Cove Road. Table 2 summarizes these modifications. 
2 Alternatives

26  Chapter 2 – Alternatives Saddle Lakes Timber Sale Final EIS

Table 2. Modifications to the proposed action

Measure As Scoped As Modified Change

Harvest acres 2,613 acres 2,207 acres -406 acres

Volume 33 MMBF 30 MMBF -3 MMBF

Total road construction 19 miles 16 miles -3 miles

NFS road 9.3 miles 10 miles +0.7 mile

Temporary road 9.2 miles 6 miles -3.2miles

Road reconditioning N/I 10.8 miles +10.8 miles

Shelter Cove LTF existing Shelter Cove 

LTF

reconstruct Shelter Cove 

LTF New Action

Fish enhancement N/I

fish passage partial 

barrier modification at 

Salt Creek

New Action

State of Alaska ROW1/ N/I 300 feet x approx.1 mile

ROW New Action

Notes: MMBF = million board feet; N/I = Not Included; ROW = Right-of-Way

1/ State of Alaska ROW on NFS lands

Forest Service resource specialists make up the interdisciplinary team (IDT). The IDT considered 

various alternatives to the proposed action to provide a reasonable range of options for meeting the 

purpose and need for the action. Alternatives were designed to address the issues identified during 

scoping (see Chapter 1), and to meet Forest Plan Standards and Guidelines (see Appendix C) and 

applicable laws. Within this range, various combinations of alternatives can be considered in 

determining the Selected Alternative. 

In response to comments received during the Saddle Lakes scoping process, the Responsible 

Official asked the IDT to investigate maximizing available timber in the roaded portions of 

inventoried roadless areas (IRAs), and redesigning the OGRs to exclude any roaded portions. 

Harvesting timber in the roaded portion of the IRAs was eliminated from detailed analysis. Since the 

Forest Plan allows for modification of the size and location of an OGR (USDA 2008b, Appendix K), 

an alternative to maximize timber availability was developed that includes harvest units in the 

roaded portion of the current small OGR in VCU 7470. 

On March 12, 2013, a project-level review was conducted by an interagency review team comprised 

of U.S. Fish and Wildlife Service (USFWS), Alaska Department of Fish and Game (ADF&G), and 

Forest Service biologists. The interagency review team reviewed the locations of the OGR with 

regard to roadless areas and their biologically preferred locations. The OGR was relocated to be 

wholly within the North Revilla IRA and the resulting area designated as Modified Landscape LUD. 

Alternatives Considered but Eliminated from Detailed Analysis

Several alternatives were considered during the planning process, but have not been included in this 

FEIS for detailed study. Federal agencies are required by NEPA to briefly discuss the reasons for 

eliminating any alternatives that were not developed in detail (40 C.F.R. § 1502.14 (a)). Public 

comments and internal scoping provided suggestions for alternatives in response to the proposed 

action, and for meeting the purpose and need of the project. Some of these alternatives were

considered to be outside of the scope of this project, already decided by a law, regulation, or the 

Forest Plan, irrelevant to the decision to be made, or not supported by scientific or factual evidence. 
Alternatives 2

Saddle Lakes Timber Sale Final EIS Alternatives - Chapter 2  27

These alternatives are described briefly below, along with the reasons for not considering them further 

in detail.

Timber Harvest from Roaded Portion of Roadless Areas

As part of Alternative 5 the IDT looked at maximizing timber harvest, including harvest within the 

roaded portion of the 2001 Inventoried Roadless Areas (IRAs) to address Issue 2 (Timber 

Availability). The IDT determined that there are approximately 250 acres of potential harvest units 

within roaded IRAs. Harvesting units in the roaded portion of the IRAs was eliminated from detailed 

analysis because the 2001 Roadless Area Conservation Rule prohibits timber harvest in IRAs, and 

does not meet the exceptions outlined in 36 C.F.R. § 294.13 (b)(4). This aspect of Alternative 5 was 

eliminated from further consideration. 

On March 26, 2014 the Ninth Circuit Court of Appeals reversed the District Court’s decision

concerning the exemption of the Tongass National Forest from the Roadless Rule, remanding the 

case to the District Court to decide whether a supplemental EIS is required for the Tongass 

exemption. In August 2014, the Ninth Circuit Court of Appeals granted another hearing, held in

December 2014 before an eleven-judge panel to rehear the appeal of the 2011 District Court decision. 

The Ninth Circuit Court has issued its en banc decision in Organized Village of Kake v. USDA, 

11-35517, upholding the Alaska District Court’s reinstatement of the roadless rule, which remains in 

effect and applies to the Tongass.

Rare and Sensitive Plants Alternative – Pacific Silver Fir

As discussed under Issues and Concerns Considered Non-significant in Chapter 1, harvest and 

regeneration of Pacific silver fir was initially considered as a significant issue (see Chapter 1) and

therefore an alternative was considered. Implementation of Forest Plan Standards and Guidelines will 

minimize adverse effects to other sensitive and rare plant populations and address any concerns. 

Therefore, this alternative was eliminated from detailed analysis.

Yellow-cedar Alternative

The IDT considered yellow-cedar and yellow-cedar decline as a potential alternative-driving issue in 

response to public comments. However, it was determined that an alternative that avoided healthy 

yellow-cedar stands was not warranted. The Forest Plan provides protection to approximately 20,000 

acres of productive and unproductive forest that contains yellow-cedar in the project area and the 

amount of yellow-cedar within proposed harvest units comprises only a fraction of the yellow-cedar 

within the project area.

Small Sales Alternative

One respondent requested that a small sales alternative be considered. Unit packaging is a contracting 

decision, not part of a NEPA decision. The timber volume in any action alternative could be 

separated administratively into timber sales of varying size and complexity. Each action alternative 

includes many harvest units suitable for small timber sale offerings. Therefore, creating an 

alternative was not necessary. Additionally, an alternative solely designed to provide timber for 

small sales was determined not to be consistent with the project’s purpose and need to contribute to a 

long-term supply of economic timber for the timber industry on the Tongass National Forest 

(including both large and small operators), in a manner that is consistent with the multiple-use goals 

and objectives of the Forest Plan. 

Items Common to All Action Alternatives ___________________

The following components are included in the action alternatives: 
2 Alternatives

28  Chapter 2 – Alternatives Saddle Lakes Timber Sale Final EIS

Road Management

All Saddle Lakes action alternatives have been analyzed using the same road management objectives 

(RMOs) for existing National Forest System (NFS) roads as the Ketchikan-Misty Fiords Ranger 

District Access and Travel Management Plan (KMRD ATM) Environmental Assessment (EA) 

analysis (USDA Forest Service 2008g) and determined by the decision on the EA. The Saddle Lakes 

Timber Sale also analyses any proposed NFS roads for access and travel management requirements. 

All new construction would be from the existing road system. All new NFS roads and reconditioned 

roads would be closed to motorized use except for about 1 mile of newly constructed NFS Road 

8300280 within the proposed State of Alaska ROW. All temporary roads would be decommissioned 

after timber harvest.

Road reconditioning is heavier maintenance and restoration of an existing stored (Maintenance Level 

1) road to the original constructed standard for use during timber harvest operations. Road

reconditioning is needed on up to 11.1 miles of existing National Forest System road and may include 

culvert replacement, surface rock replacement and subgrade repair. All new fish stream crossings will 

provide fish passage. 

Windthrow and Reasonable Assurance of Windfirmness Buffers

Silvicultural prescriptions considered the need for the addition of reasonable assurance of 

windfirmness (RAW) buffers. RAW buffers provide additional protection to riparian management 

areas (RMAs) that may be affected by windthrow. This is in addition to each Forest Plan minimum 

stream buffer prescribed on Class I, II, and III streams.

Log Transfer Facilities

There are two existing LTFs in or near the project area: one at Shelter Cove and the other at Leask 

Cove. The Shelter Cove LTF is owned and permitted by the Forest Service, and would be used to 

transport logs. Storms in 2013 damaged the Shelter Cove LTF enough to require reconstruction. 

Reconstruction would include replacement of the log bulkhead. 

The Leask Cove LTF is not federally owned. The State of Alaska Division of Forestry (DOF) has 

applied for a long-term authorization. Agreements would need to be sought by the purchaser, as well 

as permits from regulatory agencies to use this LTF. All action alternatives were developed using the 

FASTR financial tool to evaluate the use of the Shelter Cove LTF for domestic processed wood. 

Export timber would be transported via water from Shelter Cove to Leask Cove, which is an approved 

export point to ship the wood out of state. 

Fish Passage Barrier Modification

A fish passage barrier modification at lower Salt Creek (ADF&G Anadromous Catalog # 101-45-

10380), is proposed to allow improved access for coho salmon and steelhead to about 5 miles of 

upstream habitat and 139 acres of lake habitat. The 60 foot long cascade is located 0.25 mile above 

the intertidal zone, and is about 12 feet in vertical height. Coho salmon and steelhead can pass this 

naturally occurring barrier only at high flow levels. Modifying the barrier would allow improved 

access for these fish at all flow stages. Explosives would be used to modify the barrier, creating a 

series of low step and resting pools for upstream fish migration during lower flow levels. All inchannel work would be agreed upon with the ADF&G – Division of Habitat and the USACE. See 

aquatics resource report for further details. 
Saddle Lakes Timber Sale Final EIS Alternatives - Chapter 2  29

State of Alaska Right-of-Way on NFS Lands

The State of Alaska Department of Transportation and Public Facilities (ADOT&PF) has requested 

approval from the Forest Service to build, operate, and maintain about 1 mile of road that would 

connect the currently isolated Shelter Cove road system to the community of Ketchikan via the 

Revilla Road, and the White River and Leask Lake road systems. The Forest Service would approve 

this section of road through an easement that would be 300 feet wide. The exact alignment of the road 

is unknown; it is anticipated to align with NFS Road 8300280, which is proposed for construction in 

varying lengths under the action alternatives (see action alternative descriptions and maps) to access 

units 44, 106, 107, and 304. This section of new road would remain open to the public. This road does 

not go through IRAs. Connecting to the Shelter Cove road system is not necessary for the Saddle 

Lakes Timber Sale project; since there is already access to the Shelter Cove LTF, it is not a connected 

action. If the road is constructed prior to or during the Saddle Lakes Timber Sale, it may be used to 

haul timber to a different LTF.

Best Management Practices

Best management practices (BMPs) are methods, measures, or practices to prevent or reduce water 

pollution, including but not limited to structural and non-structural controls, operation and 

maintenance procedures, other requirements and scheduling and distribution of activities (Forest 

Service Handbook 2509.22, Region 10 Soil and Water Conservation Handbook). They are the result 

of extensive efforts between the Forest Service and the State of Alaska to identify practices that will 

ensure that timber harvest activities minimize soil erosion and protect aquatic habitat. BMPs, as 

applied to unit harvest and roads, are described in the unit and road cards located in the project 

record.

In 2012, the USDA Forest Service published National Core BMPs. Appendix C contains a crosswalk 

that shows how the National Core BMPs correspond to the R10 BMPs. 

Alternatives Considered in Detail __________________________

In addition to the proposed action (Alternative 2), four action alternatives are analyzed in the EIS.

The action alternatives were developed in response to significant issues and to provide a reasonable 

range of alternatives providing a clear basis for choice among options. A No-Action Alternative is 

also analyzed. Alternative maps were provided in a separate map packet in the DEIS, and included as 

pages 43-53 of this FEIS. 

Figure 4 and Figure 5 provide a visual comparison of the logging systems and silvicultural systems by 

alternative.

Alternatives 2
2 Alternatives

30  Chapter 2 – Alternatives Saddle Lakes Timber Sale Final EIS

Figure 4. Comparison of logging systems by alternative

Figure 5. Comparison of silvicultural system by alternative

Alternative 1 (No Action)

Under the No-action Alternative, no activities proposed by this project would be implemented, and 

the Saddle Lakes Timber Sale would not take place. Current and on-going management activities 

would continue. Changes might occur through current management direction (i.e., road maintenance), 

natural processes, or other management decisions in the future. This alternative does not preclude 

timber harvesting from other areas at this time or from the Saddle Lakes project area at some time in 

the future.

The CEQ regulations require a No-action Alternative (40 C.F.R. §§ 1502.14 (d), 1508.25 (b) (1)).

Unlike the action alternatives, the No-action Alternative does not meet the purpose and need for the 

project. However, the No-action Alternative provides a benchmark, enabling the Responsible Official 

to compare the magnitude of environmental effects of the action alternatives. 
Alternatives 2

Saddle Lakes Timber Sale Final EIS Alternatives - Chapter 2  31

Alternative 2 (Proposed Action) 

Objectives and Design Criteria: Alternative 2 was designed to harvest timber in the roaded land 

base in the Timber Production and Modified Landscape LUDs. Silvicultural prescriptions were 

developed to meet scenic integrity objectives (SIOs) for the project area. Alternative 2 was also 

designed to avoid or minimize adverse effects to sensitive and rare plants. Further, Alternative 2 was 

designed to maintain old-growth connectivity corridors between OGRs, and wildlife elevational 

corridors within the Modified Landscape LUD. 

Timber Harvest: Alternative 2 would harvest 30.4 MMBF of old-growth timber on 2,207 total 

acres. This alternative proposes 1,055 acres of even-aged management (clearcut) using conventional 

(cable and shovel) logging systems, as well as 1,152 acres of uneven-aged management (single-tree 

selection with 33 percent basal area removal) using shovel and helicopter logging systems. Helicopter 

logging would be used for about 50 percent of the acres.

Roads: Alternative 2 would construct 15.8 miles of road; 10.2 miles of new NFS road and 5.6 

miles of temporary road. About 0.4 mile of the NFS Road 8300280 would be constructed within the 

State of Alaska ROW. Road reconditioning is proposed on 10.8 miles of stored NFS road. 

Alternative 3

Objectives and Design Criteria: Alternative 3 addresses Issue 3 (Wildlife Habitat and Subsistence 

Use) and Issue 4 (Scenic Integrity and Recreational Opportunities) while allowing for economic 

timber harvest. Alternative 3 was developed to maintain wildlife habitat and landscape connectivity. 

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

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

Old-growth landscape connectivity corridors are maintained between OGRs, and wildlife elevational 

corridors are maintained within the Modified Landscape LUD. 

The prescriptions chosen for Alternative 3 also reduce impacts to scenery, which minimizes effects on 

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

(SIOs) for Modified Landscape LUDs. 

Timber Harvest: Alternative 3 would harvest 17.1 MMBF of old-growth timber on 1,012 total 

acres. This alternative proposes 816 acres of even-aged management (clearcut) using conventional 

logging systems, as well as 196 acres of uneven-aged management (single-tree selection with 33 

percent basal area removal) using helicopter logging systems. Helicopter logging would be used for 

about 19 percent of the acres. 

Roads: Alternative 3 would construct 11.7 miles of road; 6.7 miles of new NFS road and 5.0 miles of 

temporary road. About 0.4 mile of the new NFS Road 8300280 would be constructed within the State 

of Alaska ROW on NFS lands. Road reconditioning is proposed on 7.7 miles of stored NFS road. 

Alternative 4 – Preferred Alternative

Objectives and Design Criteria: Alternative 4 addresses Issue 1 (Timber Economics) and Issue 2 

(Timber Availability). Alternative 4 was designed to maximize timber harvest from an economical 

unit pool outside of IRAs and OGRs. 

As designed, Alternative 4 does not meet Forest Plan Scenery Standards and Guidelines and would 

require a reduction in scenery standards that would be accomplished by removing four of the five 

VPR designations in or adjacent to the project area. 
2 Alternatives

32  Chapter 2 – Alternatives Saddle Lakes Timber Sale Final EIS

Timber Harvest: Alternative 4 would harvest 51.0 MMBF of old-growth timber on 2,424 total 

acres. This alternative proposes 2,112 acres of even-aged management (clearcut) using conventional 

(cable and shovel) logging systems, as well as 312 acres of uneven-aged management (single-tree 

selection with 33 percent basal area removal) using cable and helicopter logging systems. Helicopter 

logging would be used on about 21 percent of the acres. 

Roads: Alternative 4 would construct 29.4 miles of road; 19.6 miles of new NFS road and 9.8 miles 

of temporary road. About 1 mile of the new NFS road (Road 8300280) would be constructed within 

the State of Alaska ROW. Road reconditioning is proposed on 10.8 miles of stored NFS road. 

Alternative 5

Objectives and Alternative Design Criteria: Alternative 5 addresses Issue 2 (Timber Availability). 

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

Landscape LUDs. The small OGR in VCU 7470 would be relocated within the North Revilla IRA, 

and the vacated area would be designated as Modified Landscape LUD where timber harvest is 

allowed. Alternative 5 maximizes the amount of conventional (cable and shovel) logging systems 

using even-aged management (clearcut).

As designed, Alternative 5 does not meet Forest Plan Scenery Standards and Guidelines and would 

require a reduction in scenery standards that would be accomplished by removing all five VPR

designations in or adjacent to the project area. Alternative 5 would also require a Forest Plan 

amendment to modify the small OGR. 

Timber Harvest: Alternative 5 would harvest 60.7 MMBF of old-growth timber on 2,875 total 

acres. This alternative includes 2,594 acres of even-aged management (clearcut) using cable and 

shovel logging systems, as well as 281 acres of uneven-aged management (33 percent basal area 

removal) using cable, shovel, and helicopter logging. Helicopter logging would be conducted for 

about 25 percent of the acres. 

Roads: Alternative 5 would construct 32.3 miles of road; 20.6 miles of new NFS road and 11.7 miles 

of temporary road. About 1 mile of the new NFS Road 8300280) would be constructed within the 

State of Alaska ROW. Road reconditioning is proposed on 11.1 miles of stored NFS road. 

Alternative 6

Objectives and Alternative Design Criteria: Alternative 6 addresses Issue 1 (Timber Economics), 

Issue 2 (Timber Availability), and Issue 4 (Scenic Integrity and Recreational Opportunities) and. 

Similar to Alternative 4, Alternative 6 was designed to maximize timber harvest from an economical 

unit pool outside of IRAs and OGRs, while reducing impacts to the visual and recreation resources in 

the planned Saddle Lakes Recreation Area VPR. This alternative leaves logical settings within the 

recreation area for potential future harvest and entry.

As designed, Alternative 6 does not meet Forest Plan Scenery Standards and Guidelines and would 

require a reduction in scenery standards that would be accomplished by removing four of the five 

VPR designations in or adjacent to the project area. 

Timber Harvest: Alternative 6 would harvest 40.5 MMBF of old-growth timber on about 2,138 total 

acres. This alternative proposes 1,654 acres of even-aged management (clearcut) using cable and 

shovel logging systems, and 484 acres of uneven-aged management (single-tree selection with 33 

percent basal area removal) using cable and helicopter logging systems. Helicopter logging would be 

used on about 22 percent of the acres. 
Alternatives 2

Saddle Lakes Timber Sale Final EIS Alternatives - Chapter 2  33

Roads: Alternative 6 would construct 24.5 miles of road; 16.3 miles of new NFS road and 8.2 miles 

of temporary road. About 1 mile of the new NFS Road 8300280 would be constructed within the 

State of Alaska ROW on NFS lands. Road reconditioning is proposed on 10.8 miles of stored NFS 

road. 

Comparison of Alternatives_______________________________

This section compares outputs and provides a summary of the effects of implementing each 

alternative in terms of the significant issues. Table 3 presents a direct comparison of the alternatives.

This table is summarized from Chapter 3, which should be consulted for a full understanding of these 

and other environmental consequences. 
2 Alternatives

34  Chapter 2 – Alternatives Saddle Lakes Timber Sale Final EIS

Table 3. Comparison of alternatives by issue

Measure Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5 Alternative 6

Issue 1: Timber Economics

Timber Volume by Species Millions of Board Feet (MMBF)

Sitka spruce 0 3.9 2.2 6.6 7.8 5.2

Hemlock 0 13.9 7.8 23.4 27.8 18.6

Western Redcedar 0 5.8 3.3 9.8 11.6 7.8

Alaska Yellow-cedar 0 3.5 2.0 5.9 7.1 4.7

Total Sawtimber Volume 0 27.2 15.3 45.7 54.3 36.3

Total Utility Volume 0 3.2 1.8 5.3 6.4 4.2

Total Volume ((Sawtimber Utility) 0 30.3 17.1 51.0 60.7 40.5

Logging System Acres

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

Shovel 0 495 292 538 578 538

Helicopter 0 1,100 196 497 719 479

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

Road Construction and Reconditioning Miles

New NFS Road 0 10.2 6.7 19.6 20.6 16.3

New Temporary Road 0 5.6 5.0 9.8 11.7 8.2

Total New Road Construction 0 15.8 11.7 29.4 32.3 24.5

Road Reconditioning of Stored NFS Roads 0 10.8 7.7 10.8 11.1 10.8

Financial Efficiency Analysis (Limited Export Policy & Domestic Processing)

Financial Efficiency Analysis Dollars per Thousand Board Feet (MBF)

Indicated Advertised Rate $0 -$14.05 -$12.08 -$2.00 -$4.66 $3.62

Road Construction, Reconditioning and LTF 

Reconstruction Costs $0 $81 $105 $91 $84 $95

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

Dollars (in millions)

Total Production Costs (stump-to-mill, roads, and 

manufacturing costs) $0 $17.7 $10.0 $29.3 $35.0 $23.1
Alternatives 2

Saddle Lakes Timber Sale Final EIS Alternatives - Chapter 2  35

Measure Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5 Alternative 6

Financial Efficiency Analysis (Domestic Processing)

Financial Efficiency Analysis Dollars per Thousand Board Feet (MBF)

Indicated Advertised Rate $0 -$70.73 -$104.52 -$95.15 -$97.91 -$89.71

Road Construction, Reconditioning and LTF 

Reconstruction Costs $0 $81 $105 $91 $84 $95

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

Total Production Costs (stump-to-mill, roads, and 

manufacturing costs) $0 $19,870,891 $11,689,070 $34,522,468 $41,223,979 $27,260,063

Employment Number of Annualized Jobs Supported

Total Jobs Estimated(Current R10 Policy) 0 121 68 203 241 161

Limited Export Policy & Domestic Processing) 0 145 81 243 290 194

Effects of Visual Priority Route (VPR)

Designation Removal Acres

Harvest in Areas that decreases in scenic integrity

objective (SIO) 0 0 0 1,285 1,642 743

Harvest in Areas with no change in scenic 

integrity objective (SIO) 0 2,207 1,012 1,139 1,233 1,395

Project Area that decreases in scenic integrity 

objective (SIO) 0 0 0 8,270 8,750 6,810

Additional Suitable timberlands available for harvest due to modification of the small Old-Growth Reserve in VCU 7470

Old-Growth Forest 0 0 0 0 322 0 

Issue 3: Wildlife Habitat and Subsistence Use

Issue 3A: Wildlife Habitat

Cumulative Change to Deer Habitat on All Land Ownerships

Historic Deep Snow Winter Habitat (high-POG 

≤800’ elevation on south aspect) Percent Reduction From Historic Acres

WAA 406 - 4,194 acres -33.8% -35.1% -34.0% -34.9% -35.1% -34.6%

WAA 407 - 1,937 acres -38.4% -39.9% -39.2% -41.5% -43.3% -41.5%

Historic Average Winter Habitat (POG ≤1,500’

elevation) Percent Reduction From Historic Acres

WAA 406 - 54,385 acres -21.8% -23.9% -22.5% -24.1% -24.7% -23.8%

WAA 407 - 28,932 acres -19.2% -21.9% -20.8% -22.1% -23.0% -21.8%
2 Alternatives

36  Chapter 2 – Alternatives Saddle Lakes Timber Sale Final EIS

Measure Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5 Alternative 6

Historic Non-winter Habitat (all habitats except 

older young-growth) Percent Reduction From Historic Acres

WAA 406 - 125,078 acres -9.9% -11.0% -10.3% -11.1% -11.5% -11.0%

WAA 407 - 61,000 acres -9.1% -10.5% -10.0% -10.6% -11.1% -10.5%

Cumulative Change in Deer Model Habitat Capability (DHC) on All Land Ownerships

1954 Theoretical Number of Deer Percent Reduction in DHC Since 1954 (at stem exclusion)

WAA 406 – 3,568 -31.4% -32.8% -31.8% -33.0% -33.4% -32.7%

WAA 407 – 2,465 -58.7% -60.3% -59.6% -60.6% -61.3% -60.5% 

Cumulative Effects on Wolves on All Land Ownerships

1954 Deer Model Deer Density Deer Density Compared to Historic Deer Density (deer/mi2 at stem exclusion) 

WAA 406 – 18 deer/mi2 12.3 12.1 12.3 12.1 12.0 12.1

WAA 407 - 24 deer/mi2 9.7 9.4 9.6 9.3 9.2 9.4

Total Road Density Road Density (mi/mi2)

WAA 406 1.5 1.6 1.5 1.6 1.6 1.6

WAA 407 2.0 2.1 2.1 2.1 2.2 2.1

Cumulative Change to Black Bear Habitat on All Land Ownerships

Historic POG Within 500-feet of Class I fish 

streams Percent Reduction From Historic Habitat Acres

WAA 406 - 8,944 acres -20.1% -21.8% 21.1% -21.8% -22.2% -21.9%

WAA 407 - 6,244 acres -40.2% -41.0% -40.2% -40.9% -41.6% -40.9%

Cumulative Change to Mountain Goat Habitat on All Land Ownerships

Historic POG Within 1,300-feet of a cliff (50

degree slope or greater) Percent Reduction From Historic Habitat Acres

WAA 406 – 47,600 acres -18.4% -19.4% -18.6% -19.5% -19.8% -19.2%

WAA 407 – 24,279 acres -26.9% -28.9% -28.0% -29.1% -29.7% -28.8%

Cumulative Change to American Marten Habitat on All Land Ownerships

Historic Winter Habitat- High POG < 1500’ in 

elevation Percent Reduction From Historic Habitat Acres

VCU 7460 – 12,639 acres -42.1% -45.1% -42.7% -45.6% -46.0% -45.0%

VCU 7470 – 7,353 acres -37.0% -42.6% -39.8% -43.3% -45.5% -42.7%

VCU 7530 – 10,830 acres -42.6% -43.1% -42.8% -43.1% -43.7% -43.1%
Alternatives 2

Saddle Lakes Timber Sale Final EIS Alternatives - Chapter 2  37

Measure Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5 Alternative 6

Historic Year-round Habitat - POG Percent Reduction From Historic Habitat Acres

VCU 7460 - 19,967 acres -27.4% -31.7% -28.5% -32.3% -33.3% -31.3%

VCU 7470 – 12,278 acres -23.2% -29.5% -27.0% -30.1% -32.1% -29.4%

VCU 7530 – 18,401 acres -25.2% -26.6% -26.0% -26.6% -27.2% -26.7%

Over 30 Percent Clearcut?

VCU 7460 No Yes No Yes Yes Yes

VCU 7470 No Yes No Yes Yes No

VCU 7530 No No No No No No

Total Road Density <1,500’ Road Density (mi/mi2)

VCU 7460 2.2 2.3 2.2 2.5 2.5 2.4

VCU 7470 1.5 1.8 1.8 2.0 2.1 1.9

VCU 7530 1.8 1.9 1.8 1.9 1.9 1.9

Cumulative Change to Brown Creeper Habitat on All Land Ownerships

Interior Habitat by VCU Percent Reduction of Historic Habitat

VCU 7460 – 10,983 acres -72.2% -75.4% -73.2% -75.8% -75.9% -75.5%

VCU 7470 – 6,363 acres -51.8% -55.7% -54.5% -56.0% -58.3% -55.8%

VCU 7530 – 8,248 acres -68.2% -68.5% -68.4% -68.4% -68.5% -68.5%

Cumulative Change to Hairy Woodpecker Habitat on All Land Ownerships

High-POG Habitat by VCU Percent Reduction of Historic Habitat

VCU 7460 – 14,455 acres -37.9% -40.5% -38.4% -41.0% -41.2% -40.4%

VCU 7470 – 7,750 acres -35.1% -40.5% -37.8% -48.5% -50.5% -40.5%

VCU 7530 – 11,523 acres -40.3% -40.7% -40.5% -46.1% -46.6% -40.7%

Cumulative Change to Red-breasted Sapsucker Habitat on All Land Ownerships

Low and Medium POG Habitat by VCU Percent Reduction of Historic Habitat

VCU 7460 – 5,512acres 0% -8.5% -2.6% -9.5% -12.1% -7.5%

VCU 7470 – 4,527 acres -2.7% -10.7% -8.5% -11.3% -13.1% -10.4%

VCU 7530 – 6,878 acres 0% -3.0% -1.6% -2.9% -3.6% -3.1%
2 Alternatives

38  Chapter 2 – Alternatives Saddle Lakes Timber Sale Final EIS

Measure Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5 Alternative 6

Cumulative Change to Red Squirrel Habitat on All Land Ownerships

POG Habitat by VCU Percent Reduction of Historic Habitat

VCU 7460 – 19,967 acres -27.4% -31.7% -28.5% -32.3% -33.3% -31.3%

VCU 7470 – 12,278 acres -23.2% -29.5% -27.0% -30.1% -32.1% -29.4%

VCU 7530 – 18,401 acres -25.2% -26.6% -26.0% -26.6% -27.2% -26.7%

Cumulative Change to River Otter Habitat on All Land Ownerships

POG Habitat within beach buffers and 500’ of 

Class I or II fish streams by VCU Percent Reduction of Historic Habitat

VCU 7460 – 8,218 acres -29.7% -34.1% -31.3% -34.2% -34.9% -33.3%

VCU 7470 – 6,378 acres -32.6% -36.0% -34.5% -36.5% -37.8% -36.5%

VCU 7530 – 13,288 acres -31.5% -32.6% -32.1% 32.5% -33.0% -32.6%

Cumulative Change to Vancouver Canada Goose Habitat on All Land Ownerships

Muskeg, NPOG, and Hydric POG by VCU Percent Reduction of Historic Habitat

VCU 7460 –12,126 acres 0% -3.9% -1.6% -4.5% -5.9% -4.2%

VCU 7470 – 7,674 acres 0% -3.0% -2.5% -3.2% -3.9% -3.1%

VCU 7530 – 15,557 acres 0% -1.1% -0.6% -1.1% -1.5% -1.2%

Cumulative Change to Red-backed Vole Habitat on All Land Ownerships

POG Habitat by VCU Percent Reduction of Historic Habitat

VCU 7460 – 19,967 acres -27.4% -31.7% -28.5% -32.3% -33.3% -31.3%

VCU 7470 – 12,278 acres -23.2% -29.5% -27.0% -30.1% -32.1% -29.4%

VCU 7530 – 18,401 acres -25.2% -26.6% -26.0% -26.6% -27.2% -26.7%

Cumulative Change to Goshawk Habitat on All Land Ownerships

Historic Nesting Habitat by VCU – High and 

medium POG <1.000’ elevation Percent Reduction of Historic Habitat

VCU 7460 – 12,196 acres -36.5% -41.5% -37.6% -42.0% -43.0% -40.8%

VCU 7470 – 8,864 acres -32.7% -39.8% -36.9% -40.6% -43.1% -40.6%

VCU 7530 – 14,696 acres -42.6% -43.9% -43.3% -43.9% -44.5% -44.0%
Alternatives 2

Saddle Lakes Timber Sale Final EIS Alternatives - Chapter 2  39

Measure Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5 Alternative 6

Historic Foraging Habitat by VCU – POG 

<1.000’ elevation Percent Reduction of Historic Habitat

VCU 7460 – 13,297 acres -35.5% -39.4% -35.0% -40.0% -41.2% -38.8%

VCU 7470 – 9,582 acres -30.3% -37.3% -34.6% -38.1% -40.5% -38.1%

VCU 7530 – 16,299 acres -38.5% -40.1% -39.4% -40.1% -40.7% -40.2%

Change to Old-Growth Reserves

Old-Growth Reserves Meets Comparable Achievement of Old-Growth Goals and Objectives

IRT determination of Small OGR VCU 7470 Yes Yes Yes Yes No Yes

Forest Service Determination of Small OGR in 

VCU 7470 Yes Yes Yes Yes Yes Yes

Connectivity

Elevational Connectivity in Modified 

Landscape LUD Number of identified corridors (8 elevational corridors total-2 unaffected in all alternatives)

Maintained in current condition 6 2 6 1 1 1 

Reduced in quality 0 4 0 5 5 5 

Issue 3B: Subsistence Use

Estimated Deer Harvest as a Percent of Adjusted Deer Model Habitat Capability (DHC) 

1954 Theoretical Number of Deer Hunter Demand at stem exclusion (Percent of Historic DHC)

WAA 406 – 2,284 12% 12% 12% 12% 12% 12% 

WAA 407 – 1,578 22% 23% 22% 23% 23% 23% 

Issue 4: Scenery and Recreational Opportunities

Issue 4A: Scenery

Acres of Harvest within High Scenic Integrity Objective (SIO) 

Silvicultural Method Acres of Harvest in High SIO 

Even-aged Management (Clearcut) 0 0 0 0 173 0 

Uneven-aged management (Partial-cut) 0 0 0 0 4 0 

Acres of Harvest within Moderate Scenic Integrity Objective (SIO) 

Silvicultural Method Acres of Harvest in Moderate SIO

Even-aged Management (Clearcut) 0 129 171 774 921 530

Uneven-aged management (Partial-cut) 0 589 27 148 61 185
2 Alternatives

40  Chapter 2 – Alternatives Saddle Lakes Timber Sale Final EIS

Measure Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5 Alternative 6

Road Construction Within High and Moderate Scenic Integrity Objective (SIO) 

SIO Miles of Road Construction

High 0 0 0.1 0.2 0.2 0.2

Moderate 0 3.8 3.5 11.9 12.2 9.7

Timber Harvest Within the Saddle Lakes Recreation Area (Planned Use Area)

Silvicultural Method Acres of Harvest

Even-aged Management (Clearcut) 0 6 0 462 526 215

Uneven-aged Management (Single-tree selection

with 33% basal area removed) 0 400 32 109 62 132

Total Harvest 0 406 32 571 588 347

Effect of Visual Priority Route (VPR) Designation Removal

Decrease in Scenic Integrity Objective (SIO) Acres

Project Area 0 0 0 8,270 8,750 6,810

Greater George/Carroll Inlet Area 0 0 0 13,920 14,930 10,900

Issue 4B: Recreational Opportunities

Changes to the Recreation Opportunity Spectrum (ROS) 

ROS Class Change in ROS Acres from Existing

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

Semi-Primitive Motorized 0 0 0 0 -41 0 

Roaded Modified 0 0 0 70 111 0 
Alternatives 2

Saddle Lakes Timber Sale Final EIS Alternatives - Chapter 2  41
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Chapter 3 

Affected Environment 

and Environmental 

Consequences

Saddle Lakes Timber Sale Final EIS Introduction - Chapter 3  53

Chapter 3. Affected Environment and Environmental

Consequences

Introduction____________________________________________

This chapter describes the existing natural and physical environment (referred to as the human 

environment) of the Saddle Lakes project area that may be affected by the alternatives under 

consideration (Affected Environment). These descriptions are followed by a discussion and analysis 

of the anticipated direct, indirect, and cumulative impacts of the alternatives under consideration 

(Environmental Consequences). The analysis in this EIS focuses on the significant issues that 

highlight significant effects or unintended consequences that may occur from the alternatives under 

consideration. These issues include effects to timber economics and timber availability, wildlife and 

subsistence use, and scenic integrity and recreational opportunities. Effects are quantified where 

possible, and qualitative discussions are also included. The analysis of potential impacts of the 

alternatives under consideration includes implementation of applicable Forest Plan Standards and 

Guidelines, Forest Service best management practices, and recommended mitigation described in this 

chapter and in Appendix C.

Discussions of resources and potential effects use existing information included in the Forest Plan, 

other project environmental analyses, project-specific resource reports, agency and scientific studies, 

and related information. Where applicable, such information is briefly summarized and incorporated 

by reference to minimize duplication. The project record includes all project-specific analysis 

information, including resource reports, literature cited, documentation of field investigations, and 

information resulting from public involvement efforts. 

Land Divisions _________________________________________

The land area of the Tongass National Forest has been divided in several different ways to describe 

the resources. Divisions vary by resource since the relationship of each resource to geographic 

conditions and zones varies. Land divisions important for the effects analysis are briefly described.

Land Use Designations

The Forest Plan uses land use designations (LUDs) to guide management of National Forest System 

(NFS) lands within the Tongass National Forest. The project area includes three LUDs: Timber 

Production, Modified Landscape, and Old-Growth Habitat. These are discussed in Chapter 1 of this 

EIS (see also Figure 3).

Project Area

The project area was mapped by the interdisciplinary team (IDT) to define the boundary of the area in 

which the project will occur. The project area is about 38,459 acres in size. Included in the project 

area are 3,557 acres of non-NFS lands. The non-NFS lands are owned by the Cape Fox Corporation, 

State of Alaska, Alaska Mental Health Trust Authority, and private landowners. 

Value Comparison Units 

Value comparison units (VCUs) are distinct geographic areas, each encompassing a drainage basin 

containing one or more large stream systems. Boundaries usually follow major watershed divides. 

The Saddle Lakes project area is located within VCUs 7460, 7470, and 7530 (see Figure 2).
3 Affected Environment and Environmental Consequences

54  Chapter 3 – Introduction Saddle Lakes Timber Sale Final EIS

Game Management Units 

Game management units (GMUs) are geographical areas defined by the Alaska Department of Fish 

and Game (ADF&G) to manage wildlife populations. Legal hunting and trapping regulations govern 

each unit. The Saddle Lakes project area is located in GMU 1A.

Wildlife Analysis Areas 

Wildlife analysis areas (WAAs) are land divisions used by the ADF&G for wildlife analysis. The 

Saddle Lakes project area falls within WAAs 406 and 407 (see Figure 7). 

Watersheds

A watershed refers to the area that contributes water to a drainage or stream and to the portion of a 

forest in which all surface water drains to a common point. Watersheds can range from tens-of-acres 

that drain a single, small intermittent stream, to many thousands-of-acres for a stream that drains 

hundreds of connected intermittent and perennial streams. The watersheds used for this analysis were 

delineated by the US Geological Survey according to a national hierarchy of Hydrologic Unit Codes 

(HUC). In coastal areas, the ocean is considered the common point, so some of these units drain 

unconnected streams into the ocean. See Figure 15 and Figure 16. 

Inventoried Roadless Areas

Inventoried roadless areas (IRAs) are undeveloped areas typically exceeding 5,000 acres that meet the 

minimum criteria for wilderness consideration under the Wilderness Act. Portions of the North 

Revilla (#526) and Carroll (#535) IRAs, as identified by the 2001 Roadless Rule, are found within the 

Saddle Lakes project area (see Figure 17). 

Biogeographic Province

This designation refers to 21 ecological subdivisions of Southeast Alaska identified by generally 

distinct ecological, physiogeographic, and biogeographic features. Plant and animal species 

composition, climate, and geology within each province are generally more similar within than 

among adjacent provinces. The Saddle Lakes project area is located within biogeographical 

providence #15, Revilla Island/Cleveland Peninsula. 

Ecological Subsection

Ecological subsections are mid-sized terrestrial ecosystems (10-1,000 mi2). They further refine 

biogeographical provinces based on similar ecological characteristics (e.g., landforms, streams, 

vegetation, soils, and wetlands). The Saddle Lakes project area is located within the Traitors Cove 

Metasediments Ecological Subsection (Nowacki et al. 2001).

Analyzing Effects _______________________________________

Environmental consequences are the resulting effects of implementing an alternative on the human 

environment (40 C.F.R. § 1508.14). The EIS must describe and provide the analysis of environmental 

effects of the proposed action and each alternative analyzed in detail (40 C.F.R. § 1502.16). The 

"environmental consequences" section is devoted largely to a scientific analysis of the direct and 

indirect environmental effects of the proposed action and of each of the alternatives (CEQ 1981, 

Question 7a). The terms effects and impacts are used synonymously (40 CFR §1508.8)

Assumptions for Analysis

The following general assumptions apply to all resources included in the analysis:
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Introduction - Chapter 3  55

• All uneven-aged management would remove up to 33 percent of the stand’s pre-treatment basal

area.

• The Shelter Cove LTF would be used to transport timber from the project area.

• All new and reconditioned NFS roads would be closed (except for road 8300280), and all new

temporary roads would be decommissioned at the end of silvicultural activities.

• The State of Alaska ROW on NFS land is not a connected action.

• Timber stand initiation phase occurs between 0-25 years, and stem exclusion phase occurs

between 26-150 years.

If applicable, other resource assumptions will be included at the beginning of each issue or resource 

section. If none are included, the general assumptions apply. 

How the Effects of the Alternatives Were Evaluated

Within each issue and resource area, applicable direct and indirect effects were evaluated. Cumulative 

effects, unavoidable adverse effects, and resource commitments lost or that cannot be reversed were also 

evaluated for all alternatives being considered in this EIS. These effects are defined as follows: 

• Direct effects – Those effects caused by the action and occur at the same time and in the same

general location as the action (40 CFR §1508.8).

• Indirect effects – Those effects that occur at a different time or in a different location than the

action to which the effects are related (40 CFR §1508.8).

• Cumulative effects – Those effects on the environment that result from the incremental impact of

the action when added to the other past, present, and reasonably foreseeable future actions

regardless of what agency (federal or non-federal) or person undertakes such other actions.

Cumulative impacts can result from individually minor but collectively significant actions taking

place over a period of time (40 CFR §1508.7).

• Interrelated projects are defined for the Saddle Lakes EIS as activities that could potentially

interact with the alternatives being considered in a manner that could result in cumulative

impacts. Interrelated projects have been grouped as past, present, and reasonably foreseeable

future actions. See Appendix A – Reasons for Scheduling the Environmental Analysis of the

Saddle Lake Project.

• Unavoidable adverse effects – Those effects that could occur as a result of implementing any of

the action alternatives. Some of these effects would be short-term, while others would be longterm.

• Irreversible commitments – Those commitments that cannot be reversed, except perhaps in the

extreme long term. This term applies primarily to the effects of use of nonrenewable resources,

such as minerals or cultural resources, or to factors, such as soil productivity, renewable only over

long periods of time.

• Irretrievable commitments – Those commitments (e.g., timber production) lost for a period of

time. The commitment is irretrievable rather than irreversible because future entries could harvest

those areas if they are still classified as part of the suitable timber base.

Available Information____________________________________ 

Much of the Tongass National Forest resource data resides in an electronic database formatted for a 

geographic information system (GIS). Resource specialists conducted field inventories starting in 
3 Affected Environment and Environmental Consequences

56  Chapter 3 – Introduction Saddle Lakes Timber Sale Final EIS

2008. Some field investigations are still underway and the results of some studies are still being 

incorporated. The IDT resource specialists used GIS software (ArcMap) to assist in the analyses of 

these data. GIS data is available in tabular (numerical) and map formats. For this EIS, all the maps, 

and most of the numerical analyses, are based on GIS resource data supported by field inventories. 

Incomplete and Unavailable Information

The Council on Environmental Quality regulations provide direction on how to proceed with the 

preparation of an EIS when information is incomplete or unavailable (40 CFR §1502.22). None of the 

incomplete or unavailable information identified was critical to the impact analysis. 

It should be noted that there is incomplete knowledge about many of the relationships and conditions 

of wildlife, fish, forests, climate change, jobs, and communities. The ecology, inventory, and 

management of a large forest area is a complex and developing science. The biology of fish and 

wildlife species prompts questions about population dynamics and habitat relationships; and the 

interaction of resource supply, the economy, and communities is the subject matter of an inexact 

science. However, the basic data and central relationships are sufficiently well-established in the 

respective sciences for the deciding official to make a reasoned choice between the alternatives, and 

to adequately assess and disclose the possible adverse environmental consequences.

Resources Not Present

Karst Resources

The Forest geologist and the project soils scientist reviewed the proposed action and determined that 

karst and cave resources are not present in the Saddle Lakes project area. 

Resources Likely to be Unaffected

In addition to the significant issues, several resources and resource uses in the project area are likely 

to remain unaffected by the Saddle Lakes Timber Sale, or would not be affected to a significant 

degree. Even though significant effects are not anticipated, these resources are briefly discussed in the 

sections of this chapter which follow the significant issues, to the extent that measurable effects or 

differences between the alternatives are present. These resources and resource uses include:

• Air Quality and Climate Change

• Environmental Justice

• Heritage Resources

• Lands and Minerals

Floodplains

Executive Order 11988 directs federal agencies to avoid, to the extent possible, adverse impacts 

associated with the occupancy and modification of floodplains. This project does not propose 

floodplain occupancy. Roads crossing floodplains have been designed to pass floods in accordance 

with BMP 14.17 (FSH 2509.22). Road cards provide site-specific details. 

Major floodplains are mapped as soil units: There are 820 acres of mapped floodplains in the Saddle 

Lakes project area, 95 acres of which have been previously harvested. These floodplain areas have revegetated and pose no future man-induced sedimentation risk, and with time will return to their full 
Saddle Lakes Timber Sale Final EIS Introduction - Chapter 3  57

function. About 0.6 mile of roads has been built on mapped floodplains in the past and constitutes a 

permanent loss of floodplains. 

No mapped floodplains are found within any of the proposed activity areas for any action alternative. 

Further, none of the action alternatives propose new road construction or timber harvest on 

floodplains in the analysis area. Small un-mapped floodplains may be present within RMAs and may 

be crossed by new road construction. Roads crossing these areas have been designed to pass floods 

and minimize effects in accordance with BMP 14.17 (FSH 2509.22) as depicted on road cards. 

Affected Environment and Environmental Consequences 3
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58  Chapter 3 – Issue 1 - Timber Economics Saddle Lakes Timber Sale Final EIS

Issue 1: Timber Economics

Issue Statement: An economical timber sale would help support the local and 

regional economies of Southeast Alaska.

Lack of a steady supply of economic timber can adversely affect the viability of Southeast Alaska’s 

forest products industry and the ability of the industry to contribute to the diversity and stability of 

local and regional economies. The Saddle Lakes project is one component of this supply. To compare 

the alternatives, analyses included the quantity and quality of timber offered costs of road 

construction, reconstruction and maintenance, and costs associated with logging systems and 

silvicultural prescriptions. A broader discussion about the Tongass National Forest timber program is 

in Appendix A of this EIS.

Units of Measure

The following units of measure were used to evaluate effects of the proposed action and compare 

alternatives:

• Indicated advertised rate (dollars per MBF);

• Acres by logging system (shovel, cable, helicopter);

• Volume of timber by species (net sawlog and net utility wood, in MBF and MMBF);

• Road construction/reconstruction costs and LTF costs (dollars per MBF);

• Logging costs (dollars per net MBF removed, without utility);

• Total Production Costs (stump-to-mill, roads, and manufacturing costs in millions of dollars), and

production costs per MBF per net removed; and

• Employment supported by the project (number of annualized jobs).

Methodology

Financial efficiency analysis is required by USDA FS Handbook, R10, Supplement 2409.18-2013-1. 

The financial analysis spreadsheet tool – RV (FASTR), October 21, 2013 version, was used to process 

and analyze data for comparison of costs and benefits associated directly with implementation of the 

Saddle Lakes project.

The FASTR model uses logging costs and manufacturing costs developed for the Alaska Region 

(R10) timber sale appraisal program. Costs reflect production studies and data collected from timber 

harvest contract purchasers in Southeast Alaska. Timber volume estimates by species were developed 

for each harvest unit based on a combination of site-specific common stand exam data collected from 

plots throughout the project area, including proposed units, during 2011 to 2013. The FASTR model 

was used to provide an indication of sawlog and utility volume by species (net MBF). Net volumes by 

alternative were calculated using FASTR. 

Direct logging and sawmill employment and income are generated by FASTR, and are estimates only 

of direct income and employment that would be supported from activities for any timber harvested 

from the Saddle Lakes project. Therefore, financial efficiency analyses should be considered solely as 

a tool for comparing the alternatives. Indirect benefits are not estimated due to the small scale of the 

project and the size of the affected communities. Because of direct, indirect, induced, and multiplier 

Resources by Significant Issue ______________________________ 
Saddle Lakes Timber Sale Final EIS Issue 1 – Timber Economics - Chapter 3  59

effects, total economic impacts of the action alternatives are expected to be greater than shown in this 

analysis. 

FASTR outputs are intended for initial planning purposes, and provide a useful gauge of current 

economic conditions for a timber sale. The FASTR model was used to provide an indication of the 

indicated advertised rate, sawlog and utility volume by species, road construction/reconstruction and 

LTF costs, logging costs, total selling value (lumber and export log sales) and total production costs. 

These data are useful as units of measure to compare relative differences between alternatives and 

may not reflect absolute values. Merchantable timber from harvest units, and road right-of-way 

timber located on NFS lands would be cruised to determine its quantity, quality and value for the 

contract. The final contract appraisal will include selling values, cost information, and a profit and 

risk allowance posted from the most recent quarterly update bulletin to determine the advertised value 

at the time of offering. 

Analysis Area

The NFS lands in the Saddle Lakes project area are considered the analysis area for the financial 

efficiency analysis since that is where the value of the timber considered in the analysis is located.

Although timber from other land ownerships within the area may influence the value of the timber to 

some purchasers, this is not incorporated into this analysis. Also, timber from this project may be split

into several contracts or combined with timber from other projects.

Also, this analysis is limited to a snapshot in time based on available information and does not 

speculate on timber market fluctuations. At the time of the appraisal, the value of the timber or costs 

may increase or decrease.

The cumulative effects analysis area considers the whole Tongass National Forest, which combines 

the timber from various projects into the Tongass timber program. Contracts are usually not restricted 

to bidders from a distinct geographic area and can include bidders outside of Southeast Alaska, 

including bidders from the rest of the United States. In addition to the timber managed by the Forest 

Service, the State of Alaska (Division of Forestry (DOF), Alaska Mental Health Trust Authority

(AMHT), and the University of Alaska), and Alaska Native Corporations also support the Southeast 

Alaska timber industry. 

Affected Environment

Various factors affect timber sale economics including species composition and quality, timber 

volume, silvicultural system, logging systems, road construction, and hauling and towing distances. 

The ability to export timber that is surplus to Alaskan needs or is not suitable to current Alaska 

manufacturing facilities also can increase the value of the timber.

Forest Products Industry in Southeast Alaska

The forest products industry has been a part of the economy of Southeast Alaska since settlement, 

with sharp growth in the 1950s due to the start of pulp mills. Employment in the forest products 

industry began to decline with the termination of the long-term sale contracts in 1994 and 1997, with 

subsequent closure of the Ketchikan Pulp Company mill in 1997. The forest products industry in 

Southeast Alaska currently consists of individual- and family-owned sawmills and independent 

logging businesses. 

The two currently operating medium-sized mills in Southeast Alaska are Viking Lumber Company 

located in Klawock and Icy Straits Lumber Company located in Hoonah. Viking Lumber Company 

currently has timber under contract with the Tongass National Forest on Kupreanof Island and Prince 

Affected Environment and Environmental Consequences 3
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60  Chapter 3 – Issue 1 - Timber Economics Saddle Lakes Timber Sale Final EIS

of Wales Island. The timber under contract by the Icy Straits Lumber Company is on Chichagof 

Island. Alcan Forest Products, LLC (ALCAN), based in Ketchikan purchases timber contracts on the 

Tongass National Forest but does not have a processing facility. Timber purchased by ALCAN is 

either sold for domestic processing or sold exported under current Alaska Regional policy. 

Other small mills are located throughout Southeast Alaska. The mills closest to the project area 

include Tongass Forest Enterprises in Ketchikan, and operators on Prince of Wales Island in the towns 

of Thorne Bay, Craig, Klawock, Coffman Cove, and Edna Bay. As of May 2014, there were about 43 

different operators with timber under contract. 

Currently, the timber industry in Southeast Alaska is based predominantly on the harvest and 

processing of old-growth timber. The transition to the harvest of young-growth timber is underway 

and largely depends on when the young-growth timber is large enough to produce an economic 

product and when there is enough interest by the current industry. Manufacturing young-growth 

timber would involve refitting most of the mills in Southeast Alaska.

Employment

Based on forest products employment data for the period 2002 through 2011 total timber industry 

employment in Southeast Alaska dropped from 512 jobs to 262 jobs (Table 4).

Table 4. Forest products industry employment in Southeast Alaska, 2002 through 2011

Year Tongass 

Logging1/ Tongass 

Sawmill1/

Total 

TongassRelated 

Employment

Other 

Sawmill

Other 

Logging

Total Other 

Timber 

Employment

Total 

Industry 

Employment

2002 63 110 173 40 299 339 512

2003 108 91 199 64 298 362 561

2004 82 95 177 53 220 273 450

2005 88 96 184 52 263 315 499

2006 81 77 158 46 217 263 421

2007 44 70 114 63 225 288 402

2008 52 70 122 24 118 142 265

2009 48 39 87 19 110 129 216

2010 61 46 107 7 133 140 247

2011 62 47 109 3 150 153 262

Source: Alaska Department of Labor, Kilborn et al. (2004), Brackley et al. (2006b), Brackley and Crone (2009), Alexander and 

Parrent (2010), Alexander (2011), Alexander (2012), Alexander and Parrent (2012), and Parrent (2012). Data on file with: 

Regional Economist, Ecosystems Planning, USDA Forest Service, PO Box 21628, Juneau, AK 99802-1628

1/ Estimated based on the ratio of Tongass timber harvest to total timber harvest in Southeast Alaska.

Alaska Region Limited Export Shipment Policy and Domestic Processing

Market demand for softwood logs and lumber is highly variable. For instance, the U.S. economic 

downturn that began in 2007 and the concurrent decline in the U.S. housing market resulted in 

dramatically reduced demand for U.S. logs and lumber. Similarly, China’s economic growth slowed 

in 2011, resulting in reduced demand for U.S. log exports (Flynn, 2012). The 2008 Forest Plan 

Amendment FEIS, Volume II, Appendix G, describes the latest timber demand procedures and 
Saddle Lakes Timber Sale Final EIS Issue 1 – Timber Economics - Chapter 3  61

projections (USDA Forest Service 2008c). The estimated market demand is calculated annually as 

discussed in Appendix A of this document. 

Between 2007 and 2013, the range of export was from 15.6 to 50.6 percent of Tongass National 

Forest timber harvests shipped as logs to foreign and domestic markets. These exports contribute 

substantially to the economic stability of Alaskan timber exporters (Flynn 2012). This shows in 

increased log exports from Tongass National Forest timber contracts from 2008 to 2012, due to 

foreign export prices that have been high enough to allow greater profits from log exports than from 

log processing in Alaska mills (Roos et. al. 2010; Alexander and Parrent 2012). In 2013, export was 

21.9 percent indicating better domestic prices, although no trend can be determined yet. 

In March 2007, the Alaska Regional Forester approved the limited interstate shipment policy, which 

allowed certain unprocessed spruce and hemlock logs to be appraised for shipment to domestic 

markets (the Lower 48 states). This hemlock-spruce export authorization was designed to offset the 

extended decline in U.S. housing construction coupled with a decline in lumber orders and selling 

values. In 2008, this policy was expanded to allow foreign export for existing contracts if a premium 

was paid for certain species. The policy was expanded in November 2009 for all contracts. In 2009, a 

foreign market appraisal was established for use on timber sales to reflect export values for spruce 

and hemlock (USDA Forest Service 2011a). The 2009 limited export policy is still in effect and 

allows hemlock and spruce export equal to 50 percent of total sale sawlog volume plus 100 percent 

export of Alaska yellow-cedar. Alaska yellow-cedar is considered surplus to the Alaskan market and 

can be requested for 100 percent export. Exceptions can be made for export when no local mill exists 

for the type of timber in a contract.

Timber volume is not pre-authorized for export. If a purchaser desires to ship timber to domestic 

destinations outside the State of Alaska or export timber overseas, they are required to apply for a 

permit from the Regional Forester after the contract is awarded. 

The Alaska Region (R10) monitors the need for export annually. This policy allows timber contracts 

with a higher proportion of lower grade hemlock and spruce to have a greater chance of appraising 

positive, while also allowing local timber purchasers and manufacturers options to stay in business 

and be poised to commence operations when market conditions improve. 

Silvicultural Systems

The choice of silvicultural system affects the financial return from a timber sale. Implementation of 

uneven-aged management has higher logging costs and affects larger areas than would be needed for 

the same harvest volume under an even-aged system (USDA Forest Service 2008c). Intensive 

silvicultural systems that employ even-aged prescriptions lead to the production of high quality 

timber in the shortest timeframe and increase total forest yields over time (Stocker 2003). Unevenaged systems are used when most economically practical, such as where high-cost helicopter yarding 

is utilized due to higher cost road construction and haul, or where resource specific mitigations are 

required. Refer to the Silviculture section for more information on prescriptions.

Logging Systems 

Cable and shovel yarding are considered conventional methods, and are about half the cost of 

helicopter yarding. Conventional methods require road access and are most economically efficient for 

even-aged silvicultural systems. Uneven-aged silvicultural systems require additional time to move 

equipment and cables which add operational costs. Shovel yarding is the least costly logging system

and is best suited for gentle terrain and yarding distances less than about 500 feet. Cable yarding is 

best suited for steeper slopes and allows longer yarding distances. Some areas cannot be accessed 

Affected Environment and Environmental Consequences 3
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62  Chapter 3 – Issue 1 - Timber Economics Saddle Lakes Timber Sale Final EIS

cost-effectively by conventional methods due to expensive road construction or because of inadequate 

log suspension required for resource protection. In these areas, helicopter yarding is used. All 

methods require a landing area where logs are loaded on trucks. In addition, helicopters require 

service landings for maintenance and fueling.

Roads, Rock Quarries, Log Transfer and Export Facilities

Road construction and reconditioning involve substantial costs and strongly affect timber sale 

economics. Transportation costs, including towing or barging of logs, are a large percentage of a 

timber purchaser’s costs in Southeast Alaska. By using the most cost-effective transportation system 

while maintaining the appropriate design standards to meet resource requirements, these costs can be 

reduced. There are about 53 miles of existing National Forest System (NFS) roads and about 33 rock 

quarries in the project area. Refer to the Transportation Resource Report for more information on 

roads, rock quarries, LTFs and sort yards. 

The Shelter Cove marine access facility (MAF) consists of a seaplane and boat float, a barge loading

and unloading ramp, a sort yard, and a log transfer facility (LTF). The LTF is a single level, native log 

bulkhead with about a 1-acre sort yard attached to it within an existing rock pit. Storms in 2013 

damaged the Shelter Cove LTF, and the lower logs of the bulkhead have deteriorated enough to 

require the reconstruction of the bulkhead, or the replacement of the bulkhead with a ramp. 

A site located at Coon Cove about 3 miles southwest of the project area on State of Alaska lands was 

historically used as a LTF for timber sales in the vicinity (see Figure 1). However, the bulkhead has 

been removed, and this site has largely been restored to its original contours. To use this site as a LTF, 

the timber purchaser would have to make a substantial investment in reconstruction, and would have 

to obtain an Army Corps 404 permit, a tideland easement, solid waste permits, water permits, and 

perform a bark dive survey. Therefore, this site was not included in this project analysis.

Two nearby export facilities, Ward Cove and Leask Cove, have been both approved by the Alaska 

Regional Forester FSH 2409.15-2009-1). These facilities can be used to load logs on barges for out of 

state shipment. Logs from the Saddles Lakes Timber Sale project could be transferred to barges at 

these points if not taken directly to an Alaskan mill.

Completion of the proposed State of Alaska road (Ketchikan to Shelter Cove) would provide a 

connection to an existing road that accesses the Leask Cove sort yard and LTF. Because it is uncertain 

whether the connection of this road would be completed, only the Shelter Cove LTF was considered 

for the transport of logs in this analysis.

Forest Service Costs

The Forest Service incurs environmental analysis and documentation costs including field inventory, 

data analysis, public involvement, and preparation of documents that satisfy the requirements of 

NEPA. This cost is considered to be a ‘sunk’ cost that applies equally to all alternatives, including the 

No-action Alternative and does not provide any comparison of the alternatives. Sale preparation costs 

include unit layout, cruising, appraisal, and contract development. Sale administration consists of 

administering the timber sale contract from the time the sale is awarded until the sale is completed. 

Engineering support consists of planning and timber sale contract administration activities associated 

with new facility and road construction, use of existing facilities and road maintenance. 

Environmental Consequences

Direct effects for timber sale economics are estimated using quantifiable measures or indicators, as 

supported by the FASTR financial analysis tool (run January 8, 2014). These outputs show a relative 
Saddle Lakes Timber Sale Final EIS Issue 1 – Timber Economics - Chapter 3  63

comparison for alternatives and are intended solely as a tool for initial planning purposes. The 

alternative with the highest indicated advertised rate generates the highest return on investment, and 

represents the alternative with the least economic risk. However, as production costs and selling 

values fluctuate, so does the indicated advertised rate.

No analysis was done to break out the most valuable timber units or divide the timber volume from an 

alternative into several sales since the combinations would be numerous and may change to meet 

markets and operators. The production costs (used throughout the following comparisons) are total 

production costs for an action alternative, divided by total sawlog volume (cost per NMBF sawlog, 

based on FASTR analyses). Production costs in the direct effects are the sum of logging and 

transportation costs, road costs, and manufacturing costs under the current R10 limited export policy. 

Effects Common to All Action Alternatives

Positive Appraisals

Under current Congressional direction (Public Law 113, House Report 3547, Section 410) no timber 

sale in the Alaska Region with a volume greater than 500 MBF shall be advertised if the indicated 

advertised rate is deficit when using a residual value appraisal. Sales with volumes under 500 MBF 

currently do not require a residual value appraisal and can be advertised using established standard 

rates.

Shelter Cove LTF Reconstruction

All action alternatives estimated haul costs to the Shelter Cove LTF. Reconstruction of the Shelter 

Cove LTF bulkhead to repair storm damage is estimated at $60,000. This estimate does not change 

between alternatives and represents a fixed cost that would be distributed over the proposed volume 

of each alternative. Higher timber volumes would therefore help distribute this cost on a per-MBF 

basis. LTF reconstruction cost, combined with road construction and reconstruction costs, is shown by 

alternative in Table 5. 

Opportunities for Small Sales

Due to the project area’s geographic location, it may be economically feasible for several small mills 

on Revillagigedo and Prince of Wales Islands to purchase small sales from the project area or to 

utilize surplus material made available from a larger mill or purchaser in their vicinity. There are 

several small mills in Thorne Bay that process volumes ranging from 30 MBF to 600 MBF yearly

(Alexander and Parrent 2012). However, costs of rafting or barging to these small mills could be 

prohibitively high, because their fixed costs are distributed over a smaller volume of timber. 

For the purposes of this analysis, a small sale is considered to be approximately 1 MMBF or less. 

Timber volume in any of the action alternatives could be administratively separated into both large 

and small sales. Each action alternative includes some harvest units that could be logged by cable or 

ground-based systems. However, an alternative could not be subdivided into only small sales since 

the cost of road construction to some units could not be supported or the higher cost of helicopter 

logging. 

Utility Volume

Tongass National Forest timber sale contracts typically include a provision specifying that the 

purchaser has the option of not removing utility logs from harvest units. Utility material does not 

meet minimum requirements for saw timber (net log scale is 50 percent or less of gross scale) and is 

primarily suitable for low-value chips. Utility logs are uneconomical because revenues do not cover 

Affected Environment and Environmental Consequences 3
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64  Chapter 3 – Issue 1 - Timber Economics Saddle Lakes Timber Sale Final EIS

the costs of felling, yarding and transport. Therefore, use of sawlog volume (gross volume minus 

utility volume) is a more meaningful metric for assessing the value of a timber sale.

Direct and Indirect Effects

Timber Sale Financial Efficiency Analysis

Comparisons of the alternatives were analyzed two ways to consider both the Alaska Region (R10) 

limited export policy and 100 percent domestic processing. Assumptions used for export policy 

scenario were:

1. Maximum allowed export of hemlock and spruce;

2. All western redcedar would be domestically processed; and

3. All Alaska yellow-cedar would be exported.

Assumptions used for the domestically processing scenario were:

1. All hemlock, spruce and western redcedar would be domestically processed; and

2. All Alaska yellow-cedar would be exported.

Alaska yellow-cedar would be 100 percent exported under both scenarios since yellow-cedar has 

been determined by the Secretary of Agriculture to be surplus to the domestic processing under 36 

CFR 223.200.

Table 5 shows a summary of the units of measure under the current R10 limited export policy. A mix 

of foreign and Alaska markets were used for the financial analysis for each alternative. The 

percentage of western hemlock appraised to foreign markets was determined by achieving the 

maximum percentage of foreign export volume allowed for each alternative under the current export 

policy. This percentage ranged from 2 to 3 percent appraised to Alaska markets depending on 

alternative, with the remainder being appraised to foreign markets.

The domestic processing scenario in Table 5 summarizes total selling value, total production costs, 

and indicated advertised rates for each alternative. Under this scenario, timber volumes and logging 

costs are the same as under the current R10 limited export policy by alternative. Differences in 

logging costs per MBF between alternatives are associated with those alternatives that have a greater 

percentage of helicopter yarding systems and uneven-aged management, due to higher logging costs 

incurred through utilizing these systems. Differences in road costs between alternatives are due to 

either more road construction or reconstruction or less timber volume to offset the miles of road.

Total selling values, total production costs, and production costs per MBF increase under the 

domestic processing scenario. These across-the-board increases in production costs are due to higher 

local manufacturing costs and increased tow costs. The estimated one-way tow distance to Viking 

Mill in Klawock from the Shelter Cove LTF is about 230 miles. This is the closest sawmill capable of 

processing the entire volume of timber from an alternative. The tow distance to the Leask Cove 

export location is about 33 miles from the Shelter Cove LTF. The increase in selling values is not 

great enough to offset the production costs due to the value of the manufactured products. These 

factors make the indicated advertised rates more deficit under a domestic processing scenario for all 

action alternatives.

Without the option of allowable export, or a substantial change in market conditions, prospective 

timber sale purchasers will not likely have an economic incentive to bid on a timber contract because 
Saddle Lakes Timber Sale Final EIS Issue 1 – Timber Economics - Chapter 3  65

of increased risk and decreased profit, or the contract may not even be offerable. If a timber sale does 

not sell, then no timber industry jobs would be supported.

For the comparison of the alternatives, the values from the FASTR analysis completed used the 

maximum export policy as assumptions. The relative ranking of the alternatives for the domestic 

processing scenario are the same as for the export policy scenario. The volume exported is

determined by the purchasers at the time of harvest and could fall within the range between the two 

analyses.

Table 5. Timber financial efficiency analysis for the Saddle Lakes Project Area

Value 

Alternative 

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

Both Export Policy and Domestic Processing Scenarios

Logging Costs 

(cost /MBF net 

Removed)

$0 $273 $246 $252 $262 $241

Road Construction

/Reconditioning 

and LTF Costs 

(cost /NMBF 

Sawlog)

$0 $81 $105 $91 $84 $95

Export Policy Scenario

Total Selling Value 

(lumber and 

export log sales)

$0 $20,650,902 $11,623,143 $34,697,843 $41,282,699 $27,597,404

Total Production 

Costs 1/ $0 $17,739,198 $9,953,014 $29,256,903 $34,953,627 $23,065,930

Production (costs 

/MBF net 

removed)

$0 $653 $652 $641 $643 $635

Indicated 

Advertised Rate 

(cost /MBF)2/

$0 -$14.05 -$12.08 -$2.00 -$4.66 $3.62

Domestic Processing Scenario

Total Selling Value 

(lumber and 

export log sales)

$0 $21,473,648 $12,074,204 $36,101,687 $42,952,961 $28,713,971

Total Production 

Costs1/ $0 $19,870,891 $11,689,070 $34,522,468 $41,223,979 $27,260,063

Production (costs/ 

MBF net removed) $0 $732 $765 $756 $759 $751

Indicated 

Advertised Rate 

(cost /MBF)2/

$0 -$70.73 -$104.52 -$95.15 -$97.91 -$89.71

Source: FASTR financial analysis tool, October 21, 2013 version. 

Notes: All volumes are in net thousand board feet (NMBF)

1/ Total production costs are logging and transportation costs (stump to mill), roads costs, and manufacturing costs.

2/ - indicates a negative value.

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66  Chapter 3 – Issue 1 - Timber Economics Saddle Lakes Timber Sale Final EIS

Projected Employment and Income

Direct employment and income from logging, sawmilling, transportation and other services are 

estimated by converting net sawlog timber volume (MMBF net sawlog) to Southeast Alaska 

annualized jobs and income (employment coefficients for the period 2007 to 2010, Alexander 2012). 

An annualized job is one job for one year (Alexander, et. al, 2010). Since some of these jobs are 

seasonal or intermittent, this may not equate to the number of full-time jobs. 

Table 6. Estimated project employment and income utilizing R10 export policy1/

Employment Measure

Alternative 

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

Local annualized jobs in 

logging 0 61 35 103 123 82

Local annualized jobs in 

sawmilling 0 27 15 45 53 36

Local annualized jobs in 

transportation and other 

services2/

0 32 18 55 65 43

Total Local Annualized 

Jobs Supported3/ 0 121 68 203 241 161

Direct Income $0 $6,434,354 $3,621,309 $10,815,264 $12,867,753 $8,602,068

Source: FASTR financial analysis tool, October 21, 2013 version. 

1/ Assumes 100 percent Alaska yellow-cedar export plus hemlock /spruce export equal to 50 percent total sale net sawlog 

volume. 

2/ Transportation and other services include towing, independent trucking, stevedoring, scaling, quality control, and marketing.

3/ Totals may not add due to rounding generated by the FASTR financial analysis tool

Based on data from the USDA Forest Service Alaska Region Economist (Alexander, 2013), Tongass 

National Forest harvests considering the export policy support an average of the following regional 

annualized jobs: 2.26 logging jobs per MMBF net sawlog volume, 2.68 sawmilling jobs per MMBF, 

and 1.53 jobs per MMBF in transportation and other services. Using the domestic processing scenario 

described above, regional annualized jobs supported include: 2.26 logging jobs per MMBF, and 2.68 

sawmilling jobs per MMBF, and 0.62 jobs per MMBF in transportation and other services. The higher 

number of jobs per MMBF in supported in the transportation sector for the export scenario is due to 

those jobs, such as stevedoring and other out-of-state barging. However, because timber sales with

allowable export would supply a lower volume of logs to local sawmills, the number of 

manufacturing jobs in Southeast Alaska would be less.

Table 6 shows projected Alaskan employment and income from logging, sawmilling, transportation 

and other services utilizing current R10 Export Policy. Table 7 provides the same analysis assuming 

current R10 Export policy is not utilized. 
Saddle Lakes Timber Sale Final EIS Issue 1 – Timber Economics - Chapter 3  67

Table 7. Estimated project employment and income utilizing domestic processing1/

Employment Measure

Alternative 

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

Local annualized jobs in 

logging 0 61 35 103 123 82

Local annualized jobs in 

sawmilling 0 63 36 106 127 85

Local annualized jobs in 

transportation and other 

services2/

0 20 11 34 40 27

Total Local Annualized 

Jobs Supported3/ 0 145 81 243 290 194

Direct Income $0 $6,898,406 $3,878,806 $11,597,568 $13,798,655 $9,224,316

Source: FASTR financial analysis tool, October 21, 2013 version. 

1/ Assumes 100 percent Alaska domestic processing of hemlock /spruce /western redcedar and 100 percent export of Alaska 

yellow-cedar. 

2/ Transportation and other services include towing, independent trucking, stevedoring, scaling, quality control, and marketing.

3/ Totals may not add due to rounding generated by the FASTR financial analysis tool

Timber Volume

Differences in timber harvest economics can be attributed to multiple factors, including: 

• timber volume/species composition;

• silvicultural prescriptions;

• logging systems;

• miles of road construction;

• haul and tow distances to the final mill destination.

Table 8. Timber volume estimates from the Saddle Lakes Project area by species and alternative

Species Volume (NMBF)

1/

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

Sitka Spruce Sawlog Volume 0 3,906 2,197 6,568 7,814 5,224

Western Hemlock Sawlog Volume 0 13,911 7,822 23,388 27,826 18,602

Western Red cedar Sawlog Volume 0 5,817 3,271 9,779 11,635 7,778

Alaska Yellow Cedar Sawlog Volume 0 3,527 1,983 5,929 7,055 4,716

Total Sawlog Volume 0 27,161 15,272 45,664 54,330 36,319

Total Utility Volume 0 3,173 1,784 5,334 6,352 4,243

Total Volume (Sawlog and Utility) 0 30,334 17,056 50,998 60,682 40,562

Volume (MMBF)2/

Total Volume (Sawlog and Utility) 0 30.3 17.1 51.0 60.7 40.6

Source: FASTR financial analysis tool, October 21, 2013 version.

1/ Net Thousand Board Feet (NMBF). Data may not add up exactly due to rounding and may be reported differently by other 

resources.

2/ Million Board Feet (MMBF). 

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68  Chapter 3 – Issue 1 - Timber Economics Saddle Lakes Timber Sale Final EIS

Western hemlock accounts from 46 to 51 percent of the total volume under the action alternatives, 

with western redcedar ranging from 19 percent to 21 percent, Sitka spruce from 13 to 14 percent, and 

Alaska yellow-cedar from 12 to 13 percent. Pacific silver fir, red alder, and shore pine comprise about 

1 percent of the total gross volume. Timber volume estimates are reported in Table 8. 

Silvicultural Systems

All action alternatives propose both even-aged and uneven-aged management. Proposed use of 

uneven-aged systems should be diligently planned, as they involve higher costs and there is a risk of 

degradation of the potential future value of a stand by applying these systems. Refer to the 

Silviculture Resource Report for information on prescriptions. 

Individual harvest units may not always be economical to harvest by themselves, but managing stands 

containing defective, lower-value timber results in increased future timber yields. This is due to 

silvicultural practices that result in managed stands with subsequently higher growth rates and 

increased volume productivity. Harvesting higher-value units within the same timber sale results in a 

greater financial return, and can compensate for costs associated with harvesting lower-value harvest 

units. Table 9 lists the proposed harvest acres by logging system by alternative.

Table 9. Acres of treatments by silvicultural system, prescription, logging system and alternative for the 

Saddle Lakes Timber Sale

Silvicultural 

System

Silvicultural 

Prescription

Logging 

system

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

Even-aged 

Management

Clearcut Cable 0 612 524 1,384 1,573 1,116

Shovel 0 443 292 538 578 538

Helicopter 0 0 0 190 443 0 

Even-aged Total 0 1,055 816 2,112 2,594 1,654

Uneven-aged 

Management

Single-tree Selection 

(up to 33 percent

removal of the basal 

area)

Cable 0 0 0 5 5 5 

Shovel 0 52 0 0 0 0 

Helicopter 0 1,100 196 307 276 479

Uneven-aged 

Total

0 1,152 196 312 281 484

Total Acreage 0 2,207 1,012 2,424 2,875 2,138

Source: FASTR financial analysis tool, October 21, 2013 version. 

Logging systems 

All action alternatives propose use of ground-based (conventional) cable and shovel logging systems, 

and helicopter yarding. Conventional methods require road access, are substantially less expensive 

than helicopter yarding, and are most economically efficient for even-aged silvicultural systems. For 

conventional logging systems, the estimated average felling, bucking, and yarding costs are $224.70 

per MBF net removed (without removal of utility wood), across all action alternatives. 
Saddle Lakes Timber Sale Final EIS Issue 1 – Timber Economics - Chapter 3  69

Analysis for this project indicate that costs of using helicopter yarding are projected to exceed costs 

of conventional logging systems by an average of about 78 percent on a per MBF basis for all action 

alternatives, even when accounting for additional road-building costs associated with conventional 

logging. For helicopter logging systems, the estimated average felling, bucking, and yarding costs 

from FASTR are $399.09 per net MBF (with optional removal of utility wood), across all alternatives. 

Table 9 displays acres by Silvicultural System, Prescription, and Logging system for each action 

alternative.

Landings

Optimum landing design represents a balance between a minimum size that will allow for safe 

operation of all equipment with additional space for handling and storage of logs, while minimizing 

construction costs and potential environmental impacts. Landings are located, designed, and 

constructed to minimize soil erosion and water quality degradation (Region 10 BMP 13.10; FSH 

2509.22). During implementation of the Saddle Lakes timber contracts, landing size, location, and 

construction specifications must be agreed upon by Forest Service timber sale administrator and the 

timber purchaser.

Typical yarder landings vary in size from a wide spot in the road for small mobile yarders, to about 

0.2 acre for a large (90-foot) tower yarder and are usually adjacent to a cable unit. In general, yarder 

landings for the Saddle Lakes project need to accommodate a medium (50 to 70-foot) tower yarder, 

and would likely be less than 0.1 acre in size. In shovel yarding harvest units, it is likely that those 

roads which access the harvest units would be used as continuous landings, thereby eliminating 

additional landing construction costs. 

Two types of landings are associated with helicopter logging: log landings and service landings. Log 

landings are used for laying down turns of logs, processing and storing logs, and loading log trucks. A 

minimum of a 100-foot by 200-foot roadside landing provides a drop zone, a safety zone, and a 

decking area. These landings are not within the unit, but located on a nearby road system. Service 

landings provide a safe landing zone for the helicopter, in addition to trailers, a pad, a fuel truck, and 

a lift truck to fuel and perform minor maintenance. Dimensions of service landings vary from one to 

two acres and it is estimated that no more than three service landings would be required for the 

project for any alternative.

Helicopter turn time is the time it takes a helicopter to go from the landing, pick up a load of logs and 

return to the landing and deliver the logs. The shortest helicopter turn times are the most economical 

and therefore the location of these landings is determined during contract administration. 

Table 10 shows estimated numbers of landings by action alternative and yarding method potentially 

necessary to facilitate yarding. Some landings may be used for multiple units, which would minimize 

construction costs and potential environmental impacts, and improve economic feasibility. Therefore 

actual numbers of landings by action alternative may be fewer than shown in Table 10. 

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70  Chapter 3 – Issue 1 - Timber Economics Saddle Lakes Timber Sale Final EIS

Table 10. Estimated numbers of landings by action alternative and yarding method necessary to facilitate 

yarding 

Landing Type Number of Landings by Alternative

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

Shovel 0 32 24 35 41 35

Cable Yarder 0 77 55 136 169 118

Helicopter Log 

Landing 0 21 12 14 19 16

Source: Tongass National Forest GIS.

Roads

Road construction and reconditioning involve substantial costs, and strongly affect timber sale 

economics. Table 5 shows the road construction and reconstruction cost by MBF while Table 11

shows proposed miles of road and overall cost. By using the most cost-effective transportation system 

while maintaining the appropriate design standards to meet resource requirements, these costs can be 

reduced. 

Road costs used in the timber economic analysis are based on road cost calculations provided in 

Appendix B of the Transportation Resource Report. Proposed road construction was designated as 

either NFS or temporary based on future access needs. Construction of proposed roads (NFS and 

temporary) would provide access for yarding and landing logs, and provide transportation routes 

connected to the existing road infrastructure. Shelter Cove LTF was used to determine haul distances 

(and therefore estimated costs) for the Saddle Lakes project. Refer to the Transportation Resource 

Report for more information on roads, rock quarries, LTFs and sort yards.

Table 11. Proposed Road construction and reconditioning costs by alternative

Road Construction / 

Reconditioning

Alternative 

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

Proposed NFS 

Road

Miles 0 10.2 6.7 19.6 20.6 16.3

Cost $0 $1,406,147 $899,541 $2,841,422 $2,999,501 $2,340,626

Proposed 

Temporary Road 

Miles 0 5.6 5.0 9.8 11.7 8.2 

Cost $0 $658,343 $579,980 $1,151,814 $1,391,860 $969,671

Road 

Reconditioning1/

(maintenance of 

closed roads)

Miles 0 10.8 7.7 10.8 11.1 10.8

Cost $0 $86,400 $61,600 $86,400 $88,800 $86,400

Total

Miles 0 15.8 11.7 29.4 32.3 24.5

Cost $0 $2,150,890 $1,541,121 $4,079,636 $4,480,161 $3,396,697

Source: Road Cost Calculations provided in Appendix B of the draft Transportation Resource Report (Powell 2013).

1/ Road reconditioning is considered road maintenance of an existing road and therefore is not included in the total miles of 

road construction.

In some years, public works funds are available to pay for all or portions of NFS road construction or 

reconstruction costs for roads used in long-term administration of the Tongass National Forest. 

Although availability of this funding would greatly improve the economic feasibility of the project, it 

was not analyzed because of the uncertainty of the amount and availability.
Saddle Lakes Timber Sale Final EIS Issue 1 – Timber Economics - Chapter 3  71

Tow Costs

Transportation of logs accounts for a large percentage of costs a purchaser incurs during the life of a 

timber sale in Southeast Alaska, and tow costs represent the largest percentage of transportation costs 

on the Saddle Lakes project. Tow costs were assessed for two scenarios: 1) towing 100 percent of 

timber volume to the Viking Mill in Klawock from the Shelter Cove log transfer facility (LTF) for 

domestic processing; and 2) towing all allowable export volume to the export facility at Leask Cove, 

while towing only the domestically processed volume to Klawock. The estimated one-way tow 

distance to Klawock from the Shelter Cove LTF is about 230 miles. The one-way distance to Leask 

Cove is about 33 miles. The average estimated tow cost for all action alternatives is $104 per MBF 

(net sawlog) towing all volume to Klawock. When the export facility at Leask Cove is used, the 

average drops to $72 per MBF (Net Sawlog, data from FASTR financial analysis tool, run January 8, 

2014). Substantially higher production costs are associated with maximizing domestic processing, due 

primarily to increased tow costs to Klawock.

Forest Service Costs

The Forest Service administrative costs were estimated for the Saddle Lakes project. Total 

administrative costs are about $104 per MBF, broken down as follows: $48 per MBF for 

environmental analysis and documentation (NEPA planning), $21 per MBF for sale preparation, $12 

per MBF for sale administration and $23 per MBF for engineering support (Vermillion 2013). The 

numbers presented in Table 12 compare relative differences between alternatives.

Table 12. Estimated Forest Service costs and Revenues by alternative 

Forest 

Service 

Costs

Alternative

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

Sale 

Preparation

$0 $564,411 $317,357 $948,893 $1,128,971 $754,715

Sale 

Administration

$0 $330,824 $186,016 $556,185 $661,736 $442,369

Engineering 

Support

$0 $615,746 $346,322 $1,035,198 $1,231,655 $823,359

Total Forest 

Service Costs $0 $1,510,981 $849,695 $2,540,276 $3,022,362 $2,020,443 

Alaska Region limited export policy

Total 

Indicated 

Advertised 

Value

$0 - $381,698 - $184,525 - $91,186 - $511,548 $131,421

Net Value 1/ $0 -$1,892,679 -$1,034,220 -$2,631,462 -$3,533,910 -$1,889,022

Domestic Processing 

Total 

Indicated 

Advertised 

Value

$0 - $1,921,079 - $1,596,249 - $4,345,086 - $5,319,610 - $3,258,069

Net value1/ $0 -$3,432,060 -$2,445,944 -$6,885,362 -$8,341,972 -$5,278,512

Source: FASTR financial analysis tool, October 21, 2013 version.

1/ Total Indicated Advertised Value minus Total Forest Service Costs

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72  Chapter 3 – Issue 1 - Timber Economics Saddle Lakes Timber Sale Final EIS

The above financial efficiency analysis is a tool decision-makers can use to gain information about 

trade-offs between costs and benefits for each alternative that can be quantified in terms of actual 

dollars spent or received in the project area. This type of analysis does not account for non-market 

benefits, opportunity costs, individual or other values that are not easily quantifiable. 

Alternative 1

Under Alternative 1, no timber management or road construction would occur in the project area on 

NFS lands. There would be no additional contribution to the local and regional economies of 

Southeast Alaska, and there would be no additional support to the local or regional forest products 

industry employment from the project area from NFS lands. Local employment would not be 

affected. 

Alternative 2

Compared to the other action alternatives, Alternative 2 has the highest production costs per unit 

volume, about $653 per MBF sawlog volume. This is due primarily to a higher percentage of the 

volume proposed for harvest using helicopter systems and uneven-aged management. Summary of 

direct and indirect effects under current R10 Export Policy includes: 

• Timber harvest on about 2,207 acres, and provides about 27 MMBF sawlog volume. Alternative 2

has more harvest volume than proposed under Alternative 3, and less harvest volume than

proposed under Alternatives 4, 5, and 6.

• Shovel, cable, and helicopter logging systems. Proposes the largest land area for helicopter

yarding of any action alternative, 1,100 acres.

• About 15.8 miles of new road construction, the second lowest of the action alternatives behind

Alternative 3.

• The lowest estimated road construction/reconstruction and LTF costs per net MBF of any

Alternative: $81 per MBF.

• The highest estimated logging costs per net MBF removed of all the action alternatives: $273 per

MBF.

• The most negative indicated advertised rate of the action alternatives: -$14.05 per MBF.

• Supports 121 total local annualized jobs and about $6.4 million dollars in direct income are

expected under Alternative 2. This represents more jobs and income than Alternative 3, but fewer

jobs and less direct income than provided by Alternatives 4, 5, and 6.

Alternative 3

Compared to the other action alternatives, Alternative 3 has the second-highest total production costs 

per unit volume, about $652 per MBF sawlog volume. This is due primarily to higher road 

construction/reconstruction, and LTF costs per harvested net timber volume removed ($/NMBF 

sawlog). Summary of direct and indirect effects under current R10 Export Policy includes: 

• Timber harvest on about 1,012 acres, and provides about 15 MMBF sawlog volume, the least

harvest volume proposed of any action alternative. Consequently Alternative 3 would have the

least potential to contribute to timber industry employment or support local and regional

economies.
Saddle Lakes Timber Sale Final EIS Issue 1 – Timber Economics - Chapter 3  73

• Shovel, cable, and helicopter logging systems. Proposes the smallest land area for helicopter

yarding of any alternative: 196 acres. However, this alternative also proposes to harvest the

fewest number of acres of any action alternative.

• About 11.7 miles of new road construction, the fewest miles of any action alternative.

• The highest estimated road construction/reconstruction and LTF costs per net MBF of any

Alternative: $105 per MBF. Largely this is due to the same fixed LTF construction cost spread

over the smallest volume.

• Lower estimated logging costs per net MBF removed than Alternatives 2, 4, and 5. These costs

are equivalent to Alternative 6 logging costs per net MBF removed: $246 per MBF.

• The second most negative indicated advertised rate of the action alternatives: -$12.08 per MBF.

• Supports the fewest jobs and direct income of any action alternative, with 68 total local

annualized jobs and about $3.6 million in direct income.

Alternative 4 

Compared to the other action alternatives, Alternative 4 has the second-lowest total production cost 

per unit volume, about $641 per MBF sawlog volume. Summary of direct and indirect effects under 

current R10 Export Policy includes: 

• Timber harvest on about 2,424 acres, and provides about 46 MMBF sawlog volume, more harvest

volume than proposed under any alternative except Alternative 5. Alternative 4 has the second

highest potential to contribute to a timber supply sufficient to meet market demand, and affect

local and regional economies.

• Shovel, cable, and helicopter logging systems. Proposes 497 acres of helicopter yarding.

• About 29.4 miles of new road construction, the second most of the action alternatives behind

Alternative 5.

• Higher estimated road construction/reconstruction and LTF costs per net MBF than Alternatives 2

and 5, and lower costs than Alternatives 3 and 6: $88 per MBF.

• Higher estimated logging costs per net MBF removed than Alternatives 3 and 6, and lower costs

than Alternatives 2 and 5: $252 per MBF.

• A lower indicated advertised rate than Alternative 6, but a higher rate than any of the other action

alternatives: -$2.00 per MBF.

• Supports the most local jobs and direct income of any alternative, except Alternative 5, with 203

total local annualized jobs and about $10.8 million dollars in direct income.

Alternative 5

Compared to the other action alternatives, Alternative 5 has lower production costs per unit volume 

than Alternatives 2 and 3, and higher production costs per unit volume than Alternatives 4 and 6, 

about $643 per MBF sawlog volume. Summary of direct and indirect effects under current R10 

Export Policy includes: 

• Timber harvest on about 2,875 acres, and provides about 54 MMBF sawlog volume. Alternative 5

has more harvest volume than proposed under any alternative, and has the highest potential to

contribute to timber industry employment or support local and regional economies.

• Shovel, cable, and helicopter logging systems. Proposes 719 acres of helicopter yarding.

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74  Chapter 3 – Issue 1 - Timber Economics Saddle Lakes Timber Sale Final EIS

• About 32.3 miles of new road construction, the most proposed road construction of any

alternative.

• The second-lowest estimated road construction/reconstruction and LTF costs per net MBF of any

alternative: $84 per MBF.

• The second-highest estimated logging costs per net MBF removed of all the action alternatives:

$262 per MBF.

• A higher indicated advertised rate than Alternatives 2 and 3, but a lower indicated advertised rate

than Alternatives 4 and 6: -$4.66 per MBF.

• Supports the most local jobs and direct income of any alternative, with 241 total local annualized

jobs and about $12.9 million dollars in direct income.

Alternative 6

Compared to the other action alternatives, Alternative 6 has the lowest production costs per unit 

volume, about $635 per MBF sawlog volume. Summary of direct and indirect effects under current 

R10 Export Policy includes: 

• Timber harvest on about 2,138 acres, and provides about 36 MMBF sawlog volume. Alternative 6

produces the third highest total timber volume of the alternatives.

• Shovel, cable, and helicopter logging systems. Proposes 479 acres of helicopter yarding.

• About 24.5 miles of new road construction, which is more than Alternatives 2 and 3 but less than

Alternatives 4 and 5.

• The second-highest estimated road construction/reconstruction and LTF costs per net MBF of any

alternative: $91 per MBF.

• The lowest estimated logging costs per net MBF removed than all other action alternatives: $241

per MBF.

• The highest indicated advertised rate of any alternative: $3.62 per MBF.

• Supports fewer local jobs and less direct income than Alternatives 4 and 5: 161 total local

annualized and about $8.6 million dollars in direct income.

Cumulative Effects

Appendix B includes the interrelated projects (i.e., past, present and reasonably foreseeable future 

actions) that have been considered in the timber economics cumulative effects analysis.

Alternative 1

Under Alternative 1, timber operators in Southeast Alaska would have no opportunity to bid on timber 

in the Saddle Lakes project area at this time, and would need to obtain timber for processing from 

other sources, if available. Other potential sources of timber in Southeast Alaska include the Tongass 

National Forest, the State of Alaska, and Native corporation lands. 

Alternatives 2, 3, 4, 5, and 6

Volume from the Saddle Lakes project area, in combination with other timber sales offered on the 

Tongass National Forest and on State of Alaska and Native corporation lands, would likely contribute 

to the long-term timber supply and enhanced stability of local and regional economies. Timber 

harvests from the Tongass National Forest have averaged about 26 percent of the volume harvested in 

Southeast Alaska during the past decade. 
Saddle Lakes Timber Sale Final EIS Issue 1 – Timber Economics - Chapter 3  75

Providing investors an assurance of a steady supply of timber is critical in the multi-year timber 

program on the Tongass National Forest. Over the past decade, timber harvest on the Tongass 

averaged about 37 MMBF per year. Because most market conditions would support a sustained

annual Tongass timber harvest of 238 MMBF per year, maximizing harvested timber volume from the 

Saddle Lakes project while minimizing per unit costs would achieve this project’s primary objective 

of helping to provide a timber supply adequate to meet annual market demand for Tongass National 

Forest.

The State of Alaska Department of Transportation and Public Facilities (ADOT & PF) is currently 

planning to extend the Ketchikan road system from the end of Revilla Road near Harriet Hunt Lake to 

Shelter Cove on Carroll Inlet (ADOT & PF, 2012). Completion of this road would provide a 

connection between the project area and the Leask Cove sort yard and LTF. As a result, costs of 

transporting forest products from the project area and other operational costs could be reduced 

increasing the probability of an economically viable Saddle Lakes Timber Sale. 

Estimates provided by the State of Alaska Division of Forestry (personal communication from State 

of Alaska Division of Forestry, with input from ALCAN Forest Products LLP, 2014) indicate that 

economic benefits of the Ketchikan to Shelter Cove Road to timber purchasers would probably be 

substantial. Reductions in costs of towing, fuel, equipment repairs, transportation, logging camps, and 

overhead such as workers compensation insurance could reduce operator costs. Based on both 

scenarios, the FASTR analyses for the preferred alternative, Alternative 4, stump-to-mill costs could 

be reduced by about $19 per MBF for the export scenario, and $4 per MBF for the domestic-only 

processing scenario (net removed without utility). 

The proposed administrative land exchange between the AMHT and the Forest Service could increase 

future timber harvest volume within the project area on State-acquired lands. 

Due to poor domestic markets and high domestic manufacturing costs, indicated advertised rate is 

lower under a domestic processing scenario for all action alternatives than under the export policy 

scenario. Alternatives 4 and 5 have the greatest potential to contribute to a timber supply, and thus to 

affect local and regional economies. Alternative 2 yields the highest value for timber volume 

available under the domestic processing scenario, under current market conditions. Alternative 6 

yields the highest value for the timber volume under the export scenario.

Affected Environment and Environmental Consequences 3
3 Affected Environment and Environmental Consequences

76  Chapter 3 – Issue 2 – Timber Availability Saddle Lakes Timber Sale Final EIS

Issue 2. Timber Availability

Issue Statement: Availability of timber within the project area that is allowed to be 

harvested under the Forest Plan affects a stable supply of timber to meet local and 

regional timber demand.

Issue 2 addresses concerns about the availability of timber within the project area. This was most 

recently described in the 2008 Forest Plan Amendment FEIS (USDA Forest Service 2008c, p. A-5) as 

Key Issue 2: “The Tongass National Forest needs to seek to provide a sufficient timber supply to

meet the market demand and help maintain a vibrant economy in Southeast Alaska.” 

This project proposes two amendments to the 2008 Forest Plan. One involves relocating a portion of 

small old-growth habitat reserve (OG LUD) into the North Revilla Inventoried Roadless Area. This 

action would provide about 322 acres of additional suitable timberlands (USDA Forest Service

2008b, p. A-1) within the project area. The other proposed amendment would remove visual priority 

route (VPR) designations, in order to meet less restrictive Forest Plan Scenery Standards and 

Guidelines. As a result, additional even-aged management and larger harvest units could be 

prescribed at this time, thereby increasing the timber harvest volume for this project and decreasing 

scenic quality from allowable in the Forest Plan. 

Units of Measure:

The following units of measure were used to evaluate effects of the proposed action and compare 

alternatives:

• Changes in acres of suitable timberlands where timber harvest is allowed because of Forest Plan

LUD allocations; and

• Changes in acres by scenic integrity objective levels.

Methodology

The Forest Plan Appendix A describes the process followed to identify timberlands on the Tongass 

National Forest suitable for timber production (USDA Forest Service 2008b). First, lands legally and 

practicably capable of timber production are classified as tentatively suitable timberlands. Then, 

because of Forest Plan Standards and Guidelines and land use designations that do not allow timber 

management, the Forest Plan further classifies whether tentatively suitable timberlands are suitable 

for commercial harvest. This process is also displayed in the Silviculture section.

GIS data were used to determine acres of suitable timberlands and acres of forestland withdrawn from 

timber production. 

Analysis Area

The analysis area for timber availability is the project area.

Affected Environment

The Saddle Lakes project area contains about 38,459 acres. National Forest System (NFS) lands 

within the project area comprise about 34,903 acres. Timberlands physically unsuitable for timber 

management comprise about 54 percent of NFS lands within the project area.
Saddle Lakes Timber Sale Final EIS Issue 2 – Timber Availability - Chapter 3  77

Young-growth stands account for 2,986 acres of the suitable forest land in the project area. However, 

there is not a market for the available young-growth forest products within the project area at this 

time.

Combined, the North Revilla and Carroll Inventoried Roadless Areas (IRAs) comprise about 18,537 

acres (about 48 percent) within the project area. Within this area, there are 4,659 acres categorized as 

tentatively suitable timberlands within Timber Production and Modified Landscape LUDs. No harvest 

was proposed in IRAs as part of the Saddle Lakes Timber Sale project due to the decision of the 

District Court to vacate the Tongass exemption of the 2001 Roadless Rule in March 2011. Therefore, 

no harvest was proposed in IRAs with this project.

Within the project area, and outside IRAs, there are 4,846 acres categorized as suitable timberlands 

within Timber Production and Modified Landscape LUDs. Suitable timberlands within the Saddle 

Lakes project area are summarized by LUD in Table 13. 

Table 13. Suitable timberland acres in the Saddle Lakes project area

LUD

Suitable Old 

Growth 

Timberlands

Suitable Young 

Growth 

Timberlands

Suitable Old 

Growth 

Timberlands 

outside IRAs

Suitable Young 

Growth 

Timberlands 

outside IRAs

Modified Landscape 5,517 1,954 3,472 1,845

Timber Production 3,987 1,101 1,374 926

Old-growth Habitat 0 0 0 0 

Totals 9,504 2,986 4,846 2,771

Source: Tongass National Forest GIS

Environmental Consequences

Estimates of direct, indirect, and cumulative effects for any proposed LUD acreage change are 

quantified by GIS. Changes in acreage by SIO classification are also quantified by GIS. 

Direct and Indirect Effects

Modification of the small OGR

Alternative 5 addresses timber availability for Saddle Lakes by proposing to move a portion of the 

small OGR in VCU 7470. The vacated area (roaded portions of the current OG Old-growth Habitat 

LUD) would be designated as Modified Landscape LUD, a development LUD where timber harvest 

is allowed. This modification would increase suitable and available timberland in the project area by 

322 acres (Table 14).

Table 14. Additional suitable timberlands available for harvest due to modification of the small Oldgrowth Reserve

Measurement 

Criteria Alt. 1 Alt. 2 Alt. 3 Alt. 4 Alt. 5 Alt. 6

Old-growth forest 0 0 0 0 3221/ 0 

Source: Tongass National Forest GIS

1/ Proposed Forest Plan Amendment to move the OGR into the North Revilla IRA and classify the current roaded portion as 

Modified Landscape LUD. 

Affected Environment and Environmental Consequences 3
3 Affected Environment and Environmental Consequences

78  Chapter 3 – Issue 2 – Timber Availability Saddle Lakes Timber Sale Final EIS

Removal of the Visual Priority Route Designation 

Alternatives 4, 5, and 6 propose to remove three or more VPR designations through a Forest Plan 

Amendment (see Issue 4a). The adopted SIOs required under the Forest Plan Scenery Standards and 

Guidelines would allow more visual disturbance. See Issue 4a for a description of SIOs. Although the 

volume of suitable and available timber does not change, this amendment would allow even-aged 

management (e.g., clearcut silvicultural systems) on a greater number of acres. To estimate the 

effects, the difference in acres of suitable and available timber that changed from the Moderate SIO to 

the Very Low SIO is used as a relative indication of available timber volume (Table 15). 

Table 15. Effects of Visual Priority Route designation removal (Alternatives 4, 5 and 6) for the Saddle 

Lakes Timber Sale Project

Alternative 

Acres of Harvest in 

Areas that Decrease in 

SIO

Acres of Harvest in 

Areas with no change 

in SIO

Project Area Acres that 

decrease in SIO

2 0 2.027 0

3 0 1,012 0

4 1,285 1,139 8,270

5 1,642 1,233 8,750

6 743 1,395 6,810

Source: Tongass National Forest GIS

Cumulative Effects

Appendix B includes the interrelated projects (i.e., past, present and reasonably foreseeable future

actions) that have been considered in the timber availability cumulative effects analysis.

Alaska Mental Health Trust Authority Land Exchange

Alaska Mental Health Trust Authority (AMHT) has proposed an administrative land exchange with 

the USDA Forest Service in the project area. If implemented, about 8,170 acres of NFS lands located 

in the project area would fall under the administration of the AMHT. These lands could be available 

for harvest and include 4,142 acres of old-growth forest and 1,284 acres of young-growth forest.
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Issue 3A – Wildlife Habitat - Chapter 3  79

Issue 3. Wildlife Habitat and Subsistence Use

Issue Statement: Timber harvest and road construction, combined with past 

management activities, would affect wildlife habitat and could affect subsistence use. 

Issue 3A. Wildlife Habitat

Public and agency comments, as well as internal scoping, expressed concerns about project effects on 

wildlife and wildlife habitat and old-growth connectivity, and subsistence use in the project area. Of 

special concern are project effects on deer because of their importance to wolves and subsistence 

users. The project area includes low-elevation (less than 1,500 feet), old-growth habitat important for 

old-growth dependent wildlife species. Removing old-growth habitat fragments wildlife habitat and 

leads to a loss of old-growth connectivity. 

Because of its proximity to the residents of Ketchikan and Saxman, the Saddle Lakes project area is 

considered an important deer hunting area for these communities. The cumulative effects on oldgrowth habitat associated with additional harvest, combined with past harvest and increasing road 

density were noted concerns.

Units of Measure:

The following units of measure were used to evaluate effects of the proposed action and compare 

alternatives:

• Percent reduction from historic and existing acres of habitat by wildlife species (using sizedensity model [SDM] habitat classifications) at the value comparison unit (VCU), and/or wildlife

analysis area (WAA) scale, biogeographic province and Revillagigedo Island scales as well as

some discussion at the GMU scale;

• Connectivity/Fragmentation in the project area by alternative (corridor analysis, reduction of

POG acres, change in patch sizes);

• Open and total road density (miles per square mile) at analysis scales specific to wolf and marten

requirements; and

• Deer model habitat capability and density.

Methodology

The wildlife effects analysis focuses on the impacts of timber sale activities on old-growth habitat and 

the effects on management indicator species (MIS), other wildlife species of interest, and habitat 

connectivity in the Saddle Lakes project area. A variety of methods were used to identify and analyze 

potential effects of the Saddle Lakes Timber Sale on wildlife including the following: past surveys, 

aerial photo interpretation, wildlife computer models, GIS analysis, field reconnaissance, input from 

field crews and other federal and State agencies. Local knowledge and scientific literature were used 

for further information regarding species occurrence in the area and habitat requirements. 

During the project planning process, wildlife habitat within the entire unit pool was assessed and 

representative samples of units and the surrounding area visited. Field reconnaissance focused on 

walk through surveys and incidental observations, but included vocalized call station protocol for 

goshawk surveys. All goshawk survey information is available in the project record.

Edge effects were calculated using information from Concannon’s thesis work on the Tongass as the 

best available information. It is unknown how well this data correlates to individual species such as 

brown creeper. Research by Kissling and Garton (2008) that specifically looked at avian species 

detected too few brown creepers to analyze buffer width. 
3 Affected Environment and Environmental Consequences

80  Chapter 3 – Issue 3A – Wildlife Habitat Saddle Lakes Timber Sale Final EIS

The size density model (SDM) GIS layer was used to classify wildlife habitat. For purposes of the 

analysis, stand initiation phase is 0 to 25 years, stem exclusion phase is 26 to 150 years and over 150 

years old is considered old-growth forest. 

For the Saddle Lakes analysis, the deer model was used, following the October 2011 direction, for 

average winter carrying capacity for direct, indirect, and cumulative effects. The analysis of deep 

snow winter deer habitat modified the 2011 direction. The 2011 direction defines deep snow as 

HPOG < 800 feet in elevation. It further defines HPOG as SD5N, SD5S and SD67. The Saddle Lakes 

analysis used SD5N, SD5S and SD67 < 800 feet in elevation on south aspects. This decision was 

based on the professional judgment of the wildlife biologist. 

Analysis conclusions are based on professional judgment using information provided by forest staff, 

knowledgeable scientists and ecologists, and relevant references and technical literature citations. 

Local ADF&G biologists were contacted for information regarding the status of species, habitats, and 

special habitat features in the Saddle Lakes vicinity.

Incomplete and Unavailable Information

Complete wildlife surveys have not been conducted for the entire Saddle Lakes project area or larger 

wildlife analysis areas (WAAs 406 and 407). Surveys are labor intensive and cost prohibitive to 

obtain project specific data. Likewise, no wildlife population data is available from ADF&G.

Information for non-NFS (State or private) lands is based upon the best information available, but 

data is lacking for some areas. The deer model direction paper (2011) says “For cumulative effects

rerun the model with all land ownerships and clearly state how non-NFS lands were treated (given 

zero habitat value or used actual data). The Wildlife Resource Report says that for direct/indirect 

effects historic harvest was considered to be high-POG if on non-hydric soils or medium-POG if on 

hydric soils (slope class<2), and that for cumulative effects historic condition on non-NFS lands was 

reconstructed using the same high-POG/medium-POG parameters. For cumulative effects analysis the 

deer model assigns a zero value to all non-federal lands but includes the non-federal acres in the deer 

density calculation. So for the historic calculation of DHC on non-federal lands the lands were given 

a value; however the land was given values to estimate the historic DHC and the calculated 

cumulative effects with current/ project/ stem exclusion having zero value. 

Local information from research conducted within Saddle Lakes or on Revillagigedo Island was 

sought in all cases, but local studies have not yet been conducted for many of the species or species 

groups addressed in this report. Peer-reviewed, published literature from Southeast Alaska is limited 

or non-existent for many of the MIS species. Much of the available information for Southeast Alaska 

is from Forest Service reports, ADF&G reports, and MS or PhD theses. 

When necessary, peer-reviewed information from other areas was used to support conclusions. 

Information from Alaska was used first, followed by British Columbia and the Pacific Northwest. 

Other research was used to document similar findings across a species range. It is unknown how well 

information from other areas applies to the Saddle Lakes area.

Existing information is sufficient to determine changes to habitat and draw generalized conclusions 

from identified habitat relationships. Given the data limitations, actual populations may vary

considerably from those predicted by this analysis. However, the approach used provides the best 

estimate of general population effects in response to habitat change. 

Analysis Area

The Saddle Lakes project area falls within portions of WAAs 406 and 407. Saddle Lakes contains 

portions of three value comparison units (VCUs): 7460, 7470, and 7530. The Saddle Lakes project 

area falls within ADF&G game management unit (GMU 1A) and Biogeographic Province 15. 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Issue 3A – Wildlife Habitat - Chapter 3  81

Only National Forest System (NFS) lands were used for direct and indirect effects analysis. WAAs 

406 and 407 were used to assess direct and indirect effects on deer, wolves, bear, and mountain goat 

due to their larger home range sizes. WAAs were specifically delineated by ADF&G to encompass 

areas used by larger, wide-ranging mammal species. VCUs, delineated by the Forest Service, are used

in this analysis to address direct and indirect effects on other species with smaller home ranges. 

Cumulative effects to wolves are also analyzed at the scale of the biogeographic province and 

Revillagigedo Island, with some discussion at the GMU scale.

Land acres in all ownerships were used for cumulative effects analysis in accordance with the 

cumulative effects definition (40 C.F.R. § 1508.7). Cumulative effects consider relevant past, present 

and reasonably foreseeable future activities (see Appendix B). 

The Leask Lakes land exchange was 5,240 total acres, of which 3,726 has been harvested. No GIS 

information exists for these acres. The cumulative effects analysis does take these acres into 

consideration but does not assign any value to the acres. 

The potential AMHT land exchange, 8,170 acres, was not included in the cumulative effects analysis 

because at the time of the analysis this land had not yet been conveyed.

Affected Environment

Topography and Climate

Topography within the Saddle Lakes area is characterized by high, generally steep mountains 

interspersed with lowland muskeg and scrub. Elevations range from sea level to over 3,100 feet in 

elevation. The highest peaks occur in the northern portion of the project area where numerous peaks 

over 2,000 feet in elevation form the east, west, and north boundary. Peaks on the southern portion of 

the project area are generally lower. The dominant ridge running north/south between North Saddle 

and Buckhorn Lakes rises up to 2,300 feet elevation, but most other peaks are less than 2,000 feet.

Proposed units in the Saddle Lakes timber sale are at low elevation; only six units extend above 1,500 

feet elevation. 

Low-elevation old-growth habitat (less than or equal to 800 feet elevation) supports many wildlife 

species during high-snow winters or as year-round habitat. Old-growth forest at intermediate 

elevations provides transitional range for migratory deer, additional year-round range for resident 

deer during low-snow winters, and year-round habitat for other species. Higher-elevation habitat 

(greater than 1,500 feet) provides summer habitat.

Climate is generally characterized as mild winters with snow, cool summers, and year-round rainfall. 

Based upon long-term yearly averages, Albert and Schoen (2007) classified northern Saddle Lakes as 

intermediate snow accumulation with low snow in the south and around George Inlet. 

Biodiversity

Biodiversity may be defined as “the variety of life forms and processes, including the complexity of 

species, communities, gene pools, and ecological functions, within the area covered by a land 

management plan” (USDA Forest Service 2008a). Biological diversity encompasses the variety of 

genetic stocks, plant and animal species and subspecies, ecosystems, and the ecological processes 

through which individual organisms interact with one another and their environments. Under the 

National Forest Management Act (NFMA), the Tongass National Forest must provide for diversity of 

plant and animal communities based on the suitability and capability of specific land areas.
3 Affected Environment and Environmental Consequences

82  Chapter 3 – Issue 3A – Wildlife Habitat Saddle Lakes Timber Sale Final EIS

The biological diversity associated with old-growth forests has long been recognized as important 

within the Tongass National Forest, and the old-growth forest is the ecosystem most directly affected 

by timber management activities on the Tongass (USDA Forest Service 2008c, p. 3-137). 

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

or prey on species that inhabit old-growth forests (USDA Forest Service 2008c, p. 3-220). 

WAAs 406 and 407 contain typical Southeast Alaska coastal temperate rain forest vegetation (see 

Silviculture and Botany sections for details). Forested areas are primarily old growth with inclusions 

of past harvest (i.e., young growth). 

Old-growth stands on the Tongass are generally greater than 150 years old (USDA Forest Service 

2008b, p. 3-137; Capp et al. 1992). The greatest variations in stand structure, including multi-storied 

canopies important to many wildlife species, occur in stands greater than 200 years old (Alaback 

1982). Following complete removal of the overstory with clearcut harvest, it may take 300 years or 

more for a stands in Southeast Alaska and north coastal British Columbia to develop old-growth 

ecological characteristics (see Orians and Schoen 2013). Old-growth forested habitat on the Tongass 

is divided into two major classifications.

1. Productive old growth (POG) or commercial timber capable of supporting at least 20 cubic feet of

industrial wood per acre per year or having greater than 8,000 board feet per acre of standing

volume.

2. Un-productive old-growth ( NPOG) or areas with at least 10 percent tree cover that otherwise

meet old-growth definitions, but which generally contain smaller, more open canopy trees not

capable of producing 20 cubic feet per acre per year.

As old-growth forest is harvested, it transitions through several ecological changes. Within 5 years of 

being clearcut, plants respond to the unrestricted sunlight producing an abundance of forage that 

reaches maximum biomass at approximately 12 to 19 years post-logging (Alaback 1982). By the time 

these regenerating stands reach 20 to 30 years, naturally regenerating conifers have become large 

enough to create canopies that shade out understory plants. As the canopy becomes denser, these 

young even-aged conifers can almost completely eliminate understory plants creating a “stem 

exclusion” phase that may last for more than 150 years (Alaback and Tappeiner 2002, Person and 

Brinkman 2013). 

Source Habitat and Sink Habitat

In population studies, source habitat is generally considered to be high-quality habitat (based upon 

local characteristics of forage, vegetation structure, etc.) where births exceed deaths, whereas sink 

habitat is considered to be low-quality habitat and where deaths exceed births (Forman 1995). Source 

and sink dynamics consider the spatial linkage of population dynamics where high-quality habitat 

provides excess individuals that maintain population densities, through migration, within low-quality 

habitats (Congdon and Dunham 1997). 

Size-Density Model

A representation of wildlife habitats within the analysis area was generated from the mapping of 

forest vegetation using the size-density model (SDM). SDM habitat classifications are shown in Table 

16 and are described in detail in the Forest Plan FEIS (USDA Forest Service 2008c, pp. 3-139 

through 3-142 and 3-231, Caouette and DeGayner 2008, Krosse and O’Connor 2009). These habitat 

groupings were used to analyze effects. 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Issue 3A – Wildlife Habitat - Chapter 3  83

Table 16. Size-density model habitat classifications found in the Saddle Lakes project area

Habitat SDM Veg Code1/

POG SD4H, SD4N, SD4S, SD5H, SD5N, SD5S, SD67

High-POG SD5N, SD5S, SD67

Medium-POG SD4N, SD4S, SD5H

Low-POG SD4H

Large Tree POG SD67 

NPOG UF, F99

Forested muskeg FM

Non-forested NF, X99

Young (<26 year old) young growth HS1, HS2, S1, S2

Older young growth (stem exclusion) HS3, S3

1/ Stand Density Model (SDM) uses timber volume class, hydric soil class, and aspect to characterize forest structure. These 

attributes were correlated with the stand density index and mean quadratic diameter to derive the various SDM categories.

Historically there were about 81,110 acres of POG in WAAs 406 and 407 combined. Currently the 

acreage is estimated to be about 66,928, a reduction of about 17 percent.

Past activities have altered the amount of available old-growth habitat for wildlife. Changes to a 

variety of habitat types are shown by combined VCUs and WAAs for NFS lands in Table 17. 

Table 17. Change in historic acres of POG Saddle Lakes VCUs and WAAs, NFS lands only

Habitat

Historic NFS 

Acres VCUs 

7460/7470/7530

Current 

NFS 

Acres 

VCUs

Percent 

Change

Historic NFS 

Acres WAA

406/407

Current 

NFS 

Acres 

WAAs

Percent 

Change

High-POG ≤800’ 

elev. 18,366 9,904 -46% 26,984 17,193 -36%

High-POG ≤1500’ 

elev. 28,340 17,018 -40% 45,655 32,032 -30%

POG ≤1500’ 

elevation 41,529 30,207 -27% 69,974 56,351 -19%

High-POG 31,213 19,711 -37% 52,033 37,851 -27%

Moderate-POG 11,407 11,407 0% 22,464 22,463 <1%

Low-POG 3,711 3,711 0% 6,613 6,613 0%

POG 46,331 34,829 -18% 81,110 66,928 -17%

Interior POG1/ 23,186 7,960 -66% 36,858 18,824 -49%

Large Tree POGSD67 unknown 1,927 unknown unknown 5,998 unknown

Unproductive Old 

Growth (UF,F99) 17,500 17,500 0% 46,215 46,215 0%

Forested muskeg 7,995 7,995 0% 17,197 17,197 0%

Non-forested (NF, 

X99) 3,202 3,202 0% 18,979 18,979 0%

Young (<26 year old) 

young growth 69 5,719 + 177 7,486 + 

Older (26+ year old) 

young growth 235 6,088 + 484 7,357 + 

1/ Based upon vegetative and climatic edge effect distances for Southeast Alaska (Concannon 1995).
3 Affected Environment and Environmental Consequences

84  Chapter 3 – Issue 3A – Wildlife Habitat Saddle Lakes Timber Sale Final EIS

Conservation Strategy

An integrated science-based, old-growth forest habitat conservation strategy was developed and 

adopted for the 1997 Forest Plan and carried forward in the 2008 Forest Plan Amendment (see 1997 

Forest Plan FEIS Appendix N and 2008 Forest Plan FEIS Appendix D for details). This old-growth 

strategy has two components 1) old-growth reserves and 2) the “matrix”. 

Old-Growth Reserve System

The 1997 Forest Plan Interagency Viable Population Committee (VPOP) systematically screened 

wildlife species and identified those old-growth associated species considered to be most sensitive to 

habitat loss and fragmentation of the old-growth ecosystem. These species were then used to 

determine the size and spacing requirements of old-growth reserves (OGRs). The approach was 

reviewed and carried forward in the 2008 Forest Plan (USDA Forest Service 2008d, Appendix D, pgs. 

D-8 and D-9). 

Old-Growth Reserve Criteria

Primary habitat criteria for OGRs are described in the Forest Plan (USDA Forest Service 2008b, pp. 

3-57 through 3-62; and Appendix K) and the Forest Plan FEIS (USDA Forest Service 2008c, 

Appendix D, pp. D-5 thru D-9. See also 1997 Forest Plan FEIS (USDA Forest Service 1997b, 

Appendix N). OGR acreage requirement calculations are based on the acres of NFS lands within the 

VCU. Adjacent to but outside the Saddle Lakes project area is the Carroll Inlet medium OGR. It is 

located along Carroll Inlet at the northern extent of the project area. No modifications are proposed to 

this medium OGR. A small OGR is located within the project area in VCU 7470. The small OGR is 

proposed for modification under Alternative 5. 

The Ketchikan to Shelter Cove road is identified in the AK DOT&PF Southeast Alaska 

Transportation Plan and is identified in the Forest Plan as a Transportation and Utility system (TUS) 

overlay LUD. A small section of this road would be located in the current OGR. The TUS overlay 

LUD takes precedence over any underlying LUD. See Wildlife Resource Report, page 1. 

"Topography, including deeply incised drainages, may preclude alternative locations. Road survey 

engineers were aware of the restriction and spent considerable time attempting to avoid the OGR. The 

road was moved out of the OGR as much as feasible. However topography prevented alternative road 

locations. Locating a road in an OGR is consistent with Forest Plan. p. 3-61 says "New road 

construction is generally inconsistent with old-growth habitat LUD objectives but new roads may be 

constructed if no feasible alternative is available." If the OGR is modified as proposed in Alternative 

5, the OGR would not be impacted by the Ketchikan to Shelter Cove Road. 

VCU 7470 OGR History

During the 2008 Forest Plan review process the stated rationale for the small OGR in VCU 7470 was 

to provide connectivity between the Naha LUD II area and the low-elevation beach fringe POG in 

the George Inlet salt chuck; however, the connection between the Naha LUD II and George Inlet salt 

chuck is interrupted by land in other ownership. When the Tongass amended the Forest Plan in 2008, 

the small OGR was mapped incorrectly. An erratum was created Feb. 6, 2012 to correct the mapping 

error and adopt the biologically preferred interagency OGR.

Matrix Management

The second component of the old-growth forest habitat conservation strategy (USDA Forest Service 

2008d, Appendix D, p. D-10) is management of the area outside the reserves that is subject to timber 

harvest (the “matrix”). The Pacific Northwest Research Station scientists noted the need to provide 

enhanced landscape connectivity and to manage human disturbance of the land similar to natural 

disturbance regimes (Kiester and Eckhardt 1994). Matrix management can serve at least three 

important roles: 1) providing habitat at smaller spatial scales, 2) increasing the effectiveness of the 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Issue 3A – Wildlife Habitat - Chapter 3  85

reserves, and 3) improving landscape connectivity (USDA Forest Service 2008d, Appendix D, p. D3). The Forest Plan Standards and Guidelines applicable to wildlife within the “matrix” are discussed 

below under individual MIS sections. 

Connectivity

Connectivity is an element of biological diversity that describes the natural condition of old-growth in 

terms of patch size and distribution. An intact, undeveloped landscape is assumed to be fully 

functional, maintaining species, communities, and their supporting ecological processes within their 

natural ranges of variability (Poiani et al. 2000). On the Tongass National Forest, landscape 

connectivity between POG blocks or between high and low elevation habitats is important to 

maintaining well-distributed, viable wildlife populations (USDA Forest Service 2008c, p. 2-54). The 

percentage of the original POG forest no longer in an old-growth condition can serve as an indicator 

of the potential effect on several biodiversity aspects, including structural diversity (within-stand), 

connectivity (unfragmented, continuous old-growth blocks), and overstory and understory species 

composition (USDA Forest Service 2008c, p. 3-151). 

Fragmentation resulting from human actions such as timber harvest, and natural causes such as 

windthrow, reduces landscape connectivity by breaking larger contiguous blocks of habitat into 

smaller patches that are at increasing distances from each other. Timber harvest creates a highly 

fragmented landscape pattern that includes increased forest-opening edge and decreased patch size 

(Thomas et al. 1988). 

Patch Size

Large, contiguous blocks of old-growth forest are more important to old-growth associated species 

than individual stands. Large old-growth blocks provide expansive foraging and hunting territories, as 

well as protection from predators, and promote genetic mixing among populations that would be less 

likely to interbreed if they were spatially separated by forest fragmentation.

As patches become smaller and more isolated, individuals are required to traverse larger gaps in 

search of suitable habitat. The distribution of a species within a fragmented landscape may change 

from being a single “continuous” population, to that of a patchily distributed population with a 

number of independent subpopulations (Haufler 2007). Populations may become isolated, and 

therefore at greater risk of local extirpation, if fragmentation hinders movement of individuals 

between subpopulations (Mladenoff 1997). The degree to which this occurs depends on speciesspecific dispersal capabilities, the distance between habitat patches, and conditions within the matrix 

between habitat patches.

Patches at the stand level (the smallest size classes) represent scales of influence important to 

organisms such as lichens, fungi, plants, invertebrates, and small-bodied mammals which may be 

locally endemic, occur in very specific forest structure or soil conditions, or have limited dispersal 

capabilities (USDA Forest Service 1997a, p. 3-24, USDA Forest Service 2008c, p. 3-168). Larger 

patches represent scales of influence important to wider-ranging species such as deer, marten, and 

forest-dwelling birds. Historic and existing patch conditions for the combined WAAs on lands in all 

ownership are displayed in Table 18. Change in specific patch sizes are analyzed under Marten, Hairy 

Woodpecker, and Red-breasted Sapsucker sections.
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86  Chapter 3 – Issue 3A – Wildlife Habitat Saddle Lakes Timber Sale Final EIS

Table 18. Historic and existing POG patch size for WAAs 406/407 combined, all land ownerships 

Patch Size

Historic All Ownerships Existing All Ownerships

Number 

of 

patches

Acres

Average 

patch size 

(acres)

Number 

of 

patches

Acres Average 

patch size

0-39 acres 158 2,245 14 274 3,158 12

40-249 acres 40 3,401 85 61 5,521 91

250-499 acres 4 1,175 294 13 4,295 330

500-999 acres 3 1,963 654 9 7,125 792

1000+ ac 10 85,993 8,599 10 56,687 5,669

Total 215 94,776 N/A 367 76,786 N/A

Source: pog_Patch_1954_071113.xlsx, pog_patches_by_alt_082313.xlsx. Note: N/A = Not Applicable.

Interior Habitat

Interior forest habitat describes forest that is far enough away from an opening to not be affected by 

the opening’s light, temperature, moisture, and wind conditions (Harper et al. 2005). When 

fragmentation occurs there is an increase in the amount of forest edge habitat, and a decrease in the 

amount of interior forest habitat. Edge effects may include changes in vegetation structure, species 

composition (both plants and animals), predation rates, and disturbance (Murcia 1995, As 1999). The 

extent or “depth” of edge effects varies with the contrast in the structure and composition of adjacent 

vegetative communities, the width of the habitat fragment, and the stability of the remaining 

vegetation, and may be species-dependent (Harper et al. 2005). Effects to interior habitat acres are 

analyzed in the Brown Creeper section. 

Concannon (1995) defined edge as 656 feet from hard edges (e.g., roads, past harvest) and 394 feet 

from soft edges (e.g., muskegs, meadows). These distances were used to define and determine 

changes to interior habitat. 

Although the actual number of species may be higher along edges, the number of habitat specialists 

(i.e., those associated with interior forest conditions or structural components of old-growth forest) 

decreases (As 1999, Kissling and Garton 2007). Species such as the brown creeper are negatively 

affected by edge and therefore benefit from larger blocks containing interior habitat. Therefore, the 

brown creeper was selected as the indicator for interior habitat in the Saddle Lakes project area. 

Historic and existing interior habitat and percent change for lands in all ownerships is shown in Table 

19. 

Table 19. Historic and Existing Interior habitat, all land ownerships, by VCU and WAA

Area Historic Existing Percent reduction

VCU 7460 10,983 3,050 (-72.2%)

VCU 7470 6,363 3,070 (-51.8%)

VCU 7530 8,248 2,623 (-68.2%)

WAA 406 30,321 14,193 (-53.2%)

WAA 407 13,949 7,440 (-46.7%)

Interior habitat based upon vegetative & climatic edge effect distances for Southeast Alaska (Concannon 1995)
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Saddle Lakes Timber Sale Final EIS Issue 3A – Wildlife Habitat - Chapter 3  87

A generally rectangular isolated patch between clearcuts, a road, and a muskeg, which would require 

a minimum of 45 acres to have 1 acre of interior habitat in the middle (Figure 6). The gray square in 

the middle represents POG. 

Figure 6. Interior productive old-growth (POG) diagram

Corridors

The connectivity between old-growth habitats in a landscape may be as important to maintaining 

diversity as the size of the old-growth patches (Noss 1983). Populations of some species exist in 

discrete subpopulations that live in distinct habitat patches surrounded by other habitats that they do 

not inhabit. However, if individuals can frequently move between subpopulations, immigrants may 

prevent subpopulations from becoming locally extirpated (Orians et al. 2013). Maintenance of habitat 

connectivity is important to minimize isolation and potential local extirpation of wildlife species 

associated with interior old-growth (Hunter 1990). 

Corridors may be functional (i.e., non-contiguous patches of old-growth forest and other vegetation 

with structural characteristics that facilitate movement across the landscape) or structural (i.e., 

physically connected patches of old-growth forest). 

To be effective, corridors should contain enough interior forest to give species the ability to avoid 

predation from edge species. Linear corridors with little or no interior habitat are generally not 

considered as effective as wider ones. However, linear corridors that network larger habitat patches 

facilitate re-establishment of species and may provide habitat for species that could not otherwise 

survive in small isolated patches (Forman and Godron 1981, Hunter 1990, Rosenberg et al. 1995, 

Rosenberg et al. 1997). For example, the small OGR in VCU 7470 contributes to functioning of 

habitat in George Inlet by connecting the habitat in these areas with potential source populations in 

the Naha LUD II; however the connectivity between the OGR and the beach itself is interrupted by 

the presence of land in other ownership around the north end of George Inlet. Within WAAs 406 and 

407, corridors along the beach, streams, and between old-growth habitats at different elevations have 

been reduced by past harvest. 

The Forest Plan indicates that projects are to be designed to maintain landscape connectivity (USDA 

Forest Service 2008b, WILD1.VI, p. 4-91) with the objective being to maintain corridors of oldgrowth forest among large and medium Old-growth Habitat reserves and other Non-development 

LUDs at the landscape scale. Connectivity currently exists between the Carroll Inlet medium OGR 
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88  Chapter 3 – Issue 3A – Wildlife Habitat Saddle Lakes Timber Sale Final EIS

partially within the north end of the project area and Naha LUD II through the North Revilla 

Inventoried Roadless Area (IRA 526). Limited connectivity currently exists between the medium 

OGR and the Semi-Remote Recreation LUD south of the project area near California Head and 

between Naha LUD II and the Semi-Remote Recreation LUD. Projects are to consider opportunities 

to allow for the elevational migration of wildlife within the Modified Landscape LUD (USDA Forest 

Service 2008b, WILD1.B.2 p. 3-115). Corridors 3, 4 and 5 were identified as elevational connectivity 

corridors within the Modified Landscape LUD (Table 20). Based on local knowledge of the Saddle 

Lakes project area, areas were identified as wildlife corridors where additional harvest could reduce 

current connectivity (Figure 7).

Table 20. Corridors in the Saddle Lakes project area

Corridor 

Number Approximate Location Connectivity Description/Importance

1 

Medium OGR in VCUs 

7460 and 7440 and 

Naha LUD II

Maintains connectivity between the medium OGR partially 

within the north end of the project area and Naha LUD II 

through the IRA #526 in accordance with Forest Plan 

landscape connectivity direction (USDA Forest Service 2008b, 

WILD1.VI, p. 4-91). This corridor is mostly outside the project 

area and is unaffected under any alternative.

2 

Small OGR in VCU

7470 at the head of 

George Inlet salt chuck

Maintain connectivity between Naha LUD II and the George 

Inlet salt chuck facilitating dispersal and re-colonization of 

vacant territories. However this connection is interrupted by 

the presence of land in other ownership.

3 North of Island Point

Important elevational corridor because it is the only windfirm 

POG corridor of sufficient width for roughly four (4) miles either 

direction that extends from the high elevation ridge near 

Buckhorn Lake east to saltwater. 

4 North of Gunsight Creek Remaining corridor from high elevation to the beach between 

Gunsight Creek and Shelter Cove.

5 North of Lemon Lake

This corridor joins the medium OGR to IRA #526 and the small 

OGR linking the beach buffer to the higher ridges and is the 

beginning of connectivity south through the project area.

6 North Saddle Lakes to 

Buckhorn Lake

Main connectivity corridor between the northern and southern

halves of the project area. 

7 North Saddle Lakes to 

George Inlet

Connects Saddle Lakes to George Inlet. Extensive deer use 

was observed along this corridor.

8 West end of North 

Saddle Lakes

This is a short, but high use travel corridor around the west 

end of North Saddle Lakes. It links corridors 6 and 7 to provide 

connectivity from Naha into the southern portions of the project 

area.
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Saddle Lakes Timber Sale Final EIS Issue 3A – Wildlife Habitat - CHAPTER 3  89

Figure 7. Saddle Lakes project area wildlife connectivity corridors
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Saddle Lakes Timber Sale Final EIS Issue 3A – Wildlife Habitat - Chapter 3  91

Management Indicator Species

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

be used to predict the likely response of other species with similar habitat requirements (Forest

Service Manual [FSM] 2631.3). The Forest Plan FEIS identifies 13 wildlife MIS (USDA Forest

Service 2008c, pgs. 3-230 to 3-241). Nine MIS have been selected for detailed analysis. Brown bear 

(Ursus arctos) do not occur on Revillagigedo Island and are not considered in this analysis. The bald 

eagle, river otter and Vancouver Canada goose are not addressed in detail in the EIS because they

generally inhabit beach, estuary, and riparian habitats that are maintained under the Forest Plan

conservation strategy or habitats that are not significantly impacted by timber harvest. Moreover, the

project would have negligible effects to these species due to the implementation of best management

practices or other avoidance and minimizations measures (see the Wildlife and Subsistence Resource 

Report for a discussion of these species). The rationale for MIS selection is displayed in Table 21. 

Impacts to their preferred habitat(s) would occur during project implementation since harvest 

activities in POG alter stand structure and diversity.

Table 21. Wildlife species selected as management indicator species (MIS) for the Saddle Lakes Timber 

Sale Project

Species Basis for MIS Selection, habitat 

preference

Associated POG Habitat Project 

Level Indicator/Measurement1

Sitka black-tailed deer 

(Odocoileus hemionus 

sitkensis) 

Important subsistence and game 

species; represents variety of 

habitat at all elevations

Deep snow winter habitat; average 

snow winter habitat; non-winter habitat 

Alexander Archipelago 

wolf (Canis lupus ligoni) 

Population concerns, major 

predator of deer, furbearer

Deer/wolf Interactions, estimated deer 

density and road density

Black bear (Ursus 

americanus) 

Important game species; early 

(<26 year old) habitat and all types 

of old-growth

Denning and Foraging habitat; and 

habitat within 500” of Class I streams

American marten (Martes 

americana) Furbearer;POG and patch size Winter and year-round habitat; 

fragmentation 

Brown creeper (Certhia 

americana) 

Snag-dependent species affected 

by edge. Acres of interior POG

Hairy woodpecker 

(Picoides villosus) 

Snag-dependent species 

representing high-volume POG

Acres of high-POG at all elevations, 

patch size

Red-breasted sapsucker 

(Sphyrapicus ruber) 

Snag-dependent species 

representing low-medium POG

Acres of low- and medium-POG at all 

elevations, patch size

Red squirrel 

(Tamiasciurus 

hudsonicus) 

Small mammal & key goshawk

prey; POG; mature, cone-bearing 

trees provide limited foraging 

habitat

Acres of POG and young-growth 

greater than 40 years old 

Mountain goat (Oreamnos 

americanus) Important game species; POG near cliffs

Sitka Black-tailed Deer

The Sitka black-tailed deer (Odocoileus hemionus sitkensis) is a subspecies of mule deer that is 

endemic to the coastal areas of Southeast Alaska and northern British Columbia. Sitka black-tailed 

deer will be here after referred to as “deer.” Deer/wolf interactions are discussed under the Wolf 

section, below.
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92  Chapter 3 – Issue 3A – Wildlife Habitat Saddle Lakes Timber Sale Final EIS

Within GMU 1A, deer populations tend to fluctuate seasonally in response to winter weather and wolf 

and bear predation (Porter 2011a). Annual variability in weather patterns and snowfall can have 

noticeable impacts on deer distribution, population density, and hunter accessibility (McCoy et al. 

2009). Abundant deer forage is available within old-growth stands in the project area. Deer numbers 

are thought to be at very low levels throughout most of GMU 1A (Porter 2011a). 

Deer Habitat

Specific habitat for deer varies by season and whether they are resident or migratory deer. Deer 

distributions within Saddle Lakes area WAAs 406 and 407 are not known, but roughly two-thirds of 

the deer studied on Admiralty Island near Juneau made distinct migrations between winter and 

summer ranges while the other one third were year-round residents of their winter range (Schoen and 

Kirchhoff 1985). Given the amount of alpine habitat in the project area, migration patterns may be 

similar within WAAs 406 and 407. Schoen and Kirchhoff (1990) recommended that where possible, 

old-growth habitat should be retained in large blocks extending from sea level to the subalpine zone 

so that deer can make elevational movements in response to changing snow conditions. See Table 20 

for identified elevational corridors in the project area.

Winter habitat is the limiting factor for deer in Southeast Alaska (USDA Forest Service 2008c, p. 3-

230). Hanley (1984) concluded that the overall effect of snow depth restricts the range of suitable 

habitats and lowers the quality of all habitats. Because snow increases the energy cost of foraging, 

grazing time required to meet minimum energy needs also increases with snow depth (Hanley et al. 

1989). 

There are potentially three thresholds of snow depth. The first, approximately 10-20 cm (~4-8 

inches), is the depth at which evergreen forbs and herb-layer shrubs become buried. The second, 

approximately 25 to 30 cm (~10-12 inches), is when deer sink in the snow beyond front knee height 

and energy costs for locomotion increase greatly. The third, snow deeper than 25 to 30 cm, is the 

point at which tall shrubs become buried (deer model direction 2011). When snow is beyond that 

depth, deer diet consists almost entirely of low quality conifer foliage, and the energy costs for 

locomotion are extremely high. 

Most of WAAs 406 and 407 are classified as an intermediate snow area during average winters based 

upon long-term yearly averages (see Climate section) and a small area in WAA 406 near Carroll Point 

is classified as low snow. Since the project area occasionally experiences severe winters with higher 

than normal snow conditions, deep snow winter habitat was analyzed. Average winter habitat 

(average snow), and non-winter habitat were also analyzed. Table 22 shows the historic and current 

acreages of deer habitat on NFS lands.

Table 22. Historic and existing deer winter habitat acreages on NFS lands in WAAs 406 and 407

WAA Habitat Historic (1954) 

Acres 2013 Acres % Change

406

Deep Snow 3,866 2,463 -36%

Average Snow 52,202 40,421 -23%

Non-Winter 122,505 116,178 -5%

407

Deep Snow 1,168 940 -20%

Average Snow 17,772 15,930 -10%

Non-Winter 41,202 40,657 -1%
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Saddle Lakes Timber Sale Final EIS Issue 3A – Wildlife Habitat - Chapter 3  93

Deep Snow Winter Habitat

Extensive research conducted in Southeast Alaska indicates that low-elevation (less than 800 feet) 

high-POG habitat containing large trees with large branches to intercept snow and containing 

relatively high amounts of quality forage is important to deer during severe winters with above 

average snowfall (Person and Brinkman 2013, Schoen and Kirchhoff 2007, Hanley 1984). Further, 

during severe winters, deer densities in POG are substantially higher than in young-growth stands 

(Brinkman et al. 2011, Schoen and Kirchhoff 2007, Doerr et al. 2005). The lowest quality habitat for 

deer that Brinkman encountered was young, shrub-sapling stage clearcuts. In those stands, the canopy 

was still sufficiently open enough to allow snow build up, but thick enough to retard snow melt. 

Therefore, winter severity and the amount of young-growth are key factors in determining the 

capability of winter range to support deer populations. 

Under intermediate and deep snow conditions, deer select those habitats that provide for snow 

interception and food availability (Suring et al. 1992, Schoen and Kirchhoff 2007). Deep snow deer 

habitat is defined in the 2011 deer model direction as HPOG (SD5S, SD5N and SD67 < 800 feet in 

elevation). However Hanley (1984), Doerr et al. (2005), Brinkman (Person 2007, email), and Person 

(2009) all found that southerly aspects below 800 feet elevation were important to deer during deep 

snow winters in Southeast Alaska so for the Saddle Lakes analysis of effects to deep snow SD5S 

SD5N and SD67 < 800 feet in elevation on south aspects were used.

Average Winter Deer Habitat

During average winters, when habitat selection by deer is not appreciably influenced by snow, deer 

select those habitats that provide the best foraging opportunities (Suring et al. 1992). Migratory deer 

move as high in elevation as snow conditions allow; resident deer also move up and down slope 

within their home ranges depending on changing snow levels (McNay and Vollner 1995, B.C. 

Ministry of Forests 1996, Schoen and Kirchhoff 2007, Colson et al. 2012). Elevations up to 1,968 feet 

may be used during relatively snow free periods (Hanley 1984, Schoen and Kirchhoff 1985) although 

1,500 feet has generally been cited as the upper elevation (Kirchhoff and Hanley 1992, White et al. 

2009). Herb-layer, evergreen plants (bunchberry and five-leaved bramble) continue to be the forage of 

highest quality, but may be more available in more open-canopied, lower-volume forests. The 2011 

deer model direction defines average deer winter habitats as all POG < 1500 feet in elevation. 

Non-Winter (Spring/Summer/Fall) Deer Habitat

Spring, summer, and fall habitat conditions are important for maintaining the nutritional condition of 

deer throughout the year (Hanley et al. 1989, Klein 1965). Body reserves accumulated during summer 

are critical for winter survival and reproduction. Does foraging in extensively clearcut habitats may 

have difficulty meeting protein requirements for lactation because of high tannin concentrations in 

sun-grown leaves (Hanley et al. 1989). Subalpine, alpine, and scrub [NPOG] forest stands were used 

by migratory deer at elevations greater than 1,969 feet (Schoen and Kirchhoff 1990). Resident deer 

remain within their home ranges, but also use open habitats such as young clearcuts, muskegs, and 

NPOG. Non-winter habitat is defined in the 2011 deer model direction as all habitats except stem 

exclusion.

Deer Model Habitat Capability

The deer model, takes into account snow depth, elevation, aspect, and vegetation to provide a habitat 

suitability index (HSI) of average winter deer habitat capability (DHC). Habitat capability values 

were designed to estimate changes in deer carrying capacity that result from timber harvest. The 

model was not designed to calculate actual deer populations since it does not include complex 

predator/prey relationships or recruitment/mortality interactions which can substantially alter actual 

deer populations (USDA Forest Service 1997b, Appendix N, p. N-32). The deer model estimates 
3 Affected Environment and Environmental Consequences

94  Chapter 3 – Issue 3A – Wildlife Habitat Saddle Lakes Timber Sale Final EIS

long-term DHC, and assumes that winter range is the limiting factor to deer populations in Southeast

Alaska (USDA Forest Service 1997b, Appendix N, p. N-33). Although deer density outputs from the

deer model are useful for estimating changes that result from proposed projects, they do not reflect 

actual known deer numbers; however, they do represent the functioning of the predator-prey system 

dynamic (2008 Forest Plan FEIS, p. 3-282). 

The condition of previously harvested stands (e.g., stand initiation or stem exclusion) and stands 

proposed for harvest are compared to the habitat capability that existed prior to large-scale timber 

harvest. In general, higher value deer habitat is reduced in value when harvested and drops further at 

the stem exclusion stage; some lower value deer habitat initially increases in value when harvested 

due to increased forage, but drops below pre-harvest levels once stem exclusion occurs. Lowelevation, high-POG stands with southern aspects and low average snowfall are assumed to provide 

the best quality deer winter habitat. Areas above 1,500 feet in elevation are assumed to have no value 

as winter habitat.

Additional information on the deer model is provided in the Forest Plan FEIS (USDA Forest Service

2008c, pgs. 3-231, 3-323, 3-265 to 3-267, and USDA Forest Service 2008d, Appendix B, pgs. B-31 to 

B-32). Table 23 shows historic and existing DHC in WAAs 406 and 407 on NFS lands. 

Table 23. Historic and existing deer habitat capability (DHC) in WAAs 406 and 407 on NFS lands

WAA Historic DHC Existing DHC Percent Reduction

406 3,276 2,521 -23%

407 1,158 1,042 -10%

Source: USFS Tongass National Forest GIS.

Deer habitat capability (DHC) does not equal actual deer; it is used as a tool to compare alternatives.

Alexander Archipelago Wolf

The Alexander Archipelago wolf (Canis lupus ligoni) is endemic to Southeast Alaska, and occurs 

throughout the southeast mainland and islands in the Alexander Archipelago except Admiralty, 

Baranof, and Chichagof (MacDonald and Cook 2007, Person et al. 1996). The USFWS was 

petitioned to list the Alexander Archipelago wolf in 1994. The USFWS decided not to list the wolf at 

that time. The decision not to list C. l. ligoni in 1994 as threatened under the Endangered Species Act 

was based in large part on the Forest Service’s commitment to habitat protection. The USFWS was 

again petitioned to list C. l. ligoni as threatened in 2011. The 90-day finding was published on March 

31, 2014 (Federal Register 2014). The USFWS found that the petition presents substantial 

information indicating that listing the Alexander Archipelago wolf may be warranted. Therefore, 

when funding becomes available, the USFWS will conduct a status review to determine if listing the 

Alexander Archipelago wolf is warranted. A final determination is expected by the end of 2015. This 

90-day finding does not change the current status of wolves. 

On Revillagigedo Island Smith et al. (1987) identified one wolf pack, which he called East Chuck 

pack, between George and Carroll Inlets. Portions of three other packs identified by Smith et al. 

(1987) occur within WAAs 406/407: the Carroll Inlet pack on the east side of Carroll Inlet, the Town 

Pack near Ketchikan, and a suspected Naha River pack. 

No statistically reliable population estimates for wolves are available for GMU 1A, including WAAs 

406 and 407, but the wolf population appears to be stable based upon mandatory harvest reporting 

(Porter 2009a). Under either State or federal subsistence regulations, hunters may legally harvest five
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Saddle Lakes Timber Sale Final EIS Issue 3A – Wildlife Habitat - Chapter 3  95

wolves between August 1 and April 30 and an unlimited number of wolves may be trapped from 

November 10 to April 30. The most common methods of hunter/trapper access are by boat (81 

percent) and off-road vehicles (14 percent) (Porter 2009a). Legal harvest annually may annually 

remove up to 25–30 percent of the estimated wolf population; however, this estimate does not include 

illegal take, which has been estimated to be as much as 46 percent of wolf mortality on Prince of 

Wales Island (Person and Russell 2008). There is no data for illegal take estimates on Revillagigedo 

Island or the WAAs in the project area. Wolf hunting and trapping regulations fall under the 

jurisdiction of the Federal Subsistence Board (FSB) and ADF&G. ADF&G is currently analyzing the 

feasibility of intensive management (predator control) within portions of GMU 1A in an attempt to 

increase deer populations (Alaska Statutes AS 16.05.255(e)), but WAAs 406 and 407 are not currently 

included in that effort.

ADF&G has a management objective of at least 30 wolves a year being taken from GMU 1A (2012 

Harvest report). The 2012 harvest report indicates that in 2010 regulatory year 42 wolves were 

harvested from GMU 1A. The scale of GMU 1A is considerable larger than the project area or WAAs 

406 and 407. 

Wolves spend most of their time below 1,200 feet elevation regardless of season (Person et al. 1996, 

Person 2001). Wolves are a habitat generalist; but data from radio-collared wolves on Prince of Wales 

and Kosciusko Islands indicated that wolves avoided clearcuts, young-growth forests, and roads

(Person 2001). However, Person and Russell (2008) state that wolves are easily observed in open 

habitats such as grassy meadows, young clearcuts, and muskegs. No wolf dens were found during 

Saddle Lakes project area field review, but suitable habitat is present adjacent to the numerous lakes 

and streams.

The following three issues related to wolf conservation were identified in Person et al. (1996): 

1) decline in deer carrying capacity (deer density);

2) effect of roads on mortality and displacement; and

3) continued exploitation or overharvest of wolves.

Three similar global protection needs were identified in NatureServe (2012): 

1) minimize habitat fragmentation and protect integrity of high-use corridors to ensure

maintenance of gene flow between neighboring populations; 

2) close logging roads following timber harvest in areas important to the wolves and their prey;

and 

3) closely regulate wolf hunting and trapping to ensure long-term viability of the wolves.

Changes in deer habitat and roads are under the jurisdiction of the Forest Service. Wolf hunting and 

trapping regulations fall under the jurisdiction of the Federal Subsistence Board (FSB) and ADF&G.

Deer Density

Due to lack of population data, the deer model has been used as an indicator to assess the ability of an 

area to support deer populations capable of maintaining both sustainable wolf populations and 

meeting human harvest demands. Person et al. (1997) clarified that habitat capability of at least 18 

deer per square mile is needed to support wolves and deer hunter demand on a sustainable basis. Deer 

densities above five deer per square mile, in conjunction with old- growth reserves, were predicted to 
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96  Chapter 3 – Issue 3A – Wildlife Habitat Saddle Lakes Timber Sale Final EIS

maintain viable wolf populations on the Tongass (Suring et al. 1993 VPOP Strategy). Because WAAs 

406 and 407 contain extensive areas of NFS land above 1,500 feet in elevation, historic deer densities 

predicted by the model were 17 deer per square mile in WAA 406, and at 18 deer per square mile in 

407 (Table 24).

Over the years the deer model has been revised and updated several times. The 1997 model was 

revised due to the misuse of the conversion factor (called the “deer multiplier”) that caused an acrossthe-board 30 percent overestimation of carrying capacity. The multiplier was changed from 1.3 to 1.0. 

Another concern was that the vegetative dataset that was used (called VolStrata) has no correlation to 

habitat quality. This was also addressed and the current deer model uses the size density model 

(SDM) instead of VolStrata. 

A concern was then raised with this revised version that the results were invalid because the acres of 

non-federal lands in the WAAs were not included in the denominator when calculating the carrying 

capacity. The most current version of the deer model now includes all non-federal lands in the 

denominator when calculating carrying capacity; the multiplier of 1.0 and SDM. 

Wolf populations are closely tied to prey abundance (Person et al. 1996, MacDonald and Cook 2009). 

Sitka black-tailed deer are the principal prey of wolves in Southeast Alaska representing up to 77 

percent of their diet, but wolves also feed heavily on spawning salmon, beaver, moose, mountain 

goat, and voles (Person et al. 1996, Smith et al. 1987, Szepanski et al. 1999. Lowell 2009a). 

Wolf/Deer Interactions in Fragmented Habitat

Wolf predation can be a primary factor in controlling deer populations in Southeastern Alaska

(Farmer et al. 2006). McNay and Vollner (1995) found predation by wolves to be highly efficient in 

fragmented, heavily logged landscapes on Vancouver Island, British Columbia.

Suitable deer habitat plays an important role in maintaining the deer/wolf equilibrium. The stability of 

such an equilibrium is contingent on the availability of suitable habitat for deer, such that the deer 

population can maintain a rate of growth sufficient to offset losses to predation (Person et al. 1996). 

Interruption of deer/wolf equilibriums through events such as severe winters or reduction in the 

quality and quantity of suitable habitat may result in widely fluctuating wolf and deer populations 

(Person et al. 1996). Hanley et al. (2005) found a strong, inverse relation between home range size of 

wolves and the proportion of deep-snow winter habitat for deer. Similarly, there was a strong relation 

between wolf pack size and proportion of deer winter habitat within a home range, resulting in higher 

wolf densities where deer densities are high (Person 2001). Population reductions resulting from 

increased wolf harvest and habitat fragmentation may increase the isolation of island wolf packs and 

reduce their ability to survive and reproduce. 

Wolf Populations and Road Density

Forest Plan Standards and Guidelines (USDA Forest Service 2008c, WILD1.XIV, p. 4-95) state that 

total road densities of 0.7 to 1 mile per square mile or less may be necessary to address wolf mortality 

concerns where they have been determined through interagency analysis to exist.

Wolf mortality has not been identified as an issue in WAAs 406 and 407 in the past due in part to the 

lack of road access. However, since the proposed Ketchikan to Shelter Cove Road would connect the 

project area to the communities of Ketchikan and Saxman in the near future and could potentially lead 

to a wolf harvest concern, road densities below 1,200 feet in elevation were analyzed to determine the 

effect on potential wolf harvest (Table 24).
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Saddle Lakes Timber Sale Final EIS Issue 3A – Wildlife Habitat - Chapter 3  97

Table 24. Historic and original and existing deer densities and road densities on NFS Lands in the Saddle 

Lakes project area

WAA Habitat Historic

Density Current Density % Change

406

Deer Density1/ 17 13 -23%

Open Road Density2/ 0 0.68 N/A

Total Road Density2/ 0 1.40 N/A

407

Deer Density1/ 18 16 -11% 

Open Road Density2/ 0 0.63 N/A

Total Road Density2/ 0 0.93 N/A

Note: N/A = Not Applicable.

1/ Theoretical deer densities calculated from the deer model DHC. Actual deer population information not available. 

2/ Road densities include only NFS roads and lands below 1,200 feet in elevation; freshwater lakes not included. Total road 

densities include open, maintenance level 1(closed), and decommissioned roads.

Black Bear

Black bears (Ursus americanus) are the most abundant bear in Alaska (Schoen and Peacock 2007), 

but no population information is available for GMU 1A (including WAAs 406 and 407). Black 

bears, bear scat, and/or rooted-out skunk cabbage were observed during field review of the Saddle 

Lakes project area. Three bear dens were located and confirmed by an ADF&G wildlife biologist 

within the Saddle Lakes project area. A fourth suspected den was found by the timber crew, but 

needs to be confirmed. A young bear was observed in the vicinity of a historic den, but the den was 

not relocated. 

Using data from studies in western Washington, where black bear habitat is similar to that in GMU 

1A, black bear density in forested habitats across Southeast Alaska was estimated at 1.4 bears per 

square mile in 1990 (Bethune 2011). 

Bear Habitat

Black bears prefer mixed deciduous-coniferous forests with a dense understory, but occur in various 

habitats with estuaries, riparian areas, and old-growth forests providing the highest-quality habitat 

(Schoen and Peacock 2007). 

Information on the denning habits in Southeast Alaska is limited, but bears on Mitkof Island made 

exclusive use of large-diameter trees, snags, or hollow logs for their winter dens, presumably because 

heavy precipitation and the poorly drained soils rendered ground dens less suitable (Erickson et al. 

1982). Similar results were found by Davis et al. (2012) on northern Vancouver Island, British 

Columbia in that dens occurred in or beneath large diameter trees that provided thermal and security 

benefits. Davis et al. (2012) also found that bears often reused the same dens over multiple years, 

particularly in areas where thermally efficient den sites were limited. Re-use was partially dependent 

upon security from predators including other bears and wolves. Saddle Lakes identified denning 

habitat as POG at all elevations.

Young clearcuts, muskegs, small openings, and subalpine meadows provide high levels of forage 

(Schoen and Peacock 2007, USDA Forest Service 2008c p. 2-233). Bears frequent beaches during the 

spring to forage on grasses and sedges. In late spring, bears can be efficient predators of deer fawns.

During mid-summer, bears begin foraging on berries and make use of habitats (such as riparian forest, 

avalanche slopes, young clearcuts, and subalpine and alpine areas) that produce abundant berry crops 

(Schoen and Peacock 2007). Saddle Lakes identified foraging habitat as all habitats except stem

exclusion. 
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98  Chapter 3 – Issue 3A – Wildlife Habitat Saddle Lakes Timber Sale Final EIS

The use of salmon-spawning streams by bears in late summer and fall in Southeast Alaska is well 

documented. Not all bears utilize salmon streams; some remain at higher elevations and forage on

vegetation, deer, and small mammals. Impacts to POG within 500 feet of Class I streams were 

analyzed to address the importance of riparian habitat to black bear. Table 25 shows historic and 

existing bear habitat within WAAs 406 and 407 on National Forest System (NFS) lands. 

While it was not possible to accurately reconstruct historic large-tree POG available information

records indicate, and field reconnaissance confirms, that much of the historic harvested targeted

higher volume stands, but it is unknown what the specific volume breakdown was. The Forest Plan 

estimated that on NFS lands, 29 percent of the historic harvest was large tree SD67 POG (USDA 

2008 FEIS Appendix B p. B-30 ). The 29 percent was used to calculate an estimated historic amount 

of SD67 in the project area WAAs combined. Past harvest for WAA 406 and WAA 407 combined is 

28,964 acres. Assuming that 29 percent of these acres were SD67 equates to about 9,269 acres. 

Currently there are 5,998 acres of SD67 in the combined WAAs, a reduction of about 35 percent. 

Table 25. Existing bear habitat on NFS Lands in WAAs 406 and 407

WAA Habitat Historic (1954) 

Acres

Existing (2013) 

Acres

% 

Change

406

Denning Habitat1/ 61,321 48,982 -20%

Foraging Habitat2/ 122,385 110,046 -10%

POG within 500 feet of Class I 

streams 7,615 6,433 -16%

407

Denning Habitat1/ 19,789 17,946 -9%

Foraging Habitat2/ 41,146 39,303 -4%

POG within 500 feet of Class I 

streams 2,517 2,320 -8%

Combined

WAAs SD67 black bear habitat3/ 9,269 5,998 -35%

1/Denning = all POG at all elevations; 

2/Foraging = all habitats except stem exclusion; 

3/ Historic SD67 calculated assuming past harvest was 32 percent SD67 (Forest Plan FEIS p. 3-293) 

Mountain Goat

Mountain goats (Oreamnos americanus) inhabit rugged, mountainous habitats in western North 

America. In Alaska, mountain goats occur in coastal regions in Southeastern and Southcentral Alaska. 

They have also been introduced into non-native range including Revillagigedo Island where they are 

now firmly established (ADF&G 2013a). Revillagigedo Island transplants include Swan Lake (WAA

406) in 1983 and Upper Mahoney Lake (WAA 407) in 1991. 

Mountain goat populations are often small and geographically isolated. As a result, mountain goat 

population trends throughout Alaska vary considerably from place to place and from year to year. 

GMU 1A has an estimated 3,000 to 4,000 goats and the populations, except for Cleveland Peninsula, 

appear to be stable with healthy goat populations (Porter 2010a). Current regulations are one goat by 

registration permit only on the east side of Carroll Inlet, or one goat by drawing permit only on the 

west side of Carroll Inlet. Most hunter access to goats is by float plane into high-elevation lakes. A 

lone mountain goat was observed on the Lemon Lake road (NFSR 8337000) in October 2012. Goats 
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Saddle Lakes Timber Sale Final EIS Issue 3A – Wildlife Habitat - Chapter 3  99

are more frequently sighted at higher elevations adjacent to the project area, or at higher elevations on 

the east side of Carroll Inlet above Swan Lake.

Habitat

The quantity and quality of winter habitat is the most limiting factor for mountain goats in Southeast 

Alaska (USDA Forest Service 2008c, p. 3-232). High snowfall can result in substantially reduced 

survival of adult mountain goats (ADF&G 2013a). In Southeast Alaska, mountain goats commonly 

use POG when wet snow pack in the alpine zone forces goats down into more protected forests 

(ADF&G 2013a, Fox et al. 1989, Fox and Smith 1988). Fox et al. (1989) recommended that mountain 

goat travel corridors between important forested wintering sites be identified and maintained. Within 

Southeast Alaska, steep slopes that provide escape terrain generally accumulate the least amount of 

snow (Fox et al. 1989).

Smith (1986) found that over 95 percent of all radio-collared goat relocations in Southeast Alaska 

were within 1,300 of a cliff (defined as slopes greater than 50 degrees). Based upon discussion with 

USFS Wildlife Biologists B. Logan and T. Schenck in 2013 (pers. comm.), POG habitat within 1,300 

feet of slopes 50 degrees or greater was used as the definition of important goat habitat in the effects 

analysis, rather than 50 percent slope as listed in Forest Plan Standards and Guidelines (USDA Forest 

Service 2008b, WILD1.XV.A.3, p. 4-96). Historic and existing habitat is displayed in Table 26. 

Table 26. Historic and existing mountain goat habitat on NFS Lands in WAAs 406 and 407

WAA Historic Habitat (acres) Existing Habitat (acres) Percent Change

406 46,296 37,896 -18%

407 15,280 13,939 -9%

Source: USFS, Tongass National Forest GIS.

POG habitat within 1,300 feet of slopes 50 degrees or greater.

American Marten

American marten (Martes americana) were specifically considered in the design of medium-sized 

old-growth reserves (10,000 to 40,000 acres) under the Forest Plan Conservation Strategy (Suring et 

al. 1993; Flynn et al. 2004; USDA Forest Service 2008a). The Viable Population (VPOP) committee 

for the 1997 Tongass Forest Plan strongly recommended that conservation areas (i.e., OGRs) be 

connected by travel corridors so marten could move between protected habitat areas (Suring et al. 

1993). Natural populations of marten are found on Revillagigedo Island (MacDonald and Cook 

2007). Marten on Revillagigedo Island belong to the subspecies M. a. americana (Small et al. 2003b). 

Since there is no indication that Pacific marten (M. caurina) occur on Revillagigedo Island, M. 

caurina is not discussed further in this analysis.

ADF&G does not have population data for marten in GMU 1A. Marten abundance, as measured by 

densities and home range sizes, is known to vary spatially and temporally throughout Southeast 

Alaska, in association with habitat suitability, prey densities, and trapping pressure (Schoen et al. 

2007, Flynn and Schumacher 2009, Flynn et al. 2012). Pauli et al. 2012 found that most (72 percent) 

of the marten in their Southeast Alaska/Queen Charlotte Island study were residents, whereas the 

remaining 28 percent dispersed distances of 9 to 25 miles. The latter were generally young of the year 

or yearlings.

The marten model has not been used in recent analyses, and it was not used it for analysis in the 

Saddle Lakes project area for the following reasons: 1) selected winter high-POG habitat corresponds 
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100  Chapter 3 – Issue 3A – Wildlife Habitat Saddle Lakes Timber Sale Final EIS

to the highest HSI values from the model; 2) habitat loss was considered, based upon the available 

research, to be a more direct approach than including a “multiplier” to predict a “theoretical” number 

of marten. 

Trappers in Southeast Alaska are more interested in marten than other furbearer species since marten 

are easy to trap, pelts are easy to process, and pelt prices are generally higher (Porter 2010b). 

Trapping pressure generally fluctuates with pelt price and weather. Under the current State and 

federal subsistence regulations, there is no trapping limit for marten in GMU 1A. 

Marten are generalist predators and vary their diet seasonally based on available prey. Marten feed on 

small mammals year-round, and voles are the most common prey for marten range-wide (Flynn et al. 

2004; Poole et al. 2004; Potvin et al. 2000). Long-tailed voles, red-backed voles, salmon, and other 

small rodents are the most common species eaten by marten in Southeast Alaska (Flynn et al. 2004, 

Ben-David et al. 1997). However, squirrels, birds, deer carcasses, and intertidal organisms are utilized 

in years when preferred foods were not readily available (Flynn and Schumacher 2009).

Habitat

Marten in western temperate North America occur in coniferous forests and select moist stands with 

complex physical structure near the ground. Thompson and Harestad (1994) summarized 10 studies 

from across marten ranges documenting selection for overmature timber, and against pole sized or 

smaller stands. The association of marten with structurally complex forests is related to their need for 

avoiding predators, accessing prey beneath the snow, and finding protected microenvironments for 

resting in winter and for giving birth and sheltering newborn. 

Due to their body shape, they are energy constrained in the winter and select habitat structure that 

helps them to conserve energy (Buskirk and Powell 1994). In Southeast Alaska, habitat requirements 

reflect a strong interaction between food, cover, and climate, with forest cover being particularly 

important for travel, denning and resting sites, hunting, avoiding avian predators, and 

thermoregulation (Flynn et al. 2004). Consequently, the quantity and quality of winter habitat is a 

limiting factor for marten in Southeast Alaska (USDA Forest Service 2008c, p. 3-234). 

Within Southeast Alaska, marten prefer POG and tend to avoid NPOG and both younger and older 

clearcuts (Flynn 2006, Flynn & Schumacher 2001). Research on nearby Chichagof Island showed 82 

percent of marten use was in forested habitat. Marten selected large multi-storied and medium multistoried habitats during the winter with 63 percent of winter locations occurring at less than 820 feet 

elevation (Flynn and Schumacher 2001, Flynn 2004 Appendix B). However, Flynn and Schumacher 

recommended using 1,500 feet elevation for winter analysis due to the number of locations (32

percent) between 800 and 1,500 feet elevation. Additional marten research is currently underway on 

Kuiu Island (Flynn et al. 2012 and 2013 progress reports), but habitat selection analysis is not yet 

available.

Marten travel through other habitat types and include a wide range of habitat types in their home 

ranges (Flynn 2006, Buskirk 2002). Habitat use and movements are strongly related to the 

distribution and abundance of food. Structural habitat complexity enhanced, rather than diminished, 

the efficiency of predatory search by marten.

Marten Populations and Road Density

An increase in road access can increase trapping pressure on marten as they are easily trapped along 

roads accessible to vehicles (Flynn et al. 2004). Open roads receive the highest and most consistent 

use, and therefore are likely to have the greatest effect on marten. Closed roads facilitate walk-in 
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Saddle Lakes Timber Sale Final EIS Issue 3A – Wildlife Habitat - Chapter 3  101

access. Historic and existing marten habitat and road densities on NFS Lands by VCU are shown in

Table 27. 

Table 27. Historic and existing marten habitat and road densities1/ on NFS Lands by VCU

VCU Habitat Historic (1954) 

Acres or mi/mi2 Existing (2013) 

Acres or mi/mi2 Percent Change

7460

Winter2/ 12,541 7,317 -42%

Year-round3/ 19,869 14,493 -27%

Open Road Density 0 1.0 N/A

Total Road Density 0 2.2 N/A

7470

Winter2/ 5,548 4,064 -27%

Year-round3/ 9,388 7,903 -16%

Open Road Density 0 0.7 N/A

Total Road Density 0 1.2 N/A

7530

Winter2/ 10,250 5,637 -45%

Year-round3/ 17,073 12,433 -27%

Open Road Density 0 0.7 N/A

Total Road Density 0 1.5 N/A

Source: USFS Tongass National Forest GIS. N/A = Not Applicable

1/ Includes only NFS total road density and lands below 1,500 feet in elevation; lakes not included in the area calculation. Total 

road densities include open, maintenance level 1(closed), and decommissioned roads.

2/ Winter habitat equals high-POG less than or equal to 1500 ft. elevation.

3/ Year-round habitat equals POG, all elevations.

Brown Creeper

The brown creeper (Certhia americana) is an uncommon year-round resident that is widely 

distributed throughout Southeast Alaska and the Tongass National Forest (Heinl and Piston 2009). 

Although widespread, this species can be difficult to detect and monitor due to its small size and

cryptic coloration, as well as its low volume, high-pitched call. Quantitative data on the abundance of 

brown creepers in the Tongass National Forest is lacking. Long-term (1966 to 2011) breeding bird 

survey data show a slightly positive trend for Alaska, but data should be used with caution due to 

small detection rates and limited samples (Sauer et al. 2012). 

Habitat

Brown creepers depend on cavities in the large-diameter snags characteristic of old-growth stands in 

Southeast Alaska (Cotter 2007b, ADF&G 2005, Andres et al. 2004, Stotts et al. 1999, DellaSalla et al. 

1996) and elsewhere (Poulin et al. 2013). Brown creepers forage primarily on trunks of live, large 

trees greater than 39 inches diameter at breast height (dbh) suggesting this species is an old-growth 

obligate (Kissling, et al., Forest Bird Presentation, Conservation Strategy Meeting, 2006). The 

preference for old-growth forests appears to be correlated with the abundance of snags and largediameter live trees with sloughing or thick bark for nest sites, and with structural components and 

microclimate (Poulin et al. 2013, Poulin et al. 2008, and Wiggins 2005). 

Studies across the US and Canada have found that brown creepers are negatively affected by edge, 

and that densities are consistently lower in edge habitat (Poulin et al. 2013, Wiggins 2005, Hejl et al. 

2002). Studies by Poulin et al. (2008) in New Brunswick, Canada, found that 62 percent of brown 

creeper nests were located greater than 328 feet from edges, with the average distance 470 feet. 
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102  Chapter 3 – Issue 3A – Wildlife Habitat Saddle Lakes Timber Sale Final EIS

Kissling and Garton (2008) found similar edge effects on brown creepers within Southeast Alaska 

based on a limited number of detections.

Interior habitat is based upon edge effect distances in Concannon (1995). Historic and existing 

interior habitat is shown for NFS lands in Table 28. 

Table 28. Historic and existing brown creeper interior POG on NFS lands, Saddle Lakes project area

VCU Historic Acres Existing Acres Percent Reduction

VCU 7460 10,885 3,050 -72%

VCU 7470 4,469 2,417 -46%

VCU 7530 7,832 2,493 -68%

Source: USFS Tongass National Forest GIS.

Interior habitat based upon edge effect distances in Concannon (1995).

Hairy Woodpecker

Hairy woodpeckers (Picoides villosus) are a widely distributed permanent resident throughout 

Southeast Alaska (Heinl and Piston 2009). Hairy woodpeckers were recorded on 83 percent (10 of 12) 

of BBS routes on the Tongass, and occurred at an estimated density of 0.1 bird per acre (Cotter 

2007b). But this data should be used with caution due to small detection rates and limited sample size. 

Hairy woodpeckers were observed in Unit 47, and occasionally seen or heard elsewhere in the project 

area.

Habitat

Hairy woodpeckers rely on dead and decaying trees, both standing and fallen, for nesting, foraging, 

and roosting. Consequently, they are sensitive to timber-harvest activities that decrease the abundance 

of these large trees (Cahall and Hayes 2009). They are primary cavity excavators for other cavitydependent wildlife species (Walters et al. 2002). Their abundance seems to be correlated with 

increasing snag density, proportion of large snags, and heartwood decay (Ripper et al. 2007, Saab et 

al. 2009). 

Table 29. Historic and existing hairy woodpecker habitat and patch size

VCU Historic Acres Existing Acres Percent Reduction

Historic and Existing hairy woodpecker habitat on NFS lands by VCU

VCU 7460 14,358 8,982 -37%

VCU 7470 5,946 4,461 -25%

VCU 7530 10,909 6,268 -43%

Hairy Woodpecker Habitat Patch Size, All Ownerships –combined WAAs 406 and 407

# of patches ≥500 acres 13 19

Total acres in patches ≥500 acres 87,956 63,812 -27.5%

Average size of patches ≥500 acres 6,766 3.359 -50.4%

Source: USFS Tongass National Forest GIS. Habitat is high-POG at all elevations. 

High-volume, western hemlock or Sitka spruce old-growth forests receive more use in the Tongass 

National Forest than medium- or low-volume stands or cedar (Hughes 1985, USDA Forest Service 

2008c pp. 3-231 & 3-240). Habitat patches greater than 500 acres are thought to provide optimal 
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Saddle Lakes Timber Sale Final EIS Issue 3A – Wildlife Habitat - Chapter 3  103

habitat (USDA Forest Service 2008c p. 3-240). Effects to hairy woodpeckers were analyzed on highPOG at all elevations and POG habitat in patches > 500 acres. Historic and existing habitat is 

displayed in Table 29. 

Red-breasted Sapsucker

The red-breasted sapsucker (Sphyrapicus ruber) is a common, primary cavity excavator that depends 

on soft, decaying wood in snags and partially dead trees for nesting and foraging. The species is 

widely distributed throughout Southeast Alaska forests during the spring, summer, and fall seasons 

and is a documented breeder on Revillagigedo Island (Heinl and Piston 2009). 

Approximately 32 percent of the global population of red-breasted sapsuckers breed in Southeast 

Alaska (Kissling et al., Forest Bird Presentation, Conservation Strategy Meeting, 2006). Relatively

little quantitative data are available on the abundance of red-breasted sapsuckers on Revillagigedo 

Island. Long-term breeding bird survey data (Sauer et al. 2012) shows a slightly positive trend for 

Alaska (7 percent increase), but data is based on small detection rates and limited sample size. Redbreasted sapsuckers were frequently observed or heard during Saddle Lakes field surveys. Redbreasted sapsucker nests were found near Units 51, 201, and 240. 

Habitat

Red-breasted sapsuckers prefer late-successional forests (greater than 200 years old) with high 

densities of large snags (Joy 2000, Kissling and Garton 2008, DellaSalla et al. 1996). Wagner (2011) 

found that tree size and presence of fungal infection (visible conks) were good indicators of nest tree 

selection by red-breasted sapsuckers in Southeast Alaska.

In Southeast Alaska, red-breasted sapsuckers are associated with low- to moderate-volume oldgrowth forest (Hughes 1985) that should be in patches greater than 250 acres (USDA Forest Service 

1997b, p. 3-357). The Saddle Lakes project identified red-breasted sapsucker habitat as low and 

medium POG. Historic and existing habitat is displayed in Table 30. 

Table 30. Existing red-breasted sapsucker habitat on NFS lands by VCU

VCU Historic Acres Existing Acres Percent 

Reduction

Red-breasted sapsucker habitat on NFS lands by VCU

VCU 7460 5,512 5,512 0%

VCU 7470 3,442 3,442 0%

VCU 7530 6,165 6,165 0%

Red-breasted Sapsucker Habitat Patch Size, All Ownerships-Combined WAAs 406 and 407

# of patches >250 acres 17 32

Total acres in patches 

≥250 acres 89,131 68,107 -23.6%

Average size patches 

≥250 acres 5,243 2,128 -59.4%

Source: USFS Tongass National Forest GIS.

Habitat is medium-POG (SD4N,SD4S, SD5H) and low-POG (SD4H).

Patch size source: GIS, pogpatch082313.xlsx
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104  Chapter 3 – Issue 3A – Wildlife Habitat Saddle Lakes Timber Sale Final EIS

Red Squirrel

Red squirrels (Tamiasciurus hudsonicus) are common in Alaska and are endemic in the coastal 

mainland of Southeast Alaska, and islands in the Alexander Archipelago south of Fredrick Sound and 

east of Clarence Strait (MacDonald and Cook 2007). No population densities are available on 

Revillagigedo Island, but Smith (2012) found average densities of 0.8 and 1.5 squirrels per acre 

during spring and autumn, respectively on nearby Mitkof Island. Under the current State and federal 

subsistence regulations, there is no harvest limit for squirrels in the GMU 1A and no closed season.

Habitat

Red squirrel population density is strongly correlated with the density of large trees and snags, which 

may limit breeding females. Old-growth forests, particularly spruce trees, provide the highest value 

habitat since they contain higher densities of cavities and interlocking branches for homesites, and 

produce important cone seeds for squirrels (Cook, et al. 2006). Red squirrels can live in younggrowth stands that have reached seed-producing age (i.e., 30 to 40 years, Burns and Honkala 1990), 

but seed crops may be unreliable at this age and stands do not provide the snags and downed logs 

necessary for food caching and reproduction until at least 100 years of age (Suring 1988). 

Koprowski (2005) summarized information showing that squirrel population dynamics appear to be 

closely associated with cone abundance. Red squirrel habitat is identified as POG at all elevations. 

Historic and Existing red squirrel habitat is displayed in Table 31. 

Table 31. Existing red squirrel habitat on NFS lands by VCU

VCU Historic Acres Existing Acres Percent Reduction

VCU 7460 19,869 14,493 -27%

VCU 7470 9,388 7,903 -16%

VCU 7530 17,073 12,433 -27%

Source: USFS Tongass National Forest GIS.

Habitat is all classifications of POG at all elevations.

Other Wildlife Species of Interest

Other wildlife species of interest selected for detailed project analysis and the rationale for their 

selection are displayed in Table 32. Impacts to their preferred habitat(s) would occur during project 

implementation since harvest activities in POG alter stand structure and diversity. Effects for many 

species continue and/or intensify long-term as harvested stands enter into the stem exclusion phase. 

Endemic small mammals are discussed below. Herons, raptors, and murrelets and neotropical birds 

are analyzed in detail in the Wildlife Resource Report located in the project record. 

Table 32. Selected other species of interest (OSI) in the Saddle Lakes project area

Species Basis for OSI Selection, 

habitat preference

Associated POG Habitat Project 

Level Indicator/Measurement

Southern red-backed 

Vole (Myodes gapperi 

solus) 

Endemic small mammal most 

likely to be affected by timber 

harvest; important prey 

species.

Acres of POG 
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Saddle Lakes Timber Sale Final EIS Issue 3A – Wildlife Habitat - Chapter 3  105

Endemic Small Mammals

Endemic species are distinct, unique species with a restricted area or range (Schoen et al. 2007b). 

Southeast Alaska has been found to be a region with an especially high degree of endemism in its 

small mammal fauna. This is apparently due to its archipelago geography and its highly dynamic 

glacial history. Mammal surveys on the Tongass have resulted in the documentation of new 

distributions, new species, and distinct populations. There are currently 24 mammal species or 

subspecies considered endemic to Southeast Alaska (Cook et al. 2001). However, there continue to be 

gaps in knowledge about the natural history and ecology of wildlife subspecies indigenous to 

Southeast Alaska (Hanley et al. 2005). The proportion of endemics decreases from the outer islands in 

the archipelago eastward toward the inner islands nearer the mainland with the pattern more 

pronounced in the southern part of the archipelago (MacDonald and Cook 2007). Consistent with this 

pattern, Revillagigedo Island was mapped fairly low on the biodiversity hotspot scale (Cook et al. 

2006, ISLES website). 

No small mammal surveys were conducted specifically for the Saddle Lakes project. However, 

endemic small mammal surveys were completed on Revillagigedo Island, including the Saddle Lakes 

area, by MacDonald and Cook as part of the ongoing ISLES project (Cook and MacDonald 2013a). 

Five small mammal species were collected at the Shelter Cove site: dusky shrew, cinereus shrew, 

northwest deermouse, meadow jumping mouse, and southern red-backed vole. An additional species, 

long-tailed vole, was collected at the head of Carroll Inlet.

Revillagigedo Island Southern Red-backed Vole

The southern red-backed vole (Myodes gapperi solus) is the only endemic small mammal restricted to

Revillagigedo Island; (MacDonald and Cook 2011, MacDonald and Cook 2007; Smith 2005). No 

population data is available for this species. 

Habitat

No habitat studies have occurred related to the Revillagigedo Island red-backed vole. The best 

information on red-backed voles in Southeast Alaska comes from nearby Wrangell Island (Smith and 

Nichols 2004, Smith et al. 2005) where studies were conducted on the Wrangell Island red-backed 

vole (Myodes gapperi wrangeli) association with old growth. Unlike studies elsewhere, vole densities 

were not consistently higher in old growth but varied between years and were likely influenced by 

overall population density (Smith et al. 2005). Habitat features that were correlated with vole density 

included the amount of down, decayed wood and the cover of surface water during spring (Smith et 

al. 2005, Hanley et al. 2005). 

Young-growth supported a higher proportion of the population during a high density year than the 

following years when overall densities were much lower. Vole densities in young-growth showed 

substantially greater variation among years and average body mass and reproductive rates were lower 

with minimal evidence of juvenile recruitment into the population (Smith and Nichols 2004, Smith et 

al. 2005). As a result, Smith and Nichols (2004) questioned whether young growth could sustain 

breeding populations in intensively managed landscapes. Smith et al. (2005) found that vole densities 

in old-growth declined the least between years indicating that it was the highest-quality habitat and 

that regenerating young growth was a dispersal sink. 

Sullivan and Sullivan 2011 found substantially more red-back voles in partially cut stands than in 3 to 

20 year old clearcut stands in British Columbia, but their sites were drier than sites in Southeast 

Alaska. Because densities and reproductive rates were highest in POG forest, and questions remain on 

young-growth, POG was selected as the measurement criteria for red-backed voles.
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106  Chapter 3 – Issue 3A – Wildlife Habitat Saddle Lakes Timber Sale Final EIS

Threatened, Endangered, Candidate, and Sensitive Species

A review of all federally listed threatened, endangered, and candidate fish and wildlife species within 

Alaska and Alaska Region (USFS R10) sensitive species was completed. Existing survey data, GIS 

layers and databases, research, literature reviews, and information in the 2008 Forest Plan FEIS 

(USDA Forest Service 2008d, Appendix F, pgs. F-1 to F-16) were used for analysis. 

Species not occurring within Southeast Alaska inside waters and/or the southern portion of the 

Tongass National Forest were dropped from further analysis. Species potentially occurring within the 

Saddle Lakes area (Table 33) are analyzed in detail in the Biological Assessment/Biological 

Evaluation (Reeck 2013) located in the project record. There is no critical habitat designated within or 

adjacent to the Ketchikan-Misty Fiords Ranger District (KMRD) or the Saddle Lakes project area. 

Humpback whales and Steller sea lions inhabit the marine waters adjacent to the Saddle Lakes project 

area. Yellow-billed loons nest exclusively in arctic tundra (USFWS 2006), but winter range includes 

the coastal waters of southern Alaska. A detailed discussion of the Queen Charlotte goshawk is 

provided below because this species is associated with the old-growth forest ecosystem and affected 

by timber management. 

Table 33. Threatened, endangered, candidate, and sensitive species occurring in the Saddle Lakes 

project area or nearby vicinity

Common Name Scientific Name Status 

Humpback whale Megaptera novaeangliae Endangered

Steller sea lion (Eastern DPS) Eumetopias jubatus Delisted / R10 Sensitive1/

Yellow-billed loon Gavia adamsii Alaska Region 10 Sensitive 

Species

Queen Charlotte goshawk Accipiter gentilis laingi Alaska Region 10 Sensitive 

Species

1/ The Steller sea lion eastern Distinct Population Segment (DPS) was delisted under the Endangered Species Act effective 

December 4, 2013 (Federal Register Vol. 78, No. 213). Members of the endangered Western DPS have been documented in 

northern Southeast Alaska but rarely occur south of Fredrick Sound and would be unlikely to occur in the Saddle Lakes project 

area (NMFS 2013).

2/ Yellow-billed loon (Gavia adamsii) was added as a candidate species (March 2009). A determination of “no effect” was 

made for yellow-billed loons due to incidental occurrence and lack of its habitat disturbance. Since that time, on October 1, 

2014, the USFWS issued a 12-month finding on the petition to list the yellow-billed loon, and determined that listing as a 

threatened or endangered species is not warranted (79 FR 59195-59204).

Queen Charlotte Goshawk

The Queen Charlotte goshawk (Accipiter gentilis laingi), a subspecies of the northern goshawk, is 

identified as a species of concern throughout its range and is identified as a sensitive species by the 

Forest Service, Alaska Region (USDA Forest Service 2009). The Queen Charlotte subspecies 

(hereafter goshawk) occurs on the Queen Charlotte Islands and Vancouver Island in British Columbia 

and from the Alexander Archipelago in Alaska north to Prince William Sound. Recent goshawk 

population analysis by Sonsthagen et al. (2012) has identified Revillagigedo Island (REV cluster) as a 

short-term, long-term, and historic population sink with high immigration from Admiralty Island and 

coastal British Columbia.

Habitat

In Southeast Alaska, goshawks preferentially use high-volume old-growth forest, followed by 

medium-volume old-growth forest and avoid non-forested, clearcut, and regenerating areas (Smith 

2013, Federal Register 2007). Within the 20 to 30 acres immediately surrounding nests, 89 percent of 
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Saddle Lakes Timber Sale Final EIS Issue 3A – Wildlife Habitat - Chapter 3  107

nests were located in high-POG stands with relatively dense, multi-storied canopies (Lewis et al 

2003, McClaren 2004, and Doyle 2006 as cited in USDA Forest Service 2008c, p. 3-227). Nest trees 

tend to be located in the least fragmented area of individual home ranges (USFWS 2007). Nests 

generally do not occur above 1,000 feet elevation (Titus et al. 1994). Nesting areas in Southeast 

Alaska can be 2,500 acres in size (Flatten et al. 2001). The Saddle Lakes analysis identified goshawk

nesting habitat as high and medium-POG ≤1,000 feet elevation and foraging habitat as POG ≤1,000 

feet elevation.

Predominant prey items during the breeding season (red squirrel, Steller’s jay, grouse, varied thrush, 

and woodpeckers) are species most abundant or occur exclusively, in old-growth forest. As a result, 

goshawks rely almost entirely on POG as foraging habitat (Smith 2013).

No nests have been found in the Saddle Lakes project area despite repeated surveys over multiple 

years. Goshawk nests can be difficult to locate (Flatten et al. 2001). Nesting activity varies yearly in 

response to prey and weather with territory occupancy lower in fragmented forest than in contiguous 

forest (USFWS 2007). Two goshawk sighting were recorded in 2012. One occurred near the Shelter 

Cove LTF in early spring and another occurred near North Saddle Lake in October. These areas were 

surveyed multiple times with no response. The sighting in October is past the known breeding of 

goshawks. The Forest Plan Standards and Guidelines say that for a probable nest 1) aggressive, 

territorial breeding season adults vocalizing or attacking an observer (without locating a nest) or 2) 

adults observed during the breeding season in a territory and recently fledged young were observed 

(without locating a nest). Neither of these criteria was met. 

No goshawk sightings occurred in the project area in 2013.

Environmental Consequences

Actions Common to All Alternatives

Ketchikan to Shelter Cove Road State of Alaska Right-of-Way on NFS Land

The State of Alaska right-of-way (ROW) (see Chapter 2) needed to construct the Ketchikan to Shelter 

Cover road impacts about 40 acres of NFS land. About 0.3 mile of road could be constructed within 

the small OGR in VCU 7470. New road construction is generally inconsistent with Old-growth 

Habitat LUD objectives, but new roads may be constructed if no feasible alternative is available

(USDA Forest Service 2008b, TRAN A, p. 3-61). Road survey engineers were aware of the restriction 

of roads in OGRs and spent considerable time attempting to avoid the OGR. The road was moved out 

of the OGR as much as feasible. However, topography prevented alternative road locations. 

The ROW, and construction within the ROW, would have minimal effect on wildlife habitat due to 

the limited acres involved. Disturbance from construction activities would be temporary in nature. 

Effects of the additional road construction on road density are discussed in the Wolf and Marten MIS 

sections. Effects of the Ketchikan to Shelter Cove Road on wildlife from increased public access are 

discussed by species under cumulative effects in the MIS.

Fish Passage Barrier Modification

All action alternatives include a partial-barrier modification to improve upstream access to coho

salmon and steelhead runs in lower Salt Creek. Blasting would be used to produce steps and resting 

pools. Disturbance would be temporary (i.e. limited to the blasts) and limited to the immediate 

blasting area. Bald eagle timing restrictions are not required since the proposed blasting is over 1⁄2 
3 Affected Environment and Environmental Consequences

108  Chapter 3 – Issue 3A – Wildlife Habitat Saddle Lakes Timber Sale Final EIS

mile from the closest nest. Barrier modification is not expected to have measurable effects on wildlife 

species or habitat.

Biodiversity

Impacts to old-growth habitat occur immediately after project implementation. This short-term 

change occurs as harvested stands begin to regenerate (stand initiation phase, 0 to 25 years). Effects 

continue long-term as harvested stands enter into the stem-exclusion phase (26 to 150 years) where 

dense regeneration tends to shade out all understory habitat. Young-growth thinning can delay the 

onset of stem exclusion or temporarily improve low light conditions, but thinning benefits typically 

last 15 to 20 years (Alaback 2010, Cole 2010, McClellan et al. 2014). 

Reductions in productive old-growth (POG) habitat and resultant effects on many Tongass wildlife 

species may persist for 150 -300 years. The decline in old-growth habitat from timber harvest and 

road construction is considered an irreversible commitment (USDA Forest Service 2008b p. 3-2). The 

current management practice of re-harvesting managed stands within 100 years of the first harvest 

“has the potential to permanently change the disturbance regime of these forests from long-term gap 

dynamics (with dominant trees persisting an average of 300 to 500 years or more) to more frequent 

stand-replacing disturbance. A key ecological consequence of these short-duration disturbance cycles 

is the elimination of late-successional habitats” (Alaback et al. 2013). A forest with greatly increased 

frequency of major disturbance may at a certain point experience local extirpation of species that 

depend on the structural and functional components of old-growth (Orians et al. 2013). 

Table 34. Changes to POG by alternative and WAA

Acres (% reduction from existing)

Historic Existing 

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

WAA 406 61,321 48,982 47,873 48,626 47,756 47,441 47,934

(-2.3%) (-0.7%) (-2.5%) (-3.1%) (-2.1%)

WAA 407 19,789 17,946 17,169 17,478 17,093 16,852 17,179

(-4.3%) (-2.6%) (-4.8%) (-6.1%) (-4.3%)

WAAs

406 & 407 81,110 66,928 65,042 66,104 64,849 64,292 65,114

(-2.8%) (-1.2%) (-3.1%) (-3.9%) (-2.7%)

Old growth Reserves

The Forest Plan, Appendix K provides that under limited circumstances, a line officer may decide to

modify the size and location of an OGR. One of the reasons is if the OGR will be affected by land 

conveyance, power line, mine or other project that was not considered in the Forest Plan (Appendix 

K, p. K-2). The dismissal of the Tongass exemption to the 2001 Roadless Rule, which affects 48 

percent of the project area, was not considered by the 2008 Forest Plan and falls under this category. 

In response to scoping comments, the Responsible Official requested a project-level review of the 

VCU 7470 small OGR that included an option for relocating the OGR into the North Revilla 

Inventoried Roadless area (IRA). 

The project-level review was conducted on March 12, 2013, by an Interagency Review Team (IRT) 

comprised of USFWS, ADF&G, and Forest Service biologists. The IRT reviewed the existing OGR 

and developed one option entirely within the North Revilla Inventoried Roadless Area, and two 

hybrid options that were partially within roadless. The detailed 2013 Saddle Lakes OGR Report is 
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Saddle Lakes Timber Sale Final EIS Issue 3A – Wildlife Habitat - Chapter 3  109

located in the project record. The existing OGR is in the biologically preferred interagency location

(IOGR). During the 2008 Forest Plan review process the rationale for current location of the VCU 

7470 OGR was that it include a large block of POG and volume class 6/7 habitat, and provide 

connectivity between the Naha LUD II area and the low-elevation beach fringe POG in the George 

Inlet Salt Chuck. This review also acknowledged that the quality wildlife habitat around the salt 

chuck was on non-National Forest System land. 

Acreage requirements for the OGR are based on the acres of NFS lands within VCU 7470. The only 

OGR criteria with actual acreage requirements are the total OGR acres and POG acres. All other 

criteria are more subjective. The Roadless OGR option summarized below was selected by the 

Responsible Official to carry forward for analysis in Alternative 5.

Roadless OGR Option 

A majority of the existing VCU 7470 OGR is already located within the North Revilla Inventoried 

Roadless Area. The proposed Roadless OGR retains this portion in its entirety and proposes to 

remove the roaded acres currently included in the OGR and replace these acres with Roadless acres. 

The Roadless OGR eliminates both the early seral (young-growth) habitat acres and road miles 

(Appendix K criteria) and results in reduced total OGR and POG acres. It also results in the reduction 

of several biological criteria described below and summarized in Table 35. 

• It reduces the connection between the Naha LUD II and George Inlet Salt Chuck by clearcutting

units 301 through 308 and 310 through 312. Partial harvest units along the Salt Creek stream

corridor would minimize further reductions to this connection. Some connectivity would be

maintained by the Class I stream buffer on Salt Creek. The presence of State land located around

the north end of George Inlet already interrupts the connection between the Naha LUD II area and

the wildlife habitat around the salt chuck at George Inlet.

• It contains a smaller percentage of the largest remaining block of POG within the VCU;

• It reduces the amount of low-elevation, large tree and HPOG; and winter and nesting habitat;

• It reduces the amount of Class I riparian habitat; and

• It excludes the known Alaska Region sensitive plant populations. The presence of sensitive plant

populations within the Roadless OGR is currently unknown since surveys have not been

conducted.

The Ketchikan to Shelter Cove road is identified in the AK DOT&PF Southeast Alaska

Transportation Plan and is identified in the Forest Plan as a transportation and utility system (TUS)

overlay LUD. The TUS overlay LUD takes precedence over any underlying LUD. New road

construction is generally inconsistent with Old-growth Habitat LUD objectives, however new roads 

may be constructed if no feasible alternative is available (USDA Forest Service 2008b, TRAN A, p. 

3-61). Topography, including deeply incised drainages, can preclude alternative locations. Although 

the road was located to the extent feasible outside of the existing OGR, a small section of this road 

would be located in the existing Forest Plan OGR under alternatives 2, 3, 4 and 6, resulting in direct 

road access to this OGR. 

Under Alternative 5, the road would be located outside of the proposed Roadless OGR. The location 

of the road in relation to the Roadless OGR under this alternative would eliminate direct road access 

to the OGR and the OGR would be more isolated resulting in less impact to wildlife and important 

wildlife habitat associated with the OGR.
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110  Chapter 3 – Issue 3A – Wildlife Habitat Saddle Lakes Timber Sale Final EIS

Table 35. Old Growth Reserve (OGR) Criteria for Small OGR in the Saddle Lakes Project Area 

Forest Plan Appendix K Requirements

Required Minimum total OGR acres1/ 2,534

Required minimum POG acres2/ 1,267

Existing OGR 

(Alts 2,3,4,5)

Roadless OGR 

(Alt 5)

Total OGR acres 3,225 (+691) 2,852 (+318)

POG acres 2,182 (+915) 1,941 (+674)

Acreage requirements Exceed Exceed

Appendix D General Design Criteria7/- No specific acre/mile requirements

Circular rather than linear to maximize interior 

habitat/minimize fragmentation Yes Yes

Minimizes roads (total miles)3/ 2.6 0 

Minimizes early seral habitat (acres) 80 0 

Riparian/beach/estuary habitats (Class I stream 

miles) 5.6 mi 4.9 mi

Includes largest remaining block of POG in 

VCU? Yes Yes

Rare/Underrepresented features (rare or 

sensitive plants) 4 0 

Deep snow deer winter habitat (acres)4/ 864 657

Marten winter habitat (acres)5/ 1,248 1,086

Goshawk nesting habitat (acres)6/ 989 794

Murrelet nesting habitat SD67 (acres) 174 149

Other Considerations-Project/OGR Specific

Connectivity Yes No

Low elevation POG <800’ (acres) 1,360 1,059

N/A = Not Applicable.

1/ Small OGRs are a contiguous landscape of at least 16 percent of the National Forest System land area of each VCU. 

2/ At least 50 percent of the small OGR should be productive old growth.

3/ 1.8 miles of current mainline and planned State ADOT Ketchikan Shelter Cove Road system within or adjacent to OGR.

4/ HPOG < 800 feet in elevation, on south aspect.

5/ HPOG < 1,500 feet in elevation.

6/ HPOG and medium-POG ≤1,000 feet elevation

7/ Appendix D describes additional design criteria and assumptions used to design the OGRs system.

Comparable Achievement Determination of Roadless OGR 

Determination of comparable achievement of Old-growth LUD goals and objectives is based on 

Forest Plan Old growth Habitat Goals and Objectives and must consider the criteria listed in 

Appendix K (Forest Plan p. 3-62, WILD1B) and a review of additional OGR design criteria provided 

in Appendix D of the 2008 Forest Plan Final EIS (USDA Forest Service 2008b). 

The Roadless OGR meets the goals and objectives of the Old Growth habitat LUD by maintaining 

areas of old growth forest and their associated natural ecological process and providing habitat for 

old-growth associated resources. The Roadless OGR provides habitat, in conjunction with other 

non-development LUDs, to maintain viable populations of native and desired non-native species 
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Saddle Lakes Timber Sale Final EIS Issue 3A – Wildlife Habitat - Chapter 3  111

and subspecies associated with old growth forests (population viability is determined at the scale of 

the Tongass National Forest and not at the project level). 

The Roadless OGR also contributes to the habitat capability of fish and wildlife resources to support 

sustainable human subsistence and recreational uses and maintains components of flora and fauna 

biodiversity and ecological processes associated with old-growth forests. The Roadless OGR does not 

contain any early seral conifer stands, roads or facilities. All criteria listed in Appendix K were 

considered in the Roadless OGR. Appendix K criteria include that small reserves are a contiguous 

landscape of at least 16 percent of the National Forest System land area of each VCU and at least 50 

percent of the small reserve should be productive old growth. The Roadless OGR exceeds these acre 

requirements (+318 total acres and +674 acres of POG). Appendix K states the size and location of 

small OGRs will consider the following: 

• OGRs shall contain a minimum of 400 acres of productive old-growth forest. Do not map isolated

reserves with less than 400 acres of productive old growth. The Roadless OGR contains 1,941

acres of POG (+674).

• The preferred biological objective is for each reserve to contain at least 800 acres of productive

old-growth forest. The Roadless OGR has 1,941 acres of POG.

• VCUs that are partially allocated to a Non-development LUD - compare the computed acreage

required to the acres of productive old growth in the Non-development LUD. If the Nondevelopment LUD acres are less than the area necessary for a small reserve, first use the

productive old growth acres in the existing Non-development LUD to establish a small reserve,

and then add additional acres of productive old growth to achieve the required small reserve size

and composition. The Roadless OGR uses the old growth acres in the IRA to establish the small

OGR.

• VCUs that are separated by saltwater channels - reserves may be separated, but attempt to

retain 800 acres of productive old growth in each. This does not apply to VCU 7470.

• In very large VCUs, generally larger than 10,000 acres, the allocated old growth may be mapped

in separate reserves as long as each reserve has a minimum of 800 acres of productive old growth.

However, larger contiguous reserves are preferred to multiple smaller reserves. This does not

apply to VCU 7470. In very large VCUs that contain relatively little productive old growth and

the computational rule requires an amount of productive old growth that exceeds 50 percent of

the existing productive old growth in the VCU, map a reserve of at least 400 acres of productive

old growth. This does not apply to VCU 7470.

• VCU boundaries do not match watershed or ecological boundaries - up to 30 percent of the

allocated old growth acres in a VCU may be mapped in an adjacent VCU if the resulting reserve

achieves old-growth reserve objectives. The resulting small reserve in both VCUs must be

contiguous. Total acreage is attributed to the VCU with 70 percent of the OGR. This does not

apply to VCU 7470.

Appendix K also states to review Appendix D of the Forest Plan FEIS which include the general 

design criteria for OGR. These general criteria include the following: 

• The OGR be circular rather than linear, the Roadless OGR is circular.

• The OGRs should minimize roads and young-growth and the Roadless OGR contains no roads or

young-growth.
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112  Chapter 3 – Issue 3A – Wildlife Habitat Saddle Lakes Timber Sale Final EIS

• To include riparian, beach and estuary habitat, but does not include any specific acre requirements

for this criterion. The Roadless OGR contains riparian habitat but not beach or estuary habitat

(the Forest Plan OGR does not contain beach or estuary habitat either).

• To include the largest block of POG but again it does not include any specific acre requirements

for this criterion. The Roadless OGR does contain the largest block of POG in the VCU, just

fewer acres than the exiting Forest Plan OGR.

• Rare or underrepresented features (such as sensitive plants) should be included; The Roadless

OGR does not include the known sensitive plant population that were included in the Forest Plan

OGR; however no plant surveys have been conducted in the Roadless OGR so it is unknown if

populations of these and other sensitive or rare plants are in the Roadless OGR.

• To include deep snow deer winter range. However, there are not specific acre requirements for

this criterion. The Roadless OGR does include deep snow deer winter range.

• To include marten habitat. However, there are not specific acre requirements for this criterion.

The Roadless OGR does include marten habitat.

• To include known or potential goshawk and murrelet nesting habitat. However, there are not

specific acre requirements for this criterion. The Roadless OGR does include potential nesting

habitat for both goshawks and murrelets.

Appendix D (p. D-8) states that there is no requirement to ensure connectivity among all small OGRs 

or between small OGRs and non-development LUDs (which form parts of large and medium OGRs) 

and used the following parameters to ensure OGRs maintained connectivity:

• Only one connection in one direction was necessary

• The beach fringe serves as a connector

• The connection did not have to be the shortest distance

The medium OGR in Carroll Inlet is in VCU 7460, which contains both a medium and small OGR. 

These OGRs are separated by Carroll Inlet. The medium OGR is on the west side of Carroll Inlet and 

is directly connected to the Naha LUD II area to the west and to the medium OGR in VCU 7440. The 

medium OGR in VCU 7460 is connected via the beach buffer to the small OGR in this same VCU. 

This small OGR is directly connected to the very large LUD II area to the east. 

The existing connectivity for the small OGR is not a Forest Plan requirement. It is a site-specific 

feature that was originally added by the interagency review team in 1991 during the Shelter Cove EIS 

review process. The 1997 Forest Plan deleted the connection to the Salt Lagoon. During the review 

process for the 2008 Forest Plan the 2006 IRT added this connectivity back to the OGR. The low 

elevation POG acres considered by the 2006 IRT again were a site-specific feature; however, it is 

similar to both the important (deep snow) deer winter range and goshawk habitat features that are 

already included as a general design feature to consider when evaluating small OGRs (Appendix D). 

The deer model letter of direction identifies deep snow deer habitat as HPOG < 800 feet in elevation. 

Goshawk habitat measurement criteria include: medium- and HPOG less than 1,000 feet elevation 

for nesting habitat, and all POG less than 1,000 feet elevation for foraging habitat. 

The Saddle Lakes IRT determined that the Roadless OGR would not provide comparable 

achievement of Old-Growth Habitat LUD goals and objectives. However, this determination is based 

on a comparison of the proposed Roadless OGR to the existing Forest Plan OGR. Table 36 provides a 

comparison of the existing and proposed Roadless OGR to the Forest Plan Old-Growth Habitat goals 

and objectives which include the Appendix K and Appendix D criterion described above. Based on 
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Saddle Lakes Timber Sale Final EIS Issue 3A – Wildlife Habitat - Chapter 3  113

this comparison, the Roadless OGR does provide a comparable achievement of Forest Plan OldGrowth Habitat goals and objectives. The Forest Plan requires that modified OGRs provide a 

comparable achievement of the Old-growth habitat LUD goals and objectives and not that each OGR

provide the same on the ground site specific achievement as other OGRs.

Table 36. Comparison of Existing Forest Plan OGR and Roadless OGR to Old Growth habitat Goals and 

Objectives/Appendix K and Appendix D.

Forest Plan OGR Roadless OGR

Old Growth Habitat Goals and Objectives Forest Plan p. 3-57

Maintain areas of old-growth forests and their associated natural 

ecological processes to provide habitat for old-growth associated 

resources.

Yes Yes

Provide old-growth forest habitats, in combination with other LUDs, 

to maintain viable populations of native and desired non-native fish 

and wildlife species and subspecies that may be closely associated 

with old-growth forests.

Yes Yes

Contribute to the habitat capability of fish and wildlife resources to 

support sustainable human subsistence and recreational uses Yes Yes

Maintain components of flora and fauna biodiversity and ecological 

processes associated with old-growth forests. Yes Yes

Allow existing natural or previously harvested early seral conifer 

stands to evolve naturally to old-growth forest habitats, or apply 

silvicultural treatments to accelerate forest succession to achieve 

old-growth forest structural features.

Yes N/A

To the extent feasible, limit roads, facilities, and permitted uses to 

those compatible with old-growth forest habitat management 

objectives.

Yes Yes

Wildlife Habitat Planning: WILD1 Forest Plan p. 3-62

Maintain contiguous blocks of old-growth forest habitat in a forestwide system of old-growth reserves to support viable and welldistributed populations of old-growth associated species and 

subspecies.

Yes Yes

During project-level environmental analysis, for projects areas that 

include or are adjacent to mapped old-growth habitat reserves, the 

size, spacing, and habitat composition of mapped reserves may be 

further evaluated (See Appendix K for mapping criteria).

N/A N/A

Adjust reserves not meeting the minimum criteria to meet or exceed 

the minimum criteria. N/A N/A

Alternative reserves must provide comparable achievement of the 

Old-growth Habitat LUD goals and objectives. Determination as to 

comparability must consider the criteria listed in Appendix K.

Yes Yes

Forest Plan Appendix K p. K-1

Review Appendix D of the Final EIS, which includes the 

assumptions for the design of the old-growth reserve system. Yes Yes

Small reserves are a contiguous landscape of at least 16 percent of 

the National Forest System land area of each VCU and at least 50 

percent of the small reserve should be productive old growth. This 

goes on to include eight specific size and location criteria to 

consider, all of which are met or do not apply. 

Yes Yes
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114  Chapter 3 – Issue 3A – Wildlife Habitat Saddle Lakes Timber Sale Final EIS

Forest Plan OGR Roadless OGR

Step 1- Interagency Review Process

Review the purpose and rationale for current location of the Forest 

Plan OGR as documented in the current Tongass Old Growth 

database

Yes Yes

Assess whether the purpose and rationale for the location of the 

OGR has changed Yes Yes

Use the design criteria to define the biologically preferred location 

for the OGR Yes Yes

Document this proposal as the interagency proposed OGR in the 

Tongass Old Growth database and in an Interagency OGR Review 

report.

Yes Yes

Step 2- Decision Process

Incorporate the interagency review team OGR recommendation in 

the NEPA process, considering the best biological location for the 

OGR while balancing other considerations.

Yes Yes

The interagency team will work with the decision maker to develop 

alternate proposals, if necessary to meet other Forest Plan 

objectives.

Yes Yes

Implemented OGR must meet the minimum criteria as described 

below (See List B. below- all met or do not apply). Yes Yes

Attempt to develop a viable project that avoids conflicts with the 

biologically preferred OGR. Yes Yes

At a minimum, the biologically preferred OGR will be considered in 

an alternative in the NEPA document. Yes Yes

Where modifications to the biologically preferred OGR are required 

to meet Forest-wide multiple use goals and objectives 1) Follow the 

management prescriptions as defined for the Old-growth Habitat 

LUD;

Yes Yes

2) Document the rationale for modifications to the biologically

preferred OGR. Yes Yes

Appendix K-List B

OGRs shall contain a minimum of 400 acres of productive oldgrowth forest. Do not map isolated reserves with less than 400 

acres of productive old growth.

Yes Yes

The preferred biological objective is for each reserve to contain at 

least 800 acres of productive old-growth forest. Yes Yes

In VCUs that are partially allocated to a Non-development LUD, 

compare the computed acreage required to the acres of productive 

old growth in the Non-development LUD. If the Non-development 

LUD acres are less than the area necessary for a small reserve, 

first use the productive old growth acres in the existing Nondevelopment LUD to establish a small reserve, and then add 

additional acres of productive old growth to achieve the required 

small reserve size and composition.

N/A N/A

In VCUs that are separated by saltwater channels, reserves may be 

separated, but attempt to retain 800 acres of productive old growth 

in each.

N/A N/A

In very large VCUs, generally larger than 10,000 acres, the 

allocated old growth may be mapped in separate reserves as long 

as each reserve has a minimum of 800 acres of productive old 

growth. However, larger contiguous reserves are preferred to 

multiple smaller reserves.

N/A N/A
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Saddle Lakes Timber Sale Final EIS Issue 3A – Wildlife Habitat - Chapter 3  115

Forest Plan OGR Roadless OGR

In very large VCUs that contain relatively little productive old growth 

and the computational rule requires an amount of productive old 

growth that exceeds 50 percent of the existing productive old 

growth in the VCU, map a reserve of at least 400 acres of 

productive old growth

N/A N/A

Where VCU boundaries do not match watershed or ecological 

boundaries, up to 30 percent of the allocated old growth acres in a 

VCU may be mapped in an adjacent VCU if the resulting reserve 

achieves old-growth reserve objectives. The resulting small reserve 

in both VCUs must be contiguous. Total acreage is attributed to the 

VCU with 70 percent of the OGR.

N/A N/A

OGR boundaries should follow recognizable features that are 

identifiable on the ground. Features should be permanent and 

easily identifiable. Features may include but are not limited to 

streams, roads, distinctive ridges and ridge-tops, watershed 

boundaries, and v-notches.

Yes Yes

Appendix D General Design Criteria Forest Plan FEIS p. D-7 

OGRs were located so that spacing is maintained in the four 

cardinal directions Yes Yes

Circular rather than linear to maximize interior habitat/minimize 

fragmentation Yes Yes

Riparian, beach, and estuary habitats were considered as 

contributing elements to OGRs-included in OGR? Yes Yes

Minimizes early seral habitat (acres). In VCUs where managed 

stands constitute a high portion of the total acres, including seral 

habitat that previously supported high volume stands to the OGR 

was favored if it achieved a more circular shape, maintained 

connectivity or included rare habitats

Yes Yes

Minimizes roads (total miles)3/ No Yes

Site-specific factors in placing reserves were considered to help meet multiple biodiversity or wildlife 

habitat objectives (no size/acre requirements). Factors included, but were not limited to:

Includes largest remaining block of POG in VCU Yes Yes

Rare/Underrepresented features (such as rare or sensitive plants) Yes Yes

Deep snow deer winter habitat (acres)4/ Yes Yes

Marten winter habitat (acres)5/ Yes Yes

Goshawk nesting habitat (acres)6/ Yes Yes

Murrelet nesting habitat SD67 (acres) Yes Yes

N/A = Not Applicable.

1/ Small OGRs are a contiguous landscape of at least 16 percent of the National Forest System land area of each VCU. 

2/ At least 50 percent of the small OGR should be productive old growth.

3/ 1.8 miles of current mainline and planned State ADOT Ketchikan Shelter Cove Road system within or adjacent to OGR.

4/ HPOG < 800 feet in elevation, on south aspect.

5/ HPOG < 1,500 feet in elevation.

6/ HPOG and medium-POG ≤1,000 feet elevation

7/ Appendix D describes additional design criteria and assumptions used to design the OGRs system.

Connectivity/Fragmentation

An intact landscape is “a VCU having less than 5 percent of its original POG harvested” (USDA 

Forest Service 2008c, p. 3-168). None of the project area VCUs (7460, 7470, and 7530) qualifies as 

being intact. Relatively high concentrations of past harvest have occurred in these VCUs. In many of 
3 Affected Environment and Environmental Consequences

116  Chapter 3 – Issue 3A – Wildlife Habitat Saddle Lakes Timber Sale Final EIS

these areas, biodiversity has been affected due to the intensity of past harvest and the higher 

reductions in larger tree POG types (USDA Forest Service 2008c, p.163). All action alternatives 

would further reduce all POG habitats. Because clearcut harvest has the greatest impact on POG 

forest, it would have the greatest impact on connectivity. Uneven-age management would remove up 

to 33 percent of the basal area. This would maintain plant understories comparable to plant 

communities typically found in old-growth, but stand structure, snow interception capability, and tree 

size could be affected for 50 years or more (Deal 2009).

See MIS section below for how changes in POG and changes in connectivity and fragmentation affect 

Tongass wildlife.

Patch Size

All action alternatives would reduce existing habitat patches. Specific patch sizes are analyzed under 

Marten (< 40 acre patches), Hairy Woodpecker (<500 acre patches), and Red-breasted Sapsucker (< 

250 acres patches) MIS sections.

Timber harvest, through the removal of POG forest, can directly remove nest trees, and also increases 

habitat fragmentation and associated edge effects, such as increased rates of nest predation (Andren 

1994; Chalfoun et al. 2002). As forest patch size decreases through fragmentation, forest-edge habitat 

and predator access increase. Some avian predators, especially corvids (i.e., ravens, crows, jays), are 

known to increase both with forest fragmentation and proximity to human activity (Burger 2002). In a 

study of the edge effects and nest predation risk on species such as marbled murrelets, Malt and Lank 

(2007) found that disturbances by avian predators at nests were significantly more frequent at hard 

edges (clearcuts) relative to interiors, but less frequent at soft edges (regenerating forest); there were 

no edge effects at natural-edged (riparian) sites. Thus, edge-associated predation risk may subside 

with the progression of forest succession. 

Table 37. Change in patch size, all ownerships

Patch Size

(in acres) Historic Existing Alt. 2 Alt. 3 Alt. 4 Alt.5 Alt. 6

Number of patches / acres of patches

0-39 158 / 2,245 274 / 3,158 279 / 3,279 274 / 3,155 278 / 3,197 275 / 3,181 274 / 3,151

40-249 40 / 3,401 61 / 5,521 60 / 5,373 61 / 5,484 61 / 5,420 60 / 5,409 61 / 5,457

250-499 4 / 1/175 13 / 4,295 13 / 4,295 13 / 4,295 13 / 4,295 13 / 4,295 13 / 4,295

500-999 3 / 1,963 9 / 7,125 9 / 6,817 9 / 7,026 9 / 6,778 9 / 6,709 9 / 6,778

1000+ 10 / 85,993 10 / 56,687 10 / 55,190 10 / 56,002 10 / 55,034 10 / 54,722 10 / 55,296

Interior Habitat

Interior habitat would be reduced under all action alternatives. Changes in interior habitat are 

analyzed under the Brown Creeper MIS section. 

Corridors

Treatment of identified corridors under the action alternatives are described and summarized in Table 

38. In addition to the specific corridors, all action alternatives would remove leave strips left by the

previous timber sales making it harder for deer to move up and down the slopes in the winter. This 

affects connectivity for species such as marten and red-backed voles, and affects habitat for small,

less-mobile species such as salamanders, gastropods, and arthropods. Effects related to corridors are 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Issue 3A – Wildlife Habitat - Chapter 3  117

discussed under Deer, Marten, Red Squirrel MIS sections, and under the Endemic Small Mammal 

section.

Table 38. Treatment of corridors under action alternatives in the Saddle Lakes project area

Corridor Treatment(s) Alt. 2 Alt. 3 Alt. 4 Alt. 5 Alt. 6

1 None Maintains Maintains Maintains Maintains Maintains

2 

Alternative 5 would move the 

OGR and clearcut Units 300 

through 308 and 310 through 

312.

Maintains Maintains Maintains Reduces Maintains

3 

Alternatives 4, 5, and 6 would 

clearcut Units 204 (east of the 

road), and 207 and partial-cut

Units 203 and 204 (west of the 

road). Alternative 5 would also 

partial-cut Unit 224.

Maintains Maintains Reduces Reduces Reduces

4 None Maintains Maintains Maintains Maintains Maintains

5 Alternatives 2, 4, 5, and 6 

would clearcut Units 8 and 9. Reduces Maintains Reduces Reduces Reduces

6 

Alternative 2 would partial-cut

Units 154 and 48. Alternative 4 

would clearcut Units 48, 53 

and 154 and partial-cut Unit 

49. Alternative 5 would

clearcut Units 48, 49, 53, 122, 

and 154. Alternative 6 would 

clearcut Units 48 and 154 and 

partial-cut Unit 49.

Reduces Maintains Reduces Reduces Reduces

7 

Alternative 2 would partial-cut

Unit 28. Alternatives 4 and 5 

would clearcut Units 28, 31, 

40, 71, 113, and 114 and 

partial-cut Units 30 and 71. 

Alternative 6 would clearcut 

Units 31, 40, 113, and 114 and 

partial-cut Unit 30.

Reduces Maintains Reduces Reduces Reduces

8 

Alternative 2 would partial-cut

Units 46 and 116. Alternative 4 

would clearcut Units 46 and 

116. Alternative 5 would 

clearcut Units 46, 115, and 

116. Alternative 6 would 

clearcut a portion Unit 46 and 

partial-cut Unit 116.

Reduces Maintains Reduces Reduces Reduces

Management Indicator Species

Sitka Black-tailed Deer

Effects Common to All Action Alternatives

All of the action alternatives would reduce deer habitat (deep snow winter, average winter and nonwinter habitat discussion below). Even-aged prescriptions (i.e., clearcut logging) would directly 

reduce the amount of deer habitat and reduce habitat capability for deer (Person et al. 1996). 
3 Affected Environment and Environmental Consequences

118  Chapter 3 – Issue 3A – Wildlife Habitat Saddle Lakes Timber Sale Final EIS

Clearcutting causes both short-term and long-term effects. “Although during summer and mild winter 

conditions, deer may benefit from young clearcuts, the long-term prognosis is permanent loss of 

suitable foraging habitat (Person and Brinkman 2013).” 

Many young-growth stands have been precommercially thinned (PCT) which delays the onset of the 

stem-exclusion phase (Hanley et al. 2013). However, analysis of past PCT treatments by Alaback 

(2010) on Prince of Wales Island showed that while thinning can be effective in improving wildlife 

habitat it is a relatively short-term benefit. Alaback 2010 found that soon after thinning (generally not 

more than 15 years), crop trees expand their branches and create a dense overstory canopy shading 

out understory forage. McClellan et al. (2014) noted similar canopy closure in stands 21 years post 

thin on the False Island area of Chichagof Island. 

Closed-canopy, young-growth stands (roughly 26 to 150 years old) provide minimal forage due to the 

lack of light penetration to the forest floor (stem exclusion phase). Loss of old-growth habitat to stem 

exclusion represents an irreversible commitment of resources (USDA Forest Service 2008c, p. 3-2) 

representing a permanent loss of old-growth deer habitat under current 100 year rotations. 

Young clearcuts would provide forage during relatively snow-free periods and can be a refuge from 

wolves. However, increased slash levels in young-growth stands could hinder movement and increase 

energy debt accessing forage (McClellan et al. 2014, Hanley 1984). Once stem exclusion occurs, 

young-growth stands may provide cover, but contain minimal forage and contribute to mortality from 

malnutrition and predation (Farmer et al. 2006). 

Forage would increase temporarily in young clearcuts, but decrease long-term along all elevational 

gradients once stem exclusion occurs. Stem exclusion reduces the amount of high-quality forage 

available during non-winter periods and can cause deer to enter the winter in poorer condition. Stem 

exclusion contributes to malnutrition in lactating females and poor survival of fawns. High quality, 

abundant forage in summer, fall, and spring habitats is important to restore body condition and 

accumulate body reserves (Parker et al. 1999).

Timber harvest can make deer more susceptible to hunting mortality in the fall. Farmer et al. (2006) 

found that buck use of young clearcuts in landscapes accessible by roads increased risk of death from 

hunting. Initial hunting access within most of WAAs 406 and 407 is by boat, but logging roads are 

used for additional access to hunting areas. 

Partial cutting would have less effect on deer habitat as stands would not develop into stem exclusion. 

Logging slash could affect access to available forage for several years. Review of historic unevenaged (partial-cut) treatments on the Tongass showed that uneven-aged harvest maintained understory 

forage better than clearcut harvest (Deal et al. 2009, Deal 2001). Stand structural diversity and plant 

composition and abundance were greater in partial-cut stands than in young-growth stands developing 

after clearcutting (Deal, 2001, Deal and Tappeiner 2002). Fifty years after partial-cutting, tree 

diameters, large tree numbers, species composition, stand complexity, and understory diversity were 

similar to original stand conditions (Deal et al. 2009). However, in the short-term, partial cutting 

opens the overstory canopy and provides less snow interception. Therefore, the uneven-aged 

management prescriptions would result in shorter-term (roughly 50 year) reductions in deer winter 

habitat. Actual change in canopy depends upon individual stand prescription removal pattern. 

Different removal patterns, all with 30 percent basal area removed, are simulated in Figure 8

(excerpted from Vanderwel et al. 2011). 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Issue 3A – Wildlife Habitat - Chapter 3  119

Figure 8. Variation in partial cutting removal patterns

Direct/Indirect Effects

Measurement criteria for analyzing direct and indirect effects to the Sitka black-tailed deer are 

disclosed below. NFS lands within WAAs 406 and 407 were used for direct effect analysis for deer.

Deep Snow Winter Habitat

Measurement criteria: acres of high-POG (SD5N, SD5S, SD67) less than or equal to 800 feet in 

elevation on south aspects.

The greatest adverse effect to deer results from clearcutting the higher volume stands at low 

elevations which are critical to deer during winters with heavy snow fall (Porter 2011a). 

Hunters and predators, (e.g., wolves and bears) also contribute to declines during or following deep 

snow winters and may inhibit subsequent recovery (Hanley 1984; also see Wolf Section below). 

Farmer et al. (2006) found that predation by wolves was the primary source of mortality for adult and 

yearling females and malnutrition was the major cause of death in juveniles. 

The negative energy balance (energy debt) of deer during winter is a direct consequence of decreased 

availability of high-quality food, and is aggravated by additional energy costs associated with snow 

and cold temperatures (Parker et al. 1999). Partial cutting would affect deep snow winter habitat until 

sufficient canopy closure occurs to provide snow interception. Actual change in canopy and the length 

of time that deep snow habitat would be affected depends upon individual stand prescription removal 

pattern.

Average Winter Habitat

Measurement criteria: acres of POG less than 1500 feet in elevation. 

Except for portions of six units (16, 17, 28, 71, 72, and 140), all proposed timber harvest is less than 

1,500 feet elevation. Therefore, almost all proposed timber harvest would remove average winter deer 

habitat. Timber harvest reduces forage availability and snow interception and lowers the long-term 

carrying capacity for deer. See deer model results for changes in habitat capacity during average 

winters. 

Partial cutting could have short-term negative effects until sufficient canopy closure occurs to provide 

snow interception. Partial harvest units could provide habitat during relatively snow-free periods. 
3 Affected Environment and Environmental Consequences

120  Chapter 3 – Issue 3A – Wildlife Habitat Saddle Lakes Timber Sale Final EIS

Non-Winter (Spring/Summer/Fall)

Measurement criteria: all habitats except older (26 to 150 year old) young-growth. 

Spring, summer, and fall habitat conditions are important for maintaining the nutritional condition of 

deer throughout the year to ensure healthy, productive populations (Hanley et al. 1989, Klein 1965). 

Body reserves accumulated during summer with abundant digestible forage are critical to winter 

survival and for does to meet the nutritional costs of lactation. During the spring, elevations below 

1,000 ft. (300 m) are used by deer in greater proportion than their abundance (Schoen and Kirchhoff 

1990, Hanley 1984, Schoen et al. 1981) and represented 73 percent of deer locations by Schoen and 

Kirchhoff (1990). As the snowline recedes, deer move around and make greater use of areas with 

new, green vegetation. By late spring, high quality forage is abundant, and migratory deer move near 

their summer ranges. Subalpine, alpine, and in scrub forest stands accounted for highest percentage of 

use by migratory deer; elevations >600 m (1,969 ft.) were used statistically more than their 

abundance (Schoen and Kirchhoff 1990). Resident deer remain within their home ranges, but also 

make use of open habitats such as young clearcuts, muskegs, and NPOG where forage is abundant.

Direct effects to deep, average and non-winter deer habitat for Forest Service lands in WAAs 406 and 

407 are shown in Table 39. Note that Table 39 shows acres of harvest by WAA 406 and 407 

separately and the text discusses the amount of harvest of WAAs 406 and 407 combined. Alternatives 

2, 4, and 6 are similar in the overall amount of habitat affected, but vary in harvest prescriptions. 

Table 39. Change in deer habitat on NFS Lands in WAAs 406 and 407

Habitat

Remaining Habitat Acres (% reduction from existing acres)

Historic 

(ac)

Existing \ 

Alt. 1 (ac) Alt. 2 Alt. 3 Alt. 4 Alt. 5 Alt. 6

WAA 406

Deep snow 

winter 3,866 2,463 2,411

(-2.1%)

2,457

(-0.2%)

2,418

(-1.8%)

2,411

(-2.1%)

2,429

(-1.4%)

Average 

winter 52,202 40,421 39,322

(-2.7%)

40,065

(-2.7%)

39,196

(-2.7%)

38,890

(-2.7%)

39,373

(-2.7%)

Non-winter 122,505 116,178 114,832

(-1.1%)

115,711

(-0.4%)

114,675

(-1.3%)

114,259

(-1.7%)

114,881

(-1.7%)

Non-winter 

at stem 

exclusion

122,505 116,178 108,699

(-6.4%)

109,579

(-5.7%)

108,543

(-6.6%)

108,127

(-6.9%)

108,750

(-6.4%)

WAA 407

Deep snow 

winter 1,168 940 911

(-3.0%)

925

(-1.6%)

881

(-6.3%)

844

(-10.2%)

881

(-6.3%)

Average 

winter 17,772 15,930 15,161

(-4.8%)

15,465

(-2.9%)

15,082

(-5.3%)

14,843

(-6.8%)

15,163

(-4.8%)

Non-winter 41,202 40,657 39,797

(-2.1%)

40,112

(-1.3%)

39,718

(-2.3%)

39,461

(-2.9%)

39,811

(-2.0%)

Non-winter 

at stem 

exclusion

41,202 40,657 38,443

(-5.4%)

38,758

(-4.7%)

38,364

(-5.6%)

38,107

(-6.3%)

38,457

(-5.4%)

Source: USFS, Tongass National Forest GIS.

Deep snow winter habitat = high-POG ≤800 ft. elevation on south aspect

Average winter habitat = POG≤1,500 ft. elevation

Non-winter habitat = all habitats except stem exclusion young growth. 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Issue 3A – Wildlife Habitat - Chapter 3  121

All action alternatives would reduce deer model habitat capability. The effects would occur 

immediately after project completion (stand initiation), and intensify at 25 to 30 years as the 

harvested stands transition into the stem-exclusion stage. Reductions in habitat capability could lead 

to a decline in the deer population, particularly following severe winters. Deer model results are 

shown by alternative in Table 40. 

With deer numbers likely below carrying capacity, it is not known what affect the proposed harvest 

would have upon existing deer numbers, but less habitat would be available which could lead to 

increased mortality during deep snow winters. Reduced habitat capability could hinder the State’s 

intensive management objective to increase deer in GMU 1A and result in fewer deer being available 

to hunters. 

Table 40. Deer model habitat capability on NFS Lands1/ in WAAs 406 and 407

Stand Age

Deer Habitat Capability (% reduction from existing) 

Historic Existing \ 

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

WAA 406

0 to 25 

years2/

3,276 2,521

(-23%)

2,482

(-1.5%)

2,505

(-0.6%)

2,479

(-1.7%)

2,472

(-1.9%)

2,485

(-1.4%)

26 to 200 

years3/

2,396

(-5.0%)

2,433

(-3.5%)

2,391

(-5.2%)

2,378

(-5.7%)

2,400

(-4.8%)

WAA 407

0 to 25 

years2/

1,158 1,042

(-10%)

1,014

(-2.7%)

1,027

(-1.4%)

1,010

(-3.1%)

997

(-4.3%)

1,011

(-3.0%)

26 to 200 

years3/

978

(-6.1%)

995

(-4.5%)

971

(-6.8%)

954

(-8.4%)

974

(-6.5%)

Source: USFS, Tongass National Forest GIS. 1/ NFS lands only. Partial harvest was modeled as clearcut. Habitat capability 

does not equal actual deer; it is used as a tool to compare Alternatives. 2/ 0 – 25 years represents the initial effect of project 

implementation. 3/ 26 – 200 years represents the effect of stem exclusion.

Alternative 1 

Alternative 1 would have no effect on deer from this project. All existing deep snow habitat would 

remain to support current deer populations during winters with above average snowfall. With most of 

the project area below 1,500 feet elevation, Alternative 1 would maintain the highest level of average 

winter habitat. All non-winter habitat would be maintained, which would help deer enter the winter in 

better nutritional condition with higher fat reserves. Deer habitat capability would decline slightly as 

previously harvested stands enter stem exclusion. 

Alternative 1 would maintain the existing OGR between the Naha LUD II and George Inlet salt 

chuck, and maintain the current connectivity between source and sink habitat. It should be noted 

however that the current connectivity between the existing OGR and the beach buffer around George 

Inlet is already compromised by the presence of State land. It would also maintain current elevational 

corridors linking summer and winter habitat, allowing deer to move up and down slopes during the 

winter as snow levels allowed.

Alternative 2

Alternative 2 would harvest 2,206 acres of combined deer habitat of which includes 81 acres of deep 

snow winter habitat, 1,868 acres of average winter habitat (Table 39). This alternative maintains the 
3 Affected Environment and Environmental Consequences

122  Chapter 3 – Issue 3A – Wildlife Habitat Saddle Lakes Timber Sale Final EIS

second highest level of deer habitat of the action alternatives since it contains a higher percentage of 

partial-cutting.

The 53 acres of deep snow that are clearcut represent a long-term loss of deer habitat during deep 

snow winters, whereas the 27 acres deep snow that are of partial-cut represents a shorter-term loss. 

Within average winter habitat, clearcutting would occur on 916 acres and partial cutting would occur 

on 952 acres. About 48 percent of the non-winter habitat (1,055 acres) would be clearcut resulting in 

long-term effects, and 52 percent (1,152 acres) would be partial-cut resulting in short-term effects 

from slash. Effects would be more pronounced in resident deer that do not migrate to high-quality 

alpine areas during the summer.

Deer model habitat capability would be maintained at 98 and 97 percent of current levels, 

respectively within WAAs 406 and 407 initially (Table 40), then drop to 95 and 94 percent as the 

harvest units transition into stem exclusion. Actual impacts would likely be less, as the current deer 

model does not account for partial harvest and all harvest units are modeled as clearcut. Alternative 2 

would maintain elevational corridors 3 and 4 (see Figure 7). 

Alternative 2 would reduce the effectiveness of corridors 6, 7, and 8 short-term by partial cutting

Units 28, 46, 48, 116, and 154. Alternative 2 would reduce corridor 5 by clearcutting Units 8 and 9. 

Clearcut units would hinder movement up and down slopes and contribute to increased risk of winter 

malnutrition, predation and/or hunting mortality. 

Alternative 2 would maintain the existing OGR maintaining the current connectivity between the 

Naha LUD II and George Inlet salt chuck (corridor 2). It should be noted however that the current 

connectivity between the existing OGR and the beach buffer around George Inlet is already

compromised by the presence of State land.

Alternative 3

Alternative 3 would have the least effect of the action alternatives on deer habitat since it would 

harvest the least amount of habitat (Table 39). It would harvest 1,012 total acres of deer habitat of 

which 21 acres are deep-snow winter habitat, and 821 acres of average-winter habitat. Many lowelevation, south-facing slopes were excluded from harvest in this alternative, and no units were 

proposed within the identified elevational corridors (see Figure 7). All 21 acres of harvest in deepsnow winter habitat would be clearcut. Alternative 3 would clearcut 663 acres and partial-cut 158 

acres of average-winter habitat. About 82 percent (816 acres) of the non-winter habitat would be 

clearcut and 19 percent (196 acres) would be partial-cut. The risk of malnutrition would be slightly 

higher than existing levels as would predation risk, but less than in the other action alternatives. 

Deer model habitat capability is maintained at 99 percent of current levels initially (Table 40), and 

then drops to 96 and 95 percent of existing habitat capability within WAAs 406 and 407 as harvested 

units move into stem exclusion. Actual impacts would likely be less, as all harvest units are modeled 

as even-aged management (clearcut) in accordance with current deer model direction.

Alternative 3 was specifically designed to maintain the identified elevational and connectivity 

corridors. Alternative 3 would maintain the existing OGR in VCU 7470 so the current connectivity 

between the Naha LUD II and George Inlet salt chuck would be maintained. It should be noted 

however that the current connectivity between the existing OGR and the beach buffer around George

Inlet is already compromised by the presence of State land. 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Issue 3A – Wildlife Habitat - Chapter 3  123

Alternative 4

Alternative 4 would harvest a total of 2,424 acres of deer habitat, 104 acres of which is deep-snow 

winter habitat, and of which is 2,073 acres of average-winter habitat (Table 39). It would harvest the 

second-highest amount of timber, and 87 percent of total harvest would have even-age clearcut 

prescriptions. As a result, it would have the second-highest impact on deer habitat.

Under Alternative 4, 101 of the 105 acres of deep-snow winter habitat harvested would be clearcut. 

Alternative 4 would clearcut 1,794 acres of average-winter habitat and 279 acres would be partial-cut. 

Alternative 4 would clearcut stands along the elevational gradient limiting a deer’s ability to move up 

and down slopes in search of forage. Non-winter habitat would initially drop to 99 percent of existing 

levels in WAA 406 then drop to 93 percent at stem exclusion. Alternative 4 would clearcut 2,112 acres 

of non-winter habitat and partial-cut 312 acres.

Deer model habitat capability is maintained at 98 and 97 percent of current levels initially (Table 40), 

and then drops to 95 and 93 percent long-term within WAAs 406 and 407 as harvested units transition 

into stem exclusion.

Alternative 4 would reduce corridors 3, 5, 6, 7, and 8 which would affect connectivity long term. 

Specific units in conflict include: even-aged management (clearcutting) in Units 8, 9, 28, 31, 40, 46, 

48, 53 71-1, 71-3, 113, 114, 116, and 154 and uneven-aged management in Units 30, 49, 71-2, 203, 

and 204. Alternative 4 does not implement elevational corridors within the Modified Landscape LUD

(USDA Forest Service 2008b WILD1.B.2. p 3-115). This would further reduce deer mobility since 

elevational connectivity is already very limited on the landscape.

Alternative 4 would maintain the existing OGR in VCU 7470, maintaining current connectivity 

between the Naha LUD II and George Inlet salt chuck. It should be noted however that the current 

connectivity between the existing OGR and the beach buffer around George Inlet is already

compromised by the presence of State land.

Alternative 5

Alternative 5 would have the greatest impact on deer by harvesting the greatest amount of timber, 

hence deer habitat, throughout all seasons (Table 39). Alternative 5 harvests a total of 3,115 acres of 

total habitat; of which 148 acres are deep-snow winter habitat (95 percent of which is clearcut), and 

2,619 acres average-winter habitat.

Deep-snow habitat would be the most fragmented under this alternative increasing the risk of 

mortality from malnutrition or predation. Most stands harvested within average-winter habitat would 

be clearcut (2,410 acres), but 208 acres would be partial-cut. Ninety percent (2,594 acres) of the nonwinter harvest would be clearcut whereas 10 percent (291 acres) would be partial-cut. 

Deer model habitat capability is maintained at 98 and 96 percent of current levels initially (Table 40), 

and then drops to 94 and 92 percent long term within WAAs 406 and 407 at stem exclusion. 

Alternative 5 does not implement elevational corridors within the Modified Landscape LUD (USDA 

Forest Service 2008b WILD1.B.2. p. 3-115). It would reduce corridors 2, 3, 5, 6, 7, and 8. Even-aged 

management (clearcut) units include 8, 9, 28, 31, 40, 46, 48, 49, 53, 71-1, 71-3, 113, 114, 115, 116, 

122, and 154. Uneven-aged management units include 30, 71-2, 203, 204, and 224. 

Alternative 5 would move a portion of the existing OGR in VCU 7470 into the North Revilla IRA 

requiring a Forest Plan Amendment to implement. Relocation of the OGR would reduce the overall 

acres of protected deer habitat, and reduce the connectivity between the Naha LUD II and George 
3 Affected Environment and Environmental Consequences

124  Chapter 3 – Issue 3A – Wildlife Habitat Saddle Lakes Timber Sale Final EIS

Inlet salt chuck by clearcutting Units 300 through 308 and 310 through 312. Reduction in 

connectivity could limit the ability to replenish sink habitat given the movement patterns found by 

Colson et al. (2012) on nearby Prince of Wales Island, and McNay and Vollner (1995) in British 

Columbia. It should be noted however that the current connectivity between the existing OGR and the 

beach buffer around George Inlet is already compromised by the presence of State land located 

between the OGR and George Inlet. The interagency review team determined that the Roadless OGR 

does not provide comparable achievement of the Old-growth Habitat LUD goals and objectives nor 

does it provide a comparable achievement of biological design criteria including deer winter habitat 

when compared to the existing Interagency preferred OGR. The determination of the Roadless OGR 

option not providing a comparable achievement was based on comparing the proposed OGR against 

the existing OGR. The Forest Plan states that modified OGR must provide a comparable achievement 

of the Old-growth Habitat LUD goals and objectives not that each OGR must provide the exact same 

on the ground site specific achievement as the current OGR; therefore the a determination was made 

of a comparable achievement of the old-growth habitat goals and objectives for the Roadless OGR.

The Roadless OGR does meet the acre requirements for a small OGR in this VCU; it does contain 

acres of deer winter range, acres of potential goshawk and murrelet habitat and other Old-growth 

Habitat LUD goals and objective criteria as listed in the Forest Plan, Forest Plan Appendix K and 

Forest Plan FEIS Appendix D. 

Alternative 6

Alternative 6 would harvest a total of 2,143 acres of deer habitat, 93 acres of which is deep snow 

winter habitat, and 1,815 acres of average-winter habitat. Alternative 6 ranks third of the action 

alternative for impacts on deer habitat and risk to deer populations (Table 39). 

Alternative 6 would clearcut 87 of 93 acres of deep-snow winter habitat. Alternative 6 would clearcut 

1,423 acres of average-winter habitat, and 391 acres would be partial-cut. Alternative 6 would also 

clearcut stands along elevational gradients limiting a deer’s ability to move up and down slope in 

search of forage. Roughly 77 percent (1,654 acres) of the non-winter habitat would be clearcut and 23 

percent (484 acres) would be partial-cut. 

Deer model habitat capability is maintained at 99 and 97 percent of current levels initially (Table 40), 

and then drops to 95 and 93 percent as habitat capabilities within WAAs 406 and 407 as stands move 

into stem exclusion.

Alternative 6 does not implement elevational corridors within the Modified Landscape LUD. 

Alternative 6 reduces elevation corridors 3, 5, 6, and 7, and reduces the width and effectiveness of 

corridor 8. Specific units in conflict include: uneven-aged management in Units 30, 49, 203, 204, 

224, and even-aged management (clearcut) in Units 8, 9, 31, 40, 48, 113, 114, 116, 154, and 207. 

Alternative 6 would maintain the existing OGR in VCU 7470, maintaining the existing connectivity 

between the Naha LUD II and George Inlet salt chuck to replenish sink habitat. It should be noted 

however that the current connectivity between the existing OGR and the beach buffer around George

Inlet is already compromised by the presence of State land.

Cumulative Effects

Cumulative effects analysis for deer includes all land ownerships within WAAs 406 and 407 and uses 

the same habitat measurement criteria used in the direct and indirect effects analysis. The deer model 

was used for analyzing cumulative change to average-winter carrying capacity and deer habitat

capability (DHC). 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Issue 3A – Wildlife Habitat - Chapter 3  125

Effects Common to All Action Alternatives

Most past and recent timber harvest has been by even-aged management (clearcutting). Early harvest 

was generally at lower elevations in higher-volume stands which affected both winter and non-winter

habitat. The greatest impact has been to deep-snow winter habitat. With one-third to almost one-half 

of this deer habitat already impacted (Table 41), deer populations may have a difficult time in 

rebounding after deep-snow winter die-offs and be more susceptible to predation and malnutrition. 

These latter two factors could affect recruitment rates and predator/prey relationships. 

Impacts to deep-snow habitat may partially explain the low deer numbers within this portion of GMU 

1A. Impacts to average winter habitat have been less intensive. 

Transition to young growth harvest was recently mandated by the Secretary of Agriculture (USDA 

2013). This will increase the harvest of young growth over the next 10-15 years confirming that 

harvest of old-growth is an irreversible commitment of resources (USDA 2008c, p. 3.2) that cannot be 

renewed under short-term timber rotations.

Much of the older harvest is currently in stem exclusion. Some older harvest stands on Cape Fox 

lands in George Inlet have recently been clearcut a second time.

Table 41. Cumulative change to deer habitat on all land ownerships in WAAs 406 and 407

Habitat

Remaining Habitat Acres (% reduction from historic acres)

Historic 

(ac)

Existing \ 

Alt. 1 (ac) Alt. 2 Alt. 3 Alt. 4 Alt. 5 Alt. 6

WAA 406

Deep snow 

winter 4,194 2,775

(-33.8%)

2,723

(-35.1%)

2,769

(-34.0%)

2,729

(-34.9%)

2,723

(-35.1%)

2,741

(-34.6%)

Average 

winter 54,385 42,506

(-21.8%)

41,408

(-23.9%)

42,150

(-22.5%)

41,281

(-24.1%)

40,975

(-24.7%)

41,459

(-23.8%)

Non-winter

initial 126,769 120,343

(-5.1%)

118,997

(-6.1%)

119,876

(-5.4%)

118,840

(-6.3%)

118,425

(-6.6%)

119,047

(-6.1%)

Non-winter 

at stem 

exclusion

125,078 112,641

(-9.9%)

111,295

(-11.0%)

112,174

(-10.3%)

111,139

(-11.1%)

110,723

(-11.5%)

111,345

(-11.0%)

WAA 407

Deep snow 

winter 1,937 1,193

(-38.4%)

1,165

(-39.9%)

1,178

(-39.2%)

1,134

(-41.5%)

1,098

(-43.3%)

1,134

(-41.5%)

Average 

winter 28,932 23,379

(-19.2%)

22,609

(-21.9%)

22,914

(-20.8%)

22,531

(-22.1%)

22,291

(-23.0%)

22,612

(-21.8%)

Non-winter

initial 65,777 62,893

(-4.4%)

62,032

(-5.7%)

62,347

(-5.2%)

61,954

(-5.8%)

61,696

(-6.2%)

62,046

(-5.7%)

Non-winter 

at stem 

exclusion

61,000 55,446

(-9.1%)

54,585

(-10.5%)

54,900

(-10.0%)

54,507

(-10.6%)

54,250

(-11.1%)

54,599

(-10.5%)

Source: USFS Tongass National Forest GIS. 

Approximately 500 acres of habitat was inundated on the east side of Carroll Inlet from the 

construction of the Swan Lake hydro facility. An additional 61 acres of could be affected by the 

proposed expansion. 
3 Affected Environment and Environmental Consequences

126  Chapter 3 – Issue 3A – Wildlife Habitat Saddle Lakes Timber Sale Final EIS

Additionally if the proposed AMHT land exchange is approved, substantial impacts could occur from 

logging within the 8,170 acre Shelter Cove parcel (AMHT 2014, Forest Resource Management Plan). 

Any land exchange would result in a reduction in the modeled deer habitat capability as all nonNational Forest System lands are given a zero value in the deer model. The 8,170 acres of AMHT 

land was not included in the cumulative effects because at the time of analysis it was still in Forest 

Service ownership. 

The Ketchikan to Shelter Cove Road, when completed, would connect the communities of Ketchikan 

and Saxman to the Saddle Lakes project area. This would make the Saddle Lakes project area more 

accessible to hunters and would likely increase hunting pressure in WAA 406 west of Carroll Inlet 

and WAA 407. Declines in the deer population resulting from reduced habitat capability may decrease 

the number of deer available to wolves and hunters (Person 2001, Farmer et al. 2006, Brinkman et al. 

2009). 

Deer Model Results

See the Methodology section above for a description of parameters used in the deer model for 

cumulative effects. 

Historic and recent clearcut timber harvest on all land ownerships, combined with the Saddle Lakes 

Timber Sale, would further impact deer habitat carrying capacity (Table 42) and therefore have more 

long-term adverse effects. 

Historic deer habitat capability was reconstructed for all ownerships using the best information 

available and this resulted in historic values different from those values calculated on National Forest 

System (NFS) lands only. Non-NFS lands were given zero current habitat capability per current 

model direction. Partial harvest was modeled as clearcut. 2011 Deer Model Direction states “For 

cumulative effects rerun the model with all land ownerships and clearly state how non-NFS lands 

were treated (given zero habitat value or used actual data) OR Discuss non-federal (non-NFS) lands 

(percent of area, contribution to overall habitat, etc. in general write-up, not as part of the deer 

model).” 

Alternative 1 

Alternative 1 would not harvest POG or build any additional roads, and would not contribute to 

cumulative effects on deer habitat and deer. However, the combination of past harvest and foreseeable 

projects would affect deer habitat and deer. Of the alternatives being considered, Alternative 1 would 

have the least cumulative impacts on deer habitat (Table 41). Deep-snow habitat has been affected the 

most of any habitat by past projects, and has the highest potential to limit deer populations. Past 

harvest in the stand initiation phase (0 to 25yrs) would continue to move toward stem exclusion. 

These stands would provide some forage during relatively snow free winters and during the nonwinter season. Once stem exclusion occurs, deer habitat would be permanently lost under the current 

100-year rotation. Past harvest within beach and riparian buffers, OGRs and other non-development 

LUDs would be reduced long term (150 plus years) but would eventually recover. 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Issue 3A – Wildlife Habitat - Chapter 3  127

Table 42. Cumulative change in deer habitat capability (DHC) on all land ownerships in WAAs 406 and 

4071/

Historic

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

Deer Habitat Capability (DHC; % reduction from historic)

WAA 406

0 to 25 

years2/

3,568

2,521

(-29.3%)

2,482

(-30.4%)

2,505

(-29.8%)

2,479

(-30.5%)

2,472

(-30.7%)

2,485

(-30.4%)

26 to 200 

years3/

2,446

(-31.4%)

2,396

(-32.8%)

2,433

(-31.8%)

2,391

(-33.0%)

2,378

(-33.4%)

2,400

(-32.7%)

WAA 407

0 to 25 

years2/

2,465

1,042

(-57.7%)

1,014

(-58.9%)

1,027

(-58.3%)

1,010

(-59.0%)

997

(-59.6%)

1,011

(-59.0%)

26 to 200 

years3/

1,019

(-58.7%)

978

(-60.3%)

995

(-59.6%)

971

(-60.6%)

954

(-61.3%)

974

(-60.5%)

Source: USFS Tongass National Forest GIS.

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

current habitat capability per current model direction. Partial harvest was modeled as clearcut. Habitat capability does not 

equal actual deer; it is used as a tool to compare alternatives. 2/ 0 – 25 years represents the initial effect of project 

implementation

3/ 26 – 200 years represents the effect of stem exclusion.

Alternatives 2, 3, 4, 5, and 6

Cumulative effects on deer habitat are similar between alternatives because most harvest has been by 

clearcutting. Deep-snow winter habitat would be reduced to between 65 and 66 percent of historic 

levels in WAA 406, and to 57 to 61 percent of historic levels in WAA 407. With the above reductions 

in habitat, deer populations may have a difficult time in rebounding after severe winter die-offs and 

be more susceptible to predation and malnutrition. These latter two factors could affect recruitment 

rates and predator/prey relationships. 

Impacts to average-winter habitat has been less intensive, but more widespread than impacts to deepsnow winter habitat. A range of 75 to 77 percent of the average-winter habitat would remain in WAA

406 and about 77-79 percent in WAA 407 (Table 41). Impacts to non-winter habitat have been 

substantially less than impacts to winter habitat due to the inclusion of NPOG and non-forested 

habitats. Non-winter habitat at stem exclusion would be maintained at between 88 and 90 percent of 

historic levels in both WAAs 406 and at 407. 

Habitat capability, as predicted by the deer model for WAA 406, would be reduced long term to 

roughly 67 to 68 percent of historic levels at stem exclusion (Table 42). Habitat capability in WAA 

407 would be reduced to roughly 39 to 40 percent of historic levels at stem exclusion.

Summary of Deer Effects

The resulting percent of DHC remaining at both end of project and stem exclusion on National Forest 

System (NFS) lands are above the percent that the Forest Plan predicted for both WAAs on NFS land 

(2008 Forest Plan FEIS Table 3.10-7 p. 3-269-273. Relative Changes to Deer Habitat Capability by 

WAA by Alternative). The Forest Plan predicted that at full implementation of the Forest Plan under 

Alternative 6 ,WAA 406 would retain about 64 percent of the original DHC and in WAA 407 about 

73 percent would remain. As a result of Saddle Lakes at stem exclusion on NFS lands, WAA 406 is 

estimated to retain between 71 and 73 percent of the original DHC and WAA 407 from about 82-85 

percent of the original DHC. The percentage of remaining deer habitat capability on NFS land in both 
3 Affected Environment and Environmental Consequences

128  Chapter 3 – Issue 3A – Wildlife Habitat Saddle Lakes Timber Sale Final EIS

WAAs is within what was calculated for these WAAs in the 2008 Forest Plan FEIS (p.3-269 to 2-273; 

Table 3.10-7) 

Alternative 1 ranks the highest overall in terms of least effects to deer since it would maintain all 

current old-growth deer habitat. This alternative would contribute to maintaining current deer 

populations and hunter success. Of the action alternatives, Alternative 3 ranks highest in terms of least 

effects to deer habitat and populations followed by Alternatives 2, 6, and 4. Alternative 5 would have 

the greatest impact on deer habitat, and therefore the greatest potential impact on deer populations 

and hunter success. Differences between the alternatives are largely due to differences in silvicultural 

prescriptions. Alternatives 4, 5, and 6 impact deer further by reducing elevational connectivity 

corridors within the project area. Alternative 5 moves a portion of the small OGR in 7470, resulting in 

a reduction of connectivity and a further reduction in the quality and quantity of the habitat. 

Alexander Archipelago Wolf

Direct/Indirect Effects

The measurement criteria for analyzing direct and indirect effects on the Alexander Archipelago wolf 

include deer density (from deer model), and road density less than or equal to 1,200 feet elevation. 

For direct and indirect effects, NFS lands within WAAs 406 and 407 were used. 

Effects Common to All Action Alternatives 

All action alternatives would reduce current deer densities, and increase road densities below 1,200 

feet in elevation. 

Deer Density

The reduction of deer habitat and deer densities from clearcutting, as well as habitat fragmentation 

can affect wolf populations. Because wolves in Southeast Alaska use other resources when deer are 

unavailable, switching to alternative prey such as salmon could help to reduce long-term numerical 

declines in wolf populations (Szepanski et al. 1999). All action alternatives would reduce deer 

densities in WAA 406 and 407 by less than one deer per square mile initially, and about one deer per 

square mile at stem exclusion. Alternative 5 would have the highest likelihood of causing deer 

population declines, and therefore the highest risk of impacting wolf populations. 

Current estimated deer densities in WAA 406 are about 13 deer per square mile and 16 deer per 

square mile in WAA 407. None of the action alternatives would meet Forest Plan Standards and 

Guidelines that say to provide, where possible, habitat capable of support deer necessary to sustain 

both wolf populations and the hunters; this is generally considered to be 18 deer per square mile 

(USDA Forest Service 2008b, WILD1.XIV.2, p.4-95). This density of deer provides a high

probability of functioning and persisting predator-prey dynamics between wolves and deer (Person

2014). Therefore, the Saddle Lakes Timber Sale would slightly decrease the number of deer currently 

available to sustain both wolves and hunter demand. 

Wolf/Deer Interactions in Fragmented Habitat

All action alternatives would increase forest fragmentation. Timber harvest, road building, and 

subsequent spatial isolation of winter habitats may intensify predation on resident deer populations 

and indirectly impede recruitment of migratory deer. Deer concentrate in residual patches of oldgrowth forest during winter and may suffer higher mortality from wolf predation (Person and 

Kirchhoff 2009, Person et al. 1996, Kirchhoff 1994). While wolves may benefit short term from 

concentrations of deer, overall declines in deer populations could lead to fluctuating wolf populations 

and result in less wolves over time.
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Issue 3A – Wildlife Habitat - Chapter 3  129

Farmer et al. (2006) determined predation by wolves was the primary source of mortality for does and 

yearling females; topographic features such as the proportion of flat terrain exerted the strongest 

influence on predation. Flat and/or open habitats with greater snow accumulation increased the risk 

whereas hillsides and steeper terrain enabled deer to detect predators more easily and made pursuit 

more difficult for wolves.

Road Density

Roads facilitate movements by wolves and may enhance wolf efficiency into areas where deer are 

concentrated (Person et al. 1996). Person (2006) updated the relationship between road density for 

lands below 1,200 feet elevation and wolf mortality related to hunting and trapping. Results indicated 

that the probability of excessive wolf harvest was 40 percent for WAAs with road densities greater 

than 0.7 miles per square mile if the WAA is connected to a community road system. Probability of 

overkill was only 13 percent if the WAA was not road accessible from a community. Roads 

themselves do not decrease habitat capability for wolves, but increased density of roads may lead to 

higher hunting and trapping mortality (USDA Forest Service 2008d Appendix D, p. D-26). Wolf 

mortality has not been identified as a concern for the Saddle Lakes area since it is not connected to a 

community. Increased total road density from project roads could facilitate walk-in access to 

additional hunting and trapping areas, but would not increase the probability of overkill. 

Table 43. Effects to wolf on NFS lands1/ in WAAs 406 and 407

Parameter

Deer and Road Densities

Historic Existing \ 

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

WAA 406

Deer Density 17 13.112.9 13.0 12.9 12.9 12.9

Deer Density stem exclusion 12.5 12.7 12.5 12.4 12.5

Open Road (mi)2/

N/A

73.8 82.2 76.9 87.9 88.9 86.1

Max Open road density (mi/mi2) 0.7 0.8 0.7 0.8 0.8 0.8

Total road (mi) 151.4 159.8 154.5 165.5 166.5 163.7

Total road density (mi/mi2) 1.4 1.5 1.4 1.5 1.5 1.5

WAA 407

Deer Density 18 16.015.6 15.8 15.5 15.3 15.6

Deer Density stem exclusion 15.0 15.3 14.9 14.7 15.0

Open Road (mi)2/

N/A

23.9 31.3 31.0 35.0 36.3 34.3

Max Open road density (mi/mi2) 0.6 0.8 0.8 0.9 1.0 0.9

Total road (mi) 35.3 42.7 42.5 46.4 47.7 45.7

Total road density (mi/mi2) 0.9 1.1 1.1 1.2 1.3 1.2

Source: USFS, Tongass National Forest GIS. N/A = Not Available.

1/ Includes only NFS roads and lands below 1,200 feet elevation; freshwater lakes not included.

2/ Open road densities would increase during life of the sale then would revert to existing level of open road.

Current open road density in WAA 406 is 0.7 mile per square mile. Under all action alternatives, 

open road densities within WAAs 406 would either remain at 0.7 mile per square mile, or increase 

slightly to 0.8 mile per square mile (Table 43). Current open road density in WAA 407 is 0.6 mile 

per square mile. Under all action alternatives, open road densities within WAAs 406 would increase 

to 0.8 to 1.0 mile per square mile (Table 43). After project roads are closed at the end of the sale, 

open road densities would return to existing levels. Current total road density in WAA 406 is 1.4 
3 Affected Environment and Environmental Consequences

130  Chapter 3 – Issue 3A – Wildlife Habitat Saddle Lakes Timber Sale Final EIS

miles per square mile and would either remain the same or increase to 1.5 miles per square mile. 

Current total road density in WAA 407 is 0.9 and could increase to 1.1 to 1.3 miles per square mile. 

State of Alaska Right-of Way on NFS Land

Road construction by the State of Alaska within the ROW would increase the open and total road 

miles in WAA 407 (see Table 43) by 0.7 mile under Alternatives 2 and 3, and by 0.1 mile under 

Alternatives 4, 5, and 6. Open and closed road densities would increase less than 0.1 mile per square 

mile. Once new timber sale roads are closed (except for Road 8300280), open road densities in WAA 

407 would equal 0.7 mile per square mile under all action alternatives. Total road density would equal 

1 mile per square mile.

Table 43 summarizes effects to wolf on NFS lands in WAAs 406 and 407. 

Alternative 1

Alternative 1 would have the lowest impact on wolves since it would maintain the highest deer 

density to support wolves and the lowest road density to help prevent overharvest. 

Deer Density

Alternative 1 would have no direct effect on deer density and therefore, no effect on deer/wolf 

interactions. In WAA 406 the estimated deer density at stem exclusion under Alternative 1 would 

decline from 13.1 deer per square mile to 12.5 deer per square mile. In WAA 407 the estimated deer 

density at stem exclusion under Alternative 1 would decline from 16.0 deer per square mile to 15.0 

deer per square mile. 

Wolf/Deer Interactions in Fragmented Habitat

Existing connectivity would be maintained allowing deer to utilize slopes to escape wolves. 

Secondary prey sources such as salmon would also be unaffected under this alternative. Wolf 

populations would continue to fluctuate based upon natural processes such as prey availability after 

average and severe winters and from hunting and trapping mortality. 

Wolf Populations and Road Density

Total road densities are currently above 1 mile per square mile in WAA 406, but are below 1 mile per 

square mile in WAA 407 (Table 43). Road density would not change under Alternative 1. Total road 

densities in WAA 407 would remain above the Forest Plan Standards and Guidelines (USDA Forest 

Service 2008b, WILD1.XIV.1 p. 4-95), but road density has not been an issue for the Saddle Lakes 

area since it is not currently connected to any community. Regulatory processes are currently in place 

to deal with human-caused mortality.

Alternatives 2, 3, 4, 5, and 6

See Effects Common to All Action Alternatives section above. Of the action alternatives, Alternative 

3 has the lowest potential impact on wolves followed by Alternatives 2, 6, 4, then 5. 

Cumulative Effects

The measurement criteria for analyzing cumulative effects to wolves are the same as those used for 

direct and indirect effects. All land ownerships in WAAs 406 and 407 were used as the scale for 

analysis. Impacts on wolves are also considered at the Revilla Island/Cleveland Peninsula 

biogeographic province level. The Forest Plan FEIS states, “Most of the WAAs that currently meet 

the Wolf guideline, but may not meet it in the future after 100 plus years of implementation, are 

located in the North Central Prince of Wales and Revilla Island/Cleveland Peninsula Biogeographic 

Provinces “(USDA Forest Service 2008c, pp.3- 283 to 3-284)”. 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Issue 3A – Wildlife Habitat - Chapter 3  131

Effects Common to All Action Alternatives

Historic timber harvest and road construction on all land ownerships has reduced deer habitat 

capability and therefore deer densities as calculated by the deer model (Table 44). Habitat capability 

was reduced on the east side of Carroll Inlet (WAA 406) with the construction of the Swan Lake 

hydro-facility and lake (about 500 acres). The proposed expansion of the dam would impact another 

95 acres (47 acres of HPOG, 41 acres of medium and low POG and about 8 acres of non POG), 

reducing habitat capability. The proposed Trust land exchange would affect deer and road densities, if 

approved. 

Public motorized access would increase with the completion of the Ketchikan to Shelter Cove Road. 

This public road would increase open road densities, and likely increase hunting and/or trapping 

pressure for deer and wolves, and cause a shift from current boat-based access to vehicle access. 

While wolf mortality has not been identified as a concern in the past, completion of the Ketchikan to 

Shelter Cove Road could lead to wolf mortality concerns in the future. Using the information from 

Person (2006) above, the probability of overkill (i.e., unsustainable harvest) of wolves would increase 

from 13 percent to 40 percent with completion of the Ketchikan to Shelter Cove Road. 

Table 44. Cumulative effects on wolves on all land ownerships in WAAs 406 and 407

Historic Existing / 

Alt 1

Alternatives

Alt. 2 Alt. 3 Alt. 4 Alt. 5 Alt. 6

WAA 4061/

Number of Deer/square mile

Deer Density

18

12.7 12.5 12.7 12.5 12.5 12.6

Deer Density stem 

exclusion 12.3 12.1 12.3 12.1 12.0 12.1

Road Density (mi) 

Open Road (mi)2/

N/A

91.7 100.1 94.8 105.8 106.8 104.0

Max Open road 

density (mi/mi2

) 0.8 0.9 0.8 0.9 0.9 0.9

Total road (mi) 170.0 178.4 173.1 184.1 185.1 182.3

Total road density 

(mi/mi2

) 1.5 1.6 1.5 1.6 1.6 1.6

WAA 4071/

Number of Deer/square mile

Deer Density

24

10.0 9.8 9.9 9.7 9.6 9.7

Deer Density stem 

exclusion 9.7 9.4 9.6 9.3 9.2 9.4

Road Density (mi) 

Open Road (mi)2/

N/A

136.2 143.6 143.3 147.2 148.6 146.6

Max Open road 

density (mi/mi2

) 1.8 1.9 1.9 2.0 2.0 2.0

Total road (mi) 149.1 156.5 156.2 160.1 161.5 159.5

Total road density 

(mi/mi2

) 2.0 2.1 2.1 2.1 2.2 2.1

Source: USFS, Tongass National Forest GIS. N/A = Not Available.

1/ Includes both NFS and non-NFS roads and lands below 1,200 feet elevation; freshwater lakes not included. 2/ Open road 

densities would increase during life of the sale then would revert to existing level of open road.
3 Affected Environment and Environmental Consequences

132  Chapter 3 – Issue 3A – Wildlife Habitat Saddle Lakes Timber Sale Final EIS

Alternative 1 

Alternative 1 would not contribute to cumulative effects. However, previously harvested stands have

and will continue to decrease deer density as additional stands move into stem exclusion. From deer 

model results, deer densities across all land ownerships were historically at or above the 18 deer per 

square mile. Based upon land selection and past harvest, deer densities within WAAs 406 and 407 are 

now at 12.7 and 10.0 deer per square mile, respectively (Table 44). They would decrease further (32 

percent and 40 percent reduction from historic levels, respectively) as previously harvested stands 

continue to move into stem exclusion. 

The likelihood of unsustainable wolf harvest would increase with the completion of the Ketchikan to 

Shelter Cove Road. Total road densities are substantially above 1 mile per square mile. The Ketchikan 

to Shelter Cove Road would increase these densities. 

Alternatives 2 , 3, 4, 5, and 6

None of the action alternatives would provide 18 deer per square mile to support wolves at the 

cumulative level across all land ownerships. Alternatives 2 through 6 when added to past projects 

would reduce deer densities in WAA 406 by roughly 6 deer per square mile from historic conditions 

at stem exclusion (Table 44). Deer densities in WAA 407 would drop from historic conditions to 

roughly 15 deer per square mile from historic conditions once stem exclusion occurs. In WAA 406 the 

estimated deer density at stem exclusion could decline from 13.1 deer per square mile to between 

12.4 and 12.7 deer per square mile. In WAA 407 the estimated deer density at stem exclusion could

decline from 16.0 deer per square mile to between 14.7 and 15.3 deer per square mile. 

As a result of past and proposed management activities, wolf home range sizes may be forced to 

expand to contain sufficient deer, wolves may have to shift to other less advantageous prey sources, 

and/or pack size could be reduced due to insufficient deer numbers. 

Alternative 5 would move a portion of the current small OGR in VCU 7470 into the North Revilla 

Roadless Area. This would result in the reduction of the important connectivity corridor between the 

Naha LUD II and George Inlet salt chuck; however this connection is already impacted by the

presence of State land between the existing OGR and George Inlet. This could affect the movement of 

Revillagigedo Island wolf packs.

Total road density would increase further above the guideline of 0.7 to 1.0 mile per square mile in 

both WAAs (Table 44). While wolf mortality has not been a concern in the past, dynamics could shift 

with the completion of the Ketchikan to Shelter Cove Road and become a concern (see analysis based 

upon Person and Logan (2012) below). It is uncertain what, if any, regulatory changes on wolf harvest 

may occur given the State of Alaska’s intensive management goals for GMU 1A (but not WAAs 406 

and 407), and the ESA listing proposal currently being evaluated by the USFWS.

Since deer density is currently below 18 deer per square mile and total road densities are above 1 mile 

per square mile, the methodology used in Person and Logan (2012) was used to determine if wolves 

in WAAs 406 and 407 are at risk of chronic unsustainable mortality or pack depletion. Person and 

Logan (2012) assumed that an annual reported harvest rate of greater than or equal to three wolves 

per home range (30 percent of pack) indicated unsustainable harvest mortality within a WAA. 

Unsustainable harvest for greater than 5 years indicated risk that chronic unsustainable harvest was 

occurring. Kill of greater than seven wolves per pack were considered “pack depletion.” 

Using ADF&G wolf harvest data for WAAs 406 and 407 (Porter 2013a), WAA 406 averaged 3.0 kills 

per pack and WAA 407 averaged 1.6 kills per pack. 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Issue 3A – Wildlife Habitat - Chapter 3  133

Looking at the individual years between 2000 and 2013, WAA 406 had annual harvests of greater 

than or equal to three wolves, eight times during the 14-year reporting period. These data indicate a 

risk of chronic unsustainable mortality. WAA 406 also experienced pack depletion (i.e., annual 

harvest rate of greater than seven wolves) twice during the reporting period. 

Three times during the 14-year reporting period, WAA 407 had annual harvests of greater than or 

equal to three wolves, indicating unsustainable mortality but not chronic unsustainable mortality. No 

pack depletion occurred in WAA 407 during the 14-year reporting period. 

Evaluating effects of harvest mortality on wolf populations using WAAs as spatial units is not ideal.

However, they are the smallest reportable unit by which harvest data are reliably tabulated. Therefore, 

Person and Logan (2012) urge caution about inferring the sustainability of harvest for any particular 

WAA, without considering neighboring areas. See the Wildlife Resource Report for analysis of 

mortality risk on Revillagigedo Island.

Revillagigedo Island/Cleveland Peninsula Biogeographic Province

Wolves were also analyzed by considering deer model deer density outputs for all WAAs within the

Revilla Island/Cleveland Peninsula Biogeographic Province level (Province 15). According to deer 

model outputs, five out of the 19 WAAs in Province 15 historically had deer densities of 18 deer 

per square mile or greater. Currently, only four of the 19 WAAs have least 18 deer per square mile 

or greater (Table 45). 

Table 45. Deer model densities in the Revilla Island/Cleveland Peninsula Biogeographic Province 

(Province 15)

WAA Deer Density 

Historic2/ Deer Density Current2/

1997 FP 

historic 1/

2008 FP NFS 

historic

2008 FP 

current

101 15 14 12 22 21

202 0 0 0 0 0

303 18 18 19 19 18

404 12 12 15 12 12

405 25 21 25 22 18

406 17 13 16 16 12

407 11 10 11 17 15

408 6 6 5 13 13

509 14 13 14 15 14

510 15 10 14 14 10

511 5 5 6 5 5

612 18 18 18 18 18

613 21 20 21 20 19

614 15 13 13 20 20

715 9 9 8 8 8

1815 9 9 8 9 9

1816 11 10 13 11 10

1817 17 17 16 16 16

1902 21 17 22 21 16

Source: USFS, Tongass National Forest GIS.

1/ All non-NFS lands were assigned zero habitat capability (historic and present) due to lack of non-NFS data at the 

biogeographic province scale and to be consistent with Forest Plan methods.

2/Deer model results as run for Saddle Lakes

The deer model results are similar to those predicted in the 1997 Forest Plan. They are similar to the 

2008 Forest Plan results with two noted exceptions; WAA 101 Gravina and WAA 303 Duke Island. 

The 2008 Forest Plan calculations for WAA 101 show deer density being above 18 deer per square 
3 Affected Environment and Environmental Consequences

134  Chapter 3 – Issue 3A – Wildlife Habitat Saddle Lakes Timber Sale Final EIS

mile, both historically and currently. However, calculations run for the Saddle Lakes Timber Sale 

show these WAAs below 18 deer per square mile (Table 45). This may be due to the extensive nonNFS lands on Gravina that were not included in 2008 Forest Plan density calculations. Calculations 

for WAA 303 show slight differences and may be due to updated GIS layers since Duke Island is in a 

non-development LUD. The Forest Plan calculations for WAA 303 are slightly above 18 deer per 

square mile, whereas the Saddle Lakes area historic and current calculations are slightly below 18 

deer per square mile.

The above data suggests that, based on modeled deer densities alone, the Saddle Lakes area WAAs 

and the Revilla Island/Cleveland Peninsula Biogeographic Province may not be capable of both 

sustaining wolf populations and meeting hunter demand. While hunter demand could be affected 

sometime in the future (see subsistence section), all WAAs in Revilla Island/Cleveland Peninsula 

Biogeographic Province are projected to remain above 5 deer/mi2 necessary for viability (Suring et al. 

1993 VPOP Strategy). Therefore, deer densities within the Revillagigedo Island/Cleveland Peninsula 

Biogeographic Province are expected to contribute to maintaining viable wolf populations on the 

Tongass.

Summary of Wolf Effects

Alternative 1 has the least effect on wolves followed by Alternatives 3, 2, 6, 4, then 5, in increasing 

order of effects. Current deer densities in WAAs 406 and 407 are below the Forest Plan guideline of 

18 deer per square mile (USDA Forest Service 2008b, p. 4-95). Clearcut timber harvest would 

decrease habitat capability for deer for up to 150 years or longer. Partial cutting would have shorterterm effects. Therefore, the action alternatives would increase the risk that there will be an insufficient 

number of deer to sustain both wolves and hunter demand. The Saddle Lakes Timber Sale would have 

minor impacts on deer density (approximately 1 deer per square mile reduction). However, at stem 

exclusion, cumulative activities (see Appendix B) in WAAs 406 and 407 would reduce historic deer 

densities by 33 and 63 percent respectively, which could likely affect predator/prey equilibriums. 

Decline in deer numbers can cause wolf home ranges to expand or lead to reductions in pack size or 

condition. 

Roads allow movements by wolves, and may enhance wolf efficiency in areas where deer are 

concentrated. The Saddle Lakes Timber Sale would have a minor impact on road density (less than 1 

percent). However, the completion of the Ketchikan to Shelter Cove Road would connect the Saddle 

Lakes area to the communities of Saxman and Ketchikan. The Ketchikan to Shelter Cove Road could 

cause an increase in trapping pressure potentially making road density and wolf mortality a concern. 

Roads constructed under the Saddle Lakes Timber Sale would add to this concern, as they would 

provide walk-in access into new areas. Wolf populations are currently thought to be stable within 

GMU 1A, with unlimited trapping allowed. Intensive management for deer by ADF&G could further 

decrease wolf populations if expanded to the Saddle Lakes project area WAAs.

Black Bear

Direct/Indirect Effects

The measurement criteria for analyzing direct and indirect effects on the black bear include: acres of 

POG for denning habitat; all habitats except older young growth for foraging habitat; and POG within 

500 feet of Class I fish streams to address the importance of riparian habitat. Three bear dens were 

located and confirmed by ADF&G wildlife biologist within the Saddle Lakes project area. NFS lands 

within WAAs 406 and 407 were used as the scale for direct and indirect effects analysis.
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Issue 3A – Wildlife Habitat - Chapter 3  135

Effects Common to All Action Alternatives

The greatest impact to black bear habitat is the clearcutting of POG, which removes the large trees 

used for denning. This in turn leads to lower bear reproductive success and population density, and 

higher dispersal and mortality (Schoen and Peacock 2007). Young clearcuts provide bears with an 

abundance of forage due to increases in shrub and berry productivity, but forage disappears with the 

onset of stem exclusion (Schoen and Peacock 2007, Brodeur et al. 2008). In addition, young-growth 

stands often lack the root masses and large hollow trees used as denning sites (Bethune 2011).

Partial cutting could affect suitable denning habitat if large diameter trees are removed or if large 

trees with rot are felled for safety reasons. However, these stands would develop large trees more 

quickly than clearcut units (Deal et al. 2009). Partial-cut units would continue to provide forage (Deal 

2007); actual change in available forage would depend upon individual stand removal pattern. 

The availability of spawning salmon in the summer and fall affects body size, reproductive success, 

and population density (Schoen and Peacock 2007). Riparian management area buffers (RMAs) 

protect the first 100 feet adjacent to Class I streams, but not the adjacent habitat heavily utilized by 

foraging bears. However, Schoen and Peacock (2007) assumed, similar to more abundant research on 

brown bear in Alaska, that black bears with access to salmon occur in higher densities and have large 

body size and higher reproductive success than bears not feeding on nutrient-rich salmon. Although 

brown bear do not occur, Saddle Lakes calculated impacts to POG within 500 feet of anadromous fish 

streams to address the importance of riparian habitat to black bear.

The current Forest Plan has no standards and guidelines for black bears. A mitigation measure to

adjust unit boundaries to implement 300-foot buffers around confirmed bear dens in units 64, 

116, and 123 is suggested; it is up to the Responsible Official to implement this measure or not. 

See Table 46 for changes to denning, foraging habitat and habitat within 500 feet of Class I streams. 

Historic conditions for large-tree SD67 POG cannot be reconstructed from currently available 

information. From field recon, it appears that early logging targeted larger, higher-volume stands, but 

harvest ranged from volume classes five through seven. Therefore, although suitable habitat has been 

reduced, it is uncertain how black bears have been affected. Harvest proposed under the Saddle Lakes 

project would decrease existing habitat by 2 percent under Alternative 3 to 19 percent under 

Alternative 5. Alternative 1 has the lowest risk to black bears followed by Alternatives 3, 2, 6, 4, and 

5. 

Alternative 1 

Alternative 1 would have no effect on black bear denning habitat, foraging habitat or foraging 

habitat/cover within 500 feet of Class I streams (Table 46). Alternative 1 would maintain the existing 

OGR connectivity in VCU 7470 preserving the important link with the Naha LUD II source 

populations and George Inlet salt chuck; however this connection is already impacted by the presence 

of State land between the OGR and George Inlet. Existing stands would continue to move toward 

stem exclusion and individual den sites could be affected by natural processes such as windthrow. 

Alternative 2 

Alternative 2 would harvest a total of 1,886 acres of bear denning habitat (Table 46). Impacts to bear 

denning would be long term until young growth reaches sufficient size to provide the trees and snags 

necessary to accommodate bear use. Alternative 2 would clearcut around one confirmed den and 

partial-cut around a second confirmed den. The remaining confirmed den falls outside of unit 

boundaries. Uneven-aged management prescriptions could maintain denning structures, particularly 
3 Affected Environment and Environmental Consequences

136  Chapter 3 – Issue 3A – Wildlife Habitat Saddle Lakes Timber Sale Final EIS

in large unmerchantable trees, but the extent will not be known until individual stand prescriptions are 

written, and OSHA safety regulations are implemented during logging. 

Table 46. Change in bear habitat on NFS Lands in WAAs 406 and 407

Habitat

Acres (% change from existing)

Historic Existing 

\ Alt. 1 Alt. 2 Alt. 3 Alt. 4 Alt. 5 Alt. 6

WAA 406

Denning Habitat1/ 61,321 48,982 47,873

(-2.3%)

48,626

(-0.7%)

47,756

(-2.5%)

47,441

(-3.1%)

47,934

(-2.1%)

Foraging Habitat2/ 122,385 110,046 108,699

(-1.2%)

109,579

(-0.4%)

108,543

(-1.4%)

108,127

(-1.8%)

108,750

(-1.2%)

POG within 500 

feet of Class I 

streams

7,615 6,433 6,288

(-2.3%)

6,350

(-1.3%)

6,285

(-2.3%)

6,252

(-2.8%)

6,279

(-2.4%)

WAA 407

Denning Habitat1/ 19,789 17,946 17,169

(-4.3%)

17,478

(-2.6%)

17,093

(-4.8%)

16,852

(-6.1%)

17,179

(-4.3%)

Foraging Habitat2/ 41,146 39,303 38,443

(-2.2%)

38,758

(-1.4%)

38,364

(-2.4%)

38,107

(-3.0%)

38,457

(-2.2%)

POG within 500 

feet of Class I 

streams

2,517 2,320 2,272

(-2.1%)

2,318

(<0.1%)

2,275

(-1.9%)

2,233

(-3.8%)

2,275

(-1.9%)

SD67 black bear habitat by VCU3/

VCU 7460 Unk 709 643

(-9.3%)

696

(-1.8%)

583

(-17.8%)

573

(-19.2%)

607

(-14.4%)

VCU 7470 Unk 686 628

(-8.5%)

642

(-6.4%)

605

(-11.8%)

572

(-16.6%)

605

(-11.8%)

VCU 7530 Unk 531 531

(0%)

531

(0%)

531

(0%)

531

(0%)

531

(0%)

VCUs combined Unk 1,927 1,802

(-6.5%)

1,869

(-3.0%)

1,719

(-10.8%)

1,676

(-13.0%)

1,743

(-9.5%)

Source: USFS, Tongass National Forest GIS.

1/ Denning = POG – all SD categories SD4H through SD67 at all elevations.

2/ Foraging = All habitats except stem exclusion. 

3/ Acres of large-tree POG (SD67); 

4/ The amount of historic large tree (SD67) habitat is unknown and cannot be reconstructed from available information.

Alternative 2 would clearcut 1,055 acres of foraging habitat and partial-cut 1,152 acres. Partial-cut 

units would continue to provide forage long term, but abundance could vary based on stand 

prescriptions. 

Alternative 2 would decrease foraging and security habitat within 500 feet of Class I streams by 

harvesting 193 acres. 

Alternative 2 would maintain the existing OGR connectivity in VCU 7470 preserving the important 

link with the Naha LUD II source populations and George Inlet salt chuck; however this connection is 

already impacted by the presence of State land between the OGR and George Inlet. Alternative 2 

would have the second-least impact on bear habitat of the action alternatives.
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Issue 3A – Wildlife Habitat - Chapter 3  137

Alternative 3

Alternative 3 would harvest 824 acres of bear denning habitat (Table 46). Alternative 3 would partialcut around one confirmed bear den. The remaining bear dens fall outside of unit boundaries. 

Alternative 3 would clearcut 816 acres of foraging habitat and partial-cut 196 acres, and would 

clearcut 85 acres of cover and forage habitat within 500 feet of Class I streams. 

Alternative 3 maintains the existing OGR connectivity in VCU 7470 preserving the current 

connectivity with the Naha LUD II source populations and George Inlet salt chuck; however this 

connection is already impacted by the presence of State land between the OGR and George Inlet. 

Alternative 3 would have the least impact on bear habitat of the action alternatives.

Alternative 4

Alternative 4 would harvest 2,079 acres of bear denning habitat (Table 46). Denning habitat would be 

reduced long term from the 1,798 acres of clearcutting, but less so from the 281 acres of partialcutting. Alternative 4 would clearcut around one confirmed bear den and partial-cut around a second 

confirmed den. The remaining known bear den is outside of the boundaries of harvest units. 

Alternative 4 would clearcut 2,112 acres of bear foraging habitat and partial-cut 312 acres. Alternative 

4 would clearcut 193 acres of habitat within 500 feet of Class I streams. 

Alternative 4 maintains the existing OGR connectivity in VCU 7470 preserving the current 

connectivity with the Naha LUD II source populations and George Inlet salt chuck; however this 

connection is already impacted by the presence of State land between the OGR and George Inlet. It 

has the second greatest impact on bear habitat of the action alternatives.

Alternative 5

Alternative 5 would harvest 2,635 acres of bear denning habitat (Table 46). Alternative 5 would 

clearcut both units that contain bear dens, resulting in a direct loss of den sites. Alternative 5 would 

have the greatest long-term impact on foraging habitat (Table 46) by harvesting 2,875 acres of POG, 

predominantly through clearcutting. Alternative 5 would have the greatest impact to habitat within 

500 feet of Class I streams since 268 acres of existing habitat would be clearcut, leaving only the 100 

foot riparian buffer (RMA).

Alternative 5 would move the small OGR in VCU 7470, reducing the connection between the Naha 

LUD II and George Inlet salt chuck however this connection is already impacted by the presence of 

State land between the OGR and George Inlet. After moving the OGR, proposed clearcutting would 

reduce foraging and security habitat along Salt Creek beyond the 100 foot RMA. Alternative 5 has the 

greatest impact on bear habitat of the action alternatives.

Alternative 6

Alternative 6 would clearcut 1,423 acres of bear denning habitat and partial-cut 391 acres (Table 46). 

Alternative 6 would clearcut around one confirmed den and partial-cut around a second confirmed 

den. The remaining confirmed den falls outside of unit boundaries. Alternative 6 would harvest 2,138 

acres of foraging habitat. Impacts to foraging habitat would be similar, but slightly less than described 

in Alternative 4, due to a higher proportion of uneven-aged management. Alternative 6 would harvest 

200 acres of foraging and security habitat within 500 feet of Class I streams.

Alternative 6 maintains the existing OGR connectivity in VCU 7470 preserving the current 

connectivity with the Naha LUD II source populations and George Inlet salt chuck; however this 

connection is already impacted by the presence of State land between the OGR and George Inlet. 

Alternative 6 has the third greatest impact on bear habitat of the action alternatives.
3 Affected Environment and Environmental Consequences

138  Chapter 3 – Issue 3A – Wildlife Habitat Saddle Lakes Timber Sale Final EIS

Cumulative Effects

The measurement criteria for analyzing cumulative effects on the black bear are the same as those 

used for direct and indirect effects. All land ownerships within WAAs 406 and 407 were used as the 

scale for the cumulative effects analysis.

Effects Common to All Action Alternatives

All past and current activities within WAAs 406 and 407 have affected bears or bear habitat in some 

manner. Changes in denning and foraging habitat have contributed to reductions in black bear 

populations in GMU 1A (Bethune 2011). Even-aged timber harvest (clearcut) has had the greatest 

impact on bear habitat, as stands are currently in stem exclusion or will be in stem exclusion within 

30 years. 

If the proposed AMHT land exchange is approved, an additional 8,170 acres would be taken out of 

NFS ownership and Forest Plan Standards and Guidelines, including beach buffers and RMAs, would 

no longer apply. This potential impact was not included in cumulative effects analysis because the 

land is currently still in Forest Service ownership.

The Ketchikan to Shelter Cove Road connection is likely to increase hunting pressure within the 

portions of WAAs 406 and 407 that can be accessed from the road system. Table 47 shows cumulative 

reduction in bear habitat. 

Table 47. Cumulative effects to black bear habitat in all land ownerships for WAAs 406 and 407, Saddle 

Lakes project area

Habitat

Acres (% reduction from existing)

Historic Existing 

\ Alt. 1 Alt. 2 Alt. 3 Alt. 4 Alt. 5 Alt. 6

WAA 406

Denning Habitat1/ 63,536 51,099

(-19.6%)

49,990

(-21.3%)

50,743

(-20.1%)

49,873

(-21.5%)

49,558

(-22.0%)

50,051

(-21.2%)

Foraging Habitat2/ 125,078 112,641

(-9.9%)

111,295

(-11.0%)

112,174

(-10.3%)

111,139

(-11.1%)

110,723

(-11.5%)

111,345

(-11.0%)

POG within 500 feet 

of Class I streams 8,944 7,143

(-20.1%)

6,998

(-21.8%)

7,060

(-21.1%)

6,995

(-21.8%)

6,961

(-22.2%)

6,988

(-21.9%)

WAA 407

Denning Habitat1/ 31,257 25,704

(-17.8%)

24,927

(-20.3%)

25,235

(-19.3%)

24,850

(-20.5%)

24,609

(-21.3%)

24,937

(-20.2%)

Foraging Habitat2/ 61,000 55,446

(-9.1%)

54,585

(-10.5%)

54,900

(-10.0%)

54,507

(-10.6%)

54,250

(-11.1%)

54,599

(-10.5%)

POG within 500 feet 

of Class I streams 6,244 3,734

(-40.2%)

3,686

(-41.0%)

3,732

(-40.2%)

3,689

(-40.9%)

3,647

(-41.6%)

3,689

(-40.9%)

SD67 Habitat by Combined WAAs

SD673/ 9,269 5,998

-35%

4,1964/

-30%

4,129

-31%

4,279

-29%

4,322

-28%

4,255

-29%

Source: USFS, Tongass National Forest GIS.

1/ Denning = POG all elevations. 

2/ Foraging = All habitats except stem exclusion shown for stem exclusion phase. See deer non-winter for initial effects on 

similar habitat.

3/ The Forest Plan estimated that on Forest Service lands, 29 percent of the historic harvest was large tree SD67 POG (USDA 

2008 FEIS Appendix B p. B-30).

4/ Based on acres of SD67 harvested by combined VCUs
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Issue 3A – Wildlife Habitat - Chapter 3  139

Alternative 1 

Alternative 1 would not contribute to cumulative effects within the Saddle Lakes area. However, past

timber harvest and other management activities on all ownerships have reduced black bear denning

habitat in WAAs 406 and 407 to 80 and 82 percent, respectively of what was available historically 

(Table 47). Foraging areas along Class I streams have been impacted the greatest with about 60 

percent of the historic habitat remaining in WAA 407 and about 80 percent remaining within WAA 

406. Reductions in foraging habitat may mean that bears enter the winter in poorer condition which 

can affect overwinter survival and reproductive success.

Alternatives 2, 3, 4, 5, and 6

Cumulative impacts are similar between the action alternatives and include incremental impacts from 

past and future harvest discussed under Alternative 1. Denning and foraging habitat would be reduced 

long-term (Table 47). Alternative 5 would result in the greatest impact to denning, foraging and 

habitat along Class I streams. In WAA 406 these habitats would have 78 percent, 88 percent and 78 

percent remaining of what was historically available. In WAA 407 these habitats would have 79 

percent, 89 percent and 58 percent remaining of what was historically available. 

Summary of Bear Effects

Past, present, and future management actions would reduce bear denning habitat by up to 22 percent 

and foraging habitat by up to 12 percent in WAA 406 and foraging habitat along streams by up to 42 

percent in WAA 407. These actions have likely reduced bear populations as a result. Alternative 1 

would have no direct impact on current bear habitat or populations. Alternative 3 would have the next 

lowest impact, followed by Alternatives 2, 6, and 4, in increasing levels of effects. Alternative 5 

would have the greatest impact to black bears. The long-term effects of clearcut logging, even with 

precommercial thinning (PCT), are detrimental to black bear populations in GMU 1A (Bethune 

2011). 

Mountain Goat

Direct/Indirect Effects

The interagency mountain goat habitat capability model has shown the most important goat habitat to 

generally be productive old-growth forest within 1,300 feet of escape terrain. Measurement criteria 

for analyzing direct and indirect effects to mountain goats include acres of POG within 1,300 feet of 

slopes greater than or equal to 50 degrees (cliffs) NFS lands within WAAs 406 and 407 were used as 

the scale for direct and indirect effects analysis. Actual impacts to goat populations are unknown 

since they are a relatively new introduction in the area, but appear to be stable to increasing (Porter 

2010a). 

Effects Common to All Action Alternatives

Timber harvest can affect mountain goat populations by reducing the amount of habitat available for 

mountain goats during the critical winter season (ADF&G 2013a). The amount and distribution of 

escape terrain within suitable winter habitat is a primary determinant of goat winter range (Fox et al. 

1989). Nannies with kids would be the most impacted as they have the most restricted area within 

escape cover to avoid predators.

Table 48 summarizes change in mountain goat habitat by alternative. 
3 Affected Environment and Environmental Consequences

140  Chapter 3 – Issue 3A – Wildlife Habitat Saddle Lakes Timber Sale Final EIS

Table 48. Change in mountain goat habitat

1/ on NFS Lands in WAAs 406 and 407

Area Historic

Acres (% reduction from existing acres)

Existing \ 

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

WAA 406 46,296 37,896 37,407

(-1.3%)

37,775

(-0.3%)

37,328

(-1.5%)

37,191

(-1.9%)

37,482

(-1.1%)

WAA 407 15,280 13,939 13,433

(-3.6%)

13,667

(-2.0%)

13,383

(-4.0%)

13,241

(-5.0%)

13,470

(-3.4%)

Source: USFS, Tongass National Forest GIS.

1/ POG within 1,300 feet of a cliff (slope 50 degrees or greater).

Alternative 1

There would be no effect on mountain goats or goat habitat under Alternative 1. All current habitat 

would remain and continue to provide escape cover from predators and forage. 

Alternative 2

Alternative 2 would harvest 996 acres of mountain goat habitat of which 651 acres are partial-cut and 

344 acres are clearcut (Table 48). Impacts would be long-term in clearcut units, but partial-cut units 

would continue to provide habitat, but quality would be reduced in more severe winters. Compared to 

other action alternatives, Alternative 2 would have the second lowest risk of affecting goat habitat.

Alternative 3

Alternative 3 would harvest 393 acres of goat habitat, of which 124 acres are partial-cut and 269 acres 

are clearcut (Table 48). Clearcut areas represent long-term to permanent habitat loss. Similar to 

Alternative 2, partial-cut units would continue to provide habitat, but quality would be reduced in 

more severe winters. Alternative 3 would have the least impact of the action alternatives on goat 

habitat. 

Alternative 4

Alternative 4 would harvest 1,125 acres of goat habitat in project area WAAs, of which 239 acres are 

partial-cut and 885 acres are clearcut (Table 48). Impacts would be long-term in clearcut units, but 

partial-cut units would continue to provide habitat, but quality would be reduced in more severe 

winters. Since most units would be clearcut, impacts to goat habitat would be more severe than 

Alternatives 2 or 3. Alternative 4 would have the second greatest effect on mountain goat habitat and 

predator/prey equilibrium of the action alternatives.

Alternative 5

Alternative 5 would harvest 1,404 acres of goat habitat, with 201 acres partial-cut and 1,203 acres 

clearcut (Table 48). Impacts would be long-term in clearcut units, but partial-cut units would continue 

to provide habitat, but quality would be reduced in more severe winters. Alternative 5 proposes the 

greatest amount of clearcutting representing the greatest long-term to permanent habitat loss. Of the 

action alternatives, Alternative 5 would have the greatest impact on goat habitat. The proposal to 

relocate a portion of the OGR under Alternative 5 should have no impact on mountain goats or their 

habitat. 

Alternative 6

Alternative 6 would harvest 884 acres of goat habitat, of which 311 acres are partial-cut and 573 acres 

are clearcut (Table 48). Impacts would be long-term in clearcut units, but partial-cut units would 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Issue 3A – Wildlife Habitat - Chapter 3  141

continue to provide habitat, but quality would be reduced in more severe winters. Alternative 6 would 

have the third lowest risk of affecting goats and predator/prey equilibrium of the action alternatives. 

Alternative 6 harvests less mountain goat habitat overall than Alternative 2, but proposes more 

clearcutting.

Cumulative Effects

Measurement criteria for analyzing cumulative effects to mountain goats are the same as was used for 

analyzing direct and indirect effects. All land ownerships within WAAs 406 and 407 were used as the 

scale for the cumulative effects analysis.

Effects Common to All Action Alternatives

Cumulative impacts to mountain goat habitat have been more substantial across time and all land 

ownerships. Past timber harvest has directly removed both winter foraging areas and escape terrain. 

Additional impacts could occur from the proposed Swan Lake and Mahoney Lake hydropower 

expansion projects

Table 49 summarizes cumulative change in mountain goat habitat by alternative.

Table 49. Cumulative change in mountain goat habitat1/ on all land ownerships in WAAs 406 and 407

Area Historic

Acres (% reduction from historic acres)

Existing \ 

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

WAA 406 47,600 38,865

(-18.4%)

38,376

(-19.4%)

38,744

(-18.6%)

38,297

(-19.5%)

38,159

(-19.8%)

38,451

(-19.2%)

WAA 407 24,279 17,760

(-26.9%)

17,253

(-28.9%)

17,487

(-28.0%)

17,203

(-29.1%)

17,061

(-29.7%)

17,290

(-28.8%)

Source: USFS, Tongass National Forest, GIS.

1/ POG within 1,300 feet of a cliff (50 degree slope or greater).

Alternative 1 

Alternative 1would not contribute to cumulative effects since there are no direct or indirect effects.

However, past management activities in WAA 406 have reduced historic goat habitat (Table 49).

Additional habitat could be affected in both WAAs 406 and 407 by the proposed AMHT land 

exchange since the proposal includes forest habitat adjacent to higher elevation ridges. These acres 

were not included in the cumulative analysis because at this time the land has not yet been conveyed.

Alternatives 2 , 3, 4, 5, and 6

Cumulative impacts to mountain goats would be more substantial in scope and intensity than direct 

and indirect effects (Table 49). Present and future management actions may affect the established 

population as habitat is reduced below existing amounts. Nannies with kids would be the most 

impacted as they have the most restricted area within escape cover to avoid predators. Reduced winter 

habitat would affect available foraging areas and/or the amount of forage available. This could either 

push goats into areas further from escape cover making them more susceptible to predation, cause 

then to expend more energy obtaining forage, and/or affect body condition and subsequent 

reproductive success.
3 Affected Environment and Environmental Consequences

142  Chapter 3 – Issue 3A – Wildlife Habitat Saddle Lakes Timber Sale Final EIS

Summary of Mountain Goat Effects

Impacts from the Saddle Lakes project would be limited (up to 5 percent reduction from the existing 

condition) whereas cumulative effects have been more substantial (up to 30 percent reduction). 

However, since these mountain goat populations are a relatively recent introduction (1983 and 1991), 

it is uncertain how much past management activities have actually impacted goat populations. Both 

populations are stable to expanding (Porter 2010b). Alternative 1 would maintain the most goat 

habitat followed by Alternatives 3, 2, 6, 4, and 5, in increasing order of effects. 

American Marten

Direct/Indirect Effects

The measurement criteria used to analyze direct and indirect effects to marten include: Acres of highPOG less than or equal to 1,500 feet elevation as the winter measurement, POG for year-round 

effects, and road densities less than 1,500 feet elevation. NFS lands within VCUs 7460, 7470, and 

7530 were used as the scale for analysis. 

The marten model has not been used in recent analyses, and it was not used it for analysis in the 

Saddle Lakes project area for the following reasons: 1) selected winter high-POG habitat corresponds 

to the highest HSI values from the model; 2) habitat loss was considered, based upon the available 

research, to be a more direct approach than including a “multiplier” to predict a “theoretical” number 

of marten. 

Well-distributed marten populations were defined as occurring in every third-order watershed or 

generally a 10,000 acre landscape approximately the size of an average VCU (USDA Forest Service 

1997a, p. 3-398). Direct and Indirect effects to marten were calculated at the VCU level.

Effects Common to All Action Alternatives

Clearcut harvest reduces canopy cover, the amount of coarse woody debris, the availability of 

denning and habitat for prey species, and marten hunting efficiency. Clearcutting differs from natural 

disturbances in that it represents a large-scale change rather than small dispersed patches where trees 

remain standing or partially standing (Hansen et al. 1991). Clearcuts reduce forest cover exposing 

martens to much higher snow accumulations and predation risks (Schoen et al. 2007a). Avoidance of 

both young and older clearcuts in the winter is well documented both in Alaska (Flynn 2006, Flynn & 

Schumacher 2001, Flynn & Schumacher 1999) and other areas. Therefore, clearcutting creates longterm habitat loss.

Cheveau et al. 2013 and Johnson et al. 2009 found that clearcutting affected female body index 

(reproduction) and juvenile survival respectively.

Partial-cutting may have less effect on marten populations. Thompson and Harestad (1994) theorized 

that selective logging which removed less than 30 percent of the basal area every 100 years in 

temperate rain forests would not reduce habitat carrying capacity. Godbout and Ouellet (2008) found 

that marten neither selected for or against units that had been partial-cut as long as canopy cover and 

structure was maintained.

Roads can indirectly affect marten by facilitating trapper access. Habitat suitability for marten begins 

to decline when road density reaches 0.2 mile per square mile. Interior areas away from roads can act 

as a refugium from trapping (Flynn et al. 2007). Marten within these source areas are able to disperse 

into sink areas after the trapping season ends. Extensive roading results in most marten home ranges 

being intercepted by roads which can result in the entire population being vulnerable to overharvest 

(Suring et al. 1993). 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Issue 3A – Wildlife Habitat - Chapter 3  143

Table 50 summarizes change in marten habitat by VCU. 

Table 50. Change in marten habitat on NFS Lands by VCU

Habitat Historic

Acres (% reduction from existing) and Road Density1/

Existing \ 

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

VCU 7460

Winter2/ 12,541 7,317 6,941

(-5.1%)

7,246

(-1.0%)

6,871

(-6.1%)

6,820

(-6.8%)

6,947

(-5.1%)

Year-round3/ 19,869 14,493 13,641

(-5.9%)

14,277

(-1.5%)

13,524

(-6.9%)

13,321

(-8.1%)

13,713

(-5.4%)

Open Road 

Density

(mi/mi2

) N/A

1.0 1.1 1.0 1.3 1.3 1.2

Total Road 

Density

(mi/mi2

) 

2.2 2.3 2.2 2.5 2.5 2.4

VCU 7470

Winter2/ 5,548 4,064 3,649

(-10.2%)

3,856

(-5.1%)

3,598

(-11.5%)

3,438

(-15.4%)

3,642

(-10.4%)

Year-round3/ 9,388 7,903 7,126

(-9.9%)

7,435

(-5.9%)

7,050

(-10.8%)

6,809

(-13.8%)

7,136

(-9.7%)

Open Road 

Density

(mi/mi2

) N/A

0.7 1.1 1.1 1.4 1.4 1.3

Total Road 

Density

(mi/mi2

) 

1.2 1.6 1.6 1.9 2.0 1.8

VCU 7530

Winter2/ 10,250 5,637 5,584

(-0.9%)

5,610

(-0.5%)

5,583

(-1.0%)

5,518

(-2.1%)

5,583

(-1.0%)

Year-round3/ 17,073 12,433 12,176

(-2.1%)

12,293

(-1.1%)

12,177

(-2.1%)

12,064

(-3.0%)

12,166

(-2.1%)

Open Road 

Density

(mi/mi2

) N/A

0.7 0.8 0.7 0.8 0.8 0.8

Total Road 

Density

(mi/mi2

) 

1.5 1.6 1.6 1.6 1.6 1.6

Source: USFS, Tongass National Forest, GIS. N/A = Not Available.

1/ NFS total road density below 1,500 feet elevation. 

2/ Winter habitat equals high-POG less < 1500 ft. elevation

3/ Year-round habitat equals POG, all elevations.

State of Alaska Right-of Way on NFS Lands

The State of Alaska ROW on NFS lands would increase the open and total road miles in VCU 7470 

by 0.7 mile under Alternatives 2 and 3 and by 0.1 mile under Alternatives 4, 5, and 6 (Table 50). Open 

and closed road densities would increase less than 0.1 mile per square mile. Once new timber sale 

roads are closed (except for proposed NFS Road 8300280), open road densities in VCU 7470 would 
3 Affected Environment and Environmental Consequences

144  Chapter 3 – Issue 3A – Wildlife Habitat Saddle Lakes Timber Sale Final EIS

equal 0.7 mile per square mile under all action alternatives. Total road density would equal 1.3 mile 

per square mile.

Alternative 1

Alternative 1 would have no direct or indirect effect on marten populations or marten habitat. 

Existing winter and year-round habitat would be maintained. Population dynamics would continue to 

function. Prey abundance (see red squirrel and endemic mammal sections) would continue to 

fluctuate from natural causes. Therefore, current hunting efficiency and social interactions would 

continue. The small OGR would be maintained in its current location, maintaining the current 

connectivity between source and sink habitat and facilitating marten movement across the landscape.

Existing open and total road densities are above 0.6 mile per square mile but have not created 

mortality concerns. Trappers are currently allowed to trap an unlimited number of marten. Pelt price 

and weather currently influence trapping pressure more than road density. Under this alternative, 

changes in marten populations are expected to be directly attributable to natural causes (e.g., 

fluctuations in prey populations), changes in pelt price, or both. 

Alternative 2 

Alternative 2 would harvest a total (combined VCUs) of 844 acres of high-POG winter habitat and 

1,885 acres of year-round POG habitat. Alternative 2 would have the second lowest impact on marten 

populations and marten habitat of the action alternatives (Table 50). Winter habitat would be directly 

affected within the 370 acres of clearcut harvest. The 474 acres partial-cut may have minimal effect 

on marten. The 916 acres of clearcutting within year-round POG would directly affect denning and 

resting sites and prey abundance. Home ranges of affected individuals would likely increase in size. 

Alternative 2 would increase open and total road densities by 0.1 mile per square mile in VCU 7460, 

by 0.4 mile per square mile in VCU 7470, and by 0.1 mile per square mile in VCU 7530. 

Alternative 3

Alternative 3 would harvest a total (combined VCUs) of 306 acres of high-POG winter habitat and 

824 acres of year-round POG habitat. Alternative 3 would have the least impact on marten 

populations and marten habitat of the action alternatives (Table 50). About 201 acres of winter habitat 

would be clearcut. Similar levels of impact would occur to year-round habitat (Table 50). Based on 

identified linear relationships, timber harvest in Alternative 3 could result in a 1 to 6 percent reduction 

in marten populations. However, the 105 acres of partial cutting in winter habitat and 161 acres of 

partial cutting in year-round habitat may have minimal effect on marten. 

Alternative 3 would not increase open road densities in VCUs 7460 or 7530, but would increase 

current road densities in VCU 7470 to 1.1 miles per square mile. Total road densities would increase 

less than 0.1 miles per square mile in VCU 7460, increase by an additional 0.4 miles per square mile 

in VCU 7470, and increase by an additional 0.1 miles per square mile in VCU 7530. 

Alternative 4

Alternative 4 would harvest 967 acres of high-POG winter habitat and 2,079 acres of year-round POG 

habitat. Alternative 4 would have the second highest impact on marten populations and marten habitat

(Table 50). About 774 acres of winter habitat would be clearcut directly affecting marten and 195 

acres would be partial-cut. Timber harvest in Alternative 4 could result in up to a 12 percent reduction 

in marten populations. Winter habitat would be affected long term within clearcut harvest units. 

Home ranges of affected individuals would likely increase in size.
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Issue 3A – Wildlife Habitat - Chapter 3  145

Alternative 4 would increase open and total road densities by 0.3 mile per square mile in VCU 7460, 

by 0.7 mile per square mile in VCU 7470, and by 0.1 mile per square mile in VCU 7530. 

Alternative 5

Alternative 5 would harvest 1,242 acres of high-POG winter habitat and 2,635 acres of year-round 

POG habitat. Alternative 5 would have the greatest impact on marten habitat and populations (Table 

50). Roughly 1,132 acres of winter habitat would be clearcut and 109 acres partial-cut. Most yearround habitat would be clearcut. Timber harvest in Alternative 5 could result in up to a 14 percent 

reduction in marten populations. Harvest within POG would directly affect denning habitat. 

Depending upon species, prey abundance would be affected long-term or permanently under current 

100-year timber rotations. Home ranges of affected individuals would likely increase in size. Habitat 

for important prey species would be reduced to the greatest extent under Alternative 5. This reduction 

in prey could also reduce the number of marten within the Saddle Lakes area. 

Alternative 5 would increase open and total road densities by 0.3 mile per square mile in VCU 7460 

during the life of the sale, open road density by 0.7 mile per square mile and total road density by 0.8 

mile per square mile in VCU 7470, and open and total road densities by 0.1 mile per square mile in 

VCU 7530. 

Alternative 6

Alternative 6 would harvest 846 acres of high-POG winter habitat and 1,814 acres of year-round POG 

habitat. Alternative 6 would fall in the middle of the action alternatives for impacts on marten 

populations and marten habitat. Roughly 599 acres of winter habitat would be clearcut with the 

remaining 247 acres being partial-cut. About 1,423 acres of year-round habitat would be clearcut with 

the remaining 391 acres being partial-cut. Timber harvest in Alternative 6 could result in up to a 10 

percent reduction in marten populations. 

Alternative 6 would increase open and total road densities by 0.2 mile per square mile in VCU 7460 

during the life of the sale, by 0.6 mile per square mile in VCU 7470, and open and total road 

densities by 0.1 mile per square mile in VCU 7530. 

Cumulative Effects

Measurement criteria for analyzing cumulative effects to marten are the same as those used for 

analyzing direct and indirect effects. All land ownerships within WAAs 406 and 407 and VCUs 7460, 

7470 and 7530 were used as the scale for the cumulative effects analysis.

Based on three widespread studies (Utah, Maine, Québec), Potvin et al. (2000) conclude that martens 

can tolerate a maximum of 30 percent clearcut harvest within in their home range (also referred to as 

30 percent clearcut tolerance). Poole et al. (2004), Wasserman et al. (2012), and Cushman et al. 

(2011) observed similar results in British Columbia, Idaho, and Wyoming, respectively. This is a 

different measurement that the 1997 Forest Plan marten guideline of 33 percent harvest threshold by 

VCU. Fragmentation constrained foraging paths to the extent that marten were unable to select cover 

types that offered the highest densities of prey species, affecting foraging efficiency. Feldhammer et 

al. (2003) summarized multiple studies suggesting that martens fail to colonize or abandon home 

range size landscapes with less than 60 percent mature forest. Below this threshold, marten inhabit 

suboptimal habitat, spend excessive energy on hunting and have less time available for social 

interaction and breeding. 

Flynn found similar trends in Southeast Alaska: indices of fragmentation correlated with marten 

density with marten numbers higher in less fragmented habitats (Flynn 2006). Flynn et al. 2004 

interpreted the fragmentation variables to collectively indicate that areas with larger and more evenly 
3 Affected Environment and Environmental Consequences

146  Chapter 3 – Issue 3A – Wildlife Habitat Saddle Lakes Timber Sale Final EIS

distributed patches of forest supported higher densities of martens than areas with more fragmented 

forest. Findings by Flynn suggest that trends may be consistent across marten range, and that research 

findings from other areas may be applicable in Alaska.

The Marten Scientific Panel (USDA Forest Service 1997b, Appendix N) concluded that clearcut 

Silviculture on a 100-year rotation would result in further fragmentation of marten habitat and there 

could be substantial gaps in marten distribution which could be permanent and result in limited 

interaction between populations. The consequence of a gap would be some measure of reduced gene 

flow within the population and the greater the size and number of gaps, the higher the risk of reducing 

gene flow. Populations that have become isolated or reduced in size face increased risks of extirpation 

from inbreeding, genetic drift, and random environmental events (Flynn and Schumacher 1997). 

Effects Common to All Action Alternatives

Cumulative effects on marten come from clearcut timber harvest and road construction. Long-term 

effects were considered to be 150 years or longer to provide the full suite of marten habitat 

requirements. The proposed AMHT land exchange of 8,170 acres, if approved, could affect over 

4,000 acres year round marten habitat in VCUs 7460 and 7470. Therefore, impacts to marten would 

be higher than shown in Table 51. The additional 6 miles of road to be constructed under the 

Ketchikan to Shelter Cove Road would not have a substantial impact on road density. It could, 

however, affect trapper access as it would connect Ketchikan and Saxman to the project area VCUs 

and WAAs, and add an additional means of access. With this road connection, roads built under the 

proposed Saddle Lakes Timber Sale would contribute to open and closed road densities, and 

increase the amount of trapper access to the project area. Project roads would open new areas to 

trapping during the life of the timber sale, and provide walk-in access post-sale. 

Table 51 summarizes cumulative change in marten habitat in all land ownerships.

Table 51. Cumulative change in marten habitat on all land ownerships by VCU and WAA

Habitat Historic

Acres and Road Density1/(% reduction from historic)

Existing \ 

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

VCU 7460

Winter2/ 12,639 7,317

(-42.1%)

6,941

(-45.1%)

7,246

(-42.7%)

6,871

(-45.6%)

6,821

(-46.0%)

6,947

(-45.0%)

Yearround2/ 19,967 14,494

(-27.4%)

13,641

(-31.7%)

14,277

(-28.5%)

13,524

(-32.3%)

13,321

(-33.3%)

13,713

(-31.3%)

Over 30% 

clearcut?3/ N/A No Yes No Yes Yes Yes

Open Road 

Density

(mi/mi2

) 

0 1.0 1.1 1.0 1.3 1.3 1.2

Total Road 

Density

(mi/mi2

) 

0 2.2 2.3 2.2 2.5 2.5 2.4

VCU 7470

Winter2/ 7,353 4,634

(-37.0%)

4,219

(-42.6%)

4,425

(-39.8%)

4,168

(-43.3%)

4,008

(-45.5%)

4,212

(-42.7%)

Yearround2/ 12,278 9,434

(-23.2%)

8,657

(-29.5%)

8,965

(-27.0%)

8,580

(-30.1%)

8,339

(-32.1%)

8,667

(-29.4%)
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Issue 3A – Wildlife Habitat - Chapter 3  147

Habitat Historic

Acres and Road Density1/(% reduction from historic)

Existing \ 

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

Over 30% 

clearcut?3/ N/A No Yes No Yes Yes No

Open Road 

Density

(mi/mi2

) 

0 1.1 1.4 1.4 1.6 1.7 1.6

Total Road 

Density

(mi/mi2

) 

0 1.5 1.8 1.8 2.0 2.1 1.9

VCU 7530

Winter2/ 10,830 6,216

(-42.6%)

6,164

(-43.1%)

6,190

(-42.8%)

6,162

(-43.1%)

6,097

(-43.7%)

6,162

(-43.1%)

Yearround2/ 18,401 13,761

(-25.2%)

13,504

(-26.6%)

13,621

(-26.0%)

13,505

(-26.6%)

13,392

(-27.2%)

13,494

(-26.7%)

Over 30% 

clearcut?3/ N/A No No No No No No

Open Road 

Density

(mi/mi2

) 

0 1.0 1.1 1.1 1.1 1.1 1.1

Total Road 

Density

(mi/mi2

) 

0 1.8 1.9 1.8 1.9 1.9 1.9

WAA 406

Winter2/ 36,435 24,555

(-32.6%)

24,127

(-33.8%)

24,458

(-32.9%)

24,055

(-34.0%)

23,940

(-34.3%)

24,132

(-33.8%)

Yearround2/ 63,536 51,099

(-19.6%)

49,990

(-21.3%)

50,743

(-20.1%)

49,873

(-21.5%)

49,558

(-22.0%)

50,051

(-21.2%)

Open Road 

Density

(mi/mi2

) 

0 0.7 0.8 0.7 0.8 0.8 0.8

Total Road 

Density

(mi/mi2

) 

0 1.3 1.4 1.4 1.4 1.4 1.4

WAA 407

Winter2/ 15,865 10,443

(-34.2%)

10,028

(-36.8%)

10,235

(-35.5%)

9,977

(-37.1%)

9,817

(-38.1%)

10,022

(-36.8%)

Yearround2/ 31,257 25,704

(-17.8%)

24,927

(-20.3%)

25,235

(-19.3%)

24,850

(-20.5%)

24,609

(-21.3%)

24,937

(-20.2%)

Open Road 

Density

(mi/mi2

) 

0 1.6 1.7 1.7 1.8 1.8 1.8

Total Road 

Density

(mi/mi2

) 

0 1.8 1.9 1.9 1.9 1.9 1.9

Source: USFS, Tongass National Forest, GIS.

1/ Total road density below 1,500 feet elevation.

2/ Winter habitat equals high-POG ≤1500’ elevation; year-round equals POG all elevations.. 

3/ Consistent research threshold is 30 percent clearcut harvest within marten home range. 
3 Affected Environment and Environmental Consequences

148  Chapter 3 – Issue 3A – Wildlife Habitat Saddle Lakes Timber Sale Final EIS

The amount, location, and type of modification to POG can directly affect connectivity within the 

project area. Thompson (1994) found that residual stands of less than 40 acres were used less than 

expected. Bissonette et al. (1989) and Chapin et al. (1998) found similar results on patch size. Since 

land ownership and WAA boundaries are administrative rather than physical in limitations on patch 

size, patch size was calculated across the combined 406 and 407 WAA and across all land 

ownerships. Table 52 summarizes change in marten habitat patch size on all land ownerships in 

combined WAAs.

Table 52. Change in marten habitat patch size on all land ownerships in WAAs 406 and407 combined

Patch Size Historic Alt. 1 Alt. 2 Alt. 3 Alt. 4 Alt 5 Alt 6

Number of patches 

≥40 acres 57 93 92 93 93 92 93

Total acres in 

patches ≥40 acres 92,532 73,651 71,622 72,807 71,527 71,135 71,826

Percent Reduction in 

acres 

N/A -20.4% -22.6% -21.3% -22.7% -23.1% -22.4%

Average size patches 

≥40 acres 1,623 792 779 783 769 773 772

Percent Reduction 

average patch size N/A -51.2% -52.0% -51.8% -52.6% -52.4% -52.4%

Source: USFS Tongass National Forest GIS: pogpatch082313.xlsx. Note: N/A = Not Applicable.

Alternative 1

Alternative 1 would not contribute to cumulative effects. However, due to past activities that have 

long-term effects, marten winter habitat within project area VCUs is currently at 57 to 63 percent of 

what was available historically. Year-round habitat is at 73 to 77 percent of historic levels. Both 

younger and older clearcuts are avoided during the winter (Flynn & Schumacher 1999, Flynn & 

Schumacher 2001). As a result, past and recent clearcutting represent long-term to permanent loss of 

marten winter habitat. Marten are most energy constrained during the winter and require suitable 

habitat where prey are not only abundant, but also available beneath the snow. Stem exclusion stands 

are unlikely to support abundant prey. Use of these or similar stands would cause marten to expend 

excess energy searching for prey, increasing the chance of mortality (Buskirk and Powell 1994, 

Harlow 1994). Cumulative impacts are slightly less at the broader WAA scale than at the VCU scale 

(Table 51). 

From identified linear relationships between clearcut harvest and marten density, marten populations 

could be reduced 27 percent from historic levels in VCU 7460, 23 percent in VCU 7470, and 25 

percent in VCU 7530. POG would continue to dominate project area VCUs as the amount of clearcut 

would remain below the 30 percent threshold identified by research. Marten populations would be 

more influenced by fluctuations in prey. 

If linear relationships also apply to winter habitat (i.e., the limiting factor for marten) marten 

populations could be reduced by 43 percent during winters making it harder for populations to 

rebound during high prey, low snow years. 

Most trappers in GMU 1A access trapping areas using boats (Porter 2010b). This trend would likely 

continue for trapping near the beach or areas east of Carroll Inlet. However, the Ketchikan to Shelter 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Issue 3A – Wildlife Habitat - Chapter 3  149

Cove Road would connect the project area to Ketchikan and Saxman, and enable vehicle and/or 

snowmobile access to nearby trapping areas.

Alternatives 2 , 3, 4, 5, and 6

Alternatives 2, 4, and 6 would reduce marten winter habitat within project area VCUs (Table 51) 

maintaining slightly over half of the winter habitat that was available historically. Impacts would be 

slightly less under Alternative 3, and slightly more under Alternative 5. 

Alternative 2 would maintain connectivity corridors 1, 2, 3, and 4 (Table 38) and reduce corridor 5 

due to clearcutting. Based upon limited research, partial cutting in corridors 6, 7, and 8 may have a 

minimal effect on marten, but would maintain overall dispersal throughout the project area. The small 

OGR would be maintained in its current location, providing connectivity between source and sink 

habitat. 

Alternative 3 would cause the least amount of habitat fragmentation by maintaining all corridors by 

not harvesting many low elevation stands, and by maintaining all identified elevational connectivity 

corridors (Table 38). The small OGR would be maintained in its current location, providing 

connectivity between source and sink habitat and facilitating marten movement across the landscape.

Connectivity corridors 1, 2 and 4 would be maintained under Alternative 4, but corridors 3, 5, 6, 7, 

and 8 would be reduced due to clearcutting within the corridors (Table 38). This could have long-term 

impacts on marten dispersal throughout the project area. The small OGR would be maintained in its 

current location, providing connectivity between source and sink habitat. 

Alternative 5 would maintain corridor 1 and 4, but corridors 2, 3, 5, 6, 7, and 8 would be reduced due 

to clearcutting within the corridors (Table 38). Alternative 5 would move the small OGR in VCU 

7470 into the North Revilla Roadless Area reducing the connection with the Naha LUD II and 

reducing the overall amount of protected high-POG and POG habitat. The OGR relocation could 

restrict movement of source populations in the Naha LUD II to recolonize vacant territories within the 

project area. This connection is already impacted by the presence of State land located around George 

Inlet limiting the connectivity between the OGR and the salt chuck. Harvest of Units 300 to 312 

within the current OGR would affect marten movement patterns and make marten more susceptible to 

predation. 

Alternative 6 would maintain corridors 1, 2 and 4, but corridors 3, 5, 6, and 7 would be reduced due 

to clearcutting within the corridors (Table 38). The width of corridor 8 would be reduced due to 

clearcutting in Unit 46. Elimination of connectivity would have long-term impacts on marten 

dispersal. The small OGR would be maintained in its current location, providing connectivity 

between source and sink habitat and facilitating marten movement across the landscape.

 The AMHT land exchange if approved would increase the habitat loss and all alternatives except 

Alternative 3 would exceed the 30 percent of the landscape clearcut in VCUs 7460 and 7470. Impacts 

are slightly less at the broader WAA scale (Table 51). Unlike the above direct effects, cumulative 

effects would be higher during winter, further affecting marten populations. 

The action alternatives, combined with past and foreseeable future management actions, could reduce 

marten populations by at least 33 percent. If linear relationships also apply to winter habitat (i.e., the 

limiting factor for marten) populations could be reduced by 43 to 45 percent. Marten could inhabit 

suboptimal habitat where they spend excessive energy on hunting prey, and have lower reproductive 

success, or territories could be abandoned causing gaps in project area distribution. 
3 Affected Environment and Environmental Consequences

150  Chapter 3 – Issue 3A – Wildlife Habitat Saddle Lakes Timber Sale Final EIS

Research in Southeast Alaska by Flynn et al. (2004) supports the conclusion that all action 

alternatives would further reduce the effective patch size and connectivity of marten habitat since they 

marten do not use younger or older young growth. Other research (see Affected Environment) has 

shown that clearcuts affect marten movement. Under the action alternatives, POG habitat in patches 

greater than or equal to 40 acres will have decreased roughly 20 percent from historic levels, and the 

number of patches almost doubled (Table 52). The average size of the available patches has decreased 

by over 50 percent. Reduction in available habitat and connectivity could cause marked change in 

marten foraging behavior and foraging efficiency, change movement path selection, cause marten to 

inhabit suboptimal habitat, and spend excessive energy on hunting prey. Also a reduction in habitat 

could cause marten to have less time available for social interaction and breeding, affect female body 

index reducing reproductive success, and cause juveniles to disperse farther distances where they 

experienced poorer body condition, and suffered twice the mortality risk. 

OGRs and IRAs would act as refugia from trapping and continue to provide habitat for marten, but 

Flynn et al. (2004) found that OGRs do not support the densities of marten predicted by Forest Plan 

analysis. The current small OGR in VCU 7470 would be maintained under Alternatives 2, 3, 4, and 6, 

which would maintain the important connectivity link with source habitat in the Naha LUD II to 

repopulate vacant territories within Saddle Lakes VCUs. Alternative 5 would move the existing small 

OGR and reduce this important link by clearcutting the current connection. The connection between 

the current OGR and the George Inlet salt chuck is already impacted by the presence of State land. As 

a result, vacant territories within Saddle Lakes VCUs and WAAs may not be repopulated, causing 

gaps in marten distribution on a broader scale. 

With the completion of the Ketchikan to Shelter Cove Road, some trapper access could shift from 

boats to vehicles and/or snowmobiles. Therefore, open road densities ranging could affect habitat 

suitability and lead to overharvest of marten (Table 51). Trapping pressure would continue to 

fluctuate with pelt price and weather.

Summary of Marten Effects

Cumulative habitat loss under Alternatives 2, 4, and 5 would exceed the research threshold of 30 

percent clearcut tolerance in VCUs 7460 and 7470. Habitat loss under Alternative 6 would exceed the 

30 percent threshold in VCU 746 as well (Table 51). This puts these VCUs at increased risk of not 

maintaining marten populations. Habitat loss in VCU 7530 would not exceed thresholds under any 

alternative (Table 51). The consequence of additional harvest could leave localized gaps in 

distribution and reduced gene flow within the population, lower densities of marten, lower body 

condition and reproductive success, altered foraging patterns and efficiency, and lower winter survival 

due to loss of denning sites beneath the snow. The greater the size and number of gaps, the higher the 

risk of reducing gene flow. Alternative 5 would move the small OGR in VCU 7470, reducing the 

important connection between the Naha LUD II source and sink habitat within the George Inlet salt 

chuck; however this connection is already impacted due to the presence of State land between the 

current OGR and George Inlet.

Of the action alternatives, Alternative 3 would have the least cumulative effects on marten 

populations and marten habitat. The cumulative effects of Alternatives 2 and 6 are similar, and would 

rank second of the action alternatives in terms of having the least cumulative effects. Impacts under 

Alternative 2 may be slightly less than Alternative 6 because of the amount of uneven-age 

management harvest proposed. Alternative 4 would have the second greatest cumulative effects on 

marten, with Alternative 5 having the greatest cumulative effects on marten habitat, connectivity, 

dispersal capability, and populations. 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Issue 3A – Wildlife Habitat - Chapter 3  151

Brown Creeper

Direct/Indirect Effects

Measurement criteria include acres of interior POG. NFS lands within VCUs 7460, 7470, and 7530 

were used as the scale for analysis.

Interior POG habitat was calculated from GIS layers using the edge effect distances identified in 

Concannon (1995). 

• All clearcuts were buffered (656 feet);

• Edge effects from roads running through forested areas were calculated using the same effective

distance as clearcuts (656 feet) due to a similar abrupt edge;

• Muskeg/non-forested areas were buffered (394 feet) since the edge was naturally feathered by the

muskeg/forest interface; and

• Roads clearing through non-forested areas were calculated using the same distance as muskegs

(394 feet).

Effects Common to All Action Alternatives

Hejl et al. (2002), Wiggins (2005), and Poulin et al. (2013) summarized multiple studies across the 

United States where brown creepers were substantially more abundant in unlogged versus logged 

conditions including clearcuts, partial-cuts, and regenerated pole-sapling stands. Immature and mature 

young-growth forests (even 100-yr old stands) often did not contain essential structural characteristics 

such as of large, mature and old-growth trees that provide both foraging and nesting sites. Partial 

cutting, (even with less than 30 percent removal) affected brown creeper abundance (Mahon et al. 

2008, Vanderwel et al. 2007 and 2011, Young and Hutto 2002). 

Logging and the resulting fragmentation of forest reduces the overall availability of suitable nesting 

and foraging habitat, increases the distance between suitable nesting/foraging habitat patches, and 

decreases reproductive success by lowering prey availability (Wiggins 2005). However, the primary 

effect of forest fragmentation is that brown creepers may simply avoid breeding in small forest 

fragments (Hejl et al. 2002a, Hejl et al. 2002b, Hobson and Bayne 2000). Several Southeast Alaska 

studies (DellaSala et al. 1996, Kissling and Garton 2008) found substantially fewer or an absence of 

creepers in logged habitat or narrow buffers. Hejl, et al. (2002a) summarized that retaining 

continuous, unfragmented areas of unlogged mature and old-growth forests would provide optimum 

brown creeper habitat. According to work by Deal et al. 2009, partial-cut stands may regain large tree 

structural diversity and function within 50 years, but brown creepers require large decadent trees with 

sloughing bark which could take longer to develop.

The number of brown creepers is expected to decline with habitat loss and/or reproductive success 

would be reduced from current levels as birds occupy sub-optimal habitat. Changes to brown creeper 

habitat are shown in Table 53. 

Alternative 1

Alternative 1 would have no effect on brown creeper habitat or populations. Although the project area 

is currently fragmented, all existing patches of interior habitat would be maintained to support brown 

creeper populations.

Alternative 2

Alternative 2 would affect 610 acres of interior habitat (Table 53). Partial cutting in units 47, 48, 50, 

75, 80, and 123 would impact the large patch of interior habitat on the south shore of North Saddle 
3 Affected Environment and Environmental Consequences

152  Chapter 3 – Issue 3A – Wildlife Habitat Saddle Lakes Timber Sale Final EIS

Lakes. Partial-cutting in Units 28, 29, and 147 would affect the interior habitat patch on the north 

side of the lake. Clearcutting Unit 67 would affect the interior habitat patch near Granite Island/

George Inlet and preclude brown creeper use long term or permanently under a 100-year rotation. 

Edge effect from Units 43 and 44 would reduce interior POG within the VCU 7470 small OGR. 

Other smaller patches would be affected throughout the project area. About 89 percent of the interior 

habitat would be maintained in VCU 7460, 90 percent in VCU 7470 and about 99 percent of the 

interior habitat would be maintained in VCU 7530. Large interior patches within roadless areas 

would be unaffected by Alternative 2. Alternative 2 would have the third lowest risk to brown 

creeper populations of the action alternatives since it harvests the third lowest number of acres. 

Table 53. Effect on brown creeper and interior habitat1/ on NFS Lands by VCU in acres

VCU Historic 

(ac)

Existing / 

Alt. 1 (ac)

Acres (% reduction from existing acres)

Alt. 2 Alt. 3 Alt. 4 Alt. 5 Alt. 6

VCU 7460 10,885 3,050 2,704

(-11.3%)

2,940

(-3.6%)

2,661

(-12.8%)

2,651

(-13.1%)

2,691

(-11.8%)

VCU 7470 4,469 2,417 2,174

(-10.1%)

2,248

(-7.0%)

2,153

(-10.9%)

2,060

(-14.8%)

2,165

(-10.4%)

VCU 7530 7,832 2,493 2,471

(-0.9%)

2,474

(-0.8%)

2,473

(-0.8%)

2,471

(-0.9%)

2,471

(-0.9%)

Source: USFS Tongass National Forest GIS

1/ Interior habitat based upon vegetative & climatic edge effect distances for Southeast AK (Concannon 1995).

Alternative 3

Alternative 3 would affect 298 acres of interior brown creeper habitat. Impacts would be greatest in 

VCU 7470 (Table 53). About 96 percent of the interior habitat would be maintained in VCU 7460, 93 

percent in VCU 7470 and about 99 percent of the interior habitat would be maintained in VCU 7530. 

Units impacting VCU 7470 include Units 43, 44, and 67. The second greatest effects to brown 

creepers would be in VCU 7460. Partial cutting in Unit 123 would reduce the size of the large interior 

patch on the south side of North Saddle Lakes. Other patches of interior brown creeper habitat would 

be affected throughout the project area. Brown creepers would be less impacted in Alternative 3 as 

most large patches would remain.

Alternative 4

Alternative 4 would affect 672 acres of interior brown creeper habitat reducing available habitat 

throughout project area VCUs (Table 53). About 87 percent of the interior habitat would be 

maintained in VCU 7460, 89 percent in VCU 7470 and about 99 percent of the interior habitat would 

be maintained in VCU 7530. In addition to the effects described under Alternative 2, the entire large 

patch by North Saddle Lakes would be removed and additional impacts would occur near the George 

Inlet salt chuck from the clearcut harvest proposed in Units 64, 65, 66, and 155. Harvest within the 

wildlife corridor through Units 203, 204, 207, and 224 would remove the interior patch north of 

Island Point. Alternative 4 has the second highest effect on brown creeper habitat, breeding success, 

dispersal, and overall populations. 

Alternative 5

Alternative 5 would impact 806 acres of brown creeper habitat predominantly through clearcutting 

(Table 53). About 87 percent of the interior habitat would be maintained in VCU 7460, 85 percent in 

VCU 7470 and about 99 percent of the interior habitat would be maintained in VCU 7530. 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Issue 3A – Wildlife Habitat - Chapter 3  153

Clearcutting in Units 46, 47, 48, 49, 50, 74, 75, 80, 115, 118 and 123 would eliminate the large 

patch of interior habitat on the south shore of North Saddle Lakes. Units 28, 29, 30 and 147 would 

eliminate the patch on the north side of the lake. Additional impacts would occur near the George 

Inlet salt chuck from clearcutting Units 64, 65, 66, and 155. By not implementing the wildlife 

corridor through Units 203, 204, 207, and 224, the interior patch north of Island Point would be 

removed. The large block of interior POG in the current VCU 7470 OGR would be reduced both 

due to a portion of the OGR being moved into the roadless area and Units 300 to 312 being 

harvested. Since most units would be clearcut, harvest would result in a long-term loss of brown 

creeper habitat. Alternative 5 would have the greatest effect on brown creepers of all alternatives. 

Alternative 6

Alternative 6 would affect 633 acres of interior brown creeper habitat reducing available habitat 

(Table 53). About 88 percent of the interior habitat would be maintained in VCU 7460, 90 percent in 

VCU 7470 and about 99 percent of the interior habitat would be maintained in VCU 7530. Harvest of 

Units 48, 49 50, 118, and 123 would remove most of the block located south of North Saddle Lakes. 

Additional impacts would occur near the George Inlet Salt Chuck from Units 64, 65, 66, and 155, and 

to the VCU 7470 OGR from Units 44 and 106. Alternative 6 has the second lowest risk of the action 

alternatives since it proposes the second lowest number of acres, or the third lowest risk overall. 

Cumulative Effects

Cumulative effects to brown creeper come from ongoing effects from past and more recent timber 

harvest activities on all land ownerships, with smaller impacts from hydroelectric projects. Some of 

the greatest historic interior POG losses were along the eastern shore of Carroll Inlet, with smaller 

losses along the western shore within the Saddle Lakes project area. Larger blocks of current habitat 

are primarily restricted to OGRs and inventoried roadless areas. 

Brown creepers appear to be impacted by all types of harvest or large tree removal, all activities 

would reduce brown creeper habitat. Additional fragmentation would occur with the completion of 

the Ketchikan to Saddle Lakes Road. Impacts from the proposed 8,170 acre land exchange would 

depend upon approval, but could affect multiple patches of interior habitat within the Saddles Lakes 

project area, including patches within the small OGR in VCU 7470. The effects of the proposed land 

exchange were not analyzed because at the time of this analysis these lands had not been conveyed.

Alternative 1

The Saddle Lakes project would not contribute to cumulative effects. Impacts to brown creeper 

interior habitat have been substantial (up to a 72 percent reduction) representing long-term to 

permanent habitat loss under 100-year rotations (Table 54). About 28 percent of the interior habitat 

would be maintained in VCU 7460, 48 percent in VCU 7470 and about 32 percent of the interior 

habitat would be maintained in VCU 7530. Since beach buffers are currently protected, some historic 

coastal habitat could be restored after 150 years, but suitability would be influenced by the adjacent 

upland condition. Alternative 1 would have the least impact on brown creepers and their habitat. 

Alternatives 2, 3, 4, 5, and 6

Alternatives 2, 3, 4, 5, and 6 would reduce brown creeper habitat and populations (Table 54). 

Alternative 3 would have the least impact of action alternatives maintaining about 27 percent of the 

interior habitat would be maintained in VCU 7460, 45 percent in VCU 7470 and about 32 percent of 

the interior habitat would be maintained in VCU 7530. Alternative 5 would have the greatest impact 

of action alternatives maintaining about 24 percent of the interior habitat would be maintained in 

VCU 7460, 42 percent in VCU 7470 and about 31 percent of the interior habitat would be maintained 
3 Affected Environment and Environmental Consequences

154  Chapter 3 – Issue 3A – Wildlife Habitat Saddle Lakes Timber Sale Final EIS

in VCU 7530. Roughly one-quarter to one-third of historic interior habitat would remain. About 

one-half of the historic habitats would remain at the larger WAA 406 and 407 scale. 

The AMHT land exchange of 8,170 acres, if approved, would further reduce interior habitat. 

The small OGR in VCU 7470 and the adjacent North Revilla Roadless Area contains the largest block

of interior habitat that remains within the Saddle Lakes project area. This contributes to a slightly

lower impact within VCU 7470 and WAA 407. Under Alternative 5 the large block of interior POG in 

the current VCU 7470 OGR would be reduced both due to a portion of the OGR being moved into 

the roadless area and Units 300 to 312 being harvested. 

Table 54. Cumulative change in brown creeper/interior habitat1/ on all land ownerships by VCU and WAA

Area Historic 

(ac)

Acres (% reduction from historic acres)

Existing / 

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

VCUs

VCU 7460 10,983 3,050

(-72.2%)

2,704

(-75.4%)

2,940

(-73.2%)

2,661

(-75.8%)

2,651

(-75.9%)

2,691

(-75.5%)

VCU 7470 6,363 3,070

(-51.8%)

2,820

(-55.7%)

2,897

(-54.5%)

2,799

(-56.0%)

2,656

(-58.3%)

2,811

(-55.8%)

VCU 7530 8,248 2,623

(-68.2%)

2,601

(-68.5%)

2,605

(-68.4%)

2,604

(-68.4%)

2,601

(-68.5%)

2,602

(-68.5%)

WAAs

WAA 406 30,321 14,193

(-53.2%)

13,824

(-54.4%)

14,063

(-53.6%)

13,783

(-54.5%)

13,771

(-54.6%)

13,811

(-54.5%)

WAA 407 13,949 7,440

(-46.7%)

7,190

(-48.5%)

7,267

(-47.9%)

7,168

-48.6%)

7,025

(-49.6%)

7,180

(-48.5%)

Source: USFS Tongass National Forest GIS; SaddleWildlfieSummariesByAlt0618.xlsx. Note: VCU = Value Comparison Unit; 

WAA = Wildlife Analysis Area.

1/ Interior habitat based upon vegetative & climatic edge effect distances for Southeast AK (Concannon 1995).

Summary of Brown Creeper Effects

Impacts to brown creeper interior habitat from past management activities have been substantial (over

72 percent loss in VCU 7460) and would be further reduced with implementation of the Saddle Lakes 

Timber Sale, and identified future management activities (up to76 percent loss in VCU 7460). 

Clearcutting represents long-term to permanent habitat loss under 100-year rotations. Partial-cutting 

would reduce local populations, but impacts could be of shorter duration. Actual time of recovery 

within partial-cut units would depend on the harvest prescriptions. Since beach buffers are currently

protected, some historic coastal habitat could be restored after 150 years, but suitability would be 

influenced by the adjacent land condition. Past, present and future management actions have or could

reduce the amount of interior habitat acres. These actions have likely lowered reproductive success,

decreased juvenile dispersal success, and caused substantial reductions in brown creeper populations 

resulting in widespread gaps in distribution. The remaining habitat is predominantly within OGRs and 

other non-development LUDs, or IRAs. Alternative rankings from greatest to lowest risk are 5, 4, 6, 

2, 3 then 1. Alternative 1 does not contribute to direct or cumulative effects. 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Issue 3A – Wildlife Habitat - Chapter 3  155

Hairy Woodpecker

Direct/Indirect Effects

Measurement criteria include acres of high-POG (SD5N, SD5S, SD67) at all elevations. The VCU

scale was used to analyze direct and indirect effects on the hairy woodpecker.

Effects Common to All Action Alternatives

Hairy woodpeckers depend on cavities in large-diameter trees and hard snags characteristic of highPOG stands. Clearcutting has an immediate effect on hairy woodpecker habitat by altering the 

complex ecological structure afforded by old-growth forest stands (Cotter 2007). Replacing mature 

stands with young stands eliminates decaying trees and reduces insect infestations, which are 

detrimental to habitat capability and likely results in population declines (Jackson et al. 2002, 

Kissling and Garton 2008, Anderson 2003, Penhollow and Stauffer 2000, Cahall and Hayes 2009). 

Information on the specific quantitative correlation between habitat loss and reduction in hairy 

woodpecker populations was not found, but information in Zarnowitz and Manuwal (1985) suggests 

that it may not be a linear relationship. Under current 100-year rotations, clearcutting represents 

permanent habitat loss since stands would be re-harvested before producing large trees with sufficient 

decay to create cavities for nesting and support sufficient insect populations for foraging. 

Vanderwel et al. (2007) found no clear trends on the effects of partial harvest on hairy woodpeckers in 

Ontario as long as key structural components were maintained. Also, partial-cutting would affect 

stand volume and likely decrease preferred high-POG habitat to less preferred medium- or low-POG. 

Habitat would recover within a shorter timeframe than clearcut units.

Changes in high-POG are shown in Table 55. Direct effects would be the greatest within VCU 7470 

under all action alternatives, increasing the importance of the large block of high-POG within the 

existing small OGR.

Table 55. Effect on hairy woodpecker high-POG habitat1/ on NFS lands by VCU

VCU Historic 

(ac)

Existing / 

Alt. 1(ac)

Acres (% reduction from existing acres)

Alt. 2 Alt. 3 Alt. 4 Alt. 5 Alt. 6

VCU 7460 14,358 8,982 8,596

(-4.3%)

8,911

(-0.8%)

8,535

(-5.0%)

8,476

(-5.6%)

8,612

(-4.1%)

VCU 7470 5,946 4,461 4,044

(-9.3%)

4,252

(-4.7%)

3,994

(-10.5%)

3,833

(-14.1%)

4,039

(-9.5%)

VCU 7530 10,909 6,268 6,216

(-0.8%)

6,241

(-0.4%)

6,214

(-0.9%)

6,149

(-1.9%)

6,214

(-0.9%)

Source: USFS, Tongass National Forest GIS; SaddleWildlifeSummariesByAlt0618.xlsx. Note: VCU = Value Comparison Unit.

1/ Habitat is high-POG at all elevations.

Alternative 1

Alternative 1 would have no effect on hairy woodpecker habitat or populations. All existing highPOG habitat would be maintained (Table 55). Hairy woodpecker populations would remain at current 

levels unless affected by natural causes such as windthrow or predation. 

Alternative 2

Alternative 2 would clearcut 370 acres of preferred high-POG hairy woodpecker habitat, and partialcut 485 acres. The 1 to 9 percent habitat reductions (Table 55) could cause reductions in individuals 

or shifts in territories. Fewer high-POG stands and large diameter trees would be available as nesting 
3 Affected Environment and Environmental Consequences

156  Chapter 3 – Issue 3A – Wildlife Habitat Saddle Lakes Timber Sale Final EIS

and foraging habitat. Effects would be greater than Alternatives 1 and 3, but less than Alternatives 4, 

5, or 6. Alternative 2 maintains the current small OGR which contains some of the largest blocks of 

high-POG habitat currently present in the area.

Alternative 3

Alternative 3 would have the least impact of the action alternatives on hairy woodpeckers since it 

would retain the greatest amount of high POG (Table 55). Alternative 3 would clearcut 201 acres of 

preferred high-POG habitat and partial-cut 106 acres. Alternative 3 maintains the large block of 

habitat within the existing small OGR in VCU 7470. 

Alternative 4

Alternative 4 would have the second highest impact on high POG by clearcutting 772 acres and 

partial cutting 195 acres of high-POG habitat (Table 55). Alternative 4 maintains the current small 

OGR which contains some of the largest blocks of high-POG habitat currently present in the area.

Alternative 5

Alternative 5 would have the greatest impact on high POG (Table 55). Habitat would be reduced long 

term by 1,133 acres of clearcutting, but impacts may be shorter termed in the 120 acres of partial 

cutting. Alternative 5 would move the small OGR in VCU 7470 into the roadless area. Clearcutting of 

Units 300 through 308 and 310 through 312 would remove a large block of high-POG currently 

present within the OGR, and would result in a permanent habitat loss under the current 100 year 

rotation. 

Alternative 6

Alternative 6 ranks third of all the action alternatives for impacts to high POG. It would remove 599 

acres of habitat by clearcutting, and 246 acres of habitat by partial cutting (Table 55). 

Cumulative Effects

All land ownerships within project area VCUs and WAAs were used to evaluate cumulative effects on 

hairy woodpeckers. The combined WAAs were used to evaluate cumulative effects on patch size 

greater than or equal to 500 acres. All POG categories were used for analyzing patch size since hairy 

woodpeckers do use other POG classes, though it is not preferred (Hughes 1985). Cumulative effects 

to hairy woodpeckers come primarily from past and recent timber harvest and road construction 

activities (fragmentation). The 3,726 acres of Leask Lake clearcut harvest are not included in Table 56 

as it is unknown what percentage of the harvest may have been high-POG. Therefore, the table likely 

underestimates the overall effect to hairy woodpecker habitat within WAA 407. The Ketchikan to 

Shelter Cove road clearing could affect up to 16 acres of POG (calculated using 2 miles of road times 

a 66 foot clearing width). The Swan Lake dam expansion would affect 47 acres of high-POG habitat. 

The proposed AMHT land exchange, if approved, would have substantial impacts on hairy 

woodpecker habitat. The effects of the proposed land exchange were not analyzed because at the time 

of this analysis these lands had not been conveyed. 

In addition to directly removing habitat, timber harvest would affect the amount of POG habitat in 

block 500 acres or larger. The total amount of habitat within patches 500 acres or larger have been 

reduced to 72 percent of historic levels (Table 56). 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Issue 3A – Wildlife Habitat - Chapter 3  157

Table 56. Effect on hairy woodpecker high-POG habitat on all land ownerships by VCU and WAA

Area Historic 

(ac)

Acres (% reduction from historic acres)

Existing \ 

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

VCU

VCU 7460 14,455 8,982

(-37.9%)

8,596

(-40.5%)

8,911

(-38.4%)

8,535

(-41.0%)

8,476

(-41.2%)

8,612

(-40.4%)

VCU 7470 7,750 5,031

(-35.1%)

4,614

(-40.5%)

4,822

(-37.8%)

3,994

(-48.5%)

3,833

(-50.5%)

4,609

(-40.5%)

VCU 7530 11,523 6,883

(-40.3%)

6,830

(-40.7%)

6,856

(-40.5%)

6,214

(-46.1%)

6,149

(-46.6%)

6,829

(-40.7%)

WAA

WAA 406 41,994 29,557

(-29.6%)

29,119

(-30.7%)

29,459

(-29.8%)

29,057

(-30.8%)

28,932

(-31.1%)

29,133

(-30.6%)

WAA 407 16,951 11,528

(-32.0%)

11,111

(-34.5%)

11,319

(-33.2%)

11,061

(-34.7%)

10,900

(-35.7%)

11,107

(-34.5%)

Source: USFS Tongass National Forest GIS; SaddleWildlifeSummariesByAlt0618.xlsx.

Alternative 1

Alternative 1 would not contribute to cumulative effects. However, effects from past management

could continue into the foreseeable future. Proposed future projects may cause further decline. 

Approximately 60 to 65 percent of the historic high-POG habitat currently remains within project 

area VCUs (Table 56). Impacts are slightly less at the broader WAA scale, with 68 to 70 percent of 

the historic habitat remaining. Widespread habitat loss has likely affected hairy woodpecker 

populations, but the actual extent is unknown. 

Alternatives 2, 3, 4, 5, and 6

All action alternatives would have similar effects on all three project area VCUs. Hairy woodpecker

habitat would decline to roughly 50 to 60 percent of historic habitat levels. Large patch habitat 

(greater than or equal to 500 acres) would be reduced by about 30 percent. Loss of habitat has had an 

impact on hairy woodpecker populations by reducing nesting success and/or affecting distribution on 

a localized scale. Alternative 3 would maintain the highest level of hairy woodpecker habitat and 

patches > to 500 acres followed by Alternatives 2, 6, 4, and 5. Under Alternative 5, high POG in the 

current VCU 7470 OGR would be reduced both due to a portion of the OGR being moved into the 

roadless area and units 300 to 312 being harvested. 

Under the action alternatives, the number of patches would increase slightly, but amount of habitat 

within these patches would decrease to 70 to 72 percent of historic levels (Table 57). Average patch 

size would also decrease. The remaining large patches of POG are predominantly located within 

OGRs, other non-development LUDs, and the roadless areas. 

Summary of Hairy Woodpecker Effects

Direct effects to high-POG habitat varies from less than 1 percent up to 14 percent depending upon 

the alternative and the VCU. However, cumulative effects are more substantial. About 38 to 51 

percent of the historic VCU habitat would be lost long-term from harvesting high-POG habitat

depending on alternative and VCU. Large patches (greater than or equal to 500 acres) would decrease 
3 Affected Environment and Environmental Consequences

158  Chapter 3 – Issue 3A – Wildlife Habitat Saddle Lakes Timber Sale Final EIS

26 to 28 percent from historic levels. Alternative rankings from least effect to greatest effect are 

Alternative 1, 3, 2, 6, 4, and 5 respectively. 

Table 57. Change in hairy woodpecker habitat patch size on all land ownerships in WAAs 406 and 407

Comparison Historic Alt. 1 Alt. 2 Alt. 3 Alt. 4 Alt 5 Alt 6

Number of patches 

≥500 acres 13 19 19 19 19 19 19

Total acres in patches 

≥500 acres 87,956 63,812 62,006 63,028 61,812 61,432 62,074

Percent Reduction 

(ac) N/A (-27.5%) (-29.5%) (-28.3%) (-29.7%) (-30.2%) (-29.4%)

Average size of 

patches ≥500 acres 6,766 3.359 3,263 3,317 3,253 3,233 3,267

Percent Reduction 

average patch size N/A (-50.4%) (-51.8%) (-51.0%) (-51.9%) (-52.2%) (-51.7%)

Source: USFS Tongass National Forest GIS; Note: N/A = Not Applicable.

Red-Breasted Sapsucker

Direct/Indirect Effects

Measurement criteria includes: acres of medium- and low-POG (SD5H, SD4S, SD4N, and SD4H) at 

all elevations. The scale used to analyze direct and indirect effects includes VCU 7460, 7470, and 

7530. 

Effects Common to All Action Alternatives

Effects to red-breasted sapsuckers are very similar to those described under hairy woodpecker. The 

main difference is in the type of POG affected (medium- and low-POG vs. high-POG). Matsuoka et 

al. 2012 and DellaSalla et al. 1996 found that sapsuckers were associated with old growth on nearby 

Prince of Wales Island and occurred in old growth in greater densities than in any young-growth type. 

Kissling and Garton (2008) mention a fragmentation threshold, but did not state what percentage of 

young growth was required to cause populations to decline. The choice of large-diameter snags may 

reflect an attempt to maximize nest space for large clutch size, thermal insulation, and/or protection

from predators (Joy 2000). 

Clearcutting will remove nesting and foraging habitat. Effects of partial harvest on red-breasted 

sapsuckers are varied. Beese and Bryant (1999) found higher densities in unharvested stands than

green tree retention stands in British Columbia. Conversely, Mahon et al. (2008) found higher 

densities of red-breasted sapsuckers in northwestern British Columbia partial-cut stands with up to 60 

percent of the stand volume removed. Differences may be a function of harvest prescription and stand 

condition remaining after harvest, differences in areas, or both. OSHA safety regulations will likely

require many existing snags to be felled during logging operations further reducing suitable habitat.

Changes in red-breasted sapsucker preferred habitat are shown in Table 58. 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Issue 3A – Wildlife Habitat - Chapter 3  159

Table 58. Effect on red-breasted sapsucker habitat on NFS lands by VCU

VCU Historic 

(ac)

Acres (% reduction from existing)

Existing \ 

Alt. 1(ac) Alt. 2 Alt. 3 Alt. 4 Alt. 5 Alt. 6

7460 5,512 5,512 5,045

(-8.5%)

5,366

(-2.6%)

4,988

(-9.5%)

4,845

(-12.1%)

5,101

(-7.5%)

7470 3,442 3,442 3,083

(-10.4%)

3,182

(-7.6%)

3,056

(-11.2%)

2,976

(-13.5%)

3,097

(-10.0%)

7530 6,165 6,165 5,961

(-3.3%)

6,052

(-1.8%)

5,962

(-3.3%)

5,915

(-4.1%)

5,952

(-3.5%)

Source: GIS, SaddleWildlfieSummariesByAlt0618.xlsx

Medium- and Low-POG all elevations.

Alternative 1

There are no direct or indirect effects on red-breasted sapsuckers from Alternative 1. Except for 

natural events, all existing medium- and low-POG habitat within the project area would remain.

Populations of red-breasted sapsuckers are expected to remain at current levels unless altered by

natural events. Alternative 1 maintains the current small OGR.

Alternative 2

Alternative 2 would reduce red-breasted sapsucker habitat within project area VCUs by 1,030 acres or 

by 7 percent across all project area VCUs combined (Table 58). Approximately 546 acres would be 

clearcut and 484 acres partial-cut. Alternative 2 maintains the current small OGR. 

Alternative 2 ranks second of the action alternatives behind Alternative 3 because of the higher 

amount of partial cutting in Alternative 2 versus Alternative 6.

Alternative 3

Alternative 3 would reduce red-breasted sapsucker habitat within project area VCUs by 518 acres 

(Table 58). Approximately 462 acres would be clearcut and 56 acres partial-cut. Alternative 3 

maintains the current small OGR. 

Alternative 3 ranks first among the action alternatives for maintaining red-breasted sapsucker habitat.

Alternative 4

Alternative 4 would reduce red-breasted sapsucker habitat within project area VCUs by 1,112 acres 

(Table 58). Approximately 1,026 acres would be clearcut and 86 acres partial-cut. Alternative 4 

maintains the current small OGR. 

Alternative 4 ranks fourth of the action alternatives for maintaining habitat since it harvests the 

second highest amount of existing habitat.

Alternative 5

Alternative 5 would have the greatest impact on red-breasted sapsucker habitat and number of 

individuals (Table 58). Approximately 1,281 acres would be clearcut and 102 acres partial-cut. Loss 

of suitable habitat would be more widespread with the relocation of the Small OGR in VCU 7470. 

Alternative 5 ranks last of the action alternatives for maintaining red-breasted sapsucker habitat.
3 Affected Environment and Environmental Consequences

160  Chapter 3 – Issue 3A – Wildlife Habitat Saddle Lakes Timber Sale Final EIS

Alternative 6

Alternative 6 would reduce red-breasted sapsucker habitat within project area VCUs by 969 acres

(Table 58). Approximately 824 acres would be clearcut and 145 acres partial-cut. Alternative 6 

maintains the current small OGR.

Alternative 6 ranks second of the action alternatives for maintaining more open old-growth habitat 

preferred by red-breasted sapsuckers.

Cumulative Effects

All ownerships within project area VCUs and WAAs were used for cumulative effects analysis. 

Changes to patch sizes greater than or equal to 250 acres were analyzed under cumulative effects. 

Effects would be very similar to those listed under direct effects, but broader in context. Cumulative 

effects come mainly from recent and proposed timber harvest and road construction activities as most 

historic harvest targeted higher volume stands. Approximate 16 acres of POG habitat would be 

affected by the Ketchikan to Shelter Cove road clearing. The Swan Lake dam expansion would affect 

an additional 41 acres of med- and low-POG habitat. If approved, the AMHT land exchange would 

further impact red-breasted sapsucker habitat. The AMHT land exchange was not included in the 

analysis of cumulative effects because the land has not yet been conveyed. Cumulative change in redbreasted sapsucker habitat for all ownerships is shown in Table 59. 

Kissling and Garton (2008) found that in Southeast Alaska, red-breasted sapsucker densities were 

positively correlated with forest buffer width and appeared to be maximized when buffers were at 

least 400 m (1,312 feet) wide. Kissling & Garton (2008) chose to use buffer width, because patch 

boundaries were difficult to define when forested landscape features were interconnected. Effects to 

patches of POG > 250 acres were analyzed under cumulative effects. 

Table 59. Effect on red-breasted sapsucker habitat on all land ownerships by VCU and WAA

Area Historic

(ac)

Acres (% reduction from historic)

Existing \ 

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

VCU 7460 5,512 5,512

(0%)

5,045

(-8.5%)

5,366

(-2.6%)

4,988

(-9.5%)

4,845

(-12.1%)

5,101

(-7.5%)

VCU 7470 4,527 4,403

(-2.7%)

4,043

(-10.7%)

4,143

(-8.5%)

4,016

(-11.3%)

3,936

(-13.1%)

4,058

(-10.4%)

VCU 7530 6,878 6,878

(0%)

6,674

(-3.0%)

6,765

(-1.6%)

6,676

(-2.9%)

6,628

(-3.6%)

6,665

(-3.1%)

WAA 406 21,542 21,542

(0%)

20,871

(-3.1%)

21,284

(-1.4%)

20,817

(-3.4%)

20,626

(-4.3%)

20,918

(-2.9%)

WAA 407 14,306 14,175

(-0.9%)

13,816

(-3.4%)

13,916

(-2.7%)

13,789

(-3.6%)

13,709

(-4.2%)

13,830

(-3.3%)

Source: GIS, SaddleWildlfieSummariesByAlt0618.xlsx.

Medium- and Low-POG all elevations.

Changes in patch size are shown in Table 60. 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Issue 3A – Wildlife Habitat - Chapter 3  161

Table 60. Change in red-breasted sapsucker habitat patch size, all land ownerships WAAs 406 and 407

Comparison Historic Alt. 1 Alt. 2 Alt. 3 Alt. 4 Alt 5 Alt 6

Number of patches 

>250 acres 17 32 32 32 32 32 32

Total acres in 

patches ≥250 acres 89,131 68,107 66,724 67,323 66,107 65,726 66,369

Percent Reduction in 

acres (-23.6%) (-25.1%) (-24.5%) (-25.8%) (-26.3%) (-25.5%)

Average size patches 

≥250 acres 5,243 2,128 2,022 2,104 2,066 2,054 2,074

Percent Reduction 

average patch size (-59.4%) (-61.4%) (-59.9%) (-60.6%) (-60.8%) (-60.4%)

Source: USFS Tongass National Forest GIS, pogpatch082313.xlsx

Alternative 1

Alternative 1 would not contribute to cumulative effects, but past clearcut harvest has reduced

available habitat. The patch size analysis shows greater impacts. The 17 historic patches of POG 

greater than or equal to 250 acres have been split into 32 smaller blocks. Less than 77 percent of the 

original POG in blocks greater than or equal to 250 acres is currently present. Additional patches 

could be removed under Alternative 1 if the proposed AMHT land exchange is approved. 

Alternatives 2, 3, 4, 5, and 6

Alternatives 2, 3, 4, 5, and 6 would contribute to cumulative effects on red-breasted sapsucker habitat 

(Table 59). The loss of habitat would reduce the number of large diameter trees capable of supporting 

cavities large enough to handle large clutch size, provide thermal insulation, and/or protection from 

predators. All 32 current patches greater than or equal to 250 acres would be maintained. Patches

have been reduced to 75 percent of what was historically available (Table 60). The loss of POG 

habitat combined with habitat reduction within large patches has likely reduced red-breasted 

sapsucker populations within Saddle Lakes project area VCUs and WAAs. The reduction in 

sapsuckers has likely caused localized gaps in distribution potentially affecting predators such as 

goshawks.

Summary of Red-breasted Sapsucker Effects

The loss of medium and low-POG habitat from management activities would further reduce the 

number of large diameter trees capable of supporting cavities large enough to handle large clutch size, 

provide thermal insulation, and/or protection from predators. The loss of POG habitat combined with 

habitat reduction that has occurred due to past projects within large patches would further reduce redbreasted sapsucker populations within the Saddle Lakes area VCUs and WAAs. This reduction in 

sapsuckers has likely caused localized gaps in distribution potentially affecting predators such as 

goshawks. Alternatives ranked from least effect to greatest effect are as follows: 1, 3, 6, 2, 4, and 5. 

Red Squirrel

Direct/Indirect Effects

Measurement criteria includes: acres of POG at all elevations as breeding habitat. The VCU scale 

was used to analyze direct and indirect effects.
3 Affected Environment and Environmental Consequences

162  Chapter 3 – Issue 3A – Wildlife Habitat Saddle Lakes Timber Sale Final EIS

Effects Common to All Action Alternatives

Red squirrel densities and numbers of midden are substantially higher in mature to old forests than 

clearcuts (King et al. 1998, Coté and Ferron 2001). Red squirrels typically rely upon mature forests 

that produce large quantities of tree seed, shaded microclimates for fungal growth and long-term cone 

storage, and cavities for nesting. Clearcutting and management schemes that do not promote the 

return of forests to these conditions will not favor re-establishment and long-term persistence of red 

squirrels (Koprowski 2005). The lack of overstory cover in clearcuts makes red squirrels more subject 

to predation, especially by marten. Red squirrels in Southeast Alaska will cross short gaps caused by 

clearcutting if down logs and nearby trees provide for rapid, inconspicuous travel (Bakker and Van 

Vuren 2004, Bakker 2006). However, clearcuts limit the availability of down logs and interconnected 

vegetation over time and create barriers to red squirrel dispersal (Bakker 2006). Clearcutting would 

either reduce the number of red squirrels or cause a shift into old-growth territories vacant from 

overwinter mortality. With the higher amount of clearcut harvest, increased competition for remaining 

suitable habitat could also occur. Red squirrels would be more susceptible to predation by having 

fewer escape routes and fewer old-growth dispersal routes. 

Stand age appears to influence red squirrel abundance and use of young growth. Haughland and 

Larsen (2004) found that mature forest (120-140 years old) provided the best habitat followed by 

mature edge, thinned edge, and lastly thinned forest (81-100 years old) in young-growth stands in 

British Columbia. Squirrel density, overwinter success, and female reproductive success were highest 

in the mature forest.

Herbers and Klenner (2007) studied the effects of partial harvest on red squirrels in central British

Columbia. They found an approximate 1:1 relationship between logging intensity and declining red 

squirrel density 2 to 4 years after logging. Herbers and Klenner (2007) found that when 50 percent 

of the basal area was removed from the stand, red squirrel abundance diminished by 40 percent. If 

findings by Herbers and Klenner (2007) are applicable in Southeast Alaska, partial harvest 

prescriptions for Saddle Lakes would reduce red squirrel densities by about 30 percent. 

Road construction through POG has generally minor impacts in the form of reducing canopy escape 

routes making red squirrels more susceptible to predation (Gucinski et al. 2001). 

Alternative 1

There are no direct or indirect effects to red squirrels under Alternative 1. Large trees and snags 

would continue to provide quality cavity nesting habitat, and foraging habitat with abundant cone 

production. Overstory canopy would continue to provide interlocking canopies for efficient foraging

and as escape routes from predators. Alternative 1 maintains the current amount of red squirrel 

habitat. Alternative 1 maintains the current small OGR. 

Alternative 2

Alternative 2 would harvest 1,885 acres of POG habitat with roughly half (916 acres) clearcut (Table

61). Clearcutting would either reduce the number of red squirrels or cause a shift into old-growth 

territories vacant from overwinter mortality. Red squirrel densities could be reduced by about 30 

percent in partial-cut units. Alternative 2 maintains the current connectivity through the small OGR in 

VCU 7470. Alternative 2 would maintain connectivity corridors 2, 3, and 4. The partial cutting in 

corridors 6, 7, and 8 would provide sufficient overhead cover to facilitate dispersal. Corridor 5 would 

be reduced which would affect red squirrel dispersal and use. Because of the amount of partial 

cutting, Alternative 2 would have the second-lowest impact of the action alternatives on red-squirrel 

densities and dispersal.
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Issue 3A – Wildlife Habitat - Chapter 3  163

Table 61. Change in red squirrel habitat

1/ on NFS lands by VCU

VCU Historic 

(ac)

Acres (% reduction from existing acres)

Existing \ 

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

VCU 7460 19,869 14,493 13,641

(-5.9%)

14,277

(-1.5%)

13,524

(-6.7%)

13,321

(-8.1%)

13,713

(-5.4%)

VCU 7470 9,388 7,903 7,126

(-9.8%)

7,435

(-5.9%)

7,050

(-10.8%)

6,809

(-13.8%)

7,136

(-9.7%)

VCU 7530 17,073 12,433 12,176

(-2.1%)

12,293

(-1.1%)

12,177

(-2.1%)

12,064

(-3.0%)

12,166

(-2.1%)

Source: USFS Tongass National Forest GIS

1/ POG all elevations.

Alternative 3

Alternative 3 would harvest 824 acres of POG habitat with 161 acres partial-cut, or about half the 

amount of harvest as any other action alternative (Table 61). Red squirrel densities could be reduced 

by 30 percent in partial-cuts. Alternative 3 maintains important wildlife corridors facilitating dispersal 

into vacant territories. It also maintains the important connectivity through the small OGR between 

source habitat in the Naha LUD II and the remainder of the project area. Alternative 3 would have the 

lowest impact of the action alternatives on red squirrel densities and dispersal.

Alternative 4

Alternative 4 would harvest 2,079 acres of POG habitat with 281 acres partial-cut (Table 61). Red

squirrel densities could be reduced by 30 percent in partial-cuts, and would be eliminated from 

clearcuts. In addition, Alternative 4 reduces corridors 3, 5, 6, 7, and 8 further limiting the availability 

of escape routes and creating barriers to red squirrel dispersal. As a result, it may be harder for red

squirrels to recolonize vacant territories that develop from winter mortality. Alternative 4 maintains

the small OGR in VCU 7470 that provides connectivity between source habitat in the Naha LUD II 

and the remainder of the project area. Alternative 4 has the second-greatest impacts to squirrels 

after Alternative 5. 

Alternative 5

Alternative 5 would harvest 2,635 acres of POG breeding habitat with 222 acres partial-cut (Table 

61). Alternative 5 would have the greatest impact on red squirrel habitat and populations since 

clearcutting (2,413 acres) represents long-term to permanent reductions in breeding habitat, and 

shorter-term reductions in foraging habitat. Alternative 5 reduces corridors 2, 3, 5, 6, 7, and 8 

impacting the availability of escape routes and creating barriers to red squirrel dispersal. Alternative 5 

would move the small OGR in VCU 7470 reducing the connectivity with source populations in the 

Naha LUD II with the rest of the project area. This could affect success in recolonizing the 

George/Carroll Inlet area in the event of serious winter mortality. This connectivity is already 

impacted by the presence of State land located between the OGR and George Inlet. Alternative 5 has 

the greatest impacts to red squirrels.

Alternative 6

Alternative 6 would harvest 1,814 acres of POG breeding habitat with 391 acres partial-cut (Table 

61). Connectivity corridors 2 and 4 would be maintained, but corridors 1, 3, 5, 6, and 7 would be 

reduced due to clearcutting within the corridors. The width of corridor 8 would be reduced due to 
3 Affected Environment and Environmental Consequences

164  Chapter 3 – Issue 3A – Wildlife Habitat Saddle Lakes Timber Sale Final EIS

clearcutting in Unit 46. Alternative 6 would have impacts on connectivity hence limiting 

the availability of escape routes and creating barriers to red squirrel dispersal. 

Cumulative Effects

Cumulative effects for red squirrels are similar to those described above under direct effects. Suitable 

habitat has been reduced by timber harvest and other activities such as hydropower facility 

construction. The Swan Lake hydropower facility flooded 500 acres during construction, although it 

is uncertain how much of this was POG. The proposed expansion would remove an additional 61 

acres of POG habitat. The Mahoney Lake hydropower construction would not expand the current 

lake, but would remove (clear) an undisclosed amount of habitat on non-NFS lands for support 

facilities in the near future.

Recent clearcut harvest has the greatest effect followed by partial cutting and lastly historic harvest 

since some of these older stands may provide foraging habitat. Alaska Mental Health Trust recently 

harvested 3,726 acres (71 percent of the land base) at Leask Lakes. It is assumed that all harvested 

acres were POG and therefore reduced red squirrel habitat. Another proposed AMHT land exchange 

could affect additional acres. Timber harvest from the Saddle Lakes project would directly remove 

habitat for red squirrels. 

Road construction through POG has generally minor impacts in the form of reducing canopy escape 

routes making red squirrels more susceptible to predation (Gucinski et al. 2001). The Ketchikan to 

Shelter Cove Road would reduce habitat in two ways: 1) it would remove roughly 16 acres of POG 

during right-of-way clearing, and 2) create additional gaps in the canopy. 

Alternative 1

Alternative 1 would have no effects on red squirrel habitat and would not contribute to cumulative 

effects. Impacts to red squirrels from past timber harvest and associated road construction have 

reduced habitat to roughly 75 percent of historic levels in Saddle Lakes VCUs (Table 62). Impacts 

have been slightly less at the broader WAA scale with about 81 percent of the habitat maintained. 

Table 62. Cumulative change in red squirrel habitat1/ on all land ownerships by VCU and WAA

Area Historic

(ac)

Acres (% reduction from historic acres)

Existing \ 

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

VCU 7460 19,967 14,494

(-27.4%)

13,641

(-31.7%)

14,277

(-28.5%)

13,524

(-32.3%)

13,321

(-33.3%)

13,713

(-31.3%)

VCU 7470 12,278 9,434

(-23.2%)

8,657

(-29.5%)

8,965

(-27.0%)

8,580

(-30.1%)

8,339

(-32.1%)

8,667

(-29.4%)

VCU 7530 18,401 13,761

(-25.2%)

13,504

(-26.6%)

13,621

(-26.0%)

13,505

(-26.6%)

13,392

(-27.2%)

13,494

(-26.7%)

WAA 406 63,536 51,099

(-19.6%)

49,990

(-21.3%)

50,743

(-20.1%)

49,873

(-21.5%)

49,558

(-22.0%)

50,051

(-21.2%)

WAA 407 31,257 25,704

(-17.8%)

24,927

(-20.3%)

25,235

(-19.3%)

44,850

(-20.5%)

24,609

(-21.3%)

24,937

(-20.2%)

Source: USFS Tongass National Forest GIS, SaddleWildlfieSummariesByAlt0618.xlsx

1/ POG, all elevations.
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Issue 3A – Wildlife Habitat - Chapter 3  165

Alternatives 2, 3, 4, 5, and 6

The cumulative effects of all action alternatives and other activities would maintain 67 to 71 percent 

of the red squirrel habitat in VCU 7460, 69 to 73 percent in VCU 7470, and 73 to 74 percent in VCU 

7530 (Table 62). All harvest would affect canopy closure increasing the risk of predation and 

eliminating or reducing escape routes. Harvest would directly reduce the number or large trees 

suitable for denning and affect cone crop production. Young-growth stands over 40 years of age may 

again produce cones, but are less reliable than older trees and do not have sufficient size or decay to 

support dens. Long timeframes would be required for stands to develop suitable denning trees with 

cavities.

Summary of Red Squirrel Effects

All action alternatives would reduce historic red squirrel habitat by 26 to 33 percent and likely cause 

gaps in distribution. Increased fragmentation affects squirrel dispersal and increases the risk of 

predation and reduces overwinter survival. Reductions in red squirrel numbers could affect 

populations of predators such as marten and goshawk. Alternative ranking in terms of greatest to least 

risk is as follows: Alternative 5, 4, 6, 2, 3, and 1. 

Other Species of Interest

Endemic Small Mammals – Revillagigedo Island Southern Red-backed Vole 

Direct/Indirect Effects

Measurement criteria include: acres of POG at all elevations. The VCU scale was used to analyze 

direct and indirect effects.

Alternative 1

Alternative 1 would not impact small endemic mammals or more specifically the Revilla Island redbacked vole. All existing habitats would be maintained. Populations would continue to fluctuate from 

natural causes such as weather and predation. 

Alternatives 2, 3, 4, 5, and 6

Endemic species within island geography are especially vulnerable to extinction. Habitat destruction, 

direct hunting, competition for food, and other factors also put intense pressure on island endemics 

(Cook and MacDonald (2013a). 

The effects of clearcutting and fragmentation on endemic populations of small mammals are largely 

un-documented, but have potential for substantial impacts (Cook and MacDonald 2001). Clearcut 

harvesting creates a highly fragmented landscape that increases the amount of forest-opening edge 

and decreases the size of old-growth forest patches. These patches may be too small or isolated from 

other similar stands to function habitat for less mobile species associated with old growth (Harris 

1984, Thomas et al. 1988). The isolation of small mammal populations and the lack of connectivity of 

suitable habitat increase the risk and decrease the likelihood of long-term persistence of local 

populations after extensive clearcut harvest (Swanston et al. 1996).

No studies have been completed on red-back vole response to partial cutting in Alaska. In general, 

red-backed voles seem to persist in some partially harvested forests if mature forest components such 

as large overstory coniferous trees, downed logs, and understory are maintained (Sullivan and 

Sullivan 2011, Fauteux et al. 2012)..In a 14-year study in British Columbia, Ransome et al. (2009) 

found that red-backed vole numbers were highest in uncut forest, intermediate in 2.5-acre group 

selection cuts with 33 percent removal, and lower in large clearcuts.
3 Affected Environment and Environmental Consequences

166  Chapter 3 – Issue 3A – Wildlife Habitat Saddle Lakes Timber Sale Final EIS

Effects to red-backed vole habitat would be similar to those described under Red Squirrel (see Table 

61). Partial-cutting would maintain habitat for red-backed voles although vole densities would likely 

be reduced based upon the above research. Clearcutting would remove habitat long-term, affect size 

and connectivity of remaining habitat patches, and put small mammal populations at higher risk of 

local extirpation. Alternatives 4, 5, and 6 would further impact small endemics reducing corridors 3, 

5, 6, 7, and 8. Since the predominant prescription in Alternative 5 is even-aged clearcutting, it would 

have the most substantial effect overall. 

Alternative 5 would move the roaded portion of the existing small OGR in VCU 7470 into a 2001 

Roadless area and remove the connectivity between source habitat in the Naha LUD II and George 

Inlet salt chuck making it harder for vacant territories to be recolonized. However this connectivity is 

already affected by the presence of State land between the OGR and George Inlet.

Cumulative Effects

Cumulative changes to POG habitat for red-backed voles (25 to 32 percent reduction from historic 

levels) are the same as for red squirrels (Table 62). The extent to which cumulative disturbance from 

forest management poses a threat to the persistence of endemic Revillagigedo red-backed vole 

populations remains unclear and they may not be as sensitive to overstory removal as reported for 

voles elsewhere (Smith and Nichols 2004, Smith et al. 2005). However, Smith et al. 2005 found that 

overall young growth was a population sink. 

Summary of Endemic Small Mammal Effects

All action alternatives, combined with past, present, and future activities, would reduce historic redback vole POG habitat by up to 32 percent. Young growth may provide habitat when cyclic 

populations are high, but their long-term value has been questioned. Densities were lower long term

and reproductive success and body condition were lower suggesting that young growth is a sink 

habitat. Changes in red-back vole numbers could affect predators such as goshawks and marten.

Neotropical Migratory Birds

Direct/Indirect Effects

Alternative 1

Alternative 1 would maintain all existing habitat for neotropical migratory birds.

Alternatives 2, 3, 4, 5, and 6

Direct habitat and disturbance related effects to migratory birds would occur under all action 

alternatives. As with other species, clearcut harvest would have the greatest impacts to habitat. The 

primary effect to birds would be nest destruction or abandonment if management activities occur in 

suitable nesting habitat during the breeding/nesting period, which generally begins April 15 and 

continues until July 15 when young birds have fledged (USFWS 2009b). The normal timber 

operating season is April 1 through November, but activities may occur outside this season if weather 

permits. Therefore, there is substantial overlap with the breeding/nesting period of migratory birds 

and impacts are likely.

Species most likely to be affected are those that nest in hemlock/Sitka spruce forests (e.g., chestnutbacked chickadee, Pacific-slope flycatcher) where timber harvest occurs, and thus the amount of 

harvest proposed under the alternatives is a measure of the extent of potential effects (USDA Forest 

Service 2008c pp. 3-288 & 3-289). Changes in POG habitat can be used to assess changes in nesting 

habitat for migratory bird species that use hemlock/spruce/cedar forest as primary or secondary 

habitats (see MIS section above for discussion of various POG habitats). Nesting birds repeatedly 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Issue 3A – Wildlife Habitat - Chapter 3  167

disturbed by people in proximity to the nest could abandon the effort. See Wildlife Resource Report 

for additional information. 

Species that utilize early successional or shrub habitats (e.g. McGillivray’s warbler, golden-crowned 

sparrow, and golden-crowned kinglet) may benefit short term (1 to 25 years) from the proposed 

timber harvest due to the increase shrub production in early clearcuts. Habitat would be reduced long

term with the onset of stem exclusion.

Impacts to species using other habitats (e.g., cliffs, tide flats, rocky shorelines) would be negligible at 

the population level.

Cumulative Effects

Alternative 1 

The Saddle Lakes Timber Sale would not contribute to cumulative effects under Alternative 1. 

Previously harvested habitat would remain unsuitable for many species into the long term future.

Alternatives 2, 3, 4, 5, and 6

Alternatives 2 through 6 would contribute to cumulative effects. Past activities have removed habitat 

suitable for forest related migratory birds. Impacts to POG habitat would be similar to MIS 

discussions above.

Summary of Neotropical Migratory Bird Effects

All action alternatives harvest hemlock/spruce/cedar forest, used as primary habitat by 14 migratory 

bird species. Alternatives are not anticipated to have a measurable effect on any migratory bird 

populations, although individuals and their nests may be impacted. Timber operating seasons overlap 

substantially with the migratory bird nesting season and can lead to nest destruction and/or 

abandonment. 

Threatened, Endangered, Candidate, and Sensitive Species

A detailed analysis of effects on threatened, endangered, candidate, and sensitive species is provided 

in the Saddle Lakes Biological Assessment/Biological Evaluation and summarized in Table 63. 

Effects to the marine environment would be limited to temporary disturbance from LTF 

reconstruction and project related vessel traffic. Humpback whales are the only federally listed 

species occurring in the marine environment adjacent to the Saddle Lakes project. They are regularly 

sighted in the Inside Passage and coastal waters of Southeast Alaska (NMFS 1991) and have 

occasionally been observed in Carroll and George Inlets. R10 sensitive species Steller sea lions and 

Queen Charlotte goshawk occur in or near the project area and yellow-billed loons potentially occur. 

Black oystercatchers (R10 sensitive species) occur on KMRD, but inhabit more exposed shorelines 

and are not suspected to occur within Carroll or George Inlets (S. Heinl, email). 

Steller sea lions are regularly sighted in the Inside Passage and coastal waters of Southeast Alaska 

(NMFS 1991) and have occasionally been observed in Carroll and George Inlets. The largest Steller

sea lion rookeries are now in Southeast Alaska and British Columbia with the two largest occurring

on the Forrester Island complex and Hazy Islands off the west coast of Prince of Wales Island in

Southeast Alaska (NMFS 2008). Grindall Island is the closest known minor sea lion haulout; it is 

approximately 20 miles west of the Saddle Lakes area on the opposite side of West Behm Canal. The 

Steller’s sea lion eastern Distinct Population Segment (DPS) was delisted under the Endangered

Species Act effective December 4, 2013 (Federal Register Vol. 78, No. 213). Members of the 

endangered Western DPS have been documented in northern Southeast Alaska but rarely occur 

south of Frederick Sound (NMFS 2013c). 
3 Affected Environment and Environmental Consequences

168  Chapter 3 – Issue 3A – Wildlife Habitat Saddle Lakes Timber Sale Final EIS

Because timber harvest would reduce nesting and foraging habitat, detailed analysis of effects to the 

Queen Charlotte goshawk is provided below. 

Table 63. Summary of threatened, endangered, candidate, and sensitive species determinations

Federally Listed Species No Effect Beneficial 

Effect 

Not Likely to 

Adversely Affect

Likely to Adversely 

Affect 

Humpback Whale Alt 1 Alts 2, 3, 4, 5, 6

R10 Sensitive Species No Impact Beneficial 

Impact

May Impact 

Individuals1/ Likely to Result in 

Loss or Trend2/

Steller’s Sea Lion Alt 1 Alts 2, 3, 4, 5, 6

Yellow-billed loon Alt 1 Alts 2, 3, 4, 5, 6

Queen Charlotte Goshawk Alt 1 Alts 2, 3, 4, 5, 6

1/ Actual determination: “may adversely impact individuals, but not likely to result in a loss of viability in the Planning Area, nor 

cause a trend toward federal listing”.

2/ Actual determination: “likely to result in a loss of viability in the Planning Area, or a trend toward federal listing.”

Queen Charlotte Goshawk

Direct/Indirect Effects

Measurement criteria include: medium- and high-POG (SD4N, SD4S, SD5H, SD5N, SD5S, and 

SD67) less than 1,000 feet elevation for nesting habitat, and all POG less than 1,000 feet elevation for 

foraging habitat. The VCU scale was used to analyze direct and indirect effects.

Effects Common to All Action Alternatives

Timber harvest affects goshawks by reducing the amount of suitable nesting habitat, and impacting 

prey abundance, and/or prey availability (USFWS 2007). Nest habitat is affected in two ways: direct 

removal of higher volume, structurally diverse habitat and increased fragmentation. Nests tend to be 

located in the least fragmented areas of individual home ranges, and nest areas in large patches of old 

or mature forest are used more consistently than those in small patches (multiple studies summarized 

in USFWS 2007). 

Clearcut logging “significantly degrades” habitat for the goshawk by creating large forest openings 

devoid of prey (USFWS 2007). Young growth may support some prey species. However, prey are 

generally unavailable because stand structure is too dense to allow goshawks to hunt effectively 

(USFWS 2007). Logging removes both foraging cover and perches. Goshawks hunt by alternating 

short flights with a period of watching from a perch, then attacking prey from the perch. This method 

of hunting relies on cover to conceal the predator’s approach, perches from which to observe and 

attack, adequate visibility for spotting prey, and adequate space between trees to allow for flying 

between perches and attacking prey (USFWS 2007). Prey abundance has been shown to have a direct 

influence on whether goshawks nest in any given year. Low prey diversity increases goshawk 

sensitivity to habitat modification since habitat reduction may reduce prey abundance (see red 

squirrel, hairy woodpecker, and red-breasted sapsucker analysis in Wildlife Resource Report). Longer 

foraging distances increase energy demands on adults and increase risk of nest abandonment and 

decrease protection of chicks from adverse weather or predation. With impacts to foraging habitat, 

goshawks may spend more time foraging and forage further distances which could impact chick 

survival and condition. Thus, habitat quantity and quality is a function of the amount and distribution 

of POG through space and time (USFWS 2007). Clearcutting may also favor open habitat competitors 

or predators such as red-tailed hawks, barred owls, and great-horned owls (USFWS 2007). 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Issue 3A – Wildlife Habitat - Chapter 3  169

Partial cutting has less effect on goshawks because it retains some older trees for nesting, maintains 

relatively high-value foraging habitat, and maintains habitat for a diverse suite of prey (Iverson et al. 

1996). 

Timber harvest, and subsequent lack of habitat, could increase competition by other raptors, increase 

predation, reduce life expectancy, and reduce nesting success.

Reduced suitable habitat patch sizes and connectivity may disrupt source–sink dynamics by 

modifying the balance between local extirpation and recolonization (Sonsthagen et al. 2012). Since 

the Revillagigedo Island cluster is already a short-term, long-term, and historic population sink 

(Sonsthagen et al. 2012), this loss of goshawk habitat increases the risk of local extirpation. The 

Revillagigedo Island cluster is already a short-term, long-term and historic population sink 

(Sonsthagen et al. 2012); this loss of goshawk habitat increases the risk of local extirpation.

Alternative 1

Alternative 1 would have no direct or indirect impact on goshawks because no timber harvest 

activities would occur. All existing nesting and foraging habitat would remain intact to support 

current levels of goshawks and prey (Table 64). Natural processes such as weather and fluctuations in 

prey would continue to influence whether goshawks nest in any given year. 

Table 64. Impacts to goshawk habitat on NFS lands by VCU

Habitat Historic 

(ac)

Acres (% reduction from existing)

Existing \ 

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

VCU 7460

Nesting1/ 11,476 7,745 7,126

(-8.0%)

7,603

(-1.8%)

7,068

(-8.7%)

6,948

(-10.3%)

7,216

(-6.8%)

Foraging2/ 13,196 8,846 8,052

(-9.0%)

8,637

(-2.4%)

7,978

(-9.8%)

7,820

(-11.6%)

8,129

(-8.1%)

VCU 7470

Nesting1/ 5,288 4,539 3,915

(-13.7%)

4,174

(-8.0%)

3,843

(-15.3%)

3,620

(-20.2%)

3,846

(-15.3%)

Foraging2/ 6,523 5,150 4,474

(-13.1%)

4,737

(-8.0%)

4,403

(-14.5%)

4,169

(-19.0%)

4,406

(-14.4%)

VCU 7530

Nesting1/ 11,721 7,383 7,181

(-2.7%)

7,279

(-1.4%)

7,182

(-2.7%)

7,094

(-3.9%)

7,171

(-2.9%)

Foraging2/ 13,353 8,783 8,527

(-2.9%)

8,644

(-1.6%)

8,527

(-2.9%)

8,437

(-3.9%)

8,516

(-3.0%)

1/ Nesting habitat = high-POG & medium-POG ≤1,000 feet elevation.

2/ Foraging habitat = POG ≤1,000 feet elevation.

Alternative 2

Alternative 2 would clearcut 733 acres of goshawk nesting habitat and partial-cut 712 acres (Table 

64). Partial-cutting would occur on a portion of the quality habitat on the south side of North Saddle 
3 Affected Environment and Environmental Consequences

170  Chapter 3 – Issue 3A – Wildlife Habitat Saddle Lakes Timber Sale Final EIS

Lakes and above the beach buffer near Island Point. Nesting habitat would become more fragmented 

throughout the project area. 

Alternative 2 would impact 1,726 acres of foraging habitat of which 892 acres (52 percent) would be 

clearcut. All nesting and foraging habitat within the existing OGR would be maintained. Alternative 2 

ranks second among the action alternatives for preserving goshawk habitat behind Alternative 3. 

Alternative 3

Alternative 3 would impact 611 acres of nesting habitat of which 500 acres (82 percent) would be 

clearcut. Alternative 3 would impact 762 acres of foraging habitat of which 647 acres (85 percent) 

would be clearcut. All nesting and foraging habitat within the existing OGR would be maintained. 

High quality nesting and foraging habitat on the south side of North Saddle Lakes and above the 

beach buffer near Island Point is maintained under this alternative. Alternative 3 maintains current

connectivity and reduces the amount of fragmentation. Alternative 3 would have the least impact on 

goshawk nesting and foraging habitat and consequently the least impact on goshawks of the action 

alternatives (Table 64).

Alternative 4

Alternative 4 ranks fifth among the action alternatives in terms of maintaining nesting and foraging 

habitat to support goshawk populations. Alternative 4 would impact 1,574 acres of nesting habitat of 

which 1,398 acres (89 percent) would be clearcut. Alternative 4 would impact 1,870 acres of foraging 

habitat of which 1,678 acres (90 percent) would be clearcut (Table 64). All habitat within the existing 

OGR would be maintained. Quality habitat on the south side of North Saddle Lakes would be either 

clearcut or partial-cut and the habitat above the beach buffer near Island Point would be clearcut. 

Alternative 4 would create a more fragmented landscape and does not maintain connectivity corridors 

for important prey species. Alternative 4 ranks fifth among the action alternatives in terms of 

maintaining nesting and foraging habitat to support goshawk populations. 

Alternative 5

Of the 2,002 acres of nesting habitat being harvested, 1,864 acres (93 percent) would be clearcut. 

Alternative 5 would impact 2,352 acres of foraging habitat of which 2,196 acres (93 percent) would 

be clearcut. High quality habitat on the south side of North Saddle Lakes and above the beach buffer 

near Island Point would be clearcut under this alternative. In addition, the roaded portion of the small 

OGR in VCU 7470 would be relocated into the roadless area reducing the amount of high-and 

medium POG habitat and further fragmenting the area. Under Alternative 5, the project area would be 

highly fragmented outside of OGRs and roadless areas. Alternative 5 would have the greatest impact

on nesting and foraging habitat and on goshawks overall (Table 64).

Alternative 6

Alternative 6 would reduce goshawk nesting habitat by 1,435 acres of which 1,151 acres (80 percent) 

would be clearcut (Table 64). Alternative 6 would impact 1,728 acres of foraging habitat of which 

1,449 acres (84 percent) would be clearcut. Quality habitat on the south side of North Saddle Lakes 

would be either clearcut or partial-cut. The habitat above the beach buffer near Island Point would be 

clearcut. The existing OGR in VCU 7470 would be maintained, but current connectivity corridors 

would impacted increasing fragmentation overall. Alternative 6 ranks third for maintaining nesting 

and foraging habitat and supporting goshawk populations. 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Issue 3A – Wildlife Habitat - Chapter 3  171

Table 65. Cumulative impact goshawk habitat on all land ownerships by VCU and WAA

Habitat Historic

(ac)

Acres (% reduction from existing acres)

Existing 

\ Alt. 1 Alt. 2 Alt. 3 Alt. 4 Alt 5 Alt 6

VCU 7460

Nesting 12,196 7,748

(-36.5%)

7,129

(-41.5%)

7,606

(-37.6%)

7,071

(-42.0%)

6,951

(-43.0%)

7,219

(-40.8%)

Foraging 13,297 8,849

(-33.5%)

8,055

(-39.4%)

8,640

(-35.0%)

7,981

(-40.0%)

7,823

(-41.2%)

8,132

(-38.8%)

Over 33% 

clearcut? Y Y Y Y Y Y 

VCU 7470

Nesting 8,864 5,962

(-32.7%)

5,338

(-39.8%)

5,596

(-36.9%)

5,266

(-40.6%)

5,042

(-43.1%)

5,268

(-40.6%)

Foraging 9,582 6,680

(-30.3%)

6,004

(-37.3%)

6,267

(-34.6%)

5,934

(-38.1%)

5,699

(-40.5%)

5,936

(-38.1%)

Over 33% 

clearcut? N Y Y Y Y Y 

VCU 7530

Nesting 14,696 8,442

(-42.6%)

8,241

(-43.9%)

8,339

(-43.3%)

8,241

(-43.9%)

8,157

(-44.5%)

8,230

(-44.0%)

Foraging 16,229 9,975

(-38.5%)

9,719

(-40.1%)

9,836

(-39.4%)

9,719

(-40.1%)

9,629

(-40.7%)

9,708

(-40.2%)

Over 33% 

clearcut? Y Y Y Y Y Y 

WAA 406

Nesting 40,172 27,934

(-30.5%)

27,114

(-32.5%)

27,689

(-31.1%)

27,056

(-32.6%)

26,851

(-33.2%)

27,193

(-32.3%)

Foraging 44,126 31,887

(-27.7%)

30,837

(-30.1%)

31,539

(-28.5%)

30,764

(-30.3%)

30,516

(-30.8%)

30,904

(-30.0%)

Over 33% 

clearcut? N N N N N N 

WAA 407

Nesting 25,153 14,535

(-42.2%)

13,911

(-44.7%)

14,169

(-43.7%)

13,839

(-45.0%)

13,615

(-45.9%)

13,841

(-45.0%)

Foraging 28,481 17,862

(-37.3%)

17,186

(-39.7%)

17,449

(-38.7%)

17,166

(-39.7%)

16,882

(-40.7%)

17,118

(-39.9%)

Over 33% 

clearcut? Y Y Y Y Y Y 

Source: USFS Tongass National Forest GIS.

Cumulative Effects

All ownerships within project area VCUs and WAAs were used for cumulative effects analysis.
3 Affected Environment and Environmental Consequences

172  Chapter 3 – Issue 3A – Wildlife Habitat Saddle Lakes Timber Sale Final EIS

Additional impacts to goshawks come from the past timber harvest on all ownerships. Current high 

levels of fragmentation and impacts on nesting habitat (up to 45 percent reduction from historic 

levels) could be affecting goshawk use of the area and limiting nesting. Research in British Columbia 

suggests that landscapes that should be managed for at least 40 to 50 percent mature and old-growth 

forest to provide adequate nesting and foraging habitat for Queen Charlotte goshawks (Doyle 2005, 

Northern Goshawk Recovery Team 2008 ). Up to 33 percent of the productive old-growth in a 

watershed or VCU in early seral stage (i.e. at least 67 percent in old-growth) was considered capable 

of sustaining goshawks on the Tongass (Iverson et al. 1996, 1997 FP Appendix N pages N-38 thru N41). Harvesting at a rate exceeding this and creating an excess amount of early (0 to 100 year old) 

forest increases the risk of not sustaining goshawks (1997 FEIS, p. 3-393, Iverson et al. 1996). 

Goshawks are at or would be at increased risk of sustainability as a result of Saddle Lakes and 

identified future projects. VCUs 7460 and 7530 are currently at increased risk with more than 33 

percent of the suitable habitat harvested (Table 65). Cumulative impacts would increase up to 43 

percent as a result of the Saddle Lakes project combined with other activities. VCU 7470 currently 

contains less than 33 percent (32.7 percent) past harvest, but would be above and therefore at higher 

risk, after implementation of the Saddle Lakes and other foreseeable projects. Habitat alteration and 

fragmentation can affect goshawk survival and productivity at the population level if it decreases 

foraging habitat quality across the landscape (USFWS 2007). Non-NFS harvest and hydropower 

construction/expansion would further increase risk.

Random events coupled with reduced suitable habitat patch sizes and connectivity may disrupt 

source–sink dynamics by modifying the balance between local extirpation and recolonization 

(Sonsthagen et al. 2012). Since the Revillagigedo Island cluster is already a short-term, long-term, 

and historic population sink (Sonsthagen et al. 2012), this loss of goshawk habitat increases the risk 

of local extirpation.
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Issue 3B – Subsistence Use - Chapter 3  173

Issue 3B. Subsistence Use

Unit of Measure:

Deer abundance and competition estimated by hunter demand as a percent of Deer Habitat Capability 

(DHC). The Saddle Lakes project area and WAAs 406 and 407 fall within the community use areas of 

Metlakatla, Saxman, and Ketchikan. Metlakatla and a portion of Saxman are classified as rural and 

receive subsistence priorities under ANILCA. Ketchikan is classified as a non-rural community and 

residents do not have a subsistence priority under ANILCA. 

Introduction

The Alaska National Interest Lands Conservation Act (ANILCA), passed by Congress in 1980, 

mandates that rural residents of Alaska be given a priority for subsistence uses of fish and wildlife. 

The subsistence regulations contained in 50 C.F.R § 100.3(c)(25) apply on all public lands, excluding 

marine waters, but including all inland waters, both navigable and non-navigable, within and adjacent 

to the exterior boundaries of the Tongass National Forest, including Admiralty Island National 

Monument and Misty Fjords National Monument.

Section 810 of ANILCA requires the Forest Service, in determining whether to withdraw, reserve, 

lease, or otherwise permit the use, occupancy, or disposition of National Forest System land in 

Alaska, to evaluate the potential effects on subsistence uses and needs. This analysis typically focuses 

on food-related resources most likely to be affected by habitat loss or alteration associated with land 

management activities.

The U.S. District Court Decision in Kunaknana v. Watt defines a significant restriction to subsistence 

use: 

...restriction for subsistence uses would be significant if there were large reductions in 

abundance or major redistribution of these resources, substantial interference with harvestable 

access to active subsistence-use sites, or major increases in non-rural resident hunting. 

Incomplete and Unavailable Information

Current subsistence use information is lacking. Surveys for Ketchikan (non-rural) were completed 5 

years ago. Information for Saxman and Metlakatla is approximately 13 years old. Accurate data 

cannot be derived from ADF&G harvest records since some Saxman residents have a Ketchikan 

mailing address.

Existing data is sufficient to determine that deer are the main land mammal used and that use of deer 

is minor compared to marine resources.

Affected Environment

The Saddle Lakes project area and WAAs 406 and 407 fall within the community use areas of 

Metlakatla, Saxman, and Ketchikan. Metlakatla and a portion of Saxman are classified as rural and 

receive subsistence priorities under ANILCA. Ketchikan is classified as a non-rural community and 

residents do not have a subsistence priority under ANILCA. 

Subsistence use areas vary by community, but the highest use generally occurs within a 15-mile 

radius of the community (USDA Forest Service 2008c, p. 3-426). Wolfe (2004) contrasts the 

difference between subsistence objectives and sport hunting: 
3 Affected Environment and Environmental Consequences

174  Chapter 3 – Issue 3B – Subsistence Use Saddle Lakes Timber Sale Final EIS

• Subsistence users typically hunt and fish in ways to efficiently optimize food output per

investment of effort and money. Special trips to more distant parts of the community use area

occur seasonally for special resources, or on certain years when local fish and game are scarce;

• Sport hunting commonly promotes principles of “fair chase,” high-quality hunts, and greater

opportunities for participation by other sportsmen. Less emphasis is placed on using the most

efficient logging system or on distance traveled.

Salmon and other finfish, shellfish, marine plants and mammals, terrestrial wildlife including deer 

and other mammals, as well as berries, cedar bark, and timber are all subsistence resources harvested 

by rural communities in Southeast Alaska. 

Community Profiles

Subsistence research conducted in Southeast Alaska over the past two decades has included 

community studies, use area mapping, household surveys, and studies of specific subsistence 

harvests. The Tongass Resource Use Cooperative Survey (TRUCS) was completed in 1988. The 1997 

Forest Plan provided a comprehensive analysis of subsistence resources and potential effects, both 

Tongass-wide and for each rural community of Southeast Alaska. Detailed community use 

information is available in the 1997 Forest Plan FEIS (USDA Forest Service 1997a, pgs. 3-419 to 3-

435, 3-575 to 3-714, and Appendix H). Additional information is presented in the 2008 Forest Plan 

FEIS (USDA Forest Service 2008c, pp. 3-419 through 3-433). 

Metlakatla

Metlakatla is located on Annette Island, 15 miles south of Ketchikan. It is a Federal Indian 

Reservation and a traditional Tsimshian community with a subsistence lifestyle. Metlakatla residents 

harvest an average of 70 pounds of wild resources per person per year. In 1987, Metlakatla residents 

harvested 55 pounds of fish and marine invertebrates per person, which comprised 78 percent of the 

total resource harvest (ADF&G 1999b). Deer and other mammals comprised 17 percent. Deer 

comprised almost 11 pounds per person or roughly 15 percent of harvested resources. 

The majority (70 percent) of deer harvest by Metlakatla residents takes place in three WAAs (101, 

202, and 405) located in the vicinity of the community (USDA Forest Service 2008c, p. 3-649). 

Therefore, while some Metlakatla residents may hunt in the Saddle Lakes area, it is not a major use 

area for deer.

Saxman

Saxman is located 2 miles south of Ketchikan on the South Tongass Highway. Tlingit from the old 

villages of Tongass and Cape Fox resettled at the present site of Saxman in 1894. Today Saxman 

continues as a predominantly Tlingit community, with its own city and tribal governing bodies. 

Saxman is a recognized Native village with most residents maintaining a subsistence based lifestyle.

WAA 406 is one of the areas where Saxman residents obtain approximately 75 percent of their annual 

deer harvest. With the completion of the Ketchikan to Shelter Cove road, use within this area is 

expected to increase.

Saxman residents harvested 152 pounds of fish and marine invertebrates per person in 1999, which 

comprised 70 percent of per capita subsistence harvest in Saxman (ADF&G 2000). Deer accounted 

for 18 percent of the harvest. Harvest of all land mammals (including deer) dropped to only 13 

percent (ADF&G 2000).
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Issue 3B – Subsistence Use - Chapter 3  175

Ketchikan

Ketchikan does not have subsistence priority under ANILCA. However, many Ketchikan residents 

use the Tongass National Forest for hunting and fishing. The first Ketchikan residents were Tlingit 

members of the Tongass Tribe (Garza et al. 2006). Although the US purchased the territory of Alaska 

from Russia in 1867, Ketchikan became a European town in the mid 1880s when the first fish 

cannery was built. WAAs 406 and 407 are two of the areas where Ketchikan residents obtain 

approximately 75 percent of their annual deer harvest. With the completion of the Ketchikan to 

Shelter Cove road, use within these WAAs is expected to increase.

No comprehensive household harvest survey has been conducted for Ketchikan. In 2006, the 

Ketchikan Indian Community (KIC) conducted their own survey using ADF&G standard household 

survey protocols adapting the household survey questions which had been used in Saxman (Garza et 

al. 2006). According to their survey results, Ketchikan residents harvest an average of 90 pounds of 

wild resources per person, per year. Ketchikan residents harvested 70 pounds of fish and marine 

invertebrates per person in 2006, which comprised 78 percent of total resource harvest (Garza et al. 

2006). Total large land mammal harvest comprised roughly 15 percent. Deer comprised 10.5 pounds 

per person or roughly 12 percent of harvested resources. 

Environmental Consequences

ANILCA requires the analysis of the potential effects on subsistence uses of all actions on federal 

lands in Alaska. This analysis most commonly focuses on those food-related resources most likely to 

be affected by habitat degradation associated with land management activities. 

Marine resources account for more than half of the total per capita harvest in all Southeast Alaska 

communities. As a result, management activities that restrict access for subsistence harvest of land

mammals have had a relatively small effect on overall subsistence harvest by weight (USDA Forest

Service 2008c, p. 3-424). The 2008 Forest Plan Record of Decision determined that, Forest-wide, 

under full implementation of the plan, the only subsistence resources likely to be significantly 

affected was Sitka black-tailed deer (USDA Forest Service 2008a, p. 61); therefore, only effects to 

deer were analyzed in detail.

Three factors related to subsistence uses are specifically identified by ANILCA: 1) resource 

distribution and abundance, 2) access to resources, and 3) competition for the use of resources.

Effects on Subsistence Use of Deer

Distribution and Abundance

Current deer populations on Revillagigedo Island are thought to be at very low levels (Porter 2011a). 

Populations fluctuate seasonally in response to winter weather and predation, and long-term in 

response to clearcutting (Porter 2011a). Under all alternatives, including the No-action Alternative, 

deer habitat capability will decrease as a result of existing young-growth stands entering the stem 

exclusion stage and from proposed harvest. Under the action alternatives analyzed in this EIS, the 

possibility of a change in abundance or distribution would be roughly the same for Alternatives 2, 4, 

and 6, slightly less for Alternative 3, and slightly more for Alternative 5. The Saddle Lakes project 

would reduce deer habitat capability up to 8 percent from existing conditions (WAA 406 on Forest 

Service land), and up to 61 percent from historic habitat capabilities (WAA 407 on all lands). The 

stem exclusion effect from past harvest would override the short-term increase of forage in the new 

clearcuts due to even-aged management. The reader is referred to the Sitka black-tailed deer MIS 

Section for more information.
3 Affected Environment and Environmental Consequences

176  Chapter 3 – Issue 3B – Subsistence Use Saddle Lakes Timber Sale Final EIS

Some localized shifts in deer distribution could occur in response to the reduction in POG forest and 

habitat connectivity and to disturbance caused by harvest activities. . However, this is not expect to 

change overall distribution within WAAs 406 or 407, or cause mass migration of deer to adjacent 

WAAs (Colson et al. 2012, BC Ministry of Deer 1999, McNay and Vollner 1995). The remaining 

POG would be further away from roads so deer could be less accessible to hunters or require more 

effort to obtain.

Access

ANILCA Section 811 states that rural residents engaged in subsistence uses shall have reasonable 

access to subsistence resources on the public lands. None of the alternatives would limit the use of 

public lands for the purposes of subsistence gathering activities. Beach access would not be affected 

by the Saddle Lakes project. Access to most deer hunting in the area is currently by boat, but the road 

systems are used to access additional areas.

The 2008 KMRD Access Travel Management Plan (ATM) Decision Notice (DN) and Finding of No 

Significant Impact (FONSI) determined which roads on Revillagigedo Island would remain open to 

public use. Roads closed under the ATM decision are technically closed even though not all physical 

barriers have been installed to date. The Saddle Lakes project decision would update the ATM to 

include project constructed roads, but would not change access decisions made in the ATM. Closed 

roads would provide easier walk-in access for hunters until such time as brush and alder make the 

roads impassable. Total walk in impassability from brush is not expected to occur within the 

foreseeable future.

The Ketchikan to Shelter Cove Road would connect additional areas in WAA 407 (including the 

Saddle Lakes area), and would connect the area in WAA 406 west of Carroll Inlet to the communities 

of Saxman and Ketchikan. This additional road access is expected to increase hunting pressure within 

the Saddle Lakes project area and could lead to increased competition between user groups (see 

Competition section below). All communities having new road access to previously under-utilized 

subsistence areas have capitalized on the opportunity to expand their range. Subsistence use from 

Metlakatla may also expand given the daily ferry service between Metlakatla and Ketchikan. The 

Ketchikan to Shelter Cove Road will make access less weather dependent than boating.

Competition for Deer

For analyzing competition, the following assumptions are made consistent with the Forest Plan FEIS 

(USDA Forest Service 2008c, p. 3-432): 

• Habitat reductions will result in increased competition if regulations allow sport use to remain

constant, with the same number of users seeking fewer huntable resources.

• The demand for resources will remain constant or increase slightly as the habitat capability

remains the same or declines over time.

Changes in deer abundance from timber harvest and increased road access to deer by both rural and 

non-rural hunters would affect competition for deer. Increased competition may result when less 

expensive access to the area or within the area is provided. Such is the case when road systems are 

established to local communities (USDA Forest Service 2008c, p. 3-421). 

Over 90 percent of GMU 1A hunters are local residents living within GMU 1A (Porter 2011a). From 

the 1999 data, Saxman residents harvested an estimated 198 deer whereas Ketchikan residents 

harvested 760 deer in GMU 1A (ADF&G 1999). 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Issue 3B – Subsistence Use - Chapter 3  177

Because actual hunter demand is unknown, ADF&G deer harvest survey reports were used in this 

analysis to estimate the hunter demand. While these reports were extrapolated from random surveys 

for many years, the data provides the best available information. ADF&G has recently gone to 

mandatory reporting for all deer hunters which, over time, will provide better information. 

ADF&G deer harvest survey results for WAA 406 (email from B. Porter, ADF&G, 08/19/2013) show 

an average of 56 deer per year being harvested from 2002 to 2011. WAA 407 received less use with 

an average of 21 deer harvested per year. Actual harvest averages 0.6 deer per hunter or 1.6 deer per 

successful hunter in WAA 406, and 0.3 deer per hunter or 1.1 deer per successful hunter in WAA 407. 

This approach may be slightly conservative since not all hunters are successful and actual harvests are 

less. Some hunters may also hunt in more than one WAA or GMU. Analysis included lands in all 

ownerships with all non-NFS lands being given a zero value for deer in the deer model. After 

including predation in the deer model since wolves and bear are present in Saddle Lakes area WAAs, 

hunter demand for 190 deer equates to 8 percent of the historic habitat capability in WAA 406. 

Hunter demand for 142 deer in WAA 407 equals 9 percent of the historic habitat capability. 

Table 66. Estimated deer harvest as a percent of deer habitat capability (DHC) by WAA. 

WAA Stand 

Age

Estimated Hunter Demand as a Percent of DHC

Historic Existing / 

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

WAA 406

0-25 

years

2,284

(8%)

1,613

(12%)

1,588

(12%)

1,603

(12%)

1,587

(12%)

1,582

(12%)

1,590

(12%)

26-200 

years

2,284

(8%)

1,564

(12%)

1,533

(12%)

1,557

(12%)

1,530

(12%)

1,522

(12%)

1,536

(12%)

WAA 407

0-25 

years

1,578

(9%)

669

(21%)

649

(22%)

657

(22%)

646

(22%)

638

(22%)

647

(22%)

26-200 

years

1,578

(9%)

652

(22%)

626

(23%)

637

(22%)

621

(23%)

611

(23%)

623

(23%)

Source: USFS Tongass National Forest GIS.

1/ Habitat capability reduced by 36% to account for predation. Non-NFS lands were given zero value per deer model direction.

It is assumed that a deer population at carrying capacity should be able to support a hunter harvest 

(demand) of approximately 10 percent of the habitat capability that is sustainable and provides a 

reasonably high-level of hunter success (USDA Forest Service 2008c, pp. 3-428). Hunter success can 

be expected to decline when demand represents 10 to 20 percent of habitat capability. If demand 

exceeds 20 percent of habitat capability, harvest of deer by hunters may be restricted. This is done 

either directly through restrictions in seasons and bag limits, or indirectly through reduced hunter 

efficiency and increased difficulty in obtaining deer relative to historical rates.

Demand would remain at approximately 12 percent in WAA 406 (Table 66) indicating that hunters 

may experience reduced hunter efficiency, and moderate difficulty in obtaining deer. Demand would 

increase from 21 to 22 percent of habitat capability in WAA 407 (Table 66) indicating that hunter 

success could be expected to decline. Over the long-term, the proposed harvest would develop into 

stem exclusion and further reduce habitat capability. Table 66 shows that at stem exclusion and 

beyond (26-200 years) the hunter demand will remain unchanged or increase by 1 percent (from 22 

percent to 23 percent). Current and projected deer demand in WAA 407 is at the level at which deer 

harvest may be restricted (greater than 20 percent), either directly through restrictions in seasons and 
3 Affected Environment and Environmental Consequences

178  Chapter 3 – Issue 3B – Subsistence Use Saddle Lakes Timber Sale Final EIS

bag limits, or indirectly through reduced hunter efficiency and increased difficulty in obtaining deer 

relative to historical rates. This fits with the harvest survey data in that WAA 407 has a lower success 

rate than WAA 406. Based upon the 2002 to 2011 harvest data averages (Porter 2013b), 38 percent of 

all hunters were successful in WAA 406, whereas only 23 percent were successful in WAA 407.

Trends are not likely to change as a result of the Saddle Lakes project. Ketchikan residents would 

continue to harvest the greatest number of deer from the Saddle Lakes WAAs. Therefore, reductions 

in habitat capability to support deer could lead to increased competition between rural and non-rural 

hunters for available resources. Demand may also increase with the Ketchikan to Shelter Cove road 

connection. Use from Metlakatla may increase causing additional completion between rural 

subsistence users. Additional non-rural and non-resident hunters may hunt the area given the easy 

access to and from Ketchikan. If future restrictions are necessary due to increased demand and/or less 

deer, then Ketchikan and other non-rural hunters would be restricted first. If further restrictions 

become necessary, then a “customary and traditional use” determination could be made for Saxman

and potentially Metlakatla restricting other subsistence.

Effects on Subsistence Use of Fish

For Metlakatla, Saxman, and Ketchikan, fish is by far the major subsistence resource harvested, 

averaging 59 percent of the total subsistence harvest. During 2011, sockeye salmon made up 80 

percent of the regional harvest for the Ketchikan subsistence and personal-use combined fisheries 

area, which includes Metlakatla and Saxman (ADF&G 2013). Currently there is no regulated sockeye 

subsistence or personal-use fishery within the Saddle Lakes project area. Other fisheries resources 

include eulachon, shrimp, sea cucumber, and Dungeness crab. The federal subsistence fishery for 

eulachon was closed in the Ketchikan area (Commercial Fishing District 1) in 2012, 2013, and 2014 

following unexpectedly low returns of eulachon to the Carroll River in beginning in 2011. There are 

no known freshwater subsistence activities taking place in the project area.

The risk to fish and aquatic habitat from the Saddle Lakes project would be minimal. The Tongass 

Timber Reform Act (TTRA), Forest Plan Riparian Standards and Guidelines, and best management 

practices (BMPs) would help protect aquatic resources. 

Findings

Wildlife Resources

The Forest Plan indicated that forest-wide, deer habitat capabilities in some portions of the Tongass 

National Forest may not be adequate to sustain the current levels of deer harvest. Also, that full 

implementation of the Forest Plan could be accompanied by a significant possibility of a significant 

restriction on the abundance and/or distribution of deer, and on competition for this resource (USDA 

Forest Service 2008a, p. 61). 

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

effects on subsistence, as described above. Based on that evaluation, the Saddle Lakes project may 

have a significant possibility of a significant restriction of subsistence uses on deer due to changes in 

abundance and competition. The Ketchikan to Shelter Cove Road would increase access to deer 

affecting the demand and/or the amount of competition in the Saddle Lakes project area.

Based upon community use information and MIS analysis, the Saddle Lakes project shall not result in 

a significant restriction of other wildlife uses. 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Issue 3B – Subsistence Use - Chapter 3  179

To be in compliance with ANILCA, and consistent with current Forest policy (FSH 2090.23), the 

following actions are required as a result of the finding of a significant possibility of a significant 

restriction:

• The proposed action be modified to remove the significant restriction finding; or

• The process be stopped for that action and the action prohibited; or

• After notifying the Regional Forester and requesting concurrence, proceed to Notice and

Hearings.

Fisheries Resources

Effects from action alternatives are expected to be minor to subsistence fishery resources. Therefore, 

the Saddle Lakes Timber Sale is not expected to result in a significant restriction of fisheries 

subsistence uses.

Notice and Hearings

If the above evaluation results in the finding of a significant possibility of a significant restriction of 

subsistence uses and the responsible line officer decides to proceed, the official shall: 

• Give notice to the Alaska Department of Fish and Game (for wildlife and fisheries subsistence

uses);

• Give notice to the appropriate Subsistence Regional Advisory Councils and local fish and game

advisory committees (for wildlife and fisheries subsistence uses); and

• Give notice and hold a public hearing in the vicinity of the area involved.

Notice shall not be less than 30 days and may be extended. Notices in a, b, and c, above may run 

concurrently. 
3 Affected Environment and Environmental Consequences

180  Chapter 3 – Issue 4A – Scenery Saddle Lakes Timber Sale Final EIS

Issue 4. Scenery and Recreational Opportunities

Issue Statement: Timber harvest and road construction could affect the scenery and 

recreational opportunities in the Saddle Lakes project area.

Internal concerns were expressed regarding the effects that timber harvest would have on areas visible 

from Visual Priority Routes and Use Areas (VPRs). The five VPRs in and adjacent to the project area 

include: Saddle Lakes Recreation Area, Harriet Hunt to Shelter Cove Connection Road (hereafter 

referred to as the Connection Road), Shelter Cove Boat Ramp, Carroll Inlet, and George Inlet. 

Changes to recreational opportunities may occur because of road construction and timber harvest. 

The Scenery and Recreation Relationship

Managing the scenery of National Forest timber harvests is important to the recreation resource 

because visitors seeking recreation opportunities on a National Forest often have strong expectations 

of beautiful landscapes and a non-exploitive relationship with nature (Niemi and Whitelaw 1999; 

Durning 1999 as cited in Ribe 2009). Scenic beauty is an important issue affecting socially acceptable 

forestry and timber harvest decisions on the Tongass National Forest, and it also has a direct 

relationship with outdoor recreation opportunities. Most recreation activities take place in, and are 

dependent on, settings primarily undeveloped and widely dispersed (USDA Forest Service 2008c, p. 

3-370). These two resources are combined into one issue because of the strong connection between 

the two.

Issue 4A. Scenery

Units of Measure:

The following units of measure were used to evaluate effects of the proposed action to scenery and 

compare alternatives:

• Acres of timber harvest by silvicultural prescription within areas of high and moderate scenic

integrity objective (SIO);

• Miles of road construction within project areas of high and moderate SIO;

• Acres of timber harvest by silvicultural prescription within the planned Saddle Lakes Recreation

Area viewshed; and

• Project area acres that would change SIO if visual priority routes (VPRs) are removed.

Methodology

Developing a system to quantify a resource that is hard to measure such as scenery has been a 

challenge to land management agencies. While the land and its characteristics are fairly constant, it is 

the perceptions of people and society that brings value to the scenery. Methodology used to evaluate 

scenery impacts for this project is called the Scenery Management System (SMS) and is described in 

Landscape Aesthetics (USDA Forest Service, 1995b). SMS provides the systematic framework used 

by the Forest Service for the inventory of scenic resources and provides measurable standards for its 

management. Please refer to the Scenery Resource Report for a more detailed explanation of the 

methodology of the scenery analysis. This section attempts to simplify the SMS process and 

terminology to provide clarity to the reader. 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Issue 4A – Scenery - Chapter 3  181

Scenery analysis:

• Evaluates whether the standards and guidelines for scenery established by the Forest Plan for

each alternative are met. 

• Quantifies the effects on scenery—not only the direct and indirect effects of this project, but also

the cumulative effects—considering this project in the context of other projects happening, or

recently implemented, in the area.

• Considers recommendations for any mitigation, enhancement, and monitoring deemed necessary.

Incomplete and Unavailable Information

During the preparation of the EIS, the VPR associated with the Harriet Hunt to Shelter Cove 

Connection Road was defined along the existing Forest Service road (road 8300000), since the exact 

route connecting the existing road to the Ketchikan road system was unknown at the time. This VPR 

was used to create GIS layers and data for the scenery analysis. The proposed action was later 

modified to include the State of Alaska right-of-way (ROW) on NFS lands (see Chapter 2, Items 

Common to All Action Alternatives). The exact alignment of the road within this ROW is unknown, 

but is anticipated to align with NFS Road 8300280, which is proposed for construction in varying 

lengths under the action alternatives (see Action Alternative descriptions). This short segment of the 

route was not used as a VPR in the analysis, as the effects are not expected to significantly change 

from the original. 

Analysis Area

The analysis area for scenery is the project area. In some factors, particularly the cumulative effects 

analysis, the project area is broken down into smaller areas, in which case VCUs are used. VCUs are 

used to represent a viewshed because they have similar spatial boundaries.

Affected Environment

Elements that comprise the existing condition of the scenery resource in the project area include: 

landscape character, scenic attractiveness, land use designations (LUDs), visual priority routes and 

use areas (VPRs), and existing scenic integrity (ESI). The desired condition is represented by the 

scenic integrity objectives (SIO), and developed using visibility and distance zones (DZ). Visual 

absorption capacity (VAC) helps determine what activities can take place while meeting the SIOs. All 

together these comprise the affected environment.

The most critical elements are covered in this section of Chapter 3: scenic integrity, VPR, ESI, and 

SIO. Please refer to the Scenery Resource Report for an in-depth discussion of all the affected 

environment elements. 

Scenic Integrity

Scenic integrity is a term used to describe the visual condition of the landscape while avoiding the use 

of the value judgments associated with scenery. Different people have different opinions of what is 

good, ugly, pretty, boring, or worthwhile when discussing scenery, but they should be able to agree on 

the level of integrity, or “intactness” of the landscape they are viewing. Scenic integrity is used to 

describe existing conditions, future conditions, or management goals, all referring to how “whole” the 

view looks or will look from the viewer’s perspective. The viewer is considered to be a “casual 

observer,” someone like a tourist, or a boat passenger, that is not studying the view but is observing it, 

possibly while doing something else. It is not someone with detailed knowledge of the harvest 

activities of an area or of the scenery analysis process.
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182  Chapter 3 – Issue 4A – Scenery Saddle Lakes Timber Sale Final EIS

Table 67. Scenic Integrity Definitions

Scenic Integrity Level Definition

Very High Landscapes that are intact, with only minute, if any, deviations.

High Landscapes that appear intact. Deviations are not readily evident to the 

casual observer.

Moderate Landscapes that appear slightly altered. Deviations are noticeable to 

the casual observer, but do not dominate the landscape.

Low

Landscapes that appear moderately altered. Deviations can begin to 

dominate a scene, but must blend with the surrounding landscape, as 

viewed by the casual observer.

Very Low Landscapes that appear heavily altered. Deviations clearly dominate, 

but must blend to some degree.

Unacceptably Low

Landscapes that appear extremely altered. Deviations are extremely 

dominant and borrow little, if any, form, line, color, texture, pattern or 

scale from the landscape character.

Photographic examples of the levels of scenic integrity can be found in the Forest Plan (USDA Forest Service 2008b, pages 4-

61 to 4-63). 

Scenery analysis uses scenic integrity in three ways. First, is to describe the existing condition of a 

landscape, before a project is implemented. Second is to describe the future condition of the 

landscape after a project has been implemented. Third, the SIOs, is a target condition with which a 

project should comply. The SIOs are the most important factor of scenery analysis on the Tongass 

National Forest. The Forest Plan defines SIOs for all of the Tongass, and projects are designed to 

meet or exceed the SIOs, in order to be in compliance with the Forest Plan. 

Scenic Integrity Objectives (SIO)

Scenery integrity objective (SIO) is the term used to describe the desired visual condition of the 

landscape, and is applied to any activity that has the potential to affect the scenic character of the 

landscape. The SIO is also used to describe the degree of acceptable alteration of the characteristic 

landscape, and each LUD is assigned SIOs as seen from visual priority travel routes and use areas 

(VPRs). 

For this project, as seen in Figure 10, the areas of moderate SIO are found along the Connection 

Road, around Saddle Lakes, and along Carroll Inlet, and are areas within Modified Landscape LUD 

that are close to VPRs. The units of measure look more closely at areas of moderate SIO as it is more 

difficult to have timber harvest in these areas while keeping the visible activity subordinate to the 

landscape. The majority of the project area is very low SIO (Table 68), and managed as landscapes 

that may appear heavily altered.

Existing Scenic Integrity (ESI)

Using the levels of scenic integrity previously discussed, the land is mapped according to the existing 

condition, and this mapping is called existing scenic integrity (ESI). ESI is defined as the current state 

of the landscape, considering previous human alterations (USDA Forest Service 1995, p. I-2). 

ESI changes over time, as some alterations may revegetate and begin to blend in with the surrounding 

landscape or as new projects that impact scenic integrity are implemented. It is important to compare 

the ESI of the project area to the adopted SIO of the LUD to determine if the existing condition 

conflicts with management goals (SIO), and how much additional disturbance is allowed. 
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Saddle Lakes Timber Sale Final EIS Issue 4A – Scenery - Chapter 3  183

Table 68. Existing scenic integrity (ESI) and scenery integrity objective (SIO) types in the Saddle Lakes 

project area

Scenic Integrity Level ESI 1/

(Percent of Project Area)

SIO2/

(Percent of Project Area)

Very High 45% 0%

High 2% 9%

Moderate 7% 13%

Low 36% 16%

Very Low 5% 53%

1/ Source: USFS Tongass National Forest GIS, existing scenic integrity layer (ESI, updated 2014).

2/ Source: USFS Tongass National Forest GIS.

When comparing ESI to SIO in the project area, it is evident that almost half of the project area is 

high or very high ESI, which means almost half of the project area appears intact. With only 9 percent

of the project area managed to high SIO, it is expected that activities will occur to reduce the scenic 

integrity of what is currently high or very high ESI. Two-thirds of the project area is managed for low 

or very low SIO, and able to accommodate more extensive visual changes such as clearcuts. Only 13

percent of the project area is managed for moderate SIO. These areas are the focus of several of the 

units of measure for this issue, because of the difficulty in creating timber harvest activities that 

remain visually subordinate to the landscape. 

Visual Priority Routes and Use Areas (VPR)

The Forest Plan identifies visual priority routes and use areas (VPRs) to recognize routes and areas 

from which scenery will be emphasized. VPRs include towns, campsites, trails, roads, waterways, and 

dispersed recreation areas, and are listed in Appendix F of the Forest Plan. VPRs indicate areas from 

where people are likely to be viewing the landscape, and most often have a small footprint. A road

may be identified as a VPR, but the trees alongside the road are not—but they are visible from the 

VPR. What can be seen from a VPR is extremely important, because that helps define the SIO. What 

is visible, and how far away it is from the viewer, as well as what LUD the landscape being looked at 

is in, determines the SIO for that area. 

The VPRs in and adjacent to the project area are shown in Figure 9. The Forest Plan (page 4-57) lists 

the SIOs adopted for each LUD. 

Table 69. Visual Priority Routes (VPRs) in and adjacent to the Saddle Lakes project area

VPR VPR Type

George Inlet Salt Water Use Areas

Carroll Inlet Salt Water Use Areas

Harriet Hunt to Shelter Cove Connection Road Routes not constructed or NEPA Cleared: Planned 

or Opportunities

Saddle Lakes Recreation Area Routes not constructed or NEPA Cleared: Planned 

or Opportunities

Shelter Cove Boat Ramp Routes not constructed or NEPA Cleared: Planned 

or Opportunities

Source: USFS Tongass National Forest GIS; USDA Forest Service 2008b, Appendix F, pp. F-22 –F-24.
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184  Chapter 3 – Issue 4A – Scenery Saddle Lakes Timber Sale Final EIS

Three of the VPRs used in this analysis are considered “Routes not constructed or NEPA Cleared: 

Planned or Opportunities.” The Ketchikan-Misty Fiords Ranger District is the only district with VPRs 

that fall into this category, with five VPRs total classified as such. This project includes three of those 

five. 

For purposes for this analysis, these “Planned” VPRs were treated as though they were existing and 

given equal weight as VPRs. As landscape features, they do already exist. It is assumed that the 

Harriet Hunt to Shelter Cove Connection Road, Saddle Lakes, and Shelter Cove boat ramp will see 

increased use if the Ketchikan to Shelter Cove Road is constructed, connecting these areas to the 

Ketchikan road system (see Recreation Cumulative Effects section). No additional construction 

would be necessary for them to accept increased use or to change from “Planned” VPRs to existing 

VPRs.
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Figure 9. Saddle Lakes Project Area visual priority routes (VPRs) 
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Saddle Lakes Timber Sale Final EIS Issue 4A – Scenery - Chapter 3  187

Figure 10. Scenic integrity objective (SIO) current condition for the Saddle Lakes project area
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188  Chapter 3 – Issue 4A – Scenery Saddle Lakes Timber Sale Final EIS
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Saddle Lakes Timber Sale Final EIS Issue 4A – Scenery - Chapter 3  189

Environmental Consequences

Direct and Indirect Effects

The following table presents a summary of actions associated with the alternatives, including the 

number of VPR designations proposed to be removed. A Forest Plan amendment would be needed 

for the removal of VPR designations.

Table 70. Saddle Lakes Timber Sale activities

Alt.

Even-aged 

Silvicultural 

Methods1/

(acres)

Uneven-aged 

Silvicultural 

Methods2/

(acres)

Helicopter Harvest

(% of total harvest)

NFS Road 

Construction

(miles)

VPRs Removed

(number of VPRs)

1 0 0 0% 0 0 

2 1,055 1,100 50% 10.2 0 

3 816 196 19% 6.7 0 

4 2,112 312 21% 19.6 4 

5 2,594 281 25% 20.6 5 

6 1,654 484 22% 16.3 3 

Source: USFS Tongass National Forest GIS

1/ Includes clearcut method.

2/ Includes only uneven-aged silvicultural methods; 33% basal removal).

As stated previously, the analysis area for direct and indirect effects is the Saddle Lakes project 

area. The effects of VPR removal were also examined within the “Greater George and Carroll Inlet 

Area” which includes the viewsheds as seen from the length of those VPRs (see Scenery Resource 

Report for more detail). Existing harvest areas less than 30 years old are considered to still be 

visible (i.e., existing condition) and are used in analysis of direct effects. Harvest areas older than 

30 years are considered to be visually recovered. 

Clearcut Harvest vs. Partial Harvest (33 Percent Basal Area Removal, UA33)

The effects associated with the two silvicultural prescriptions in this project are quite different. In a 

very general sense, the clearcut prescription creates visible impacts while the UA33 prescription does 

not. Clearcuts can be designed to blend well with the landscape, and therefore may not be very 

noticeable, while impacts from the UA33 prescription may be visible at a close distance. For this 

analysis, we assume that units of UA33 would not be noticeable to the casual observer, and views of 

the project area exclusively consisting of units of UA33 would appear visually intact. 

Effects Common to All Action Alternatives

State of Alaska Right-of-way on NFS Lands

The proposed State of Alaska Right-of-way is located within Old-growth Habitat and Modified 

Landscape LUDs. The SIOs along the proposed alignment are high in Old-growth Habitat LUD, and 

moderate and very low in the Modified Landscape LUD. The Ketchikan to Shelter Cove Road ROW 

is at low elevation, and is not on a very steep slope, therefore would have minimal visual impact and 

meet the SIOs of the area.
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190  Chapter 3 – Issue 4A – Scenery Saddle Lakes Timber Sale Final EIS

Fish Passage Barrier Modification and Shelter Cove LTF Reconstruction 

No effects are anticipated to the scenery resource as a result of implementing the fish passage barrier 

modification and the Shelter Cove LTF reconstruction. 

Effects Comparison for the Action Alternatives (Alternatives 2 to 6)

The following tables are used to display effects for the action alternatives (Alternatives 2 to 6), and 

referred to in the alternative effects analyses that follow. Table 71 summarizes the silvicultural 

prescription acres in SIO by alternative. Table 72 summarizes road construction by SIO for each 

alternative. Table 73 quantifies the effects to SIO distribution of removing VPRs in Alternatives 4, 5 

and 6. Table 74 summarizes the harvest within the Saddle Lakes Recreation Area viewshed by 

prescription for each alternative.

Table 71. Acres of harvest by existing scenic integrity objective (SIO) for the Saddle Lakes Timber Sale 

Project

Scenic 

Integrity 

Objective

(SIO) 

Alternative 2 Alternative 3 Alternative 4 Alternative 5 Alternative 6

CC UA33 CC UA33 CC UA33 CC UA33 CC UA33

High 0 0 0 0 0 0 173 4 0 0 

Moderate 129 589 171 27 774 148 921 61 530 185

Low 255 187 134 35 427 78 499 109 389 86

Very Low 671 375 512 134 912 85 1001 107 735 213

Totals 1055 1151 817 196 2113 311 2594 281 1654 484

Source: USFS Tongass National Forest GIS. Note: Numbers may not add due to rounding.

Table 72. Miles of proposed roads by alternative and scenic integrity objective (SIO) for the Saddle Lakes 

Timber Sale Project

Scenic 

Integrity 

Objective

(SIO) 

Alt. 2 Alt. 3 Alt. 4 Alt. 5 Alt. 6

Existing 

SIO 

Existing 

SIO 

Existing 

SIO 

Revised 

SIO 

Existing 

SIO 

Revised 

SIO 

Existing 

SIO 

Revised 

SIO 

High 0 0.1 0.2 0.2 0.8 0 0.2 0.2

Moderate 3.8 3.5 11.9 0 12.2 0 9.7 3.7

Low 4.2 2.0 6.8 6.6 6.8 6 5.1 2.9

Very Low 10.3 6.6 11.1 23.2 12.6 26.4 10.6 18.7

Total 18.2 12.1 30 32.4 25.5

Source: USFS Tongass National Forest GIS. Note: Numbers may not add due to rounding. Revised SIO is after Forest Plan 

amendments are completed, removing VPRs for that Alternative.

Table 73. Effects of VPR removal (Alternatives 4, 5 and 6) for the Saddle Lakes Timber Sale Project

Alternative 

Acres of Harvest 

in Areas that 

Decrease in SIO

Acres of Harvest 

in Areas with no 

change in SIO

Project Area 

Acres that 

decrease in SIO

Greater 

George/Carroll 

Inlet Area Acres 

that decrease in 

SIO 

4 1,285 1,139 8,270 13,920

5 1,642 1,233 8,750 14,930

6 743 1,395 6,810 10,900

Source: USFS Tongass National Forest GIS.
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Saddle Lakes Timber Sale Final EIS Issue 4A – Scenery - Chapter 3  191

Table 74. Acres of harvest within Saddle Lakes Recreation Area viewshed1/, by prescription

Prescription Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

CC 6 0 462 526 215

UA33 400 32 109 62 132

Total 406 32 571 588 347

Source: USFS Tongass National Forest GIS.

1/ Viewshed includes the following units, including any variations of them (i.e., -1, -2): 18, 19, 21, 27, 28, 29, 30, 31, 40, 46, 

47, 48, 50, 51, 52, 75, 80, 114, 115, 116, 118, 122, 123, 125, 126, 134, 138, 147, 154, 156, 157, 158.

The following section describes the direct and indirect effects to scenery resources by alternative. 

Alternative 1

Alternative 1 would have no direct effects on the scenery resource because no timber harvest or road 

construction would occur. There would be a continued increase of the existing scenic integrity (ESI) 

(e.g., from very low to low, or low to moderate) because there would be no new harvest. Regrowth in 

previously harvested areas would lessen the visual disturbances of these older cuts and they would 

slowly become less noticeable.

Alternative 2

Alternative 2 is the proposed action, and was designed to allow the maximum timber harvest that 

would still meet the Forest Plan Standards and Guidelines for scenery, as well as all other resources.

Originally, many, if not all, partial harvest units were a 50 percent basal removal, which would meet 

the Moderate SIO requirements. Later in the process, the partial harvest units were changed from 50

percent basal removal to 33 percent basal removal for silvicultural reasons. Currently, from a scenery 

perspective, Alternative 2 is the best example of an alternative that illustrates the amount of harvest 

and road construction that can be implemented while meeting Forest Plan Standards and Guidelines.

It should be noted that units were removed from the alternative, or prescribed as partial harvest, for 

reasons other than scenery, including wildlife, soils, and economics.

Alternative 2 meets the Forest Plan Standards and Guidelines for scenery. This alternative would 

harvest 718 acres (33 percent of total project acres) within areas of moderate SIO, of which 129 acres 

would be clearcut. Alternative 2 would require the construction of 3.8 miles of road within areas of 

moderate SIO). No changes of SIO acreage inside or outside of the project area would occur, as no 

VPRs are proposed to be removed. Forest visitors in the VPR areas of the Modified Landscape LUD 

would see a landscape where harvest activities are allowed, but development would be subordinate to 

the existing landscape character. In other words, as the viewer looks at the scenery, it may not be 

immediately obvious that timber harvest has occurred within their view. Within the Saddle Lakes 

Recreation Area VPR viewshed, a total of 406 acres of timber would be harvested with almost all of 

that being partial harvest.

Alternative 2 ranks second highest among the action alternatives in terms of having the least effects to 

the scenery resource.

Alternative 3

Alternative 3 meets the Forest Plan Standards and Guidelines for scenery. This alternative would 

harvest 198 acres (20 percent of total project acres) within areas of moderate SIO, of which 171 acres 

are clearcut. This alternative would construct 3.5 miles of road within areas of Moderate SIO. No 

changes of SIO acreage inside or outside of the project area occur, as no VPRs are proposed to be 

removed. Forest visitors in the VPR areas of Modified Landscape LUD would see the landscape 
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192  Chapter 3 – Issue 4A – Scenery Saddle Lakes Timber Sale Final EIS

where the harvest activities are allowed, but development would be subordinate to the existing 

landscape character. In other words, as the viewer looks at the scenery, it may not be immediately 

obvious that timber harvest has occurred within their view. Within the Saddle Lakes Recreation Area 

VPR viewshed, there would be less harvest occurring than in Alternative 2, with only 32 acres being 

harvested in that area, all of which is partial harvest.

Alternative 3 has the least effects to the scenery resource of all the action alternatives. 

Common Issues for Alternatives 4, 5, and 6

Removal of VPR Designations 

There are two main factors that make up SIO: LUD and VPR. Therefore, changing either factor can

result in a change to SIO. A VPR can be modified, changing the aspect or distance from which the 

land is viewed for analysis purposes or the LUD can be changed. This project proposes to remove 

VPR designations in order to change the SIOs and would result in the lands being managed using 

scenery integrity objectives for non-priority/seldom seen routes and use areas (Forest Plan p. 4-57). 

The harvest proposed in Alternatives 4, 5, and 6 does not meet Forest Plan Standards and Guidelines 

for scenery without removing VPR designations. Each alternative proposes to remove a different 

number of VPR designations, but there is some commonality between all these removals.

Alternatives 4, 5, and 6 propose harvest that would result in more visual impact and change than the 

landscape could absorb while still meeting the current management objectives (SIO). Under these 

alternatives, VPR designations would be removed, resulting in changes in SIOs by removing the areas 

of moderate SIO and changing some areas from low to very low. Changes are on all lands visible to 

the VPRs, are in place from now onward, and apply to all future projects in areas affected by the 

proposed SIO changes. Not all areas would change SIO, but those areas that do would allow more 

disruption to scenic integrity from now into the future. More detail on this action is found in the 

Scenery Resource Report.

In cases where the use of an area has declined over time (cabin removal or road closure), removing a 

VPR designation is a simple change. However, there is no data or anecdotal evidence to show the use 

of any of these VPRs has decreased since the 2008 Forest Plan. In this project, removing VPR

designations is to increase the amount of timber harvest that can occur at this time. It is expected that 

if the Ketchikan to Shelter Cove Road is built, the Saddle Lakes Recreation Area, Shelter Cove boat 

ramp and other areas near the project area may see an increase in use. 

Possible Effects caused by VPR designation removal 

George and Carroll Inlets are VPRs that have a viewshed much larger than the Saddle Lakes project 

area. Removing them would affect a large area, but much of the land visible from the inlets has 

existing evidence of timber harvest. Some lands are Timber Production LUD, in which the SIOs 

enable a larger impact from projects, and some are private and State of Alaska lands, which do not 

fall under the Forest Plan Standards and Guidelines. Removing the VPR designations and having the 

Saddle Lakes project go forward with larger levels of harvest, may have a more visible impact than 

Alternative 2 and Alternative 3, but not drastically change the visual experience of either George or 

Carroll Inlet. They both show evidence of significant timber harvest, and would continue to do so into 

the future. This VPR designation is removed in Alternatives 4, 5, and 6. 

The Ketchikan to Shelter Cove Road VPR is similar to the George and Carroll Inlet VPR, as the road 

passes areas where evidence of timber harvest is already noticeable. Removing the VPR would mean 

travelers along the road would see landscapes dominated by harvest activities, rather than seeing 

landscapes where timber harvest impacts are subordinate to the overall view, but not change it from 
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Saddle Lakes Timber Sale Final EIS Issue 4A – Scenery - Chapter 3  193

an entirely untouched area to a heavily altered one. This VPR designation is removed in Alternatives 

4, 5, and 6. 

The Saddle Lakes Recreation Area VPR viewshed is currently all high and very high ESI meaning 

that most of the land visible from the lakes has not been altered at this time. It is currently managed 

for moderate SIO, where the landscape can appear slightly altered, but any evidence of activity (such 

as timber harvest) should not dominate the view. Removing this VPR designation would change this 

area to very low SIO, and after project completion, would result in a landscape that appears heavily 

altered. This VPR designation is removed in Alternatives 4 and 5.

The Shelter Cove boat ramp VPR designation is not removed in several alternatives because it was 

determined that no units are visible from this VPR, and removing this designation would not affect 

the potential harvest. This VPR designation is removed in Alternative 5. 

Alternative 4

The harvest proposed in Alternative 4 does not meet Forest Plan Scenery Standards and Guidelines 

without a Forest Plan amendment to remove four VPRs: George Inlet, Carroll Inlet, Saddle Lakes 

Recreation Area, and the Harriet Hunt to Shelter Cove Connection Road. Under this alternative, 922 

acres of harvest (38 percent of total project acres) occurs in areas currently categorized as moderate 

SIO, 774 of which are clearcut. This is 204 acres more than Alt. 2, with a much different balance of 

clearcut and partial harvest. Within the Saddle Lakes Recreation Area viewshed, 571 acres would be 

harvested, 81 percent of which are clearcut. This is 165 acres more than Alternative 2, though again 

this alternative has much more clearcut than partial-cut. This alternative would construct 0.2 mile of 

road in existing areas of high SIO, and 11.9 miles of road in existing areas of moderate SIO. The 

removal of the VPRs would change the SIOs of 1,285 acres of harvest in the project area, and 8,270 

project area acres, all to a lower SIO. After the Forest Plan amendment is completed, there would no 

longer be any areas of moderate SIO in the project area, and no harvest would occur in areas of 

moderate SIO. There would still be 0.2 mile of road constructed in areas of high SIO, but none in 

areas of moderate SIO. As an indirect effect of the VPR removal, 13,900 acres in the George and 

Carroll Inlet viewsheds will change SIO. The changes to the SIO would enable more activity that alter 

scenery to take place, and remain for future projects in the George and Carroll Inlet areas, including 

but not limited to timber harvest, utility corridor expansions, and recreation developments. Alternative 

4 has very similar effects to scenery as Alternative 5 and more detail can be found in Alternative 5.

Alternative 4 ranks the second highest among the action alternatives in terms of having the most 

effects to the scenery resource.

Alternative 5

The harvest proposed in Alternative 5 does not meet Forest Plan Scenery Standards and Guidelines

without a Forest Plan amendment to remove five VPRs: George Inlet, Carroll Inlet, Saddle Lakes 

Recreation Area, the Harriet Hunt to Shelter Cove Connection Road, and the Shelter Cove Boat 

Ramp. Alternative 5 harvests 669 acres more than Alternative 2, or 30 percent more acres than 

Alternative 2. The difference in unit prescriptions, however, means that Alternative 5 harvests 

1,539 more acres of clearcut than Alternative 2 (145 percent more than Alternative 2). 

Under this alternative, 982 acres of harvest (34 percent of project area acres) occur in areas currently 

categorized as moderate SIO, 921 of which are clearcut. This is 264 acres more than Alternative 2, 

with a much different balance of clearcut and partial harvest. Alternative 5 is the only alternative that

harvests from areas currently categorized as high SIO, with 173 acres of clearcut and 4 acres of 

UA33. Within the Saddle Lakes Recreation Area viewshed, 588 acres are harvested, 89 percent of

which are clearcut. This is 182 acres more than Alternative 2, though again Alternative 5 has much 
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194  Chapter 3 – Issue 4A – Scenery Saddle Lakes Timber Sale Final EIS

more clearcut than partial-cut. This alternative would construct 0.8 miles of road in existing areas of 

high SIO, and 12.2 miles of road in areas currently categorized as moderate SIO, compared to the 3.8 

miles constructed in moderate SIO in Alternative 2. To enable this alternative to comply with the 

Forest Plan scenery objectives, it is proposed to remove five VPRs. The removal of VPRs would 

change the SIOs of 1,642 acres of harvest in the project area, and 8,750 project area acres, all to a 

lower SIO (Table 73). After the Forest Plan amendment is completed, there would no longer be any 

areas of moderate SIO in the project area. After these changes, no harvest would occur in areas of 

moderate SIO, nor would there be any road construction in areas of high or moderate SIO. This 

alternative also has a Forest Plan amendment to change the Old-growth Habitat LUD, with a net 

decrease in acreage of just over 400 acres. This reduces the High SIO acreage by the same amount. 

These changes are a part of the 14,900 acres of SIO change that would occur in the George and 

Carroll Inlet watersheds as an indirect effect of this project. The changes to SIO would enable more 

activity that alters the scenery to take place, and remain for any future projects in the George and 

Carroll Inlet areas, including but not limited to timber harvest, utility corridor expansions and 

recreation developments. 

The main difference between Alternative 5 and Alternative 4 is the result of the Old-growth Habitat 

LUD change and the slightly increased harvest. They would have very similar visual effects. The 

largest impacts would be seen from Saddle Lakes (i.e., the “Saddle Lakes Recreation Area”), which 

are currently very high and high ESI. Forest visitors in these areas would be seeing landscapes where 

the harvest activities are allowed to dominate the scenery. To help visualize the changes, the 

following figures were developed, and show both the existing view and the location of proposed units 

on the same view. The white overlay shows the unit locations but is not intended to be a photorealistic 

depiction of the future view. The map in Figure 11 indicates the location at which the photo was 

taken, the direction of the view, and the prescription of the units. Figure 12 shows the existing view at 

the eastern lake within the Saddle Lake Recreation Area, with Figure 13 showing the proposed units 

superimposed on the existing view. All units seen from this view are planned as clearcuts. 

Impacts from the VPR removal will also be noticeable along the Connection Road and Carroll Inlet, 

where Forest visitors may view landscapes where harvest activities are allowed to dominate the 

scenery. The visual impact would be less than at the Saddle Lakes Recreation Area because the 

Connection Road and Carroll Inlet already have existing clearcuts, many of which are already 

noticeable to the casual observer, while the Saddle Lakes Recreation Area viewshed is currently 

visually intact. 

Alternative 5 has the most effects to the scenery resource of all the action alternatives.
Affected Environment and Environmental Consequences 3

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Figure 11. Photo point 101 location map, Saddle Lakes Recreation Area
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196  Chapter 3 – Issue 4A – Scenery Saddle Lakes Timber Sale Final EIS

Figure 12. (Photo point 101) existing view looking from North Saddle Lake (Saddle Lakes Recreation 

Area), southeast to northwest

Figure 13. (Photo point 101), with proposed Alternative 5 units shown as an overlay over Figure 12 above
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Saddle Lakes Timber Sale Final EIS Issue 4A – Scenery - Chapter 3  197

Alternative 6

The harvest proposed in Alternative 6 does not meet Forest Plan Scenery Standards and Guidelines 

without a Forest Plan amendment to remove three VPRs: George Inlet, Carroll Inlet, and the Harriet 

Hunt to Shelter Cove Connection Road. Alternative 6 would harvest 715 acres within existing areas 

of moderate SIO, of which 191 acres are clearcut. This is 3 acres total less than Alternative 2, but has 

62 acres more of clearcut than Alternative 2. This alternative would also construct 0.2 mile of road 

within existing areas of high SIO, and 9.68 miles of road within existing areas of moderate SIO. 

Within the Saddle Lakes Recreation Area viewshed, 347 acres of harvest would occur, with 62 

percent of it clearcut. This is 59 acres less than Alternative 2, but again has a larger number of acres 

of clearcut than that alternative. After the Forest Plan amendment is completed, 350 acres of harvest 

would occur in areas of moderate SIO. About 0.2 mile of road would still be constructed within areas 

of high SIO, while 3.7 miles of road would be constructed in areas of moderate SIO. The removal of 

the three VPRs would change the SIOs of 743 acres of harvest in the project area, and 6,810 project 

area acres, all to a lower SIO. These changes are a part of the 10,900 acres of SIO change that would 

occur in the George and Carroll Inlet viewsheds as an indirect effect of this project. The changes to 

SIO would enable more activity that alters the scenery to take place, and remain in effect for future 

projects in the George and Carroll Inlet areas, including but not limited to timber harvest, utility 

corridor expansions, and recreation developments. 

The largest impacts of this project may be seen in Carroll Inlet and along the Ketchikan to Shelter 

Cove connection road. Forest visitors in these areas could landscape where the harvest activities are 

allowed to dominate the scenery. This alternative does, however, keep the Saddle Lakes Recreation 

Area VPR and have significantly reduced harvest in that viewshed compared to Alternatives 4 and 5. 

Much of the recreation area viewshed would remain managed as moderate SIO, appearing relatively 

unaltered, preserving the potential recreation value. 

Alternative 6 ranks third highest among the action alternatives in terms of having the least effects to 

the scenery resource.

Cumulative Effects

Appendix B includes the interrelated projects (i.e., past, present and reasonably foreseeable future 

actions) that have been considered in the scenery cumulative effects analysis.

Cumulative effects for scenery resources in all affected viewsheds are estimated using quantifiable 

measures as indicators for actual effects. The cumulative effects scenery analysis area is best 

represented as a viewshed, and using VCUs to represent viewsheds, includes VCUs 7460, 7530 and 

7470. All harvest areas 30 years old or younger are included as past disturbance, and are assumed to 

have been harvested using even-aged silvicultural methods (i.e., clearcutting). The Swan Lake power 

line corridor clearing is also included. Young-growth thinning (e.g., precommercial thinning) is not 

included because it would likely have a minimal effect on scenery.

Percent allowable visual disturbance represents an index of cumulative effects and is an estimate of 

the possible level of disturbance as modeled by the Forest Plan FEIS (USDA Forest Service 2008c, 

Appendix B, p. B-23). Visual disturbance outcomes vary by the scenic objectives for each of the 

LUDs available for timber harvest. Using this model it was assumed for viewsheds within the Timber 

Production LUD, that up to 50 percent of suitable lands within a viewshed may be under development 

(i.e., visually disturbed by harvest) at one time. For viewsheds within the Modified Landscape LUD, 

the percent allowable visual disturbance is 25 percent. Visual disturbance is calculated by adding the 

past, present, and reasonably foreseeable even-aged harvest acres and dividing by the acres of suitable 
3 Affected Environment and Environmental Consequences

198  Chapter 3 – Issue 4A – Scenery Saddle Lakes Timber Sale Final EIS

land within a viewshed or VCU on NFS lands. It is calculated from a “birds-eye” view and not based 

on the view from specific viewpoints.

Table 75 represents a comparison of the expected cumulative visual disturbance by alternative. The 

table cell boxes highlighted in bold with a heavy border show areas that exceed the recommended 

limit of cumulative visual disturbance.

Cumulative Effects Common to all Action Alternatives

Cumulative effects to scenery consider the incremental impact of an action when added to past, 

present, and reasonably foreseeable future actions on NFS lands, as well as activities on adjacent nonNational Forest System lands. Previous development in the project area has modified the scenic 

environment of many areas from a natural-appearing condition to a condition where some landscapes 

appear heavily altered. The effects of past timber harvest would continue to lessen over time, 

becoming more natural appearing during the reasonably foreseeable future, but consideration must be 

given to the potential incremental effects of other ongoing and future actions. 

Alternative 1

No timber harvest or road construction is proposed under Alternative 1 that would result in direct 

effects. Therefore, no cumulative effects are anticipated. The scenery effects of past timber harvest 

would continue to lessen over time, particularly in VCU 7530, and the project area would become 

more natural appearing during the reasonably foreseeable future.

Alternative 2

Alternative 2 is above the 25 percent disturbance reference point in VCU 7530 at 26 percent, in the 

Modified Landscape LUD. Disturbance within all other VCUs are within the modeled allowances for 

all LUDs.

Alternative 3

The total disturbance in all VCUs, for all LUDs, is within the modeled allowances for this alternative.

Alternative 4

Alternative 4 would exceed the 25 percent modeled allowance for total disturbance in the Modified 

Landscape LUD in all VCUs, with 35 percent total disturbance in VCU 7460, 29 percent in VCU 

7470, and 28 percent in VCU 7530. All VCUs are under the 50 percent mark for Timber Production 

LUD areas.

Alternative 5

Alternative 5 exceeds the 25 percent modeled allowance for total disturbance in the Modified 

Landscape LUD in VCUs 7460 and 7470 by 43 percent and 37 percent, respectively. The remaining 

VCU (7530) slightly exceeds the 25 percent mark, at 29 percent. All VCUs are under the 50 percent 

mark for Timber Production LUD areas. 

Alternative 6

Alternative 6 exceeds the 25 percent modeled allowance for total disturbance in the Modified 

Landscape LUD in two VCUs, 26 percent in VCU 7470 and 29 percent in VCU 7530. All VCUs are 

under the 50 percent mark for Timber Production LUD areas. 

Conclusion

Alternative 3 would rank highest as having the least effects to the scenery resource of the action 

alternatives, followed by Alternative 2 as the second highest, and then Alternative 6 in the middle. 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Issue 4A – Scenery - Chapter 3  199

Alternative 5 ranks highest as having the most effects to the scenery resource of the action 

alternatives, and Alternative 4 ranks second highest as having the most effects. 

Alternatives 2 and 3 meet the Forest Plan Scenery Standards and Guidelines. Areas of the project 

likely to be viewed closely by the public may appear slightly altered, but the impacts of the project 

would be subordinate to the view blending with the surrounding landscape.

Alternatives 4, 5, and 6 do not meet the Forest Plan scenery Standards and Guidelines unless a Forest 

Plan amendment is done to remove the VPR designations. With the implementation of the proposed 

amendments, these alternatives would meet the Forest Plan. These three alternatives do not meet the 

goal of the Modified Landscape LUD to recognize scenic value in the project area, and all exceed the 

recommended allowances for total disturbance in Modified Landscape LUDs.

Design Features and Mitigation Measures

For the Saddle Lakes project, mitigation to reduce scenery effects has been incorporated into harvest 

unit design and harvest unit prescriptions. Units with moderate SIOs were given priority for 

mitigation. Primary measures included: 1) deferring harvest of a setting or group of settings; 2) 

modifying unit size and/or shape; and 3) changing prescription to partial harvest with 33 percent basal 

removal. Some areas of low and very low SIO were mitigated using the same measures in order to 

keep the area from falling below the required SIO. 
3 Affected Environment and Environmental Consequences

200  Chapter 3 – Issue 4A – Scenery Saddle Lakes Timber Sale Final EIS

Table 75. Expected cumulative visual disturbance by alternative in the Saddle Lakes project area

VCU LUD

Total 

Acres in 

VCU w/in 

Project 

Area

Suitable 

Land 

(Acres)

Suitable 

Land (%)

Alternative 1

Total 

Disturbance

(% of Suitable 

Land)

Alternative 2

Total 

Disturbance

(% of Suitable 

Land)

Alternative 3

Total 

Disturbance

(% of Suitable 

Land)

Alternative 4

Total 

Disturbance

(% of Suitable 

Land)

Alternative 5

Total 

Disturbance

(% of Suitable 

Land)

Alternative 6

Total 

Disturbance

(% of Suitable 

Land)

7460

ML 6,108 2,424 40% 4% 11% 10% 35% 43% 23%

TM 4,689 1,874 40% 0% 9% 5% 10% 12% 7%

7470

ML 5,158 2,627 51% 5% 17% 15% 29% 37% 26%

TM 7,279 2,820 39% 4% 9% 9% 12% 13% 9%

7530

ML 4,327 1,418 33% 18% 26% 21% 28% 29% 29%

TM 2,483 1,242 50% 25% 41% 37% 41% 41% 41%

Project 

Area 

ML 16,028 6,738 42% 7% 16% 14% 30% 36% 26%

TM 14,452 5,935 41% 7% 16% 14% 17% 18% 15%

Source: USFS Tongass National Forest GIS;

Note: ML = Modified Landscape LUD, TM = Timber Production LUD.
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Issue 4B – Recreational Opportunities - Chapter 3  201

Issue 4B. Recreational Opportunities

Changes to recreational opportunities may occur because of road construction and timber harvest in 

the Saddle Lakes project area.

Units of Measure:

The following units of measure were used to evaluate effects of the Saddle Lakes Timber Sale to 

Recreation and compare alternatives: 

• Changes to Recreation Opportunity Spectrum (ROS) system classification (acres).

In addition to these units of measure, a qualitative discussion of the project’s effects on the 

recreational opportunities and experience in the project area is included. 

Methodology

Acres of ROS and road miles used in this analysis were calculated using GIS digital data. However, 

due to the nature of recreation, this analysis relies heavily on a qualitative discussion of recreation 

activities and how they fit in the “big picture” for residents and visitors. Guided use numbers are 

reported annually and entered in the Tongass Outfitter / Guide Database which was queried for the 

numbers reported in this analysis. 

Roads shown as mixed use or as open to vehicles less than 50 inches wide (OHV Trails) on the 

KMRD Motor Vehicle Use Map (MVUM) were considered “open” for this analysis. It is important to 

note that this definition may differ from other resource analyses in this EIS. Closed roads may be 

used by recreationists on foot, bicycle, or other non-motorized means of travel. “Closed” roads for the 

recreation analysis are considered to be all roads not shown on the MVUM, regardless of whether 

they are NFS roads not open to the public (objective maintenance level 1- OBML 1) or temporary 

roads that are or are scheduled to be decommissioned. 

The scenery analysis is frequently referenced because of the close connection between the scenery of 

the areas used for recreation. Scenic beauty is an important issue affecting socially acceptable forestry 

and timber harvest decisions on the Tongass National Forest, and it also has a direct relationship with 

outdoor recreation opportunities. Most recreation activities take place in, and are dependent on, 

settings primarily undeveloped and widely dispersed (USDA Forest Service 2008c, p. 3-370). 

Incomplete and Unavailable Information

The Forest Service does not collect specific data with regard to the number of people or specific 

activities carried out while visiting the Saddle Lakes project area. Effects to recreation users are based 

on professional judgment, anecdotal information, and information on the types of activities generally 

done for recreation in similar areas. 

The Saddle Lakes area was identified in the Forest Plan as important to hunters (subsistence) and 

Forest Service employees have seen the Shelter Cove dock full during deer hunting season. The 

amount of guided use is known from annual use reports which disclose the amount and type of use. 

Information is also available on the types of activities people do along the Ketchikan road system.

Recreation use types in the project area were anticipated based on use of similar areas as well as 

household surveys conducted for the State of Alaska Department of Transportation and Public 

Facilities (ADOT&PF). The amount of expected guide use in the future was based on the capacity of 

the area established in a previous NEPA analysis (USDA Forest Service 2012). Cumulative effects 

were evaluated with the knowledge of a reasonably foreseeable road connection from Ketchikan and 
3 Affected Environment and Environmental Consequences

202  Chapter 3 – Issue 4B – Recreational Opportunities Saddle Lakes Timber Sale Final EIS

therefore the assumption that the project area would see similar uses as the rest of the Ketchikan road 

system. 

The lack of exact numbers of recreation users in the project area does not affect the analysis. 

Analysis Area

The recreation analysis area for direct and indirect effects is the Saddle Lakes project area. In 

addition, the importance of tourism to the regional (Southeast Alaska) economy is discussed in the 

analysis, but is not analyzed in detail. 

Cumulative effects for recreation are analyzed at a larger scale than the project area – not a set area 

with a “hard boundary,” but an area that includes the proposed Ketchikan to Shelter Cove Road and 

therefore a qualitative discussion about the types of recreation and tourism opportunities available 

from the Ketchikan road system.
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Issue 4B – Recreational Opportunities - Chapter 3  203

Figure 14. Existing Recreation Opportunity Spectrum classes in the Saddle Lakes Project Area
3 Affected Environment and Environmental Consequences

204  Chapter 3 – Issue 4B – Recreational Opportunities Saddle Lakes Timber Sale Final EIS
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Issue 4B – Recreational Opportunities - Chapter 3  205

Affected Environment

The project area does not include Wilderness Area; Wild, Scenic, and Recreational Rivers; or any 

National Recreation Trails.

Past harvest and road building have set the current stage for recreational use of the Saddle Lakes 

project area. Roads allow visitors easier access to and throughout the project area. The project area is 

accessible from the Shelter Cove dock and log transfer facility (LTF). In addition, a road from the 

Coon Cove LTF also accesses the project area across non-NFS lands. Although the Coon Cove LTF is 

outside the project area on non-NFS land, a few people may access the project area along the road 

from this LTF. Access to the project area along this road is not analyzed in detail in Issue 4B because 

it is expected to be minimal.

Recreation Opportunity Spectrum

Appendix I of the Forest Plan (USDA Forest Service 2008b, pgs. I-1 to I-8) contains Recreation 

Opportunity Spectrum (ROS) Standards and Guidelines to help identify, quantify, and describe the 

types of recreation settings that the Tongass National Forest provides. The ROS inventory system is 

not a management system, so it does not dictate what type of activities are permitted in a given area.

Rather, the ROS system portrays the combination of activities, settings, and experience expectations 

along a continuum that ranges from highly modified to primitive environments. There are seven ROS 

classifications along this continuum; Figure 14 shows the existing ROS classes for the Saddle Lakes 

project area. 

The ROS inventory is used to assess the potential effects of the alternatives on recreation settings. 

Each ROS class includes setting indicators and applicable standards and guidelines. ROS is generally 

applied across a larger area of land to avoid isolated segments of one type being surrounded by 

another type. However, sometimes there are segments of land that seem to not fit the description of 

the surrounding assigned ROS class.

The current ROS classification indicates a Roaded Modified (RM) designation for the area 

surrounding the existing roads and previous harvest units. Although the entire Shelter Cove road 

system is classified as RM, the area immediately around North Saddle Lakes has a more naturalappearing landscape (high to very high ESI) than other areas along the road system. This area may 

not completely fit the RM classification, but is not large enough to warrant a separate setting. 

A portion of the southern part of the project area has a Semi-Primitive Non-Motorized (SPNM) 

setting, while the northern part of the project area, adjacent to the Naha LUD II, is designated as 

Semi-Primitive Motorized (SPM) (Figure 14). Although no roads exist in the SPM setting, there is 

float plane traffic to many of the lakes in the Naha watershed, which is contained in the same SPM 

setting, and the designation fits with the descriptions provided in Appendix I when all setting 

indicators are considered.

Visual Priority Routes and Use Areas

Appendix F of the Forest Plan (USDA Forest Service 2008b, pgs. F-1 to F-24) contains a list of visual 

priority routes and use areas (VPRs). The scenery section (Issue 4A) provides a discussion about 

VPRs, and includes a list of the VPRs used in the scenery analysis in Table 69. The recreation 

analysis also uses these VPRs. 

Note that the Harriet Hunt to Shelter Cove Connection Road (VPR), is referred to as the Ketchikan to 

Shelter Cove Road in the recreation analysis to be consistent with the project title used by the State of 

Alaska Department of Transportation and Public Facilities (DOT&PF).
3 Affected Environment and Environmental Consequences

206  Chapter 3 – Issue 4B – Recreational Opportunities Saddle Lakes Timber Sale Final EIS

Planned Saddle Lakes Recreation Area

The area immediately around North Saddle Lakes is in a natural-appearing condition (high to very 

high existing scenic integrity) and is designated as Modified Landscape LUD in the 2008 Forest Plan. 

Currently there are no developed recreation facilities in the Saddle Lakes project area. Recreation use 

in the project area is dispersed recreation. The planned Saddle Lakes Recreation Area would be the 

most likely destination in the project area for dispersed camping, and use of the lakes for kayaking 

and canoeing is probable. 

Tourism and Visitor Use

The 2012 population estimate of the Ketchikan Gateway Borough was 13,779 individuals, a two 

percent increase from 2010 (US Census Bureau 2013). Because the Saddle Lakes area is remotely 

located (only boat and plane accessible) from Ketchikan, large numbers of people do not frequent the 

area at this time. The primary recreational use in the project area has been hunting, both sport and 

subsistence. For example, on opening day of the 2013 deer hunting season, private boats were taking 

up all available space at the Shelter Cove dock (Noah Lloyd, personal communication 2013). 

Subsistence use is addressed in Issue 3B. 

Despite the rainy climate, the demand for outdoor recreational activities in the Ketchikan area is 

strong and varied (McDowell Group 1990). Fishing, hiking, boating / kayaking / canoeing, nature 

tours / sightseeing, and berry picking are popular outdoor activities undertaken by locals and visitors. 

Strong demand for road accessible camping and fishing opportunities exists in the community, with 

about 72 percent of households reporting fishing annually (McDowell Group 1990). There is an 

active snowmobile club in Ketchikan, although opportunities are limited by both the moderate winter 

weather and available places to go. Although current use of the Saddle Lakes project area is fairly 

low, there is high likelihood of increased use by both residents and visitors once the proposed 

Ketchikan to Shelter Cove Road is built. In 2009, household surveys conducted by a contractor for 

ADOT&PF as part of their analysis of the proposed road indicated the following top five activities to 

be pursued once the road is complete: sightseeing or simply driving around, camping, hiking, 

freshwater fishing, and hunting (ADOT&PF 2012). 

Forest-wide Goals and Objectives describe the desired conditions sought to be attained on the Forest.

One goal specified by the Forest Plan relates to local and regional economies: provide a diversity of 

opportunities for resource uses that contribute to the local and regional economies of Southeast 

Alaska. One of the objectives to help achieve this goal is to support a wide range of natural resource 

employment opportunities within Southeast Alaska’s communities. This objective is also reflected in 

the purpose and need for the Saddle Lakes Timber Sale.

The visitor industry plays an important role in the Southeast Alaska economy, including Ketchikan. 

Most visitors arrive in Ketchikan during the months of May through September. According to a report 

prepared for the Alaska Department of Commerce, the visitor industry contributed 21 percent of the 

employment and 15 percent of the labor income for Southeast Alaska between May 2011 and April 

2012. That equates to about 10,200 jobs (27 percent) of the State-wide visitor industry jobs 

(McDowell Group 2013). 

Ketchikan is a principal destination for visitors to the Tongass National Forest; receiving almost a 

million cruise ship visitors annually as well as independent travelers that arrive via the ferry system, 

private boats, and flights. In October 2013, the Ketchikan Daily News reported that preliminary 

figures showed that just over 960,000 cruise ship passengers visited Ketchikan during 2013, an 

increase of almost 74,500 passengers from the previous year. This figure tops the record of nearly 

931,000 visitors in 2008 (Ketchikan Daily News 2013). Ketchikan is the second most visited 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Issue 4B – Recreational Opportunities - Chapter 3  207

destination in Alaska, with 58 percent of all visitors stopping in Ketchikan (McDowell Group 2012). 

In 2006, the visitor industry created about 1,500 jobs (14 percent) of Ketchikan’s payroll jobs 

(McDowell Group 2010). About 27 percent of those jobs were in tours and transportation, with 

another 37 percent in retail. 

Recreation Places

A “Recreation Place” is defined by the Forest Plan as a geographical area having one or more 

physical characteristics particularly attractive to people engaging in recreation activities. They are 

usually easy to access and can be identified through patterns of use associated with protected boat 

anchorages and landings, aircraft landing sites, and roads. They may be beaches, streamside or 

roadside areas, trail corridors, hunting areas, or the immediate area surrounding a lake, cabin site, or 

campground (USDA Forest Service 2008b, p. 7-32). A “Home Range Recreation Place” is a 

recreation place within about a 20-mile radius of a community (USDA Forest Service 2008c, p. 2-59). 

The Shelter Cove road system / Saddle Lakes area is identified as a recreation place in the 1997 

Forest Plan (see USDA Forest Service 1997c, Recreation Place Inventory map; and USDA Forest 

Service 2008c, p. 3-371) and falls within the home range of Ketchikan residents. The setting of a 

recreation place plays a key role in its attractiveness and use. Many recreation opportunities, such as 

viewing scenery or pursuing solitude are dependent on this relationship and require a natural type of 

setting, whereas others, such as hunting or fishing, are less dependent on the type of setting (USDA 

Forest Service 2008c, p. 3-371). 

Outfitter/Guide Use

In the past 5 years (2008 to 2012), one outfitter-guide has used the Saddle Lakes project area. Use has 

been minimal (17 service days total), and was for black bear hunting in the project area.

Commercial boat-based tours use both George and Carroll Inlets (VPRs), but do not have any shore 

stops and therefore do not require a special use permit from the Forest Service. In addition, private 

cabins (inholdings) do exist along the shores of George Inlet. 

During the recent planning efforts associated with the 2012 Ketchikan-Misty Fiords Ranger District 

Outfitter and Guide Management Plan, guides requested more opportunities close to town as a 

potential means to grow their businesses. The Record of Decision (USDA Forest Service 2012) 

allows for up to 1,420 service days per year to be issued to outfitter and guides in the South Revilla 

Natural Accessible Use Area, which includes the Shelter Cove road system. That use area also 

includes the Shoal Cove and Thorne Arm (Elf Point) road systems. This analysis assumes that those 

guided service days would be issued for the Shelter Cove road system. This is because the proposed 

Ketchikan to Shelter Cove Road makes access to the project area easier than it currently is, and would 

provide a location close to town as requested by the guides. In addition, this assumption provides a 

worst case scenario for effects from the Saddle Lakes project (in relation to outfitter and guides).

Recreation Access

The Ketchikan road system (all roads connected to Ketchikan) accesses numerous hiking trails and 

developed campgrounds, but provides a limited road system for recreationists to drive. Most of the 

road system connected to Ketchikan is on non-federal lands, and past timber harvest and urban/rural 

scenes dominate much of the land visible from the Ketchikan road system. No National Forest 

System (NFS) or State of Alaska roads connected to Ketchikan are open for off-highway vehicle 

(OHV) use. However, some OHV use does occur on private land. One road within the Saddle Lakes 

project area (NFS road 8337000, 4.6 miles) is currently assigned through the 2008 KMRD Access and 

Travel Management (ATM) Plan (USDA Forest Service 2008g), and the associated Motor Vehicle 
3 Affected Environment and Environmental Consequences

208  Chapter 3 – Issue 4B – Recreational Opportunities Saddle Lakes Timber Sale Final EIS

Use Map (MVUM) as an OHV Trail (open only to vehicles 50 inches or less in width). According to 

the KMRD ATM Plan, about 25.6 miles of road are open to mixed use (vehicles and OHVs) along the 

Shelter Cove road system (all within the Saddle Lakes project area).

The Ketchikan to Shelter Cove Road would connect the currently isolated Shelter Cove road system 

to the community of Ketchikan increasing access to the project area. The State of Alaska has 

requested a right-of-way on NFS lands within the Saddle Lakes project area for the construction, 

operation, and maintenance of about 1 mile of new road associated with the Ketchikan to Shelter 

Cove Road. Household surveys were conducted by a contractor for ADOT&PF as part of the analysis 

for this proposed road. The surveys identified an unmet need for access to lands through which the 

proposed road would travel, especially for access to recreational and subsistence-related activities 

(ADOT&PF 2012). Survey respondents indicated an interest in simply having additional roads to 

drive and access to additional land for recreation purposes; the number of trips along the route are 

projected to increase 60 to 70 percent. 

Environmental Consequences

Direct and Indirect Effects

The following tables are used to display effects for the alternatives, and referred to in the alternative 

effects analyses that follow. The changes to ROS class expected under each alternative are shown in 

Table 76, while Table 77 provides a list of project area units important to the overall recreation 

experience in the Saddle Lakes project area by action alternative. Important units for the recreation 

resource include units within the Saddle Lakes viewshed and units along the road in the small OldGrowth Habitat LUD. Although Scenery analyzed all units in the Saddle Lakes viewshed, Recreation 

considered a subset of those with a focus on those units along the lake shores and adjacent to the main 

road (8300000) nearest the lakes.

Table 76. ROS class acres1/ by alternative for the Saddle Lakes Timber Sale Project

ROS class2/ Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5 Alternative 6

SPNM 5,133 5,133 5,133 5,063 5,063 5,133

SPM 6,644 6,644 6,644 6,644 6,603 6,644

RM 26,663 26,663 26,663 26,733 26,774 26,663

Total 38,440 38,440 38,440 38,440 38,440 38,440

Acres 

changed 

from SPM to 

RM

0 0 0 0 41 0 

Acres3/

changed 

from SPNM 

to RM

0 0 0 70 70 0 

Source: USFS Tongass National Forest GIS.

1/ Acres may not total the same as other resource analyses due to rounding. In addition, about 20 acres of saltwater contained 

within the project boundary are not included in this table.

2/ ROS Classes: SPNM = Semi-Primitive Non-Motorized; SPM = Semi-Primitive Motorized; RM = Roaded Modified

3/ Harvest prescriptions calling for uneven-aged management with up to 33% removal were not considered to change ROS 

setting (for the scenery criteria) because they are not generally noticeable to the casual observer.
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Issue 4B – Recreational Opportunities - Chapter 3  209

Table 77. Harvest units of high concern to recreation by alternative (acres1/ and prescription2/) for the 

Saddle Lakes Timber Sale Project

Harvest Unit Alternative 2 Alternative 3 Alternative 4 Alternative 5 Alternative 6

27 14 ac UA33 14 ac CC 14 ac CC

29 42 ac UA33 42 ac CC 42 ac CC

30 15 ac UA33 15 ac UA33 15 ac UA33

46 48 ac UA33 48 ac CC 48 ac CC

36 ac CC,

7 ac UA33.

5 ac no cut

47 15 ac UA33 15 ac CC 15 ac CC

48 19 ac UA33 19 ac CC 19 ac CC 19 ac CC

50 20 ac UA33 20 ac CC 20 ac CC 9 ac CC

51 24 ac UA33 24 ac CC 24 ac CC 9 ac CC

80 13 ac UA33 13 ac CC 13 ac CC 4 ac CC

114 16 ac CC 16 ac CC 16 ac CC

115 12 ac CC

118 19 ac UA33 19 ac UA33 19 ac UA33

134 15 ac UA33 15 ac CC 15 ac CC

138 15 ac UA33 15 ac CC 15 ac CC

147 16 ac UA33 16 ac CC 16 ac CC

300 23 ac CC

301 14 ac CC

302 15 ac CC

303 12 ac CC

305 20 ac CC

306 11 ac CC

307 36 ac CC

308 9 ac CC

311 4 ac CC

Total Acres 241 0 291 447 134

Even-aged 

Clearcut 0 0 257 413 93

Uneven-aged 

33% removal 241 0 34 34 41

Source: USFS Tongass National Forest GIS

1/ Acres are rounded to nearest whole number.

2/ UA33 = uneven-aged management (single-tree selection), CC = even-aged management (clearcut).

Effects Common to All Action Alternatives (Alternatives 2 through 6)

The first few years following timber harvest, people would likely use the recently harvested units for 

berry picking, hunting, and firewood gathering. Recreationists using the project area during project 

implementation would experience an increased encounter rate and possible temporary adverse effects 

to their experience. The Shelter Cove dock could have less available space for use by recreationists 

because contractors may also tie up to the dock. Increased traffic levels may increase the safety risk 
3 Affected Environment and Environmental Consequences

210  Chapter 3 – Issue 4B – Recreational Opportunities Saddle Lakes Timber Sale Final EIS

posed to visitors along the open roads in the project area, and dust generated by more vehicles and 

truck/equipment traffic may affect some visitors. Noise levels due to active road construction and 

logging activities may affect the experience of some visitors. Recreational and commercial boaters in 

Carroll Inlet could have additional encounters with boat traffic associated with project activities, such 

as crew boats, barge traffic, or log raft towing. In addition, there could be occasional escaped logs in 

the water, presenting a hazard to boaters. All of these effects would be temporary during the active 

phases of the project. 

The State of Alaska right-of-way would result in an additional 1.1 miles of open road available for 

recreation users, creating a total of 26.7 miles of open road in the project area. Effects to the project 

area from linking Ketchikan and Shelter Cove via road are considered under Cumulative Effects. 

NFS Road 8337000 would be returned to OHV Trail status after completion of project activities and 

would be available for use by vehicles 50 inches or less in width. 

New roads built as part of the Saddle Lakes Timber Sale would be open only for administrative 

purposes during project implementation, and would be closed to all motor vehicle use after the 

completion of silvicultural activities. The only exception to motorized closure after sale activities is 

for the above mentioned State of Alaska right-of-way which is expected to coincide with proposed 

NFS Road 8300280. Non-motorized use of closed roads associated with the timber sale would be 

allowed after the project, which could make access to currently difficult to reach areas easier, 

especially for the first few years.

Due to safety concerns during active logging operations, roads shown on the MVUM as open may be 

temporarily closed to the public. These roads would be appropriately signed (marked) in accordance 

with provisions in the timber sale contract. At this time it is unknown which roads may be 

temporarily closed, how long the temporary closures would last, or what time of year the temporary 

closures may take place. Closures may affect access to portions of the project area during popular 

times of the year such as hunting season. 

The proposed modification of a naturally occurring partial fish barrier on Salt Creek would improve 

access to upstream habitat for coho salmon and steelhead allowing more harvest by sport 

(recreational), subsistence, and commercial fisheries. This modification was considered to have a 

negligible effect on recreation as a whole and is not considered further in this analysis. 

It is assumed for analysis that most if not all recreation users would use the dock instead of the 

Shelter Cove LTF to access the project area. There may be some OHVs offloaded at or near the LTF 

site, especially with the addition of a low angle barge ramp as part of the LTF reconstruction project. 

However, this is anticipated to be a small percentage of total recreation use and therefore the 

proposed Shelter Cove LTF Reconstruction is expected to have minimal effect on recreation. 

The following section describes the direct and indirect effects of timber harvest and road construction 

on recreation resources by alternative.

Alternative 1

The existing condition of the project area would continue. Limited outfitter-guide use of the area 

would likely continue, with service days remaining available (unused). Primary recreation in the area 

would continue to be hunting (sport and subsistence). No timber harvest or road construction is 

proposed under Alternative 1, resulting in no change to the ROS. No changes to the miles of open or 

closed roads would occur. Scenic integrity around North Saddle Lakes would remain intact because 

no harvest of adjacent units would take place. 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Issue 4B – Recreational Opportunities - Chapter 3  211

Alternative 2

Alternative 2 proposes harvest in eleven of the units (241 acres) of high concern to recreation, but all 

units include uneven-aged silvicultural methods with 33 percent removal (Table 77). Harvest in these 

units would not be as noticeable to the casual observer (recreation visitors) when compared to a 

silvicultural prescription calling for a higher percentage of tree removal (e.g., even-aged clearcut 

method). This alternative would have fewer impacts to recreation than Alternatives 4 and 5, but more 

than Alternative 3. 

Alternative 2 would construct 15.8 miles of road to facilitate the timber sale. After completion of the 

timber harvest these roads would be available for non-motorized activities such as hiking.

Alternative 3

Under Alternative 3, no harvest is proposed in units of high concern to recreation (Table 77) and there 

would be no changes to the ROS classes. Timber harvest occurring in this alternative would not be 

easily noticed by the average forest visitor recreating in the area.

Alternative 3 includes 11.7 miles of road construction to facilitate the timber sale. After completion of 

the timber harvest these roads would be available for non-motorized activities such as hiking.

Alternative 3 would have the least impacts to recreation resources over all other action alternatives 

(Alternatives 2, 4, 5, and 6). 

Alternative 4

Alternative 4 proposes harvest in fourteen of the units (291 acres) of high concern to recreation (Table 

77). All units are proposed for even-aged silvicultural prescriptions (clearcut), with the exception of 

two units which are proposed for uneven-aged silvicultural prescriptions with 33 percent removal (34 

acres). Timber harvest would be easily noticed by the average forest visitor recreating in the area.

Visitors would not experience much visual diversity along the road system. Opportunities for easy 

access to recreational activities within a mature old-growth forest would be more restricted than is 

currently available in the project area.

Minor changes in the ROS boundary would be needed due to the harvest of Unit 149 in this 

alternative. This unit lies near the boundary between RM and SPNM ROS classes. Due to the 

topography of the proposed unit location, a new “buffer” around the unit would be needed. This

would change 70 acres from SPNM (loss of 1.4 percent) to RM (gain of 0.4 percent). 

Alternative 4 includes 29.4 miles of road construction to facilitate the timber sale. After completion 

of the timber sale these roads would be available for non-motorized activities such as hiking. 

Alternative 4 would have more impacts to recreation than Alternatives 2, 3, and 6, but less impacts 

than Alternative 5.

Alternative 5

Alternative 5 would have the greatest impacts to recreation among the action alternatives, specifically 

on the diversity of recreational opportunities available within the project area. Alternative 5 proposes 

the greatest amount of harvest (2,875 acres) and road construction (32.3 miles) of all the action 

alternatives. This includes modifying the small OGR along the existing Road 83000000, which would 

reduce opportunities for easy access to recreational activities within mature old-growth forest. 

Alternative 5 would also have the highest likelihood of impacting visitors’ experiences during active 

logging and road construction operations since there would be greater and longer time-periods of 

noise, traffic levels, and temporary road closures. 
3 Affected Environment and Environmental Consequences

212  Chapter 3 – Issue 4B – Recreational Opportunities Saddle Lakes Timber Sale Final EIS

Alternative 5 proposes harvest in twenty-four units of high concern to recreation (447 acres) (Table 

77). Similar to Alternative 4, all units are proposed for even-aged silvicultural prescriptions (clearcut), 

with the exception of two units proposed for uneven-aged management with 33 percent removal (34 

acres). Timber harvest would be easily noticed by the average forest visitor recreating in the project 

area, particularly in the Saddle Lakes Recreation Area and the current Old-Growth Habitat LUD. 

Alternative 5 includes 32.3 miles of road construction to facilitate the timber sale. After completion 

of the timber sale these roads would be available for non-motorized activities such as hiking. 

Similar to Alternative 4, minor changes in the ROS boundary would be needed due to the harvest of 

Units 149 and 300 in this alternative. Unit 149 lies near the boundary between RM and SPNM ROS 

classes. Unit 300 is near the boundary between RM and Semi-Primitive Motorized (SPM) ROS 

classes. The new ROS boundaries result in a loss of 70 acres (1.4 percent) of SPNM and 41 acres (0.6 

percent) of SPM, which would add 111 acres of RM within the project area. 

Alternative 6

Alternative 6 proposes harvest in eight units of high concern to recreation (134 acres) (Table 77). Six 

units propose even-aged (clearcut) silvicultural prescriptions (93 acres), and three units propose 

uneven-aged silvicultural prescriptions with 33 percent removal (41 acres). 

Although visitors would notice the harvest of these units while recreating in the project area, 

Alternative 6 would have less impacts to recreation opportunities than Alternatives 2, 4, and 5. This is 

because of the configuration and the location of the units, and the harvest prescriptions proposed for 

them. Alternatives 6 and 2 are approximately equal in terms of recreation impacts in the short term 

because although Alternative 2 proposes more acres of harvest in the units of concern, those acres 

would be uneven-aged management. However, that uneven-aged management means Alternative 2 

uses more helicopter harvest (and less road building) around the lakes, and main roads may be closed 

more often to allow for public safety during helicopter operations. 

Five of the six units proposed for even-aged management have been modified in this alternative to 

have less impact than Alternatives 4 and 5; these five units are proposed for uneven-aged 

management under Alternative 2 at the same acreage as Alternatives 4 and 5. Unit 46 at the south end 

of the largest lake would not harvest the 5 acre setting closest to the lake in Alternative 6, thereby 

effectively increasing the lake buffer. It also would have a 7 acre setting harvested with an unevenaged treatment, lessening the visibility of the upper section of the unit to those recreating on the lake 

or driving the main road (8300000). Units 50 and 51 are also along the main road between the two 

North Saddle Lakes; both of these units in this Alternative would harvest fewer acres (leaving some 

settings for possible future harvest). Unit 80 is along the east shore of the larger lake and would 

harvest a 4 acre setting adjacent to Unit 48, resulting in less road building and harvest along the ridge 

east / above the lake than in Alternatives 4 and 5. In addition, although Unit 48 along the east side of 

the large lake would allow for an even-aged prescription, mitigation measures on unit configuration 

would reduce the visibility and therefore the impact to recreation visitors.

Alternative 6 includes 24.5 miles of road construction to facilitate the timber sale. After completion of 

the timber harvest, these roads would be available for non-motorized activities such as hiking.

Cumulative Effects

Appendix B includes the interrelated projects (i.e., past, present and reasonably foreseeable future 

actions) that have been considered in the recreation cumulative effects analysis.
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Issue 4B – Recreational Opportunities - Chapter 3  213

Cumulative Effects Common to all Action Alternatives

Past harvest and road building have set the current stage for recreational use of the Saddle Lakes 

project area. Roads constructed for timber harvest allow visitors easier access to and throughout the 

project area. 

The most relevant foreseeable future activity that would affect recreation is the planned KetchikanShelter Cove Road that would link the existing Shelter Cove Road system (in the Saddle Lakes 

project area) to the Ketchikan road system. The State of Alaska DOT&PF would build a new single 

lane road to provide vehicle access to Shelter Cove and the public and private lands in between Lake 

Harriet Hunt and Shelter Cove. The State of Alaska is currently in the process of obtaining all the 

necessary land owner permissions (easements) from the various ownerships the route would cross and 

any potentially required permits, such as Corps of Engineers. The estimated start of construction for 

the new section is 2015. 

The proposed Ketchikan to Shelter Cove Road would improve access to and throughout the project 

area by constructing about 6 miles of open road, of which about 1 mile is on NFS lands within the 

Saddle Lakes project area. This new road connection would allow people in Ketchikan to drive to the 

Saddle Lakes area instead of having to boat or fly to the area. As noted in the existing condition 

section, sightseeing / driving for pleasure is desired by locals, so this connection would lead to 

increased recreational use of the project area. The road would also allow for a wider range of visitors 

to access the project area and provide a more-economical means of getting there. At this time, the 

project area must be reached by boat or plane; once the road is connected to Ketchikan, older 

individuals, those with disabilities, and those people without a boat / plane could drive to the area 

(ADOT&PF 2012b).

Currently, the main road (NFS Road 8300000) through the Saddle Lakes project area is open to mixed 

use, which allows for both OHV and passenger vehicle use. This road would become part of the 

Ketchikan to Shelter Cove Road. It is unknown at this time if there would be any change to this 

designation once the road is connected to Ketchikan, but there is a possibility that OHV use would be 

restricted because other State of Alaska roads do not allow OHV use.

Recreational use is projected to be primarily road-based dispersed recreation such as sightseeing, 

camping, berry-picking, hunting, and fishing. The Saddle Lakes Recreation Area would be the most 

likely destination in the project area for dispersed camping, and use of North Saddle Lakes for 

kayaking and canoeing is probable. Freshwater fishing in the lakes and streams of the Saddle Lakes 

area is also likely. An increase in outfitter-guide use is projected; up to 1,084 service days is available 

for summer use by outfitter guides in the South Revilla Natural Accessible Use Area (road based 

operations along the Shelter Cove, Shoal Cove, and Thorne Arm road systems) with additional 

service days available in the spring and fall seasons.

Use of the 4.6 miles of OHV Trail (8337000 road) is expected to increase once people can drive to the 

area via the Ketchikan to Shelter Cove Road. Continued use would result in increased maintenance 

costs from an already declining recreation budget. In order to maintain the OHV trail additional 

funding or maintenance agreements could explored with user groups or alternate funding sources. 

Without additional maintenance funding or agreements OHV trails may need to be closed because of 

unsafe conditions or to prevent resource damage (soils, water quality). In addition, there is an 

enforcement concern about user-created trails (off-road use) throughout the project area once access 

to the project area increases with completion of the Ketchikan to Shelter Cove Road. 

In addition, firewood gathering and Christmas tree cutting would likely increase in the area since 

there are currently very few places along the Ketchikan road system for these activities.
3 Affected Environment and Environmental Consequences

214  Chapter 3 – Issue 4B – Recreational Opportunities Saddle Lakes Timber Sale Final EIS

Alaska Mental Health Trust Authority Land Exchange

The proposed Alaska Mental Health Trust Authority (AMHT) land exchange with the Tongass 

National Forest is also likely to affect recreation opportunities within the Saddle Lakes Timber Sale 

project area. About 8,170 acres are currently proposed for exchange from the Forest Service to the 

AMHT in the Saddle Lakes project area (AMHT 2012). These lands would no longer be managed by 

the Forest Service and current and future uses would be affected. 

Recreational use of AMHT lands is allowed, but must be non-commercial, non-motorized, and dayuse only (AMHT 2008). For example, dispersed camping, OHVs, and guided use would not be 

allowed; Road 8330000 is currently mixed use (vehicles and OHVs allowed) so if the exchange 

occurs and no motorized use is allowed by AMHT, this opportunity would be lost. There is also a 

segment of the 8300000 road that could be affected by this proposed exchange. There is a possibility 

that the Forest Service could retain some rights associated with the roads during the exchange; 

however, since that would have to be analyzed and negotiated during the exchange, the recreation 

analysis assumes that an established public recreation policy for AMHT lands would be in place. 

In addition, the proposed location for the land exchange would reduce the amount of SPNM ROS 

class in the project area, which in turn would affect the range of available recreation opportunities. 

The Carroll Roadless Area, located in the project area would be reduced by about 3,300 acres (33 

percent of the roadless area), which would affect the Semi-Primitive Non-Motorized and SemiPrimitive Motorized classes of dispersed recreation opportunities (see Roadless section). A portion of 

the small Old-growth Habitat LUD would also be affected by the proposed exchange. 

Outside the project area, a developed campground is available at Settlers Cove State Park, in addition 

to the Forest Service campgrounds in the Ward Lake Recreation Area (Signal Creek, Last Chance, 

and 3 C’s Group Use). Guided tours for a wide range of activities occur on federal, State and private 

lands around Ketchikan and along the Ketchikan road system. These include but are not limited to: 

sightseeing by vehicle, boat, or air; hiking; bicycle and motorcycle; interpretive and historical tours; 

fishing – both freshwater and saltwater; wildlife viewing; ziplines; canoeing / kayaking; and 

snorkeling. 

The following section describes the cumulative effects to recreation resources by Alternative.

Alternative 1

No direct or indirect effects would occur under Alternative 1 and therefore, no cumulative effects 

would occur under this alternative. The project area would continue to see approximately the same 

use levels and types of recreation as it does currently with no changes to ROS or road miles.

Alternative 2

Alternative 2 retains all the VPR designations in the project area and proposes uneven-aged 

management for the units of concern to recreation (Saddle Lakes Recreation Area). These units would 

be less visible to the casual observer (most recreationists) and thus would have minimal effect on 

recreation.

Alternative 3

Similar to Alternative 2, Alternative 3 retains all the VPR designations in the project area, leading to 

higher scenic integrity in the project area, which is important to recreation. Alternative 3 proposes no 

harvest in areas of high concern to recreation and has the least impact to the recreation resource.
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Issue 4B – Recreational Opportunities - Chapter 3  215

Alternative 4

Alternative 4 proposes to remove the George Inlet, Carroll Inlet, Ketchikan to Shelter Cove Road, and 

Saddle Lakes Recreation Area VPR designations decreasing scenic integrity throughout the project 

area now and into the future. The greatest impact to recreation would occur from removal of the 

Saddle Lakes Recreation Area VPR designation. Most recreation within the project area is anticipated 

to occur around the North Saddle Lakes, and scenic changes to this area could affect the experience of 

visitors to the lakes. 

Alternative 5

The effects of Alternative 5 would be similar to Alternative 4, except all five VPRs would be removed 

and the Old-growth Habitat LUD would be modified. The proposed Ketchikan to Shelter Cove Road 

passes through mostly non-NFS land until it reaches the western edge of the Saddle Lakes project 

area. Much of this land has had timber harvest. Under Alternative 5, the small OGR would be 

modified (moved away from the road) to allow for additional timber harvest along the existing 

8300000 road (which would become part of the Ketchikan to Shelter Cove Road). This would lead to 

visitors viewing fairly constant young-growth on their drive from Ketchikan through the project area 

to Shelter Cove at Carroll Inlet, regardless of land ownership. The SIO of the area would be very low. 

This may reduce the diversity of visitors to the project area, including guided clients who are typically 

interested in seeing more-natural landscapes during their visit.

Alternative 6

The effects of Alternative 6 would be similar to Alternative 4, except that there would be fewer 

impacts to recreation because the Saddle Lakes Recreation Area would be maintained as a VPR and 

several units near the Saddle Lakes Recreation Area would not be harvest or would be modified to 

lessen the visual impact, in turn reducing the impact to recreation. The Saddle Lakes Recreation Area 

viewshed would continue to be managed for moderate SIO into the future. Most recreation within the 

project area is anticipated to occur around the North Saddle Lakes so although there would be scenic 

integrity objective reductions by removal of these VPRs, the impacts to recreation are less than in 

Alternatives 4 and 5. In the Saddle Lakes Recreation Area viewshed, Alternatives 2 and 6 are about 

equal: Alternative 2 has more total harvest but uses only uneven-aged management in the units of 

concern to recreation while Alternative 6 allows for some harvest in alternate configurations.

However, because Alternative 6 removes three VPRs which reduces SIOs over vast acres in the 

greater George / Carroll viewsheds (see Scenery, Issue 4A), in the long term, recreation opportunities 

would be reduced for activities needing more natural environments more than in Alternatives 2 and 3, 

making Alternative 6 rank in the middle of the action alternatives. 

Conclusion

Under all action alternatives, the State of Alaska would receive an easement from the Forest Service 

to construct, operate, and maintain about 1 mile of new road associated with the Ketchikan Shelter 

Cove Road. The Ketchikan to Shelter Cove Road would increase recreation use in the project area.

Alternatives 2, 3, 4, and 6 would provide a better experience and high SIO to visitors because the 

OGR would provide a view of large trees along the road shortly after entering NFS land on the drive 

from Ketchikan to Shelter Cove (thus alternating between harvest-dominated landscapes and more 

natural landscapes).

The Saddle Lakes Recreation Area would be the most likely destination in the project area for 

dispersed camping, and use of the lakes for kayaking and canoeing is probable. Freshwater fishing in 

the lakes is also likely. As described under Affected Environment, OHV use is currently limited on 

the Ketchikan road system, and the Ketchikan to Shelter Cove Road project would increase the 
3 Affected Environment and Environmental Consequences

216  Chapter 3 – Issue 4B – Recreational Opportunities Saddle Lakes Timber Sale Final EIS

available opportunities for this activity because of the OHV Trail in the Saddle Lakes project area.

Snowmobile use of the road in the winter is also a possibility.

Maintaining scenic integrity around the lakes (Saddle Lakes Recreation Area) would improve the 

experience for both local residents and visitors because it would provide a more natural appearing 

landscape in comparison to the surrounding harvested landscapes. Harvested landscapes may be 

observed all along the drive to Saddle Lakes as the connection road would cross through private and 

State lands, as well as the west part of the project area. Those action alternatives which do not modify 

or move the Old-growth Habitat LUD (Alternatives 2, 3, 4, and 6) would continue to provide an area 

of high SIO along the road to the west of the lakes. This would maintain a diverse spectrum of road 

accessible visual conditions and recreational opportunities en route to the primary destination around 

the lakes.

Tourism is an important part of the Ketchikan and Southeast Alaska economy, with guided activities 

on NFS lands playing an important role in that industry. A natural appearing landscape could 

encourage more recreational use of the area and provide a desirable destination for guided activities.

Guided activities often have an educational or interpretive component. Possible topics could be to 

contrast the harvested and unharvested areas, discuss the reasons for timber harvest, and provide an 

opportunity to showcase resource management and multiple use concepts. A portion of the fees paid 

by guides are returned to the district where they were generated. Up to 1,084 guided use service days 

for nature tours (sightseeing) and freshwater fishing are anticipated as a result of the road connection.

Alternatives 4 and 5 would have the most negative effect on recreation resources because they lower 

the scenic integrity objectives around the lakes by removing the Saddle Lakes Recreation Area VPR

designation. This change not only affects how much timber harvest / road building can occur under 

the Saddle Lakes project, but also allows for higher harvest levels into the future. Alternative 6 would 

maintain the SIO around the lakes while still providing for about 42 MMBF of timber harvest. 

However, this alternative would remove the VPR designations for the Ketchikan to Shelter Cove 

Road, George Inlet, and Carroll Inlet. Alternatives 2 and 3 preserve all VPRs in the project area 

(Saddle Lakes Recreation Area, Ketchikan-Shelter Cove Road, George Inlet, Carroll Inlet, and Shelter 

Cove boat ramp). Alternatives 4 and 6 also preserve the Shelter Cove boat ramp VPR.

All alternatives would maintain the 8337000 road as an OHV trail (4.6 miles). In the long-term, there 

is a concern for maintenance of this OHV trail and alternate funding sources would need to be 

explored to keep the trail open. Newly constructed roads associated with the timber sale would be 

closed to motor vehicle use at the end of the project and would be available only for administrative 

use during the project. Temporary road closures could occur during active timber sale activities, 

particularly for OHV use. These closures may negatively affect recreation users for short periods of 

time, and would be the most disruptive if they occur during the fall hunting season. 

Alternatives 1, 2, 3, and 6 do not result in any ROS changes within the project area. Alternatives 4 

and 5 would require a small change to the ROS class boundaries. This is about a 1 percent (1.4

percent) decrease to the acres of SPNM class, with less than a 1 percent decrease to the acres of SPM 

additional under Alternative 5. 

Design Features and Mitigation Measures

In Alternative 6, the lake buffer would be increased to 200 feet along the west boundary of Unit 48 to 

provide more of a visual screen for the proposed road in Unit 48, as well as the timber harvest itself. 

In addition, the boundary between Units 48 and 49 (east boundary of Unit 48 / west boundary of

Unit 49 would be feathered (varied rather than straight). This combination would reduce the impacts
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Issue 4B – Recreational Opportunities - Chapter 3  217

of a unit of high concern to recreation in the Saddle Lakes Recreation Area, when viewed from the 

lake and the road along the west side of the lake (8300000 road). 

In all action alternatives, NFS road 8337000 would be returned to OHV trail status, as currently 

shown on the MVUM, upon completion of timber sale activities. Any implemented road closure 

measures must be such that they are usable (passable / crossable) by OHVs (vehicles 50 inches or less 

in width). 
3 Affected Environment and Environmental Consequences

218  Chapter 3 – Air Quality and Climate Change Saddle Lakes Timber Sale Final EIS

Other Resources

Air Quality and Climate Change

This section describes the general air quality conditions expected in the Saddle Lakes project area and 

the information available about climate change in Southeast Alaska. Climate change and air pollution 

are closely linked, although in research and politics they have been largely separated. It is generally 

accepted that greenhouse gases (GHGs) are impacting the Earth’s climate by warming the surface and 

the atmosphere, thus affecting rainfall, glacier and sea ice retreat, and sea level, among other factors 

(Ramananthan and Feng 2009). However, many of the traditional air pollutants (particulate matter or 

PM) and GHGs have common sources and may interact physically and chemically in the atmosphere 

causing a variety of environmental impacts on the local, regional and global scales (Bytnerowicz et al. 

2007). 

Affected Environment – Air Quality

Air quality on the Tongass National Forest and in Southeast Alaska is generally very good. The 

prevailing winds off the Pacific Ocean, the relatively small amount of industrial development and 

population centers, and the general lack of smoke from large-scale wildland fire all contribute to 

maintaining clean air in the region. However, localized air pollution from sources such as mining 

operations, marine vessels and cruise ships, wood-burning stoves, vehicle exhaust, diesel power and 

asphalt plants, incinerators, and unpaved roads can contribute to deterioration of air quality at various 

scales (temporal and spatial) that could impact sensitive receptors on the Tongass National Forest.

Designated sensitive receptors of air quality impacts are lichens (Dillman et al. 2007; USDA Forest 

Service 2008b). Lichens, especially canopy epiphytes, are particularly sensitive to pollution and 

climate because they obtain their water and nutrients from the atmosphere rather than soils, lack 

barriers to water or pollutants, and because their metabolism is moisture activated. This means lichens 

are very responsive to shifts in moisture and temperature (Geiser 2012). 

Under the Forest Plan, the goal of air resource management (ARM) is to maintain the current air 

resource condition to protect the Forest’s ecosystems from on- and off-Forest air emissions sources.

To help resource managers understand if on- and off-Forest air pollution is impacting sensitive 

receptors, we established a network of biomonitoring plots in 1989 that use lichens as indicators of air 

quality. Permanent plots are monitored every 8 to 10 years to determine if contaminant concentrations 

in lichens are above established thresholds developed for the Forest from pristine areas (Dillman et al. 

2007). The consistent monitoring allows resource managers to gather trend data on contaminants 

(some of which are criteria pollutants or similar species such as nitrogen for nitrogen dioxide, sulfur 

for sulfur dioxide and lead). Concentrations above the established thresholds indicate that something 

in the vicinity of the plot is contributing additional levels of a particular contaminant over what is 

expected as background for the Forest. 

The air quality condition has been derived from established air quality biomonitoring plots on other 

parts of Revillagigedo Island - Misty Fiords Wilderness (Manzanita Lake) and near Ketchikan (Ward 

Lake and Settlers Cove). Overall, lichens from plots on Revillagigedo Island were not above 

contaminant thresholds established for the Tongass National Forest (Dillman et al 2007). These plots 

are in direct influence from Ketchikan road system and human population activities (at Ward Lake 

and Settlers Cove) such as wood stoves, garbage burning, and other fossil fuel combustion activities. 

Additionally, the air quality objective under the current Forest Plan is to attain national and State 

ambient air quality standards forest-wide. To determine if national and State ambient air quality 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Air Quality and Climate Change - Chapter 3  219

standards are being met in the region, an annual review of EPA and Alaska Department of 

Environmental Quality reports is conducted at the forest level.

There is no non-attainment area in the vicinity of the project area.

Affected Environment – Climate Change

Climate fundamentally shapes our surroundings. Climate is extremely important to local ecosystems 

as well as human health and infrastructure since temperature, precipitation, winds, and meteorological 

events (for example, the timing of the first and last frost, the beginning and end of a rainy season, or a 

severe storm causing flooding) all influence the distribution of water, soils, plants, and wildlife across 

the globe. Significant, lasting change to existing weather patterns is commonly called “climate 

change.” 

The term “greenhouse gases” (GHGs) refers to a variety of gases in the Earth’s atmosphere that react 

with sunlight in a way that influence global air temperature. GHGs are a function of air quality and 

include carbon dioxide, methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons, and sulfur 

hexafluoride (EO 13514). These GHGs are typically reported in units of carbon dioxide equivalent 

(CO2e).

Long-term climate trends and decadal climate cycles have always occurred in Southeast Alaska, 

influencing air temperature and precipitation (Neal et al. 2002). There is a growing body of literature 

on the topic of climate change and likely effects on aquatic and terrestrial ecosystems of the Tongass 

National Forest (e.g., Bryant 2009, Hodgkins 2009, Hood and Berner 2009, Haufler et al 2010, 

Wolken et al. 2011, Hennon et al. 2012). 

Changing Climate

The Tongass National Forest is a matrix of forests, wetlands, alpine meadows, ice, and rocks. Climate 

change impacts these landscapes in different and potentially unanticipated ways. The forest’s role in 

the global carbon cycle is thought to be significant, equal to about 8 percent of the carbon stored in all 

forests in the Lower 48 (USDA Forest Service 2013d). 

The U.S. Global Change Research Program (2009) reported that Alaska has experienced a 3.4 degree 

Fahrenheit rise in average annual temperatures over the past 50 years with an increase in winter 

temperatures of 6.4 degree Fahrenheit. Temperatures are expected to continue to rise. These increases 

in temperatures have led to other related changes to climate, such as an increase in snow-free days 

and shifts in precipitation. Snow-free days have increased across Alaska by an average of 10 days.

According to Hennon et al. (2012), the forests of coastal Alaska are expected to experience the largest 

twenty-first century increase in frost-free days anywhere in North America (Meehl et al. 2004) as the 

winter climate moves across the snow–rain threshold (Hennon et al. 2012). 

According to Haufler et al. (2010), anticipated climate change impacts to NFS lands and the lands of 

other ownerships on the Tongass National Forest include changing sea levels, increased ocean 

temperatures and changing circulation patterns, increased ocean acidification, increased storm 

intensities, changes to stream temperatures and flows, loss of glaciers, changes to wetlands, forest 

temperature and precipitation changes, and increases in invasive species. Climate change has been 

linked to increases in GHGs, with the primary factor being the rise in CO2 levels (Haufler et al. 2010). 

Yellow-cedar Decline

As discussed by Haufler et al. (2010), forest temperature and precipitation changes have an impact on 

NFS lands. In Southeast Alaska, these changes have been associated with a declining Alaska yellow-
3 Affected Environment and Environmental Consequences

220  Chapter 3 – Air Quality and Climate Change Saddle Lakes Timber Sale Final EIS

cedar (Callitropsis nootkatensis) distribution, henceforth referred to as yellow-cedar. Although 

distribution of yellow-cedar has been undergoing change over the last century, scientists are 

indicating that these distribution changes are increasing due to climate change (Hennon and Shaw 

1997, Beier et al. 2008, Hennon et al. 2008). 

For more detail on yellow-cedar decline, see the section entitled Forest Health and Natural 

Disturbances in the Silviculture section in this chapter. There are about 1,797 acres of yellow-cedar 

decline mapped in the Saddle Lakes project area, with the majority occurring at elevations below 

1,400 feet (USDA GIS Cedar Decline layer located in the project record).

Carbon Sequestration

Forest ecosystems represent the largest terrestrial carbon sink on earth, such that the United Nations 

Framework Convention on Climate Change (see United Nations Framework Convention on Climate 

Change website) has recognized their management as an effective strategy for offsetting GHG 

emissions (Wilson et al. 2013). Although much of the attention on the forest carbon sequestration 

strategy in the United States has been on the role of private lands, public forests in the United States 

represent approximately 20 percent of the U.S. timberland area and also hold a significantly large 

share (30 percent) of the U.S. timber volume. With such a large standing timber inventory, these 

forested lands have considerable impact on the U.S. forest carbon balance (Depro et al. 2007). 

Sequestration refers to the storage of carbon to reduce atmospheric carbon (CO2) and mitigates the 

effects of climate change. For the purposes of federal land managers, biological sequestration occurs 

when atmospheric carbon is absorbed and stored by plants or soils. Biological sequestration is the net 

increase of carbon stored within a parcel of land over time, while the net decrease is considered an 

emission. In other words, a standing forest that exists today is not, in and of itself, considered 

sequestration, but any additional carbon that is stored within that forest as it grows over time would 

be considered sequestration (CEQ 2012). 

Forests absorb carbon dioxide and reduce its presence in the atmosphere. Growing forests sequester 

and store more carbon over time until growth slows down considerably at maturity. Older trees 

sequester carbon through new growth at a declining rate, but retain pools of stored carbon until they 

burn or decay as they decline, die or are harvested. Actively growing forests turn water, sunlight and

atmospheric carbon dioxide into solid carbon and oxygen and continue to store significant amounts of 

carbon when they are old. Carbon is continuously cycled among these storage pools and between 

forest ecosystems and the atmosphere as a result of biological processes in forests (e.g., 

photosynthesis, respiration, growth, mortality, decomposition, and disturbances such as fires or pest 

outbreaks) and anthropogenic activities (e.g., harvesting, thinning, clearing, and replanting). Because 

the carbon sequestration system consists of multiple pools, the fluxes between them, and numerous 

processes, it is important to consider forest carbon as a complete system, rather than just focusing on 

one pool or process. For example, if you were to just consider carbon fixed by growing trees through 

photosynthesis, you might assume that young forests are desirable because they sequester carbon 

faster than old forests. However, it is also important to consider the importance of carbon stored in 

older forests, both in live biomass and dead pools (Oregon Forest Resources Institute 2013). 

The Tongass National Forest, like most forests, is considered a carbon sink (i.e., it stores more carbon 

in its systems than is released by natural processes). Cool conditions inhibit decomposition, slowing 

the rate of biomass breakdown and carbon release. Decaying plant matter is incorporated into the 

system’s soil profile, where it accumulates and may reside indefinitely. As a result, mature forests 

generally store considerable amounts of carbon on the forest floor. As such, a critical ecosystem 

service sustained by the forest is carbon sequestration (i.e., the removal of carbon dioxide from the 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Air Quality and Climate Change - Chapter 3  221

atmosphere and keeping that carbon inactive by storing it in live or dead biomass as well as organic

soil matter).

In 2012, the Forest Inventory and Analysis (FIA) program made numerous carbon storage estimates 

available via online tools (see FIA Forest Carbon Estimation website) and prepared the first national 

assessment of the biomass and carbon attributes of down woody material (USDA 2012a).

Table 78 shows the total carbon storage on the Tongass National Forest. 

Table 78. Total carbon storage in the Tongass National Forest

State 

Total Forest Carbon (million metric tons)

Live 

Aboveground

Live 

Belowground

Dead 

Wood

Floor 

Litter 

Soils

(organic) TOTAL

Alaska 

(Southeast only) 386 86 142 207 385 1,206

Source: FIA Current data as of 15 Jul 2013 Standard Tables of Forest Carbon Stock Estimates by State (Forest Inventory and 

Analysis National Program website).

Notes: Alaska only includes the Southeast Alaska coast and does not include the 111 million acres of Interior Alaska because 

the FIA program does not yet collect plot data there.

Greenhouse Gasses

Climate change due to GHGs is a global phenomenon, so the spatial context for this discussion is the 

global climate.

The most important GHGs directly emitted by humans include carbon dioxide (CO2), methane (CH4), 

nitrous oxide (N2O), and several other fluorine-containing halogenated substances. Naturally 

occurring GHGs include water vapor, CO2, CH4, N2O, and ozone (O3). Although these GHGs occur 

naturally in the atmosphere, human activities have changed their atmospheric concentrations.

Atmospheric CO2 concentration has increased from a pre-industrial value of 280 ppm to nearly 390 

ppm today, mostly due to carbon emissions from fossil-fuel burning and deforestation. GHGs trap 

heat and make the planet warmer.

The primary sources of GHG emissions in the Saddle Lakes project area are from transportation 

emissions (from seaplane flights, ferry/cruise ship activity, and vehicle travel) and emissions from 

fuel combustion associated with the city of Ketchikan. To provide context in understanding levels of 

GHGs, on a national level, GHG emissions totaled 6,822 million metric tons CO2e in 2010 

(Environmental Protection Agency 2012) and global GHG emissions totaled 31,781 million metric 

tons CO2e in 2010 (U.S. Energy Information Administration 2013). 

Environmental Consequences

Direct, Indirect and Cumulative Effects on Climate Change and Carbon Sequestration

Alternative 1 would likely result in a similar rate of climate change as current conditions, and would 

therefore have little or no effect on the rate of climate change in the Saddle Lakes project area or at 

least would not have an effect on the rate of climate change. Similarly, the rate of carbon 

sequestration would likely remain at its current rate for several years. Based on the literature review 

(see Climate Change Resource Report, Howle and Krosse 2014), it is uncertain whether the rate of 

carbon sequestration would be higher or lower under Alternative 1 compared with the action 

alternatives. It is possible that the rate of carbon sequestering would be slightly higher under the No-
3 Affected Environment and Environmental Consequences

222  Chapter 3 – Air Quality and Climate Change Saddle Lakes Timber Sale Final EIS

action Alternative (at an unquantifiable level). As Depro et al. (2007) found, with longer periods of 

time (100 years) with no harvest, there would be an annual increase in carbon sequestration. 

Alternative 1 is not expected to affect the current rate of climate change or carbon sequestration and 

thus would not add to the past, present, or reasonably foreseeable factors related to climate change. 

Direct, Indirect and Cumulative Effects on Yellow-cedar regeneration 

Alternative 1 would likely result in the same rate of yellow-cedar decline and current rates of 

regeneration, or at least would not have an effect on the rates of regeneration and/or decline. Since 

these factors are directly related to seasonal snow pack (loss of snow cover at lower elevations) and 

thawing cycles in late winter, a No-action Alternative would have no direct, indirect, or cumulative 

effects on overall yellow-cedar decline and/or regeneration.

Direct, Indirect and Cumulative Effects on Greenhouse Gas Emissions

Alternative 1 results in no construction-related CO2e emissions because no Forest Service 

construction or harvest operations would take place. However, CO2e would continue to be produced 

in the Ketchikan area (near Saddle Lakes) annually as a result of existing vehicle, aviation, and 

ferry/cruise ship emissions. Therefore, GHGs emissions are likely to remain the same as current 

conditions under Alternative 1. 

Alternatives 2, 3, 4, 5 and 6

Effects Common to All Action Alternatives

For all action alternatives, road construction activities, timber harvest operations, and administration 

of all operations by use of service vehicles throughout the life of the timber sale would result in 

emissions of greenhouse gases. These activities involve removing vegetation, grading and recontouring the ground surface, hardening the road, potential extraction of materials such as gravel, 

soil, and rock from on-island material sources, and constructing bridges all of which require fuelburning construction machinery, an increase in construction-related vehicle traffic a 3 to 10 year 

period. These construction actions would increase CO2e emissions due to fuel combustion from 

construction equipment and the vehicles of construction crews. 

Although the nature of the effects would be the same for all action alternatives, the magnitude of 

effects would differ per alternative. This environmental impact statement only evaluates the change in 

CO2e emissions produced by the action alternatives as compared to the No-action Alternative when 

assessing project effects to climate. This qualitative approach also matches federal protocol (Council 

on Environmental Quality 2012) in using CO2e as the single assessed metric to encompass all 

greenhouse gas emissions.

The effects of project activities on regional changes in climate, in carbon sequestration and on the 

natural regeneration of yellow-cedar would be evaluated qualitatively for all action alternatives.

Direct, Indirect and Cumulative Effects on Climate Change and Carbon Sequestration

The following sub-sections qualitatively assess the potential impact of the action alternatives in 

general on carbon sequestering and climate change, but do not attempt to calculate quantifiable 

impact values.

Overall, under the action alternatives, the rate of climate change and carbon sequestration would 

likely continue at the current rate for several years. Based on the literature review presented in the 

Climate Change Resource Report, (Howle and Krosse 2014), it is uncertain whether the rate of carbon 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Air Quality and Climate Change - Chapter 3  223

sequestration would be higher or lower under no action compared with the action alternatives; 

however, it is possible that the rate of carbon sequestering would be slightly higher under the Noaction Alternative (at an unquantifiable level). As Depro et al. (2007) found, with longer periods of 

time (100 years) with no harvest, there would be an annual increase in carbon sequestration. 

Direct, Indirect and Cumulative Effects on Yellow Cedar Regeneration

All action alternatives would likely result in the same rate of yellow-cedar decline and current rates of 

regeneration, or at least would not have an effect on the rates of regeneration and/or decline. 

Direct, Indirect and Cumulative Effects on Greenhouse Gas Emissions

During timber sale operations, fuel combustion associated with harvesting timber would result in 

CO2e emissions. Additionally, the distance vehicles travel to and from the harvest units, regardless of 

the location, would increase, during the life of the sale. Both of these changes would increase CO2e 

emissions through additional fuel consumption. 

For all action alternatives, construction activities—removing vegetation; grading and recontouring the 

ground surface; hardening the roads; potential extraction of materials such as gravel, soil, and rock 

from on-island material sources, constructing bridges and operation of timber harvest machinery 

(yarders, shovels, loaders, log trucks) would require fuel-burning construction machinery, an increase 

in construction-related vehicle traffic, and two to three seasons of construction in addition to a 3 to 10 

year timber harvest operation over the life of the sale. These construction actions would increase 

CO2e emissions due to fuel combustion from construction equipment and the vehicles of construction 

crews.

The CO2e emissions from construction were assessed qualitatively for all alternatives based on the 

duration and type of construction activity that would occur. The relative amounts of GHGs for each 

action alternative is proportional to the amount of road construction and harvest operations. 

Therefore, Alternative 5 would have the highest anticipated GHGs, followed by Alternatives 4, 6, 2, 

and 3, which would have lower levels. 

Overall, the effects of this project on climate change and air quality are negligible. The Air Quality

and Climate Change resource reports in the project record contain a more-detailed discussion of the 

environmental effects of climate change and air quality from the activities identified for the Saddle 

Lakes project. 

Although important on a global scale, it is estimated that the forests of the Tongass represent 

approximately only one quarter of 1 percent of the stored carbon in forests worldwide (USDA Forest 

Service 2008c, p. 3-19). Therefore, it is reasonable to conclude that small, if even measurable, 

changes in carbon sequestration, greenhouse gasses, and yellow-cedar decline under any of the action 

alternatives would not be a relevant factor for choosing among alternatives. Additionally, as described 

above and in the Forest Plan, the task of understanding all the factors that influence climate change 

contains substantial uncertainty and for these reasons is not essential to a reasoned choice among 

alternatives.

None of the action alternatives are predicted to measurably contribute to the cumulative effects on 

climate change.
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224  Chapter 3 – Aquatics Saddle Lakes Timber Sale Final EIS

Aquatics

This section focuses on sedimentation, streamflow, and stream temperature as well as fish habitat and 

distribution. These are the principle areas of hydrology and fisheries that may be impacted by timber 

harvest and road construction activities.

Road construction and use, as well as stream crossings are primary sources of sediment into streams. 

Even-aged logging systems (e.g., clearcutting) on slopes may adversely affect peak streamflows and 

therefore, fish habitat. Water quality can be affected by timber harvest through sedimentation caused 

by increased traffic on the road system and harvest practices such as cable yarding and shovel 

loading. Increased water temperatures can be caused by removal of trees (which shade streams). 

The following units of measure were used to evaluate current watershed condition, the effects of the 

proposal, and to compare alternatives:

Units of Measure:

• Changed streamflow: Cumulative harvest levels since 1984 in affected watersheds. The year

1984 has been used because a 30-year window has been determined as the time necessary for 

hydrologic recovery (Moore and Wondzell, 2005) 

• Increased sediment: Percentage of basin comprised of roads (from acres of existing and proposed

new road construction), and number of existing and proposed stream crossings.

• Changes in stream habitat: Miles of new roads, new stream crossings, timber harvest, and

landslides.

Methodology

The analysis was based on field data collected by Forest Service personnel and GIS. Field surveys 

focused on verifying fish habitat and mapping new streams. 

Incomplete and Unavailable Information

Stream flow and water quality data are unavailable for the affected watersheds. These data are not 

required for the effects analysis, which is based on known cause and effects relationships supported 

by peer reviewed literature.

Any remaining unmapped streams will be documented and mapped prior to implementation or during 

final unit layout. Forest Plan protection measures will be applied to these streams. Because of 

topographic and vegetative constraints, small Class IV channels, springs and seeps are not always 

visible. Data taken from several years of intensive stream surveys within the project area was updated 

during the 2014 field season to further define the aquatic resource in the area. It is believed that only a 

few unmapped streams remain in the project area and are likely small ephemeral Class IV channels, 

or non-streams (seeps). Contributions made by remaining unmapped streams are not expected to 

impact our analysis.

The lack of stream gauge data and the incomplete cataloguing of classified streams within the 

proposed action area were not critical for the analysis of the potential impacts. Analysis of potential 

effects was based on the assumption that risk to aquatic habitats was possible with all existing and 

proposed new disturbances, and that implementation of Standards and Guidelines and best 

management practices would minimize these risks.
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Aquatics - Chapter 3  225

Analysis Area

The watersheds used for this analysis were delineated by the US Geological Survey (USGS) 

according to a national hierarchy of Hydrologic Unit Codes (HUC). The project area includes 

portions of four 6th-level HUC watersheds, further divided into twelve true watersheds. Twelve of 

these function as true watersheds. In coastal areas, the ocean is considered the common point, so 

some of these units drain unconnected streams into the ocean. These areas do not function as true 

watersheds. All of the watersheds located in the project area are listed in Table 79 and displayed on 

Figure 15 and Figure 16. 

Table 79. Affected watersheds in the project area used in the analysis of the Saddle Lakes Timber Sale

6th-level

HUC 

Watershed

7th-level HUC Watershed

(all in 1901010205)

Total 

Acres

National 

Forest 

(acres)

Non-National 

Forest (acres)

Percent National 

Forest Land in 

Watershed

Calamity 

CreekFrontal 

Carroll Inlet

0305 (N. Saddle Lake) 5,879 5,458 419 92.8%

0307 (Twin Peaks) 815 815 0 100%

0308 (Gunsight Creek) 2,062 2,062 0 100% 

0310 (Shelter Cove-A) 163 163 0 100% 

0310 (Shelter Cove-B) 93 93 0 100%

0310 (Shelter Cove-C) 194 194 0 100%

0310 (Shelter Cove-D) 1,588 1,588 0 100%

George 

InletFrontal 

Carroll Inlet

0901 (Hidden Lakes) 1,830 834 996 45.6%

0903 1,612 433 1,179 26.9%

0910 (George Inlet-B) 151 0 151 0% 

0910 (George Inlet-C) 677 0 677 0% 

0910 (Coon Cove-A) 968 1 967 0.1%

0910 (Coon Cove-B) 182 0 182 0%

Marble 

CreekFrontal 

Carroll Inlet

0503 (Buckhorn Lake) 3,441 3,299 142 95.9%

0504 (Road End) 2,469 2,453 16 99.4%

0510 (California Cove-C) 791 442 349 55.9%

0510 (California Cove-D) 114 114 0 100% 

0510 (California Cove-E) 2,375 2,375 0 100%

Salt Lagoon

0601 (Horseshoe Ridge) 4,048 4,048 0 100%

0602 (Lemon Lake) 1,560 1,560 0 100%

0603 (Big Salt Creek) 4,654 4,337 317 93.2%

0604 (Upchuck Creek) 938 806 132 85.9%

0605 (Rainbow Creek) 4,078 3,091 988 75.8%

0606 (Salt Lagoon-A) 344 208 136 60.5%

0606 (Salt Lagoon-B) 25 0 25 0%

0606 (Salt Lagoon-C) 412 148 264 35.9%

TOTAL 41,463 34,522 6,940 83.3%

Source: USDA Tongass National Forest GIS

Notes: Acres are rounded to nearest whole number. Percentages are rounded to nearest tenth.

Italicized text designates true watersheds.
3 Affected Environment and Environmental Consequences

226  Chapter 3 – Aquatics Saddle Lakes Timber Sale Final EIS

The analysis was conducted on all watersheds at both the 6th-level and 7th-level HUC affected by 

this project, including watershed areas that extend beyond the project boundary and/or beyond Forest 

boundaries. The analysis includes all available information for each watershed, including information 

from non-NFS lands.
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Aquatics - Chapter 3  227

Figure 15. Hydrologic unit code (HUC) 6th-level watersheds, stream classes, and locations of red pipes (red fish crossings) in the Saddle Lakes project area
3 Affected Environment and Environmental Consequences

228  Chapter 3 – Aquatics Saddle Lakes Timber Sale Final EIS
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Aquatics - Chapter 3  229

Figure 16. Hydrologic unit code (HUC) 7th-level watersheds, stream classes, and locations of red pipes (red fish crossings) in the Saddle Lakes project area 
3 Affected Environment and Environmental Consequences

230  Chapter 3 – Aquatics Saddle Lakes Timber Sale Final EIS
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Aquatics - Chapter 3  231

Affected Environment

Climate

Precipitation within the analysis area ranges from about 100 inches to 140 inches annually, with the 

highest rainfall occurring during October and lowest in June. Individual storms vary dramatically 

over short distances and can produce intense rainfall and high winds resulting in windthrow. 

Streamflow

Timber harvest can change streamflow by altering the collection and storage of water, thus altering 

the amount and timing of water delivery to the stream. Reductions in canopy interception and plant 

transpiration rates resulting from harvest can increase annual water yield as well as peak flows in 

small streams (Jones and Grant, 1996). Rates of timber harvest in the project area have varied among 

watersheds, but were generally higher in the 1980s and 1990s. Harvest of suitable timber was 

primarily in valley bottoms and along toe slopes easily accessible from the road system.

Stream discharge within Southeast Alaska is predominantly controlled by rainfall events, with peak 

discharges occurring during fall and winter storms (Jones and Fahl, 1994). No active or historic 

stream gages exist within the project area. Evaluation of the data from nearby streamflow gages 

suggests that project area streamflow is likely influenced by spring snowmelt. The entire project area 

is below 5,000 feet in elevation, the project area has been determined to be in the rain-dominated 

hydrologic zone (Edward et al. 2008). Variable effects on low flows following harvest have been 

reported in rain-dominated coastal watersheds (Keppeler and Ziemer, 1990; Hicks et al., 1991). A 

study in Southeast Alaska concluded that timber harvest may result in higher levels of stream flow 

during dry periods (Bartos, 1989). However, recent analysis of these data suggests the change could 

be due to climatic cycles, not timber harvest (Neal, 2000). In another Southeast Alaska study, analysis 

of cumulative water yields in Staney Creek and a control watershed (Old Toms Creek) on Prince of 

Wales Island showed a decrease in Staney Creek’s annual water yield between 1995 and 2002. This 

time frame is consistent with the period of hypothesized maximum young-growth canopy closure, and 

supports the inference that increased evapotranspiration rates resulted in decreased stream runoff 

during this period. However, the analysis also showed that after 2002, the Staney Creek-Old Toms 

Creek water yield relationship returned to pre-1981 conditions. Analysis of summer minimum stream 

flow patterns for the Staney Creek period of record did not show evidence that potential changes in 

forest canopy interception rates affected low flow regimes. During the pre-harvest period (1965 to 

1970) Staney Creek actually exhibited higher variability in minimum summer streamflows than under 

young-growth forest conditions (1990 to 2010). As in the first study, this outcome may be related to 

the dominant influence of climatic regime shifts such as the Pacific decadal oscillation (Neal, 

personal communication 2010). 

An estimate of 29 percent of the timber harvested in the previous 30 years has been used as a measure 

of the time necessary for hydrologic recovery, referring to the decreasing impact of forest practices 

through time as a result of vegetation regrowth in the rain-dominated hydrologic zone (Grant et al. 

2008, Moore and Wondzell, 2005). More recent evidence supports the theory that increases in peak 

flows are only detectable in relatively small flows with a return period of six years or less in raindominated hydrologic zone such as those in the project area. Grant et al (2008) provides analytical 

thresholds to evaluate potentially detectable peak flow effects resulting from timber harvest and 

roads. 

Table 80 summarizes harvest acres from 1984 to present, of the true watersheds which have had prior 

timber harvest within the project area. None of the affective watersheds exceed the 29 percent 

cumulative harvest in the last 30 years. Within the Saddle Lakes project area, only Coon Cove-A and 
3 Affected Environment and Environmental Consequences

232  Chapter 3 – Aquatics Saddle Lakes Timber Sale Final EIS

B and George Inlet C watersheds have exceeded the 29 percent cumulative watershed harvest within a 

30 year time period. There is no planned harvest in these watersheds and little to no national forest 

land; therefore these watersheds were not analyzed further. 

Table 80. Past harvest in 7th HUC Watersheds in the Saddle Lakes project area (True Watersheds) 

7th HUC Watershed

(all in 1901010205)

Total 

Acres

Total 

Harvested 

(acres)

Total Harvested 

(% watershed)

Total 

Harvested 

since 1984 

(acres)

Total Harvested 

since 1984

(% watershed)

0305 (N. Saddle Lake) 5,879 544 9.30% 529 9.00%

0307 (Twin Peaks) 815 70 8.60% 70 8.60%

0308 (Gunsight Creek) 2,062 305 14.80% 305 14.80%

0901 (Hidden Lakes) 1,830 388 21.20% 376 20.50%

0503 (Buckhorn Lake) 3,441 242 7.00% 192 5.60%

0504 (Road End) 2,469 249 10.10% 245 9.90%

0602 (Lemon Lake) 1,560 222 14.20% 222 14.20%

0603 (Big Salt Creek) 4,654 380 8.20% 246 5.30%

0604 (Upchuck Creek) 938 169 18.00% 169 18.00%

0605 (Rainbow Creek) 4,078 795 19.50% 550 13.50%

Source: USDA Tongass National Forest GIS

Notes: Acres all rounded to nearest whole number. Percentages rounded to nearest tenth.

Water Quality

Beneficial Uses of Waters in the Project Area

The Alaska Integrated Water Quality Monitoring and Assessment Report provides information on 

water bodies within the State that do not fully or partially support their designated beneficial uses, 

known as the 303(d) list. None of the streams in the project area, including nearby waterbodies, are 

included on this list of impaired waters (ADEC, 2013).

No State-classified public water systems or potable water supply uses occur within the project area, 

but three pending or issued permit/certificates are located on State land downstream. No streams 

affected by this project are being used under these permits. 

Sediment and Turbidity

The primary water quality parameters potentially affected by timber harvest and road building are 

suspended sediment loads, turbidity, and stream temperature. No sedimentation or turbidity data is 

available for the watersheds in the project area. Generally, in undisturbed watersheds in Southeast 

Alaska, suspended sediment loads in non-glacial streams are very low (Schmeige et al., 1974). 

Sediment can be introduced into streams from management-related and natural processes, including 

road building, timber harvest, landslides, debris flows, and erosion of stream banks. 

Road surfaces are potential sediment sources to stream channels (Wemple and Jones 2003, Wemple et 

al. 1996, Megahan and Kidd 1972, Reid and Dunne 1984). Studies in Southeast Alaska have 

correlated higher rates of road erosion with heavy traffic, among other factors (Kahklen and Hartsog 

1999). 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Aquatics - Chapter 3  233

There are 95 miles of existing road in the project area watersheds. This figure includes roads of any 

ownership including State and local roads, and all NFS roads (system and temporary) built, regardless 

of age or operational maintenance level. Percentage of the watershed area comprised of roads has 

been used to help quantify the risk of flow-related impacts to aquatic systems, including sediment 

introduction into streams. On Washington’s Olympic Peninsula, accumulation of fine sediment in 

streambeds was found to be highest in basins where the road area exceeded 2.5 percent of the basin 

area (Cederholm et al. 1980). Basin area is measured in acres and square miles. A statistical 

relationship between fine streambed sediment and watershed disturbance has not been reported in 

Southeast Alaska studies (Bryant et al. 2004, Woodsmith et al. 2005). However, Cederholm’s 

suggested threshold provides a way to evaluate the potential impacts of roaded area in the affected 

watersheds in comparison to findings elsewhere in the Pacific Northwest.

Table 81 summarizes the existing road miles in the affected watersheds. Short-term increases in 

sediment and turbidity likely occurred during road construction and maintenance in these watersheds.

Table 81. Existing roads and road density in True Watersheds

7th-level HUC Watershed

(all in 1901010205)

Total 

Square

Miles

Total Acres Existing Roads 

(miles)1/

Total Road 

Density

(mi/mi2

) 

Percent Basin 

Area as 

Road2/

0305 (N. Saddle Lake) 9.19 5,879 15.93 1.7 1.3%

0307 (Twin Peaks) 1.27 815 1.78 1.4 1.1%

0308 (Gunsight Creek) 3.22 2,062 7.33 2.3 1.7%

0901 (Hidden Lakes) 2.86 1,830 7.01 2.5 1.9%

0503 (Buckhorn Lake) 5.38 3,441 5.21 1.0 0.7%

0504 (Road End) 3.86 2,469 5.88 1.5 1.2%

0602 (Lemon Lake) 2.44 1,560 2.71 1.1 0.8%

0603 (Big Salt Creek) 7.27 4,654 5.38 0.7 0.6%

0604 (Upchuck Creek) 1.47 938 2.4 1.6 1.2%

0605 (Rainbow Creek) 6.37 4,078 14.32 2.2 1.7%

Source: USDA FS GIS

Note: Square miles are rounded to nearest hundredth, percentages are rounded to nearest tenth, and acres all rounded to 

nearest whole number. 

1/ Includes all roads, regardless of ownership, type, or operational level. 

2/ Percent Basin as Roads calculated as: {[Existing road miles * 5,280ft/mi*40ft (assumed clearing width) / 43,560ft2

/acre] / 

watershed size (acres)} *100

Mass movement events such as landslides and debris torrents may be accelerated by forest 

management activity if surface or subsurface hydrologic characteristics of the site are altered, as can 

occur with timber harvest and road drainage diversions (Swanston and Swanson, 1976; Swanston and 

Marion, 1991; May, 2007). Watersheds in the project area are generally characterized by low relief 

(steepness) of the mainstem channels, with portions of the watershed having high concavity profiles 

where steep mountain slopes meet low-gradient valleys. Landslides and debris flows in these settings 

typically deliver sediment and debris in discrete deposits in the form of large log jams and alluvial 

fans at confluences, resulting in patchy disturbance patterns (Benda et al., 2004; May, 2007). 

Landslide acreage is highest in Horseshoe Ridge watershed, but with the highest percentage of slopes 

greater than 72 percent, this can be expected. Buckhorn Lake is an anomaly with only 1 acre of steep 
3 Affected Environment and Environmental Consequences

234  Chapter 3 – Aquatics Saddle Lakes Timber Sale Final EIS

slopes, yet with the highest occurrence of landslides. More information regarding mass movement 

events can be found within the Soils Report located in the project record. 

Windthrow is also a source of natural disturbance potentially impacting sediment delivery to streams 

in project area watersheds (see Silviculture section for further discussion of windthrow). Aerial photo 

and field assessments of windthrow in proposed units within project area watersheds indicate natural 

riparian windthrow is not a significant stream disturbing process, although individual tree windthrow 

is likely an important source of large woody debris (LWD) into stream channels.

Additional RMA protection through the use of reasonable assurance of windfirmness buffers per 

Landwehr (2007) guidelines would be considered and implemented as needed during harvest unit 

layout for any units within riparian management areas (RMAs) where windthrow hazard is high or 

moderate to ensure integrity of RMA buffers (see unit and road cards located in the project record).

Stream Temperature

Removal of riparian vegetation and the resultant increase in solar radiation can lead to increased 

stream temperatures (Beschta et al., 2000). Riparian management areas are designed to protect 

riparian zone interactions between streams, floodplains, riparian wetlands and uplands (Paustian 

2004). The Forest Plan Standards and Guidelines require that RMAs be delineated according to 

stream value classification and channel type process groups, with minimum protection standards 

defined for harvest and road building activities. RMAs are delineated for all Class I, II, and III 

streams within or adjacent to proposed harvest units according to guidelines established in the 

Aquatic Habitat Management Handbook (USDA Forest Service 2001a) and the Forest Plan (USDA 

Forest Service 2008b, pgs. D-1 to D-20). 

Timber harvest in upland areas has also been linked to increases in maximum daily stream 

temperatures. Pollock et al. (2009) found that the strongest predictor of increased stream temperatures 

was the percentage of total watershed harvested rather than the percentage of riparian canopy 

harvested. However, the authors had difficulty parsing out the difference since most of the riparian 

vegetation was harvested concurrent with adjacent upland harvest. The results from that study show 

that only one in six basins with 25 to 50 percent cumulative harvest had the probability to exceed a 7-

day average daily maximum (7DADM). 

Aquatic Habitat

The channel process groups used to classify and map streams in the project area reflect knowledge 

about inherent stream channel functions and processes affecting fish habitat (Paustian et al., 1992). 

The process groups also aid in the understanding of the effects of past practices. Channel types further 

categorize streams using physical attributes such as gradient, width, pattern, stream bank incision and 

containment, and riparian plant community composition. 

Streams on the Tongass National Forest are also classified by value classes from I to IV and nonstreams indicating levels of habitat use by fish populations and are delineated according to the criteria 

described in the Aquatic Habitat Management Handbook (USDA Forest Service, 2001b). 

Class I - Streams and lakes with anadromous or adfluvial fish or fish habitat; or high quality resident 

fish waters, or habitat above fish migration barriers known to be reasonable enhancement 

opportunities for anadromous fish.

Class II - Streams and lakes with resident fish or fish habitat and generally steep (6-25 percent or 

higher) gradient (can also include streams with a 0-6 percent gradient) where no anadromous fish 

occur, and otherwise not meeting Class I criteria.
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Aquatics - Chapter 3  235

Class III – Streams are perennial and intermittent streams that have no fish populations or fish 

habitat, but have sufficient flow or sediment and debris transport to directly influence downstream 

water quality or fish habitat capability. For streams less than 30 percent gradient, special care is 

needed to determine if resident fish are present.

Class IV - Other intermittent, ephemeral, and small perennial channels with insufficient flow or 

sediment transport capabilities to have immediate influence on downstream water quality or fish 

habitat capability. Class IV streams do not have the characteristics of Class I, II, or III streams, and 

have a bankfull width of at least 0.3 meter (1 foot).

Non-streams - Rills and other watercourses, generally intermittent and less than 1 foot in bankfull 

width, little or no incision into the surrounding hillslope, and with little or no evidence of scour. 

Table 82. Stream class, density, and Class I/II lake and pond habitat in affected watersheds

6th HUC 

Watershed

Area1/ Miles of Stream by Stream 

Class2/

Stream 

Density3/ Class I / II 

Lakes and 

Ponds 

(acres)

Number of 

Class I / II 

Lakes and

(mi Ponds 2) Class 

I 

Class 

II

Class 

III

Class 

IV (mi/mi2

) 

Calamity CreekFrontal Carroll 

Inlet

16.87 5.4 20.6 28.6 4.8 3.52 535 17

George InletFrontal Carroll 

Inlet

8.47 7.0 12.2 3.7 0.6 2.77 192 20

Marble CreekFrontal Carroll 

Inlet

14.36 16.3 14.9 13.9 1.6 3.25 168 3 

Salt Lagoon 25.10 18.1 21.0 46.3 2 3.48 265 6 

Totals 64.79 46.9 68.7 92.5 9.0 3.35 1,160 46

Note: 

1/ The sum of the 7th level HUCs analyzed within each 6th HUC watershed.

2/ Total stream miles are rounded to nearest tenth and do not include linear lake miles.

3/ Stream density rounded to nearest hundredth.

The abundant Class I and Class II habitat described in Table 82 indicates high fisheries value within 

the project area. At the 6th-level scale, Salt Lagoon watershed has the highest total miles of Class I 

and II streams, while the Calamity Creek-Frontal Carroll Inlet watershed has more lake and pond 

surface area. Specifically, Rainbow Creek has the most Class I anadromous habitat of any watershed 

with over 8 miles, followed closely by Road End with 7.6 miles of Class I streams. North Saddle 

Lake has nearly double the amount of Class II stream habitat of any other watershed with close to 

14.5 miles. 

Fish Species in the Project Area

The Alaska Department of Fish and Game (ADF&G) maintains the Anadromous Water Catalog 

(AWC), which provides information about waters important for the spawning, rearing, or migration of 

anadromous fish (Johnson and Blanche, 2010). The AWC, along with field verification, provide 

information for the fish species found within each watershed. Each watershed contains small and 

medium-sized drainages which contribute to a marine sport and commercial fishery, and support a 

limited freshwater fishery. Both the recreational and commercial fisheries are important to the local 
3 Affected Environment and Environmental Consequences

236  Chapter 3 – Aquatics Saddle Lakes Timber Sale Final EIS

economy of the area, and these fish populations contribute to the subsistence needs of local 

communities. 

Seven anadromous and/or resident salmonid fish species are present in project area streams and listed 

in Table 83. Although no records were found, sculpin spp. and three-spine stickleback are also likely 

to occur in project area watersheds.

Table 83. Anadromous and resident fish species known to occur in Saddle Lakes project area 

watersheds

6th-level

HUC 

Watershed

Anadromous Salmon, Char, and Trout

Pink Salmon 

(Oncorhynchus. 

gorbuscha) 

Chum 

Salmon 

(O. keta) 

Coho 

Salmon 

(O. 

kisutch) 

Sockeye 

Salmon 

(O. 

nerka) 

Dolly 

Varden 

(Salvelinus 

malma) 

Cutthroat 

Trout (O. 

clarki) 

Steelhead 

(O. 

mykiss) 

Calamity 

CreekFrontal 

Carroll Inlet

X X X X X 

George 

InletFrontal 

Carroll Inlet

X X X X 

Marble 

CreekFrontal 

Carroll Inlet

X X X X X 

Salt 

Lagoon X X X X X X X 

Sources: ADF&G Anadromous Waters Catalog (see Anadromous Waters Catalog website) and USFS Tongass National 

Forest Field Sampling data. 

Note: Fish scientific genus name: O. = Oncorhynchus

Threatened and Endangered Fish Species

No threatened and endangered fish species are generally found in the near-shore waters, nor do they 

utilize any of the freshwater habitats within the project area. A comprehensive discussion of fish 

species with this listing can be found in the Biological Evaluation (located in the project record). 

NMFS determined on April 02, 2014, that listing of the Southeast Alaska DPS of Pacific herring 

(Clupea pallasii) is not warranted at this time (79 FR 81518). 

Fish Passage

The condition of existing roads, culverts, and drainage features was assessed using road condition 

surveys (RCS). The road condition survey (RCS) in its original protocol design is no longer 

performed on the Tongass National Forest. The RCS protocol collected an extensive amount of 

baseline information on a variety of road related items. These included sign and drainage structure 

inventories, road integrity evaluations, access, stream characteristics, fish presence and an assessment 

of fish passage capability. The initial baseline RCS was conducted on Revillagigedo Island in 1999 

thru 2001. Since that time additional surveys have been completed to update the initial survey and 

improve our inventory of known fish stream crossings, their passage capability and the quality and

quantity of habitat located upstream of fish crossings not meeting passage standards. These surveys 

were completed in 2005 and directly for the Saddle Lakes EIS between 2012 and 2014. The original 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Aquatics - Chapter 3  237

baseline RCS survey with the updates provides us with enough information to perform our analysis in 

the EIS and is sufficient to provide a credible estimate of the effects, comparison of alternatives, and 

support an informed decision. As part of these surveys, each road crossing structure in a fish stream is 

assessed for its ability to provide unimpeded fish passage (USDA Forest Service 2001a). The Tongass 

National Forest developed a juvenile fish passage evaluation criteria matrix with an interagency group 

of professionals (Flanders and Cariello 2000). The evaluation matrix stratifies culverts by type, and 

establishes thresholds for culvert gradient, stream channel constriction, debris blockages, and vertical 

barriers (or perch) at culvert outlet. Fish crossings are categorized red, gray, or green according to 

passage conditions. Fish crossing categories are as follows (USDA Forest Service 2012): 

• Green Category: conditions have a high certainty of meeting adult and juvenile fish passage

requirements at all desired stream flows;

• Gray Category: conditions are such that additional and more detailed analysis is required to

determine their juvenile fish passage ability. This additional analysis includes use of the FishXing

analytical software; and

• Red Category: conditions that have a high certainty of not providing juvenile fish passage at all

desired stream flows (also called red pipes).

According to the most current RCS data (collected from 1995 to 2005), there are currently 11 red, 2 

gray, and 9 green fish crossings within the project area. However it is important to note that some of 

these streams are likely not accessible to upstream passage due to natural barriers above the culverts. 

For example, surveys of the culvert (red pipe) at road 8337000 at Milepost 0.153 showed a 45 percent

gradient directly above that creates a flow dependent barrier. The culvert is not perched and 

preventing fish passage, but because of the upstream gradient access to upstream habitat is difficult 

due to natural stream features. Only Dolly Varden have been sampled above and below the culvert. 

Upstream access by adult salmonids is prevented on this stream by a 6.2m chute/cascade falls a few 

meters from salt water. 

Collectively, for the project area, there are about 7.64 linear miles of Class II habitat upstream of 

these red crossings (Table 84). While the linear miles of the lakes were not included in the summary, 

there are 290 acres of Class II lakes upstream of red crossings. Figure 15 and Figure 16 show the 

locations of red fish crossings. Table 84 shows the number of red crossings in each watershed within 

the project area, as well as the amount of potential habitat affected.

While red fish crossings have a high certainty of not providing juvenile fish passage at all desired 

stream flows, they are not necessarily complete barriers. More often they impede passage to juvenile 

fish at higher flows, and remain passable at lower flows. A study conducted on Mitkof Island found 

most cutthroat and Dolly Varden move within a narrow range of flows with few moving at higher 

flow volumes (Bryant et al., 2009). All fish in the study moved upstream at flows below bankfull 

conditions. A description of RCS data and red fish crossings information is located in the project 

record.

Road crossings are maintained and repaired in accordance with our road maintenance plan. All red 

and grey culverts (red pipes) will be addressed through the on-going forest priority process and 

replaced depending on amount of upstream habitat and available funding. Replacement priority 

depends on a variety of metrics, for example the quantity and quality of upstream habitat, and 

diversity of fish in the system.
3 Affected Environment and Environmental Consequences

238  Chapter 3 – Aquatics Saddle Lakes Timber Sale Final EIS

Table 84. Summary of red fish crossings by milepost and associated upstream fish habitat in the Saddle 

Lakes project area

6th HUC Watershed Road 

Number Milepost Stream 

Class

Miles of 

Upstream 

Class I / II 

Habitat1/

Acres of 

Upstream Lake

Class I / II 

Habitat

2/

Salt Lagoon 8300000 13.528 II 0.1 0 

Salt Lagoon 8300000 15.447 II 0.1 0 

Salt Lagoon 8300000 15.465 II 0.9 0 

George Inlet-Frontal Carroll Inlet 8330000 4.65 II 0.1 0 

Calamity Creek-Frontal Carroll Inlet 8300000 18.082 II 1.9 218

Calamity Creek-Frontal Carroll Inlet 8300000 18.386 II 0.3 0 

Calamity Creek-Frontal Carroll Inlet 8337000 0.153 II 2.4 72

Calamity Creek-Frontal Carroll Inlet 8340000 0.929 II 0.2 0 

Marble Creek-Frontal Carroll Inlet 8340000 10.081 II 1.2 0 

Marble Creek-Frontal Carroll Inlet 8340000 11.224 II 0.04 0 

Marble Creek-Frontal Carroll Inlet 8340000 11.252 II 0.4 0 

11 red crossings total 11 Class II 7.64 290

Source: USFS GIS

Note: Acres are rounded to the nearest whole number and miles are rounded to the nearest tenth. 

1/ Upstream habitat lengths based on field-based habitat assessment data and GIS.

2/ Lake acres calculated in GIS.

Marine Environment

Watersheds within the project area include shoreline along George and Carroll Inlets and contain 

diverse estuarine and tidal habitats, areas vital for some commercially important species such as 

Dungeness crab and juvenile salmon. These areas are part of a complex and diverse ecosystem that 

includes shrimp, flatfish, marine worms, starfish, sponges, anemones, sea cucumbers, urchins, 

shellfish, plankton, marine algae, and other organisms.

The Shelter Cove LTF, located on Carroll Inlet, would be used to barge or raft the logs for this 

project. For the purposes of this analysis, it is assumed that Shelter Cove LTF would be used to 

transfer logs to water for rafting or barging to another processing location. 

The last underwater survey associated with the Shelter Cove Tideland Lease was completed in 2009 

and bark accumulation was 0.24 acre of continuous bark debris and 0.48 acre of discontinuous bark 

debris, meeting permit requirements. The Transportation section in this chapter discusses LTFs in 

more depth. 

Environmental Consequences

The ability to measure changes in streamflow, sediment, habitat features, or other aquatic parameters 

in response to the Saddle Lakes Timber Sale is limited due to the lack of baseline data, and the natural 

range of variability of these parameters in response to climate and other factors. Nonetheless, 

sufficient information is available for these watersheds to proceed with a credible comparison of the 

magnitude and extent of likely effects across alternatives. 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Aquatics - Chapter 3  239

Direct and Indirect Effects

Direct and indirect effects for all affected watersheds are estimated using surrogates for actual effects 

(e.g., stream crossings are a measure, or indicator, for increased sediment) as supported by the 

literature cited.

Effects Common to All Action Alternatives

Streamflow

Effects on streamflow in project watersheds may include an increase in annual water yield, increased 

peak flows, and altered timing of water delivery in small streams. Timber harvest causes changes in 

the collection, storage, and delivery of water in watersheds primarily by affecting evapotranspiration, 

canopy interception, cloud-water interception, snow accumulation and melt rates. Peak flow increases 

may be undetectable on the watershed scale when harvest levels are below 25 percent (Jones and 

Grant, 1996; Beschta et al., 2000). Recent literature suggests that for watersheds located in the raindominated zone peak flow increases are only detectable in flows with a return period of 6 years or 

less, and that effects of forest harvest on extreme flows cannot be detected using current technologies 

and data record lengths (Grant et al., 2008). Forest harvest effects are maximized in small watersheds, 

and diminish or remain constant with increasing watershed size. Further, when present, peak flow 

effects on channels should be confined to a relatively discrete portion of the channel network (Grant 

et al., 2008). 

Changes in water yield, peak flow, and timing of water delivery to channels for each alternative are 

difficult to measure and are likely to be undetectable, diminishing with time as a result of hydrologic 

recovery through vegetation regrowth. Changes in streamflow may occur based on cumulative harvest 

levels exceeding 29 percent (Grant et al., 2008). Only one of the watersheds would reach or exceed 

this level with implementation of Alternative 5 (Table 86). When water velocity slows down, either 

because of decreased gradient, or spreading out over a larger cross-sectional area, it tends to flatten 

out and extend the peak of a flood. For this reason, ES, PA, FP streams all tend to have higher 

‘storage’ (both water and sediment) function than the more contained, steeper, bedrock process groups 

which are characterized as transport streams. In addition, Carter (1996) said:

Wetlands associated with lakes and streams store floodwaters by spreading water out 

over a large flat area. This temporary storage of water decreases runoff velocity, reduces 

flood peaks, and distributes stormflows over longer time periods, causing tributary and 

main channels to peak at different times....A strong correlation exists between the size 

of flood peaks and basin storage (percentage of basin area occupied by lakes and 

wetlands) in many drainage basins throughout the United States (Tice, 1968; Hains, 

1973; Novitzki, 1979, 1989; Leibowitz and others, 1992). Novitzki (1979, 1989) found 

that basins with 30 percent or more areal coverage by lakes and wetlands have flood 

peaks that are 60 to 80 percent lower than the peaks in basins with no lake or wetland 

area. 

Upchuck Creek is vulnerable due to having steep headwater slopes draining into low gradient 

floodplain or palustrine channels. 

The method of harvest can also affect aquatic impacts. Helicopter logging generally creates fewer

disturbances to the soil structure when compared to conventional (cable or shovel) logging methods. 

Harvest prescriptions including single-tree selection, and those requiring a percentage of the available 

timber in a unit be retained may also help diminish the potential for increased peak flows to streams 

by lowering the intensity of the harvest treatment (Grant et al., 2008). Table 85 summarizes the 

percentage of uneven-aged prescriptions and helicopter clear cut logging by alternative. Effects to 

watershed hydrology and subsequent risk to downstream fisheries decrease with partial cutting. 
3 Affected Environment and Environmental Consequences

240  Chapter 3 – Aquatics Saddle Lakes Timber Sale Final EIS

Table 85. Logging system and silvicultural system with the least risks to aquatic habitat for the Saddle 

Lakes project area

Method/System

Acres of Harvest by Alternative

Alternative 2 Alternative 3 Alternative 4 Alternative 5 Alternative 6

Clearcut 129 171 774 921 530

Uneven-aged 

Management 589 27 148 61 185

Source: USFS Tongass National Forest FASTR data (January 8, 2014)

Roads may affect peak flows by intercepting shallow subsurface flows and leading it more rapidly to 

the stream network via ditches and culverts (Jones and Grant, 1996; Wemple and Jones, 2003). Harr 

et al. (1975) found peak flows increased significantly in a watershed with 12 percent of its area 

occupied by roads. The percentage of roads within the basin area is low in all project area watersheds 

with a total of 1.1 percent of the area of all watersheds as roads. Alternative 5 would increase this 

total percentage the most to 1.5 percent, with Alternatives 4 and 6 at 1.4 percent, and Alternatives 2 

and 3 at 1.3 percent. All action alternatives would increase the risk runoff generation and 

sedimentation from roads. Grant et al (2008) includes the influence of roads when they exceed 2

percent of basin area (Table 86).
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Saddle Lakes Timber Sale Final EIS Aquatics - Chapter 3  241

Table 86. Rain-dominated hydrologic zone scenario. Bolded cells indicate watersheds that reach 2 percent or more of basin area as roads in a given 

alternative. Bordered cells indicate watersheds that may experience detectable peak flow increase as a result of cumulative roads and harvest level.

7th HUC Watershed

(all in 1901010205)

Alt 1 (Existing 

Condition) Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

Size 

(acres)

Harvest 

Since 1984 

(%)

Basin Area Harvest Roads Exceed 2% of Basin Area / 

Detectable Peak Flow Increase

0305 (N. Saddle Lake) 5,879 9.0% 15.2% 11.3% 21.1% 23.3% 16.2% Roads > 2% in Alts 4 and 5, no peak 

flow increase

0307 (Twin Peaks) 815 8.6% 10.1% 9.9% 10.1% 10.1% 10.1% No/no

0308 (Gunsight Creek) 2,062 14.8% 20.1% 19.1% 22.4% 22.5% 22.4% Roads 2% in Alts 4, 5, and 6, no peak 

flow increase

0310 (Shelter Cove-A) 163 9.2% 18.4% 18.4% 18.4% 18.4% 18.4% No/no

0310 (Shelter Cove-B) 93 15.1% 23.7% 23.7% 23.7% 23.7% 23.7% Roads > 2% in all Alts, no peak flow 

increase

0310 (Shelter Cove-C) 194 5.2% 5.2% 5.2% 5.7% 5.7% 5.7% No/no

0901 (Hidden Lakes) 1,830 20.5% 25.4% 25.4% 26.6% 28.4% 25.4% Roads > 2% in all Alts, no peak flow 

increase

0503 (Buckhorn Lake) 3,441 5.6% 9.8% 7.2% 9.4% 9.8% 9.8% No/no

0504 (Road End) 2,469 9.9% 14.2% 14.1% 14.2% 14.2% 14.2% No/no

0510 (California Cove-C) 791 1.4% 4.7% 4.7% 4.7% 4.7% 4.7% No/no

0510 (California Cove-E) 2,375 14.7% 18.6% 15.1% 23.7% 26.9% 23.8% No/no

0602 (Lemon Lake) 1,560 14.2% 19.6% 17.8% 22.5% 22.5% 18.8% No/no

0603 (Big Salt Creek) 4,654 5.3% 6.4% 7.0% 7.4% 10.7% 7.4% No/no

0604 (Upchuck Creek) 938 18.0% 26.1% 23.5% 26.7% 32.9% 24.6% Roads > 2% in Alt 5, Alternative 5 

may increase peak flows by 12%

0605 (Rainbow Creek) 4,078 13.5% 19.4% 16.9% 23.0% 23.1% 22.4% Roads > 2% in all Alts, no peak flow 

increase

0606 (Salt Lagoon-C) 412 1.0% 8.7% 5.1% 8.7% 8.7% 8.7% No/no

Note: Acres are rounded to the nearest whole number and the percentages are rounded to the nearest tenth. Acres are adjusted for partial harvest.
3 Affected Environment and Environmental Consequences

242  Chapter 3 – Aquatics Saddle Lakes Timber Sale Final EIS

Sedimentation and Turbidity 

Each of the action alternatives relies on the existing road system, and all would require the 

construction of both new NFS and temporary roads, and reconditioning of existing NFS roads. Road 

construction would increase the percentage of each basin comprised of roads. 

All road construction would require the use of rock quarries. In general, a quarry is required for 

every 2 miles of new road built, and each quarry typically requires about 5 acres of clearing. 

Alternative 5 proposes the most miles of new road and would require an estimated sixteen quarries 

and 80 acres of clearing to build. Alternative 3 would require an estimated six quarries and 30 acres 

of clearing. 

All new and reconditioned NFS roads would be closed (except for Road 8300280) and all new 

temporary roads would be decommissioned at the end of the timber sale. Closed roads continue to 

receive minimal maintenance depending on their maintenance level. See the Transportation Resource 

Report for more information. Decommissioning activities on temporary roads would include the 

removal of all structures, restoring streams to their natural widths, installing waterbars, and other 

erosion control measures as needed. Decommissioning roads decreases the potential for sediment 

delivery to streams from the failure of drainage structures; however, these roads can still have longlasting effects to aquatic resources. Therefore, total road miles in each watershed were analyzed. Old 

road beds permanently influence the hydrology of the landscape and non-motorized use is allowed on 

decommissioned and closed roads.

In the action alternatives, proposed road construction would not exceed 2.5 percent of the basin area 

as roads (BAAR). In Alternative 5, Hidden Lakes has 2.4 percent BAAR, Rainbow Creek has 2.3 

percent, and North Saddle Lake has 2.2 percent BAAR proposed. Alternative 5 proposes the most 

new miles of road in each watershed, and would likely create the greatest amount of sediment and 

turbidity. However, given the relatively small increase of sediment and turbidity and proper 

application of Forest Plan Standards and Guidelines and BMPs during implementation, the effects 

would not be measurable.

All action alternatives would increase the number of crossings on Class II and III streams (Table 87). 

Alternative 5 proposes the greatest total number of Class II and III crossings, but has the most 

crossings that would be decommissioned post-project. There are no proposed crossings on Class I 

streams in the project area. Risk of sediment delivery to streams is higher at road crossings due to the 

lack of vegetation buffers at the interface. All crossings on proposed road segments would undergo 

additional verification by Forest Service personnel prior to implementation of any action alternative. 

Table 87. Road-stream crossings by alternative and stream class in affected watersheds

Stream 

Class

Alternative 2 Alternative 3 Alternative 4 Alternative 5 Alternative 6

NFS Temp NFS Temp NFS Temp NFS Temp NFS Temp

I 0 0 0 0 0 0 0 0 0 0 

II 6 1 1 0 6 2 7 3 7 1 

III 1 1 2 1 8 4 8 4 6 2 

Source: USDA Tongass National Forest GIS

Notes: NFS = National Forest System road; Temp = temporary road
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Aquatics - Chapter 3  243

Road cards describe road management objectives, construction timing restrictions, and the locations 

of all new stream crossings on NFS roads. Unit cards also discuss temporary roads. Road and unit 

cards are located in the project record.

Removal of trees within 200 feet of NFS roads (for constructing log stringer bridges, expanding 

existing rock quarries, and constructing new rock quarries) would be addressed by applying Forest 

Plan Standards and Guidelines and BMPs. A quarry development plan would be reviewed prior to 

development of new rock quarries. 

Each of the action alternatives increase landslide potential, with relative risk related to the amount of

proposed even-aged (clearcut) harvest acres on soils with slopes over 72 percent. Effects are difficult

to quantify since landslides may or may not occur in conjunction with timber harvest or road 

building activities. Alternatives 4 and 5 propose the most harvest acres on slopes greater than 72 

percent; however, only 123 and 163 acres respectively out of 4,441 acres are proposed on slopes 

greater than 72 percent. Only two of these acres are near a stream system, located in the Salt Lagoon 

watershed; these acres are roughly 500 feet from a Class III stream channel. These acres are 

proposed in the Calamity Creek and Salt Lagoon watersheds. See the Soils report for more detail 

regarding mass movement events within the project area boundary. 

Effects from modifying the natural barrier on lower Salt Creek (ADF&G Anadromous Catalog # 101-

45-10380) would include short-term sediment delivery downstream.

Watershed-wide effects of the short-term sediment delivery from these activities are not expected to 

degrade Alaska State Water Quality Standards (ADEC, 2008). Erosion control plans would be 

developed before construction to minimize or mitigate erosion, sedimentation, and resulting water 

quality degradation (BMP 14.5). 

Stream Temperature

The risk of changes to stream temperature is low, and would likely be site-specific, resulting from 

potential landslides or debris flows. Because watersheds with harvest have been linked to increases in 

stream temperatures (Pollock et al. 2009), there exists the possibility of higher temperatures on 

discrete portions of streams, especially with regard to Alternative 5 as it proposes the most acres of 

clear cut harvest, including three openings greater than 100 acres in size.

Riparian buffers provide protection from non-point-source pollution, help maintain stream 

temperature by reducing solar radiation, and maintain riparian and aquatic habitat. Harvest in units 

which contain Class IV streams or are adjacent to Class III streams flowing downstream into Class 

I/II fish-bearing streams could result in slight short-term increases in stream temperature. However, 

these effects would not likely be measurable given the overall size of the drainage basins into which 

the streams flow.

Aquatic Habitat

All Class I and Class II streams that flow directly into Class I streams are protected from harvest 

activities within a minimum horizontal distance of 100 feet from the bankfull margins (see TTRA).

Riparian buffer widths in excess of 100 feet are determined based on the stream process group 

classification. Forest Plan Standards and Guidelines provide for the protection of riparian buffers on 

all fish-bearing and Class III streams through designation of riparian management areas (RMAs). 

RMAs are designed to protect riparian zone interactions between streams, floodplains, riparian 

wetlands and uplands (Paustian, 2004). RMAs are mapped in GIS according to a buffering routine 

where RMA widths are assigned to each process group stream segment (see unit card narrative in 

project record), and riparian polygons delineated by soil types and wetland plant communities 
3 Affected Environment and Environmental Consequences

244  Chapter 3 – Aquatics Saddle Lakes Timber Sale Final EIS

(Paustian, 2004). These GIS-generated RMAs can be queried for planning purposes, with final RMA 

buffer widths determined by site-specific assessment of riparian vegetation and soils, extent of the 

flood-prone width, occurrence of secondary flood plain channels, topography, and other indicators. 

RMA buffers reduce the risk of increased stream temperatures through shading provided by the 

riparian vegetation. 

Protection and maintenance of naturally functioning aquatic ecosystems from ground-disturbing 

activities associated with timber harvest is provided through application of RMA buffers. RMA noharvest buffers on Class I, II, and III streams would avoid direct impacts to aquatic habitat from 

timber harvest. Effects would be negligible for sediment and limited to those road/stream crossing

locations due to the potential for culverts to become plugged with sediment and debris. Increased 

sediment effects can also be associated with watersheds containing 2.5 percent or greater basin area in 

roads (Cederholm et al. 1980). None of the affected watersheds in the project area would reach this 

level of road area under any of the alternatives (Table 88).
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Saddle Lakes Timber Sale Final EIS Aquatics - Chapter 3  245

Table 88. Percentage of basin area as roads by alternative

Alt 1 (Existing 

Condition) Alt 2 Alt 3 Alt 4 Alt 5 Alt 6

7th HUC Watershed (all 

in 1901010205) Miles1 % Basin as 

Roads2 Miles % Basin as Roads Miles % Basin as Roads Miles % Basin as Roads Miles % Basin as Roads Miles % Basin as Roads

0305 (N. Saddle Lake) 15.93 1.3% 19.1 1.6% 19.58 1.6% 26.08 2.2% 26.77 2.2% 21.84 1.8%

0307 (Twin Peaks) 1.78 1.1% 1.9 1.1% 1.78 1.1% 1.89 1.1% 1.9 1.1% 1.9 1.1%

0308 (Gunsight Creek) 7.33 1.7% 7.58 1.8% 7.84 1.8% 8.35 2.0% 8.35 2.0% 8.35 2.0%

0901 (Hidden Lakes) 7.01 1.9% 8.01 2.1% 9 2.4% 8.01 2.1% 9.01 2.4% 8.01 2.1%

0504 (Road End) 5.88 1.2% 7.56 1.5% 8.81 1.7% 7.38 1.4% 7.56 1.5% 7.56 1.5%

0503 (Buckhorn Lake) 5.21 0.7% 7.19 1.0% 5.46 0.8% 6.8 1.0% 7.19 1.0% 7.19 1.0%

0510 (California Cove-C) 2.39 1.5% 2.55 1.6% 2.55 1.6% 2.55 1.6% 2.55 1.6% 2.55 1.6%

0510 (California Cove-E) 5.53 1.1% 6.68 1.4% 5.71 1.2% 8.66 1.8% 8.66 1.8% 8.66 1.8%

0602 (Lemon Lake) 2.71 0.8% 3.25 1.0% 3.25 1.0% 4.04 1.3% 4.04 1.3% 3.25 1.0%

0603 (Big Salt Creek) 5.38 0.6% 6.83 0.7% 7.53 0.8% 7.67 0.8% 8.01 0.8% 7.67 0.8%

0604 (Upchuck Creek) 2.4 1.2% 3.31 1.7% 3.39 1.8% 3.67 1.9% 4.01 2.1% 3.35 1.7%

0605 (Rainbow Creek) 14.32 1.7% 17.59 2.1% 17.2 2.0% 19.38 2.3% 19.38 2.3% 19.29 2.3%

0606 (Salt Lagoon-C) 0.15 0.2% 0.86 1.0% 0.59 0.7% 0.86 1.0% 0.86 1.0% 0.86 1.0%

TOTAL 76.02 1.2% 92.41 1.4% 92.69 1.4% 105.34 0.8% 108.29 1.7% 100.48 1.6%

This table includes the additional road miles proposed by DOT for a road extension in Salt Lagoon, 0603.

Percent Basin as Roads calculated as: {[Existing road miles * 5,280ft/mi*40ft (assumed clearing width) / 43,560 ft2/acre] / watershed size (acres)} * 100

1 Acres rounded to nearest whole number 

2 Includes all roads, regardless of ownership, type, or operational maintenance level
3 Affected Environment and Environmental Consequences

246  Chapter 3 – Aquatics Saddle Lakes Timber Sale Final EIS

Road crossings on Class I and II streams can directly affect fisheries resources. Effects to these 

resources would be minimized by following the BMPs during installation. Table 87 summarizes 

proposed road-stream crossings by alternative.

Increased peak flows can potentially result in wider channels for a given drainage area (Grant and 

Swanson 1990, Dose and Roper 1994, Jones and Grant 1996). Such conditions can affect stream 

temperature, as well as pool quantity and quality. According to Grant et al. (2008), data suggest that 

peak flow effects would likely be confined to relatively small portions of the stream network 

downstream of the harvest activity in areas where the channel gradient is less than approximately 2 

percent. This, specifically, would include Class I reaches with the floodplain and palustrine process 

group designation. These process groups account for approximately 21 miles of stream. Upchuck 

Creek is vulnerable to effects due to steep headwaters draining into floodplain channels. 

Units with increased risk of windthrow have been identified and would receive consideration for 

reasonable assurance of windfirmness (RAW) buffers during unit layout using Landwehr (2007) 

RAW guidelines. The most recent monitoring of effectiveness of windfirm buffers, on the Tongass, 

indicated post-harvest windthrow was present to some degree in 55 percent of the 262 monitoring 

sites with a mean of 6.7 percent and a median of 0.8 percent (USDA Forest Service 2012). Windthrow 

mortality within the buffers was highly variable, ranging 0 to 85 percent, with 74 percent of the 

buffers having less than 5 percent cumulative windthrow mortality (USDA Forest Service 2012). 

Minimal amounts of windthrow in riparian management areas (RMAs) surrounding harvest units may 

occur in each action alternative. In the Saddle Lakes project area, prevailing storm winds are from the 

south, with areas exposed to Carroll and George Inlets and ridges that funnel wind experiencing 

stronger winds.

Implementation of BMPs and Forest Plan Standards and Guidelines has been shown to provide 

protection through RMA buffers and sedimentation mitigations that:

• Maintain natural and beneficial quantities of large woody debris over the short-term and longterm.

• Maintain stream banks and stream channel processes.

• Provide for the beneficial uses of riparian areas by maintaining water quality.

Lakes and ponds account for 2.8 percent of project area watersheds (Table 82). These bodies of water 

are assigned class designations like streams and receive similar consideration during unit layout. 

There would be negligible effects to lake and pond habitat due to lake riparian buffers and 

implementing Forest Plan Standards and Guidelines and BMPs.

Fish Passage

Effects to fish passage are assumed to be site-specific and related primarily to road crossings, but may 

also be affected by the increased risk of landslides due to timber harvest and road building. Effects of 

the proposed activities to fish passage are considered minor since culvert installation on proposed fish 

crossings would be conducted in accordance to Forest Plan Standards and Guidelines and BMPs, and 

provide fish passage as outlined on the road cards. 

Fish Passage Barrier Modification

A fish passage barrier modification at lower Salt Creek (ADF&G Anadromous Catalog # 101-45- 

10380), is proposed to improve access for coho salmon and steelhead to about 5 miles of upstream 

habitat and 139 acres of lake habitat. The 60 foot long cascade is located 0.25 mile above the 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Aquatics - Chapter 3  247

intertidal zone in T. 73 S., R. 92 E., Section 17 of the Copper River Meridian (CRM), and is about 12 

feet in vertical height, consisting of two separate falls of 5.5 and 6.5 feet respectively. Coho salmon 

and steelhead can pass this natural partial barrier only at certain flows. Modifying these falls would

allow adult coho salmon and steelhead to better pass these falls over a wider range of flow conditions.

It is possible that a small amount of sediment may enter the stream during blasting operations;

however this will be temporary and short in duration. Common methods to minimize and mitigate the 

impacts of blasting on fish and fish habitat will be implemented following BMPs and ADF&G 

Blasting standards IHP-13-051 (2013) which will further minimize effects to fish and the aquatic 

ecosystem during blasting operations. 

Marine Environment

Log Transfer Facility and Road Building

The marine waters in George and Carroll Inlets are likely to be affected by reconstruction and use of 

the Leask and Shelter Cove LTFs.

Rebuilding the bulkhead during LTF reconstructions may cause an increase in sediment but these 

effects would be localized to the project area and limited to the duration of work. In addition, Forest 

Plan Standards and Guidelines and BMPs further reduce the likelihood of effects to essential fish 

habitat or the marine environment during construction activities. 

The potential effects on the marine environment from use of LTFs during timber operations include 

diminished habitat for managed species and their prey from bark accumulation and reduced rearing

capability for juvenile salmon from potential water quality impacts (Eagleton, et al. 2011). In areas 

dominated by bark accumulation, species richness may be significantly reduced (Kirkpatrick, et al. 

1998). Sediment and hazardous materials control measures would be included in the design to 

minimize effects on water quality, and BMPs 12.8 (oil pollution prevention and servicing/refueling 

operations), 12.9 (oil and hazardous waste contingency planning), 12.16 (control of solid waste 

disposal), and 14.26 (log storage/sort yard erosion control) would be implemented. LTF/log rafting 

activities will adhere to the APDES permit requirements. Dive surveys will follow the permit

requirements and likely occur before and after the project. Negligible impacts to the marine 

environment are expected from any of the proposed LTF/log rafting activities. The effects are likely

to be limited in both quantity and distribution as most activities and spills would be on-shore having 

only localized effects to nearshore fish and fish food resources from runoff to the marine 

environment. Please refer to the Essential Fish Habitat Assessment for more detailed analysis of

effects to the marine environment. 

Alternative 1

Alternative 1 would have no direct or indirect effects to aquatic resources. Existing conditions would 

remain the same. Post-harvest vegetation recovery would continue in all watersheds. Selection of this 

alternative would not preclude regular maintenance of existing roads, including erosion control 

measures and removal or replacement of culverts. Sediment delivery to streams from periodic road 

maintenance and ongoing use of existing roads is expected to be minor and within water quality 

standards set by the State of Alaska.

Alternative 2

Alternative 2 would not have any watershed surpass the 29 percent basin area harvest in 30 years or 

2.5 percent basin as roads. Road construction would result in an additional ten stream crossings, with 

seven located on Class II streams. Under this alternative, about 48 percent of the harvest in project 

area watersheds is even-aged (clearcut), of which 4 acres are on slopes greater than 72 percent. 
3 Affected Environment and Environmental Consequences

248  Chapter 3 – Aquatics Saddle Lakes Timber Sale Final EIS

Of the action alternatives, Alternative 2 would generate the second least amount of sedimentation to 

aquatic habitat; and has the second least likelihood of affecting streamflow and stream temperature.

Alternative 3

Alternative 3 would not have any watershed surpass the 29 percent basin area harvest in 30 years or 

2.5 percent basin as roads. Road construction would result in an additional five stream crossings, with 

one located on a Class II stream. Under this alternative, about 81 percent of the harvest in project area 

watersheds is even-aged (clearcut), of which, 4 acres are on slopes greater than 72 percent. 

Of the action alternatives, Alternative 3 would generate the least amount of sedimentation to aquatic 

habitat; and has the least likelihood of affecting streamflow and stream temperature.

Alternative 4

Alternative 4 would not have any watershed surpass the 29 percent basin area harvest in 30 years or 

2.5 percent basin as roads. Road construction would result in an additional 23 stream crossings, with 

eight being located on Class II streams. Under this alternative, about 87 percent of the harvest in 

project area watersheds is even-aged (clearcut), of which 12 acres are on slopes greater than 72 

percent. 

Of the action alternatives, Alternative 4 would generate the second greatest amount of sedimentation 

to aquatic habitat; have the second highest likelihood of affecting streamflow and stream temperature.

Alternative 5

Alternative 5 would have one watershed, Upchuck 0604 surpass 29 percent basin area harvest in 30 

years but no watersheds would surpass 2.5 percent as roads. Hidden Lakes comes close under 

Alternative 5 at 2.4 percent basin as roads. Road construction would result in an additional 25 stream 

crossings, with 10 being located on Class II streams. Under this alternative, about 90 percent of the 

harvest in project area watersheds is even-aged (clearcut), of which 12 acres are on slopes greater 

than 72 percent. 

Compared to other action alternatives, Alternative 5 would generate the greatest amount of 

sedimentation to aquatic habitat due to the highest amount of new road construction, and has the 

highest likelihood of affecting streamflow and stream temperature because it proposes the most acres 

of clear cut harvest, including the proposal for three openings greater than 100 acres in size. 

Alternative 6

Alternative 6 would not have any watershed surpass the 29 percent basin area harvest in 30 years or 

2.5 percent basin as roads. Road construction would result in an additional 13 stream crossings, with 

eight being located on Class II streams. Under this alternative, about 77 percent of the harvest in 

project area watersheds is even-aged (clearcut), of which 4 acres are on slopes greater than 72 

percent. 

Of the action alternatives, Alternative 6 would generate the third-greatest amount of sedimentation 

to aquatic habitat; have the third highest likelihood of affecting streamflow and stream temperature. 

Cumulative Effects

For the cumulative effects analysis, the 6th-level HUC watersheds are broken down further into 

smaller 7th-level HUC basins to include the shoreline where watersheds (frontal watersheds) span 

inlets and waterways to include other land masses. Cumulative percent basin harvest over time is 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Aquatics - Chapter 3  249

determined by using the 7th-level HUC watershed designation. Results are then evaluated to 

determine if there has been detectable peak flow increases attributable to past harvest. 

Appendix B includes the interrelated projects (i.e., past, present and reasonably foreseeable future 

actions) that have been considered in the aquatics cumulative effects analysis.

Cumulatively, there is a general trend toward recovery of slope stability and pre-harvest rates of 

canopy interception and evapotranspiration rates in all of the watersheds due to vegetation regrowth 

since the 1990s. As of this report, about 624 acres have been harvested within the project area during 

the past decade (GIS data), with the latest harvest occurring in 2011 in the Calamity Creek-Frontal 

Carroll Inlet watershed.

Cumulative Effects Common to all Action Alternatives

Cumulative effects to aquatic resources from the majority of the past, present, and reasonably 

foreseeable future actions listed in Appendix B would be negligible for all action alternatives due to

their small scope and scale, however three of these actions are larger and are discussed further below.

The cumulative effects of past and proposed timber harvest are similar among all action alternatives. 

Each of the action alternatives would increase cumulative harvest levels from current levels in all 

watersheds. Calamity Creek watershed would have the highest cumulative percent harvest, followed 

by Salt Lagoon watershed. 

Cumulative changes would include water yield, peak flow, stream temperature, and timing of water 

delivery to channels for each Alternative. These changes are difficult to measure and are likely to be 

undetectable, diminishing with time as a result of hydrologic recovery through vegetation regrowth. 

For most watersheds, cumulative effects from past timber harvest are considered negligible.

The AMHT Land Exchange could remove 8,170 acres of land from Forest Service management, 

BMPs and standards and guidelines protection measures within this area. The following watersheds 

lay within or downstream from the proposed land exchange area: Shelter Cove-A, Gunsight Creek, 

Rainbow Creek, Twin Peaks, North Saddle Lake, Salt Lagoon-B, Up Chuck Creek, Big Salt Creek, 

Salt Lagoon-A, Salt Lagoon-C, George Inlet-B, and hidden Lakes. Effects to these watersheds would 

be dependent on the type of activities that occur after land exchange.

The proposed Ketchikan to Shelter Cove Road connection could increase traffic resulting in 

increasing sediment delivery potential. The road would need to be maintained and resurfaced more 

often to minimize sediment delivery to streams and erosion. 

Alternative 1

Because there are no direct or indirect effects from Alternative 1, no cumulative effects would occur. 

Ongoing road and trail maintenance activities are expected to improve or sustain watershed hydrology 

conditions in the long-term by maintaining drainage efficiency through crossing structures, thereby 

minimizing sources of stream sedimentation. The risk of landslides associated with previously-built 

roads is ongoing and considered a potential indirect effect of past management activities, because if 

landslides do occur, they may or may not deliver sediment into streams. 

Alternative 2, 3, 4, 5, and 6

See Cumulative Effects Common to all Action Alternatives. 
3 Affected Environment and Environmental Consequences

250  Chapter 3 – Aquatics Saddle Lakes Timber Sale Final EIS

Essential Fish Habitat Assessment 

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 and 

proposed actions that may adversely affect essential fish habitat (EFH) for federally managed marine 

and anadromous fish species. The Act promotes the protection of essential fish habitat through 

review, assessment, and mitigation of activities that may adversely affect these habitats. EFH 

consultation has been combined with the Forest Service NEPA process. 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 as of June 28, 2012, consultation is still required 

under the Act and the 2007 procedures remain applicable and have been followed for this 

Assessment.

Federally managed fish species are those under the jurisdiction of the North Pacific Management 

Council, managed by the NMFS, and included in a fishery management plan (FMP). These common 

managed species include the salmon species: Chinook, chum, pink, coho, and sockeye salmon, as 

well as walleye Pollock, Pacific cod, arrowtooth flounder, yellowfin, rock, rex sole, dover and 

flathead sole, Alaska plaice, sablefish, Pacific Ocean perch, shortraker, rougheye, northern, 

thornyhead, yelloweye, dusky rockfish, sculpin, skates, squid, octopus, forage fish, and weathervane 

scallop. Several common species not managed under FMP include halibut, ling cod, Pacific herring, 

Dungeness crab, cutthroat trout, steelhead, and Dolly Varden char. 

EFH is the water and substrate necessary for fish spawning, breeding, feeding, or growth to maturity. 

Freshwater EFH includes streams, rivers, lakes, ponds, wetlands and other bodies of water currently 

and historically accessible to salmon. Marine EFH in Alaska includes estuarine and marine areas from 

tidally submerged habitat to the 200-mile exclusive economic zone. 

EFH for Pacific salmon recognizes six critical life history stages: (1) spawning and incubation of 

eggs, (2) juvenile rearing, (3) winter and summer rearing during freshwater residency, (4) juvenile 

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

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

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

For the Saddle Lakes project area this would include the low-gradient reaches of Calamity CreekFrontal Carroll Inlet, Marble Creek-Frontal Carroll Inlet, George Inlet-Frontal Carroll Inlet, and 

Salt Lagoon. It also includes the marine environment adjacent to the Shelter Cove Log Transfer 

Facility (LTF) located in Carroll Inlet.

Direct and Indirect Effects

All action alternatives have potential to impact EFH. Proposed road construction and road crossings 

could indirectly affect downstream Class I EFH. 

Approximately 47 miles of Class I streams have been identified in the five watersheds of the Saddle 

Lakes Timber Project. Populations of State and federally managed species of pink, chum, coho, and 

sockeye salmon occur within the project area (ADF&G Anadromous Waters Catalog 2013). 

Freshwater life stages of pink, chum, coho, and sockeye salmon could be affected by the Saddle 

Lakes project. These life stages include: freshwater eggs; freshwater larvae and juveniles; estuarine 

juveniles; and freshwater adults. 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Aquatics - Chapter 3  251

There will likely be some sediment input to lower Salt Creek during blasting operations at the partial 

barrier falls but this will be small in scale and short in duration, clearing up quickly. The temporary 

addition of sediment to Salt Creek is offset by the long term benefit to coho salmon and steelhead. 

New proposed crossings of Class II and III streams could indirectly affect downstream Class I EFH; 

no new Class I stream crossings areproposed. Construction of new, reconditioned, and temporary roads 

varies by alternative and can also affect EFH in the project area. Potential effects on freshwater EFH 

include changes in water yield, peak flow volume and timing of flow delivery, sediment delivery, 

altered riparian vegetation (Class IV streams and the new road-stream crossings), and fish passage at 

road crossings. More thorough descriptions of road types can be found in the Transportation section. 

Potential Adverse Effects on Marine EFH 

Potential adverse effects on marine EFH include the Leask and Shelter Cove LTF reconstruction and 

bark deposition. The accumulation of bark and other woody debris on the ocean floor associated with 

the transfer and storage of logs can impact marine habitats by smothering organisms or creating 

unfavorable water quality conditions. All necessary federal or State permits would be obtained prior 

to any work for the reconstruction of the LTF. The Transportation section in this chapter discusses the 

LTF in more detail. Alternative 5 could have the greatest accumulation of bark and other woody 

debris because it would generate the highest volume of transferred logs.

The marine waters in Carroll Inlet are the only marine waters likely to be affected by the Saddle 

Lakes Timber Sale. It is expected that Shelter Cove will be used exclusively under all alternatives to 

transfer logs to water for rafting or barging to another processing location. All logs along the road 

system associated with action alternatives are being appraised to the Shelter Cove LTF. Export logs 

are being appraised to the Leask Cove LTF, but for the purposes of this analysis, it is being assumed 

logs will be hauled to the Shelter Cove LTF. The Transportation section in this chapter discusses all 

LTF options in more depth. 

Rafting logs involves constructing small rafts in front of the LTF and towing them to a temporary 

staging area off shore. These small rafts are combined to form large rafts that are then towed to the 

mill. A staging area is needed because large rafts cannot be towed through channels, bays and fjords 

due to impacts on navigation. An Alaska Pollutant Discharge Elimination System Program (APDES) 

permit must be obtained from Alaska Department of Environmental Conservation (ADEC) to stage 

rafts if the timber sale operator chooses to raft and tow logs.

Activities with potential for spills of hazardous materials such as fuel require Spill Prevention, 

Control and Countermeasure plans (SPCC). Forest Service environmental engineers will review all 

SPCC plans prior to any petroleum products being on site. These plans must comply with all State 

and Federal laws and permits. LTFs, sort yards, and fuel storage areas must also comply with all 

applicable BMPs.

No impacts to the marine environment are expected from any of the proposed NFS or temporary 

roads. All roads are located away from the marine environment and applicable BMPs will be 

implemented to minimize effects to water quality and aquatic habitat, however there is a potential for 

minor effects to the marine environment from LTF/log rafting activities. 

Marine benthic habitats dominated by bark accumulation support fewer and less abundant marine 

species. These bark accumulations can persist for up to 26 years (Kirkpatrick et al, 1998). APDES 

permit requirements limit bark accumulation depth to less than 10cm where coverage is continuous 

(100 percent) for more than 1 acre. The last dive associated with the Shelter Cove Tideland Lease was 

completed in 2009 and bark accumulation was 0.24 acre of continuous bark debris and 0.48 acres of 
3 Affected Environment and Environmental Consequences

252  Chapter 3 – Aquatics Saddle Lakes Timber Sale Final EIS

discontinuous bark debris. The Shelter Cove LTF is owned and permitted by the Forest Service. It is 

in need of reconstruction due to its exposure to seawater and teredo worms (Teredo navalis). The 

existing native log bulkhead will be replaced in kind, or a less expensive low angle ramp may be 

constructed, depending on the transport method chosen by the timber purchaser. Work would be 

conducted during the normal operating season, typically May through October, and would have to be 

timed with low and extreme low tides. Because of the necessary tidal timing, work may take up to 6-8 

weeks to complete construction of the new bulkhead. Whether a new bulkhead or a low angle ramp is 

constructed, work will be conducted within the existing disturbed areas. Work may include the 

following: 

• Excavation and removal of existing rock and bulkhead. Excavation would be sloped inland at an

angle to provide a safe work area and to minimize material from raveling into the marine

environment.

• End haul of any unsuitable material to an approved location.

• Old log bulkhead will be placed in an approved location. Removal of other waste material would

be the responsibility of the contractor.

• Haul of borrow material from existing pits if additional material is needed.

• Assembly of log crib, backfill, compaction, and placement of geotextiles.

All necessary federal or State permits will be obtained prior to any work for the reconstruction of the 

LTF. Whether a new bulkhead or a low angle ramp is constructed and if logs are to be watered, all 

logs or log bundles will have a soft entry into the water.

Past surveys at the Leask Cove LTF noted the substrate changed from boulder to sand dominant at 

about 30 meters from the mean high tide line. Barnacle and rockweed were the most abundant 

species present; however, the overall diversity and abundance of organisms was low. Bark residues 

at 40 meters from the mean high tide line were observed and appeared to continue with depth. Bark 

accumulations on the surveyed site were not of a depth or extent to be considered problematic. Divers 

also noted a narrow band of eelgrass (<10 meters wide) running the length of the project area but the 

growth was relatively sparse. In contrast, eelgrass beds at the mouth of Leask Creek appeared to be 

extensive and dense. The Clean Water Act section 404(b)(1) guidelines consider eelgrass a special

aquatic species because it provides habitat for a large number of marine species as well as providing

important feeding and cover for juvenile salmon. 

The following lists a number of fish species that may be found in the marine environment and their 

life stages that could be affected by the use of the LTFs for the Saddle Lakes timber sale. Marine 

species potentially affected by the Saddle Lakes project include:

Arrowtooth flounder (Atheresthes stomias), Atka mackerel (Pleurogrammus monopterygius), Dover 

sole (Microstomus pacificus), flathead sole (Hippoglossoides elassodon), Pacific cod (Gadus 

macrocephalus), Pacific ocean perch (Sebastes alutus), rex sole (Glyptocephalus zachirus), rock sole 

(Lepidopsetta bilineatus), sablefish (Anoplopoma fimbria), sculpin (Cottidae family), 

shortraker/rougheye rockfish (Sebastes borealis), skates (Rajidae family), squid (Cephalopoda class), 

walleye pollock (Theragra chalcogramma), weathervane scallops (Patinopecten caurinus), yelloweye 

rockfish (Sebastes ruberrimus), yellowfin sole (Limanda aspera). 

In addition, salmon species include pink, chum, coho, and sockeye which could be affected during 

estuarine juvenile, marine juvenile, marine immature and maturing adult stages. The potential effects 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Aquatics - Chapter 3  253

on marine EFH by rafting logs include diminished habitat for managed species and their prey, as well 

as reduced rearing capability for juvenile salmon from potential water quality impacts. 

Primary prey items for the following species are based on the Gulf of Alaska Fishery Management 

Plan (NPFMC 1998): 

• Sablefish feed throughout the water column. Larval sablefish feed on a variety of zooplankton.

Juveniles feed primarily on macrozooplankton and euphausiids. Adults are opportunistic feeders.

Their main diet is other fish, including salmon fry and Pollock. Other food includes benthic

invertebrates, squid, jellyfish, and fishery discards.

• Sculpins mainly feed near the bottom. Prey items include crabs, barnacles, and mussels. Larger

sculpins eat fish.

• Adult chum, sockeye, coho and pink salmon are primarily fish eaters, although pelagic

crustaceans and squid are also consumed (with the exception of chum), particularly by pink

salmon. Juvenile salmon consume plankton and small crustaceans.

• Arrowtooth flounder feed in gravel-mud substrates near the seafloor. Adults feed on other

groundfish. Juveniles feed on euphausiids, crustaceans, amphipods, and young pollock. Larvae

feed on phytoplankton and zooplankton.

• Pacific cod are omnivorous. Adult cod feed mostly on other fish such as walleye pollock,

yellowfin sole, and fisheries discard. Young cod feed mostly on invertebrates such as amphipods,

crangonid shrimp, polychaete worms, and bivalves.

• Skates feed on bottom invertebrates (crustaceans, mollusks, polychaetes) and fish.

• Walleye pollock feed throughout the water column on copepods, euphausiids, young pollock, and

other fish.

• Yelloweye rockfish eat primarily fish including other small rockfish, herring, sandlance, as well

as caridean shrimp, small crabs, and lingcod eggs.

• Shortraker and rougheye rockfish feed primarily on shrimp, squids, and myctophids. Juveniles

feed on shrimp and amphipods.

• Pacific ocean perch are overwhelmingly planktivorous, and may eat small shrimp and squids.

Juveniles eat mostly calanoid copepods and euphausiids.

Primary prey items for the following species are based on the Alaska Fisheries Science Center NOAA 

website:

• Atka mackerel are a schooling semi-demersal fish. Juveniles and adults eat mainly copepods and

euphausiids, but have been known to eat shrimp, gastropods, annelids, and fish eggs and larvae.

• Rock sole eggs are adhesive and are laid on the bottom of the ocean. The larvae that hatch

consume small zooplankton until they metamorphosis into juveniles. Juveniles are abundant in

shallow, near-shore waters and feed on polychaetes and small crustaceans. Adult continue to eat

small invertebrates throughout their lives.

• Yellowfin sole adults exhibit a benthic lifestyle and occupy separate winter spawning and

summertime feeding distributions feeding mainly on benthic infauna and epifauna, euphausiids,

and fish.

• Flathead sole adults exhibit a benthic lifestyle and occupy separate winter spawning and

summertime feeding distributions with their diet composed primarily of organisms living on the
3 Affected Environment and Environmental Consequences

254  Chapter 3 – Aquatics Saddle Lakes Timber Sale Final EIS

bottom (epibenthic) and pelagic organisms in close association with the bottom (nektobenthic). 

Flathead sole less than 30 cm total length consumed mainly mysids, gammarid amphipods, and 

decapod shrimps, whereas flathead sole larger than 30 cm total length consumed mainly 

ophiuroids, walleye pollock, and decapod shrimps. 

• Rex sole feed almost exclusively on benthic invertebrates. Small (<15 cm SL) rex sole feed

mainly on amphipods and other crustaceans. Large (15-45 cm SL) rex sole prey chiefly on

polychaetes. Rex sole <20 cm SL prey primarily on euphausiids, decapod crab larvae, copepods,

Oikopleura, and ostracods. Mollusks form only a minor part of rex sole diet. Euphausiids are

principal prey only during summer and cumaceans and Oikopleura are more common during the

winter.

• Dover sole feed almost exclusively on benthic infaunal and epifaunal invertebrates, mainly

polychaetes, ophiuroids, and mollusks. Amphipods are important crustacean prey and pelecypods

make up the most molluskan biomass consumed. Annelids are usually dominated in the diet of

juvenile Dover sole.

Water quality effects include increased risk in fuel spills from equipment used for barge loading, 

increases in sediment levels from increased road use, and bark leachates and shading beneath log rafts 

and equipment floats. The effects are likely to be limited in both quantity and distribution as most 

activities and spills would be on-shore having only localized effects to near-shore fish and fish food 

resources from runoff to the marine environment. Following the best current direction, logs are 

proposed to be transported to Shelter Cove MAF via the road system and then barged around the end 

of the island to Leask Cove LTF. Barging logs instead of rafting them would have fewer effects on 

marine species. 

Consultation

The four main steps in the consultation process are the following:

• The Forest Service determines if the proposed action will have “no adverse effect” or if it “may

adversely affect” EFH. Only the “may adversely affect” determination triggers consultation.

• An EFH Assessment is prepared by the Forest Service as a component of the NEPA and

forwarded to the NMFS to initiate formal consultation.

• The NMFS will respond in writing as to whether it concurs with the conclusion in the EFH

Assessment and may provide conservation recommendations to further minimize effects of the

action on EFH.

• The Forest Service must provide a written response to NMFS within 30 days explaining its

evaluation of the conservation recommendations. The response may include reasons for not

following the recommendation.

The formal consultation begins when NMFS receives a copy of the draft environmental impact

statement (DEIS) with the EFH Assessment. Documentation of the consultation process, including a 

summary of how EFH may or may not be adversely affected and the consultation requirements have 

been satisfied is included in the FEIS. The ROD will contain a summary of the EFH consultation 

conclusions. 

This EFH Assessment satisfies the requirements by providing: (1) a description of the proposed 

action; (2) an analysis of the potential adverse effects of the action on EFH and the managed species; 

(3) the Forest Service’s conclusions regarding the effects of the action on EFH; (4) a discussion of 

proposed mitigation, if applicable.
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Saddle Lakes Timber Sale Final EIS Aquatics - Chapter 3  255

EFH Effects Determination

The Forest Service determines that the Saddle Lakes project may adversely affect freshwater and 

marine EFH for the following reasons:

• The project entails ground disturbing actions (i.e. timber harvest and road construction, including

fish bearing stream crossings) in watersheds that contain anadromous species.

• Log hauling will occur on existing roads that cross anadromous fish streams.

• Log transfer would occur at facilities in the proximity of marine waters and inter-tidal habitats.

• Blasting operations on the partial barrier at Salt Creek Falls would have a temporary input of fine

sediment immediately following blasting operations.

• Unforeseen events such as landslides, debris blockages of culverts, fuel spills, and road failures.

The Forest Service will ensure that adverse effects to EFH would be minimized through 

implementation of the following measures:

• All Class I and II streams within the project area will be protected by a no-harvest buffer

(RMA) of 100 feet or more (unit cards describe site-specific activities).

• All Class III streams will be protected by no-harvest buffers to the top of the side slope (v-notch)

according to the Forest Plan. This minimizes the potential impact to downstream EFH .

• Additional precautionary measures will be prescribed to minimize windthrow in RMA buffers

where the risk of windthrow is high or where extensive windthrow has occurred. These measures

include retaining additional trees adjacent to the RMA to help ensure resistance to windthrow.

• Temporal restrictions will be made to limit in-water work to protect critical fish life stages.

• Maintenance will be built into road construction contracts to correct existing erosion features.

• All proposed road crossing structures will adhere to Fish Standards and Guidelines for passage

(pp 4--11-12) in the Forest Plan (USDA Forest Service, 2008b).

• New and reconditioned roads will be closed to motor vehicle use after silvicultural activities are

complete.

• Temporary roads will be decommissioned after timber harvest is complete.

• Log staging activities will occur outside the minimum 300 foot buffer protecting Class I streams

entering Shelter Cove (Appendix G, S-1).

• Standards and Guidelines of the Forest Plan and best management practices (BMPs) will be

implemented to protect water quality and aquatic habitat protection for all freshwater streams and

for the LTFs within the project area. Unit cards describe specific applications of BMPs in the

vicinity of freshwater streams.

• Dive surveys to monitor bark accumulation are required annually for all permittees which transfer

a total of 15 million board feet during the life of the permit (these are 5 year permits), and which

are located in water depths less than -100 feet at MLLW. Annual bark monitoring is not required

during years when the LTF is not operating. This will ensure APDES requirements are met for

bark accumulation.
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256  Chapter 3 – Aquatics Saddle Lakes Timber Sale Final EIS

Unavoidable Adverse Impacts

Unavoidable adverse impacts to EFH associated with this project include short-term increases in 

sediment delivery and subsequent turbidity in streams from road construction and maintenance 

activities. Other short-term impacts include bark accumulation, leachate, and shading impacts to the 

marine environment near the LTF. 

Irreversible and Irretrievable Commitments of Resources

This project does not propose any irreversible or irretrievable commitments of aquatic resources.
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Environmental Justice - Chapter 3  257

Environmental Justice

Executive Order 12898 requires federal agencies to identify and address disproportionately high and 

adverse human health or environmental effects of its programs, policies, and activities on minority 

populations and low-income populations in the United States. Environmental justice analysis 

considers whether there is a disproportionately high and adverse effect from any of the alternatives on 

low-income and minority populations in communities near the project area, and incorporates by 

reference the analyses presented in the Wildlife and Subsistence Resource Reports. The Saddle Lakes 

Timber Sale is a federal action that has potential environmental effects. The analysis area for 

environmental justice includes the communities of Ketchikan, Metlakatla, and Saxman. 

The Council on Environmental Quality (CEQ) issued guidance on analyzing effects on environmental 

justice under NEPA in December 1997. This guidance clarified that such analyses should recognize 

the interrelationships between cultural, social, occupational, historical, and economic factors that may 

amplify the environmental impacts. Impacts on subsistence resource use also impact the social and 

cultural lives of residents. The CEQ guidance clarified that the identification of disproportionate 

effects does not preclude the agency from going forward with the proposed action, but should 

heighten attention to project alternatives, mitigation and monitoring needs, and the preferences of the 

affected communities (CEQ 1997, p. 10). 

A more-detailed analysis is contained in the Environmental Justice Resource Report, in the project 

record.

Effects

The effects of the actions are indiscriminate and not expected to have a disproportionately high and 

adverse effect on the health or well-being of the minority or low-income populations that use the 

project area. There are no cumulative or foreseeable projects within the area of analysis that would 

cause a disproportionately high and adverse human health or environmental effect on any minority or 

low-income population. 
3 Affected Environment and Environmental Consequences

258  Chapter 3 – Heritage Resources Saddle Lakes Timber Sale Final EIS

Heritage Resources

Heritage resources include an array of historic and prehistoric cultural sites and traditional cultural 

properties (TCPs). The National Historic Preservation Act (NHPA) sets forth government policy and 

procedures regarding these "historic properties," that is, districts, sites, buildings, structures and 

objects included in or eligible for the National Register of Historic Places (NRHP). Section 106 of the 

NHPA (16 U.S.C. 470) requires that federal agencies consider the effects of their actions on such 

properties, following regulations issued by the Advisory Council on Historic Preservation (36 C.F.R. 

§ 800).

The Section 106 review process occurs through consultation with the Alaska State Historic 

Preservation Office (SHPO), the Advisory Council on Historic Preservation (ACHP), federallyrecognized tribal governments, and other parties with an interest in the effects of the proposed action 

on historic properties, commencing at the early stages of project planning. One of the goals of 

consultation is to identify historic properties or sacred sites (Executive Order 13007) that potentially 

may be affected by the proposed action, assess potential effects and seek ways to avoid, minimize, or 

mitigate any adverse effects on historic properties.

Consideration of the effects of the Saddle Lakes Timber Sale consisted of (1) defining the area of 

potential effects (APE), (2) conducting a review of existing historic and archaeological information 

about the project area including the results of past heritage surveys, and through consultations with 

affected tribes and groups, (3) implementation of any additional fieldwork deemed necessary to 

assess potential effects, (4) development of recommendations based on the results of 1, 2, and 3, and 

(5) consultation with the Alaska SHPO to seek concurrence with recommendations regarding 

significance and effect. 

Methodology

Criteria used to evaluate the proposed harvest and road construction activities effects on heritage 

resources are defined by the Third Amended Programmatic Agreement (2010) among the Alaska 

Region of the Forest Service, ACHP, and the Alaska SHPO. 

To ensure that the procedural requirements of 36 C.F.R. § 800 (Protection of Historic Properties) were 

met, additional heritage resource investigations of the project’s APE were conducted during 2012 and 

2013. This resulted in an additional 25.3 acres of new survey including a sampling of proposed 

harvest units, proposed road corridors, and the area of the proposed Salt Creek barrier modification. 

The heritage resource survey did not result in the identification of any new sites, and made a 

determination of no historic properties affected by the proposed project. 

A review of previous cultural resource surveys in the areas around Carroll Inlet and George Inlet was 

conducted. Until the late 1970s, few significant cultural resource surveys had been conducted in these 

areas. However, as of 2013 there have been twenty-two cultural resource surveys of varying size and 

intensity conducted in or within 5 miles of the APE for the proposed Saddle Lakes Timber Sale. Three 

were conducted by private contractors and were related to the Swan Lake Hydro Electric Project, the 

Swan Lake-Lake Tyee Intertie, and the proposed Mahoney Hydroelectric Project. All of the other 

surveys were conducted by Forest Service archaeologists. Fifteen of these surveys were conducted 

within or very near the proposed Saddle Lakes Timber Sale APE. Approximately 3,052 acres have 

been surveyed within the project area for the proposed Saddle Lakes project. These cultural resource 

surveys were all completed to clear locations for previous timber sales, including timber harvest units, 

gravel pits, roads, bridges, and log transfer facilities (LTFs). In all cases, no sites eligible for or listed 

on the NRHP were found to be located within the project areas.
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Incomplete and Unavailable Information

A complete intensive survey for heritage resources has not been completed for the entire area of 

potential effect (APE) for the proposed action.

Complete intensive heritage surveys are not possible due to limited time, budget, and personnel. 

Therefore it is possible that some heritage resources may not be discovered.

All past heritage surveys (covering ~3,052 acres) were conducted by qualified cultural resource 

managers including a survey in 2013 of ~25 acres in the area of potential effect (APE) in both low 

and high sensitivity areas and a literature search for the project area revealed three Alaska Heritage 

Research Site (AHRS) sites to be located within or adjacent to the APE for the proposed project. 

KET-306, a subsistence camp, is located within the APE for the proposed project. However, the site 

is located within the 1,000-foot wide beach fringe that is protected from development by Forestwide Standards and Guidelines (USDA Forest Service 2008:4-4) and would not be affected by the 

proposed timber harvest activities. The two other sites, KET-15 and KET-18, are located in the 

intertidal areas and should not be affected by the proposed project. Tribal consultation regarding the 

proposed project did not reveal significant concerns by local Native peoples and no sacred sites were 

identified to the Forest Service by them. The locations of heritage sites and surveys were recorded

with GPS and delineated in the GIS system.

Building on experience gained through past and ongoing surveys and other inventory activities, the 

Forest Service has developed, tested, and improved the accuracy of its site-predictive locational 

modeling to better characterize areas of high and low cultural resource sensitivity. This locational

model has been approved by the State Historic Preservation Officer (SHPO) and Advisory Council on 

Historic Preservation within a programmatic agreement of 2010. Using this model has been proven 

very effective in locating cultural sites. Within the last 15 years no historic properties have been

adversely affected in the KMRD due to timber harvest or other types of activities.

Survey strategy for potential impacts to heritage resources was based on the fact that new ground

disturbance would take place in areas of low cultural resource sensitivity and that the utilization of 

Forest Plan Standards and Guidelines, and best management practices would eliminate or reduce 

the risk of any potential impacts. The chances of adverse effects to unknown historic properties are 

therefore considered low. 

Analysis Area

The APE is the analysis area and includes the federal lands located within the project boundary, and 

the areas immediately adjacent to Shelter Cove, Coon Cove, and Leask Cove. 

Affected Environment

At one time, George Inlet and Carroll Inlet were both a portion of the Tlingit Saxman (Cape Fox 

people) territory, but Natives are not in agreement that this area is now territory of the Tlingit Tongass 

people. Though this area is now claimed by the Tongass people, and their right is recognized by the 

Saxman people, both groups actually use the area for hunting, trapping, fishing and berry collecting at 

the present time as do the Tsimshian people (Goldschmidt and Haas 1998). Cedar bark was also

collected along the shorelines of George Inlet and Carroll Inlet as evidenced by many culturally

modified trees (CMTs) observed in the area.

The Native peoples of this area have left their mark on the land evidenced by a variety of site types 

including seasonal villages or campsites, middens, both stone and wood fish traps and weirs, rock art, 
3 Affected Environment and Environmental Consequences

260  Chapter 3 – Heritage Resources Saddle Lakes Timber Sale Final EIS

sacred and religious areas, and subsistence or resource gathering places. The Cape Fox, Tongass, and 

Tsimshian peoples continue to recreate, hunt, and gather on these lands today. 

Mammals, fish, shellfish and aquatic plants have provided important resources for people from 

prehistoric time until today. Fish traps have been identified in Carroll Inlet and George Inlet that attest 

to prehistoric use of the area. There are is only one known archaeological site located within the 

proposed Saddle Lakes Timber Sale project area. This site is modern subsistence camp showing 

recent use (KET-00306). Within 3 miles of the APE are two dated archaeological sites including a 

shell midden (prehistoric garbage concentration including shell, bone, and charcoal) dating to 2,230 ± 

70 radio carbon years BP (Before Present) and the oldest site in near the project area which is a 

wooden fish weir dated to 2,630 ± 70 radio carbon years BP. These sites show use of the area for 

more than two and a half thousand years. 

Certain types of heritage resources, such as sites, artifacts, and other observable results of human 

activity, have a greater probability of being located in specific areas, which create patterns of human 

use across the landscape through time. The environmental characteristics that invited human use and 

habitation in ancient times are often the same factors that invite use today. These high sensitivity 

areas (lakes and marine shorelines), which are not evenly distributed across the landscape, are often 

below 100 feet in elevation and/or are areas of animal, plant, or mineral resource abundance USDA 

Forest Service 2008c, p. 3-437). 

Heritage Resources in the Saddle Lakes Project Area

There are thirty-nine Alaska Heritage Resource Sites (AHRS) located within a 5-mile radius of the 

APE for the proposed Saddle Lakes Timber Sale project (Table 89).

Table 89. Known Alaska heritage resource sites located within a five-mile radius of the Saddle Lakes 

project area

Heritage Sites

KET-00015 KET-00017 KET-00018 KET-00026 KET-00078 KET-00079

KET-00102 KET-00107 KET-00108 KET-00302 KET-00306 KET-00412

KET-00418 KET-00422 KET-00423 KET-00424 KET-00426 KET-00427

KET-00444 KET-00448 KET-00449 KET-00473 KET-00497 KET-00498

KET-00499 KET-00500 KET-00501 KET-00502 KET-00551 KET-00568

KET-00644 KET-00747 KET-00748 KET-00749 KET-01098 KET-01099

KET-01100 KET-01121 KET-01256

These sites are predominantly prehistoric in nature and include shell middens, rock art, fish traps 

(both wooden and stone in composition), and a rock shelter burial. Two of the sites are historic mines. 

Others include ruins of a salmon hatchery, an Adirondack style shelter built by the Civilian 

Conservation Corps (CCC), a homestead, several collapsed shacks, and two modern fish camps. Only 

a very small portion of the recorded sites have been evaluated as to their eligibility for the NRHP and 

are considered eligible for management purposes. The Forest Service consulted with the Organized 

Village of Saxman (OVS), the Metlakatla Indian Community (MIC), the Ketchikan Indian 

Community (KIC), and the Tongass Tribe who are the tribal groups that historically were culturally 

affiliated with the proposed Saddle Lakes project area. No significant concerns or recommendations 

were voiced by these entities.
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Heritage Resources - Chapter 3  261

Within the APE for the proposed Saddle Lakes Timber Sale, three AHRS sites were found. The first is 

a modern subsistence camp (KET-00306), and is situated within the protected 1,000-foot coastal 

(beach) buffer zone (Forest Plan 2008b, pg. 4-4). The other two sites are a fish trap (KET-00015) and 

a fish trap complex with petroglyphs (KET-00018). Both are located within the APE. Past monitoring 

of these fish trap sites during LTF construction and previous timber harvesting activities showed no 

effect to fish traps or petroglyphs. Monitoring and documentation of the traps and petroglyphs in 

2012 only showed natural weathering occurring at the sites. 

Environmental Consequences

The APE for all alternatives is considered to be the “project area” as defined in this document. Direct 

effects include damage to heritage resources due to timber harvest activities. Therefore, areas of direct 

effect are defined as planned timber harvest units and road corridors. Indirect effects result from 

activities peripheral to the timber harvest itself. These would include the risk of increased damage of 

historic properties due to increased visitation in the project area. Increased visitation might result 

from higher numbers of workers in the area during road construction and timber harvest activities, or 

from increased accessibility to the area due to road improvements.

As stated in the Programmatic Agreement, Section VIIB, and the Forest Plan, Heritage Resources

section (HSS1, IVB, pg. 4-17) the preferred management of sites listed in, nominated to, or eligible 

for the NRHP is avoidance and protection. All of the sites recorded in the APE of the project area 

would be fully avoided. As per the Programmatic Agreement, while there are historic properties 

present in the APE, the project would have no effect on them as defined by 36 CFR 800.16(i). The 

imposition of a 1,000-foot coastal (beach) buffer aids in the avoidance of heritage properties because 

it reduces harvest and road construction activities from areas with the highest potential for heritage 

sites. Proposed harvest units and roads are, for the most part located in low-sensitivity areas for 

heritage resources.

The proposed projects activities are not expected to result in the discovery or disturbance of human 

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

provisions of the Native American Graves Protection and Repatriation Act (NAGPRA).

No sacred sites have been identified in the project area, either by tribal governments or traditional 

practitioners (Executive Order 13007). 

The proposed projects activities are not expected to restrict Alaska Native access to traditional 

religious or spiritual sites protected under the American Indian Religious Freedom Act (AIRFA) and 

Forest Service Standards and Guidelines for the treatment of sacred sites (USDA Forest Service 2008, 

pg. 4-19). 

Direct and Indirect Effects

Direct effects include damage due to harvest and road construction activities. Therefore, areas of 

direct effect are defined as planned harvest units and road corridors. Potential direct effects to historic 

properties due to human activities come primarily from road construction, vandalism, or theft. Sites 

can be bulldozed, collapsed, dug up, looted, or destroyed. Indirect effects can occur to historic 

properties by trampling, increased erosion, disturbance and displacement of cultural artifacts. For 

example, trampling the surrounding area can result in site erosion or plant cover loss, thereby 

exposing the site to weathering. 

Indirect effects result from activities peripheral to the harvest itself. These would include the risk of 

increased damage of historic properties due to increased visitation of the project area. Increased 
3 Affected Environment and Environmental Consequences

262  Chapter 3 – Heritage Resources Saddle Lakes Timber Sale Final EIS

visitation might result from higher numbers of workers in the area during harvest or from increased 

accessibility to the area due to road improvements.

Effects on historic properties can be eliminated or reduced by avoiding the cultural resources sites or 

by using mitigation measures to reduce the potential impacts (see mitigation and monitoring section 

below). 

Alternative 1

Alternative 1 would result in no changes to the existing condition, and no direct or indirect effects 

would occur. Ongoing activities in the project area would continue, such as recreation and subsistence 

uses associated with lake and marine shorelines, and activities associated with existing roads that

facilitate access to locations of high sensitivity for heritage resources. 

Alternatives 2, 3, 4, 5, and 6

No direct effects to heritage resources are anticipated under the action alternatives. All of the 

proposed timber harvest units and roads are inland and on relatively steep terrain, within the low 

probability zone for cultural resources (Programmatic Agreement 2010). Based on the results of the 

archaeological examination of the APE, harvest units and roads were designed to avoid all heritage 

resources. All historic properties found during the field investigations were used to modify the project 

to completely avoid potential effects to heritage resources. 

No direct impacts on the three AHRS sites located within the APE are anticipated. Site KET-00306 is 

situated within the protected 1,000-foot coastal (beach) buffer zone and would therefore not be 

affected since no activities are proposed here. Past monitoring of sites KET-00015 and KET-00018 

showed no affect, and therefore, no direct or indirect effects to the sites or historic properties are 

anticipated under the action alternatives. 

No direct or indirect effects are anticipated to any of the nearby (within a 5-mile radius of the APE) 

archaeological sites (Table 89) and culturally modified trees since these are located either in the 

intertidal zone or within a protected buffer established along the beach fringe. 

The proposed modification to the fish passage barrier on lower Salt Creek (ADF&G Anadromous 

Catalog # 101-45-10380) as described in Chapter 2, would not directly or indirectly affect any known 

cultural resources. Also, no effects to heritage resources from the Shelter Cove LTF reconstruction are 

anticipated.

Harvest and road construction under the action alternatives is not anticipated to significantly increase 

access and visitation to areas of high sensitivity for heritage resources. All new road construction 

would be closed to motorized use after timber harvest except for the 1.1 mile public road ROW. 

Cumulative Effects

Cumulative effects to heritage resources result from the collective impacts of natural decay, erosion, 

and forest processes as well as modern cultural processes, which may include recreational artifact 

collection and vandalism of historic properties and developments such as timber harvest and road 

construction. 

Effects Common to All Alternatives

No past or present activities in the project area are expected to contribute to cumulative effects on 

heritage resources.
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Alternative 1

Since no direct or indirect effects to heritage resources would occur under Alternative 1, there would 

be no cumulative effects. 

Alternatives 2, 3, 4, 5, and 6 

Recreational activities would likely increase into and throughout the project area when the Ketchikan 

to Shelter Cove Road is built connecting the Ketchikan road system to the Shelter Cove road system, 

including the public road ROW across NFS lands. As a result of increased visitation in the project 

area, future expanded use of the intertidal and beach fringe areas could eventually affect historic 

properties. 

Cumulative effects of the action alternatives are considered minimal for all action alternatives. 

Harvest and road construction are not in areas of high potential for heritage resources or near known 

historic properties. The action alternatives would not contribute significantly to the degradation of 

known historic properties in the project area.

NHPA Section 106 Compliance

The Heritage Resource Report (R2013100552001) was sent for review and consultation to the Alaska 

State Preservation Officer on September 18, 2013. As per the Programmatic Agreement (2010), if 

there are historic properties present but the undertaking would have no effect upon them as defined in 

36 CFR 800.16(i), then the Heritage Specialist may make a determination of “No Historic Properties 

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

eligibility pursuant to 36 CFR 800.4. The statute (36 CFR 800.16(i)) states that “effect” means 

alteration to the characteristics of a historic property qualifying if for inclusion in or eligibility for the 

National Register of Historic Places. Since all the known historic properties located with the APE for 

this undertaking would be fully avoided, the characteristics of the historic properties would not be 

impacted.

The District archaeologist for the Saddle Lakes project has determined that the activities proposed 

under any of the alternatives for the Saddle Lakes Timber Sale would have “No Effect on Historic 

Properties.” However, should previously unidentified cultural resources including prehistoric sites, 

historic sites, cultural objects, or burials be encountered during timber harvest or road building or 

other activities, the project administrator shall halt operations within 100 feet of the area and 

immediately notify the Forest Supervisor and the Ketchikan Misty-Fiords District archaeologist, who 

would in turn notify the State Historic Preservation Officer (SHPO), representatives of the Ketchikan 

Indian Community and the Organized Village of Saxman. Work may not be resumed in that area until 

so authorized by the Forest Supervisor.

Mitigation Measures

Log rafting and/or storage would only be allowed at approved locations positioned well away from 

the fish trap and petroglyph sites. Log rafting activities would also be monitored by the District 

archaeologist throughout the duration of timber sale activities. 

A monitoring program can help assure that proposed activities do not affect cultural resources or 

historic properties through soil disturbance, rutting, compaction, and erosion. Monitoring also 

addresses issues of additional use of the area that may increase the potential for deliberate looting or 

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

Should previously unidentified cultural resources be encountered during project activities, the project 

administrator shall halt operations within 100 feet of the area and immediately notify the Forest 
3 Affected Environment and Environmental Consequences

264  Chapter 3 – Heritage Resources Saddle Lakes Timber Sale Final EIS

Supervisor and the District archaeologist, who would in turn notify the State Historic Preservation 

Officer (SHPO). Mitigation measures would be implemented before those project activities may 

resume.

Monitoring Recommendations

The Third Amended Programmatic Agreement (2010) among the Alaska Region of the Forest 

Service, the ACHP, and the Alaska SHPO stipulates how archaeological inventory and monitoring is 

to be conducted for a proposed project. Archaeological inventory and monitoring is based upon the 

likelihood of locating archeological and historic sites based upon the physical, biological, and cultural 

features and history of the area to be investigated. 

The Forest Service recognizes two sensitivity zones in the Alaska Region: high sensitivity and low 

sensitivity. The Programmatic Agreement states that a sample of all areas of high sensitivity subject 

to direct impact is to be monitored during and/or after the actual ground disturbance. The impact areas 

to be monitored would be determined on a case-by-case basis. For areas considered low sensitivity, a 

sample of all areas of actual ground disturbance is to be subjected to post-disturbance monitoring. 

Again, the location and acreage sampled would be determined on a case-by-case basis. Monitoring of 

these areas would commence with the start of the project’s timber harvest work and conclude with 

some post-disturbance surveys.

The two sensitivity zones are as follows:

1. High sensitivity zones:

a. All land between mean lower low water and 100 ft. of elevation above mean high water,

with no consideration of slope.

b. Areas of former lode and placer mining activity.

c. River valleys, lake, and river systems providing passes or portages across larger land

masses.

d. Lake and stream systems containing, or known to have contained, anadromous fish runs;

including a focus on barrier falls locations in such systems.

e. Elevated/fossil marine, river, and lake terrace systems.

f. Caves and rockshelters, areas of karst landforms, and rock formations known for caves

and rockshelters.

g. Areas associated with myths and legends such as traditional cultural properties or cultural

landscapes.

h. Known sources of potential raw materials (obsidian sources, exceptional concentrations

of cedar trees, etc.).

i. Alpine areas if ethnographic or historic evidence or previous surveys conducted nearby

indicate cultural use, such as high elevation mountain peaks overlooking saltwater that

may contain rock cairns.

j. Other areas identified through or oral history research and information sources.

2. Low sensitivity zones:

a. The low sensitivity zone includes all land not relegated to the high sensitivity zone.

To verify affect assumptions the District archeologist would periodically visit the project area and 

follow standard monitoring protocols. Monitoring would ensure that such activities do not adversely 

affect cultural resources and address issues of future recreational use that may increase the potential 

for looting or inadvertent disturbance of heritage resources. District archeologists would conduct a 
Affected Environment and Environmental Consequences 3

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visual inspection of the use area, focusing particular attention on areas with known heritage or high 

sensitivity areas for potential heritage resources. Soil probes and other subsurface tests may be used 

to determine the integrity of buried sites. Photographic reference and GPS waypoints may be 

established at each monitored location to serve as a visual baseline as future visits are made. 

Information gathered during monitoring would be recorded in the District Historical Sites database. 

Maps, drawings, photos, and other references would also be collected to gauge future site conditions. 
3 Affected Environment and Environmental Consequences

266  Chapter 3 – Invasive Plants Saddle Lakes Timber Sale Final EIS

Invasive Plants

Invasive plants directly compete with native plants and can cause displacement of the native plants by 

site occupancy. In addition, these species can have a number of indirect effects including changes to 

biological diversity and ecosystem services (D’Antonio et al. 2004). Potential impacts include 

changes in the food base for wildlife and possible changes in the natural soil erosion and sediment 

accumulation dynamics. In addition, altered recreational quality may also be a product of some 

invasive plant infestations on NFS lands (D’Antonio et al. 2004; Mack et al. 2000). EO 13112 directs 

all federal agencies to address the impacts their actions may have on invasive species.

In determining what plants qualify as “invasive,” the Alaska Natural Heritage Program’s (ANHP) 

Weed Ranking Project results were used (http://akweeds.uaa.alaska.edu/akweeds_ranking_page.htm). 

The ranking process takes into account documentation of each plant species, including climatic 

comparison of Alaska's climates to climates where the plant is known to thrive, potential ecological 

impact, biological characteristics and dispersal ability of the plant, the plant's distribution, and 

feasibility of control. Plants are then ranked on a scale of 0-100, 100 having the highest invasiveness 

rank.

The Tongass National Forest high-priority invasive plant species list is a list of target plants of which 

the Forest is most concerned (USDA Forest Service 2007). This list uses the Alaska Natural Heritage 

Program’s (ANHP) Weed Ranking Project results to rank the invasiveness of each species. This list of 

plants includes those with which we have initiated some control measures across the Forest. 

Generally speaking, a plant with a ranking higher than 60 (out of 100) is a high priority plant for 

control, however there are a few exceptions. Reed canary grass (Phalaris arundinacea) is well 

established, and eradication would be impossible to achieve, so it is not a high priority plant for 

control, despite the fact that it has a very high invasiveness ranking of 83. Likewise, common 

dandelion (Taraxacum officinale) is well established, and therefore would not be a high priority plant, 

even though it has a relatively high invasiveness ranking of 62. 

This section provides a summary of the current status of invasive plants within the Saddle Lakes 

project area, and their relative risk of expanding their current infestation area as a result of the 

proposed action or the alternatives. A risk assessment also documents the risk for new infestations of 

invasive plants not yet on the Shelter Cove road system due to the actions proposed in the project and 

several proposed non-Forest Service actions. 

Methodology

Invasive plant surveys were conducted by a qualified botanist on the Shelter Cove road system and 

Shelter Cove log transfer facility (LTF) in 2007. This includes driving or walking the road system and 

stopping at different locations to survey more intensely for invasive plants. The entire main road and 

temporary road system was not completely surveyed. However, the most important vector locations 

were identified as the LTF and float plane dock area, rock pits, and other disturbed areas along the 

main roads. Surveys were done at the appropriate time of year to identify the broadest range of 

possible invasive plant species. The locations of the invasive plants were documented with a GPS, 

and delineated in GIS. 

Incomplete and Unavailable Information

A complete survey for invasive species has not been performed for the entire proposed action area. 

Surveys for invasive species are labor intensive and expensive, and generally become obsolete in a 

short period due to the speed with which weeds can expand in the new areas.
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The lack of a complete census on the locations and aerial extent of invasive plants within or adjacent 

to the proposed action area was not critical for the analysis of the potential impacts. Potential impacts 

were based on the assumption that all existing and new disturbance is at risk for invasive plant 

establishment and that implementation of standards and guidelines and best management practices 

would eliminate or reduce the risk of potential impacts.

Analysis Area

For invasive plants, two elements usually exist which promote their spread: open sunlight and 

exposed mineral soil (disturbance). Since risk of further spread occurs along the road system, the 

analysis area is directly adjacent to existing roads.

Affected Environment

A total of eight invasive plant species are documented to occur within the Saddle Lakes project area. 

Of these eight plants, two are classified as high-priority invasive plant species by the Tongass 

National Forest: Phalaris arundinacea and Leucanthemum vulgare. In Table 90 a summary of plants 

and their invasive ranking and general locations in the project area is provided.

Table 90. Invasive species known in the Saddle Lakes project area

Scientific name Common name Rank1/ General locations

Festuca rubra Red fescue NR2/ Log transfer area and road system

Leucanthemum vulgare Oxeye daisy 61 Log transfer area and road system

Phalaris arundinacea Reed canary grass 83 Log transfer area and road system

Plantago major Common plantain 44 Log transfer area and road system

Ranunculus repens Creeping buttercup 54 Log transfer area and road system

Sonchus arvensis ssp. 

arvensis Field Sowthistle NR2/ Log transfer area

Taraxacum officinale Common dandelion 58 Log transfer area and road system

Trifolium repens White clover 59 Log transfer area and road system

Note:

1/ Ranking (0-100) designated by the Alaska Natural Heritage Program.

2/ Not ranked by Alaska Natural Heritage Program.

Invasive Plant Risk Assessment

This risk assessment evaluates the locations of known invasive plants, existing habitat vulnerability, 

and the potential response of invasive plants as a result of project actions that result in habitat 

alterations and increased vectors.

Two high-priority species occur commonly along Saddle Lakes area roads in the project area: oxeye 

daisy (Leucanthemum vulgare) and reed canary grass (Phalaris arundinacea). These species are 

primarily selected for treatment in land use designations (LUDs) where the Forest is managing for 

natural and near natural desired conditions. These do not generally include development LUDs with 

road systems. This is due to the widespread nature of these species and the low probability of success 

in control. 
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268  Chapter 3 – Invasive Plants Saddle Lakes Timber Sale Final EIS

Environmental Consequences

Habitat vulnerability is a review of site-specific factors present in the Saddle Lakes project area which 

would make the project area vulnerable or resistant to invasive plant infestation. For most invasive 

plants, two elements usually exist which promote their spread: open sunlight and exposed mineral 

soil (disturbance). Since the majority of risk to further spread occurs along the existing road system, 

this analysis considers only those habitats directly adjacent to existing roads. Table 91 lists vegetation 

types found in the project area adjacent to the existing road corridor, and their vulnerability to 

invasive plant infestation.

Table 91. Existing vegetation types within and near the Saddle Lakes project area and their associated 

habitat vulnerability 

Vegetation Type Habitat vulnerability due to light Habitat vulnerability due to 

disturbance

Forested, undisturbed Low Low

Young-growth:

Sapling to pole size classes High Low

Stem exclusion stage Low Low

Stem re-initiation stage Low Low

Wetlands (marshes, muskegs, 

meadows) High Moderate

Riparian areas (floodplains, alluvial 

fans, lake edges and other stream 

crossings) 

Moderate Moderate to High

Soil cover includes mosses, lichens, rocks and ground vegetation. Within the Tongass National Forest, 

soil cover is generally high due to the prolific vegetative growth that exists here. Exposed mineral 

soils naturally occur only along areas of dynamic water movement and as a result of gravity, such as 

riparian areas, including streams of all types, and landslides. Even so, these areas are often covered 

with layers of moss and vegetated with forbs and shrubs. It is uncommon to see naturally produced 

areas of exposed mineral soils except along the beach fringe, in estuaries, floodplains and alluvial 

fans, as well as in areas of high mass movement such as landslides. Therefore, the majority of soil 

disturbance is generated by management actions as a result of road building, recreation activities and 

timber harvest operations.

The type of soil exposed is correlated to the habitat vulnerability. Exposed mineral soils have a higher 

vulnerability to invasive plant infestations than exposed organic soils. Mineral soils are generally 

found along riparian areas, estuaries, and mountain and hill slopes of forested habitats. Organic soils 

are generally found in wetlands, beach fringes, and alpine areas. Therefore, the habitats with the 

highest vulnerability related to soil type is riparian areas, estuaries, and other stream corridors directly 

adjacent to road corridors. In the case of the Saddle Lakes project area, the lake shore near the roads 

is also a vulnerable habitat.

The degree of soil disturbance within forested habitats as a result of timber harvest is related to the 

type of logging systems used to remove the timber. For example, cable systems using suspension 

(partial or full) would create little or no soil disturbance. However, ground-based systems (high lead 

and shovel) have the potential to create more soil disturbance. Certainly, road corridors, landings, 

trails, and LTFs are the most disturbed areas on the Forest. Within the project area, previous soil 

disturbance occurs in roads, rock pits, and to a lesser degree in previously harvested timber units.
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Low-risk areas are currently roadless areas (about 48 percent of the project area), undisturbed 

habitats, and closed canopy young-growth forests. Moderate and high-risk areas include 

wetlands, floodplains, lake margins, open forests having soil disturbance, and newly disturbed 

areas such as roads, clearcut areas, landings, and rock quarries. 

Non-project Dependent Vectors 

Non-project vectors present in the Saddle Lakes project area include roads, wildlife migration, wind, 

water, and land use modification. 

Effects by wildlife and other environmental factors (i.e. wind and water) are expected to be similar to 

current conditions. 

Road construction, maintenance, and use have high potential for spreading invasive plants. Current

road use includes hunters, fishermen, and Forest Service administrative use. Use is considered low 

since the road system is currently isolated; however, the Saddle Lakes road system is proposed for 

connection to the Ketchikan road system. This action would become a source of invasive plants, as 

the Ketchikan road system has numerous highly invasive plants and is discussed in the mitigation

measures section.

A land exchange involving about 8,170 acres has been proposed between the Forest Service and the 

State of Alaska Mental Health Trust Authority. It is expected that there would be a change in land use 

management that could result in the increase in propagation of invasive species.

The LTFs at Shelter Cove and Coon Cove are used for shore transfer of materials, vehicles and 

equipment. Consequently, these areas are highly prone to established communities since vehicle

travel begins and ends at these locations. Use of the LTFs would increase with the timber sale 

implementation.

No additional risks are anticipated to the spread of invasive plants as a result of implementing the fish 

passage barrier modification and Shelter Cove LTF reconstruction. 

Habitat Alteration Expected as a Result of Project

Long-term habitat alterations expected as a result timber harvest activities include vegetation removal 

(light intensity alterations) and some minimal level of exposure of mineral and organic soils as a 

result of new road construction and rock pits. The ground disturbance and open habitat created by 

shovel and cable harvest do create an opportunity for invasive plants to invade previously forested 

habitat, particularly with higher levels of soil disturbance created using high lead and shovel logging 

systems (see Soils section for more information on soil disturbance related to logging systems). 

However, none of the known invasive plants currently in the project area near proposed clearcut 

harvest units are expected to thrive inside a unit once the young forest regenerates.

The other primary long-term habitat change in a timber sale area are the rock quarries, roads, timber 

landings, bridges, camp areas, sort yards and LTFs built or repaired to support timber harvest 

operations. These types of sites already exist in the project area from previous timber sales, and 

would not expand substantially with the proposed timber sale. The roads, rock quarries, camp areas, 

sort yards and LTFs are large, open, disturbed sites ideally suited for many invasive plants. 

This project proposes to construct up to 32.3 miles of new road and would create a number of new 

rock quarries. Potential existing rock pits and possible locations of new rock pits have been identified, 

but the exact rock sources to be used for the project have not been finalized. 
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270  Chapter 3 – Invasive Plants Saddle Lakes Timber Sale Final EIS

This project also proposes to alter up to 2,875 acres of forested habitat into open stands of varying 

size. It is also predicted that timber harvest would create some soil disturbance as a result of harvest 

operations (see Soils and Watersheds section). Overall, these proposed activities would result in low 

to moderate alterations to the current habitat conditions as a result of this project.

Secondary long-term alterations in habitat as a result of this project are changes in light availability 

and wind patterns on the ground. The additional light, wind speed (especially along roads), and 

increased water runoff along roads can all favor the spread of invasive plants. 

Increased Vectors as a Result of Project Implementation

The primary vector as a result of this project is new road construction. Use of old rock quarries 

creates additional vectors for spreading invasive plants. Secondarily, construction and logging 

equipment brought from other locations may be new vectors for spreading invasive plant seeds and 

roots. New stream crossings create openings and have exposed soils which can act as vectors to 

spread invasive plants along waterways. Barges or ships used to transport logs may be a vector for 

aquatic plants and other invasive aquatic species, primarily through ballast water. Seed sources used 

to revegetate the roadsides and rock quarries are no longer a vector, since the Tongass National Forest 

uses virtually “weed-free” seeding specifications in all revegetation efforts. The Saddle Lakes Timber 

Sale would increase traffic use on the roads in the project area temporarily. The increased traffic 

would increase the potential vectors of spread.

Since the primary vectors for the spread of invasive plants in the Saddle Lakes project area are new 

road construction and infested rock quarries, we consider how much takes place in order to assess the 

risk of increased or new introductions of invasive plants. 

• Up to 32.3 miles of new road construction

• Unknown how many existing and new rock quarries identified for future rock sources for this

project are infested with high-priority invasive plants. Sites would be inventoried before project

implementation.

Management Considerations/Mitigation and Monitoring

The invasive plant management goals and strategies for this project follows guidance contained in 

Forest Service Manual 2900 (Invasive Species Management) and the Region 10 and Tongass Invasive 

Plant Management Plan (USDA Forest Service 2005). The primary goal for this project is prevention 

and minimization of spreading certain invasive plants further into the project area. It focuses on 

limiting the introduction and spread of existing high-priority invasive plants into new areas, 

especially in the process of road construction.

Factors for management are considered:

1. Management considerations for this project do not include those high-priority invasive plants

known in the project area which are ubiquitous. The Tongass National Forest only controls these 

plants in certain locations, such as wilderness and other non-management LUDs, when infestation 

sizes are manageable (< 1 acre). These include the following species:

a. Oxeye daisy – L. vulgare

b. Reed canary grass – P. arundinacea

The logic for not treating these species at this time is due to their widespread distribution along the 

road system, and the low likelihood of success in their ultimate control. However, the application of 
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Saddle Lakes Timber Sale Final EIS Invasive Plants - Chapter 3  271

soil erosion BMPs assists in reducing the risk of continued spread while management efforts focus on 

avoiding the introduction of these species into pristine habitats and LUDs managed for natural and 

near natural conditions. These do not include the Timber Production LUD, in which this project area 

is located.

Summary and Overall Risk Assessment for All Alternatives

The anticipated overall invasive plant response to the proposed actions in all five action alternatives 

in the Saddle Lakes Timber Sale project is moderate to high for known invasive plant species 

spreading into new roads, and possibly into some vulnerable areas such as stream crossings. This risk 

is associated with the known invasive plant species currently in the project area along the existing 

road systems. This risk level was determined based on the following factors:

• Locations of high-priority invasive plants occur at the LTF and along existing road corridors.

• Control of the two high-priority species is not feasible at this time due to extensive distribution in

the project area.

Alternative 1, the No-action Alternative, would have little to no impact in the spread of invasive 

plants. The five action alternatives (Alternatives 2 to 6) are relatively equal in contribution to the 

introduction and spread of invasive plants, as all contain road building, stream crossings of roads, and 

rock pit expansion. The risk of introduction of new invasive plants or the spread of existing plants 

into forested areas, other natural habitats, and along temporary roads and landings is moderate. This 

risk was determined based on the following factors: 

• Forested areas harvested in this project are expected to regenerate rapidly which lessens the

susceptibility to invasion.

• Temporary roads would be decommissioned and revegetate naturally, eventually forming a

closed canopy, reducing spread if invasive plants are not introduced during operations.

• Mitigation and monitoring recommendations should help prevent further spread of new highpriority invasive species and those not yet widely distributed.

The focus would be in keeping current populations along the road sides and within contained rock pit 

areas, and avoiding introduction into the project area. 

Risks increase considerably in the project area upon completion the Ketchikan to Shelter Cove road 

as it presents the opportunity to bring several highly invasive plants to the Saddle Lakes project area. 

Additionally, the proposed land exchange between the Forest Service and AMHT adds complicating 

issues in regards to invasive plants, as AMHT has a different management strategy for treating 

invasive plants. 

Design Features and Mitigation Measures

With the above stated management consideration, the following mitigation measures are 

recommended for management to consider in lowering the risk of spread of invasive plants: 

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

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

constructing new roads. All rock/fill sources would be inspected by certified personnel.

a. If any rock sources become contaminated with high-priority species and certification

cannot be attained without treatment or avoidance methods, consider the use of weed

infested rock for re-constructing existing roads only.
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272  Chapter 3 – Invasive Plants Saddle Lakes Timber Sale Final EIS

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

constructions and new landings.

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

after the project for new invasive plant introductions.

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

project area after the project completion, and prior to closing temporary roads as part of the

District 5-year program of work for invasive species management. Prioritize controlling any new

populations relative to other populations of high-priority species needing treatment on the

District. This recommendation may change if the road from Ketchikan is completed, as

eradication may be impossible for some species once the road is connected.

4. Require washing of any off-road equipment and road brushers brought to the LTF from other

locations prior to arrival at the Saddle Lakes project area.
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Saddle Lakes Timber Sale Final EIS Inventoried Roadless Areas - Chapter 3  273

Inventoried Roadless Areas

Inventoried roadless areas (IRAs) are defined as undeveloped areas typically exceeding 5,000 acres 

that meet the minimum criteria for wilderness consideration under the Wilderness Act. In 1972, the 

Forest Service initiated a review of National Forest System roadless areas larger than 5,000 acres to 

determine their suitability for inclusion in the National Wilderness Preservation System. The second 

and final review process, known as Roadless Area Review and Evaluation II (RARE II), resulted in a 

nationwide inventory of roadless areas. Since the completion of RARE II, Congress has designated 

some areas as wilderness, and additional reviews have been conducted through the land management 

planning process and other large-scale assessments. 

Roadless areas within the Tongass National Forest were evaluated and considered for 

recommendation as potential wilderness in the Tongass Land Management Plan Revision Final 

Supplemental Environmental Impact Statement (SEIS) - Roadless Area Evaluation for Wilderness 

Recommendations (USDA Forest Service 2003b). The 2008 Forest Plan FEIS tiers to the 2003 Final 

SEIS. However, the Roadless Area Conservation Rule published in the Federal Register (FR) on 

January 12, 2001, prohibits, with specific exceptions, road construction and road reconstruction, and 

timber harvest in IRAs (66 FR 3272-3273). 

The Saddle Lakes project area includes portions of the North Revilla (526) and Carroll (535) IRAs. 

Combined, they encompass about 18,597 acres (about 48 percent) of the project area. A small portion 

(about 4 percent) of the North Revilla IRA is located in the northern portion of the project area, and a 

large portion (about 88 percent) of the Carroll IRA is generally located from the middle of the project 

area and continues south (Figure 17).

Units of Measure:

The following units of measure were used to evaluate effects of the proposed action and compare 

alternatives: 

• Percent of IRAs affected by acres of timber harvest and miles of new and temporary road

construction, including 600-foot buffers around harvest units (that portion of the buffer

falling inside the IRA boundary for units within 600 feet of the IRA boundary) and 1,200-

foot buffers around roads (that portion of the buffer falling inside the IRA boundary for

roads within 1,200 feet of the IRA boundary); and

• Potential change to the roadless characteristics of IRAs.

Methodology

Although none of the action alternatives propose harvest or road construction within the IRAs, this 

analysis focuses on the indirect effects within the “zones of influence” from proposed activities, 

which include 600-foot "buffers" around harvest units, and 1,200-foot "buffers" along roads. When a 

harvest unit is within 600 feet of an IRA boundary, or a proposed road is within 1,200 feet of an IRA 

boundary, the area of the 600-foot unit buffer or 1,200-foot road buffer that falls inside the IRA 

boundary is analyzed for indirect effects to the IRA. The analysis also focuses on the potential 

impacts to the unique or outstanding biological, physical or social values of the IRAs. Roadless 

characteristics (i.e., values or features that make the area appropriate and valuable for wilderness) 

are described in the November 2000 Forest Service Roadless Area Conservation FEIS (USDA Forest 

Service 2000, Vol. 1, pp. 3-3 to 3-7) and are also described in the Roadless Area Conservation Rule 

(66 FR 3,254). 
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274  Chapter 3 – Inventoried Roadless Areas Saddle Lakes Timber Sale Final EIS

The 2003 Final SEIS (Volume III: Appendix C - Part 2) provides roadless area descriptions for the 

North Revilla (526) and Carroll (535) IRAs. 

The 2001 roadless dataset from the Tongass Corporate GIS has been used in this analysis to analyze 

the anticipated indirect effects within the “zone of influence.” Anticipated indirect and cumulative 

effects on the roadless characteristics are discussed in terms of potential change to roadless 

characteristics in the North Revilla and Carroll IRAs. 

This project-level analysis does not evaluate roadless areas for wilderness recommendation. 

However, roadless characteristics are used in this EIS to analyze and disclose the potential changes 

to these characteristics. Potential effects are also discussed in more detail in the individual resource 

analysis sections. Effects to roadless characteristics are summarized at the end of this section. Table 

92 summarizes the roadless characteristics considered, and the section in Chapter 3 of the EIS where 

potential effects are discussed in more detail. As previously mentioned, none of the action 

alternatives propose harvest or road construction within the IRAs, and therefore no direct effects are 

anticipated. 
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Saddle Lakes Timber Sale Final EIS Inventoried Roadless Areas - Chapter 3  275

Figure 17. Inventoried Roadless Areas in the Saddle Lakes project area
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276  Chapter 3 – Inventoried Roadless Areas Saddle Lakes Timber Sale Final EIS
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Inventoried Roadless Areas - Chapter 3  277

Table 92. Roadless characteristics and discussion

Roadless Characteristics1/ Chapter 3 Section

Biological Values

Diversity of plant and animal communities Issue 3A, Aquatics, Plants

Habitat for threatened, endangered, proposed, candidate, 

and sensitive species and for those species dependent on 

large, undisturbed areas of land

Issue 3A, Aquatics, Plants

Physical Values

High quality or undisturbed soil, water, and air Aquatics, Climate Change, Soils, Wetlands

Sources of public drinking water Lands and Minerals

Social Values

Primitive, Semi-Primitive Non-Motorized, and Semi-Primitive 

Motorized classes of dispersed Recreation opportunities Issue 4B (Recreation)

Reference landscapes Issue 4A (Scenery) 

Natural appearing landscapes with high scenic quality Issue 4A (Scenery) 

Traditional cultural properties and sacred sites Heritage

Other locally identified unique characteristics Issue 3B (Subsistence)

Sources:

1/ USDA Forest Service 2000, pp. 3-3 to 3-7; 66 Fed. Reg. 3,254 (January 12, 2001).

Analysis Area

The analysis area for the roadless resource includes the entire North Revilla and Carroll IRAs. Maps 

of these IRAs can be found in the map section of the SEIS CD (USDA Forest Service 2003b). 

Affected Environment

Southeast Alaska residents are, for the most part, surrounded by land that has many of the 

characteristics of wilderness. Routine travel and ordinary outdoor recreation activities typically 

require a higher degree of skill, risk-taking, and self-reliance than is usually required of adventurous 

backcountry visitors on other National Forests. This wildness and the lifestyles associated with it are 

highly prized by residents and visitors alike (USDA Forest Service 2008c). 

Portions of the North Revilla (526) and Carroll (535) roadless areas are located in the Saddle Lakes 

project area. The project area (38,459 acres) contains about 18,598 acres of roadless. This equates to 

about 48 percent of the project area. Table 93 summarizes the total number of acres associated with 

these two roadless areas, total IRA acres, and IRA acres in the Saddle Lakes project area. Table 94

summarizes the land use designations (LUDs) in the two IRAs and their acreages.

Table 93. Roadless area acres and roadless acres within the project area for the 2001 Roadless Rule

Roadless Area Total Roadless Area 

Acres Roadless Area Acres Percent1/

of Total 

Roadless Area

North Revilla 215,414 8,639 4% 

Carroll 11,364 9,958 88% 

Totals 226,778 18,597 48% 

Source: USDA Forest Service GIS. Numbers are rounded to nearest whole number

1/ percentage of the IRA within the Saddle Lakes project area.
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278  Chapter 3 – Inventoried Roadless Areas Saddle Lakes Timber Sale Final EIS

Table 94. LUD acres in roadless areas

LUD LUD Acres in Roadless LUD Percentage of Roadless 

North Revilla IRA

Old-growth Habitat 2,709 31% 

Modified Landscape 1,886 22% 

Timber Production 4,010 46% 

Carroll IRA

Modified Landscape 3,551 36% 

Timber Production 6,293 63% 

Source: USDA Forest Service GIS

North Revilla IRA

The North Revilla IRA is situated on the west coast of Revillagigedo Island and is bordered to the 

east by Misty Fiords National Monument Wilderness. Behm Canal borders the IRA to the north and 

saltwater and areas of timber harvest and associated roads border the IRA to the west. The west 

shoreline of the area has been developed from Naha Bay north to Gedney Pass, with roads and 

harvest units extending along drainages into the IRA. The city of Ketchikan is located approximately 

5 miles south of the southern portion of this IRA. The rural part of Ketchikan, north of the city 

(Ketchikan Gateway Borough) defines the boundary all the way to Naha Bay and Loring along the 

Behm Canal (Figure 2).

The IRA is characterized by rugged terrain. Mountain slopes are steep, causing deeply incised 

drainages. The central portion of the North Revilla IRA is dominated by an extensive lake chain

associated with the Naha River and its tributaries. Elevation ranges from sea level to over 4,000 

feet. Vegetation is typical Southeast Alaska coastal temperate rain forest, primarily western 

hemlock and Sitka spruce with moderate components of cedar. The Traitors Cove Metasediments 

Ecological Subsection is the dominant subsection within the IRA (USDA Forest Service 2003). 

Biological Values

The only federally listed threatened and endangered species that occur adjacent to the North 

Revilla IRA is the humpback whale (endangered). Pacific herring (once a candidate species but 

found in 2014 to not be warranted for listing by NOAA) are also known to occur in the waters near 

the IRA. 

No federally listed fish species or State of Alaska listed fish species occur in the streams and lakes of 

the Tongass National Forest. However, fourteen evolutionarily significant units (ESUs) for salmon 

and distinct population segments (DPSs) for steelhead that originate from either the Columbia River 

system or the Puget Sound area could potentially be present in Alaskan waters during some period of 

their marine life stage. The southern DPS of green sturgeon that originates from the Sacramento River 

could also be present in the inside waters of Southeast Alaska, particularly during the winter. 

However, existing data suggests that most do not migrate this far north and they would only be in the 

area seasonally. No critical habitat has been designated for these species in Alaskan waters. In 2009, 

the Region 10 sensitive fish species was updated and stated no sensitive fish species occurred within 

the Tongass National Forest (USDA Forest Service, 2009b). 

Northern goshawks have been found along major drainages in the North Revilla IRA (USDA Forest

Service 2003). Two sightings for the Queen Charlotte goshawk (R10 Sensitive Species) were 

recorded in 2012. More information on goshawks can be found in this chapter under Issue 3A. 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Inventoried Roadless Areas - Chapter 3  279

No federally listed threatened or endangered plant species are known or suspected to occur on the 

Tongass National Forest. Eleven Forest Service Region 10 sensitive plants are known or suspected to 

occur on the Ketchikan-Misty Fiords Ranger District. Of these, six are suspected to occur within the 

North Revilla IRA. More information on sensitive and rare plants can be found in this chapter under 

the Plants section. 

The North Revilla IRA has populations of Sitka black-tailed deer, wolves, black bear, otter, marten, 

beaver, mink, eagles, loon, and common waterfowl (USDA Forest Service 2003). Based on 

MacDonald and Cook (2007, 2009), 24 mammalian species are known to occur on Revillagigedo 

Island. Large, undisturbed areas of land, with important old-growth forested habitat for foraging, 

breeding, nesting and denning are important for most wildlife species viability. More details on 

wildlife and wildlife habitat can be found under Issue 3A in this chapter.

Maintenance of wildlife habitat corridors is important to minimize isolation and potential local 

extirpation of wildlife species associated with interior old-growth (Hunter 1990, USDA Forest 

Service 2008b, p. 3-380). A few elevational connectivity corridors were designed within the Saddle 

Lakes project area through the Modified Landscape LUD to link non-development LUDs through the 

IRAs (see Corridor discussion under Issue 3A). Portions of the small Old-growth Reserve in VCU

7470 at the head of George Inlet salt chuck is within the North Revilla IRA. This corridor maintains 

connectivity between Naha LUD II and the George Inlet salt chuck thereby facilitating dispersal and 

re-colonization of vacant territories.

Streams and lakes within the North Revilla IRA provide habitat and contribute to the production of 

fish that support the local subsistence, sport, and commercial fisheries of the area, and are a major 

food source for many wildlife species. Fish and aquatic resources on the Tongass National Forest 

provide major subsistence, commercial, and sport fisheries, as well as traditional and cultural values. 

Abundant rainfall and watersheds with high stream densities provide for the diversity of freshwater 

habitats. Seven anadromous and/or resident salmonid fish species are present in project area streams 

and include coho, pink, chum, and sockeye salmon, cutthroat and steelhead trout, and Dolly Varden 

char.

Physical Values

There are no glaciers or unique geologic features in the North Revilla IRA (USDA Forest Service 

2003). There is a swath of mid- to high-vulnerability karst that overlaps with this IRA in two small 

areas near Painted Peak, Marble and Licking Creek. However, there are no karst resources mapped 

within the project area and none have been reported during resource evaluation for the project 

(Baichtal 2013). There are no Research Natural Areas in the IRA. The IRA is part of a larger 

unroaded land area, which includes the Misty Fiords National Monument located east of the IRA. 

Soils in the North Revilla IRA range from very poorly drained to well drained soils. Most soils in the 

Saddle Lakes project area have a thick organic or duff layer that prevents erosion of the underlying 

mineral soil from raindrop impact and supplies many nutrients for plant growth. There are several 

areas of very unstable soils within the North Revilla IRA, primarily located in the northwestern 

portion inside the project area boundary. See the Soils section in this chapter for more details.

Five broad types of wetlands occur within the project area. These wetland types have different soil 

and vegetative communities, occupy different landscape positions, and have somewhat different 

functions and values. Wetland types in the North Revilla IRA include forested wetlands, scrubshrub/muskeg, alpine wetland, lakes and ponds and tall sedge fens. See the Wetlands section in this 

chapter for more details on wetlands.
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280  Chapter 3 – Inventoried Roadless Areas Saddle Lakes Timber Sale Final EIS

The Swan Lake Hydroelectric Project is located in this IRA, but is northeast of the project area. There 

are no existing or planned water projects within the IRA and no additional hydroelectric water 

projects are planned (USDA Forest Service 2003). There are no mining claims located within this 

IRA and the potential for mineral development is considered to be low (USDA Forest Service 2003).

Social Values

There is high opportunity for solitude and the entire IRA provides primarily primitive recreation 

opportunities (see Recreation discussion under Issue 4B in this chapter). The recreation settings in 

this IRA within the project area boundary include Semi-primitive Motorized (SPM) (area adjacent to 

the Naha LUD II) with the remainder being Roaded Modified (RM) due to the area surrounding 

existing roads and previous harvest units (see USDA Forest Service 2008b Appendix I for a full 

description of these recreation settings). Although no roads exist in SPM settings, there is float plane 

traffic to many of the lakes in the Naha watershed. Frequent floatplane landings bring people to and 

from the five public recreation cabins in the IRA (USDA Forest Service 2003); however, these cabins 

are located outside the project area. The Misty-Fiords National Monument Wilderness Area, just east 

of the IRA, also contains many recreation attractions. 

The Forest Service Scenery Management System (SMS) uses the term scenic integrity objective

(SIO) to describe the desired visual condition of the landscape. The SIO for the portion of the IRA 

within the Saddle Lakes project area that is adjacent to the Naha LUD II boundary to the North and 

along the west side of Carroll Inlet is rated as “high,” and represents about nine percent of the lands 

within the project area all within the Old-growth Habitat LUD. The portion of the IRA within the 

project area just north of North Saddle Lakes is rated as “very low” due to past harvest and road 

construction (see Scenery discussion under Issue 4A). Overall, the land within the entire North 

Revilla IRA (215,414 acres) has high natural integrity and moderate apparent naturalness (USDA 

Forest Service 2003), but is influenced along its borders in many places by ongoing urban 

developments and developments associated with timber management on federal, State, and private 

lands. The State of Alaska and Alaska Native Corporations have made extensive land selections in the 

headwaters of Ward Creek, along George and Carroll Inlets, and along the south boundary of this 

IRA. Development in the IRA also includes the Swan Lake Hydroelectric Facility, northeast of the 

project area. About 7 acres of the Swan Lake Powerline corridor is located in the IRA inside the 

project area boundary. The Upper Carroll Timber Sale FEIS (USDA Forest Service, 1996) resulted in 

a sale area that extends into the North Revilla IRA. These modifications have had a low impact on the 

overall natural appearance of the IRA. However, the developments that have occurred on adjacent 

lands, affect the areas near them and the apparent naturalness of portions of this IRA. 

Within the project area, about 4,010 acres of the IRA (roughly 46 percent) is allocated to the Timber 

Production LUD, about 1,886 acres (roughly 22 percent) to the Modified Landscape LUD, and about 

2,709 acres (roughly 31 percent) to the Old-growth Habitat LUD (Table 94).

Viewed from nearby travel routes, the North Revilla IRA provides a natural backdrop to the 

developed areas in the foreground. Visual priority routes and use areas identified by the Forest Plan in 

the vicinity of the IRA include Carroll Inlet (Saltwater Use Area) and the Harriet Hunt-Shelter Cove 

Road Connection (Planned Route) (USDA Forest Service 2008b, Appendix F). The State of Alaska 

Department of Transportation and Public Facilities (DOT&PF) has been planning a road (i.e., 

Ketchikan to Shelter Cove Road) that would extend the Ketchikan road system from the end of 

Revilla Road near Lake Harriet Hunt to Shelter Cove on Carroll Inlet. This road is identified in the 

2004 Southeast Alaska Transportation Plan (SATP). Funding for future State road construction has 

been approved, and construction is anticipated to begin in 2015. The proposed road would cross NFS 
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land just above the Salt Lagoon, and a right-of-way (ROW) authorization is needed from the Forest 

Service. The 1 mile ROW is outside the North Revilla IRA, but is in close proximity to it.

The 2008 Forest Plan FEIS (USDA Forest Service 2008c, 3-575) lists subsistence resources of 

greatest importance to be salmon, other finfish, marine invertebrates, and deer. Communities that may 

potentially use the Saddle Lakes project area for subsistence and personal-use fishing and hunting are 

Metlakatla, Saxman, and Ketchikan. For more information on subsistence, see Issue 3B in this 

chapter. 

Many people visit IRAs to experience spiritual renewal, and this includes Alaska Native sites. The 

North Revilla IRA has a rich history. Prehistoric and historic Alaska Native cultures used this area. 

Their activities mostly centered in the Naha Bay area and probably extended into the interior in the 

Naha drainage (USDA Forest Service 2003). The Naha River, which is inside the IRA but outside the 

Saddle Lakes project area, has been an important subsistence use area through recent history. A 

number of prehistoric and historic sites have been identified through archeological surveys, oral 

histories, and other historical records. The heritage resource survey did not result in the identification 

of any new sites. No sacred sites have been identified in the project area, either by tribal governments 

or traditional practitioners (see the Heritage section in this chapter for more information).

Carroll IRA

The Carroll IRA is bordered to the north, east, and part of the west by areas developed for forest 

management. Developed non-National Forest System lands border the area to the south and part of 

the west. The area is located on a peninsula bordered by George Inlet and Carroll Inlet to the west and 

east, respectively (Figure 17). The area is characterized by rugged terrain, steep mountain slopes, and 

lakes (USDA Forest Service 2003).

Biological Values

Occurrences of federally listed plant and animal threatened and endangered species are the same as 

those discussed above for North Revilla IRA. Similarly, the Queen Charlotte goshawk is expected to 

occur within this IRA. More information on goshawks can be found in this chapter under Issue 3A. 

No federally listed fish species or State of Alaska listed fish species occur in the streams and lakes of 

the Tongass National Forest. See discussion above for North Revilla IRA Biological Values section 

regarding fish ESUs and DPSs. No sensitive fish species occurs within the Tongass National Forest 

(USDA Forest Service, 2009b). 

Similar to the North Revilla IRA, six Forest Service Region 10 sensitive plants are suspected to occur 

within the Carroll IRA. See discussion above for North Revilla IRA Biological Values section 

regarding plants. 

Similar to the North Revilla IRA, the Carroll IRA also has populations of Sitka black-tailed deer, 

black bear, wolves, otter, marten, beaver, mink, eagles, loon, and common waterfowl. See discussion 

above for North Revilla IRA Biological Values section regarding wildlife and their habitat.

Elevational connectivity corridors were designed within the Saddle Lakes project area through the 

Modified Landscape LUD to link non-development LUDs through the IRAs (see Corridor discussion 

under Issue 3A). The Carroll IRA helps to preserve the linkage between the medium OGR located in 

the northeast portion of the project area, and the semi-remote LUD south of the project area. 

Similar to the North Revilla IRA, the Carroll IRA includes streams and lakes that provide habitat and 

contribute to the production of fish that support the local subsistence, sport, and commercial fisheries 
3 Affected Environment and Environmental Consequences

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of the area, and are a major food source for many wildlife species. Similar to the North Revilla IRA 

seven anadromous and/or resident salmonid fish species are present in project area streams.

Physical Values

There are no glaciers or unique geologic features in the Carroll IRA. There is a small area of high 

vulnerability karst located in the mountainous region southwest of Buckhorn Lake. The karst 

resources are mapped as 101 acres, or 1 percent, of the entire IRA. About two-thirds of the karst is 

mapped as high-vulnerability karst. However, there are no karst resources mapped within the project 

area and none have been reported during resource evaluation for this project (Baichtal, 2013). 

Soils in the Carroll IRA are similar to soils in the North Revilla IRA; however, there are less very 

unstable soils in this IRA (see Soils section in this chapter).

Similar to the discussions under the North Revilla IRA above, there are five broad types of wetlands 

in the Carroll IRA. However, unlike the North Revilla IRA, the Carroll IRA contains more wetland 

types that are relatively scarce within the larger landscape (tall sedge fens, lakes and ponds, and 

alpine wetlands) and are considered high-value wetlands (see Wetlands section in this chapter for 

more details).

There are no existing or planned hydroelectric or domestic water projects within the IRA. Mineral 

development potential in this IRA is very low. 

Social Values

The Carroll IRA provides low opportunity for solitude and moderate opportunity for primitive 

recreation within the area, thus providing primarily semi-primitive recreation opportunities (see 

Recreation discussion under Issue 4B). The recreation settings in this IRA within the project area 

boundary include Semi-primitive Non-motorized (SPNM) in the interior non-roaded portion of the 

IRA, and Roaded Modified (RM) adjacent to areas that have been developed (see USDA Forest 

Service 2008b Appendix I for a full description of these recreation settings). Aircraft noise can be 

heard virtually everywhere year-round. There are no developed recreation facilities in this IRA 

(USDA Forest Service 2003).

The Carroll IRA appears unmodified and in a natural condition. However, a large portion of 

developed areas surrounding this IRA, particularly on the west side along George Inlet, affects the 

natural integrity and apparent naturalness of the area. The scenery integrity objective (SIO) for the 

majority of the Carroll IRA within the project area boundary is rated as “very low” with smaller 

portions rated as “low” or “moderate.” There is no “high” SIO for this IRA (see Scenery discussion 

under Issue 4A). The State of Alaska and Alaska Native Corporations have received extensive land 

selections along George and Carroll Inlets and ongoing development has occurred on these lands. The 

State of Alaska owns the parcel adjacent to the northeast end of George Inlet and surrounding the salt 

lagoon. Within this parcel, plots have been laid out and some plots deeded to private individuals. The 

Alaska Mental Health Trust Authority owns the parcel adjacent and to the northwest of George Inlet. 

Cape Fox Corporation also owns a parcel located east of George Inlet that is adjacent to the Carroll 

IRA. Past harvest and associated road construction has also occurred in the IRA. One Forest Service 

timber sale (Buckdance Madder Reoffer) from the Sea Level Timber Sale FEIS (USDA Forest 

Service, 1999) occurred partly within the Carroll IRA. About 5 acres of the Swan Lake Powerline 

corridor is also located in the northern portion of the IRA inside the project area boundary. Visual 

priority routes and use areas identified by the Forest Plan in the vicinity of the area include Carroll 

Inlet and George Inlet (Saltwater Use Areas) (USDA Forest Service 2008b, Appendix F).
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Within the project area, about 6,293 acres of the IRA (roughly 63 percent) is allocated to the Timber 

Production LUD, and about 3,551 acres (roughly 36 percent) to the Modified Landscape LUD (Table 

94).

Subsistence fishing and hunting in the Carroll IRA is similar to what is discussed above under Social 

Values for the North Revilla IRA. 

Similar to discussions under the North Revilla IRA above, prehistoric and historic Alaska Native 

cultures used the Carroll IRA. A number of prehistoric and historic sites have been identified through 

archeological survey, oral history, and historic documentation (USDA Forest Service 2003). See the 

Heritage section in this chapter for more information. There are no areas of scientific interest in this 

IRA.

Environmental Consequences

Incomplete and Unavailable Information

Detailed information about the future use of the lands proposed for exchange by the Alaska Mental 

Health Trust Authority (AMHT) is unavailable. However, the November 2013 Forest Resource 

Management Plan (published as part of the Trust Land Office Resource Management Strategy) states 

that “TLO will be better positioned to fulfill its mandate of maximizing Trust timber assets after the 

exchange is complete. If successful, The Trust would own forest resources in areas more suitable for 

timber harvest...” (AMHT 2013). The IDT GIS Specialist provided the acres of the land exchange 

within both IRAs. Cumulative effects are qualitatively discussed, and this analysis assumes that the 

proposed parcels would no longer be managed by the U.S. Forest Service. The lack of specific data 

on the future use of the lands proposed for exchange by the AMHT was not critical for the analysis of 

the potential impacts.

Effects Common to All Action Alternatives

No direct effects to roadless characteristics would occur in any action alternative because no timber 

harvest or road construction is proposed in the North Revilla and Carroll IRAs. 

NFS and temporary roads were given the same buffer (1,200 feet) and are similarly treated in this 

analysis, although temporary and closed system roads may have a lower degree of influence on some 

roadless characteristics (e.g., ecologic values, natural integrity and appearance, scenic values, and

semi-primitive and primitive recreation opportunities) after the timber harvest is complete. Temporary

roads in particular are anticipated to continue having a diminishing effect on roadless characteristics 

over time as natural vegetation and water drainage are re-established. In all action alternatives, the 

largest reduction in the number of acres retaining roadless character is a result of the 600-foot buffer 

and 1,200-foot buffer around harvest acres and roads. The Roadless Resource Report includes a map 

showing the zones of influence used in the analysis. 

The North Revilla and Carroll IRAs would remain greater than 5,000 acres in size. 

Under all action alternatives, less than 1 percent of the North Revilla IRA and between 3 and 5 

percent of the Carroll IRA would be indirectly affected due to the application of a 600-foot buffer 

around harvest units and 1,200-foot buffer for road construction (Table 95 and Table 96). The roadless 

characteristics of both IRAs would be minimally to moderately modified throughout, but no unique 

attributes would be affected, and impacts on the overall natural appearance of these IRAs would be 

low.
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The State of Alaska ROW and public road on NFS lands would affect the zone of influence within the 

North Revilla IRA. Total acres affecting the zone of influence are shown in Table 95. The cumulative 

effects of the future road construction associated with the Ketchikan to Shelter Cove Road are 

disclosed under the Social Values section in cumulative effects below.

No indirect effects are anticipated to roadless characteristics as a result of implementing the fish 

passage barrier modification and the Shelter Cove LTF reconstruction. 

Comparison of Alternatives 

Potential indirect effects are anticipated under all action alternatives. Table 95 and Table 96 display 

the effects to roadless areas by alternative.

Table 95. Indirect effects of proposed Saddle Lakes Project on the North Revilla Inventoried Roadless 

Area

Measure of Direct and Indirect

Effects 

Alternative 

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

Acres of timber harvest (outside of 

IRA) 0 2,207 1,012 2,424 2,875 2,138

Total acres affecting zone of influence 

(600’ buffer for harvest units; 1,200’ 

buffer for roads)

0 276 177 312 403 225

Total acres affecting zone of influence 

(1,200’ buffer for State road in ROW

on NFS land) 

0 19 19 4 4 4 

Percent of North Revilla IRA affected 0 0.1 0.2 0.1 0.2 0.1

Source: USDA Forest Service GIS

Note: Acres are rounded to the nearest whole number.

Table 96. Indirect Effects of Proposed Saddle Lakes Project on the Carroll Inventoried Roadless Area

Measure of Direct and Indirect 

Effects 

Alternative

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

Total acres of timber harvest (outside 

of IRA) 0 2,207 1,012 2,424 2,875 2,138

Total acres affecting zone of influence 

(600’ buffer for harvest units; 1,200’ 

buffer for roads)

0 533 311 487 588 487

Percent of Carroll IRA affected 0 4.7 2.7 4.3 5.2 4.3

Source: USDA Forest Service GIS

Note: Acres are rounded to the nearest whole number.

Indirect Effects

Alternative 1

Under this alternative, no road construction or timber harvest is proposed. Therefore, this alternative 

would have no direct or indirect effects on the roadless characteristics in either the North Revilla or 

Carroll IRA beyond the existing condition. 
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Alternative 2

Of the action alternatives, Alternative 2 proposes the most uneven-aged management resulting in up 

to 67 percent of the stand remaining after harvest. Therefore, changes to naturally appearing 

landscapes with high scenic quality would only be slightly changed in the project area adjacent to the 

IRAs. Alternative 2 would also maintain the elevational and connectivity corridors for wildlife 

through the IRAs. 

Alternative 3

Alternative 3 proposes the least amount of road construction of all action alternatives, and the least 

amount of harvest. Development outside the IRAs would be subordinate to the existing landscape 

character. There would be no changes to the recreation opportunity spectrum (ROS) classes, and 

indirect effects from timber harvest occurring adjacent to the IRAs would not be easily noticed by the 

average forest visitor recreating in the area. In addition, Alternative 3 was specifically designed to 

maintain the identified elevational and connectivity corridors. Alternative 3 would maintain portions 

of the existing old-growth reserve (OGR) in VCU 7470 adjacent to the North Revilla IRA, and the 

connectivity between the Naha LUD II and George and Carroll Inlets would be maintained. 

Alternative 4

Alternative 4 proposes more harvest and road construction outside the IRAs than Alternatives 2 and 3, 

but would maintain portions of the existing OGR in VCU 7470 adjacent to the North Revilla IRA, 

and connectivity between the Naha LUD II and George and Carroll Inlets would be maintained. 

Alternative 4 would lower the scenic integrity in several visual priority routes adjacent to the IRAs, 

which may in turn indirectly affect the recreational experience of some visitors (see scenery and 

recreation effects discussions under Issue 4A and 4B). These indirect effects to roadless 

characteristics in the entire IRAs are anticipated to be minimal to moderate. 

Alternative 5

Timber harvest activities proposed under Alternative 5 would indirectly affect the natural appearing 

landscapes with high scenic quality adjacent to the North Revilla and Carroll IRAs, which could in 

turn indirectly affect the recreational experience of some visitors (see scenery and recreation effects 

discussion under Issue 4A and 4B). However, minimal to moderate modifications to landscapes and 

recreation opportunities are anticipated throughout the entire IRAs. 

The proposed harvest (clearcut) of units within the Old-growth Habitat LUD adjacent to the North 

Revilla IRA could indirectly impact wildlife habitat in this IRA. Although these proposed harvest 

units are outside this IRA, there would be indirect effects to wildlife habitat within this portion of the 

IRA due to the loss of connectivity between Naha LUD II and the George Inlet salt chuck (see 

discussion of effects to connectivity under Issue 3A in this chapter). Modifications to wildlife habitat 

throughout the entire North Revilla IRA would be minimal. Alternative 5 would move the small OGR 

in VCU 7470 into the North Revilla IRA. 

Alternative 6

Similar to Alternatives 4 and 5, Alternative 6 would indirectly affect the natural appearing landscapes 

with high scenic quality adjacent to the North Revilla and Carroll IRAs, but to a lesser degree (see 

scenery and recreation effects discussion under Issue 4A and 4B). Similar to Alternatives 2, 3, and 4, 

Alternative 6 would maintain portions of the existing OGR in VCU 7470 in the North Revilla IRA, 

and connectivity between the Naha LUD II and George and Carroll Inlets would be maintained. 
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Cumulative Effects

Appendix B includes the interrelated projects (i.e., past, present and reasonably foreseeable future 

actions) that have been considered in the cumulative effects analysis. 

Biological Values

In terms of potential changes to the biological values of the IRAs, the proposed Alaska Mental Health 

Trust Authority land exchange would likely contribute to cumulative effects on plant and wildlife 

habitat, and for those species dependent on large, undisturbed areas of land. Because future use of 

these lands is not known, the effects cannot be quantified. The land exchange would result in a 

reduction of 638 acres (less than 1 percent) of the North Revilla IRA, including the small old-growth 

reserve in VCU 7470, which maintains connectivity between Naha LUD II and the George Inlet salt 

chuck. The incremental effect of the proposed land exchange on the diversity of wildlife and plant 

habitat would likely be minimal throughout this IRA. 

The proposed land exchange would result in a greater reduction in the size of Carroll IRA. About 

3,302 acres (roughly 29 percent of the IRA) would be lost; however, the IRA size would remain over 

5,000 acres (i.e., minimum criteria for wilderness consideration under the Wilderness Act). 

Exchanging lands in the Carroll IRA would likely change the existing condition of plant and animal 

habitat by reducing it for some plant and animal species. Rare and sensitive plants are suspected to 

occur within these IRAs (see Affected Environment under Plants section in this chapter). It is 

unknown what effects the land exchange would have on known or undocumented sensitive and rare 

plant species, and therefore, cumulative effects cannot be quantified. There would be an incremental 

effect from the proposed land exchange on the diversity of wildlife and plant habitat in the Carroll 

IRA, but until future land use is disclosed, it is uncertain what the cumulative effects would be. 

Management of these lands would no longer be administered by the U.S. Forest Service, and Forest 

Plan Standards and Guidelines would no longer apply. 

Physical Values

In terms of the potential changes to the physical values of these IRAs, the proposed Alaska Mental 

Health Trust Authority land exchange could contribute to cumulative effects. Most of the incremental 

impacts would occur in the Carroll IRA since about 29 percent of the IRA would be subject to the 

exchange. Similar to the conclusions about biological values in this IRA, management of these lands 

would no longer be administered by the Forest Service, and Forest Plan Standards and Guidelines and 

best management practices would no longer apply to physical values such as soil, water and air. For 

example, all known and field-verified very unstable (soils) areas were deferred from timber harvest in 

the Saddle Lakes Timber Sale, but possible future harvest may not employ the same deferment for 

activities that may potentially impact soils. Similarly, if Region 10 soil and water BMPs are not 

applied, there could be anticipated short-term or temporary impacts to water, such as temporary 

increases in sediment delivery in streams. Although there is uncertainty about the context and 

intensity of incremental impacts to physical values, exchanging lands in this IRA could have 

cumulative impacts. 

Social Values

Both IRAs are included in the proposed Alaska Mental Health Trust Authority land exchange (about 

8,170 acres), but the North Revilla IRA to a lesser extent (638 acres). Because of its large size 

(215,414 acres) and the small amount of land proposed for exchange (638 acres), the North Revilla 

IRA would still provide large areas in natural settings that could serve as reference landscapes and 

overall scenic qualities would not change. Past modifications by ongoing urban developments and 

developments associated with timber management on State, private and federal lands have had a low 

impact on the overall natural appearance of the IRA.
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The proposed land exchange would reduce the Carroll IRA from 11,364 acres to 8,062 acres in size, 

and depending on the future land use, could potentially reduce the scenic qualities of this IRA. This 

IRA is bordered to the north, east, and part of the west by areas developed for forest management, and 

the area to the south and part of the west by developed non-NFS lands. Combined with the indirect 

effects anticipated under Alternatives 4, 5 and 6, the proposed exchange could further reduce the 

natural integrity and apparent naturalness of the area from serving as a reference landscape.

The Ketchikan to Shelter Cove Road would expand dispersed recreational opportunities for 

Ketchikan residents and visitors, as well as opportunities for hunting, firewood cutting, microsales 

and free use permits. These changes could contribute to beneficial cumulative effects on social values 

in the North Revilla and Carroll IRAs. The Ketchikan to Shelter Cove Road is not located within 

either IRA; however, portions of it are adjacent to the IRAs. This road connection would enable more 

access for sport and subsistence fishing in the project area IRAs. Increased road access to deer by 

both rural and non-rural hunters, combined with a potential increase in hunter demand for deer, could 

affect competition for deer between subsistence users who hunt in the IRAs. Traffic would increase 

along the road, and associated noise and dust in the IRAs could change the recreation experience. 
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Lands and Minerals

This section focuses on land ownership and administration on National Forest System (NFS) and nonNFS lands, including authorizations, permits, land conveyance and minerals. Authorized uses include 

powerlines, tideland permits, easements, and water rights. This section also discloses the conflicts, if 

any, that Saddle Lakes Timber Sale may have on these property interests. To the extent that a conflict 

creates an effect on a resource, the effects are analyzed at the end of this section.

Methodology

Information in this analysis was obtained by reviewing:

• Master Title Plats prepared by the Bureau of Land Management (Bureau of Land Management

2013a ) in conjunction with the State of Alaska Land Records (Alaska 2013a);

• Bureau of Land Management Public Records (Bureau of Land Management 2013a and b);

• Status Plats and Land Records prepared by the State of Alaska Land Administration System (State

of Alaska 2013a);

• State of Alaska Recorder’s Office (State of Alaska 2013b);

• Alaska Department of Natural Resources permit/certificate database (State of Alaska 2013a, c, d,

e, and 2014);

• Ketchikan Gateway Borough GIS (Ketchikan Gateway Borough 2013);

• Ketchikan Misty Fiords Ranger District special uses permit files; and

• Alaska Mental Health Trust Authority (Alaska Mental Health Trust Authority 2009, 2013a and b).

Incomplete and Unavailable Information

All known current information and sources for information were explored. Due to the dynamic 

situation of individuals purchasing land, requesting permits or certificates, or filing mining claims 

with multiple State and federal agencies, the information reported is time sensitive. A thorough search 

was made from State and federal databases for activities that occur within this area. Other agencies’ 

proposed projects were also considered, including the State’s Ketchikan to Shelter Cove Road and the 

Alaska Mental Health Trust Authority land exchange. The State’s road project is in an active 

planning/analysis phase and information may change as the project moves forward. Discussions 

pertaining to the proposed land exchange with the Alaska Mental Health Trust Authority have 

occurred since 2009. The Alaska Mental Health Trust Authority land exchange formal proposal was 

received in September 2012 (Hillary Woods, Alaska Lands Team). This project is also subject to 

change. 

Analysis Area

The lands and minerals analysis area (both direct/indirect and cumulative effects) consists of all 

sections in the public land survey system (or rectangular survey system) that contain a unit, road, 

marine access facility (MAF) or log transfer facility (LTF) proposed or used under any alternative 

(Figure 18). The analysis area also includes specific sections where the Ketchikan to Shelter Cove 

Road and the Alaska Mental Health Trust Authority land exchange are proposed. This approach was 

chosen because it covers all the pertinent land components previously discussed and other agencies’ 

potential projects.
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Appendix B includes the interrelated projects (i.e., past, present and reasonably foreseeable future 

actions) that have been considered in the lands and minerals cumulative effects analysis

Affected Environment

Both NFS and non-NFS lands exist within the analysis area (Table 97). Federal and State 

permits/certificates are issued and may need to be considered during implementation. State land 

conveyances and mineral claims are either completed or closed. Native selected and conveyed lands 

lie within the analysis area.

Table 97. Lands and minerals ownership in the lands analysis area Saddle Lakes project area

Ownership Acres Percent of Analysis Area

National Forest System Lands 28,636 77

State of Alaska 2,113 5 

Alaska Mental Health Trust Authority 2,830 8 

Cape Fox Corporation 3,554 10

Total 37,133 100

Source: USFS Tongass National Forest GIS

Land Ownership

National Forest System Lands

The analysis area contains 28,636 acres of NFS lands. There are five land use designations (LUDs) in 

the lands and minerals analysis area: timber production, modified landscape, old-growth habitat, 

semi-remote recreation and land use designation II; as well as non-National Forest System lands. The 

Forest Plan provides standards and guidelines for lands and mineral activities in these LUDs. 

Non-National Forest System Lands

Ownership of non-NFS lands in the analysis area includes the State of Alaska, Alaska Mental Health 

Trust Authority, Cape Fox Corporation, and a small amount of private inholdings (Ketchikan 

Gateway Borough 2013). 

State of Alaska

The State of Alaska owns the parcel adjacent to the northeast end of George Inlet and surrounding the 

salt lagoon. Within the parcel, plots have been laid out and some plots deeded to private individuals. 

The State parcel includes lands in:

Copper River Meridian (C.R.M.), T. 73 S., R. 92 E., Sections 16, 17, 20, 21, 28, 29, 30, 32, and 

33. 

Alaska Mental Health Trust Authority

The Alaska Mental Health Trust Authority owns the parcel adjacent and to the northwest of George 

Inlet including lands in: 

C.R.M., T. 73 S., R. 91 E., Sections 23 to 26 inclusive, 35 and 36. 
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290  Chapter 3 – Lands and Minerals Saddle Lakes Timber Sale Final EIS

Cape Fox Corporation

Cape Fox Corporation (Cape Fox) owns the surface rights on a parcel, either through patent or an 

interim conveyance4

. This parcel is located east of George Inlet and in the center of the analysis area. 

The subsurface rights for all parcels were conveyed to Sealaska Corporation.

C.R.M., T. 73 S., R. 92 E., Sections 27 and 34. 

C.R.M., T. 74 S., R. 92 E., Sections 3 to 5 inclusive, 9, 16 to 18 inclusive, 25 and 36.

Land Administration

Forest Service Special Use Authorizations 

The Southeast Alaska Power Agency (SEAPA) maintains a special use permit for operation and 

maintenance of a power transmission lines (KET39). The permit for power transmission lines 

associated with the Swan Lake Hydropower Project, Federal Energy Regulatory Commission (FERC) 

P-2911, expires June 30, 2030. The permit authorizes a corridor, 200 feet wide by 60,313 feet long 

(total). The permit holder is authorized to clear and maintain the power line right-of-way. The 

structures are cleared frequently to allow access to the towers; the lines are cleared as needed when 

trees get 15 feet tall. Within the analysis area (NFS lands), the power line lies within C.R.M., T. 73 S., 

R. 92 E., Sections 12, 13, and 21 to 24 inclusive.

The State of Alaska requests a right-of-way authorizing the construction, operation and maintenance 

of a public road on NFS lands. See Chapter 2, Items Common to All Action Alternatives, State of 

Alaska right-of-way on National Forest System lands. 

State Issued Permits

Within the analysis area, the State of Alaska has multiple permits on State land (State of Alaska 

2013a, b and e). Permits which may affect the project are listed below. The Lands and Minerals

Resource Report contains all the permits within the analysis area.

Tidelands permits

• LAS 25104 – Alcan Forest Products (Alcan) maintained a permit for the upland sort yard, LTF

and rafting, log storage and ship moorage for the Leask Cove LTF site. This permit associated 

with the Lease Lake Timber Sale was extended to and expired on October 5, 2012. Alcan is not 

renewing the permit; however it remains on file with the State. The Alaska Department of 

Forestry has requested management control of this site; the request is pending as of April 2, 2014.

• ADL106318 – Cape Fox Corporation maintained a permit for a LTF in Coon Cove until the

permit closed in 2007. The permit includes land in Alaska Tidelands Survey No. 1136 Tract A and

B, Section 18, T. 74 S., R 92 E., C.R.M.

• ADL 107571 Cape Fox Corporation was cited with a trespass after the LTF permit (Section 18, T.

74 S., R 92 E., C.R.M.) was closed. The site was relinquished, improvements removed, the

trespass resolved, and the case closed in 2011.

4 Interim Conveyance (IC): Documents that transfer title of unsurveyed land to ANCSA Native Corporations. 

Lands received by village corporations have two ICs issued. One for the surface estate to the village and the 

second issued to the regional corporation for subsurface estate. Land received by a regional corporation has one 

IC for both surface and subsurface estate. There are a few exceptions to the normal pattern of issue. (Bureau of 

Land Management 2013a).
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Figure 18. Lands and minerals analysis area
3 Affected Environment and Environmental Consequences

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Easement Permits

• ADL 106839 – SEAPA maintains a public easement for power transmission lines, 300 feet wide

by 23,000 feet long (total). This permit expires June 30, 2030. Within the analysis area, the power 

line transects: C.R.M., T. 73 S., R. 92 E., Sections 20, 21, and 28 to 30 inclusive, and T. 73 S., R. 

91 E., Sections 25, 35, and 36. 

• ADL 105601 – Forest Service maintains a public easement for a LTF at Shelter Cove. The

easement includes all of Tracts 1 and 2 of Alaska Tidelands Survey No. 1459, located within

Section 18, T. 73 S., R. 93 E., and Section 13, T. 73 S., R. 92 E., C.R.M.. The expiration date is

August 14, 2020.

Other Permits

• ADL107083 – 107086 – Four 10-acre aquatic farm permit/leases are available for the public.

These permits are for suspended culture sites located within Sections 17, 19, 20, 29, T. 74 S., R. 

93 E., C.R.M. These leases are outside the lands and minerals analysis area but are within the 

Saddle Lakes project area.

State Issued Water Rights

Three water permit/certificates for family dwellings are pending or issued in sections 30 and 32, T. 73 

S., R. 92 E., C.R.M. (State of Alaska 2013c and d).

Cape Fox Easement to Forest Service

Within the Cape Fox lands, the Forest Service has a 66-foot road easement for Coon Cove Road. The 

rights conveyed to the United States include: 

“...the right to cut timber within the easement to the extent necessary for 

construction, reconstruction, and maintaining the road. Timber so cut may be utilized 

by the United States for construction, reconstruction, and maintenance of the road. 

Timber that is not utilized by the United States shall be cut into logs of lengths 

specified by Cape Fox and decked along the road for disposal by Cape Fox.” 

An annual maintenance plan with respect to recurrent or emergency road maintenance should be 

prepared and implemented jointly by Cape Fox and the United States (State of Alaska 2013b). 

Federal Energy Regulatory Commission Withdrawal/Easement

Per Section 24 of the Federal Power Act, all patented lands shall contain an exception/reservation in 

their title to the United States for purposes of the power line associated with the Swan Lake 

Hydropower Project P-2911 (Federal Power Act of June 10, 1920). 

Legislated Alaska Conveyances

State Land Selections

The 1958 Alaska Statehood Act authorized the State of Alaska to select lands from within the Tongass 

National Forest to further the development and expansion of Alaskan communities (Forest Plan FEIS 

page 3-300). The Saddle Lakes analysis area does not include any State land selections under the 

Statehood Act that have not already been patented.

Native Land Selections

The Alaska Native Allotment Act of 1906 provided for Native individuals who had occupied lands 

prior to their designation as National Forest to apply for conveyance. In addition, the Alaska Native 

Claims Settlement Act (ANSCA) established a process for transfer of federal land to Alaska Native.
3 Affected Environment and Environmental Consequences

294  Chapter 3 – Lands and Minerals Saddle Lakes Timber Sale Final EIS

Other than land previously patented, Native selected lands include all NFS lands in T. 74 S., R. 92 E., 

CRM (Bureau of Land Management 2013a and b). All proceeds derived from contracts on these 

selected lands shall be deposited in an escrow account until the selected lands have been conveyed or 

released (ANILCA). 

Minerals

Currently, there are no mineral claims or mineral material permits in the analysis area.

Future Proposed Easement

State of Alaska Ketchikan to Shelter Cove Road

The State of Alaska Department of Transportation and Public Facilities (DOT&PF) proposes to 

construct, operate and maintain a public road from Ketchikan to Shelter Cove, State Project 68405. 

The project’s purpose is to provide vehicle access to Shelter Cove allowing access to public and 

private lands between Lake Harriet Hunt and Shelter Cove LTF on Carroll Inlet. This would increase 

the public’s opportunities for recreation, subsistence hunting and gathering, tourism, and economic 

development (State of Alaska 2013f). 

The initial scoping for this project began in November of 2006. The State proposes that the entire 

length of road be incorporated into the State road system which would then be managed and 

maintained by the State. In January of 2012, the State of Alaska purchased the surface right-of-way 

on the White River Road from Cape Fox Corporation. The State and Alaska Mental Health Trust 

Authority are in negotiation for the ROW through Alaska Mental Health Trust lands (Garner, D. 

2014). 

Federal Public Law 109-59, Section 4407, provided the impetus for the Forest Service and the State 

of Alaska to enter into a Memorandum of Understanding (MOU). Through this MOU, a recorded 

reciprocal easement was granted to the State from near the end of Revilla Road by Lake Harriet Hunt 

to Shelter Cove (State of Alaska 2013b, USDA Forest Service 2006). 

Future Proposed Land Exchange

Alaska Mental Health Trust Authority 

The Alaska Mental Health Trust Authority (AMHT) owns lands surrounding Southeast Alaska 

communities. These lands are visual backdrops to communities and provide scenery and public 

recreation opportunities. The AMHT, having fiduciary responsibilities to protect and enhance 

Trust assets, proposes to exchange these lands rather than develop them (AMHT 2009). 

In October 2009, the AMHT proposed an administrative land exchange in Southeast Alaska between 

the AMHT and the Forest Service. One of the proposed federal parcels is within the proposed Saddle 

Lakes project area (AMHT 2009 and 2013a). The proposed federal exchange parcel is 8,170 acres. 

As of May 2013, the Trust Land Office (TLO) and the Forest Service began working jointly toward 

the signing of an Agreement to Initiate (ATI) the proposed land exchange. The TLO, which manages 

the AMHT non-cash asset base, developed a resource management strategy in November of 2013 

including a forest resource management plan. This plan states, “Timber revenue has been a major 

source of financial contribution...however those opportunities are mostly depleted...TLO’s pursuit of 

a land exchange with the U.S. Forest Service (USFS), if successful, would provide AMHT with a 

timber basket that under current conditions can provide a continuous rotation and cycle of timber 

harvest revenues and opportunities” (AMHT 2013b). 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Lands and Minerals - Chapter 3  295

Environmental Consequences

Direct and Indirect Effects

Alternative 1

No road construction or timber harvest, fish passage, or Shelter Cove LTF reconstruction is proposed 

under Alternative 1. Therefore, this alternative would have no direct or indirect effects on lands or 

minerals.

Alternative 2, 3, 4, 5 and 6

None of the action alternatives propose to acquire or dispose of any property, or terminate any special 

use authorizations. The Forest Service proposes to issue an easement to the State for the construction, 

operation and maintenance of an approximately 1-mile section of road. From a lands and minerals 

perspective, the proposed Saddle Lakes Timber Sale, fish passage barrier modification or Shelter 

Cove LTF reconstruction would not interfere with the issuance of the 1-mile easement to the State, or 

any State-issued permits and would have no direct or indirect effects under any action alternative. All 

proceeds from timber harvested in units within the Native land selection in T. 74 S., R. 92 E., CRM 

would need to be deposited into an escrow account. There are no current mineral operations to 

interfere.

Information pertaining to implementation specific to federal or State permits and Native selected

lands would be documented in the unit or road cards. These comments deal solely with 

boundary marking needs when units or roads are within 0.25 mile of non-NFS lands, being 

aware of the transmission line and its easement, and Native selection escrow needs. 

Cumulative Effects

Alternative 1

Because there are no direct or indirect effects under this alternative, there would be no contribution of 

cumulative effects.

Alternative 2, 3, 4, 5 and 6

Past timber sales or other resource projects have not affected lands and minerals resources as they 

have not interfered with permits or mineral opportunities. Future Forest Service projects would be 

analyzed and an up-to-date review on existing permits and mineral claims would be researched at that 

time. All State selected lands have been conveyed.

The proposed Ketchikan to Shelter Cove Road would increase access thereby increasing recreational 

use, subsistence and non-subsistence hunting and gathering access, and tourism. Increased access may 

open the area for mineral or mineral material opportunities and special use permits, either lands or 

recreation. The 4407 easement for this road would be an administrative change of road management. 

If the AMHT land exchange moves forward, the exchange would remove land from the federal timber 

base. The SEAPA maintains a special use permit for operation and maintenance of a power

transmission line which runs through the proposed federal exchange parcel. Reserving a transmission

line easement in the title would be needed in the exchange. No mineral claims exist in the area at this 

time; however a minerals analysis may need to be completed prior to an exchange. Native selected 

lands within the proposed exchange parcel would need to be noted and appropriately compensated.
3 Affected Environment and Environmental Consequences

296  Chapter 3 – Lands and Minerals Saddle Lakes Timber Sale Final EIS

Design Features and Mitigation Measures

Property boundaries need to be posted if a timber sale or road is constructed within 1⁄4 mile of nonNFS lands. This would be accomplished prior to implementation. Ensuring that no trespass occurs 

would be the responsibility of the timber sale contract administrator.

Be aware of the special use authorization for the Swan Lake powerline (total clearing width – 200 

feet) and the lack of potential tail holds.

Through the State, four 10-acre aquatic farm permit/leases for suspended culture sites are available 

for the public. Should these leases be issued, attention/care may be needed when barging or rafting 

logs past this area.
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Plants - Chapter 3  297

Plants

This section summarizes the botanical data available for the plants in the project area and analyzes 

and discloses the effects of the proposed Saddle Lakes Timber Sale in relation to threatened, 

endangered, sensitive, and rare plants. The plant species evaluated include those sensitive plant 

species known or suspected to occur in the Ketchikan Misty Fiords Ranger District, according to the 

2009 Forest Service Alaska Region Sensitive Species List, and rare plants ranked S1 or S2 (critically

imperiled or imperiled in the State) by the Alaska Natural Heritage Program.

Units of Measure:

The following units of measure were used to evaluate effects of the proposed action and compare 

alternatives: 

• Number of individuals and known locations of sensitive and rare plants impacted directly and

indirectly through timber harvest or road construction.

Methodology

For this project, the Forest Service Alaska Region Sensitive Species List (USDA Forest Service 2009) 

was used to determine which sensitive plants to consider in the analysis. The Alaska Natural Heritage 

Program (ANHP) website (http://aknhp.uaa.alaska.edu/botany/rare-plants-species-lists/rare-vascularhulten/#content) (accessed December 2013) was used for accessing the ANHP Rare Vascular Plant 

Tracking List, and using the ranking of rare plants, and definitions of these rankings for known rare 

plants in the area (ANHP 2013). A plant species is considered rare in the project area if it is ranked S1 

or S2 (ANHP). The Regional Sensitive Species List identifies certain rare plants on the ANHP list as 

sensitive, known or suspected to occur on the Tongass (Table 98). 

Botanical surveys were conducted in the Saddle Lakes project area by the Forest Service and focused 

on probable habitat of rare and sensitive plants such as old-growth forests, wetlands, riparian areas, 

meadows, bogs, lake margins, and rock outcrops. Surveys were conducted in 2007, 2011 and 2012 

during planning stages of this project. As of May 2013, 61 sensitive and rare plant surveys were 

conducted by the Forest Service in the project area. Forty-six of the surveys were conducted in 36 

different units within the five action alternatives, along six proposed temporary roads. Another 15 

surveys were conducted outside the boundaries of proposed units and roads in sensitive plant habitats. 

See the project Biological Evaluation for Plants (Dillman 2013b) in the project record for further 

information on the pre-field review and field surveys.

Within the project area there are two known sensitive plant populations documented for the Tongass 

National Forest (date of search 3/2013). The lesser-round-leaf orchids were discovered during 

botanical surveys for this project and other similar timber management projects in the area. No 

additional rare and sensitive plants for the project area were identified.

This section is based in part on the results of these surveys. The number of individuals and 

populations in a particular location are evaluated in association with the proposed actions under each 

alternative. The characteristics of their locations are indicators of habitat conditions that may also be 

affected by the proposed actions 

Analysis Area

The spatial context for the direct and indirect effects analysis includes all proposed timber units and 

road corridors, and nearby areas in which habitat alteration associated with harvest and road 

construction can reasonably be expected to occur. The temporal context for direct effects is 
3 Affected Environment and Environmental Consequences

298  Chapter 3 – Plants Saddle Lakes Timber Sale Final EIS

immediately or shortly after an action is made that may impact rare and sensitive plants. Indirect and 

cumulative effects may be measured in years, since it may take a long time before deleterious effects 

are evident in relation to sensitive plant numbers or populations.

Affected Environment

Sensitive and rare plant habitats present in the Saddle Lakes project area are diverse, from beach 

forest to alpine. Terrestrial habitats are characterized by the abundance and movement of water. Welldrained site conditions support productive forest habitats, while poorly-drained site conditions 

support wetlands and unproductive forests (Schoen and Dovichin 2007, USDA Forest Service 2008c). 

Surface and subsurface water within the terrestrial habitats is influenced by geomorphology, geology, 

soil drainage, hydrology and climate (USDA Forest Service 2001b).

The project area lies within the maritime climatic zone. The average rainfall for the Ketchikan area is 

150 inches per year. During the winter, higher elevations receive snow. Wind is the dominant natural 

disturbance regime, causing natural openings in the forest structure (Schoen and Dovichin 2007). 

Avalanche and landslides are also common natural disturbance factors.

No federally listed threatened or endangered plants are known or suspected to occur on the Tongass 

National Forest. Therefore, effects on federally listed plants are not discussed in this section.

Sensitive Plants

Sensitive plants are those plant species identified by the Regional Forester for which population 

viability is a concern, as evidenced by: a) Significant current or predicted downward trends in 

population numbers or density, and b) Significant current or predicted downward trends in habitat 

capability that would reduce a species' existing distribution (USDA 2005b). Seventeen vascular plants 

and one lichen are designated as sensitive in the Alaska Region (Table 98). Sensitive plants and their 

habitats known or suspected to occur on the Ketchikan-Misty Fiords Ranger District are delineated by 

bold text in table cells. The rationale for analyzing or not analyzing these plants further is also 

provided in Table 98. 

Table 98. U. S. Forest Service, Alaska Region (R10) sensitive plants

Common Name Scientific Name Occurrence Rationale for Analyzing/Not Analyzing 

Further

Eschscholtz's little 

nightmare

Aphragmus 

eschscholtzianus S 

Plants and their habitats are not known or 

suspected to occur on the Ketchikan-Misty 

Fiords Ranger District.

Moosewort fern Botrychium tunux Y 

Plants and their habitats are not known or 

suspected to occur on the Ketchikan-Misty 

Fiords Ranger District.

Spatulate 

moonwort fern

Botrychium 

spathulatum Y 

Suspected: Sandy beach habitat not 

occurring in the project area. Dropped from 

analysis.

Moonwort, no 

common name

Botrychium 

yaaxudakeit Y 

Plants and their habitats are not known or 

suspected to occur on the Ketchikan-Misty 

Fiords Ranger District.

Edible thistle Cirsium edule var. 

macounii Y 

Known: Preferred habitat not occurring in 

the project area where timber harvest 

activities are proposed. Dropped from 

analysis.
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Plants - Chapter 3  299

Common Name Scientific Name Occurrence Rationale for Analyzing/Not Analyzing 

Further

Sessileleaf 

scurvygrass

Cochlearia 

sessilifolia N 

Plants and their habitats are not known or 

suspected to occur on the Ketchikan-Misty 

Fiords Ranger District.

Spotted lady’s 

slipper

Cypripedium 

guttatum N 

Plants and their habitats are not known or 

suspected to occur on the Ketchikan-Misty 

Fiords Ranger District.

Mountain lady’s 

slipper

Cypripedium 

montanum Y 

Suspected: Some habitat for this plant 

occurs in the project area and includes open 

forests and wet meadows.

Large yellow 

lady’s slipper

Cypripedium 

parviflorum var. 

pubescens

Y 

Suspected: Some habitat for this plant 

occurs in the project area and includes bogs 

and wet meadows.

Calder’s loveage Ligusticum calderi Y 

Suspected: Proposed harvest activities 

would not occur on calcareous substrates in 

subalpine meadows. Dropped from analysis.

Pale poppy Papaver alboroseum S 

Plants and their habitats are not known or 

suspected to occur on the Ketchikan-Misty 

Fiords Ranger District.

Alaska rein orchid Piperia 

unalascensis Y 

Suspected: Some habitat for this plant 

occurs in the project area and includes dry 

open sites, under tall shrubs in riparian 

zones, mesic meadows, and drier areas in 

coniferous and mixed evergreen forests 

from low elevation to subalpine.

Lesser roundleaved orchid

Platanthera 

orbiculata Y 

Known: There are two known locations of 

this orchid in the project area in forested 

habitats where timber harvest activities are 

planned. 

Kruckeberg’s 

swordfern

Polystichum 

kruckebergii Y 

Known: Preferred habitat not occurring in 

project area where timber harvest activities 

are proposed. Dropped from analysis.

Unalaska mistmaid

Romanzoffia 

unalaschcensis Y 

Suspected: Some habitat for this plant in 

the project area includes gravelly areas 

along streams, and on ledges and crevices 

in rock outcrops.

Henderson’s 

checkermallow

Sidalcea 

hendersonii Y 

Suspected: Habitat does not occur within 

the footprint of the proposed road building 

and timber harvest activities.

Dune tansy

Tanacetum 

bipinnatum subsp. 

huronense

Y 

Plants and their habitats are not known or 

suspected to occur on the Ketchikan-Misty 

Fiords Ranger District.

Lichen, no 

common name Lobaria amplissima Y 

Known: Habitat is scarcely present in 

Carroll Inlet as the beaches on the Saddle 

Lakes side are not exposed to open ocean; 

habitat is not preferable because most of the 

beaches in the project area have been 

logged and contain young-growth forests 

less than 50 years; and ho timber harvest 

activities are proposed in beach buffer. 

Dropped from analysis.

Source: USDA Forest Service GIS Data

Notes: Occurrence - S = suspected, Y = known, N= no.
3 Affected Environment and Environmental Consequences

300  Chapter 3 – Plants Saddle Lakes Timber Sale Final EIS

The following sensitive plants are known or suspected in the project area. Please refer to the Plant 

Biological Evaluation (Dillman 2013) for detailed description of each species known range and other 

information relative to their rarity: 

Mountain Lady Slipper Orchid

The ANHP ranks the mountain lady’s slipper orchid as G4S1 (apparently secure globally and 

critically imperiled in Alaska). On National Forest System (NFS) lands the plant is known from three 

locations; the Stikine River near the mouth of Clearwater River (Kikahe River), Etolin Island, and 

upper Lynn Canal near the mouth of Endicott River. Habitat for this plant in the project area includes 

open forests and wet meadows.

Large Yellow Lady’s Slipper Orchid

The large yellow lady’s slipper orchid is ranked as G5S1 (secure globally and critically imperiled in 

Alaska). Cypripedium parviflorum Salisb. is comprised of three varieties (Sheviak 2002) var. 

parviflorum, var. makasin (Farw.) Sheviak and var. pubescens. It is known from two populations on 

northern Prince of Wales Island, where it is growing in peatlands. Habitat for this plant in the project 

area includes bogs and wet meadows. 

Alaska Rein Orchid

The ANHP ranks the Alaska rein orchid as G5S3 (secure globally; and rare/uncommon within 

Alaska). On the Tongass National Forest it is known from Duke Island (on ultramafic rocks), Doolth 

Mountain on Chichagof Island, Gravina Island, Red Bluff Bay on Baranof Island, and Rio Roberts on 

Prince of Wales Island. Habitat for this plant in the project area includes dry open sites, under tall 

shrubs in riparian zones, mesic meadows, and drier areas in coniferous and mixed evergreen forests 

from low elevation to subalpine. 

Lesser Round-Leaf Orchid

The ANHP ranks the lesser round-leaved orchid as G5S3S4 (secure globally; and rare to uncommon). 

On Revillagigedo Island, the orchid is known from 71 populations on the project area and 291 

populations across the Forest. The most common habitat for the orchid that also occurs in the project 

area includes low elevation forested wetlands, medium to high volume old-growth hemlock forests 

with slopes between 15 and 75 percent and high bryophyte cover (Dillman 2008). The orchid is also 

found in redcedar dominated forests with low forb cover as well as forest edges and gaps in otherwise 

shady forests, which also occur in the project area. There are two known populations of this orchid in 

the project area in forested habitats with redcedar component where timber harvest activities are 

planned. 

Unalaska Mist-Maiden

The ANHP ranks the Unalaska mist-maiden as G3S3S4 (rare or uncommon globally), and rare or 

uncommon in Alaska. It is known from one location on the Tongass National Forest, Bald Mountain 

on Heceta Island. Two other plants are documented from Southeast Alaska, one from the Grindle 

Hills near Bering Glacier, and the other was collected near Sitka. The Sitka population has not been 

relocated, and was apparently destroyed in connection with road building. Habitat for this plant in the 

project area includes gravelly areas along streams, and on ledges and crevices in rock outcrops. 

Rare Plants

Plants are designated as rare on the Tongass National Forest for several reasons. These plant species 

are very uncommon, and some may have conservation concerns but have not been designated by the 

Regional Forester as sensitive plants. No rare plant populations with an S1 or S2 ranking were found 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Plants - Chapter 3  301

in the project area. See Botany Resource Report for this project for more information (Dillman 

2013a). 

Environmental Consequences

The direct, indirect, and cumulative effects of the proposed Saddle Lakes Timber Sale are used to 

determine the risk of the project on sensitive species that may potentially be affected. This is 

conducted through a risk assessment, included in the Biological Evaluation for Plants (Dillman 

2013b).

Direct/Indirect Effects

Direct effects are those effects that would occur immediately or soon after the implementation of the 

action. Direct effects to sensitive and rare plants due to project activities include:

Physical Damage: Plants may be destroyed or damaged through crushing by logging equipment and 

activities associated with tree felling and yarding. Road building would completely bury or remove 

plants or entire populations if they were located within the road prism, and could also damage plants 

or populations of plants located along the perimeter of the road embankment (road right-of-way). 

Individual tree species would be harvested and removed from the forest. Other trees may be knocked 

over or broken off due to logging practices. 

Indirect effects are those effects that may occur at a later point in time, perhaps after the project has 

been implemented. Indirect effects to sensitive and rare plants due to project activities may include 

the following: 

Hydrology: Road building can alter the hydrology, as surface and ground water may be redirected 

and channelized by roadside ditches, altering the hydrologic regime. Increased water levels may result 

in the death or decline in vigor of plants not adapted to a high water table. Conversely, plants adapted 

to wetland conditions may become desiccated by a decrease in water availability. best management 

practices (BMPs) would be implemented that limit alterations to hydrology (see Aquatics section).

Light Levels: Partial or complete removal of the tree canopy results in an increase in the light levels 

in the understory, potentially resulting in light levels beyond the tolerance for shade dependent 

species. Once the stand regenerates, light levels would decrease with increasing canopy cover due to 

high density of small conifers. This too may alter normal light requirements for many species, 

including sensitive and rare plants. 

Effects Common to All Alternatives 

Individuals of mountain lady’s slipper, large yellow lady’s slipper, Alaska rein orchid, and Unalaska 

mist-maiden were not found in the project area. No other rare plants with an S1 or S2 rating were 

found in the project area. Therefore, no direct impacts to these sensitive or rare plants are anticipated 

under any of the alternatives. Under all alternatives, undocumented individuals of mountain lady’s 

slipper, large yellow lady’s slipper orchid, Alaska rein orchid and Unalaska mist-maiden or other rare 

plants could be indirectly impacted through light level changes and changes in hydrology if 

individuals exist in the project area. However, habitats associated with these plants are scarce in the 

project area overall and those present are not associated with proposed disturbance areas (harvest 

units and roads). 

No effects are anticipated to the botany resource as a result of implementing the fish passage barrier 

modification and Shelter Cove LTF reconstruction. 
3 Affected Environment and Environmental Consequences

302  Chapter 3 – Plants Saddle Lakes Timber Sale Final EIS

Alternative 1

For all the assessed species, Alternative 1, the no-action alternative would not result in direct or 

indirect effects on sensitive or rare plant populations or their habitats. 

Alternative 2

Alternative 2 has the potential to directly impact one population consisting of one individual of lesser 

round-leaf orchid in Unit 67 without design features. Changes in light levels and hydrology due to 

timber harvest may indirectly impact the one known individual of the lesser round-leaf orchid in Unit 

67. 

Alternative 3

Alternative 3 may directly impact approximately 41 individuals (or 2 populations) of lesser round-leaf 

orchid in Units 111 and 67. Lesser round-leaf orchid may be indirectly impacted through light levels 

changes and hydrology.

Alternative 4 

Alternative 4 may directly impact one population of one individual of lesser round-leaf orchid in Unit 

67. One individual of lesser round-leaf orchid may be indirectly impacted through light levels and

hydrology changes. 

Alternative 5

Alternative 5 may directly impact one individual of lesser round-leaf orchid in Unit 67, and roughly 

40 plants in Units 111, 311 and 307, or 2 populations. Lesser round-leaf orchid may be indirectly 

impacted by Alternative 5 through light levels and hydrology changes. 

Alternative 6

Alternative 6 could directly impact one individual of lesser round-leaf orchid in Unit 67, or 1 

population. This individual of lesser round leaf orchid could be indirectly impacted through changes 

in light levels and hydrology. 

Cumulative Effects

The spatial context for cumulative effects of project activities is Revillagigedo Island. Past, present 

and reasonably foreseeable future actions on Revillagigedo Island that may have impacted or have the 

potential to impact individuals, populations, and the reproductive and dispersal capabilities of 

sensitive or rare plants or their habitats have been considered in the cumulative effects analysis. 

Appendix B includes the interrelated projects (i.e., past, present and reasonably foreseeable future 

actions) that have been considered in the cumulative effects analysis. Cumulative effects to sensitive 

and rare plants due to project activities may include the following: road construction, road storage or 

decommissioning, gravel extraction, timber harvest, subsistence use, the proposed Alaska Mental 

Health Trust land exchange, and recreation.

Individually these effects may be minor, but together can result in incremental effects over time. The 

effects of past Forest Service actions in areas where known sensitive and rare plants occur were 

analyzed through the NEPA process for each past project. None of the past Forest Service projects on 

Revillagigedo Island threatened to impact the viability of known sensitive or rare plants to become 

listed as threatened or endangered. 

However, the impacts to sensitive and rare plant habitat cannot be avoided as the nature of most 

proposed actions contain ground-disturbing actions. Since most ground-disturbing actions 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Plants - Chapter 3  303

predominantly occur in old-growth habitat, the Forest Service acknowledges the importance of this 

habitat through a network of old-growth reserves within the cumulative effects area. Other non-forest 

habitat types that may be associated with potential sensitive or rare plant habitat, while present in the 

cumulative effects analysis area, have minimal disturbance associated with them and are therefore of 

lesser concern than the old-growth habitat.

The following section describes the cumulative effects to plant resources by alternative. For each 

action alternative, the cumulative effects are similar in that past surveys on Revillagigedo Island have 

documented the lesser round-leaf orchid in 71 populations, with a total of 435 individuals. All of the 

locations with more than one individual have recommendations to be protected or avoided during 

management activities to the extent feasible. If any of the populations are associated with future 

Forest Service projects, they would have botanical surveys conducted and project design features or 

mitigation measures recommended to help protect this orchid. With current design features in place to 

help mitigate impacts, all action alternatives would not cumulatively affect the viability of this species 

in the project area. 

There are no known individuals of mountain lady’s slipper orchid, large yellow lady’s slipper orchid, 

Alaska rein orchid and Unalaska mist-maiden on Revillagigedo Island. Some small areas of habitat 

may be impacted in any action alternative but those impacts would not cumulatively affect these 

species.

The determination for lesser round-leaf orchid under all action alternatives is that this project may 

adversely impact individuals, but is not likely to result in a loss of viability in the project area nor 

cause a trend toward federal listing. The determination for mountain lady’s slipper orchid, large 

yellow lady’s slipper orchid, Alaska rein orchid, and Unalaska mist-maiden is no impact for all action 

alternatives. See the project Biological Evaluation for Plants (Dillman 2013b) in the Saddle Lakes 

project record for further information.

Alternative 1

Since no direct or indirect effects would occur under Alternative 1, there would be no cumulative 

effects. Past timber harvest, road construction, and other activities have resulted in some impacts to 

the habitats of these assessed species. In all cases, none of these actions have threatened sensitive 

plant species viability, or the viability of known rare plants.

Alternative 2

One individual of lesser round-leaf orchid was found in this alternative. This individual equates to 

less than 1 percent of the known individuals or populations of this plant in the cumulative effects area 

of Revillagigedo Island. The possible negative effects to this plant as a result of project activities 

would not affect the viability of this species in the cumulative effects area. With design features in 

place to help mitigate impacts to known sensitive plants, Alternative 2 would not cumulatively affect 

the viability of this species. 

Alternative 3

The two known populations of lesser round-leaf orchid have very few individuals. One location has 

one plant and the other population contains approximately 40 individuals. This amounts to less than 5 

percent of the known individuals and populations possibly impacted in the cumulative effects area. 

The possible negative effects to these plants as a result of project activities would not affect the 

viability of this species in the cumulative effects area. With design features in place to help mitigate 

impacts to known sensitive plants, Alternative 3 would not cumulatively affect the viability of this 

species.
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304  Chapter 3 – Plants Saddle Lakes Timber Sale Final EIS

Alternative 4

There was one individual of lesser round-leaf orchid under this alternative. This individual equates to 

less than 1 percent of the known individuals or populations of this plant in the cumulative effects area 

of Revillagigedo Island. The possible negative effects to this one individual as a result of project 

activities would not affect the viability of this species in the cumulative effects area. With design 

features in place to help mitigate impacts to known sensitive plants, Alternative 4 would not 

cumulatively affect the viability of this species.

Alternative 5

There are two known populations of lesser round-leaf orchid under this alternative. One population 

has one individual and the other consists of about 40 individuals that could be affected. This amounts 

to less than 5 percent of the known individuals and populations possibly impacted in the cumulative 

effects area. The possible negative effects to these plants as a result of project activities would not 

affect the viability of this species in the cumulative effects area. With design features in place to help 

mitigate impacts to known sensitive plants, Alternative 5 would not cumulatively affect the viability 

of this species. 

Alternative 6

One population of lesser round-leaf orchid in the project area for Alternative 6 contains one plant. 

This individual equates to less than 1 percent of the known individuals or populations of this plant in 

the cumulative effects area of Revillagigedo Island. The possible negative effects to this one 

individual as a result of project activities would not affect the viability of this species in the 

cumulative effects area. With design features in place to help mitigate impacts to known sensitive 

plants, Alternative 6 would not cumulatively affect the viability of this species.

Design Features and Mitigation Measures

To maintain known sensitive plants in the project area, viable populations would be flagged and 

avoidance measures implemented such as direct felling and yarding in accordance with Forest-wide 

Standards and Guidelines for sensitive plants (USDA Forest Service 2008b). 

If any previously undiscovered sensitive plants are encountered at any time prior to or during 

implementation of this project, protect the population and avoid any disturbance in the area 

containing the population (and similar habitats in that vicinity). The District or Forest botanist or 

ecologist should be notified immediately to evaluate the population and recommend avoidance or 

mitigation measures.
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Saddle Lakes Timber Sale Final EIS Silviculture - Chapter 3  305

Silviculture

This section discusses the rationale used in selecting silvicultural prescriptions for harvest units 

analyzed in the proposed Saddle Lakes Timber Sale project. The timber sale project proposes timber 

harvest resulting in a change of vegetation in portions of the project area. Proposed harvest units can 

be described as productive old-growth (POG) stands where tree growth is generally offset by decay 

resulting in decadent stands of timber. Vegetation modification may include changes to forest 

structure, species composition, and stand health and stability. Changes in vegetation are determined 

by a prescribed silvicultural system that meets project goals and objectives while staying within 

Forest Plan Standards and Guidelines. 

Units of Measure:

The following units of measure were used to evaluate effects of the proposed action and compare 

alternatives: 

• Changes to forest stand structure over time;

• Changes in forest health and productivity;

• Changes in regeneration and species composition of each individual stand; and

• Windthrow hazard and the effects of windthrow.

Methodology

The area covered by this analysis is the Saddle Lakes Timber Sale project area. Information was 

obtained from the GIS data library, aerial photos, and the Forest Service Activity Tracking System 

(FACTS).

Inventory data of the project area was collected during the 2008, and 2011 through 2013 field 

seasons using a combination of walk-through stand exams and sample plots (using the common 

stand exam protocol in a grid system of one plot per 10 acres). The data was summarized using the 

Natural Resource Information System (NRIS): Field Sampled Vegetation program. This 

information is available from KMRD district files. 

The information gathered by this inventory was used to determine the following stand characteristics, 

which contributed to the development of a site-specific silvicultural diagnosis for each harvest unit. 

Observations include stand development stage; stand structure; windthrow potential; and disease and 

decay severity. Logging system feasibility for each harvest unit was also confirmed during field 

visits.

Even-aged and uneven-aged silvicultural systems are prescribed for proposed harvest units within the 

Saddle Lakes project area, and were developed with guidance by a certified silviculturist to meet the 

objectives identified by the planning interdisciplinary team (IDT). The following criteria were used to 

select the appropriate silvicultural system for each harvest unit:

• Desired condition, as determined by the Forest Plan;

• Forest Plan Standards and Guidelines;

• Operational feasibility (logging systems);

• Economics;

• Stand conditions (diseases and decay fungi);
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306  Chapter 3 – Silviculture Saddle Lakes Timber Sale Final EIS

• Windthrow hazard (the presence of tree and stand attributes determining windthrow potential);

and

• Species composition of regeneration.

Incomplete and Unavailable Information

Please refer to this discussion under Issue 2. Timber Availability on page 76. 

Analysis Area

National Forest System (NFS) lands are classified by vegetative cover, soil type, and administratively 

designated land use. This classification scheme is intended to show the amount of land that is covered 

by forested vegetation, with further divisions to show the amount of that land that is capable of, and 

available for, timber production (Figure 19). The Saddle Lakes project area is 38,459 acres and is 

used as the analysis area for this project. The project area is made up of NFS land (34,898 acres) and 

non-NFS land (3,557 acres).

Appendix B includes the interrelated projects (i.e., past, present and reasonably foreseeable future 

actions) that have been considered in the Silviculture cumulative effects analysis

Forest Land

About 93 percent (32,619 acres) of the NFS land in the Saddle Lakes project area is classified as 

forest land. Forest land has at least 10 percent of the area occupied by forest trees of any size, or 

formerly had such a tree cover and is not currently developed for non-forest use.

Non-Forest Land

About 7 percent (2,279 acres) of the NFS land in the Saddle Lakes project area is classified as nonforest. Non-forest land is defined as having fewer than 10 percent of the area occupied by forest trees 

of any size, or formerly had such a tree cover and is now developed for non-forest use.

Productive Forest Land 

About 59 percent (20,635 acres) of the NFS land in the Saddle Lakes project area (63 percent of the 

project area’s forest land) is classified as productive forest land. These lands have timber volumes of 

greater than or equal to 8,000 board feet per acre, or have the potential to achieve this volume and are 

capable of maintaining that volume. This land is capable of producing 20 cubic feet/acre/year of 

industrial wood per year. Productive forest land includes young-growth stands that have regenerated 

with conifer species after natural or human disturbance. Productive forest land does not necessarily 

mean that the stand is within the timber base that is available for commercial timber harvest.

Non-Productive Forest Land 

About 34 percent (11,984 acres) of the NFS land in the Saddle Lakes project area (37 percent of the 

project area’s forest land) is classified as non-productive forest land. These lands are forest lands that 

do not support enough timber volume to meet the criteria for productive forest land.

Suitable and Available Forest Land

About 28 percent (9,784 acres) of the NFS land in the Saddle Lakes project area (47 percent of the 

productive forest land in the project area) is classified as suitable and available forest land. These 

lands include areas physically suitable for timber harvest, can be adequately restocked in 5 years, and 

have been identified in the Forest Plan as within a LUD that is available for timber production. Some 
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Saddle Lakes Timber Sale Final EIS Silviculture - Chapter 3  307

land was removed from the suitable timber base due to Forest Plan Standards and Guidelines within 

those areas.

Unsuitable and Unavailable Forest Land 

About 31 percent (10,851 acres) of the NFS land in the Saddle Lakes project area (53 percent of the 

productive forest land in the project area) is classified as unsuitable and unavailable forest land. These 

lands have resource concerns or are in LUDs that preclude timber harvest. Unsuitable and unavailable 

lands include areas within riparian, beach, and estuary buffers, land on slopes greater than 72 percent

that have unstable soils (harvest is allowed on slopes exceeding 72 percent, but requires an onsite 

slope stability analysis to determine suitability), and other lands currently withdrawn from timber 

production by the Forest Plan or IRAs. 

Volume Strata

Volume strata were determined by using the GIS volume class layer and combining it with GIS soils 

and aspect information. The gross board foot volume of live trees per acre (MBF per acre) by volume 

strata was determined by the re-aggregation of stand exam plot data by volume strata (Table 99). 

Seven stand types have been defined and delineated. The seven stand types can be stratified into high, 

medium, and low volume strata, which are defined below:

High Volume Strata: Areas within timber inventory volume classes 5, 6, and 7 that are on nonhydric soils and have a north or south aspect.

Medium Volume Strata: Areas within timber inventory volume class 5 located on hydric soils or 

areas within timber inventory volume class 4 located on non-hydric soils. 

Low Volume Strata: Areas within timber inventory volume class 4 located on hydric soils. 

Table 99. Gross volume/acre by volume strata in the Saddle Lakes Timber Sale project area

Volume Strata Gross Average Volume/Acre

(MBF/acre)1/

Suitable/Available Forest 

Land Acres2/

Low 21.2 1,150 

Medium 24.9 2,553

High 32.2 2,334

Total 27.12 6,037

Source: USFS Tongass National Forest GIS.

1/ Gross average volume/acre for live trees based on re-aggregated Common Stand Exam plot data.

2/ This is a weighted average based on the Suitable/Available Forest Land project area acres.
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308  Chapter 3 – Silviculture Saddle Lakes Timber Sale Final EIS

Figure 19. Land classifications and acreages in the Saddle Lakes Timber Sale

Affected Environment

Project Area Vegetation Description

The Saddle Lakes project area is a mosaic of coniferous forests in managed and unmanaged 

conditions, interspersed with muskeg, scrubland, and alpine plant communities. The forests are 

primarily dominated by western hemlock (Tsuga heterophylla) and Sitka spruce (Picea sitchensis) 

stands, and scattered stands of Alaska yellow-cedar (Callitropsis nootkatensis) and western redcedar 

(Thuja plicata). Pacific silver fir (Abies amabilis) is also found scattered in the project area as a minor

stand component. Higher percentages of Sitka spruce are found along streams and other well-drained 

sites. The understory shrubs are primarily blueberry (Vaccinium spp.), red huckleberry (Vaccinium 

parvifolium), and rusty menziesia (Menziesia ferruginea). Many species of vascular plants, lichens, 

and mosses occur throughout all habitat types. Forested muskeg with a high percentage of Alaska 

yellow-cedar occurs throughout the project area, especially in the lower elevations. Muskeg areas also 
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Saddle Lakes Timber Sale Final EIS Silviculture - Chapter 3  309

support shore pine (Pinus contorta var. contorta) and mountain hemlock (Tsuga mertensiana). Red 

alder (Alnus rubra) is found on disturbed sites such as roadsides, landslides, managed stands, and 

along stream banks.

Stand Structure

All of the stands proposed for timber harvest in the proposed Saddle Lakes project have an oldgrowth structure, and have not had any previous commercial harvesting activities. Old-growth stand 

structure varies depending on habitat type, but generally contains large trees over 100 years in age, 

multi-layered canopies, and moderate shrub understory. 

Species Composition

Plant associations are a type of vegetation classification system based on the climax plant community. 

Stands within a specified plant association are comprised of vegetation with similar species 

composition and abundance. Plant associations can be used to predict site response to changes caused 

by management practices.

The species composition of the unit pool proposed for harvest based on stand exam plots and walkthrough exam data is: western hemlock 44 percent; western redcedar 26 percent; Alaska yellow-cedar

15 percent; Sitka spruce 11 percent; and mountain hemlock 3 percent. These percentages are based on 

the percent of gross board foot volume (mbf) of live trees in the original logging system 

transportation analysis (LSTA). Pacific silver fir, red alder, and shore pine comprise about 1 percent 

of the total gross volume.

Forest Health and Natural Disturbance Issues

Forest health and natural disturbance issues in the Saddle Lakes Timber Sale project area include 

hemlock dwarf mistletoe infestations, decay-causing fungi, windthrow potential, and Alaska yellowcedar decline. The Silviculture Resource Report discusses the presence and severity rating of these 

forest damaging agents in each of the proposed harvest units (Bramstadt 2013). A generalized 

discussion of each of these forest-damaging agents is presented below. 

Hemlock Dwarf Mistletoe

Hemlock dwarf mistletoe (Arceuthobium tsugense) is widespread throughout the western hemlock 

dominated old-growth forests of Southeast Alaska, including the Saddle Lakes project area. This 

parasitic plant is also “the leading cause of disease of western hemlock in unmanaged old-growth 

stands in Southeast Alaska” (Mulvey and Lamb 2012, pg. 37). It reduces the vigor and growth rate of 

hemlock trees and often produces a low quality of timber. Cankerous swellings often occur at the 

point of infection on limbs and main stems.

Stands which are partially harvested by uneven-aged management may have some residual infested 

trees. Managers should recognize the potential reduction in timber volume and value from hemlock 

dwarf mistletoe under uneven-aged management scenarios. In some situations, the Saddle Lakes 

project proposes to partially harvest stands with high mistletoe ratings in order to mitigate the effects 

of clearcut harvest on wildlife and scenery resources. Complete harvesting is an effective method of 

controlling hemlock dwarf mistletoe, as reduction or eradication of the disease is consistent with 

management objectives (Hennon et al. 2001, pg. 7). 

Hemlock dwarf mistletoe infestation was found in most of the proposed harvest units in the Saddle 

Lakes project area. About 22 units had no mistletoe infestation observed, 69 units had a low severity 

rating, 37 units had a moderate severity rating, and 35 units had a high severity rating. Hemlock trees 
3 Affected Environment and Environmental Consequences

310  Chapter 3 – Silviculture Saddle Lakes Timber Sale Final EIS

in units were rated using the 6-class dwarf mistletoe rating system developed by Frank Hawksworth 

(Hawksworth and Wiens 1996, pg. 124). 

Decay Fungi

Approximately one-third of the old-growth timber volume is defective in Southeast Alaskan oldgrowth stands (Mulvey and Lamb 2012, pg. 36). While heart rot causes considerable damage in 

all Southeast Alaska conifer species, it is most common in western hemlock, mountain hemlock, 

and Sitka spruce. 

Decay centered in the boles of trees can weaken the support structures, thereby leading to breakage.

As the broken portion of the tree falls to the forest floor, it may wound adjacent trees and lead to 

eventual infection of the damaged trees. This is a continual process in old-growth forests in Southeast 

Alaska and contributes to the diversity of the stand structure. This process decreases the health and 

windfirmness of the stand, leading to decreased ability to provide a future timber supply and therefore 

reducing the stand’s ability to reach its desired condition. Any merchantable timber volume increase 

as a result of tree growth in most old-growth units in the Saddle Lakes project is predicted to be either 

offset or exceeded by decay. 

Decay-causing fungi are present in all of the stands within the Saddle Lakes project area. Harvest 

units in the project area were rated high, moderate, or low for decay fungi presence. There are 10 

units in the proposed unit pool that were rated high for the occurrence of decay fungi, 95 units were 

rated moderate, and 53 units were rated low. A high rating was given when it appeared that the 

average defect per tree exceeded 30 percent of the gross volume. A moderate rating was given when it 

appeared that the average defect per tree was between 20 to 30 percent of the gross volume. A low 

rating was given when the average defect per tree appeared to be less than 20 percent of the gross 

volume. A low rating was usually only given where a large amount of the trees in the stand are young.

Wind Disturbance

Wind is the major natural disturbance agent affecting forest dynamics in Southeast Alaska. It recycles 

forest stands, maintains and renews the forest ecosystem, and provides woody material for wildlife 

use. Wind also affects stand structure and development, causes the mixing of soil by uprooting trees, 

and exposes bare mineral soil, which is the preferred seedbed for Sitka spruce and cedars (Harris 

1989, pg. 13-14). 

Windthrow, or the act of trees being uprooted by the wind, plays an important role in the stand 

development of Southeast Alaska forests. The creation of canopy gaps by the loss of individual trees 

or groups of trees allows more available light to reach the forest floor. This allows for understory 

shrub species and less shade-tolerant conifers (such as Sitka spruce and cedars) to become 

established in a stand. Winds can break off portions of trees, thereby wounding nearby trees and 

allowing for their infection by decay fungi. 

The severity and frequency of wind disturbance is determined by many interrelated factors. Existing 

windthrow in a stand is an important indicator or potential hazard. Individual tree characteristics that 

aid in evaluating windthrow potential include tree height/diameter ratio, size of crown, rooting depth, 

degree of exposure, root and stem decay, tree lean, seedbed, and species. Western hemlock, mountain 

hemlock, and Sitka spruce are generally less windfirm than western redcedar and Alaska yellowcedar. Stand characteristics that aid in evaluating windthrow potential include stand age, stand height, 

stand density, species composition, topography and aspect. Areas exposed to southerly storm winds 

are generally more susceptible to windthrow risk (Harris 1989, pg. 19-27). 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Silviculture - Chapter 3  311

Individual tree and entire stand characteristics and the stand’s observed windthrow history were used 

to rate the windthrow hazard potential for each proposed harvest unit in the Saddle Lakes project area. 

Within the project area 60 units were rated high, 93 units were rated moderate, and 8 units were rated 

low for windthrow hazard. 

Yellow-Cedar Decline

Yellow-cedar decline has resulted in considerable mortality to Alaska yellow-cedar trees in Southeast 

Alaska since 1900. Mortality can be in small patches or can cover large expansive areas. Affected 

trees may die quickly (in 2 to 3 years) or slowly (over the course of 15 years or longer), with their 

crowns progressively thinning. Yellow-cedar decline is characterized by extensive tree deaths 

occurring in and around open-canopy forests on poorly drained soils. The distribution of yellow-cedar 

decline suggests climate as a trigger, with the presence of snow as the key environmental factor. 

Yellow-cedar decline is associated with freezing injury to fine roots that results when early spring 

snowpacks are not deep enough to insulate and protect the roots from late-season cold events. Where 

sufficient snow is present in spring, Alaska yellow-cedar tree roots appear to be protected from 

freezing injury. Thus, weather events in late winter and early spring that result in low snowpack cause 

injury, and sometimes mortality (Mulvey and Lamb 2012, pg. 45-47). 

In terms of ecological effects, yellow-cedar decline has altered stand structure and stand composition. 

This has led to succession favoring other conifer species, such as western hemlock, mountain 

hemlock, and (to some extent) western redcedar. Given the extent of yellow-cedar decline and poor 

regeneration of this tree species, Alaska yellow-cedar populations can be expected to diminish 

regionally, although extinction is not likely (Mulvey and Lamb. 2012, pg. 47-48). 

There are about 1,797 acres of yellow-cedar decline mapped in the proposed Saddle Lakes project

area, with the majority occurring at elevations below 1,400 feet (source: GIS Cedar Decline layer). 

Within the proposed project unit pool, 15 units were rated high, 51 units were rated moderate, and 36 

units were rated low for yellow-cedar decline, while 56 units had no yellow-cedar decline present. 

Units were rated based on the percentage of the unit affected by yellow-cedar decline. Units with over

66 percent of the area affected were rated as high, units between 33 to 66 percent affected were rated

as moderate, and units with some yellow-cedar decline (less than 33 percent) were rated as low.

On April 10, 2015, the U.S. Fish and Wildlife Service announced it’s 90-day finding on a petition to 

list yellow-cedar as endangered or threatened under the Endangered Species Act. Based on its review, 

the Service finds that the petition, dated June 24, 2014, presents substantial information indicating 

that listing this species may be warranted. The Service is seeking scientific and commercial data and 

other information on the status of and threats facing the yellow-cedar throughout all of its range 

through a 60-day public information period which will assist in a future status review.

Based on the results of the status review, the Service will issue a 12-month finding on the petition, 

which will address whether listing the species as threatened or endangered is warranted, as provided 

in section 4(b)(3)(B) of the Endangered Species Act. 

Precommercial Thinning 

Precommercial thinning (PCT) removes excessive stand stocking through the cutting of less desirable 

trees, while leaving the most desirable trees in a free-to-grow condition. PCT can be used to achieve 

various residual stand densities depending on the overall resource objectives. PCT is a treatment 

which not only redistributes stand growth on selected trees (stems), but also delays canopy closure 

and extends the time that forage is available for wildlife species (Hanley et al 2013, Cole et al. 2010, 

Doerr and Sandberb 1986). PCT is a common intermediate silvicultural treatment employed in 
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312  Chapter 3 – Silviculture Saddle Lakes Timber Sale Final EIS

young-growth stands on the Tongass National Forest. Current PCT activities across Revillagigedo 

Island are favoring the retention of Alaska yellow-cedar. This is expected to maintain and/or increase 

the amount of yellow-cedar in future stands.

The first PCT program for young-growth stands in the Saddle Lakes project area was completed in 

1990. A total of 1,094 acres of young-growth stands have been thinned between 1990 and 2012. 

Environmental Consequences

Actions Common to all Alternatives

The Forest Service proposes to grant a right-of-way (ROW) to the State of Alaska to provide for 

future road construction as part of the Ketchikan to Shelter Cove Road. The proposed Ketchikan to 

Shelter Cove Road (ROW Corridor) is about 1 mile long and 300 feet wide. The exact 

location/alignment of the future State of Alaska road construction is unknown at this time, but would 

be along a 66-foot wide by about 1 mile long ROW inside the Ketchikan to Shelter Cove Road (ROW 

Corridor). The future road would provide additional access to existing and new road systems on 

Revillagigedo Island. The Forest Service is reviewing the ROW grant application from the State of 

Alaska now. Future road construction within the ROW would be consistent with Forest Plan 

Standards and Guidelines and BMPs. The timing of the ROW grant is unknown at this time.

The construction of the Ketchikan to Shelter Cove Road would have a minimal impact to forest 

vegetation due to the small footprint of the proposed action. The majority of the ROW affects small 

portions of old-growth vegetation, but a small portion of young growth would be affected along the 

northern portion. There is an increased potential for future damages from wind in areas affected by 

road construction. However, past experience has shown that this increase would be minimal and not 

extend beyond the ROW corridor. There are many advantages to having this road connection built as 

ease of access to the Shelter Cove area would help facilitate and lower costs for future vegetation 

management projects such as forest stand improvement, watershed improvement, and wildlife habitat 

improvement. 

Desired Condition

The desired future condition for stands within the Saddle Lakes Timber Sale project area is 

determined by the LUDs established by the Forest Plan, and to some degree by the proposed Saddle 

Lakes Timber Sale project’s goals and objectives. The goals and objectives of the LUDs in the Saddle 

Lakes project area are presented in Chapter 1 of this document. Also, see Figure 3 in Chapter 1. 

Vegetation Management/Silvicultural Systems

Silvicultural systems are used to manage, harvest, and re-establish stands of forest trees for the 

purpose of meeting predetermined objectives. Silvicultural systems have been developed to increase 

commercially valuable timber more rapidly, maintain wildlife habitat, and either maintain or enhance 

scenery values. No single silvicultural system for a forest stand can be used to achieve all the desired 

combinations of amenities and products. Instead, a variety of treatments applied over an area results 

in a mosaic of stands for different uses. Existing stands are altered by proposed management actions 

through timber harvest and/or other treatments, such as thinning or pruning. 

The Forest Plan Standards and Guidelines and USDA FSM 2400 (Timber Management) provide 

detailed information about the silvicultural systems recommended for the Tongass National Forest. 

Even-aged management results in the conversion of mature stands to faster growing stands of a single 

age. Uneven-aged management results in a stand of younger trees interspersed with older trees 

distributed either in clumps or more evenly across the stand. The post-harvest conditions of the forest 
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Saddle Lakes Timber Sale Final EIS Silviculture - Chapter 3  313

stand for all systems are dependent upon the existing plant community, the retained canopy structure, 

and advanced regeneration. Species composition is monitored to ensure that the mix of species is 

roughly the same as expected on the existing site. 

The Saddle Lakes project uses two silvicultural systems, even-aged and uneven-aged to meet sitespecific objectives of the Saddle Lakes project area. The silvicultural systems chosen are based upon 

LUD direction and desired conditions, Forest Plan Standards and Guidelines, and stand conditions.

The site-specific objectives include:

• Retention of old-growth characteristics to maintain biodiversity;

• Favorable timber sale economics and logging feasibility;

• Protection of soil, watershed, wildlife habitat, and scenery characteristics of the project area;

• Regeneration of decadent, defective, and damaged stands to establish a vigorous new cohort for

future timber production; and

• Maximized wood-fiber production for future human use.

A complete silvicultural prescription for the entire length of the rotation would be written for each 

stand selected for harvest. These prescriptions provide guidance for treatments following the 

proposed timber harvest for this project, and may including subsequent entries, thinning, and pruning. 

Silvicultural prescriptions sometimes vary by alternative in order to address the different management 

objectives being analyzed in the range of alternatives. These differences in alternatives are driven by 

issues identified during the scoping process for this project. For example, a harvest unit may be 

planned for even-aged management under an alternative emphasizing the maximum timber harvest 

from the project area. Under an alternative using helicopter yarding methods to minimize road 

impacts and retain forest structure in alternatives emphasizing wildlife or scenery issues, a harvest 

unit may be planned for uneven-aged management. In most cases, the silvicultural prescription for a 

treatment area remains the same between the different alternatives. Table 100 shows acres by 

silvicultural system and the regeneration method for each alternative. 

Table 100. Acres of silvicultural system and prescription by alternative for the Saddle Lakes Timber Sale 

unit pool

Silvicultural 

System

Silvicultural 

Prescription

Logging 

system

Alternative (in acres)

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

Even-aged 

Management

Clearcutting

Cable/Shovel 0 1,055 816 1,882 2,150 1,654

Helicopter 0 0 0 190 443 0 

Even-aged Total 0 1,055 816 2,072 2,554 1,654

Uneven-aged 

Management

Single-tree 

Selection

(up to 33% 

removal)

Shovel 0 52 0 0 0 0 

Helicopter 0 1,100 196 307 275 494

Cable 0 0 0 5 5 5 

Uneven-aged Total 0 1,152 196 312 280 499

All Prescriptions Total 0 2,207 1,012 2,384 2,834 2,153

Note: Data obtained from the Ketchikan-Misty Fiords Ranger District GIS library.
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314  Chapter 3 – Silviculture Saddle Lakes Timber Sale Final EIS

Even-aged Silvicultural System (Clearcutting)

The objectives of this system are to create a fast-growing stand of trees to maximize wood-fiber 

production, and to provide favorable timber sale harvest economics and logging feasibility. Natural 

regeneration in these stands is expected to be abundant, and would represent the original species 

composition in a mostly single-aged stand. The even-aged management prescription entails the 

cutting of all or the majority of the merchantable trees in a stand (clearcutting), leaving less than 10 

percent of the original stand’s basal area following one harvest entry. It produces a fully exposed 

microsite for the development of a new age class.

Maintaining a reasonable assurance of windfirmness (RAW or windfirming) would typically be 

applied to unit edges or stream and visual buffers determined to be at risk for wind damage after 

harvest. These would generally be the edges of harvest units or stream buffers that have high 

exposure to southeast storm winds. Where windfirming is applied would vary depending on the 

topography and location of the buffer within the unit. 

Justification for Clearcutting

Even-aged management (clearcutting) is prescribed in the Saddle Lakes project area to regenerate 

stands poorly stocked with desirable trees, and are not expected to obtain the desired condition given 

their current growth trajectory. Even-aged clearcutting would target stands that are mature to overmature where the current stand growth is being offset or exceeded by decay. Clearcutting would 

preclude or minimize the risk of windthrow post-harvest, promote natural regeneration by opening up 

the canopy, minimize logging damage, and minimize tree defect and disease in the future stand to the 

maximum extent possible. (Forest Plan, page 4-72). Finally, clearcutting maximizes the use of 

conventional yarding systems (cable and shovel), which maintains the potential for an economic 

timber sale offering.

Size of Even-aged Openings

National Forest Management Act (NFMA) regulations provide that 100 acres is the maximum size of 

created openings allowed for the forest types of coastal Alaska, unless specific conditions exist. The 

Forest Plan defines these conditions (USDA Forest Service 2008b, TIM5, III.A, pg. 4-72). With 

Forest Supervisor approval, where it is determined by environmental analysis that exceptions to the 

size limit are warranted, the actual size of openings may total 150 acres if increased unit sizes 

produce more desirable benefits (USDA Forest Service 2008b, TIM5, III.C, pg. 4-72). Leave strips 

between openings must be of sufficient size and composition to be managed as a separate stand, with 

a minimum stand mapping size of 10 acres (USDA Forest Service 2008b, TIM5, III.F, pg. 4-72). 

Some proposed harvest units lie adjacent to recently created even-aged openings. Previously created 

openings must be adequately stocked with desirable tree species, which are approximately 5 feet in 

height, before the area would no longer be considered an opening for the purposes of determining 

limitations on scheduling, locating, and calculating the size of additional created openings (USDA 

Forest Service 2008b, TIM5, III.E, pg. 4-72). 

Alternative 5 of the Saddle Lakes Timber Sale project proposes three harvest openings which may 

exceed 100 acres in size. This is the only alternative that contains harvest openings greater than 100 

acres. All of these openings contain unit designs that best utilize the topography and available logging 

systems, in order to avoid the isolation of suitable timber and have the greatest impact on forest health 

(specifically in terms of providing windfirm boundaries and reducing hemlock dwarf mistletoe 

infestations in nearby young-growth stands). These larger openings also reduce the overall costs of 

preparation, logging, and administration of harvest activities over unit block designs that would limit 

opening sizes to 100 acres or less. The unit groups, overall acreages, and applicable opening size 

mitigations are shown in Table 101 below. 
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Saddle Lakes Timber Sale Final EIS Silviculture - Chapter 3  315

Table 101. Unit group information for each opening over 100 acres in size that is proposed under 

Alternative 5 of the Saddle Lakes Timber Sale Project

Unit Group Total Opening Size

(acres)

31, 33, 39, 40, 41, 112, 113, 114, 310, 312 135

36, 110, 111, 301, 302, 303, 305, 306, 307, 308, 311 143

46, 74, 115, 146 108

Source: USFS Tongass National Forest GIS.

Uneven-aged Silvicultural System (Single-tree Selection) 

Stands are proposed for uneven-aged management depending upon the identified resource concerns 

for each harvest unit. This system regenerates and maintains a multi-aged structure by removing some 

trees in various age (size) classes throughout the stands either singly, in small groups, or in strips. The 

objective of uneven-aged management is to maintain a stand with trees of three or more distinct age 

(size) classes, either mixed throughout the stand or in small groups. The remaining structure provides 

wildlife habitat and reduces visual impacts. The next entry into these stands would be in 50 to 100 

years, when additional basal area would be removed from each stand in patches or as single trees. The 

silvicultural prescription chosen to achieve the goals of this system is single-tree selection (STS). This 

silvicultural system is sometimes referred to as a partial-cut. 

Single-tree selection: Stands proposed for these prescriptions would have a minimum of 66 percent 

of the basal area retained (33 percent removed) following harvest. Trees would be removed 

individually and/or in small groups of generally 2 acres or less in size. Trees remaining after harvest 

would be about the same species mix as the original stand. The objective of this system is to 

economically harvest a percentage of each stand while retaining timber for future entries that is 

economically viable and sustainable. These types of prescriptions usually involve more intensive 

management than even-aged systems. There is no final rotation age associated with this system, as 

periodic entries are designed to maintain multiple age and diameter classes throughout the stands.

Uneven-aged management would be achieved by leaving 66 percent of a harvest unit’s pre-treatment 

basal area, based on standing live trees left uncut. Healthy, young trees in the intermediate crown 

class would be a priority for retention to promote economic future entries. Older trees with low timber 

value, but high wildlife value would also be a priority for retention. The canopy gaps and disturbance 

created by harvesting the remaining trees would promote new tree regeneration to facilitate future 

harvest entries, as well as promote the growth of understory plants important for wildlife. A retention 

level of 66 percent is used in harvest units that were identified as having particular visual and/or 

wildlife concerns. Future harvest entries would continue the process of developing additional age 

classes. The next entry would likely occur in 50 years. This would allow the intermediate age class to 

develop into mature trees and provide for another economical harvest. Small diameter trees would be 

retained that would have better economic value in the future. The silvicultural prescription would 

maximize the flexibility of helicopter yarding.

Direct and Indirect Effects

The following section describes the direct and indirect effects to silvicultural resources by alternative:
3 Affected Environment and Environmental Consequences

316  Chapter 3 – Silviculture Saddle Lakes Timber Sale Final EIS

Alternative 1

Direct Effects

Under Alternative 1, no new timber harvesting would occur. There would be no direct effects to forest 

structure, forest health and productivity, regeneration and species composition, and windthrow risk 

from the proposed Saddle Lakes Timber Sale project. 

Indirect Effects

Indirect effects to forest structure, forest health and productivity, regeneration and species 

composition, and windthrow risk would include:

Stand Structure

Old-growth stands in the project area would remain in a predominantly old-growth condition. 

However, frequent small-scale disturbance events would likely continue in the stands until a largescale event occurs. At some point in the future it is expected that some stands in the project area 

would experience larger-scale damage from a severe storm event, leading to the regeneration of these 

stands. Stand regeneration would likely lead to a two-aged stand condition, or possibly an even-aged 

stand condition. Forested lands would remain in a relatively similar stand structure condition. 

Forest Health and Productivity

Only natural changes in forest health and productivity would occur. It would be expected that forest 

growth would continue to be offset by decay. Insect and disease processes currently at work would 

persist at their existing levels but due to the general lack of thrift, the forest remains at risk and 

vulnerable to insect and disease attack. Hemlock dwarf mistletoe, where present, would remain in the 

stand and may infect hemlock stems that regenerate in the gaps adjacent to infected overstory trees. 

This would reduce the vigor and growth rate of hemlock trees, while producing a low quality of 

timber. There would be no noticeable increase or decrease in the productivity of the land for the 

production of timber products. 

Diseases present in the residual trees would likely infect the new stand to some degree. Where 

present, hemlock dwarf mistletoe would remain in the stands, and may infect hemlock stems (trees) 

that regenerate in the gaps adjacent to infested overstory trees.

Regeneration and Species Composition

Openings in the forest canopy would be created by windthrow and trees falling as a result of decay. 

Hemlock regeneration would have a competitive advantage over other species when small openings 

in the canopy occurred, further reducing the Alaska yellow-cedar and western redcedar components. 

Sitka spruce regeneration may have somewhat of a competitive advantage in these stands, due to the 

resulting soil disturbance and from uprooted trees.

Windthrow Risk

Stands would remain in a predominantly old-growth condition. Small-scale, frequent disturbance 

events would continue in the stands until a large-scale event occurred. The inherent windthrow risk 

within stands would not change appreciably. 

Alternatives 2, 3, 4, 5, and 6

Direct Effects

Direct effects to forest structure, forest health and productivity, regeneration and species composition, 

and windthrow risk would include the following.
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Stand Structure

Stand structure would be changed by timber harvesting under all of the action alternatives. The 

change would vary by alternative, based on the silvicultural prescriptions and the number of acres 

harvested (see Table 100). Where the prescription is even-aged management, harvest would take 

place by cable, shovel, and helicopter yarding systems. The direct effects would result in the creation 

of young-growth stands that have a species composition similar to the former stand, but with a 

potentially higher component of more shade-intolerant species. Even-aged management would 

primarily lead to stands without any older residual trees present within the harvest unit boundaries. 

In harvest units where 66 percent basal area retention is prescribed, the stand structure change postharvest would be expected to be minor. These stands would remain in the old-growth structural stage 

after harvest, as well as through to the next harvest entry, if unaffected by a major natural disturbance 

event.

Forest Health and Productivity

In harvest units where even-aged management is prescribed, the productivity of the land for timber 

production would be maximized. The risk of insect, disease, and decay outbreaks within the newly 

established growing timber crop would be minimized. The new trees that regenerate after even-aged 

treatments would be vigorous and free from decay. The insect and disease processes at work in the 

stands prior to harvest, including hemlock dwarf mistletoe, would be mostly eliminated. 

In harvest units where uneven-aged management is prescribed, forest health concerns could be used 

as factors to determine which trees to harvest. An attempt would be made to remove the trees that 

pose the greatest risk to the health of the new stands. However, due to the amount of disease and 

decay found within old-growth stands proposed for harvest under this system, it is unlikely that all, or 

even a significant portion, of the trees with disease and decay would be removed. This is because of 

constraints related to visuals, economics, and windthrow risk.

In harvest units where uneven-aged management is prescribed, either individual trees or small 

groups of trees would be removed. These stands would retain some old-growth forest characteristics 

(older trees, wider variation in tree sizes and spacing, decadent timber, and multiple canopy layers). 

The stand's immediate potential to grow commercial timber is expected to be reduced, in proportion 

to the amount of growing space occupied by remaining old-growth trees. 

Regeneration and Species Composition

For harvest units where even-aged management is prescribed, the resulting tree regeneration is 

expected to be vigorous and representative of the species mixture of the former stands.

Where uneven-aged management is prescribed, growing space would be limited by the retention of 

overstory trees. Natural regeneration would occur in the stands in satisfactory amounts, but the 

limited openings in the canopy combined with the low ground disturbance of helicopter yarding 

would promote hemlock regeneration, and could limit the regeneration of Sitka spruce and cedar 

trees. To offset this, it would be important to consider retaining smaller diameter, intermediate Sitka 

spruce and cedar advanced regeneration with good vigor (Deal and Tappeiner 2002, pg. 183-185). 

Windthrow Risk

Where even-aged management is prescribed, windthrow risk would be eliminated within the harvest 

units due to the removal of all large trees. The future young-growth stands created would typically be 

more windfirm than the old-growth stands they replaced.

However, exposed stand edges would have an increased risk of windthrow in the first few years postharvest, due to the presence of an adjacent opening. In units where windthrow risk has been 
3 Affected Environment and Environmental Consequences

318  Chapter 3 – Silviculture Saddle Lakes Timber Sale Final EIS

determined to be of concern, reasonable assurance of windfirmness (RAW) buffers have been 

prescribed in order to reduce or minimize the windthrow risk adjacent to unit edges, or along stream 

buffers that protrude into the harvest openings. 

Where uneven-aged management is prescribed, the basal area retention requirements were increased 

to offset the potential for blowdown in high windthrow risk areas. As a result, it is expected that 

wind risk would remain approximately the same as in the stand prior to harvest. Monitoring results 

from the Alternatives to Clearcutting Study, 5 years post-harvest in wind-prone areas reveal 

approximately 5 percent loss of basal area with the 75 percent basal area retention prescription 

(McClellan, 2007). Based on these results, only minor amounts of windthrow are expected to occur 

following harvest within proposed uneven-age management units with high windthrow risk. 

A mostly unbroken, continuous canopy would remain post-harvest in uneven-aged management units. 

This would reduce the risk of windthrow along edges and adjacent to stream buffers that protrude into 

harvest areas. In most cases, this prescription would eliminate the need for additional windfirming 

treatments in RAW zones. 

In all harvest areas, whether even-aged or uneven-aged, riparian management areas (RMAs) that have 

stream channel stability concerns and potential for windthrow have been identified. The RMAs are 

reviewed in the field once preliminary unit boundaries are in place. The specific windfirming 

prescriptions for each RMA would be determined at that time, as well as whether additional 

windfirming treatments may need to be applied, generally in the form of RAW buffers.

Indirect Effects

Indirect effects to forest structure, forest health and productivity, regeneration and species 

composition, and windthrow risk would include:

Stand Structure

In harvest units where even-aged management is prescribed (clearcut), new stands would naturally 

grow through a number of structural changes into the future. This would begin with a stand initiation 

stage where tree regeneration would first become established and understory plants would flourish. 

The stand initiation stage would be followed by a period of stem exclusion where inter-tree 

competition would shade-out the understory. After that, the stands would enter the stage of understory 

re-initiation, where tree mortality opens-up growing space and an understory, as well as the return of 

some old-growth characteristics (Oliver and Larson 1996, pg. 142-154). The time that any younggrowth stand spends in any given structural stage would be dependent upon the natural growing 

capacity of the land, and any future treatments that are applied, such as precommercial thinning.

In harvest units where uneven-aged management is prescribed, an overstory of residual trees would 

remain in the stands. The stand initiation stage would not generally occur under the 66 percent basal 

area retention prescription, except where group selection resulted in the creation of openings larger 

than 1 acre. The stem exclusion stage would generally occur at a smaller magnitude than in even-aged 

stands, except in the larger openings created. After harvest, these stands would continue to develop, 

and should regain old-growth characteristics quickly if unaffected by a major natural disturbance 

event.

Forest Health and Productivity

There would be no indirect effects to forest health and productivity for stands prescribed with evenaged management.
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Silviculture - Chapter 3  319

For harvest units prescribed with uneven-aged management, there would be a risk of the new stands 

becoming infested with the same disease and decay agents that were present in the stands prior to 

harvest (Hennon et al. 2001, pg. 7). This risk would generally be proportional to the amount of basal 

area retained. Therefore, a higher basal area retention would result in a greater risk of future infection 

than would a lower basal area retention. Decay organisms would be transferred between trees when 

decay-ridden trees fall and strike adjacent healthy trees, either during harvest operations or weather 

events post-harvest. Hemlock dwarf mistletoe would remain in the stands, and likely infest hemlock 

regeneration even with selection criteria favoring the removal of infested overstory trees first. The 

larger old trees retained for wildlife would be of low vigor. These trees would not be expected to 

grow or change in any way as a result of the growing space created by harvest activities. The 

productivity of these stands would be reduced in proportion to the amount of old trees that remain and 

occupy growing space. 

Regeneration and Species Composition

There would be no indirect effects to regeneration and species composition for stands prescribed with 

even-aged management.

For harvest units prescribed with uneven-aged management, high basal area retention could increase 

the abundance of hemlock trees in the stands. These stands could undergo a species conversion to 

nearly pure hemlock stands.

Windthrow Risk

For harvest units prescribed with even-aged management, current moderate to high windthrow risk 

areas are expected to have a lower windthrow risk after stand conversion because trees in even-aged 

stands develop structural resistance to prevailing wind patterns from increased canopy exposure, and 

contain highly windfirm trees along the edges that buffer the interior portions of the stand from the 

full force of the wind. The lower windthrow risk in these regenerating stands is expected to last 

through the next rotation (almost 100 years into the future). In harvest units prescribed with unevenaged management, windthrow risk is expected to remain about the same as the stand prior to harvest.

Table 102. Increase in total young-growth stand acreage located on suitable/available forest lands in the 

Saddle Lakes project area under all alternatives

Alternative Acreage Converted to 

Young-growth Stands (acres)1/

Resulting Total Young-growth 

Stand Acreage

(acres)2/

1 0 3,747

2 1,055 4,802

3 816 4,563

4 2,112 5,859

5 2,594 6,341

6 1,654 5,401

Source: USFS Tongass National Forest GIS.

1/ Acreages converted to young-growth stands are based on total acres prescribed to even-aged management.

2/ Resulting total young-growth stand acreages are based on 3,747 acres of young-growth stands currently located on 

Suitable/Available Forest Lands in the project area.
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320  Chapter 3 – Silviculture Saddle Lakes Timber Sale Final EIS

Cumulative Effects

The analysis area for cumulative effects is the entire Saddle Lakes project area. Cumulative effects to 

forest vegetation would result from timber harvest and intermediate silvicultural treatments. Timber 

harvesting in the Saddle Lakes project area began in 1959 and peaked in the 1990s (see Table 115). 

The project area has about 5,192 acres of young-growth stands, originating from previous even-aged 

harvesting. About 1,183 acres of young-growth stands are located on non-NFS land. Young-growth 

stands on NFS lands account for 3,747 acres of the suitable and available forest land in the project 

area, while the remaining 262 acres are unavailable for harvest. Total acreage of young-growth stands 

on suitable and available lands for future timber harvest in the project area would increase under all 

action alternatives as shown in Table 102. Acreages would vary based on the silvicultural 

prescriptions used and the number of acres harvested. 

Scattered windthrow has occurred throughout the project area along exposed stand boundaries after 

past harvesting, and due to road construction activities.

All previously harvested stands in the project area, with the exception of units harvested within the 

last 3 years, have been certified as regenerated. Regeneration stocking surveys are scheduled to be 

conducted in 2014 on about 31 acres. These former harvest units are expected to be adequately 

regenerated and certified at that time.

Between 1990 and 2012, about 1,094 acres of young-growth stands were precommercially thinned in 

the project area to reduce stocking and improve tree growth and vigor. An additional 1,136 acres of 

young-growth stands are planned for PCT in the project area sometime before 2018, under the 2013 

KMRD Timber Stand Improvement Categorical Exclusion (CE).

This project proposes to re-establish a log raft and/or barge staging area on the west side of Carroll 

Inlet, at the already-existing Shelter Cove LTF. A permit would allow for log raft and/or barge staging 

to facilitate safe log movement from the project area to regional mills and export facilities. The log 

raft/barge staging and associated activities have no potential effects on vegetation resources.

Completion of the proposed Ketchikan to Shelter Cove Road would allow for more economical 

timber harvests from the project area. Road access to and from Ketchikan would give purchasers the 

ability to transport logs via trucks instead of relying solely on more expensive rafting or barging 

methods. The proposed road would also grant the population of Ketchikan more access to needed or 

desired forest resources such as firewood, personal use timber, Christmas trees, etc.

The proposed Alaska Mental Health Trust Authority land exchange includes old-growth and younggrowth acreage in the three LUDs in the project area, as well as inventoried roadless areas (IRAs). 

This proposal would decrease the amount of NFS suitable and available forest land in the project area.

The following section describes the cumulative effects to silvicultural resources by alternative:

Alternative 1

Under this alternative, there would be no change in the young-growth acreage that is suitable and 

available for future harvesting in the project area, and therefore no cumulative effects. Stands in the 

project area would follow a natural course of forest succession. There would be no cumulative effects 

to forest structure, forest health and productivity, regeneration and species composition, and 

windthrow risk.
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Saddle Lakes Timber Sale Final EIS Silviculture - Chapter 3  321

Alternatives 2, 3, 4, 5, and 6

Stand Structure

Harvest associated with the Saddle Lake project would increase the amount of early seral stands in 

the project area where even-aged management is prescribed. Conversely, in areas where unevenaged management is prescribed, there would be little change to the old-growth structure of these 

stands and these stands continue along the gap phase cycle of development. 

Cumulatively the large snag component of the project area would decrease in proportion to the 

amount of even-aged harvest. This decrease would likely be long-term as young-growth stands may

have another regeneration harvest prior to developing a snag component similar to old-growth stands. 

However, some existing large snags could be left on site depending on operating conditions and 

would therefore lessen this effect.

Future precommercial thinning (PCT) activities would provide an opportunity to promote or maintain 

the growth of understory vegetation while promoting vigorous growth of remaining crop trees for 

future harvest. Prescriptions would be developed to manage stands for multiple resource values. 

Implementation options may include the following: leave tree spacing based on site-specific 

objectives; species manipulation; maintaining a minimum 10-foot buffer adjacent to streams; 

maintaining unthinned travel corridors for wildlife species; creation of canopy gaps; and retaining 

unharvested thickets. 

Where PCT is prescribed in young-growth stands, the canopy of the stands would be opened up 

allowing more light to reach the forest floor. Trees would generally be evenly spaced across the stand. 

The stand structure would be expected to change from stem exclusion to more understory reinitiation. Residual trees would receive more direct sunlight and most defective co-dominant and 

dominant trees would be removed from the stand. Understory vegetation would increase for a period 

of time until the crown of the residual trees expanded and closed the canopy again. The heavier the 

level of thinning, the longer the increase in understory vegetation would occur. Some natural 

regeneration of conifer (primarily hemlock) would occur. 

Untreated young-growth stands would progress through the shrubby stand-initiation phase of 

development and would eventually enter into the stem exclusion phase at approximately age 15 to 30 

years, depending on the site. The stem exclusion phase is defined by a high level of fairly uniform 

stocking where trees and the shrubby and herbaceous vegetation are typically poorly represented.

Young-growth stands would continue to develop and receive a variety of intermediate treatments at 

varying times which cumulatively increase the structural complexity of the landscape. The early seral 

structures provided by young-growth stands combined with existing old-growth, muskeg, and nonforest vegetation types provide a shifting matrix of vegetation structural types and development 

throughout the Saddle Lakes project area. The harvest and future treatment activities prescribed for 

forest stands under any of the action alternatives represent a favorable cumulative effect in terms of 

forest structure.

Forest Health and Productivity

Forest health would increase due to the removal of decadent, decaying, and damaged stands. New 

trees that regenerate on harvested sites would be vigorous and free from decay. Insect and disease 

processes, including hemlock dwarf mistletoe, would mostly be eliminated from regenerating stands. 

Future PCT activities would provide an opportunity to maintain stand growth and productivity by 

achieving optimal stocking and availability of resources. Cumulatively, the project area would contain 

old-growth stands with high levels of decay and disease interspersed with older and newly 
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322  Chapter 3 – Silviculture Saddle Lakes Timber Sale Final EIS

regenerated stands of young growth that are vigorous and essentially free of decay and disease 

growing at optimum levels. The harvest and future treatment activities prescribed for forest stands 

under any of the action alternatives represent a favorable cumulative effect in terms of forest health 

and productivity. 

Regeneration and Species Composition

Changes in species composition of the stands may occur as a result of harvest operations and 

intermediate treatments, such as PCT. Sitka spruce is expected to occur at higher levels in harvested 

stands due to the excellent regeneration of this species under favorable light and soil conditions 

created by even-aged management, and by favoring this species as a crop tree during future PCT 

treatments. Conversely, the hemlock component may be reduced in proportion to the amount of Sitka 

spruce in these stands as this species is typically targeted for removal during PCT. While hemlock is 

not a favored crop tree, it is usually well represented in young-growth stands due to the high number 

of stems and cones available on site.

Both cedar species are expected to be represented in similar proportions to their occurrence in stands 

before harvest activities. Both cedar species are shade intolerant, and would benefit from the removal 

of overstory hemlock trees, if advanced cedar regeneration is present on site. Both cedar species are 

favored crop trees when implementing PCT and could increase in proportion depending on 

regeneration.

Based on previous regeneration surveys, Pacific silver fir is expected to regenerate in even-aged 

stands in similar proportions to before harvest activities. In stands that have a Pacific silver 

component but are prescribed for uneven-aged management it is likely that the silver fir component of 

these stands could increase as site conditions would be favorable for the regeneration of shadetolerant species.

Cumulatively regeneration and species composition would remain similar to existing conditions in the 

project area, but as stands develop future intermediate treatments could favor more desirable and/or 

under-represented species.

Windthrow Risk

Scattered windthrow has occurred along exposed forest stand boundaries after past harvests and along 

recent road construction activities. No effort to buffer or stabilize these exposed boundaries and edges 

was previously made. Older, exposed stand boundaries have stabilized naturally, and recently created 

edges along new road construction are expected to stabilize as well. Where abrupt stand edges are 

created, either by timber harvest or road construction, some windthrow may occur. Windfirming 

efforts minimize windthrow, but not completely eliminate it. Future treatments, like precommercial 

thinning, would provide an opportunity to improve windfirmness in previously harvested stands. 

Thinning of young-growth stands allows crop trees to be exposed to typical wind forces and therefore 

allows these crop trees to develop structural characteristics necessary to cope with the stresses of 

wind. Large-scale wind events that significantly modify large areas of old-growth stand structure in 

the project area may occur in the future, regardless of either of the alternatives selected. If events of 

this magnitude do occur, it is unlikely that mitigation measures proposed for this project to assure 

reasonable windfirmness of stand edges or stream buffers would be effective. However, the harvest 

and future treatment activities prescribed for the stands under any of the action alternatives represent 

a favorable cumulative effect in terms of windthrow risk.
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Design Features and Mitigation Measures

Reasonable assurance of windfirmness (RAW) buffers have been prescribed in units where even-aged 

management is prescribed, and windthrow risk has been identified as a concern. RAW buffers serve 

the purpose of reducing or minimizing the windthrow risk adjacent to unit edges, or along stream 

buffers that protrude into harvest openings. In terms of streams, riparian management areas (RMAs) 

that have stream channel stability concerns and potential for windthrow have also been identified. The 

RMAs are reviewed in the field once preliminary unit boundaries are in place. The specific windfirm 

prescriptions for each RMA would be determined at that time, as well as whether additional windfirm 

treatments may need to be applied, generally in the form of RAW buffers. 
3 Affected Environment and Environmental Consequences

324  Chapter 3 – Socioeconomics Saddle Lakes Timber Sale Final EIS

Socioeconomics

This section provides an assessment of the current economic conditions in Southeast Alaska and the 

potential social effects of economic change as a result of implementing the proposed Saddle Lakes 

Timber Sale. The analysis concentrates on the potential effects associated with old-growth timber 

harvest and road construction/reconditioning, and focuses on projected jobs and income associated 

with the Saddle Lakes Timber Sale. 

Other natural resource-based industries that contribute to the Southeast Alaska economy include the 

Southeast Alaska commercial seafood industry, and the recreation and tourism industries. These 

industries have been considered in this analysis to show the general economic trends in Southeast 

Alaska along with the forest products industry. Ecosystem services are benefits people obtain from 

ecosystems and include many non-market values. For this analysis assessing impacts cannot be 

readily expressed in monetary terms.

The Environmental Justice section in this EIS discusses the potential environmental, social and 

economic effects of the Saddle Lakes Timber Sale on minority and low-income populations. 

Units of Measure:

The following units of measure were used to evaluate effects of the proposed action and compare 

alternatives:

• Timber industry employment and income - Number of annualized direct jobs and associated

income;

• Other natural resource-based industries - Qualitative assessment of likely impacts from proposed

timber harvest and road construction/reconditioning on other natural resource-based industries,

primarily the commercial seafood industry and recreation and tourism industries; and

• Non-market goods and services - Qualitative discussion;

Methodology

Socioeconomic conditions are characterized using existing data from the U.S. Department of Labor, 

Alaska Department of Labor and others. Timber industry sector employment information is gathered 

from the 2011 Alaska National Interest Lands Conservation Act (ANILCA) 706(a) Timber Supply 

and Demand Report to Congress, Statistical Appendix (USDA Forest Service 2011a). Some of the 

ANILCA report statistics are sourced from Alaska Department of Labor. Estimates of annualized 

timber jobs and related income used in timber planning were developed using the Forest Service’s 

NEPA financial analysis spreadsheet tool (FASTR) and is discussed in more detail under Issue 1 -

Timber Economics. Information from Tongass Forest Plan Monitoring and Evaluation Reports and 

resource-specific analyses for the Saddle Lakes Timber Sale has also been used. A complete list of 

references and resource information used is in the Socioeconomic Resource Report. 

Information on other natural resource-based industries was derived from McDowell Group Reports, 

Forest Service National Visitor Use Monitoring (NVUM), 2011 Alaska National Survey of Fishing, 

Hunting, and Wildlife-Associated Recreation and other resource-specific analyses developed for this 

Project. The discussion on ecosystem services tiers to and incorporates by reference the 2008 Forest 

Plan FEIS, which contains a discussion of ecosystem services at the forest planning level for the 

Tongass National Forest (USDA Forest Service 2008c, p. 3-544 to 3-556). 

Socioeconomic data and analysis in the 2010 Ketchikan to Shelter Cove Road Socioeconomic Report 

(prepared for the State of Alaska Department of Transportation and Public Facilities is incorporated 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Socioeconomics - Chapter 3  325

by reference under cumulative effects to disclose the economic impacts for Southeast Alaska 

stemming from construction and maintenance of the Ketchikan to Shelter Cove Road (Northern 

Economics 2010). 

The precision and reliability of employment data is limited by the type and accuracy of data collected 

by the Alaska Department of Labor and Workforce Development. For example, regional industry 

sector employment statistics exclude self-employed workers, fishers, domestics, and unpaid family 

workers (Alaska Department of Labor 2013). This affects some employment sector data used in this 

report, notably, the salmon harvesting and processing, where available employment information is 

limited to the seafood processing sector and excludes fishers. Recreation and tourism-related 

employment is also difficult to accurately quantify because visitors spend their money throughout the 

local economy. 

Analysis Area

The analysis area for the Saddle Lakes Timber Sale’s social and economic influence is Southeast 

Alaska. Southeast Alaska is divided into six boroughs and three census areas. The six boroughs 

correspond with the county governments found elsewhere in the United States. Four of these 

boroughs, Juneau, Sitka, Wrangell and Yakutat, are city/boroughs. The other two, Ketchikan Gateway 

and Haines, have independent incorporated communities within their boundaries. The remaining areas 

not part of a borough are allocated to three census areas: Prince of Wales-Hyder Census Area, 

Hoonah-Angoon Census Area, and Petersburg Census Area. While census areas are only statistical 

units, they are widely recognized from a data reporting standpoint by federal agencies and most State 

agencies as county equivalents.

The Southeast Alaska communities located outside of, but in close proximity to the project area, and 

whose residents may use the project area for social and economic activities (e.g., wood products, 

commercial and sport fishing, subsistence, recreation and tourism) include Ketchikan, Saxman and to 

a lesser degree, Metlakatla. Metlakatla is located on Annette Island, 15 miles south of Ketchikan and 

is within the Prince of Wales-Hyder Census Area. More information about these communities can be 

found in the Forest Plan FEIS (USDA Forest Service 2008c, pp. 3-636 to 3-681). 

Affected Environment

Forest products and recreation and tourism are the primary natural resource-based industries that 

could be affected by the Saddle Lakes Timber Sale. Information on the Southeast Alaska commercial 

fishing industry is also provided for a more complete overview of the contribution of this natural 

resource-based industry to the regional economy of Southeast Alaska. 

Economic Conditions and Trends

In the1950s, the timber industry assumed the primary position when Ketchikan Pulp Company (KPC) 

opened. The pulp mill, which became the community's largest employer, was sustained by timber 

supplied from the Tongass National Forest through a 50-year contract with the U.S. Forest Service. In 

October 1996, Louisiana- Pacific, KPC's parent company, announced it would close the pulp mill, and 

in March 1997 laid off 516 workers (Alaska Department of Labor 1997; 2001). In the recent (2010) 

book entitled, “Tongass Timber: A History of Logging and Timber Utilization in Southeast Alaska,” 

the author describes the impacts these mill closures have had on Southeast Alaska as follows: 

“Though numerous businesses have come and gone in Southeast Alaska, none have done so as 

spectacularly and with such long-term impacts as the pulp mills that the Forest Service had worked so 

long and hard to establish and maintain” (Mackovjak 2010). 
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326  Chapter 3 – Socioeconomics Saddle Lakes Timber Sale Final EIS

Job growth in the Southeast Region slowed beginning around 1990, primarily due to the declines of 

the timber and pulp industries and subsequent population loss. The structure of the Southeast 

Region’s economy changed, and although economic growth has slowed as compared to 1960-1990 

timeframe, the Region has shown modest job growth since the timber declines (Alaska Department of 

Labor 2014, exhibit 2, p. 16). Shelly Wright, the Executive Director of the Southeast Conference, 

summarized a 5-year snapshot analysis of the Southeast Alaska economy saying, “the economy of the 

region is no longer trending down following the crash of our timber economy, but has begun 

improving... over the past five years there has been slight improvement in government, seafood, 

visitor industry, health care, and mining jobs. Population is up” (Southeast Conference 2012). 

According to State Economist M. Abrahamson, “The private sector produced 500 new jobs in 

Southeast in 2012, with a diverse set of industries contributing — much more diverse than in 2011, 

when gains were exclusively in mining, seafood processing, health care, and professional services” 

(Alaska Department of Labor 2013f). 

Forest Products Industry

The forest products industry in Southeast Alaska consists of individual- and family-owned sawmills 

and independent logging businesses. Timber harvest within Southeast Alaska is the main source of 

raw materials for the region’s wood products industry (USDA Forest Service 2008c, p. 3-500) and has 

historically been an important part of the economy of Southeast Alaska. In Southeast Alaska, harvest 

levels and associated employment have shown an overall pattern of decline since 1990 (see Issue 1 – 

Timber Economics).

Timber employment dropped sharply in the 1990s and has continued to decline over the past decade, 

falling from a high of 561 jobs in 2003 to a low of 262 jobs in 2011. Tongass National Forest-related 

employment in logging and sawmilling declined from 199 jobs in 2003 to 109 in 2011, a drop of 

about 55 percent. Non-Tongass timber employment (i.e., other sawmill and logging) also declined 

over this period, falling from 362 jobs in 2003 to 153 in 2011, a decrease of 58 percent (see Table 4

under Issue 1 – Timber Economics). 

Overall, sawmill employment in Southeast Alaska dropped from 155 jobs in 2003 to 50 jobs in 2011, 

a decline of 68 percent; logging employment fell from 406 to 212 jobs over the same period, a 48 

percent reduction (Table 4). Southeast Conference (2012) stated, “In 2011, timber accounted for only 

1 percent of jobs and wages in the region with 422 jobs in Southeast (sawmill, logging, logging 

support and wood product manufacturing jobs).” Sawmill employment has historically been created

by Forest Service timber sales, with a small contribution from State timber harvest and other 

ownerships, including State of Alaska and Native Corporation lands. 

Table 103 compares projected annual average 2008 FEIS employment, and annual average 

employment between 2008 and 2011. The 2008 FEIS employment projections assumed maximum 

allowable timber harvest levels given the amount of suitable and available forest land base and 

logging/sawmill sector employment from 2000 to 2005 (USDA Forest Service 2008c, p. 3-537). 

Table 103. Average annual employment in the timber industry

Projected annual average 2008 FEIS employment1/ 1,343 employees

2008-2011 Annual Average Employment2/ 248 employees

Sources:

1/ USDA Forest Service 2008c, P. 2-47, Table 2-19. 

2/ USDA Forest Service 2011a, Table A-2. 
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Saddle Lakes Timber Sale Final EIS Socioeconomics - Chapter 3  327

Timber harvest on the Tongass National Forest also peaked in the late 1980s, with harvest levels 

slightly below 500 MMBF annually (an average of 467 MMBF) in 1989 and 1990 and providing 

between 2,569 and 2,522 jobs, respectively (Brackley et al. 2009, Appendix Table 1; USDA Forest 

Service 2011a, Table A-2). A decade later, Tongass harvest levels dropped considerably to just above 

30 million board feet annually (an average of 32 MMBF) in 2009 and 2010 (see Table 4), and the 

employment numbers followed the timber decline with 87 and 107 jobs, respectively (Table 4). The 

Tongass National Forest has averaged about 37 MMBF per fiscal year between 2002 to and 

2011.Total harvest in Southeast Alaska in 2011 was 112 MMBF, with harvest on the Tongass 

accounting for 29 percent (33 MMBF) of this total, and with more than half the total (63 MMBF) 

provided by Native Corporation lands (Table 4).

According to the Alaska Division of Forestry 2012 Annual Report, “the timber industry in Southeast 

Alaska continues to struggle due to the lack of a short-term and long-term timber supply coming from 

the Tongass National Forest and the lack of harvestable timber on Native corporation land” (ADNR 

2012, p. 10). 

Providing economic timber sales in Southeast Alaska has always been a challenge due to basic lack of 

infrastructure in a relatively isolated and harsh environment (USDA Forest Service 2008a, p.66). The 

Forest Service has received a request from the State of Alaska Department of Transportation and 

Public Facilities for a right-of-way (ROW) on NFS lands for construction, operation and maintenance 

of a public road that would connect existing roads within the project area. This State of Alaska ROW 

is needed for completing the proposed Ketchikan to Shelter Cove Road. It is important to mention this 

road connection as it would provide some benefits to the local economy and the forest products 

industry. A road accessing the project area would provide employment during the construction phases 

and likely benefit the forest products industry in the future. The potential economic benefits of the 

Ketchikan to Shelter Cove Road to the forest products industry are discussed in more detail under 

cumulative effects in Issue 1 – Timber Economics in this chapter. According to the 2010 Ketchikan to 

Shelter Cove Road Socioeconomic Report, the road construction for the Ketchikan to Shelter Cove 

Road would be in two phases: 1) improvements of the existing forest roads and the construction of a 

new segment in the middle; and 2) additional construction, draining improvements, and realignments, 

resulting in a paved, 35 mile per hour road. Road maintenance would also occur after each phase of 

construction is completed (Northern Economics 2010). 

Sawmills

The forest products industry in Southeast Alaska in its current form consists of individual- and 

family-owned sawmills and independent logging businesses. The Tongass Sawmill Capacity and 

Production Report for calendar year 2011 identified ten active and three inactive sawmills in 

Southeast Alaska, with a total installed production capacity of 160 MMBF (Alexander and Parrent 

2012, Table 4). The original list of mills to be surveyed, initially identified in 2001, consisted of 

the 20 largest and/or most active sawmills at that time. Of these 20 mills (increased to 22 in 2007), 

ten were active in 2010, three were inactive, and the other nine had been decommissioned or were 

no longer in production (Alexander and Parrent 2012). More information about mill capacity, 

production, and utilization for Southeast Alaska from Alexander and Parent 2012 can be found in 

the Socioeconomics Resource Report. 

The capacity utilization rate of the only operating medium-sized sawmill in southeast Alaska (Viking 

Lumber) in 2011 was estimated at about 13 percent (Alexander and Parrent 2012). According to the 

Alaska Division of Forestry 2012 Annual Report, Viking Lumber in Klawock, purchased one State 

sale in 2011, for about 4.5 MMBF and a large Forest Service sale for approximately 38 MMBF 
3 Affected Environment and Environmental Consequences

328  Chapter 3 – Socioeconomics Saddle Lakes Timber Sale Final EIS

(ADNR 2012, p. 10). More information about the forest products industry in Southeast Alaska and in 

the Ketchikan vicinity is provided under Issue 1 – Timber Economics in this chapter.

Fisheries and the Commercial Seafood Industry

Since Ketchikan’s establishment as a community, fishing has been integral to its economy. People 

travel from all over the world to fish in Southeast Alaska. The Tongass includes over 17,000 miles of 

salmon habitat, made up of freshwater streams and lakes where salmon return each year to spawn. 

The Tongass National Forest along with many partners is working to restore salmon streams on the 

Tongass. Streams and lakes within the Saddle Lakes project area provide habitat and contribute to the 

production of fish that supports the local subsistence, sport, and commercial fisheries of the area. 

Commercial fishing is a major industry in Ketchikan. The salmon fishery drives most of the economic 

effects associated with the commercial seafood industry in Southeast Alaska (McDowell Group 

2013b). Statewide, 2013 proved to be a record year for salmon with 272 million fish harvested. 

Southeast Alaska proved to be the most valuable salmon fishing area in 2013 with the largest number 

of salmon (38 percent) caught in the State, and an all-species harvest value of over $219 million 

(ADF&G 2013). 

The economic drivers for the commercial seafood industry in Southeast Alaska include commercial 

fishing, seafood processing, government, salmon hatcheries, and tender operators. According to the 

McDowell Group (2013a), the seafood industry directly employed about 13,500 individuals within 

the Southeast Alaska region and generated an estimated $321 million dollars in labor income in 2011. 

On an average monthly basis, the seafood industry directly created 6,500 jobs. Indirect and induced 

jobs and income are created as a result of business and personal spending stemming from the seafood 

industry. In 2011, indirect and induced employment and income resulted in employment of 4,000 

individuals (3,150 average monthly jobs), and an estimated $147 million dollars in labor income. The 

Socioeconomics Resource Report provides a complete summary of the 2011 economic data for the 

commercial seafood industry.

Recreation and Tourism

Recreation and tourism are heavily represented in the economy of Southeast Alaska (USDA Forest 

Service 2008c, p. 3-494); however, recreation and tourism-related employment is difficult to 

accurately quantify because visitors spend their money throughout the local economy. There is no 

single “tourism industry” and no direct measures of tourist-related income or employment (USDA 

Forest Service 2008c, p. 3-511). 

Because the Saddle Lakes project area is remotely located (only boat and plane accessible) from 

Ketchikan, large numbers of people do not frequent the area. Information about recreation and 

tourism in the Saddle Lakes project area is discussed under Issue 4B above in this chapter. The 

economic contributions of recreation and tourism to the Southeast Alaska economy are discussed 

below to facilitate an understanding about the potential cumulative economic impacts as a result of 

future recreation and tourism opportunities in the Saddle Lakes project area. As mentioned above 

under the Forest Products Industry discussion in this section, the future Ketchikan to Shelter Cove 

Road would provide a new public road connection into and through the project area. The Ketchikan to 

Shelter Cove Road is listed as the Harriet Hunt - Shelter Cove Connection Road in Appendix F of the 

2008 Tongass Land and Resource Management Plan (Forest Plan). Having public road access to and 

through the project area would provide for increased recreational and tourism-related opportunities 

and likely contribute to the local economy.
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Saddle Lakes Timber Sale Final EIS Socioeconomics - Chapter 3  329

Resident recreation demand is influenced by a number of factors, including regional population 

levels, per capita participation rates, and recreation travel behavior. Over time, the supply of certain 

recreation opportunities in Southeast Alaska has increased. Road systems have expanded into 

previously inaccessible areas and visitor services and tourism marketing have also increased (USDA 

Forest Service 2008c, pp. 3-373 and 3-374). 

According to the 2012 Tongass National Forest Monitoring and Evaluation Report, the Alaska 

Department of Labor employment statistics are compiled by industry sector and (as mentioned 

previously) there is no single sector representing recreation and tourism (USDA Forest Service

2012b). Employment in the recreation and tourism sector is a component of a number of related 

sectors such as leisure and hospitality and other services. Studies conducted by the McDowell Group 

for the State of Alaska Department of Commerce, Community, and Economic Development provide 

useful information on visitor volume (McDowell Group 2013c) and the economic impact of Alaska’s 

visitor industry (McDowell Group 2013b). 

According to the McDowell Group (2013b), Alaska’s visitor industry accounted for an estimated 

37,800 full- and part-time jobs between May 2011 through April 2012 in Southeast Alaska, and 

generated $3.72 billion in spending, including all direct, indirect, and induced impacts (McDowell 

Group 2013b). Table 104 summarizes the estimated visitor industry employment, labor income and 

spending in Southeast Alaska in 2011 to 2012 and provides a comparison to the State totals. These 

data include direct, indirect and induced effects of jobs and income created as the visitor dollar is respent by visitor industry businesses and their employees. Induced effects include jobs and income 

created as a result of employees of the visitor industry spending their payroll dollars in support of 

their households. 

Table 104. Estimated visitor industry employment, labor income and spending in Southeast Alaska, 2011 

to 2012

Region Employment Labor Income Visitor Spending

Southeast 10,200 $370 million $1,966 million

State of Alaska 37,800 $1.24 billion $3.72 billion

Source: McDowell Group 2013b, p. 17.

Note: Study period of May 2011 through April 2012.

Statewide, visitor industry-related employment of 37,800 accounted for 8 percent of all employment. 

In terms of relative contribution to the regional economy, visitor industry employment is most 

important in Southeast Alaska. Visitor industry-related employment of approximately 10,200 jobs 

represented 21 percent of the region’s 49,000 full- and part-time jobs (McDowell Group 2013b, p 18).

Cruise Ship Revenues

Southeast Alaska’s Inside Passage is advertised and promoted by the Division of Tourism, cruise ship 

operators, and the Southeast Alaska Tourism Council. Their marketing strategy focuses on the scenery 

of the Tongass National Forest as a major attraction. The 2011 cruise ship dockage/moorage revenues 

to Southeast Alaska municipalities (primarily Ketchikan, Juneau, Sitka and Haines), was $15,225,000 

(McDowell 2013b, p. 26). Ketchikan is a principal destination for visitors to the Tongass National 

Forest, receiving close to a million cruise ship visitors annually as well as independent travelers that 

arrive via the ferry system, private boats, and flights. It is the second most visited destination in 

Alaska, with 58 percent of all visitors stopping in Ketchikan (McDowell Group 2012c). Ketchikan

experienced a record year in 2013 for the number of cruise ship passengers. According to the January 

2014 State of Alaska report on Commercial Passenger Vessel Excise Tax, in Ketchikan there were just 
3 Affected Environment and Environmental Consequences

330  Chapter 3 – Socioeconomics Saddle Lakes Timber Sale Final EIS

over 950,000 cruise ship passengers, which is an increase of almost 54,400 passengers from 2012, 

and breaks the record of nearly 942,000 visitors in 2008 (State of Alaska DCCED 2014). According 

to the 2008 Forest Plan FEIS, shore excursions have become an important part of the cruise ship 

experience, with much of this activity centered around communities. Half-day and day excursions 

into the Forest are increasing in popularity (USDA Forest Service 2008c, pp. 3-374 to 3-375). If 

current trends continue, demand for on-shore excursions and tours may continue to increase, adding 

seasonal employment.

The Socioeconomics Resource Report also includes a summary of the annual Alaska visitor volume 

from 2003-2013, but is not specific to Southeast Alaska.

Forest Recreation Use

Some recreational use activity is known for areas on NFS lands in the Saddle Lakes project area and 

is discussed above under Issue 4B – Recreation Opportunities. During the recent planning efforts 

associated with the 2012 Ketchikan-Misty Fiords Ranger District Outfitter and Guide Management 

Plan, guides requested more opportunities close town as a potential means to grow their recreationrelated businesses. Commercial boat-based tours use both George and Carroll Inlets, but do not have 

any shore stops and therefore do not have a special use permit from the Forest Service.

Forest Service National Visitor Use Monitoring (NVUM) is a national monitoring program with a 

goal of assessing levels of Forest recreation use, demographics of users and economic contributions 

of Forest visitors. Examined employment sectors are complex and depend on many factors including 

local, State and national economies. The NVUM data provides estimates for economic contributions 

of the Tongass on the recreation and tourism industry, though employment estimates should not be 

compared with employment projections provided in the 2008 FEIS. Forest-related economic 

contributions reported by NVUM include the amount of money spent during visits. According to the 

2012 Tongass National Forest Monitoring Report, the reported annual average employment for 

industry sectors which may include recreation and tourism employment show a slight decline but 

have remained relatively stable from 2008 to 2012 (USDA Forest Service 2012b). 

Wildlife-related Recreation

The diversity of wildlife on the Forest provides many opportunities for consumptive and nonconsumptive uses including commercial, sport, and subsistence hunting and fishing, and photographic 

and viewing activities. Commercial, sport, and subsistence fisheries are important to the way of life

for Southeast Alaskan residents. Sport fishing is a favorite activity of residents and visitors (USDA 

Forest Service 2008c). 

The Saddle Lakes project area and WAAs 406/407 fall within the community use areas of Metlakatla, 

Saxman, and Ketchikan. Hunting and trapping occur in the Saddle Lakes project area, and deer

hunting is the predominate activity, although black bear hunting has also occurred in the area. The 

affected environment for wildlife subsistence use in the Saddle Lakes project area is described under

Issue 3B – Subsistence Use in this chapter. The Sitka black-tailed deer is the wildlife species 

receiving the highest hunting and subsistence use of all terrestrial species in Southeast Alaska (USDA

Forest Service 2008c, p. 3-230). Fish and aquatic resources on the Tongass National Forest provide 

important subsistence, commercial, and sport fisheries, as well as traditional and cultural values.

Roughly 50 percent of the streams (Class I and II) in the Saddle Lakes project area contain 

anadromous or resident fish, indicating high fisheries value within the project area. Currently there is 

no regulated sockeye subsistence or personal-use fishery within the Saddle Lakes project area, and 

there are no known freshwater subsistence activities taking place in the project area. 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Socioeconomics - Chapter 3  331

The Socioeconomics Resource Report also includes a summary of the U.S. Fish and Wildlife Service 

2011 National Survey of Fishing, Hunting, and Wildlife-Associated Recreation Alaska, but is not 

specific to Southeast Alaska.

Ecosystem Services

Healthy forest ecosystems are ecological life-support systems. Forests provide a full suite of goods 

and services important to public and community needs, livelihoods, and preferences. Many of these 

goods and services are traditionally viewed as free benefits to society, or “public goods” - wildlife 

habitat and diversity, watershed services, carbon storage, and scenic landscapes, for example. These 

natural assets are known as ecosystem services. The concept of ecosystem services has emerged as a 

way of framing and describing the comprehensive set of benefits that people receive from nature.

Lacking a formal market, these natural benefits are absent from traditional market “balance sheets,” 

and their contributions are often overlooked in public, corporate, and individual decision-making. 

While the natural benefits associated with the Tongass National Forest as a whole are no doubt 

considerable, they are extremely difficult to accurately measure, particularly on a per acre basis. The 

Forest Plan FEIS does not assign a monetary value to ecosystem services (USDA Forest Service

2008a, p. 51), but recognizes their importance and gives them full consideration. 

Ecosystem services are described in a number of different ways including the typology developed by 

the 2005 Millennium Ecosystem Assessment (Millennium Ecosystem Assessment 2005). According 

to the Millennium Assessment, there are four general categories of ecosystem services: provisioning, 

regulating, cultural, and supporting. Provisioning services include the products or commodities 

obtained from forest ecosystems, such as clean air, fresh water, fiber, forage, fuel, minerals and food.

Regulating services are the benefits obtained from ecosystem impacts on natural processes, such as 

air quality, climate stabilization, water quality, and erosion. Cultural services are the nonmaterial 

benefits people derive from forests, such as educational, aesthetic, spiritual and cultural heritage 

values, recreational experiences, and tourism opportunities. Supporting services are a category of 

ecosystem services often described as intermediate services (e.g., biodiversity) that contribute to the 

production of other ecosystem services often described as final ecosystem services (e.g., food). 

Supporting services include such things as pollination, seed dispersal, soil formation, nutrient cycling, 

biodiversity and resilience.

A large proportion of the Forest Plan FEIS is devoted to assessing impacts to the forest resource that 

cannot be readily expressed in monetary terms. Similarly, this EIS assesses impacts to the forest 

resources that cannot be readily expressed in monetary terms. Under the current Forest Plan, LUDs 

specify ways of managing an area of land and the resources it contains. LUDs may emphasize certain 

resources, such as remote recreation or old-growth wildlife habitat, or combinations of resources, 

such as providing scenic quality in combination with timber harvesting. Each LUD has a detailed 

management prescription, which includes standards and guidelines. Ecosystem services are discussed 

at the forest planning level for the Tongass National Forest in the 2008 Forest Plan EIS (USDA Forest 

Service 2008c, p. 3-544 to 3-556). 

Potential impacts to ecosystem services other than timber are not addressed in monetary terms, but 

are discussed in the other resource-specific sections of this EIS. The effects of the action alternatives 

on these types of services and benefits are assessed in the sections of this EIS that address watersheds, 

fisheries, soils, wildlife and subsistence use, heritage resources, and timber and vegetation, among 

others. Monetary values are not assigned to these services, but this does not lessen their importance in 

the decision making process. The Responsible Official will consider the economic values presented 

under the Issue 1: Timber Economics section in this chapter within the context of the information 
3 Affected Environment and Environmental Consequences

332  Chapter 3 – Socioeconomics Saddle Lakes Timber Sale Final EIS

presented elsewhere in this document, much of which cannot readily be translated into economic 

terms.

Environmental Consequences

Effects to the timber industry are assessed in terms of employment and income at the regional scale 

(i.e., Southeast Alaska), where effects are expected to occur. Effects to fisheries and commercial 

fishing and recreation and tourism sectors are assessed in terms of the analysis areas assessed for 

those resources. Ecosystem services are assessed by resource throughout this EIS, with analysis areas 

established for each resource.

Direct and Indirect Effects

Alternative 1

No timber harvest would occur in the project area. There would be no additional contribution to the 

local or regional Southeast Alaska economy, and there would be no additional support to the local or 

regional forest products industry employment from this project area. Alternative 1would not meet the 

purpose and need, which is to contribute to an even-flow, long-term supply of economic timber that 

contributes to the local and regional economies of Southeast Alaska (including both large and small 

operators).

As discussed in the Issue 1: Timber Economics section above, the provision of a long-term stable and 

economic timber supply is intended to support local operators and encourage investment in the wood 

products industry as it transitions to young-growth harvesting and restoration activities. The absence 

of a long-term supply of economic timber could adversely affect future investment and the potential 

for increased wood products employment in the future, as well as the anticipated transition of the 

wood products industry to young-growth harvesting and restoration activities.

In the absence of a long-term (i.e., multiple year) stable supply of economic timber from the Saddle 

Lakes Timber Sale or elsewhere, the future viability of existing mill operators could be adversely 

affected. Closure of one or more of the existing mills would result in a further reduction in jobs in the 

logging and sawmilling industries and could also affect local businesses that provide goods and 

services to these industries.

There would be no timber harvest or associated road construction/reconditioning under this 

alternative and no impacts to fisheries and the commercial seafood industry or the recreation and 

tourism industries in Ketchikan or elsewhere in the region are anticipated. 

Effects Common to All Action Alternatives

The effects of road construction, operation and maintenance associated with the State of Alaska ROW

on NFS lands would provide some economic benefits to the Southeast Alaska economy. No direct or 

indirect economic effects to fisheries or the Southeast Alaska commercial seafood industry are 

anticipated.

The fish passage barrier modification at Salt Creek would improve both salmon stream and lake 

habitat, offering more opportunities for dispersed recreation (i.e., fishing). 

Reconstruction of the Shelter Cove log transfer facility is a cost associated with the timber sale, but 

would not impact timber industry employment and income. 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Socioeconomics - Chapter 3  333

Alternatives 2, 3, 4, 5, and 6

A stable timber industry in Southeast Alaska depends on a steady flow of economic timber sales in 

order for operators and processors to make investments in machinery and employ qualified workers. 

Potential impacts in terms of timber industry employment and income (i.e., direct logging and 

sawmill/export employment) that would be supported by the projected harvest volumes under each 

action alternative are described under Issue 1- Timber Economics (see Table 6 and Table 7). The 

potential impact to nearby communities with processing facilities that may utilize the timber depend 

on many elements associated with the competitiveness and efficiency of individual operations. 

Implementation of the applicable Forest Plan Standards and Guidelines and best management 

practices (Appendix C) would mitigate potential impacts to fisheries. As a result, none of the action 

alternatives are expected to have measurable effects on fish habitat and are, therefore, unlikely to 

affect the commercial seafood industry.

Potential impacts to recreation are discussed under Issue 4B - Recreational Opportunities in this 

chapter. Although none of the action alternatives are expected to have measurable effects on fish 

habitat, road building and timber harvest activities could affect access to freshwater fishing outfitterguide locations in the project area, as well as the quality of the recreation experience of outfitter-guide 

clients in these areas. The action alternatives would all have short-term impacts on recreation and 

outfitter-guide use in the project area. No long-term impacts (i.e., impacts that extend beyond the 

duration of localized project activities) are anticipated regarding the ability of outfitter-guides to use 

currently permitted locations. Wildlife- and nature-based recreation and tourism in Ketchikan is 

mainly related to saltwater fishing, hunting, and shore excursions offered by the cruise ship industry. 

Because the Saddle Lakes project area is remotely located and visitation is low, very minimal effects 

to these recreational experiences is anticipated. Saltwater fishing-related recreation and tourism is not 

expected to be affected under the action alternatives. Since none of the action alternatives are 

expected to have measurable effects on fish habitat, the action alternatives are unlikely to affect 

businesses that focus on sport fishing. Alternatives 4, 5 and 6 would lower the scenic integrity in 

some of the project area visual priority routes (VPRs), which may in turn affect the recreational 

experience of some visitors. As discussed under the Issue 3A -Wildlife Habitat section in this chapter, 

the action alternatives would permanently reduce deer habitat capability (DHC) up to 6 percent from 

existing conditions, and up to 27 percent from historic habitat capabilities. Reductions in deer habitat 

resulting from the action alternatives would further impact subsistence and sport deer hunter success 

making it harder for hunters to obtain deer. 

Cumulative Effects

Appendix B includes the interrelated projects (i.e., past, present and reasonably foreseeable future 

actions) that have been considered in the cumulative effects analysis. Appendix B identifies the 

interrelated projects considered in this cumulative effects analysis.

Alternative 1

Under Alternative 1, there would be no timber made available under the Saddle Lakes Timber Sale 

and timber operators in Ketchikan and elsewhere in Southeast Alaska would not be able to bid on 

future timber offerings under this project. Timber projects listed in Appendix A, and discussed above 

in the Issue 1. Timber Sale Economics and Issue 2. Timber Availability sections in this chapter would 

also contribute to the timber supply. As discussed above under direct and indirect effects, in the 

absence of this project and other sources of long-term (multiple-year) economic timber, the future 

viability of existing operators in Southeast Alaska could be adversely affected. Closure of one or 

more mills would result in a further reduction in jobs in the logging and sawmilling industries and 

could also affect local businesses that provide goods and services to these industries. Further, the 
3 Affected Environment and Environmental Consequences

334  Chapter 3 – Socioeconomics Saddle Lakes Timber Sale Final EIS

absence of a multiple-year timber supply could adversely affect the anticipated transition of the wood 

products industry to young-growth harvesting and restoration activities.

The future Ketchikan to Shelter Cove Road would provide access to the Saddle Lakes project area, 

and would likely provide benefits to the forest products industry on other timber sales in the area. 

Forest products could more easily be transported from the project area and other operational costs 

would likely be reduced since more options would exist for hauling timber (e.g., Leask Cove and 

Ward Cove). 

Effects Common to All Action Alternatives

Under all action alternatives, when added to the action alternatives, the future Ketchikan to Shelter 

Cove Road would create beneficial cumulative effects to benefit the forest products industry. The 

forest products industry would realize an economic benefit with this road connection since the costs 

of transporting forest products from the project area and other operational costs would likely be 

reduced since there would be more options for hauling timber (e.g., Leask Cove and Ward Cove). 

Estimates provided by the State of Alaska Division of Forestry (personal communication from SOA 

DOF, with input from ALCAN Forest Products LP, 2014) indicate that economic benefits of the DOT

& PF road to timber purchasers may be substantial. These benefits are discussed in more detail in

cumulative effects under Issue 1- Timber Economics. Completion of this road would also reduce the 

economic risk for timber sale purchasers, and increase the economic viability of future timber sales in

the area. The future road connection would also present more opportunities for the Ketchikan-Misty

Fiords Ranger District to offer small sales to local purchasers and free use permits.

In addition, the Ketchikan to Shelter Cove Road is expected to benefit the recreation and tourism 

industry. This road would provide access into and through the project area allowing local residents to

drive to the area instead of having to boat or fly. Sightseeing and driving for pleasure is desired by 

local residents, and would likely lead to increased recreation use in the project area, and possibly 

increased spending in Ketchikan. Cruise ship clients would likely spend money on shore excursions 

into the Saddle Lakes project area. The Ketchikan to Shelter Cove Road would contribute social

benefits to the local communities since increased access would present more opportunities for

dispersed recreation (e.g., sightseeing, camping, berry-picking, hunting, and fishing) and subsistence 

activities on NFS lands and on adjacent saltwater.

Alternatives 2, 3, 4, 5, and 6

Past timber sales have contributed to the development of the existing NFS road system (8300000 

road) in the Saddle Lakes project area that would be used under all action alternatives. Timber harvest 

under the action alternatives would contribute to meeting projected market demand for timber in 

Southeast Alaska and support logging, sawmilling, and transportation and other services jobs. 

The future Saddle Lakes Recreation Area, if completed, would be a likely destination in the project 

area for dispersed camping, and use of the North Saddle Lakes for kayaking and canoeing is probable. 

Freshwater fishing in the lakes and streams would also likely increase. An increase in outfitter/guide 

use is projected and could be realized with this future road connection. Use of the 4.6 miles of off 

highway vehicle (OHV) trail (8337000 road) is expected to increase via this road connection since 

people would be able drive to the project area. The tourism industry is expected to take advantage of 

this increased road-based access by offering tours and activities in this area. Currently, there are 

several non-NFS tours and recreation offerings, and these offerings may expand to include obtaining 

a Forest Service special use permit to take visitors into the project area. Additional recreation and 

tourism opportunities as a result of this road connection would translate to more visitor spending and 

more seasonal employment in Ketchikan.
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Socioeconomics - Chapter 3  335

The future road connection would make the area more accessible to wildlife-related recreation and 

could create incremental impacts to hunting in the area. Decommissioned roads (post-timber harvest) 

would allow for easier walk-in access to the project area by both rural and non-rural users. Direct 

road access from Ketchikan, combined with a potential increase in user demand for fish, shellfish and 

deer, could increase competition between subsistence and sport users and decrease success. Increased 

competition may result when less expensive and more convenient access to the area or within the area 

is provided. Such is the case when road systems are established to local communities (USDA Forest 

Service 2008c, p. 3-421). There is currently no regulated subsistence or personal-use fishery in the 

project area and cumulative impacts to fish subsistence cannot be quantified. There would be a 

potential increase in hunter demand for deer, which could affect competition for deer between 

subsistence users. Hunting use patterns could also change with the Ketchikan to Shelter Cove Road, 

affecting the demand and/or the amount of competition in the area (Wildlife Resource Report). 

According to the 2008 Forest Plan FEIS, if a restriction were necessary, sport hunting by Ketchikan 

residents would be restricted before subsistence hunting by rural hunters is restricted (USDA Forest 

Service 2008c, p. 3-640). 

According to the 2010 Ketchikan to Shelter Cove Road Socioeconomic Report, the two-phased road

construction of the Ketchikan to Shelter Cove Road (on both NFS and non-NFS lands) would 

generate about 1,333 part-time and full-time jobs in the Region and a personal income of $72 

million dollars. Maintenance of the road would generate one to two part-time or full-time jobs in the 

Ketchikan Gateway Borough and a personal income of about $100,000 dollars (Northern Economics 

27).010, p. 

The proposed Alaska Mental Health Trust Authority Land Exchange would decrease the amount of 

NFS suitable and available forest land, resulting in less future volume available for harvest for the 

Tongass timber program. The Alaska Mental Health Trust Authority would likely use this land for 

future timber harvest activities, and the volume generated would contribute to the Southeast Alaska

regional economy. 
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336  Chapter 3 – Soils Saddle Lakes Timber Sale Final EIS

Soils

This section provides a summary of the soil resources in the Saddle Lakes project area. The analysis 

presented centers around soils concerns associated with landslides (mass movement erosion) and soil 

productivity. 

Timber harvest and road building can adversely affect the soils resource by: 

• Disturbing, displacing, or burying the nutrient-rich forest floor and exposing mineral soils to

erosion; and

• Increasing the frequency of landslides which also displace nutrient rich soils and increase erosion

potential.

Units of Measure:

Effects to soil productivity are based on the following indicators: 

• Estimates of detrimental soil conditions in harvest units based on over 20 years of soil

disturbance monitoring by logging system; and

• Estimate of future landslide activity based on a landslide inventory of the project area and the

amount of timber harvest and road construction proposed on steep or unstable slopes.

Methodology

Estimates of detrimental soil conditions by logging system are based on data presented in several soil 

quality monitoring white papers, the most pertinent of which are Landwehr and Nowacki (1999) and 

Landwehr et al. (2012). Detrimental soil conditions are estimated for both existing young-growth 

stands and proposed harvest areas.

Landslides were estimated by using the best available stability mapping of the soil cumulative effects 

area, a current landslide layer, aerial photographs, and a current point layer for the initiation point of 

each landslide. A stability map and a point layer for landslide initiation locations were created 

specifically for this analysis. Proposed harvest units on slopes steeper than 72 percent gradient or 

unstable soils were reviewed in the field. Based on field review, recommendations for avoiding very 

unstable areas or changes to yarding methods or road locations or road construction methods were 

made to minimize potential for management induced landslides. 

Analysis Area

The analysis area for direct and indirect effects to productivity includes the “activity area” (FSM 

2554). For this project, the “activity area” includes individual proposed timber harvest units and 

associated land impacted by proposed road construction. Consequently, the direct and indirect effects 

analysis areas for productivity are different for each alternative when displayed as a sum of all 

activity areas.

The analysis area for cumulative effects includes the project area minus the private lands where no 

soil information exists

Appendix B includes the interrelated projects (i.e., past, present and reasonably foreseeable future 

actions) that have been considered in the soils cumulative effects analysis. 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Soils - Chapter 3  337

Affected Environment

The project area is located within the Traitors Cove Metasediment Ecological Subsection (Nowacki et 

al 2001). Metasedimentary and sedimentary bedrock is present within the Saddle Lakes project area. 

However, many of the road cuts are plutonic intrusions of tonolite or granodiorite. At least one small 

area of pyroclastic rock exists in the southern part of the project area, thought to have originated from 

the eruption of Painted Peak on the east side of Carroll Inlet (personal communication, James 

Baichtal, Forest geologist, Tongass National Forest, 2013). 

Most soils in the project area have a thick organic or duff layer that prevents erosion of the underlying 

mineral soil from raindrop impact and supplies many nutrients for plant growth. Keeping the organic 

mat in place during management activities is a key to maintaining soil productivity. 

As a part of this analysis, a refined soil stability map was created using soil surveys, digital elevation 

maps, knowledge gained from current field observations, and interpretations of aerial photographs. 

Soil stability classes used in this analysis are interpreted approximations of the Mass Movement 

Index, and are interpreted as follows: Very Unstable (V Unstable) Areas = MMI 4; Unstable Areas = 

MMI 3; and Stable Areas = MMI 2 and 1. Slopes over 72 percent is a criterion for very unstable 

areas.

Landslides

Landslides in natural areas and managed stands in the Saddle Lakes project area have initiated 

predominantly in very unstable areas. Since 1929 a total of 42 landslides (67 acres) have initiated in 

non-harvested, old-growth stands within the project area. A total of 30 landslides (19 acres) have 

initiated in harvested areas.

The last landslide-inducing storm on the project area was in October 2010 and resulted in eight 

landslides in natural areas and 27 landslides in harvested areas. The landslide analysis for this project 

considered storm event timing and age of young growth when estimating future landslide activity for 

the next 30 years for each alternative. 

Soil Productivity

Alaska Regional Soil Quality Standards state that “a minimum of 85 percent of an area should be left 

in a condition of acceptable productivity potential for trees and other managed vegetation following 

land management activities. Currently, detrimental soil conditions occupy an estimated 0.6 percent of 

the cumulative effects area. This amount is well within the Alaska Regional Soil Quality Standard of 

15 percent maximum. Management related landslides, yarding disturbances, and temporary roads 

make up the detrimental disturbance for existing soil productivity. Recovery of productive soil 

conditions is occurring in soil disturbances within previously harvested areas (Landwehr et al 2012). 

Roads and landslides generally have slower recovery rates. 

Harvest on Slopes Greater than 72 Percent Gradient

Past harvest activities have partially avoided slopes greater than 72 percent gradient. The digital 

elevation model for the project area was used as a primary data source for mapping Very Unstable 

areas. Specifically, lands greater than 72 percent slope are considered Very Unstable unless ground 

measurements indicated they are suitable for timber harvest (Unstable rather than Very Unstable). 

There are about 49 acres of landslides on slopes greater than 72 percent (Very Unstable) within the 

project analysis area. Most landslide activity resulting from timber harvest and road construction 

occurred on lands harvested before current Forest Plan Standards and Guidelines were implemented. 

Past effects are likely to be greater than those that have occurred following more recent timber 
3 Affected Environment and Environmental Consequences

338  Chapter 3 – Soils Saddle Lakes Timber Sale Final EIS

harvest and road construction due to use of current BMPs (Landwehr 1998). Therefore, impacts from 

proposed activities are likely to be less than from past activities. 

Environmental Consequences

Desired Condition

The desired condition for soils resources is to avoid irreversible or serious and adverse effects on soil 

resources, and to prevent detrimental soil disturbance. This is achieved by following Forest-wide 

Standards and Guidelines for soils, which are found on pages 4-64 through 4-67 of the Forest Plan 

(USDA Forest Service 2008b). Application of soil conservation practices to meet Alaska Region Soil 

Quality Standards (Soil Management Handbook, FSM 2554). Key BMPs for maintaining soil 

productivity are 13.5 (Identification and Avoidance of Unstable Areas), BMP 14.7 (Minimization of 

Mass Failures), and BMP 13.9 (Guidelines for Yarding Operations).

Direct and Indirect Effects

Effects Common to all Action Alternatives

No effects are anticipated to soil resources as a result of implementing the State of Alaska right-ofway on NFS Lands, the fish passage barrier modification, and the Shelter Cove LTF reconstruction. 

Landslides, Harvest on Slopes Greater than 72 Percent Gradient, and Soil Productivity

For all alternatives, detrimental soil disturbances across the analysis area would be well within the 

Region 10 Soil Quality Standards and Guidelines. This finding is based on analysis summarized in 

the Soil and Wetland Resource Report for the Saddle Lakes project area (Silkworth 2014) and over 20 

years of soil quality monitoring data collected on the forest and documented in numerous soil quality 

monitoring reports, the most pertinent of which are: Landwehr and Nowacki 1999, and Landwehr 

et.al. 2012. The monitoring data indicates that about 3 percent of harvest units yarded with cable or 

shovel system incur detrimental soil conditions. Temporary roads and landslides are also considered 

detrimental soil conditions. Existing detrimental soil disturbance (including temporary roads and 

landslides) was estimated for each proposed harvest unit. The detailed data can be found in Silkworth 

(2014). 

Increased landslide frequencies can occur when harvesting timber or building roads on steep slopes, 

especially slopes greater than 72 percent. The analysis uses the existing landslide inventory for the 

Saddle Lakes project area to estimate future landslide activity over the next 30 years. To date a total 

of about 450 acres of Very Unstable areas have been dropped from all action alternatives, either by 

removing the entire harvest unit, adjusting harvest unit boundaries, or avoiding the Very Unstable 

area through a partial-cut silvicultural prescription.

BMPs and site-specific recommendations for soil and slope protection in harvest units and road 

segments are based on field data. Project-wide analysis was completed using soil survey data in GIS 

and aerial photos and is summarized in the Soil and Wetlands Resource Report (Silkworth 2014). 

Tabular comparison of alternatives can be found in the Soil and Wetland Resource Report for the 

Saddle Lakes project area (Silkworth 2014) in the project record provides more detail of the analysis. 

Alternative 1

Under Alternative 1, no timber harvest or road building would take place from the proposed Saddle 

Lakes Timber Sale project. No soil disturbances would be caused by new management activities 

associated with the Saddle Lakes project. Vegetation in harvested areas would continue to grow and 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Soils - Chapter 3  339

add stability to soils on those sites. Detrimental disturbance for soil productivity is calculated at 0.6 

percent of the project area. 

Alternative 2

This alternative results in an estimated 77 acres of detrimental soil disturbance from 49 acres of 

yarding disturbances, 27 acres of temporary road construction, and about 1 acre of managementrelated landslides (in the next 50 years). This would result in a detrimental soil disturbance of 3.4 

percent of the direct and indirect effects analysis area.

About 88 acres of slopes greater than 72 percent gradient would be suitable for timber harvest. About 

0.1 acre of road is located on slopes greater than 67 percent gradient. 

Alternative 3

This alternative results in about 57 acres of detrimental soil disturbance from 32 acres of yarding 

disturbance, 24 acres of temporary road construction, and about 1 acre of management-related 

landslides (in the next 50 years). This would result in a detrimental soil disturbance of 5.5 percent of 

the direct and indirect effects analysis area. 

About 42 acres of slopes greater than 72 percent gradient would be suitable for timber harvest. About 

0.3 acre of road is located on slopes greater than 67 percent gradient. 

Alternative 4

This alternative includes about 126 acres of detrimental soil disturbance from 76 acres of yarding 

disturbance, 47 acres of temporary road construction, and about 3 acres of management-related 

landslides (in the next 50 years). This would result in a detrimental soil disturbance of 5.1 percent of 

the direct and indirect effects analysis area.

About 123 acres of slopes greater than 72 percent gradient would be suitable for timber harvest. 

About 0.5 acre of road is located on slopes greater than 67 percent gradient. 

Alternative 5

This alternative includes about 155 acres of detrimental soil disturbance from 95 acres of yarding 

disturbance, 56 acres of temporary road construction, and about 4 acres of management-related 

landslides (in the next 50 years). This would result in a detrimental soil disturbance of 5.3 percent of 

the direct and indirect effects analysis area.

About 163 acres of slopes greater than 72 percent gradient would be suitable for timber harvest. 

About 0.8 acre of road is located on slopes greater than 67 percent gradient. 

Alternative 6

This alternative would result in about 106 acres of detrimental soil disturbance from 65 acres of 

yarding disturbance, 39 acres of temporary road construction, and about 2 acres of managementrelated landslides (in the next 50 years). This would result in a detrimental soil disturbance of 4.9 

percent of the direct and indirect effects analysis area.

About 84 acres of slopes greater than 72 percent gradient would be suitable for timber harvest. 

About 0.5 acre of road is located on slopes greater than 67 percent gradient. 
3 Affected Environment and Environmental Consequences

340  Chapter 3 – Soils Saddle Lakes Timber Sale Final EIS

Cumulative Effects

Landslides, Harvest on Slopes Greater than 72 Percent Gradient, and Soil Productivity

Eighty-six acres of existing landslides are found in the Saddle Lakes project area (cumulative effects 

area). Natural soil disturbances, including landslides would continue to occur. Natural soil erosion 

due to ice, wind, water, or gravity that usually occurs in small patches would continue. Vegetation in 

harvested areas would continue to grow and add root mass and stability to the soil reducing landslide 

frequency in previously harvested areas. Disturbed soil in existing harvest areas would continue to 

recover.

Alternative 1

Under Alternative 1, detrimental disturbance for soil productivity would be 278 acres, or about 0.8 

percent of the cumulative effects area. The detrimental soil conditions include 86 acres of existing 

landslides, 54 acres of estimated future landslides, 42 acres of temporary roads, and 96 acres of 

existing yarding disturbances. 

Alternative 2

Under Alternative 2, detrimental soil conditions would be about 355 acres, or about 1.2 percent of 

the cumulative effects area. The detrimental soil conditions include 86 acres of existing landslides, 

55 acres of estimated future landslides, 99 acres of temporary roads, and 191 acres of yarding 

disturbances. 

Alternative 3

Under Alternative 3, detrimental soil conditions would be about 335 acres, or about 0.9 percent of 

the cumulative effects area. The detrimental soil conditions include 86 acres of existing landslides, 

55 acres of estimated future landslides, 66 acres of temporary roads, and 128 acres of yarding 

disturbances. 

Alternative 4

Under Alternative 4, detrimental soil conditions would be about 404 acres, or about 1.1 percent of 

the cumulative effects area. The detrimental soil conditions include 86 acres of existing landslides, 

57 acres of estimated future landslides, 89 acres of temporary roads, and 172 acres of yarding 

disturbances. 

Alternative 5

Under Alternative 5, detrimental soil conditions would be about 434 acres, or about 1.2 percent of 

the cumulative effects area. The detrimental soil conditions include 86 acres of existing landslides, 

58 acres of estimated future landslides, 99 acres of temporary roads, and 191 acres of yarding 

disturbances. 

Alternative 6

Under Alternative 6, detrimental soil conditions would be about 486 acres, or about 1.1 percent of 

the cumulative effects area. The detrimental soil conditions include 86 acres of existing landslides, 

56 acres of estimated future landslides, 82 acres of temporary roads, and 162 acres of yarding 

disturbances. 

The effects to soils for all alternatives are within Alaska Region Soil Quality Standards, which require 

85 percent of an area to be in a condition of acceptable productivity for growth of desired vegetation. 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Transportation - Chapter 3  341

Transportation

National Forest Transportation System roads are constructed to provide access to National Forest 

System (NFS) lands and are included in the Forest Development Transportation Plan (see 

Transportation Standards and Guidelines in Chapter 4 of the Forest Plan, USDA Forest Service 

2008a). They are considered NFS roads or system roads, for short, as are other roads wholly or 

partially on NFS lands and are intended to be maintained for the long term. Most forest roads are 

single lane, constructed with blasted quarry rock, and designed for off-highway loads. 

Roads have the potential to affect fish habitat, soils, and water quality by increasing erosion and 

landslide potential, changing recreation settings and opportunities, altering scenery, and increasing 

legal and illegal wildlife harvest. These types of effects are discussed in the resource sections in this 

chapter. This analysis considers the effects of the new construction and reconstruction of roads used 

to access the proposed timber harvest. It also analyzes the status of these roads after timber harvest 

(open or closed) and the total transportation related costs.

Units of Measure:

The following units of measure were used to evaluate effects of the proposed action and compare 

alternatives:

• Miles of NFS road construction;

• Miles of temporary road construction;

• Miles of NFS road reconditioning;

• Miles of road to remain open to motorized vehicle traffic;

• Miles of road to be closed associated with this timber harvest activities;

• Total transportation related costs (cost of new road construction (NFS and temporary), road

reconditioning, and LTF reconstruction); and

• Total road and LTF costs per net sawlog volume harvested (cost per NMBF).

Methodology

Information sources for transportation analysis include the transportation GIS records which house 

the spatial data for road locations. An inventory of road attributes for National Forest System (NFS) 

roads is maintained on National Forest through the I-Web database. A complete list of road attributes 

and definitions of these attributes is located in the project record.

The Forest Service has conducted road condition surveys (USDA Forest Service 2000; Transportation 

System Maintenance Handbook FSH 7709.58 – Section 12.5) on many of the existing roads in the 

Saddle Lakes project area. These surveys supply site-specific detailed information about each road 

(and section of road) surveyed as of the date of the survey, including: 

• Whether the road, or a particular section of the road, is drivable;

• Number, size, and condition of drainage structures and bridges;

• Barriers to vehicle access (e.g., vegetation, barrier ditches, pulled bridges, slides);

• Maintenance requirements; and

• Barriers to fish passage through road drainage structures.
3 Affected Environment and Environmental Consequences

342  Chapter 3 – Transportation Saddle Lakes Timber Sale Final EIS

This information is used to: 1) identify maintenance trends; 2) provide information for problem 

analysis; and 3) set priorities for scheduling and funding work. The majority of the road condition 

surveys within the project area were completed between 2000 and 2005. Updates on fish stream

crossing information for the road condition survey data are ongoing. Road condition survey data has 

been uploaded to the national INFRA database and is updated in that database. Existing data are being 

used for the remaining road condition survey data, which was updated by the Forest Service as 

recently as 2008. 

Proposed new road construction routes were mapped in GIS by transportation specialists and field 

reviewed by resource specialists during site visits between 2010 through 2014. All routes have been 

or currently are scheduled for field review. Transportation specialists are flagging any remaining

routes as needed. 

Specific comments and concerns along with site-specific mitigation measures are discussed in the 

respective resource reports, in the road cards for system roads, and on the unit cards for temporary 

roads. The methodology for road location and field review does not vary by alternative. The roads are 

included or excluded by alternative based on the design criteria of each alternative.

Incomplete and Unavailable Information

Many, but not all, non-NFS road alignments are available in GIS. National Forest System road data 

for this project area is within the Routed Road layer and is complete. Most NFS decommissioned 

temporary roads have data within the Routed Road layer. Most of the remaining NFS

decommissioned temporary roads have been digitized using aerial photos and are within the NonRouted Roads layer. State and private roads are also within the Non-Routed Road layer; however, 

non- NFS lands within this project area are less than 10 percent. 

The approach to developing the impact analysis primarily focuses on the potential for additional miles 

of NFS and temp roads, their costs, and their costs in relation to the volume of timber harvested.

The best available information was used for this analysis and additional information on proposed 

stream-road crossings is still being obtained. 

Analysis Area

The analysis area for the transportation system includes the Saddle Lakes project area, and road and 

trail segments within this area. There are no roads or trails extending from within the project area and 

terminating outside the project area.

Appendix B includes the interrelated projects (i.e., past, present and reasonably foreseeable future 

actions) that have been considered in the transportation cumulative effects analysis. 

Affected Environment

To facilitate the understanding of road terminology, a road may be classified, temporary, or 

unauthorized (36 CFR 212.1). Classified roads are wholly or partially within or adjacent to NFS lands 

that are determined to be needed for long-term motor vehicle access, including State roads, county 

roads, privately owned roads, NFS roads, and other roads authorized by the Forest Service. 

Temporary roads are authorized by contract, permit, lease, other written authorization, or emergency 

operation, not intended to be part of the forest transportation system, and not necessary for long-term 

resource management. Road decommissioning consists of activities that result in the stabilization and 

restoration of unneeded roads to a more natural state. 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Transportation - Chapter 3  343

The NFS roads in the analysis area were originally built for logging and the associated administration, 

though incidental recreational and subsistence use occurs throughout the area. Road construction in 

support of logging activities in the project area began in the 1990s. 

Road Maintenance and Reconditioning

For the Tongass National Forest, the demand for roads has primarily been a function of the demand 

for access to timber resources. The maintenance and reconditioning of the existing system depends 

largely on the volume of timber hauled and, to a lesser extent, on recreation use. Road maintenance 

consists of superficial periodic repairs to the existing road surface, brushing, cleaning, and repairing 

drainage features. These tasks are performed to keep the roads in a safe and useful condition for 

which they were designed. Repairs may be accomplished as annual maintenance. Road reconditioning 

is heavier maintenance of an existing road, such as culvert replacement, surface rock replacement and 

subgrade repair.

NFS roads are managed by a system of maintenance levels (ML), depending on their intended use and 

suitability for various types of vehicles. These levels range between ML 1 (closed), ML 2 (suitable for 

high-clearance vehicles), ML 3 (suitable for passenger vehicles, rough surface), ML 4 (suitable for 

passenger vehicles, smooth surface), and ML 5 (suitable for passenger cars, dust free, possibly 

paved). 

Management of NFS roads is dynamic in the sense that roads are given both an operational 

maintenance level (OPML) and an objective maintenance level (OBML). The purpose of maintenance 

levels is to define the level of service provided by, and maintenance required for, a specific road or 

road segment. Roads are often built and operated at a higher maintenance level during the timber sale 

or other activities than they are afterwards.

The OPML is the maintenance level currently assigned to a road considering today’s needs, road 

condition, budget constraints, and environmental concerns. It defines the level to which the road is 

currently being maintained. It reflects the current condition and the ability to drive on the roads in the 

project area. The OBML is the maintenance level to be assigned at a future date considering future 

road management objectives, traffic needs, budget constraints, and environmental concerns. The 

OBML may be the same as, or higher or lower than, the OPML.

Currently, there are 52.7 miles of NFS roads, 4.6 miles of NFS trails, and 31.3 miles of non-NFS 

roads in the Saddle Lakes project area. Existing roads and their maintenance level in the Saddle Lakes 

analysis area are displayed in Table 105. As described above, the analysis area for the transportation 

system includes the Saddle Lakes project area and road and trail segments within this area. There are 

no roads or trails extending from within the project area and terminating outside the project area. 

Table 105. Existing roads and trails in the Saddle Lakes project area

Operational Maintenance Level (OPML) Miles

1 - Basic Custodial Care (Closed) 13.9

2 - Suitable for High-clearance Vehicles 38.8

Total NFS Road 52.7

NFS Motorized Trail - All Terrain Vehicle (ATV) 4.6

Non-NFS Road 31.3

Source: Forest Service INFRA database.
3 Affected Environment and Environmental Consequences

344  Chapter 3 – Transportation Saddle Lakes Timber Sale Final EIS

Non-NFS roads include decommissioned temporary roads, other public roads, and private roads. Past 

temporary road construction totals 13.8 miles. 

Marine Access Facilities and Log Transfer Facilities

A marine access facility (MAF) is an area used by humans to transfer items from land to saltwater or 

vice versa, that contains a structure such as a mooring buoy, dock, log transfer facility, boat ramp, or a 

combination of these. A log transfer facility (LTF) is used to transfer logs and timber products from 

land-based transportation forms to water-based transportation forms (or vice-versa). These facilities 

are often used for the movement of equipment needed for logging and road building. 

There are two existing LTFs in or near the project area - one at Shelter Cove and the other at Leask 

Cove (Figure 3). The Shelter Cove LTF is owned by the Forest Service, which was granted a 55-year 

tideland easement (ADL 105601) by the Alaska Department of Natural Resources, and would be used 

to transport logs. The Leask Cove LTF is not federally owned. The State of Alaska Division of 

Forestry (DOF) has applied for a long-term authorization. Agreements would need to be sought by the 

purchaser, as well as permits from regulatory agencies to use this LTF. In 2012, ALCAN 

decommissioned the privately owned Coon Cove LTF by removing the bulkhead, and restoring the 

shoreline to its natural contour. 

Shelter Cove

The Shelter Cove MAF consists of a seaplane and boat float, a barge loading and unloading ramp, 

a sort yard, and a LTF. The LTF is a single level, native log bulkhead with about a 1-acre sort yard 

attached to it within an existing rock pit. Currently the lower logs of the bulkhead have deteriorated 

enough to require the reconstruction of the bulkhead. 

The Alaska Department of Environmental Conservation (ADEC) issued authorization AKG-70-1009 

under Alaska Pollutant Discharge Elimination system (APDES) General Permit AKG-70-1000 

allowing for the discharge of bark and wood debris associated with in-water log transfer and log 

storage. The LTF permit was renewed on March 9, 2015. Renewal of this permit is in process.

The last dive associated with the Shelter Cove tideland lease was completed in 2009. Bark 

accumulation was 0.24 acre of continuous bark debris and 0.48 acre of discontinuous bark debris, 

within the requirements of the permit. 

Leask Cove

Leask Cove is outside of the project area, and currently is not connected to the Shelter Cove road 

system. Leask Cove is connected to the Ketchikan road system, but is not accessible to the public as 

roads crossing private lands are closed to the general public. This site is an approved export appraisal 

location. 

The Leask Cove MAF consists of a boat float, LTF, two 30-ton mooring buoys and a large sort yard. 

The LTF consists of a low angle ramp for placing logs in the water. Recent dive survey information is 

not available.

Coon Cove

The Coon Cove MAF consists of a deconstructed LTF. Prior to the deconstruction, there had been a 

native log bulkhead for loading barges and for placing logs in the water. Less than 0.5 mile up the 

road from the LTF is a several-acre sort yard. The Forest Service does not have a tidelands lease for 

this site, and the upland landowner (LTF, sort yard, and adjacent lands) is the Cape Fox Corporation. 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Transportation - Chapter 3  345

Minerals and Geology

There are no mining claims in the project area.

Bridges

There are five steel bridges that have an “open” operational status, and five bridges that have a 

“disposed” operational status in the project area. More details regarding bridges can be found in the 

Draft Transportation Report for the Saddle Lakes Timber Sale.

Fish Stream Crossings

There are a total of 13 red and gray known fish crossings currently in the project area boundary. Any 

road crossings involving Class I and Class II streams are addressed in the Aquatics section of this 

chapter. The Tongass National Forest developed juvenile fish passage evaluation criteria matrix with 

an interagency group of professionals (Flanders and Cariello 2000). The evaluation matrix stratifies 

culverts by type, and establishes criteria thresholds for culvert gradient, stream channel constriction, 

debris blockages, and vertical barrier (or perch) at the culvert outlet. Culvert categories are as follows 

(USDA Forest Service 2012):

• Green Category: conditions have a high certainty of meeting adult and juvenile fish passage

requirements at all desired stream flows;

• Gray Category: conditions are such that additional and more detailed analysis is required to

determine their juvenile fish passage ability. This additional analysis includes use of the FishXing

analytical software; and

• Red Category: conditions that have a high certainty of not providing juvenile fish passage at all

desired stream flows.

Most fish stream crossing structures on roads in the Saddles Lakes project area have been surveyed 

and have been categorized as green, gray, or red. Table 106 shows the number of crossings in each 

subwatershed within the project area. 

Table 106. Fish stream crossings in the Saddle Lakes project area

Subwatershed Culvert Category Total 

Green Gray Red Crossings

Calamity Creek-Frontal Carroll Inlet 5 2 4 11

George Inlet-Frontal Carroll Inlet 0 0 1 1 

Marble Creek-Frontal Carroll Inlet 0 0 3 3 

Salt Lagoon 4 0 3 7 

Total 9 2 11 22

Source: Forest Service INFRA database.

Note: Includes only crossings within the Saddle Lakes project area.

Travel Analysis Process

The desired condition for the forest transportation system is guided in part by 36 CFR 212.5(b), 

which provides guidance for determining the minimum road system needed. The Travel Analysis 

Process (TAP), formally referred to as the Roads Analysis Process (RAP), is a tiered, science-based 

system of analysis.
3 Affected Environment and Environmental Consequences

346  Chapter 3 – Transportation Saddle Lakes Timber Sale Final EIS

The first tier is the Forest-wide Roads Analysis, which is an analysis for the entire Tongass National 

Forest (USDA Forest Service 2003). The Forest-wide Roads Analysis provided management 

recommendations for Maintenance Level (ML) 3, 4, and 5 roads. 

The second tier, or mid-level tier, is the Ketchikan-Misty Fiords Ranger District Roads Analysis, 

which includes the Saddle Lakes project area (USDA Forest Service 2008d). This analysis details the 

methods and recommendations for travel management of ML 1 and 2 roads on the Ketchikan-Misty 

Fiords Ranger District. Combined, these analyses recommend road management objectives for all 

existing NFS roads on the Ranger District. Recommendations documented in the Ketchikan-Misty 

Fiords Ranger District Roads Analysis, supplemented by input from public comment, led to the 

proposed action developed for Access Travel Management (ATM) Plan for Ketchikan-Misty Fiords 

Ranger District (USDA Forest Service 2008d). 

The third tier is the project-level analysis found in the Transportation Resource Report for the Saddle 

Lakes Timber Sale. The Road Management Objectives (RMO) for each proposed system road in the 

project area are detailed on the road cards of this EIS, located in the project record, and those roads 

selected would become part of the FEIS Record of Decision. The RMO presents the OPML and 

OBML designated for each proposed NFS road. 

The proposed Saddle Lakes Timber Sale incorporates the Decision Notice for the ATM Plan for 

Ketchikan-Misty Fiords Ranger District dated July 11, 2008. The ATM Plan institutes a system of 

routes designated for motor vehicle use including class of vehicle, and if appropriate, time of year for 

motor vehicle use. The designated route system is shown on a Motor Vehicle Use Map (MVUM). The 

map can be updated annually and adjusted as conditions change. These maps are available at the 

Ketchikan-Misty Fiords Ranger District. The existing road management objectives for the Saddle 

Lakes project area are summarized in Table 105. 

Environmental Consequences

Effects Common to Alternatives 2 through 6

Alternatives 2, 3, 4, 5 and 6 all propose varying amounts of timber harvest and, subsequently, varying 

amounts of road construction. Table 107 shows proposed miles by alternative. Each action alternative 

emphasizes a management objective. The effects of road construction, road reconditioning, and 

access management on resources are discussed in their respective resource sections and reports. Sitespecific design criteria can be found on road cards and unit cards located in the project record.

Short-term effects (i.e., during implementation) to access and travel management are anticipated as a 

result from conflicts that may occur during the timber sale where hunters and loggers are using the 

roads simultaneously during the fall deer season. Long-term effects (after silvicultural activities are 

completed) would vary by alternative, and would be limited since all new roads (except for road 

8300280) in each action alternative and current OPML 1 roads would managed as ML 1 (closed). 

Table 108 shows miles of road by OBML. 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Transportation - Chapter 3  347

Table 107. Existing and proposed road miles in the Saddle Lakes project area

Measure

Miles of Road

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

Total Proposed Road Construction 0 15.8 11.7 29.4 32.3 24.5

Proposed New NFS Road 0 10.2 6.7 19.6 20.6 16.3

Proposed Temporary Road 0 5.6 5.0 9.8 11.7 8.2

Existing NFS Road 52.7 52.7 52.7 52.7 52.7 52.7

Existing Decommissioned Temporary 

Road1/ 13.8 11.9 12.6 11.9 11.9 11.9

Total Decommissioned Temporary 

Road – after implementation 13.8 17.5 17.6 21.7 23.6 20.1

Total NFS Road – after 

implementation 52.7 62.9 59.4 72.3 73.3 69.0

Road Reconditioning (maintenance of 

closed roads) 0 10.8 7.7 10.8 11.1 10.8

Source: Forest Service GIS database.

1/ The difference in Existing Decommissioned Temporary Road miles are accounted for in new construction.

Projects can often become cost prohibitive due to the high road building costs in Southeast Alaska. 

NFS roads in Southeast Alaska are more expensive to build than in other parts of the nation. The

major factor that contributes to higher costs is obtaining the rock for the roadbed. Rock is obtained by 

blasting bedrock, which is then hauled and shaped into a road over typically soft and uneven terrain. 

Other factors that contribute to the high cost of constructing Southeast Alaska roads include the 

higher costs of shipping, labor, the numerous drainage structures needed, and more complex logistics. 

To offset these high road costs, sufficient volume must be harvested. In terms of road costs and 

efficiencies, it is more economical to offer a single large sale versus multiple small sales where roads 

would be opened and then closed with each entry. 

Table 108. Miles of road by objective maintenance level (OBML) in the Saddle Lakes project area

Roads Objective Maintenance Level

Miles of Road

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

Proposed 

Roads 

1 - Basic Custodial Care (Closed) 0 9.8 6.3 18.6 19.6 15.3

2 - High Clearance Vehicles 0 0.4 0.4 1.0 1.0 1.0

3 - Suitable for Passenger Cars 0 0 0 0 0 0 

Decommission Temporary 0 5.6 5.0 9.8 11.7 8.2

Existing & 

Proposed 

Roads 

1 - Basic Custodial Care (Closed) 23.9 33.7 30.2 42.5 43.5 39.2

2 - High Clearance Vehicles 8.1 8.5 8.5 9.1 9.1 9.1

3 - Suitable for Passenger Cars 20.7 20.7 20.7 20.7 20.7 20.7

Decommission Temporary 13.8 17.5 17.6 21.7 23.6 20.1

Source: Forest Service GIS database.

Road development costs are based upon regional average costs for constructing roads in Southeast 

Alaska. Costs are applied based upon an average cost per mile for different classifications of road 

construction and reconstruction, with an additional cost per fish stream crossing. Table 109 displays 

the estimated transportation related costs of the proposed Saddle Lakes Timber Sale. Costs used for 
3 Affected Environment and Environmental Consequences

348  Chapter 3 – Transportation Saddle Lakes Timber Sale Final EIS

estimating the road development costs for each alternative can be found in the Transportation 

Resource Report.

Table 109. Estimated transportation related costs and efficiencies for the Saddle Lakes Timber Sale

Alternative 

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

Total Transportation 

Related Cost1/ $0 $2,210,890 $1,601,121 $4,139,636 $4,540,160 $3,456,697

Proposed New NFS 

Road $0 $1,406,147 $899,541 $2,841,422 $2,999,501 $2,340,626

Proposed

Temporary Road $0 $658,343 $579,980 $1,151,814 $1,391,860 $969,671

NFS Road

Reconditioning $0 $86,400 $61,600 $86,400 $88,800 $86,400

LTF Reconstruction $0 $60,000 $60,000 $60,000 $60,000 $60,000

Total Road & LTF 

Costs / Net MBF 

Sawlog ($/NMBF)2/

$0 $81 $105 $91 $84 $95

Source: Powell, 2014.

1/ Costs are estimated by road, but are not exact values; these values are presented to provide a relative comparison between

the alternatives. All costs are subject to change.

2/ This measure is used to show the relationship between road costs and volume harvested.

New construction over decommissioned roads would require less rock and would have lessened 

impacts than would an entirely new road that was constructed in an alternate location. Typically this 

type of construction would utilize existing borrow quarries. 

Direct/Indirect Effects

Alternative 1

Under Alternative 1, no new road construction or reconstruction would occur as a result of the Saddle 

Lakes project, and current management plans would continue to guide the management of NFS roads. 

There would be no direct effects resulting from this alternative. All system roads would be managed 

as directed by the Forest Plan, road management objectives, and previous NEPA decisions. 

Alternative 1 would neither increase nor decrease access within the area. This alternative would not 

impact projects already planned or currently being implemented. 

No changes would be made to the Ketchikan-Misty Fiords Ranger District ATM Plan for existing 

roads. The OBML is the maintenance level to be designated at a future date considering future road 

management objectives, traffic needs, budget constraints, and environmental concerns. The OBML 

may be the same, higher, or lower than the OPML. Each NFS road has an OBML assigned. The 

current OBMLs designated to each road would guide the future management of that road. As 

resources and funding become available, roads would be closed or upgraded to match the currently 

designated OBML. Table 105 summarizes the miles of available roads and trails respectively.

The Forest Plan’s transportation goal is to “Develop and manage roads and utility systems to support 

resource management activities; recognize the potential for future development of major 

Transportation and Utility Systems.” Since Alternative 1 proposes no new development of roads, this 

alternative would forfeit any opportunity to develop or enhance the current road system. Road 
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Saddle Lakes Timber Sale Final EIS Transportation - Chapter 3  349

maintenance, culvert replacement, and road closures prescribed by the Ketchikan-Misty Fiords 

Ranger District ATM Plan would continue as funding allows. 

Alternative 2

Alternative 2 proposes construction of 10.2 miles of NFS road, 5.6 miles of temporary road, and the 

reconditioning of 10.8 miles of existing NFS roads (Table 107). 

Future harvest along these roads is a possibility, as well as future road extensions. However, future 

opportunities for economical road construction and future land management options would be limited 

due to the high proportion of helicopter logging systems, and single-tree selection and group selection 

prescriptions. With a third of a unit’s volume and a third or more of its value (dependent upon harvest 

prescriptions) removed using uneven-aged silvicultural systems, the remaining volume would likely 

not support future road development.

Of the five action alternatives, Alternative 2 proposes the second-lowest amount of new road 

construction (Table 107). This alternative also ranks the second-lowest in transportation development 

costs (Table 109). The road development proposed in this alternative is the minimum amount of road 

required to harvest the units in accordance with the objectives of this alternative. Alternative 2 has a 

high proportion of helicopter logging systems being used, as opposed to conventional logging 

systems (i.e., shovel and cable). Conventional logging systems require more road development to 

allow access to the harvest units. However, the additional road development costs are offset by the 

lower harvest costs achieved by even-aged silvicultural systems, and also allow for greater 

management options in the future. In areas where road development costs or resource concerns 

outweigh the benefits of road development, helicopter logging systems were used to allow harvest 

without additional road development. 

In terms of the relationship between road costs and net volume harvested, Alternative 2, at $81 per 

NMBF, ranked the most efficient in road costs (Table 109). New NFS and temporary road 

construction would cross seven fish streams. See the Aquatics section for detailed information on fish 

crossings. 

Alternative 3

Alternative 3 proposes construction of 6.7 miles of NFS road, 5 miles of temporary road, and the 

reconditioning of 7.7 miles of existing NFS roads. Future harvest along these roads is a possibility, as 

well as future road extensions. 

Of the five action alternatives, Alternative 3 proposes the least amount of new road construction 

(Table 107). This alternative also ranks the lowest in transportation development costs (Table 109). 

The road development proposed in Alternative 3 is the minimum amount of road required to harvest 

the units in accordance with the objectives of this alternative.

In terms of the relationship between road costs and net volume harvested, Alternative 3, at $105 per 

NMBF, ranks the least efficient and surpassed the next least efficient in road costs by $10 per NMBF 

(Table 109). To seek to meet the market demand for timber, Alternative 3 would increase the costs of 

doing business by reducing road cost efficiencies. New NFS and temporary road construction would 

cross one fish stream. See the Aquatics section for detailed information on fish crossings. 
3 Affected Environment and Environmental Consequences

350  Chapter 3 – Transportation Saddle Lakes Timber Sale Final EIS

Alternative 4

Alternative 4 proposes construction of 19.6 miles of NFS road, 9.8 miles of temporary road, and the 

reconditioning of 10.8 miles of existing NFS roads. Future harvest along these roads is a possibility, 

as well as future road extensions. 

Of the five action alternatives, Alternative 4 proposes the second-highest amount of new road 

construction (Table 107). This alternative also ranks the second-highest in transportation development 

costs (Table 109). The road development proposed in this alternative is the minimum amount of road 

required to harvest the units in accordance with the objectives of this alternative. Alternative 4 would 

harvest the second-largest amount of timber of any alternative. This alternative also proposes a high 

proportion of conventional logging systems, as opposed to helicopter. Conventional logging systems 

require more road development to allow access to the harvest units. However, the additional road 

development costs are offset by the lower harvest costs achieved by even-aged silvicultural systems. 

The additional road development also allows for greater management options in the future. In areas 

where road development costs or resource concerns outweighed the benefits of road development, 

helicopter logging systems were used to allow harvest without additional road development. 

In terms of the relationship between road costs and net volume harvested, Alternative 4, at $91 per 

NMBF, ranked the third most efficient in road costs (Table 109). New NFS and temporary road 

construction would cross eight fish streams. See the Aquatics section for detailed information on fish 

crossings. 

Alternative 5

Alternative 5 proposes construction of 20.6 miles of NFS road, 11.7 miles of temporary road, and the 

reconditioning of 11.1 miles of existing NFS roads. Future harvest along these roads is a possibility, 

as well as future road extensions. 

Of the five action alternatives, Alternative 5 proposes the highest amount of new road construction 

and road conditioning (Table 107). This alternative also ranks the highest in transportation 

development costs (Table 109) among the action alternatives. The road development proposed in this 

alternative is the minimum amount of road required to harvest the units in accordance with the 

objectives of this alternative. This alternative would harvest the largest amount of timber of any 

alternative. Alternative 5 also has a high proportion of conventional logging systems being used, as 

opposed to helicopter. Conventional logging systems require more road development to allow access 

to the harvest units. The additional road development costs are offset by the lower harvest costs 

achieved by even-aged silvicultural systems, and also allows for greater management options in the 

future. In areas where road development costs or resource concerns outweighed the benefits of road 

development, helicopter logging systems were used to allow harvest without additional road 

development. 

In terms of the relationship between road costs and net volume harvested, Alternative 5, at $84 per 

NMBF, ranked the second most efficient in road costs (Table 109). New NFS and temporary road 

construction would cross ten fish streams. See the Aquatics section for detailed information on fish 

crossings. 

Alternative 6

Alternative 6 proposes construction of 16.3 miles of NFS road, 8.2 miles of temporary road, and the 

reconditioning of 10.8 miles of existing NFS roads. Future harvest along these roads is a possibility, 

as well as future road extensions. 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Transportation - Chapter 3  351

Of the five action alternatives, Alternative 6 is ranked third-highest for the amount of proposed new 

road construction and road conditioning (Table 107), and third-highest for transportation development 

costs (Table 109). The road development proposed in this alternative is the minimum amount of road 

required to harvest the units in accordance with the objectives of this alternative. Alternative 6 also 

proposes a high proportion of conventional logging systems to be used, as opposed to helicopter. 

Conventional logging systems require more road development to allow access to the harvest units. 

The additional road development costs are offset by the lower harvest costs achieved by these 

systems, and also allows for greater management options in the future. In areas where road 

development costs or resource concerns outweighed the benefits of road development, helicopter 

logging systems were used to allow harvest without additional road development, or units were 

deferred for future harvests.

In terms of the relationship between road costs and net volume harvested, Alternative 6, at 

$91/NMBF, ranked the second least efficient in road costs (Table 109). New NFS and temporary road 

construction would cross eight fish streams. See the Aquatics section for detailed information on fish 

crossings. 

Cumulative Effects

Alternative 1

Past timber harvests have resulted in a total of 52.7 miles of NFS road and 13.8 miles of 

decommissioned temporary roads within the Saddle Lakes project area (Table 105). In addition to the 

existing miles of road in the project area, the proposed State of Alaska Department of Transportation 

& Public Facilities (ADOT&PF) Ketchikan to Shelter Cove Road connection would add up to 5 miles 

of open roads within the project area. 

The proposed road connection would affect transportation by changing accessibility to the project 

area from currently only accessible by air or boat, to being accessible by vehicle. About 1 mile of new 

road on NFS land would connect with the existing Shelter Cove Road (NFSR 8300000), opening up a 

considerable amount of access to NFS lands between George and Carroll Inlets. This change in access 

would likely result in an increase in use of the roads in the project area. However, because the 

proposed road connection and the 8300000 road are part of the ADOT&PF 2004 Southeast Alaska 

Transportation Plan, the State of Alaska would assume the maintenance responsibilities of about 8 

miles of NFSR 8300000. In all action alternatives this would result in reduced maintenance 

responsibilities on the part of the Forest Service. Also, for all action alternatives this change in access 

may warrant an update the Ketchikan-Misty Fiords Ranger District ATM Plan, and a Travel Analysis 

of the area, but it is not part of the proposed Saddle Lakes Timber Sale.

Approximately 0.3 mile of the Ketchikan to Shelter Cove Road would cross a corner of an OGR 

LUD. New road construction is generally inconsistent with OGR objectives (Forest Plan, 3-61), 

however the Forest Plan LUD map identifies this connection as a Transportation and Utility System

(TUS) overlay LUD. The TUS LUD takes precedence over any underlying LUD (Forest Plan, 3-128). 

Additionally, with the construction of the proposed Ketchikan to Shelter Cove Road connection, 

transportation development costs may be reduced depending on the timing of ADOT&PF 

construction as reconstruction of the Shelter Cove LTF may not be needed. 

Another cumulative effect of the no-action alternative would be a forfeiture of any opportunity to 

offer restoration and enhancement projects if it is decided to offer the Saddle Lakes project as 

stewardship contracts rather than standard timber sale contracts.
3 Affected Environment and Environmental Consequences

352  Chapter 3 – Transportation Saddle Lakes Timber Sale Final EIS

Alternative 2

Road miles associated with past timber harvest and proposed timber harvest under Alternative 2 

would result in a total of 62.9 miles of NFS road and 17.5 miles of decommissioned temporary roads 

within the Saddle Lakes project area. This is the second-lowest incremental increase of NFS and 

temporary roads created among the action alternatives. Although this is an increase in the cumulative 

amount of NFS roads proposed, Alternative 2 would minimally help to achieve Forest Plan objectives 

and desired conditions for transportation as compared to Alternatives 4, 5 and 6. 

Alternative 3

Road miles associated with past timber harvest and proposed timber harvest under Alternative 3 

would result in a total of 59.4 miles of NFS roads and 17.6 miles of decommissioned temporary roads 

within the Saddle Lakes project area. This is the lowest incremental increase of NFS and temporary 

road created among the action alternatives, and would not be as helpful in achieving Forest Plan 

objectives and desired conditions for transportation as the other action alternatives.

Alternative 4

Road miles associated with past timber harvest and proposed timber harvest under Alternative 4 

would result in a total of 72.3 miles of NFS roads and 21.7 miles of decommissioned temporary roads 

within the Saddle Lakes project area. This is the second-highest of the action alternatives in 

incremental increase of NFS and temporary road. The increase in the cumulative amount of NFS 

roads would help achieve Forest Plan objectives and desired conditions for transportation. 

Alternative 5

Road miles associated with past timber harvest and proposed timber harvest under Alternative 5 

would result in a total of 73.3 miles of NFS roads and 23.6 miles of decommissioned temporary roads 

within the Saddle Lakes project area. This is the highest incremental increase of NFS and temporary 

road of all the action alternatives. The increase in the cumulative amount of NFS roads would help 

achieve Forest Plan objectives and desired conditions for transportation more than all the other action 

alternatives.

Alternative 6

Road miles associated with past timber harvest and proposed timber harvest under Alternative 6 

would result in a total of 69 miles of NFS roads and 20.1 miles of decommissioned temporary roads 

within the Saddle Lakes project area. This is the third-highest incremental increase of NFS and 

temporary road among the action alternatives. The increase in the cumulative amount of NFS roads 

would help achieve Forest Plan objectives and desired conditions for transportation. 

Design Features and Mitigation Measures 

Invasive Species Prevention

Contracts, permits, road maintenance plans and project design documents would contain appropriate 

provisions concerning the prevention and/or spread of invasive species along the road system (see 

Invasive Species section in this chapter and mitigation in Appendix C).

New rock quarries may be developed to support new road construction and road maintenance. Quarry 

sites would be developed within 500 feet of a road, and avoid Class I and Class II stream buffers, 

eagle and goshawk nest tree buffers, and the Old-growth Habitat LUD. With either the expansion of 

an existing quarry or the development of a new site, the area footprint would not exceed 5 acres. 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Transportation - Chapter 3  353

The numerous rock quarries existing throughout the Saddle Lakes project area would allow for easy 

accessibility to those quarries and may eliminate the need to develop new sites. See the 

Transportation Resource Report for a listing and location of existing rock quarries in the project area 

available for future use and expansion.

Fish Crossings

All fish-bearing streams would be crossed with a bridge, log culvert structure, or a designed fish 

passage culvert. These structures would be removed from any temporary road after timber harvest and

associated activities are complete.

New Road Construction

In addition to using the existing roads, new NFS and temporary road construction would be needed to 

access harvest units within the project area for silvicultural activities. All new road construction 

would be off of the existing road system. 

Linear grading would be used to construct the new NFS roads. Linear grading is a construction tool 

used to reduce survey and design costs. The end result of a road constructed by linear grading is 

almost identical to normal construction. All streams would receive adequate structures under the 

specifications, and major structures (bridges and large culverts) are still surveyed and designed. All 

applicable best management practices (BMPs) would apply (see Appendix C, Table 120). 

The effects of the Saddle Lakes project on transportation would be limited through the site-specific 

application of Forest Plan Standards and Guidelines and BMPs in all action alternatives (see 

Appendix C). BMPs are used to ensure soil and water resources are considered in transportation 

planning activities. Specific BMPs and site-specific design criteria are listed by resource on the road 

cards in the project record for new NFS roads and in unit cards for temporary roads. In particular, the 

following measures would reduce overall transportation system effects for the action alternatives:

• Cutslope erosion would be mitigated by timely erosion control;

• Side-slopes of greater than 55 percent grade would be mitigated by full bench construction and

slope stabilization, if necessary. The road cards contain site-specific requirements for other 

areas requiring full bench construction;

• Road construction across muskegs would be mitigated by using wetland protection measures; and

• Open road density, road induced sedimentation, and road maintenance requirements would all be

mitigated through timely road storage after silvicultural activities are complete.

All newly constructed NFS roads would have an OBML of 1, but managed as ML 2 (open by permit) 

during timber sale activities. All of these roads (except for proposed NFS Road 8300280, see below) 

would be constructed and, after completion of the silvicultural activities, would be placed in a selfmaintaining hydrologic status and managed as ML 1 (closed). This would include the placement of 

drivable water bars or dips at necessary drainage culvert locations to direct water across the road in 

event the culvert is obstructed. Other design elements, such as oversized culverts, may be used to help 

reduce the need for routine drainage maintenance. 

The ADOT&PF has requested approval from the Forest Service for a right-of-way (ROW) to build, 

operate, and maintain about 1 mile of the Ketchikan to Shelter Cove road on NFS land (proposed 

NFS Road 8300280). This section of new road would remain open to the public as it would become 

part of the Ketchikan to Shelter Cove road system.
3 Affected Environment and Environmental Consequences

354  Chapter 3 – Transportation Saddle Lakes Timber Sale Final EIS

NFS roads are needed for long term-management of the National Forest to access future timber lands 

or have resource-specific requirements for engineering controls in construction. Closed NFS roads 

needed in the future could be re-opened by filling in waterbars or re-installing stream structures. Each 

of the closed NFS roads would be needed periodically in the future for silvicultural activities or 

further expansion into development LUDs. 

Temporary roads are not needed for long-term management of the National Forest. Temporary roads 

do not access future timber lands, and do not have resource concerns that require major engineering 

controls in construction. All temporary roads would be decommissioned after timber harvest. This 

involves removing culverts and bridges, restoring natural drainage patterns, and allowing the roadway 

to re-vegetate.

Road Reconditioning

Roads proposed for reconditioning are existing NFS roads currently managed as ML 1 (closed). Road 

closure methods can vary depending on administrative access needs and the timeframe for the next

silvicultural entry. Because of the varying closure methods, road reconditioning can vary from

replacing all removed structures and brushing the revegetated roadway, to simply blading drivable 

waterbars. Reconditioning would keep the roads in a safe and useful condition for which they are 

managed, while meeting Forest Plan Standards and Guidelines and following all applicable BMPs 

(the road cards contain road-specific items). 

Wetlands Avoidance

Proposed roads are located to minimize impacts to soils, water and associated resources in accordance 

with BMPs. Wetlands are, at times, unavoidable on some portions of the location due to safety 

concerns, engineering design constraints and consideration for other resources. Alternatives to the 

location on wetlands could mean longer, higher-cost roads that may have impacted similar areas of

wetlands. High-value wetlands (estuaries and tall sedge fens) are located within the Saddle Lakes 

project area (see Wetlands Resource Report); however, no high-value wetlands, requiring practicable 

avoidance, are crossed by any new road locations. 

Log Transfer Facilities and Sort Yards

Typically, a sort yard, fuel facility, equipment compound, repair shop, and field office are located at 

log transfer facility (LTF) sites. Activities with potential for spills of hazardous materials such as fuel 

require Spill Prevention, Control and Countermeasure plans (SPCC). Forest Service environmental 

engineers would review all SPCC plans prior to any petroleum products being on site. These plans 

must comply with all State and federal permits and laws.

In addition, LTFs, sort yards, and fuel storage areas would comply with all applicable best 

management practices (BMPs) listed in FSH 2509.22, R-10 2509.22 to 2006-2 including, but not 

limited to the following sections: 

• 12.8 – Oil Pollution Prevention and Servicing/Refueling Operations;

• 14.25 – Surface Erosion Control at Facilities;

• 14.26 – Daily LTF Cleanup; and

• 14.27 – Log Storage/Sort Yard Erosion Control.

National Core BMPs (USDA Forest Service 2012d) to be followed include: 

• Road-9 – Parking and Staging Areas;
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Transportation - Chapter 3  355

• Road-10 – Equipment Refueling and Servicing; and

• Fac-2 – Facility Construction and Stormwater Control.

Camping facilities could be located either on land or on a barge near an LTF. Existing sites would be 

used where possible. All camps must obtain the appropriate State permits.

Land camps typically include a water supply, garage disposal, and sewage disposal. Water would be 

sourced from streams. Garbage would be disposed of by incineration or transported to a municipal 

disposal site. And sewage would require an approved drain field or septic tank.

A float camp would also get their water from a stream source. Garbage would be incinerated or 

transported to a municipal disposal site. Sewage would be treated prior to discharge into the ocean.

Due to the remote nature of the Shelter Cove road system, all harvested timber would be hauled by 

log trucks to a LTF, transferred to the saltwater or barges, and then towed to either a lumber mill or an 

approved export site. All logs along the road system associated with the action alternatives are being 

appraised to the Shelter Cove LTF. Export logs are being appraised to the Leask Cove LTF. For the 

purposes of this analysis, it is assumed all logs would be hauled to the Shelter Cove LTF. 

Storms in 2013 damaged the Shelter Cove LTF enough to require replacement of the log bulkhead. 

Work would be conducted during the normal operating season, typically May through October, and 

would have to be timed with low and extreme low tides. Because of the necessary tidal timing, work 

may take up to 6 to 8 weeks to complete construction of the new bulkhead. Work would be conducted 

within the existing disturbed areas. Work may include:

1. Excavation and removal of existing rock and bulkhead. Excavation would be sloped inland at an

angle to provide a safe work area and to minimize material from raveling into the marine

environment;

2. End haul of any unsuitable material to an approved location;

3. Old log bulkhead would be placed in an approved location. Removal of other waste material

would be the responsibility of the contractor;

4. Haul of borrow material from existing pits if additional material is needed; and

5. Assembly of log crib, backfill, compaction, and placement of geotextiles.

All necessary federal or State permits would be obtained prior to any work for the reconstruction of 

the LTF. If logs are to be watered, all logs or log bundles would have a soft entry into the water. 
3 Affected Environment and Environmental Consequences

356  Chapter 3 – Wetlands Saddle Lakes Timber Sale Final EIS

Wetlands

This analysis considers the effects of timber harvest and road construction on the wetlands in the 

proposed Saddle Lakes project area. Additional detailed information regarding the analysis of 

wetlands and discussion of the literature used to estimate effects can be found in the Soil and Wetland 

Resource Report for the Saddle Lakes project area (Silkworth 2014) in the project record. 

Timber harvest can affect wetlands by changing the hydrology of the site, and elevating soil moisture. 

Road building can affect wetlands by displacing wetlands with fill and disconnecting hydrologic 

connectivity across the wetland due to road ditches or road fills. 

Units of Measure:

The following units of measure were used to evaluate effects of the proposed action and compare 

alternatives: 

• Acres of wetlands lost due to road construction; and

• Acres of wetlands affected by timber harvest.

Methodology

Soil resource inventory maps, including correlations between soil series and plant communities were 

used, in part, to determine the extent of wetlands in the project area. Field observations and photo 

interpretations were used to refine the wetland map. Wetland hydrology is inferred from the soil 

moisture regime. Avoidance of wetlands can be indicated by comparing the overall percentage of 

wetlands in an area with the percentage of the road that covers wetlands. 

Analysis Area

The analysis area for the wetland resource includes individual proposed timber harvest units and the 

associated land impacted by proposed road construction. Consequently, the direct and indirect effects 

analysis areas are different for each alternative. 

Affected Environment

Wetlands are found throughout the project area, covering about one-quarter of the project area. Due to 

the extent of wetlands in the project area and because forested wetlands are managed for their timber 

resources, complete avoidance of wetlands during timber harvest and road construction activities is 

not feasible or desired. Six wetland types are found in the project area. 

Wetland Types

Forested Wetlands: These wetlands typically have hemlock, cedar, or mixed conifer overstories, 

and ground cover consisting largely of skunk cabbage and deer cabbage. They occur on poorly or 

very poorly drained hydric soils. They are most common on broad glacial valley bottoms, and on 

gently sloping hill slopes or benches. These wetlands function as recharge areas for groundwater and 

streams, and for deposition of sediment and nutrients. They produce commercial forest products and 

occupy 4,130 acres of the project area. About 94 acres of forested wetlands have been harvested and 

54 acres are occupied by roads.

Scrub-Shrub/Muskeg: This type is a combination of muskeg and sedge meadows on peat deposits, 

and low-growing blueberry and heath on higher rises. Stunted lodge pole pine and mountain hemlock 

are common. Few stands support commercial timber. They provide summer habitat for terrestrial 

wildlife species. These wetlands are located at elevations below 1,500 feet and occupy about 4,571 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Wetlands - Chapter 3  357

acres of the project area. About 28 acres have been harvested and roads occupy about 34 acres 

of scrub-shrub/muskeg wetlands. 

Alpine Wetland: This type is a combination of sedge meadows and scrub-shrub on peat deposits, 

and low-growing blueberry and heath on higher rises. Stunted lodge pole pine and mountain hemlock 

are common. These wetlands are important for snow storage and can be a source of snowmelt water 

throughout the summer. These wetlands are located at elevations above 1,200 feet. These habitats 

provide summer habitat for terrestrial wildlife species. Alpine wetlands occupy about 984 acres of the 

project area. No timber harvest or road construction has occurred on these wetlands and none is 

planned under any alternative. Alpine wetlands are not discussed further in this document.

Lakes and Ponds: This wetland type consists of open freshwater on a variety of scales, from small 

ponds on muskegs to relatively large lakes. No timber harvest or road construction has occurred on 

this type and none is planned. These wetland types are not discussed further in this document.

Tall Sedge Fens: Tall sedge fens are diverse communities of sedges dominated by tall sedges such as 

Sitka sedge, with a variety of forbs and occasional stunted trees, usually spruce or hemlock. Soils are 

deep organic, often with thin layers of alluvial mineral soil. They occur in landscape positions where 

they receive some runoff from adjacent slopes, resulting in richer nutrient status than muskegs. These 

wetlands function as areas for recharge of groundwater and streams, deposition and storage of 

sediment and nutrients, and as waterfowl and terrestrial wildlife habitat, including black bear, mink, 

river otter, and beaver. Many tall sedge fens contain beaver ponds that provide high-quality waterfowl 

and salmon-rearing habitat. About 6 acres of existing roads occur on these wetlands. Tall sedge fens 

are considered high-value wetlands and are given protection under Riparian Standards and Guidelines

in the Forest Plan. No road construction or timber harvest is planned on these wetlands under any 

alternative and is not discussed further in this document 

Estuaries: Estuaries are unique brackish environments where freshwater mixes with saltwater. They 

are the most valuable wetland in the project area, supporting complex and productive ecosystems for 

critical fish and wildlife habitat. These areas are valuable for their habitat for both aquatic and 

terrestrial species. A high diversity of wildlife is typically found in estuaries. About 3 acres of 

estuaries occur on the project area and no road construction or timber harvest has occurred in 

estuaries and none is planned under any alternative. Estuaries are considered high-value wetlands and 

are given a 1,000 foot no-harvest buffer in the Forest Plan. Estuaries are not discussed further in this 

document. 

Non-wetlands: Those habitats that do not meet the criteria for being classified as wetlands.

Environmental Consequences

The effect of timber harvest on wetlands (primarily increased soil moisture) is expected to be 

temporary. All harvested sites are expected to regenerate naturally based on many decades of 

regeneration surveys. Trees are expected to grow more slowly on wetland sites. The detailed effects 

are described in the Soil and Wetland Resource Report for the Saddle Lakes project area (Silkworth 

2014). 

The effects of road building on wetlands may vary based on the substrate (soil type) and the 

landscape position of the wetland. Regardless of the type and location, road construction on wetlands 

results in an overall loss of wetland acreage. Hydrologic effects beyond the disturbed soil (road) 

corridor are expected to be limited to within a few meters of the road. The analysis is based on 

pertinent pieces of literature discussed in the Soil and Wetland Resource Report for the Saddle Lakes 

project area (Silkworth 2014). Key pieces of literature include Glaser 1999, Kahklen and Moll 1999, 
3 Affected Environment and Environmental Consequences

358  Chapter 3 – Wetlands Saddle Lakes Timber Sale Final EIS

McGee 2000, and Landwehr 2011.Due to the preponderance of wetlands and the interspersed nature 

of wetlands with uplands on the project area, complete avoidance of wetlands from proposed road 

construction activities is not practicable. All proposed roads would be constructed according to stateapproved BMPs as required by 33 CFR 323. All roads through wetlands would also follow the 15 

baseline provisions provided in 33 CFR 323. 

Direct and Indirect Effects

Effects Common to all Action Alternatives

No effects are anticipated to wetland resources as a result of implementing the State of Alaska 

right-of-way on NFS lands, the fish passage barrier modification, and the Shelter Cove LTF 

reconstruction. 

Alternative 1

Under Alternative 1, no timber harvest or road construction activities in wetlands would take place as 

a result of the proposed Saddle Lakes Timber Sale. Therefore, no wetlands would be impacted by 

timber harvest or road construction activities under Alternative 1. 

Vegetation on harvested wetlands would continue to grow toward hydrologic maturity (older stands 

have already reached this stage).Wetlands impacted by roads in the past would continue to be 

impacted. Vegetation would occupy ditch lines and, in the case of closed roads the roadbed, may be 

occupied by red alder. The road prism would remain in an upland condition. Road ditches, where 

present, support a variety of upland and wetland vegetation depending on local conditions and seed 

sources.

Alternative 2

Alternative 2 would harvest timber on 364 acres on forested wetlands and 36 acres on scrub-shrub 

and open muskegs wetlands. Road construction under this alternative would result in conversion of 18 

acres of forested wetlands and 6 acres of scrub-shrub and open muskegs to road. Under Alternative 2, 

29 percent of proposed road construction is on wetlands. 

Alternative 3

Alternative 3 would harvest timber on 207 acres on forested wetlands and 20 acres on scrub-shrub 

and open muskegs wetlands. Road construction under this alternative would result in conversion of 11 

acres of forested wetlands and 3 acres of scrub-shrub and open muskegs to road. Under Alternative 3, 

29 percent of proposed road construction is on wetlands. 

Alternative 4

Alternative 4 would harvest timber on 374 acres on forested wetlands and 35 acres on scrub-shrub 

and open muskegs wetland. Road construction under this alternative would result in conversion of 24 

acres of forested wetlands and 9 acres of scrub-shrub and open muskegs to road. Under Alternative 4, 

25 percent of proposed road construction is on wetlands. 

Alternative 5

Alternative 5 would harvest timber 442 acres on forested wetlands and 57 acres on scrub-shrub and 

open muskeg wetland. Road construction under this alternative would result in conversion of 26 acres 

of forested wetlands and 10 acres of scrub-shrub and open muskegs to road. Under Alternative 5, 25 

percent of proposed roads are on wetlands. 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Wetlands - Chapter 3  359

Alternative 6

Alternative 6 would harvest timber on 374 acres on forested wetlands and 34 acres on scrub-shrub 

and open muskeg wetland. Road construction under this alternative would result in conversion of 24 

acres of forested wetlands and 5 acres of scrub-shrub and open muskegs to road. Under Alternative 6, 

27 percent of proposed roads are on wetlands. 

Cumulative Effects

The analysis area for cumulative effects to wetlands is the project area. Since the non-NFS lands 

around George Inlet were not needed for the analysis, the wetland analysis area for cumulative effects 

does not include those lands.

Alternative 1

Under Alternative 1, no timber harvest or road building in wetlands would take place from the 

proposed Saddle Lakes Timber Sale project. No wetlands would be impacted by direct or indirect 

effects from new land management. Past harvest activity on wetlands has impacted 122 acres of 

wetlands. 

Alternative 2

Cumulative timber harvest following implementation of Alternative 2 would be 522 acres (5 percent 

of wetlands on the project area). Cumulative wetland converted to road under Alternative 2 is 116 

acres (1 percent of the wetlands on the project area). 

Alternative 3

Following implementation of Alternative 3, cumulative timber harvest would be 349 acres (3 percent 

of the project areas wetlands). Following implementation of Alternative 3 there would be 108 acres 

of wetland converted to road (1 percent of the project area wetlands). 

Alternative 4

Following implementation of Alternative 4, cumulative timber harvest on wetlands is about 531 acres 

(5 percent of the wetlands on the project area). Cumulative road construction in wetlands is about 127 

acres (1 percent of project area wetlands). 

Alternative 5

Following implementation of Alternative 5, cumulative timber harvest in wetlands would be about 

621 acres (6 percent of project area wetlands). Roads would occupy about 130 acres of wetland 

habitat (1 percent of wetlands on the project area). 

Alternative 6

Under Alternative 6, cumulative timber harvest in wetlands would be about 522 acres (5 percent of 

project area wetlands). Roads would occupy 116 acres of wetland habitat (1 percent of wetlands on 

the project area). 

Cumulative Effects of Other Foreseeable Projects

The Ketchikan to Shelter Cove Road project could add about 2 acres of wetland converted to road on 

the project area. Cumulatively, implementation of any of the alternatives could result in less than 

about 1.2 percent of the project area wetlands converted to road. 
3 Affected Environment and Environmental Consequences

360  Chapter 3 – Other Environmental Considerations Saddle Lakes Timber Sale Final EIS

Other Environmental Considerations_______________________

Unavoidable Adverse Impacts

Unavoidable adverse impacts are those impacts that cannot be avoided due to constraints in

alternatives. Implementation of standards and guidelines, best management practices (BMPs) and 

specific mitigation would reduce most adverse impacts that would result from the proposed 

actions (unit and road cards, located in project record), but the adverse impacts (residual impacts) 

that would remain are summarized below by resource. Unavoidable adverse impacts result from 

managing the land for one resource at the expense of the use or condition of other resources. 

Adverse impacts can be reduced or mitigated by limiting the extent or duration of impacts. 

Unavoidable adverse impacts for the action alternatives would be the same as those for the 

proposed action, except where specifically noted. 

Table 110 describes the unavoidable adverse impacts of resources in the Saddle Lakes project area.

Table 110. Unavoidable adverse impacts of resources in the Saddle Lakes project area

Resource Unavoidable Adverse Impacts

Air Quality and Climate 

Change None

Aquatics

Unavoidable adverse impacts resulting from the action alternatives

include short-term increases in sediment delivery and subsequent 

turbidity in streams from road construction and increased stream 

temperatures from removal of canopy cover over feeder streams (Class 

III/IV). Other short-term impacts include bark accumulation, leachate, 

and shading impacts to the marine environment near the Shelter Cove 

LTF. Sediment delivery to streams from on-going road use, crossing 

structures, and maintenance would be minor, but more long-term in 

nature.

Environmental Justice None

Floodplains None

Heritage None

Invasive Species

Some invasive plant seed or plant parts could be transported to other 

areas of the Saddle Lakes project area regardless of mitigation 

measures taken to eliminate this risk.

Lands and Minerals None

Plants

Some sensitive plants could be inadvertently trampled during logging 

operations in spite of directional felling or other spatial protection given 

around known populations.

Recreation

There would be adverse effects to recreation opportunities with the 

removal of the Saddle Lakes Recreation Area VPR (Alternatives 4 and 

5). 

Roadless None
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Other Environmental Considerations - Chapter 3  361

Resource Unavoidable Adverse Impacts

Scenery

Much of the Saddle Lakes Timber Sale takes place in areas 

categorized as having Very Low, Low, and Moderate Existing Scenic 

Integrity (ESI). Generally, proposed harvest would maintain the scenic 

integrity of the areas at the existing level or lower it a level or two. The 

Saddle Lakes Recreation Area viewshed has 1,890 acres of Very High 

and High ESI. Harvest proposed under Alternatives 4 and 5 would

change the scenic integrity of the viewshed to Very Low. This reduction

of 4 to 5 levels of Scenic Integrity is an adverse effect to the scenery of 

the area. The scenic integrity of the viewshed would change from one 

where the scenery is or appears visually intact, to one where harvest 

activities would dominate the view.

Silviculture None

Socioeconomics None

Soils None

Subsistence

The Saddle Lakes Timber Sale may have a significant possibility of a 

significant restriction of subsistence uses on deer due to changes in 

access and demand, but not result in a significant restriction of fisheries 

subsistence uses, or other wildlife uses.

Timber None

Transportation None

Wetlands Road construction would result in a long-term loss of wetland acreage. 

Wildlife

There would be long-term (150-300 years) to permanent loss of oldgrowth habitat (and habitat capability) for management indicator 

species (MIS), R10 Sensitive species, and other species of interest

(SOI). Alternative 3 would maintain more old-growth habitat than 

Alternative 2, whereas Alternatives 6, 4, and 5 (in increasing order of 

impacts) would maintain less old-growth habitat than Alternative 2. 

Relationship between the Short-term Use of the Environment and the 

Maintenance of Long-term Productivity

This section provides the tradeoffs between short-term impacts and long-term impacts to 

environmental resources that would occur with implementation of the proposed action. Short-term 

uses, and their environmental effects, are those that occur within the first 10 years following 

implementation. Long-term productivity refers to the capability of the land and resources to continue 

producing goods and services for 50 years and beyond (USDA Forest Service 2008c, p. 3-2). 

The intensity and duration of the effects described in the EIS depend on the alternative and the 

mitigation measures applied to protect the resources. Most unavoidable effects (discussed above) are 

expected to be short term. Effects would be managed to comply with established legal limits in all 

cases, such as maximum time for regeneration. Mitigation measures and/or monitoring procedures 

have been planned for those areas that may be affected to reduce these effects. Specific mitigation 

measures are documented in the unit and road cards (located in the project record; if a decision is 

made to harvest, mitigation measures for harvest units and roads will be disclosed in the ROD).

Maintaining the productivity of the land is a complex, long-term objective. All alternatives protect the 

long-term productivity of the project area through the use of specific standards and guidelines, BMPs, 

and mitigation measures. Long-term productivity could change as a result of various management 

activities proposed in the alternatives. Timber management activities would have direct, indirect, and 

cumulative effects on the economic, social, and biological environment. 
3 Affected Environment and Environmental Consequences

362  Chapter 3 – Other Environmental Considerations Saddle Lakes Timber Sale Final EIS

Short-term adverse impacts associated with the proposed action would include the temporary loss of 

vegetation, loss of soil productivity, temporary increase in erosion potential and sedimentation in 

streams, potential increase of non-native invasive species, loss of wildlife habitat and displacement of 

wildlife, slight increases in fugitive dust emissions and other emissions from other sources, temporary 

loss of public access to roads for recreation and other uses, temporary noticeable changes to the 

viewshed, and a temporary increase in noise. Some localized adverse effects may occur on a 

recurring, though temporary, basis. Effects such as road construction, timber harvest, timber hauling, 

and the operation of internal combustion engines may cause temporary adverse effects to air quality.

Short-term beneficial impacts would include an increase in employment and spending revenue for the 

local communities and an increase in employment for Southeast Alaska (primarily Ketchikan 

Gateway Borough and Prince of Wales Island). Counties (i.e., Boroughs) also receive a portion of the 

revenues generated on NFS lands through the Secure Rural Schools and Community Self 

Determination Act (2000) and subsequent reauthorizations of this Act. Payments are allocated to 

counties for use in different types of programs or projects including: schools and roads (Title I); 

projects to benefit forest lands (Title II); and search, rescue, and firewise community efforts (Title 

III).

Long-term impacts are highly dependent on the success of mitigation. The loss of the soil resource 

due to erosion and mass failures would be a long-term adverse impact. There would also be a longterm loss of soil productivity due to the disturbance of the soil structure, which may result in a change 

in vegetation productivity or an increase in invasive species. However, specific standards and 

guidelines, mitigation measures, and BMPs are required, and it is anticipated there would be minimal 

long-term impacts for most resources. Long-term impacts to resources would vary with changes in 

vegetation resulting in long-term adverse impacts to wildlife. Some long-term adverse effects may be 

unavoidable, such as a permanent loss of old-growth habitat within the development LUDs and a 

permanent loss of habitat capability to support wildlife populations. This could result in a long-term 

loss of area for productive old-growth and for forage for wildlife.

Irreversible and/or Irretrievable Commitments of Resources

Irreversible and/or irretrievable commitments of resources refer to impacts or losses to resources that 

cannot be reversed or recovered. The term “irreversible commitments” describes the loss of future 

options. Irreversible commitments are decisions affecting nonrenewable resources, such as soils, 

minerals, plant and animal species, and heritage resources. Such commitments of resources are 

considered irreversible because the resource has deteriorated to the point that renewal can occur only 

over a long period of time or at a great expense, or the resource has been destroyed or removed. 

Irreversible effects cannot be reversed. Examples are the extinction of a species or the loss of soil due 

to erosion and mass wasting (landslides), where the loss is permanent and not reversible. The gradual 

decline in old-growth habitat may be considered an irreversible commitment (USDA Forest Service

2008c, pg. 3-2) because the resource has deteriorated to the point that renewal can only occur over a 

long period of time, 150 years or more for old-growth forest (USDA Forest Service 2008c, pg. 3-

137). 

The term “irretrievable commitment” applies to the loss of production or use of natural resources. 

Irretrievable commitments represent opportunities foregone for the period during which resource use 

or production cannot be realized. Irretrievable effects change the outputs or commodities of the land’s 

use. These decisions are reversible, but the production opportunities foregone are irretrievable. An 

example of such commitments is the allocation of LUDs that do not allow timber harvest to areas 

containing suitable and accessible timberlands. For the time over which such allocations are made, 

the opportunity to obtain timber from those areas is foregone and irretrievable. The commitment is 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Other Environmental Considerations - Chapter 3  363

irretrievable rather than irreversible because future entries could harvest timber in those areas if they 

are still classified as part of the suitable timber base. However, irretrievable commitments are 

reversible. An example of such commitment includes the development of a recreation area within 

suitable and available timber lands. For the time over which such development is in place, the 

opportunity to harvest timber from the recreation area is foregone, thus irretrievable.

Identified irreversible or irretrievable commitments in the proposed Saddle Lakes project area are 

summarized in Table 111. 
3 Affected Environment and Environmental Consequences

364  Chapter 3 – Other Environmental Considerations Saddle Lakes Timber Sale Final EIS

Table 111. Irreversible and/or irretrievable commitments1/ of resources identified in the proposed Saddle Lakes project area

Resource Irreversible 

Effects 

Irretrievable 

Effects Explanation

Air Quality and 

Climate Change No No

None of the alternatives are expected to have a measurable impact on the local or global climate or 

on air quality. The insignificant increase in GHG emissions produced as a result of the project 

operations would likely be insignificant to any long-term climatic changes. The rate of carbon 

sequestration would likely continue at the current rate for several years. All action alternatives 

would likely result in a similar rate of yellow-cedar decline as current conditions. Regeneration rates 

would also not likely change under any action alternative 

Aquatics No Yes Removal of canopy would increase stream temperatures and road crossings would increase 

sediment inputs to resident and anadromous fish habitat. Use of BMPS would minimize the effects.

Floodplains No No None of the alternatives propose new road construction or timber harvest in floodplains.

Heritage No No

Loss of heritage resource sites resulting from accidental damage or vandalism would be an

irreversible impact but is unlikely. Standards and guidelines, survey methodology prior to activities, 

and mitigation measures as specified in this document provide reasonable assurance that no 

irreversible loss of heritage resources would occur.

Invasive Species No Yes 

Invasive species spreading into disturbed areas would be irretrievable because the impact would 

be reversible. Specific Standards and Guidelines, BMPs, mitigation and monitoring would prevent 

and/or minimize spreading certain invasive plants further into the project area.

Lands and 

Minerals No No There are no commitments of resources which would affect lands or minerals.

Plants No No Specific Standards and Guidelines for sensitive plants would prevent these losses. 

Recreation No Yes

There would be a loss of recreation opportunities with the removal of the planned Saddle Lakes 

Recreation Area VPR designation (Alternatives 4 and 5). This would be an irretrievable 

commitment because the recreation opportunity in this area would be foregone.

Roadless No No

Inventoried roadless areas (IRAs) are set aside to determine their eligibility for inclusion into the 

National Wilderness Preservation System. No direct effects to IRAs are anticipated, and indirect 

effects would not lead to a loss of this resource. 

Scenery No Yes

Reduction in the visual quality of an area due to timber harvesting would be an irretrievable impact; 

however, impacted viewsheds typically recover (from a visual quality standpoint) after about 40 

years.

Silviculture No Yes It is not expected that old-growth characteristics would naturally reoccur within harvest areas for 

150 years or more; however, old-growth forest structure would eventually return to the landscape.

Socioeconomics No No

There would be increased use of local contractors during timber sale operations. This commitment 

could be viewed as a beneficial impact because of the jobs created and/or maintained, particularly 

in an economy where timber jobs have been declining. 
Affected Environment and Environmental Consequences 3

Saddle Lakes Timber Sale Final EIS Other Environmental Considerations - Chapter 3  365

Resource Irreversible 

Effects 

Irretrievable 

Effects Explanation

Soils Yes Yes

The loss of the soil resource due to detrimental disturbance may be considered a partial irreversible 

impact because soil productivity may be permanently altered. Impacts have been minimized to the 

extent feasible in all action alternatives by following Region 10 Soil Quality Standards, incorporating 

BMPs and applying mitigation measures as specified in this document. Future studies may 

determine to what extent recovery occurs from soil displacements.

Soils displaced by road construction activities are considered an irretrievable impact. Long-term 

loss of soil productivity is irreversible because the soil resource has deteriorated to the point that 

renewal can occur only over a long period of time or at a great expense

Subsistence Yes No

Reductions in deer could result in a significant possibility of a significant restriction on subsistence 

use of deer. Effects from action alternatives are expected to be minor for subsistence fishery 

resources. Any effects would likely be small, localized to the site or affected stream reach, and

short-term.

Timber No Yes

Foregoing timber harvest opportunities at this time in certain areas, due to resource concerns or 

economics, may represent an irretrievable commitment of resources because that volume cannot 

be harvested. The commitment is irretrievable rather than irreversible because future entries could 

harvest those areas if they are still classified as part of the suitable timber base.

Transportation Yes No

Road construction is an irreversible action because of the time it takes for a constructed road to 

revert to natural conditions. Irreversible actions also include the associated rock quarries which are 

developed in conjunction with these roads. 

Wetlands Yes No

Wetlands displaced by road construction activities are irreversible commitments because the 

wetland resource has deteriorated to the point that renewal can occur only over a long period of 

time or at a great expense, or because the wetland soils have been destroyed or removed. In road 

construction, wetland soils are either scraped away or are buried beneath road fill, greatly limiting 

their pre-disturbance function.

Wildlife Yes No

Under the current Forest Plan 100 year rotation, young-growth timber in development LUDs would 

be re-harvested before the stands develop old-growth characteristics (150+ years). Following 

complete removal of the overstory, it may take 300 years or more for a stands in Southeast Alaska 

and Northern coastal British Columbia to develop old-growth ecological characteristics (Orians and 

Schoen 2013). Therefore, clearcut timber harvest creates a permanent loss of old-growth habitat 

within development LUDs and a permanent loss of habitat capability to support wildlife populations.

1/ Irreversible commitments describe the loss of future options to a given resource; these effects cannot be reversed. Irretrievable commitments apply to the loss of production, harvest 

or use of natural resources; these effects can be reversed.
366  Chapter 3 – Other Environmental Considerations Saddle Lakes Timber Sale Final EIS

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Chapter 4 

Lists and References

Saddle Lakes Timber Sale Final EIS Document Contributors - Chapter 4  367

Chapter 4. Lists and References

Chapter 4 includes lists of the document contributors (both IDT members and other contributors), a 

distribution list for agencies, individuals, organizations, municipalities, Indian Reorganization Act 

(IRA) tribes and other tribal groups that will be sent the FEIS, literature cited in the FEIS, and an 

index of key words by page number. 

Document Contributors __________________________________

The following is a list of contributors to the Saddle Lakes Timber Sale EIS. Other Forest Service 

employees contributed to the completion of this document through their assistance in support 

functions. Their help is greatly appreciated.

Interdisciplinary Team Members

Jim Beard, Writer-Editor 

Education: A.A. Wildlife Biology, Los Angeles Harbor College, 1976; Biology and Zoology education at various 

Universities (part-time), 1977-1987; Fisheries Biology major, California State University, Humboldt, 1987-1991

Experience: 27 years with the Forest Service (since 1975). Writer-Editor (2 yrs), Fisheries Biologist (19 yrs), 

Biological Technician –Fisheries (3 yrs), Forestry Technician –Fire (3 yrs)

Other Relevant Experience: Biological Technician –Fisheries, USFWS (1 yr); Fisheries Technician, Pacific 

Marine Fisheries Commission (6 yrs)

Jeannie Blackmore, Natural Resource Specialist (Lands, Minerals, FERC)

Education: B.S. Forestry and Horticulture, Oregon State University 1980

Experience: 33 years with the Forest Service (since 1980). Natural Resource Specialist – Lands, Minerals, 

FERC (6 yrs); Planning Forester, Presale, Resource Assistant , GIS, Silviculture, Wildlife, Fire (27 years)

Jess Davila, Fisheries Biologist

Education: M.S. in Natural Resources (Fisheries), Oregon State University, Corvallis (2013); A.S. Fisheries, 

University of Alaska, Fairbanks (2009); B.F.A. in Fine Arts, State University of New York (SUNY), New Paltz 

(2004)

Experience: 5 years with the Forest Service (since 2009). Fisheries Biologist (1 yr), (Student-Trainee, Fisheries 

Biologist) (2 yrs), (Biological Technician—Fisheries (2 yrs) 

Karen L. Dillman, Botanist/Ecologist

Education: M.S. Biological Sciences Arizona State University, 2004; B.S Ecology, Idaho State University, 1995

Experience: 29 years with the Forest Service (since 1984). Ecologist (10 yrs), Botanist (10 yrs)

Susan Howle, Project/IDT Leader

Education: M.S. Geoscience, University of Massachusetts, Amherst, 1998; B.S. Geoscience, Middle Tennessee 

State University, Murfreesboro, 1988

Experience: 10 years with the Forest Service (since 2004). Environmental Coordinator (8 yrs), Forest Planner 

(2 yrs)

Other Relevant Experience: 5 years with BLM. Environmental Coordinator, BLM (3 yrs); Supervisory Natural 

Resource Specialist (2 yrs) 
4 Lists and References

368  Chapter 4 – Document Contributors Saddle Lakes Timber Sale Final EIS

Robert G. Lewis, Supervisory Forester

Education: M.S. Forest Science, Oregon State University, 1995; B.S. Forestry, Humboldt State University, 1990

Experience: 2.5 years with the Forest Service (since 2011). Supervisory Forester (2.5 yrs) 

Other Relevant Experience: Registered Professional Forester with about 30 years’ experience in silvicultural 

planning and prescription development, timber harvest planning and timber sales development, forest roads 

location and yarding systems, cumulative impacts analyses, logging and reforestation contract administration, 

forest inventory & timber cruising, mapping and GIS, forest regeneration & timber stand improvement, and forest 

research

Jason Powell, Transportation Planner

Education: B.S. Forest Engineering, Oregon State University, 2010

Experience: 4 years with the Forest Service (since 2009). Transportation Planner (3 yrs), Civil Engineering 

SCEP (Student Career Experience Program) (1 yr)

Other Relevant Experience: Forester, private (8 yrs); Logger (2.5 yrs); Teaching Assistant, Dept. of Forest 

Engineering, Oregon State University (1 yr)

Gene Primaky, Geographic Information Systems (GIS) Specialist/Analyst 

Education: Certificate of Forestry, AvTech Institute of Technology, 1989-1990; 3 years Forestry at Bemidji 

State University, Minnesota, 1990-1993 

Experience: 24 years with the Forest Service (since 1989). GIS Specialist/Analyst (15 yrs); Forestry Technician 

(9 yrs) 

Jill Reeck, Wildlife Biologist

Education: B.S. Wildlife & Fisheries Science, South Dakota State University, 1981; B.S. Biology, South Dakota 

State University, 1981

Experience: 33 years with the Forest Service (since 1980). Wildlife Biologist (31 yrs); Biological Technician –

Wildlife and Fisheries (2 yrs)

Greg Roberts, Silviculturist (Certified)

Education: B.S. Forestry, Southern Illinois University, 1987

Experience: 20 years with the Forest Service (since 1993). Silviculturist (4 yrs); Forester (10 yrs); Forestry 

Technician (6 yrs)

Martin Stanford, Archaeologist

Education: B.A. Anthropology/Biology, University of Colorado, Boulder, 1975; Underwater Archaeology, 

University of North Carolina, Wilmington, 1975

Experience: 27 years with the Forest Service (since 1970). Archaeologist (17 yrs), Archaeological Technician (4 

yrs), Forestry Technician (6 yrs)

Other Relevant Experience: Supervisor, ARCO Exploration Geological Facility (14 yrs); Underwater 

Archaeologist (1 yr)

Darin Silkworth, Soil Scientist

Education: M.S. Soil Science, University of Minnesota, 1980; B.S. Crop and Soil Sciences, Michigan State 

University, 1977

Experience: 9 years with the Forest Service (since 2004). Soil Scientist (9 yrs)

Other Relevant Experience: Soil Scientist, NRCS (5 yrs); Consultant Soil Scientist (17 yrs)

Danielle Snyder, Landscape Architect

Education: M.L.A. Landscape Architecture, University of Colorado Denver, 2008; B.S.M.E Mechanical 

Engineering, B.A. Drama, Tufts University, 2000

Experience: 6 years with the Forest Service (since 2007). Landscape Architect (4 yrs), Civil Engineer/Landscape 

Architect (1 yr), Engineering/Architecture Intern (1 yr)
Lists and References 4

Saddle Lakes Timber Sale Final EIS Document Contributors - Chapter 4  369

Nate Stearns, Forester (Logging Systems Specialist)

Education: B.S. Forest Management; Forest Administration and Utilization, University of Wisconsin, Stevens 

Point, 1998

Experience: 15 years with the Forest Service (since 1999). Forester (8.5 yrs.), Forestry Technician (6.5 yrs.)

Cathy Tighe, Recreation/Wilderness/Lands/Minerals District Staff Officer

Education: B.S. Biology, University of Oregon, 1994

Experience: 20 years with the Forest Service (since 1989). Recreation Staff Officer (2 yrs), Special uses Permit 

Administration (3 yrs), Wildlife Biologist (7 yrs), Resource Assistant (4 years), Biological Technician – Wildlife / 

Botany (3.5 yrs), Forestry Aide (0.5 yr) 

Damien Zona, Silviculturist

Education: M.F. Silviculture, Northern Arizona University, 2009; B.A. History, University of Arizona, 2002

Experience: 7 years with the Forest Service (since 2007). Silviculturist (4 yrs), Assistant District Silviculturist (2 

yrs), Forester (1 yr)

Other Relevant Experience: Forestry Technician, Northern Arizona University, (2 yrs)

Other Document Contributors

The following individuals significantly contributed their time through fieldwork, analysis, or review 

to earlier/current versions of the Saddle Lakes Environmental Impact Statement (EIS):

Daryl A Bingham, NEPA Planner

Education: B.S. Watershed Management, Oregon State University 2009. Environmental Science, Washington 

State University Vancouver 2006.

Experience: Bureau of Land Management, Burn Oregon. Fisheries, Riparian, Water Quality, T&E aquatics, and 

Floodplains. 2007-2014

Jason Bramstadt, Forester (Silviculture & Timber Sale Preparation)

Education: M.F. Forestry, Michigan Technological University, 2010; B.S. Biology (Plant Sciences), University of 

Wisconsin-Superior, 2009; B.A. German, Lake Forest College, 2004

Experience: 4 years with Forest Service (since 2008). Forester (2 yrs), Forestry Technician (1.5 yrs), Biological 

Technician-Plants (0.5 yrs) 

Other Relevant Experience: Research Assistant at Michigan Technological University (1 year); Research 

Assistant at University of Wisconsin-Superior (3 yrs) 

Sally Burch, Data Services Specialist (Geographic Information Systems (GIS) Analyst)

Education: Civil and Mechanical Engineering education (3 yrs), University of Alaska, Fairbanks

Experience: 25 years with the Forest Service (since 1988). Data Services Specialist, GIS (18 yrs); Civil Engineer 

Technician (7 yrs)

Other Relevant Experience: Civil Engineer Technician, U.S. Army Corps of Engineers (3 yrs)

Eric Castro, Fisheries Technician (Aquatics Contributor)

Education: B.S. Biological Sciences, California State University, Stanislaus (2005)

Experience: Six years with the Forest Service (18/8 since 2010 with three field seasons as 1039 seasonal)

Other relevant Experience: 1.5 years of Fisheries Technician with Utah Division of Wildlife Resources

Andy Klimek, Programmer Analyst (Geographic Information Systems (GIS) Analyst)

Education: B.A. English Juniata College, Huntingdon, Pennsylvania, 1991

Experience: 20 years with the Forest Service (since 1994). Information Technology Specialist, GIS Programmer 

(1 year); Data Services Specialist, GIS (2 years); Forestry Technician, Database Manager (1 yr); Supervisory 

Range Technician (10 yrs); Wilderness Ranger (6 yrs)
4 Lists and References

370  Chapter 4 – Document Contributors Saddle Lakes Timber Sale Final EIS

Patricia Krosse, Ecologist (Climate Change Contributor) 

Education: B.S. Soil Science, California Polytechnic State University, San Luis Obispo, California, 1987

Experience: 29 years with the Forest Service (since 1985); Ecology, Botany and Invasive Species Program 

Manager (14 years); Forest Ecologist (5 years); Soil Scientist (10 years)

Teague Mercer, Hydrologist

Education: B.A. Geology, Southern Oregon University, 1999

Experience: 2 years with the Forest Service (since 2011). Hydrologist (2 yrs)

Other Relevant Experience: Hydrologist, BLM (2 mo.); Hydrologic Technician, USGS (8.5 yrs)

Pete Schneider, Fisheries Biologist (Aquatics Contributor) 

Education: B.S. Zoology, University of Idaho (1994)

Experience: 15 years with the Forest Service (since 1998). Fisheries Biologist (12 yrs), Biological Technician –

Fisheries and Wildlife (3 yrs) 

Other Relevant Experience: Research Associate- Crop and Soil Science, Washington State University (2 years)

Will Young, Fish/Wildlife/Hydrology/Botany Staff Officer

Education: M.S. Fisheries Resources, University of Idaho, 2002; B.S. Fish & Wildlife Management, Montana 

State University, 1995

Experience: 11 years with the Forest Service (since 2002). Fish, Wildlife, Hydrology, Botany Program Leader (4 

yrs), Fish Biologist / Hydrologist, (7 yrs)

Other Relevant Experience: Fisheries Technician, Montana Department of Fish, Wildlife and Parks (4 yrs)

Linda Pulliam, Project/IDT Leader (retired 2012)

Rob Reeck, Planning Staff Officer (retired 2012)

Pete Roginski, Fisheries Technician

John Stevens, Geographic Information Systems (GIS) Analyst (retired 2012)

State of Alaska Contributors

The following individuals contributed their time for review to earlier/current versions of the Saddle 

Lakes Draft Environmental Impact Statement (EIS):

Clarence Clark, ADNR, Division of Forestry, Forester III

Mark Minnillo, ADF&G, Habitat Division, Habitat Biologist III

Kyle Moselle, ADNR, Office of Project Management and Permitting, Large Project/Tongass NF Coordinator
Lists and References 4

Saddle Lakes Timber Sale Final EIS Distribution List - Chapter 4  371

Distribution List ________________________________________

A copy of the Saddle Lakes Timber Sale FEIS was sent to the following agencies, organizations, 

businesses, public officials, municipalities, individuals, and tribal groups. These parties either 

commented on the project, requested a copy of the EIS at some time in the NEPA process, are part of 

the Forest Service's mandatory mailing list (Forest Service Handbook (FSH) 1909.15, Sections 23.2 

and 63.1) or are recognized municipalities or tribal groups potentially affected by, or interested in, the 

Saddle Lakes Timber Sale project.

Agencies

Advisory Council on Historic Preservation, Director 

of Planning, Washington, DC

Alaska Office of the Governor, Juneau, AK

Alaska State Dept. of Environmental Conservation, 

Division of Air Quality, Juneau, AK

Alaska State Dept. of Environmental Conservation, 

Non-point Source Program, Juneau, AK

Alaska State Dept. of Environmental Conservation, 

Stormwater Program, Anchorage, AK

Alaska State Dept. of Fish & Game, Division of 

Habitat, Craig, AK

Alaska State Dept. of Fish & Game, Division of 

Sport Fish, Ketchikan, AK

Alaska State Dept. of Fish & Game, Division of 

Wildlife Conservation, Ketchikan, AK

Alaska State Dept. of Natural Resources, ANILCA 

Coordinator, Anchorage, AK

Alaska State Dept. of Natural Resources, Regional

Manager, Juneau, AK

Alaska State Dept. of Natural Resources, Division 

of Forestry, Ketchikan, AK

Alaska State Dept. of Natural Resources, Office of 

Project Management and Permitting, Tongass 

Team Coordinator, Juneau, AK

Alaska State Dept. of Transportation, Regional 

Planner, Juneau, AK

Alaska State Historic Preservation Officer, 

Anchorage, AK

Alaska State Parks, Ketchikan, AK

Environmental Protection Agency, NEPA Reviewer 

Anchorage, AK

Environmental Protection Agency, EIS Review 

Coordinator, Seattle, WA

Environmental Protection Agency, EIS Filing 

Section, Washington, DC

Federal Aviation Administration, Office of the 

Regional Administrator, Anchorage, AK

Federal Highway Administration, Division 

Administrator, Juneau, AK

National Marine Fisheries Service, Regional 

Administrator Juneau, AK

National Marine Fisheries Service, Habitat 

Conservation Division, Juneau, AK

National Marine Fisheries Service, Protected 

Resources Division, Juneau, AK

Natural Resources Conservation Service, National 

Environmental Coordinator, Washington, DC

NOAA Office of Policy & Strategic Planning, NEPA 

Coordinator, Washington, DC

Southeast Alaska Regional Subsistence Advisory 

Council, Chair, Juneau, AK

US Army Corps of Engineers, Alaska District, Joint 

Base Elmendorf-Richardson, AK

US Army Corps of Engineers, Regulatory Field 

Office, Juneau AK

US Army Corps of Engineers, Pacific Ocean 

Division, Fort Shafter, HI

US Coast Guard, Environmental Management CG443, Washington, DC

US Coast Guard, Commandant, Dept. of Homeland 

Security, Washington, DC

US Dept. of Energy, Office of NEPA Policy and 

Compliance, Washington, DC

US Navy, Chief of Naval operations, Energy and 

Environmental Readiness Division, Washington, 

DC

USDA APHIS PPD/EAD, Deputy Director, 

Riverdale, MD

USDA Forest Service, Daryl Bingham, Tongass NF, 

Ketchikan, AK

USDA Forest Service, Ecosystem Planning 

Director, Regional Office, Juneau, AK

USDA Forest Service, Forest Supervisor, Chugach 

NF, Anchorage, AK

USDA Forest Service, Forest Supervisor, Tongass 

NF, Ketchikan, AK
4 Lists and References

372  Chapter 4 – Distribution List Saddle Lakes Timber Sale Final EIS

USDA Forest Service, Regional Forester, Regional 

Office, Juneau, AK

USDA Forest Service, Patrick Heuer, Tongass NF, 

Sitka, AK

USDA Forest Service, Sue Jennings, Petersburg 

Supervisor’s Office, Petersburg, AK

USDA Forest Service, Karen Iwamoto, Tongass 

NF, Sitka, AK

USDA Forest Service, Ken Post, Regional Office, 

Juneau, AK

USDA Forest Service, Cynthia Sever, Tongass NF, 

Petersburg, AK

USDA Forest Service, Charley Streuli, Petersburg 

Supervisor’s Office, Petersburg, AK

USDA Forest Service, Marina Whitacre, Tongass 

NF, Petersburg, AK

USDA Forest Service, Planning Department, Craig, 

AK 

USDA Forest Service, Planning Department, 

Ketchikan, AK

USDA Forest Service, Planning Department, 

Petersburg, AK

USDA Forest Service, Planning Department, 

Thorne Bay, AK

USDA Forest Service, Planning Department, 

Wrangell, AK

USDA National Agricultural Library, Beltsville, MD

USDA Office of Civil Rights, Washington, DC

USDI Alaska Affairs, Washington, DC

USDI Bureau of Land Management, Alaska State 

Office, Anchorage, AK

USDI Fish & Wildlife Service, Conservation 

Planning, Juneau, AK

USDI Fish & Wildlife Service, Ecological Services, 

Juneau, AK

USDI Office of Environmental Policy & Compliance, 

Washington, DC

Individuals

Alex Pennino, Ketchikan, AK

Astrid Peura Crocker, Ketchikan, AK

B Bigelow & R Smith, Ketchikan, AK

Bill Rotecki, Ketchikan, AK

Bob Durland, Ketchikan, AK

Brad Finney, Ketchikan, AK

Charles W. Stout, Ward Cove, AK

Christopher Boyette, Ketchikan, AK

Dick Artley, Grangeville, ID

Eric Jorgensen/Tom Waldo, Juneau, AK

Ernie Eads, Thorne Bay, AK

Elmer Makua, Ketchikan, AK

Gerard Hildebrandt, Ward Cove, AK

George Woodbury, Wrangell, AK

Linda Pulliam, Ketchikan, AK

Lyle and Kathleen Stack, Ketchikan, AK

Halli Kenoyer, Ketchikan, AK

James Llanos, Ketchikan, AK

James Stanley, Ward Cove, AK

Jerry L. Kiffer, Ketchikan, AK

Jim Simpson, Allen TX

Joan & Salvatore Beraldi, Ketchikan, AK

John Clifton, Ketchikan, AK

John Inman, Ketchikan, AK

Johnny Rice, Craig, AK

Jose G Medina, Fresno, CA

Julie Powers, Ketchikan, AK

Ken Teune

Len Laurance, Ketchikan, AK

Leslee Engler, Ketchikan, AK

Margaret Clabby, Ketchikan, AK

Marvin Charles, Ketchikan, AK 

Matthew Williams, Ketchikan, AK

Merle Hawkins, Ketchikan, AK

Mike Cessnun, Ketchikan, AK

Nora DeWitt, Ketchikan, AK

Norman Arriola, Ketchikan, AK

Dr. Paul Friesema, Env. Policy & Culture Program, 

Evanston, IL

Peter Ellis, Ketchikan, AK

Starkey Wilson, Ketchikan, AK

Susan Round, Ketchikan, AK

Victoria McDonald, Ketchikan, AK

William S. Haag, Kodiak, AK

William Wilson, Metlakatla, AK
Lists and References 4

Saddle Lakes Timber Sale Final EIS Distribution List - chapter 4  373

George Inlet Landowners

Anna G and Kurt G Gucker, Sterling, AK

Authur A and Diana L Maioriello, Anchorage, AK

Bessie J Denny, Ketchikan, AK

Bill A and Jean A Mackie, Ketchikan, AK

Bradley D and Sherri L Tyler, Ketchikan, AK

Carolyn Bell, Ketchikan, AK 

Catherine W Boulton, Idaho Springs, CO

Charles F Dunne, Metlakatla, AK

Charles and Michelle Reed, Ketchikan, AK

Chris Wenzel, Ludington, MI

Christa B Kotrc, Ketchikan, AK

Clarita J Seludo, Ketchikan, AK

Darrel B Charles, Ketchikan, AK 

Daniel C and Mary Ann Christensen, Ketchikan, AK

David W Rosendin, Ketchikan, AK

David L and Barbara A Whiteman, Tuntutuliak, AK

Don L Stewart, Ketchikan, AK

Doris E Vig, Ketchikan, AK

Edward C Graham, Ketchikan, AK

E Denny, Ketchikan, AK

E M Blair, Ketchikan, AK

Eric L and Johanna E Collins, Ketchikan, AK

Fredrick D Lauth Sr, Seattle, WA

Herbert J Craw, Ketchikan, AK

Harry W and Kaoru K Farmer, FPO, AP

Ilene L Guthrie/Nancy H Garrett, Spokane, WA

Jack Oien, Ketchikan, AK

James F & Judith E Auger, Ketchikan, AK

James E Viall, Lewistown, ID

Jerry A Scudero, Ketchikan, AK

John and Marsha Bauer, Ketchikan, AK

John E Bruns, Craig, AK

John W and Margaret E Clark, Ketchikan, AK

John F West, Ketchikan, AK

Joseph C Williams Jr, Ketchikan, AK

Joy C Gosnell, Ketchikan, AK

Judith Ann Worden, Juneau, AK

Karen C Miles, Ketchikan, AK

Kim E Adams, Coeur D’Alene, ID

Larry M and Sarah B Gilbert, Ketchikan, AK

Leroy S Jackson, Ketchikan, AK

Lester R and Sharon B Strunk, Ketchikan, AK

Louise W Clark, Ketchikan, AK

Margaret Gilmon, Dillon, CO

M & M and G & K Moyer, Ketchikan, AK

Mark Moyer, Puyallup, WA

Mary L Dahle, Ward Cove, AK

Marvin F Williams, Ketchikan, AK

Melvin J Charles, Ketchikan, AK

Michael P Moyer, Ketchikan, AK

Michael E Vandal, Auburn, WA

Mike Cottrell, Petersburg, AK

Norbert and Diana Chaudhary, Ketchikan, AK

Paul B and Susan R Perry, Ketchikan, AK

Paula C Hill, Ketchikan, AK

Rene M Ellentuch, Spokane, WA

Randy J and Patsy Quinn, Ward Cove, AK

Richard L and Judy G Coose, Ketchikan, AK

Robert and Michele Byerly, Ketchikan, AK

Rodney O Lanham/Peter J Call, Eden, UT

Ronald C and Barbara J Galdabini, Drain, OR

Ronald Towne, Ketchikan, AK

Rosemarie Bergeron, Ketchikan, AK

S A & J K Nall, Ketchikan, AK

S N & K A Baker, Ketchikan, AK

Scott J Sullivan, Ketchikan, AK

Sean Conley, Ketchikan, AK

Sharon M Seierup, Ketchikan, AK

Theodore R Guthrie, Ketchikan, AK

The Preserve at Sheep Creek LLC, Anchorage, AK

William PC Kushnick, Ketchikan, AK

Wayne Laemmle, Umpqua, OR

Warren McReynolds, Ketchikan, AK
4 Lists and References

374  Chapter 4 – Distribution List Saddle Lakes Timber Sale Final EIS

Libraries

Librarian, Alaska State Library, Juneau, AK

Librarian, Hyder Public Library, Hyder, AK

Librarian, Ketchikan Public Library, Ketchikan, AK

Librarian, Metlakatla Centennial Library, Metlakatla, AK

Librarian, University of Alaska Southeast, Ketchikan, AK

Librarian, USDA National Agricultural Library, Beltsville, MD

Librarian, Wrangell Public Library, Wrangell, AK 

Businesses and Organizations

Alaska Forest Association, Ketchikan, AK

Alaska Hummer Adventures, Ketchikan AK

Alaska Woods Service Company, Ketchikan, AK

Alcan Timber, Ketchikan, AK

Angel Reforestation, Mt. Vernon, WA

C and R Forestry, Post Falles, ID

Carlin Air, Ketchikan, AK

Carter and Carter, Coffman Cove, AK

Cascadia Wildlands Project, Cordova, AK

Center for Biological Diversity, Staff Attorney, 

Tucson, AZ

Center for Biological Diversity, Anchorage, AK

Citizen's Advisory Commission, Fairbanks, AK

Classic Alaska Charters, Ketchikan, AK

Concerned Alaskans for Resources and 

Environment (C.A.R.E.), Ketchikan, AK

CSC Tree Services, Kake, AK

Cutting Edge Forestry, Inc., Talent, OR

Dalin Charters/Guiding, Ketchikan, AK

Director, KFMJ Radio, Ketchikan, AK

Director, KRBD Radio, Ketchikan, AK

Director, KTKN Radio, Ketchikan, AK

Earth Justice, Juneau, AK

Explore Alaska Charters, LLC, Ketchikan, AK

Farwest Research, Wrangell, AK

Forest Enhancement of the West, Sitka, AK

Forestry and Land Management, Metlakatla, AK

Frontier Timber Resources, Sagle, ID

Forest Service Employees for Environmental 

Ethics, Eugene, OR

Gonzalez Forestry, Centralia, WA

Greater Southeast Alaska Conservation 

Community, President, Sitka, AK

Greenpeace, Sitka, AK 

Greenpeace, Washington, DC

Hyder Community Association, Hyder, AK

Inner Sea Discoveries/American Safari Cruises, 

LLC, Seattle, WA

Island Wings, Ketchikan, AK

Ketchikan Chamber of Commerce, Executive 

Director, Ketchikan, AK

Ketchikan Daily News, Ketchikan

Ketchikan Homebuilders Association, Ketchikan, 

AK 

Ketchikan Outdoor Recreation, Ketchikan, AK

Ketchikan Ready Mix and Quarry, Ketchikan, AK

Ketchikan Sport and Wildlife Club, Ketchikan, AK

Director, Ketchikan Visitor Bureau, Ketchikan, AK 

Meyers Chuck Community Assn., Meyers Chuck, 

AK 

Mt. St. Helens Reforestation, Inc., Chehalis, WA 

Naha Bay Outdoor Adventures, Ketchikan, AK

Natural Resources Defense Council, Senior 

Attorney, Olympia, WA

Natural Resources Defense Council, Washington, 

DC

Primo Expeditions, Ketchikan, AK

ProForest Reforestation Partnership, Sitka, AK

Rainforest Aerial Trams, Miami, FL

Ramirez Reforestation, Chehalis, WA

Rogue Charters, Ketchikan, AK

Sealaska Timber Corporation, President, 

Ketchikan, AK

Seawind Aviation, Ketchikan, AK
Lists and References 4

Saddle Lakes Timber Sale Final EIS Distribution List - chapter 4  375

Sierra Club, Juneau, AK

Sitka Conservation Society, Conservation Director, 

Sitka, AK

Skookum Reforestation, Inc., Eugene, OR

Society of American Foresters, Chapter Chair, 

Ketchikan, AK

South Tongass Fire Department, Ketchikan, AK

Southeast Alaska Conservation Council, Juneau, 

AK 

Southeast Alaska Power Agency, CEO, Ketchikan, 

AK 

Southeast Alaska Resources, Ketchikan, AK

Southeast Aviation, Ketchikan, AK

Southern Southeast Regional Aquaculture 

Association (SSRAA), Ketchikan, AK

Summitt Forests, Inc., Ashland, OR

The Nature Conservancy in Alaska, Juneau, AK

Tongass Conservation Society, Ketchikan, AK

Valley Logging Company, Ketchikan, AK

Venture Travel DBA Taquan Air, Ketchikan, AK

Viking Lumber Company, Craig, AK

Wilderness Society, Alaska Forest Program 

Manager, Anchorage, AK

Yes Bay Lodge, Ketchikan, AK

Zaldivar's Forestry Corporation, Centralia, WA

Cities and Public Officials

Honorable Don Young, US House of 

Representatives, Anchorage, AK

Honorable Mayor, City of Ketchikan, Ketchikan, AK 

Ketchikan Gateway Borough, Borough Manager 

Ketchikan, AK

Ketchikan Gateway Borough, Coastal District 

Coordinator Ketchikan, AK

Senator Mark Begich, US Senate, Ketchikan, AK

Senator Lisa Murkowski, US Senate, Ketchikan, AK

Sen. Bert Stedman, Legislative Information Office, 

Ketchikan, AK

Rep. Peggy Wilson, Legislative Information Office, 

Wrangell, AK

Tribal IRAs and Tribal Organizations

Chairman, Aboriginal Rights Committee, Metlakatla, 

AK 

Honorable Mayor, Metlakatla Indian Community, 

Metlakatla, AK

President, Alaska Native Brotherhood Grand Camp, 

Juneau, AK

President, Alaska Native Brotherhood Camp #14, 

Ketchikan, AK

President, Alaska Native Brotherhood Camp #15, 

Ketchikan, AK

President, Alaska Native Sisterhood Grand Camp, 

Juneau, AK

President, Alaska Native Sisterhood Camp #14, 

Ketchikan, AK

President, Alaska Native Sisterhood Camp #15, 

Ketchikan, AK

President, Cape Fox Corporation, Ketchikan, AK

President, Ketchikan Indian Community, Ketchikan, 

AK 

President, Kavilco Inc., Seattle, WA

President, Kavilco Inc., Ketchikan, AK

President, Organized Village of Kasaan, Ketchikan, 

AK 

President, Organized Village of Saxman, Ketchikan, 

AK 

President, Tongass Tribe, Ketchikan, AK

President, Tlingit and Haida Community Council, 

Ketchikan, AK

President, Central Council Tlingit and Haida Indian 

Tribes of Alaska, Juneau, AK

President, Sealaska Corporation, Juneau, AK

Operations Manager, Sealaska Timber Corporation, 

Ketchikan, AK

President, Wrangell Cooperative Association, 

Wrangell, AK

Saanya Kwan - Tei Kweidi, Ketchikan, AK
4 Lists and References

376  Chapter 4 – References Saddle Lakes Timber Sale Final EIS

References Cited _______________________________________

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Appendix A

Reasons for Scheduling 

the Environmental 

Analysis of the Saddle 

Lake Project

Saddle Lakes Timber Sale Final EIS Project Reasons - Appendix A  411

Appendix A – Reasons for Scheduling the 

Environmental Analysis of the Saddle Lake Project

Introduction____________________________________________

Coordinated timber harvest project planning is essential for meeting the goals of the Tongass Land 

and Resource Management Plan (Forest Plan) and to provide an orderly flow of timber to local 

industry. To determine the volume of timber to offer each year, the Forest Service can look to current 

market conditions and the level of industry operations. However, the planning process for timber 

harvest projects requires the Forest Service to rely on projections of future harvest levels to decide 

how many timber harvest projects to begin each year. This document explains how the Forest Service 

uses information about future markets and past experience to determine the volume of timber that 

needs to be started through this process each year. This appendix relies on the current annual timber 

demand analysis and the most recent project schedule.

The purpose of this appendix is two-fold: first, to explain why this project was selected for inclusion 

into the Tongass Timber Program and second, to explain the basis and components of the Tongass 

Timber program. To accomplish this, the following questions are answered:

• How does the Saddle Lakes project fit into the Tongass Timber Program and how does the Forest

Service decide where timber harvest projects are located?

• Why is timber from the Tongass National Forest being offered?

• How does the Forest Service develop forecasts about future timber market demand?

• What steps must be completed to prepare a contract for offer?

• How does the Forest Service maintain an orderly and predictable timber program?

How Does the Saddle Lakes Project Fit into the Tongass Timber 

Program? How Does the Forest Service decide where Timber 

Harvest Projects are Located? ____________________________

This project is currently in Gate 2, Project Analysis and Design (See Forest Service Handbook 

2409.18, Chapter 30 and subsequent discussion about the Gate System) and involves environmental 

analysis and public disclosure as required by the National Environmental Policy Act (NEPA). The 

sawlog volume considered for harvest under the Alternatives ranges from an estimated 15.3 to 54.3 

MMBF of sawtimber volume and the utility Volume ranges from 1.8 to 6.4 MMBF with harvest 

potentially beginning in 2015. This volume would contribute to the Tongass timber program. A noaction alternative was also analyzed in the EIS. If an action alternative is selected in the decision for 

this project, this volume will be added to the volume available for offer. 

This project contributes to the timber program planning objective of providing an orderly flow of 

timber from planning through harvest to meet timber supply requirements. A position statement (Gate 

1) was completed to document that this project warrants additional investment of funds and

personnel. Therefore, it is reasonable to be conducting the environmental analysis for this project at 

this time. 

This project meets all laws and regulations governing the removal of timber from National Forest 

System lands, including Forest Service policies as described in Forest Service manuals and 
Appendix A

412  Appendix A – Project Reasons Saddle Lakes Timber Sale Final EIS

handbooks, and the Forest Plan and Record of Decision. Based on current year and anticipated future 

timber demand and the timber supply provisions of the Tongass Timber Reform Act, the Saddle Lakes 

project is needed at this time to meet timber volume needs identified on the approved multiple-year 

timber plan. Anticipated budget allocations and resources are sufficient to prepare and offer this 

project as scheduled.

Why is This Project Occurring in This Location? _____________

Areas are selected for environmental analysis for timber harvest projects for a variety of reasons. The 

reasons this project was considered in this area include:

• The project area offers economic timber that could contribute to local demand.

• The project area includes a developed road system that provides access to many of the proposed

timber harvest units and may be used to transport harvested logs. The existing MAFs at Shelter

Cove and Leask Cove could be used.

• The project area is on the 8300000 road system, about 14 miles northeast of Ketchikan, AK and

would help support direct and indirect employment through the supply of personnel, goods and

services.

• The Saddle Lakes project area contains sufficient acres of suitable and available forest land to

make this timber harvest proposal reasonable. Areas with available timber need to be considered

for harvest in order to provide a supply of timber from the Tongass National Forest which (1)

seeks to meet the annual market demand from such forest, and (2) seeks to meet the market

demand from such forest for each planning cycle, pursuant to Section 101 of the Tongass Timber

Reform Act (TTRA).

• The proposed harvest units are within development land use designations (LUD) as allocated by

the Forest Plan.

• Effects on subsistence resources from timber harvest are projected to have few differences based

on the sequence in which areas are harvested. Harvesting other areas with available timber on the

Tongass National Forest is expected to have similar potential effects on resources, including

subsistence resources, because of widespread distribution of subsistence use and other factors.

Harvest within other areas is foreseeable under the Forest Plan.

In conclusion, this project area can provide a mixture of uses in compliance with the laws that govern 

National Forest management and is consistent with direction in the Forest Plan. 

Why is Timber Volume from the Tongass National Forest Being 

Offered? ______________________________________________

National Legislation

On a national level, the legislative record is clear about the role of the timber program in the multipleuse mandate of the national forests. One of the original objectives for creation of national forests was 

to provide natural resources, including timber, for the American public. The Organic Administration 

Act of 1897 (partially repealed in 1976) directed the agency to manage the forests in order to 

"improve and protect the forest ... [and] for the purpose of securing favorable conditions of water 

flows, and to furnish a continuous supply of timber for the use and necessities of the citizens of the 

United States" (emphasis added). The Multiple-Use Sustained Yield Act of 1960 directs the Forest 

Service to administer federal lands for “outdoor recreation, range, timber, watershed, and wildlife and 

fish purposes.” 
Appendix A

Saddle Lakes Timber Sale Final EIS Project Reasons - Appendix A  413

The National Forest Management Act (NFMA) of 1976 states that “the Secretary of Agriculture...may 

sell, at not less than appraised value, trees, portions of trees, or forest products located on National 

Forest System Lands.” Although the heart of the Act is the land management planning process for 

national forests, the Act also sets policy direction for timber management and public participation in 

Forest Service decision making. Under NFMA, the Forest Service was directed to “limit the sale of 

timber from each national forest to a quantity equal to or less than a quantity which can be removed 

from such forest annually in perpetuity on a sustained-yield basis.” 

The NFMA directs the Forest Service to complete land management plans for all units of the National 

Forest System. Forest plans are developed by an interdisciplinary team to provide for the coordination 

of outdoor recreation, range, timber, watershed, wildlife and fish, and wilderness. Forest plans 

designate areas of national forest where different management activities and uses are considered 

appropriate, including those areas suitable for timber harvest.

Alaska-Specific Legislation

Timber volume from the Tongass National Forest is being offered as part of the multiple-use mission 

of the Forest Service identified in the public laws guiding the agency. In addition, Alaska-specific 

legislation and the Tongass Forest Plan direct the Forest Service to provide timber so as to seek to 

meet market demand, subject to certain limitations.

The Alaska National Interest Lands Conservation Act (ANILCA) and the Tongass Timber Reform Act 

(TTRA) provide direction on the issue of Tongass timber supply. TTRA, Section 101 deleted 

ANILCA, Section 705 (a), which mandated a fixed timber supply and fixed budget appropriations, 

and inserted the following : 

Sec. 705 (a) Subject to appropriations, other applicable law, and the requirements of the 

National Forest Management Act of 1976 (P.L. 94-588); except as provided in subsection (d) 

of this section, 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.

Tongass National Forest Land and Resource Management Plan (Forest Plan, 

as amended)

The Tongass Land and Resource Management Plan (Forest Plan), as amended, guides all natural 

resource management activities and establishes management standards and guidelines for the 

Tongass. It describes resource management practices, levels of resource production and management, 

and the availability and suitability of lands for different kinds of resource management. This Forest 

Plan embodies the provisions of the National Forest Management Act, the implementing regulations, 

and other guiding documents. The multiple-use goals and objectives, and the land use prescriptions 

and standards and guidelines, constitute a statement of the Forest Plan's management direction.

The Forest Plan was completed in 1979 and revised in 1997. The Record of Decision (ROD) for the 

2008 Forest Plan Amendment was signed by the Alaska Regional Forester on January 23, 2008. The 

Forest Plan incorporates new resource information and scientific studies and reflects an extensive 

public involvement process. The Forest Plan defines appropriate activities within each of 19 land use 

designations (LUDs). Approximately 79 percent of the Tongass is allocated to LUDs where scheduled 

commercial timber harvest is not allowed (See subsequent discussion about How the Forest Service 

Decides Where Timber Harvest Projects Should Be Located). 
Appendix A

414  Appendix A – Project Reasons Saddle Lakes Timber Sale Final EIS

The decision for the 2008 Forest Plan establishes the annual average Allowable Sale Quantity (ASQ) 

the maximum amount of timber that may be offered) at 267 million board feet (MMBF). This is the 

same as the ASQ established for the previous Forest Plan in 1997. While technically a limit on 

volume, in effect the ASQ also limits the amount of timber that may be harvested on the Tongass. 

The environmental effects analysis in the Final EIS for the 2008 Forest Plan assumed the maximum 

timber harvest allowed under each alternative would occur annually over the next 100 to 150 years. In 

that way, the Forest Plan analysis displayed the maximum environmental effects that could be 

reasonably foreseen. However, substantially less timber volume and acres have actually been 

harvested over the last several years than the maximum level allowed under the 1997 Forest Plan (See 

Figure 20). Thus, the effects on resources are expected to be less than projected in the 2008 Forest 

Plan Amendment Final EIS.

Figure 20. Tongass timber harvest, fiscal years 2001 to 2014 

The Record of Decision for the 2008 Forest Plan Amendment includes transition language for 

projects that were being planned when the Forest Plan was completed. That language identifies three 

different categories of projects, depending on how far along they were in the project planning process 

when the Forest Plan Amendment was completed, and specifies the extent to which projects in each 

category must comply with the amended Forest Plan. The transition language lists the Saddle Lakes 

project as being in Category 3, which requires the Forest Supervisor to incorporate the direction in the 

2008 Forest Plan. 

USDA Investment Strategy for Creating Jobs and Healthy Communities in 

Southeast Alaska

After consecutive decades of population loss, the Southeast region and its 32 communities have 

experienced some population stabilization in recent years. However, socioeconomic community 

conditions remain tenuous with declining school enrollments, high energy costs, and limited job 

opportunities in many rural communities. 

USDA agencies (Farm Service Agency, Forest Service, and Rural Development) and the U.S. 

Economic Development Administration (USEDA) have partnered to support community 

revitalization through investment in economic development planning, restoration-based job creation, 

and community capacity building. USDA investment strategy goals include: 

• creating quality jobs and sustainable economic growth;

• promoting small business creation, expansion, and retention;
Appendix A

Saddle Lakes Timber Sale Final EIS Project Reasons - Appendix A  415

• improving access to capital; and

• promoting job training and educational opportunities.

To do this, USDA agencies collaborated with local business and community leaders to implement an 

industry cluster-based approach to economic development – the Southeast Alaska Cluster Initiative. 

Over the past five years (2010 – 2015), the USDA invested $1,030,000 in the Southeast Alaska 

Cluster Initiative via Forest Service (89 percent) and Rural Development (14 percent) agencies. June 

2015 marks a significant milestone for the Southeast Cluster Initiative project as it signifies nearly 

five years of USDA investment in implementing a strategic approach to regional economic 

development including economic research, asset mapping, cluster work group facilitation, and consult 

regarding regional economic development opportunities. 

Addressing Sustainable Forestry in Southeast Alaska

The timber industry’s long term survival in Southeast Alaska requires a transition from a dependence 

on old-growth timber to a program that is primarily supported by young growth. The goal is to 

transition from the dependence on harvest of old-growth forest to young growth forest management in 

a manner that allows the timber industry to adapt to these changed conditions to provide jobs and 

economic support for the communities of Southeast Alaska. 

Transition to Young Growth Timber

On July 2, 2013, the Secretary of Agriculture issued Memorandum 1044-009 (Addressing Sustainable 

Forestry in Southeast Alaska) to support the transition away from old-growth timber harvesting 

towards a forest industry based on the utilization of young growth timber. The memorandum states 

that “To conserve the Tongass National Forest under the principles of the Multiple-Use SustainedYield Act of 1960, Tongass Timber Reform Act and other relevant statutes, we must speed the 

transition away from old-growth timber harvesting and towards a forest industry that utilizes second 

growth – or young growth – forests. Moreover, we must do this in a way that preserves a viable 

timber industry that provides jobs and opportunities for residents of Southeast Alaska.” 

Retaining the existing industry is critical to this approach, therefore the transition to young growth

will be managed at a pace that allows operators to adjust, adapt, and develop markets for new 

products. The maintenance of the timber industry in Southeast Alaska will contribute to the diversity 

of the economy with the on-going development of other economic sectors such as tourism, recreation, 

fishing and mariculture and renewable energy. 

The long-term goal is that the majority of active forest management on the Tongass will be 

comprised of ecological restoration, young growth forest management, small and microsale oldgrowth timber sales and pre-commercial thinning. These projects would in turn supply local and 

regional wood products markets. 

Old-growth “Bridge Timber”

Pursuant to the Secretary’s memorandum, the Forest Service is asked to seek opportunities to supply 

sufficient old growth “bridge timber” while the industry retools for processing young growth. To 

achieve this, a supply of old growth will continue to be offered while commercial young growth 

timber processing and marketing opportunities are explored and developed. This will help maintain 

the existing workforce and retain local knowledge and experience as businesses retool toward 

smaller-diameter wood utilization. 
Appendix A

416  Appendix A – Project Reasons Saddle Lakes Timber Sale Final EIS

The amount of old-growth “bridge timber” harvested will decrease as more young-growth timber 

becomes economically viable to harvest. The duration and scale at which old-growth “bridge timber” 

will be needed is unclear. Factors such as the role of State and private land in contributing wood 

supply to a viable industry; the availability of suitable young growth that is mature and economic to 

harvest; export and domestic processing policies; and fluctuations in domestic and world markets for 

forest products must be considered, are unpredictable, and will influence the timeframe for transition. 

5-Year Tongass Integrated Plan

The 5-Year Tongass Integrated Plan (TIP) provides a transition pathway to an increased availability of 

young growth timber as well as a reliable supply of old-growth “bridge timber” for the mills in 

Southeast Alaska. 

The TIP is a schedule of integrated forest management activities derived from individual schedules 

for timber sales, watershed restoration and habitat improvement, and road decommissioning and 

maintenance. This integrated plan incorporates community and collaborative input and priorities; 

aligning planning staff and budgets to increase efficiencies and effectiveness at the district and project

level; integrating multiple programmatic activities in larger landscapes; and adding increasing 

volumes of young growth timber. The TIP creates immediate opportunities for a range of forest 

products and services, such as old and young growth timber harvest, biomass, or instream restoration 

work. The TIP also utilizes the existing industry and workforce capacity and provides a stable and 

consistent program of work to encourage new business investment. 

Projects on the TIP represent a best estimate about the range of active forest management 

opportunities across the Tongass. Declining budgets and unpredictable markets will likely make it 

difficult to implement every project as currently planned.

The TIP is one of several components of the “Transition Framework,” the effort by several USDA 

entities to explore and support economic diversification and job creation in Southeast Alaska. This 

plan is a key piece of the Framework with regards to the forestry and restoration, for two main 

reasons: 1) it maintains current infrastructure in Southeast Alaska and therefore jobs, and 2) uses that 

infrastructure as a springboard to diversify the forestry sector, creating even more jobs.

The Saddle Lake project, which is scheduled to be offered in 2015, provides some of this old-growth 

timber that can be used to bridge industry’s needs during the transition to young-growth management. 

How Does the Forest Service Develop Forecasts about Future 

Timber Market Demand? _________________________________ 

Consistent with the provisions of the Tongass Timber Reform Act, the Forest Service makes two types 

of forecasts of market demand for timber from the Tongass National Forest. The first, “planning cycle 

market demand,” forecasts the long-term demand for timber from the Tongass over the life of the 

Forest Plan, derived from trends in international demand for end products manufactured from such 

timber. Based on these long-term projections, the Forest Service also estimates annual market demand 

in order to determine how much timber to plan to offer. 

Market Demand for the Planning Cycle

Research economists with the Forest Service’s Pacific Northwest (PNW) Research Station have 

prepared several studies of “planning cycle market demand” for Tongass timber, including three 

General Technical Reports by Brooks and Haynes (1990, 1994, and 1997). In 2006, the PNW 

Research Station published new harvest projections (Brackley et al. 2006). This report and an 
Appendix A

Saddle Lakes Timber Sale Final EIS Project Reasons - Appendix A  417

addendum to it (Brackley and Haynes, 2008) provided key information for the 2008 Forest Plan 

Amendment analysis.

The Brackley et al. 2006 projections include four scenarios: 1) limited lumber production, which 

represents the situation the timber industry in Southeast Alaska has faced over the last several years; 

2) expanded lumber production, which assumes some form of demand stimulus occurs; 3) medium

integrated industry, which assumes sufficient demand stimulus occurs to cause an expansion of the 

current industry capacity and better utilization of forest products removed from public timber 

contracts; and 4) high integrated industry, assumes some kind of additional demand stimulation to 

result in full utilization of all types of forest products available from the Tongass. More detailed 

information about these scenarios and their assumptions is in the Forest Plan Amendment Final EIS 

and ROD (January 2008), and in Brackley and Haynes, 2008. 

The Brackley et al. 2006 study displays alternative projections of derived demand for timber from the 

Tongass National Forest. For the first two scenarios, which assume no market for low-grade sawlogs 

and utility volume, the estimates of planning cycle demand include sawtimber only. For the two 

integrated industry scenarios, the projections include total volume, including both sawlogs and utility. 

All scenarios include timber with a wide range of diameters and ages. Utility volume must be cut 

down along with higher-quality timber even if there is no demand for it. It is the total volume of 

timber cut on the Tongass that is of most interest, in part because environmental effects result from 

total volume cut. In addition, any comparison of scenarios must be based on comparable figures. 

Table 112 shows annualized Brackley et al 2006 projections for all four scenarios in terms of total 

Volume.

Table 112. Tongass National Forest timber volume necessary to supply derived demand for decked log 

volume and chips, in million board feet (MMBF) (Alexander 2008)1/

Year Scenario 1

Limited lumber

Scenario 2 

Expanded lumber

Scenario 3

Medium integrated

Scenario 4 High

integrated

2007 49.8 61.9 67 67

2008 49.8 66.4 139 139

2009 51.3 72.4 151 151

2010 52.8 78.5 166 166

2011 52.8 84.5 184 184

2012 54.3 90.5 204 286

2013 55.8 98.1 204 291

2014 57.3 105.6 204 295

2015 58.9 113.2 204 299

2016 58.9 122.2 204 303

2017 60.4 131.3 204 308

2018 61.9 140.3 204 312

2019 63.4 150.1 204 317

2020 64.9 163.0 204 325

2021 66.4 175.0 204 333

2022 67.9 187.1 204 342

2023 69.4 200.7 204 351

2024 70.9 215.8 204 360

2025 72.4 230.9 204 370

1/ Annualized calculation to fulfill derived demand scenarios from Brackley et al. (2006). This table was created using 

annualized values provided by Dr. Allen Brackley (personal communication, Nov 29 2006) from the model used to develop 

derived demand estimates in Brackley et al. (2006). The values for Limited Lumber Scenario and Expanded Lumber scenarios 

reported in this table have been adjusted to include low quality material not included in the demand projections and include 

saw logs, cedar export, and utility (chip) volumes available from sawmill production. The Medium and High Integrated 

Scenarios are not adjusted and include saw logs, cedar exports, chip volumes, low-grade material, and utility in Brackley et al. 

(2006).
Appendix A

418  Appendix A – Project Reasons Saddle Lakes Timber Sale Final EIS

Annual Market Demand 

The annual market demand forecast is a methodology used to set the short-term goals for the Tongass 

Timber Program – volume the Forest plans to offer in the current year, pending sufficient funding and 

sufficient NEPA-cleared volume.

The formulas and procedures used in forecasting annual market demand are described in a Forest 

Service report titled Responding to the Market Demand for Tongass Timber (Morse, 2000). These 

procedures, which have become known as the “Morse methodology,” are based on the premise that: 

• Forest product markets are volatile, especially in the short run.

• Timber purchasers in Southeast Alaska have few alternative suppliers of timber if they cannot

obtain it from the Tongass National Forest. Oversupplying this market has relatively few adverse

economic effects; undersupplying it can have much greater negative economic consequences.

• It takes years to prepare National Forest timber for sale, including completion of environmental

impact statements.

• It is difficult to estimate demand for timber from the Tongass, even a year or two in advance.

• Industry must be able to respond to rapidly changing market conditions in order to remain

competitive.

Accordingly, the Morse methodology establishes a system that considers factors such as mill capacity 

and utilization of that capacity, and seeks to build and maintain sufficient volume of timber under 

contract (i.e., timber purchased but not yet harvested) to allow the industry to react promptly to 

market fluctuations. Industry actions such as annual harvest levels are monitored and timber program 

targets are developed by estimating the amount of timber needed to replace volume harvested from 

year to year. The methodology is adaptive, because if harvest level drop below expectations and other 

factors remain constant, future timber offerings would also be reduced to levels needed to maintain 

the target level of volume under contract. Conversely, if harvest levels increase unexpectedly, future 

timber volume targets would also need to increase sufficiently to ensure that the inventory of volume 

under contract is not exhausted. By dealing with uncertainty in a flexible, science-based fashion, the 

Morse methodology is an example of adaptive management.

The Morse methodology originally used the projected harvest from the final 1997 Brooks and Haynes 

report. These procedures were updated (Alexander, 2008) to use the annual projected harvest figures 

from Brackley et al. 2006 in calculations of annual timber offer targets. No further changes to the 

Morse methodology were required as a result of the updated long-term demand projections contained 

in the Brackley et al. study.

In 2008, due to the Region 10 shipment policy, the Ketchikan veneer mill, and the success of Alaska 

producers in niche or specially markets, Brackley et al. 2008 determined that demand for National 

Forest timber in Alaska was on a trajectory most similar to scenario 2 (expanded lumber production). 

In 2011, due to the sharp downturn in wood products markets, the ‘Limited Lumber’ scenario was 

used. However, due to the export policy and good overseas markets, this projection is back to being 

based on the ‘Expanded Lumber, Scenario 2. 

For FY 2014, the goal for volume of timber to be offered is 142 MMBF. This number is not intended 

to represent actual timber purchases in any given year. Rather, it reflects the estimated volume of 

timber the Forest Service needs to offer to replace the volume expected to be harvested and help build 

a 2 to 3 year supply of timber under contract, which allows the industry to respond to market 

fluctuations. The actual volume of timber offered in any given year, however, reflects a combination 
Appendix A

Saddle Lakes Timber Sale Final EIS Project Reasons - Appendix A  419

of factors, such as final budget appropriations; completing the NEPA process; the practice of 

offering smaller sales for smaller operators rather than all the volume from a NEPA decision; the 

statutory requirement that timber sales offered in the Alaska Region appraise positive; and volume 

affected by litigation. Due to these factors, the amount of timber that is offered and sold may be less 

than the expected timber purchases as predicted in the annual demand calculations. The document 

displaying the annual demand calculation and a summary of the factors used in these calculations 

are in the project record and on the Alaska Region public website (http://www.fs.usda.gov/Internet/

FSE_DOCUMENTS/stelprdb5447816.pdf).

The planned annual timber volume offer could include a combination of new, previously offered, 

and reconfigured timber sales. Both green timber and salvage sales will be components of this 

program. Offerings will consist of those targeted for Small Business qualified firms, as well as a 

portion of the volume being made available for the open market. 

For planning and scheduling purposes, the Tongass uses a 5-year timber sale plan, which is consistent 

with Forest Service Manual 2430. This 5-year plan is based on completed and ongoing environmental 

analyses and contains information to purchasers and other interested parties, and provides a plan that 

can be adjusted in response to changing market conditions. This plan is also located on the Alaska 

Region timber management public website after it is approved by the Forest Supervisor 

(http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprd3795232.pdf ). 

Both the “annual market demand” and the “planning cycle market demand” projections are 

important for timber program planning purposes. They provide guidance to the Forest Service to 

request budgets, to make decisions about workforce and facilities, and to indicate the need to begin 

new environmental analysis for future program offerings. They also provide a basis for expectations 

regarding future harvest, and are an important source of information for establishing the schedule of 

probable future offerings. The weight given to the projections will vary depending on a number of 

factors, such as how recently they were done and how well they appear to have accounted for recent, 

site-specific events in the timber market. More information on timber demand on the Tongass 

National Forest is presented in Appendix G of the Forest Plan Amendment Final EIS (USDA Forest 

Service 2008c). 

What Steps Must Be Completed to Prepare a Timber Volume

Contract for Offer? _____________________________________ 

The Tongass National Forest’s timber program is complex. A number of projects are underway at 

any given point in time, each of which may be in a different stage of planning and preparation. A 

system of checkpoints, or “gates”, helps the Forest Service track the accomplishments of each stage 

of a project from inception to contract termination (See Forest Service Handbook 2409.18 – Timber 

Sale Preparation). 

Gate 1 – Initial Planning of Timber Harvest Project

A timber sale project plan, often referred to as a position statement, is a brief analysis of the project 

area with the intent of determining the feasibility of a potential timber sale. After the position 

statement is developed, the Forest Service decides whether the project area merits continued 

investment of time and funds for completion (see Forest Service Handbook 2409.18, Chapter 20). 

Gate 2 – Project Analysis, Design and Decision 

This stage is commonly referred to as the “NEPA” phase and includes field work, public scoping, 

analysis, draft disclosure of the effects of the project on the environment, public comment, final 

analysis and disclosure, decision, and potentially administrative appeals and litigation. Gate 2
Appendix A

420  Appendix A – Project Reasons Saddle Lakes Timber Sale Final EIS

 activities must be completed before a contract is awarded. Legislation, policy changes, and appeals 

and litigation have recently extended completion of some projects, often doubling the desired time 

frame (see Forest Service Handbook 2409.18, Chapter 30). 

Gate 3 – Sale Plan Implementation and Appraisal (Preparation of a Timber

Harvest Contract) 

During this stage, the sale plan information and direction included in the decision document from 

Gate 2 is used to layout units and design roads on the ground. This step includes a timber sale 

appraisal that initiates Gate 4. Additional site-specific information is collected at this time. In order to 

maintain an orderly flow of timber volume, Gate 3 activities need to be complete before a contract is 

offered for bid (see Forest Service Handbook 2409.18, Chapter 40). 

Gate 4 – Final Package Preparation, Review, Appraisal, and Offering (Advertise 

a Contract) 

The costs and value associated with the timber volume designed in Gate 3 are appraised and packaged

in a contract. The contract is a legally binding document that tells a prospective contractor how the 

timber must be harvested to conform to the project decision document. This step occurs during the 

final year of the project development and culminates with the advertisement of the

project for sale (see Forest Service Handbook 2409.18, Chapter 50).

Gate 5 – Bid Opening 

Gate 5 is completed with the opening of bids for the project. If a bid is submitted, contractual 

provisions govern when the award of the contract takes place, the contract length and operation 

season, and how timber removal is to occur (see Forest Service Handbook 2409.18, Chapter 60).

Gate 6 – Award a Contract 

Gate 6 is the formal designation of a contract between a bidder and the Forest Service (see Forest 

Service Handbook 2409.18, Chapter 70). 

How Does the Forest Service Maintain an Orderly and Predictable 

Timber Program? _______________________________________

Pools of Timber (Pipeline Volume) 

As discussed earlier, the Forest Service tracks the accomplishment of the different steps of 

development of each timber harvest contract with the Gate System. From a timber program 

standpoint, it is also necessary to track and manage multiple projects as they move through the Gate 

System. Because of the timeframes needed to accomplish a given timber harvest project and the 

complexities inherent in that project and program development, it is necessary to track various 

timber program volumes from Gate 1 through Gate 6. 

The goal of the Tongass National Forest timber program is to provide an even flow of timber 

offerings on a sustained-yield basis to seek to meet market demand. In recent years, this has been 

difficult to accomplish due to a combination of uncertainties such as delays related to appeals and 

litigation; changing economic factors, such as rapid market fluctuations; and industry-related 

factors, such as changes in timber industry processing capabilities. To achieve an even flow of 

timber volume offerings, ‘pools’ of volume in various stages of the Gate System are maintained so 

volume offered can be balanced against current year demand and market cycle projections. 

Today, upward trends in demand are resolved by moving out-year timber projects forward, which 

may leave later years not capable of meeting the needs of the industry. In other instances, a number
Appendix A 

Saddle Lakes Timber Sale Final EIS Project Reasons - Appendix A  421

of new projects are started based on today’s market but will not be available for a number of years. 

By the time the added projects are ready for offer, the market and demand for this volume may have 

changed. Three pools of timber volume are tracked to achieve an even flow of timber harvest 

offerings. 

The objective of the timber pools concept is to maintain sufficient volume in preparation and under 

contract to be able to respond to yearly fluctuations in a timely manner. Table 113 displays the 

current estimated volume in each pool, as well as the goal which the Tongass has established for 

the volume to be maintained in each pool, based on historic patterns. Appeals and litigation can 

cause timber harvest projects to be reevaluated, which can cause delays in making projects 

available to move through the pools, thereby not fully meeting the goals for volumes in each pool. 

Pool 1 - Timber Volume under Analysis (Gate 1 and Gate 2) 

Volume in Gate 1, the initial planning step, represents a large amount of volume, but represents a 

relatively low investment in each project. This relatively low investment level offers the timber 

program manager a higher degree of flexibility and thus, does not greatly influence the flow of 

volume through the pipeline. A signed Project Plan (FSH 2409.18, Chapter 20) is the completion 

of this gate. Areas being considered at this time are Alder Creek, Sitkoh-False Island, Neck Lake, 

Portage Bay, Kuiu Island, Twelvemile Arm, Shrimp Bay, Polk Inlet, Thomas Bay, Frosty Bay, and 

Zarembo Island. The amount of the volume identified during this stage is subject to change during 

the Gate 2 analysis. 

Gate 2, timber volume under environmental analysis as directed by the National Environmental 

Policy Act (NEPA), includes projects being analyzed and undergoing public comment through the 

NEPA process. This pool includes any project that has started the scoping process through those 

projects ready to have a decision issued. In addition, tracking how much volume is involved in 

appeals or litigation may be necessary to determine possible effects on the flow of potential timber 

projects. A signed NEPA decision (FSH 2409.18, Chapter 30) is the completion of this gate unless 

the project is subsequently appealed and/or litigated. Volume affected by appeals and litigation is 

tracked as a subset of this pool (Table 114). Project areas under analysis at this time, in addition to 

this project, are Wrangell Island and Kosciusko Island. 

Based on historic patterns, the Tongass has established a goal for the pipeline volume to be 

maintained in each of the timber pools. The goal for Pool 1 is to be maintained at approximately 4.5 

times the amount of the projected harvest to account for projects at various stages of analysis. That 

goal reflects a number of factors which can lead to a decrease in volume available, such as a decision 

in Gate 1 to drop further analysis in a particular planning area (called the “no go” decision), a 

falldown in estimated volume between Gate 1 and Gate 2, and volume not available for harvest due 

to appeals or litigation. 

Pool 2 - Timber Volume Available for Offer (Gates 3, 4, and 5) 

Timber volume available for offer includes projects for which environmental analysis has been 

completed, and have had any administrative appeals and litigation resolved. Timber in this pool can 

include a combination of new offers, previously offered unsold contracts, and remaining volume 

from cancelled contracts. The goal is to maintain Pool 2 at approximately 1.3 times the amount of 

the projected harvest to allow flexibility in offering contracts. 
Appendix A

422  Appendix A – Project Reasons Saddle Lakes Timber Sale Final EIS

Pool 3 - Timber Volume under Contract (Gate 6)

Timber volume under contract contains the volume that has been sold and a contract awarded to a 

purchaser, but which have not yet been fully harvested. Contract length is based on the amount of 

timber in the contract, the current timber demand, and the accessibility of the area for mobilization. 

The longer the contract period, the more flexibility the operator has to remove the timber based on 

market fluctuations. Timber contracts typically give the purchaser 3 years to harvest initially and 

remove the timber purchased; however, the timeframes can be extended under certain circumstances, 

such as inoperable periods of weather, injunctions, and other contractual delays. 

The size of timber sale contracts are based on the needs of Tongass-wide sawmills. The goal is to 

match sale sizes to the needs of potential bidders in the area of interest while providing for costefficient operations (Forest Service Manual 2431.13). The Forest Service will plan sale offerings to 

encourage competitive bidding in a range of sizes and species that provides opportunities for 

businesses in Southeast Alaska.

The amount of volume to be offered as small sales is based on a determination of the need of mills in 

the vicinity of the project area. Also taken into consideration is the amount of volume under contract. 

Small volume contracts are generally offered in situations where: 1) the project is designed to be 

specifically allocated to small operators; 2) an allocation of volume for small offers has made during 

the decision or during informal appeal or/ objection resolution meetings; and 3) the harvest is within 

Phase 2 lands as determined by the Forest Plan. 

The Pool 2 timber volume for sale (Table A-2) does not identify that volume which, through a 

decision by the Responsible Official, is slated only for small sales because this volume is metered out 

and not all available in the current year (even though it has gone through Gate 2). The average 

volume under contract for small sales for fiscal years 2005 through 2014 was approximately 19 

MMBF, with a range of about 13 to 24 MMBF of volume under contract annually. The average 

volume harvested by small mills during this same period was approximately 11 MMBF, with a range 

of about 6 to 17 MMBF harvested annually.

Delays at Gate 2 have affected preparation (Gate 3) and have made scheduling of offers uncertain. At 

Gate 4, contracts have been fully prepared and appraised, and are available to managers to advertise 

for bid. This allows potential purchasers an opportunity to do their own evaluations of these offerings 

to determine whether to bid, and if so, at what level.

The Tongass attempts to maintain roughly 3 years of remaining volume under contract to the 

industry as a whole. This volume of timber is the industry’s dependable timber supply, which 

allows adaptability for business decisions. This practice is not limited to the Alaska Region, but is 

particularly pertinent to Alaska because of the nature of the land base. The relative absence of 

roads, the island geography, the steep terrain, and the consequent isolation of much of the timber 

land means that timber purchasers need longer-than-average lead times to plan operations, stage 

equipment, set up camps, and construct roads prior to beginning harvest.

A combination of projected harvest and projected demand is used to estimate the volume needed to 

maintain an even-flow timber program. As purchasers harvest timber, they deplete the volume under 

contract. Timber harvest is then planned and offered to give the industry the opportunity to replace 

Enough volume in this pool is needed to be maintained to be able to schedule future offerings of the 

size and configuration that best meets market needs in an orderly manner. Although projects may 

meet the above criteria, contracts may not be offered if the volume appraises deficit or if changed 

circumstances would affect the ability to offer them. Whether an offering appraises deficit may 

change over time depending on the market and other factors. Also, some projects are either designed 

for small sales, or otherwise slated for small sales, as part of the decision or as part of an informal 

appeal resolution.
Appendix A

Saddle Lakes Timber Sale Final EIS Project Reasons - Appendix A  423

How Appeals and Litigation Affect the Tongass Timber Program

Timber harvest projects require site-specific environmental analysis that usually is documented in 

an Environmental Assessment (EA) or an Environmental Impact Statement (EIS). The public is 

notified of the analysis and is provided the opportunity to comment on proposals. 

The Saddle Lakes project will go through the predecisional objections process (36 CFR 218), which 

became effective March 27, 2013; instead of the appeals process (36 CFR 215). As before, when a 

decision completes the applicable administrative review processes, the project can still be litigated. 

Although litigation does not always preclude offering timber volume, the Forest Service and 

potential purchasers are often reluctant to enter into a contract where the outcome is uncertain. 

Since litigation can be a lengthy process, litigation can also affect the Forest’s ability to provide a 

reliable timber supply. With an unfavorable decision, the court may vacate the project’s decision 

requiring more environmental analysis to occur. 

Table 114. Timber Volume involved in appeals, objections and/or litigation1/

Timber Volume with decision reversed on appeals2/ 13.1 MMBF

Timber Volume involved with current litigation 258.4 MMBF

1/ As of 2/2/2015. 

2/ Decision overturned during internal review. Does not include timber volume currently under objection review.

Table 113. Accomplishments in gate system and timber pools (MMBF)

Pipeline Pool Volume FY 2014 Goal June 2015 

Pool 1 Volume Under Analysis (Gate 2) 6391/ 102 to 266 2/

Pool 2 Volume Available for Offer (Gate 3, Gate 4 and Gate 5) 1853/ 105 4/

Pool 3 Volume Under Contract (Gate 6) 4265/ 104 6/

1/ The goal for volume under analysis is approximately 4.5 times the projected harvest for the current year (based on 142 

MMBF for the 2014 timber demand).

2/ Volume under analysis includes all timber volume in projects with a completed project plan (Gate 1) through completion 

of the environmental analysis (Gate 2). This figure includes about 52 to 55 MMBF of young-growth timber. A range is shown 

to display the range of volume for the alternatives for the on-going projects.

3/ The goal for volume available for offer is to have at least 1.3 times the projected harvest for the current year (based on 

142 MMBF in projects that have approved NEPA and completion of timber contract preparation).

4/ This only includes the volume that is available to offer which needs to have gone through the NEPA process and appraises 

positive. This figure does include volume involved with on-going litigation – see Table A3. It does not include that volume slated 

only for small sales. 

5/ The goal for volume under contract is for purchasers to have three times the volume under contract (based on 142 MMBF). 

6/ Estimated volume under contract available for harvest as of June 2015 not including settlement contracts and those 

contracts which are in the process of being terminated. (Source: USDA Forest Service Alaska Region public website).

this volume and build or maintain their working inventory. Although there will be variation for 

practical reasons from year to year, in the long-run over both the high points and low points of the 

market cycle, the volume harvested should equal the timber volume sold. The goal for Pool 3, 

volume under contract, is to maintain timber volume at approximately three times the amount of 

annual projected harvest. This allows the purchasers to have a continuous supply of timber volume 

available for harvest so they can plan their operations and be flexible to allow for weather conditions 

and market fluctuations.
Appendix A

424  Appendix A – Project Reasons Saddle Lakes Timber Sale Final EIS

Figure 21. Tongass National Forest suitability analysis 

Non-Forest land – Land that has never supported forests, e.g. muskeg, rock and ice. 

Withdrawn Forested Lands – Lands designated by Congress, the Secretary of Agriculture, or Chief for purposes that preclude 

timber harvest, e.g. Wilderness Areas. 

Non-productive Forest – Forest land not capable of producing commercial wood on a sustained yield basis. 

Productive Forest – Forest land that meets all the criteria for timber production suitability over the planning horizon. 

How Does The Forest Service Decide Where Timber Harvest 

Projects Should Be Located?

The process for determining the suitability of the land for timber harvest is found in the 2008 Forest 

Plan, Appendix A. 

Land Suitability for Timber Harvest 

A primary consideration for selecting lands for timber harvest is the suitability of the land for 

timber production. Many acres on the Tongass National Forest are not forested. Of the forested 

lands, some of this land has been withdrawn by Congress for further consideration for resource 

management. On the Tongass National Forest, these lands include wilderness and national 

monuments. Other forested lands are not physically suitable for timber production due to non-forest 

vegetation, poor soils or steep slopes as determined by NFMA. These nonproductive forested lands 

and non-forested lands provide other uses such as wildlife habitat for some species and various 

recreation uses. Figure 21 depicts the percentages of these categories of lands within the Tongass 

National Forest. 
Appendix A

Saddle Lakes Timber Sale Final EIS Project Reasons - Appendix A  425

District Rangers develop a multi-year plan of potential timber harvest projects. The goal of the plan 

is to attain the targeted offer level for the current year, based on the estimated annual market demand, 

and to develop a timber program for several years of the planning cycle. The offer level for the 

current year is based, to the extent possible, on the forecasted annual market demand. Actual demand 

may fluctuate from year to year due to short-term market fluctuations. Actual offer levels vary year 

to year depending on several factors, including volume in Gates 2 through 3, and current market 

conditions. 

District personnel work on various timber harvest projects at different stages simultaneously, 

resulting in continual movement of these projects through the timber program pipeline. The District 

Ranger is responsible for identifying and recommending to the Forest Supervisor the project areas for 

the 5-year schedule of integrated resource activities. This schedule factors in the time to complete 

preliminary analysis, resource inventories, environmental documentation, field layout preparations 

and permit acquisition, appraisal of timber resource values, advertisement of contract characteristics 

for potential bidders, bid opening, and physical award of the contract. Once all of the Rangers’ 

recommendations are made and compiled into a consolidated schedule, the Forest Supervisor is 

responsible for the review and approval of the final timber harvest plan and prioritization of projects 

as necessary. 

Considerations the District Ranger takes into account for each project include: 

• If the project area contains a sufficient number of suitable timber production acres allocated to

development land use designations. Consideration includes if the timber volume being considered

for harvest can be achieved while meeting Forest Plan goals, objectives, and Standards and

Guidelines.

• Other resource uses and potential future uses of the area and of adjacent areas and of

non-National Forest System lands.

• Areas where the investment necessary for project infrastructure (roads, bridges, etc.) is achievable

with the estimated value of timber volume in the project area. Where infrastructure already exists,

such as the Saddle Lakes project area, the contract would allow any maintenance and upgrade of

the facilities necessary for removal of timber volume.

• Areas where investments for the project coincide with long-term management based on Forest

Plan direction.

District-level Planning 

The Forest Supervisor for the Tongass National Forest is responsible for the overall management of 

the Forest’s timber program. Included within these responsibilities is making the determination on 

the amount of timber volume to be made available to industry. Whether or not sufficient funding is 

appropriated to attain the program is the responsibility of the Congress and the President. 

The Forest Plan identifies the suitable land base for timber production, as discussed in Appendix A of 

the Forest Plan. Lands designated for possible timber harvest are in the development land use 

designations (LUDs), primarily in the Timber Production, Modified Landscape, and Scenic 

Viewshed LUDs. Timber harvest may be limited on some lands identified as part of the suitable land 

base because of Forest Plan Standards and Guidelines, such as stream and estuary buffers, and other 

laws and regulations. 
Appendix A

426  Appendix A – Project Reasons Saddle Lakes Timber Sale Final EIS

Congress’ policy for national forests, as stated in the Multiple-Use Sustained Yield Act of 1960, is 

“the national forests are established and shall be administered for outdoor recreation, range, timber, 

watershed, and wildlife and fish purposes.” Accordingly, Congress has authorized the Secretary of 

Agriculture to sell trees and forest products from the national forests “at no less than appraised 

value.” The National Forest Management Act directs that forest plans shall “provide for multiple 

use and sustained yield, and in particular, include coordination of outdoor recreation, range, timber, 

watershed, wildlife, fish and wilderness.” ANILCA, as amended by the Tongass Timber Reform 

Act, provided for timber harvest from the Tongass as well as other uses such as subsistence. Effects 

on subsistence resources from timber harvest Tongass-wide are projected to have few differences 

based on the sequence in which areas are harvested. Because of the multiple use mandate and other 

requirements of the laws, these effects to subsistence are necessary, consistent with sound 

management of public lands. 

In addition to nationwide statutes, Section 101 of the Tongass Timber Reform Act directs the Forest 

Service to seek to meet market demand for timber from the Tongass, subject to certain qualifications. 

It is the goal of the Tongass National Forest to provide an even-flow of timber on a sustained-yield 

basis and in an economically efficient manner. The amount of timber offered each year is based on 

the objective of offering enough volume to seek to meet the projected annual demand. That annual 

demand projection starts with installed mill capacity, and then looks to industry rate of capacity 

utilization under different market scenarios, the volume under contract, and a number of other factors, 

including anticipated harvest and the range of expected timber purchases. 

As described by Morse (April 2000), in terms of short-term economic consequences, oversupplying 

the market is less damaging than undersupplying it. If more timber is offered than purchased in a 

given year, the unsold volume is still available for re-offer in future years. Conversely, a short fall 

in the supply of timber can be financially devastating to the industry. 

The implementation of the timber projects depends in part on the final budget appropriation to the 

agency. In the event insufficient budget is allocated, or resolution of pending litigation or other factors 

delay projects, timber harvest projects are selected and implemented on a priority basis. Generally, the 

higher-priority projects are those where investments have been made such as roads, camps or log 

transfer facilities have already been established or where land management status is not under dispute. 

The distribution of projects across the Tongass is also taken into account to distribute the effects and 

to provide timber volume in proximity to timber processing facilities. Timber harvest projects 

scheduled for the current year that are not implemented, or the remaining volume of projects only 

partially implemented, are shifted to future years in the plan. The multi-year plan becomes very 

dynamic in nature due to the number of influences on each district. 

Conclusion ____________________________________________

There is a long legislative recognition that timber harvest is one of the appropriate activities on 

national forests, starting with the founding legislation for national forests in 1897. The Organic 

Administration Act provides that national forests may be established “to improve and protect the 

forest within the boundaries, or for the purpose of securing favorable conditions of water flows, and 

to furnish a continuous supply of timber for the use and necessities of the citizens of the United 

States.” 
Appendix A

Saddle Lakes Timber Sale Final EIS Project Reasons - Appendix A  427

Morse, K.S. 2000b. Tongass National Forest Timber Sale Procedures: Using Information About 

Market Demand to Schedule FY2001 Timber Sale Offerings. October 2000. On file with: 

Regional Economist, Ecosystem Planning. Juneau, AK: U.S. Department of Agriculture, 

Forest Service, Alaska Region. 17 p. 

USDA Forest Service. 2008a. Forest Plan Amendment Record of Decision, January 2008. 

USDA Forest Service. 2008b. Forest Plan, January 2008. 

USDA Forest Service, 2008c. Forest Plan Amendment Final Environmental Impact Statement, 

January 2008. 

USDA Forest Service. 2013. Secretary’s Memorandum 1044-009, Addressing Sustainable Forestry in 

Southeast Alaska.

USDA Forest Service. 2013. Issue Paper, Trajectory to Young Growth on the Tongass National Forest. 

January 2013. 

References

Alexander, S. 2008. Tongass National Forest Timber Sale Procedures: Using Updated Information 

about Market Demand to Schedule FY 2006 Timber Offerings. USDA Forest Service Region 

10, Juneau AK. 10 p. On file with: Regional Economist, Alaska Region, PO Box 21628, 

Juneau AK 99802.

Brackley, A.M.; Rojas, T.D.; Haynes, R.W. 2006. Timber products output and timber harvests in 

Alaska: projections for 2005-25. Gen. Tech. Rep. PNW-GTR-677. Portland, OR: U.S. 

Department of Agriculture, Forest Service, Pacific Northwest Research Station. 33 p. 

Brackley, A.M. and Haynes, R.W. 2008. Timber Products Output and Timber Harvests in Alaska: An 

Addendum. Res. Note PNW-RN-559. Portland, OR: U.S. Department of Agriculture, Forest 

Service, Pacific Northwest Research Station. 

Brooks, D.J.; Haynes, R.W. 1997. Timber products output and timber harvests in Alaska: projections 

for 1997-2010. Gen. Tech. Rep. PNW-GTR-409. Portland, OR: U.S. Department of 

Agriculture, Forest Service, Pacific Northwest Research Station. 17 p. 

Morse, K.S. 2000a. Responding to the Market Demand for Tongass Timber: Using Adaptive 

Management to Implement Sec. 101 of the 1990 Tongass Timber Reform Act. April 2000. 

Management Bull. R10-MB-413. Juneau, AK: U.S. Department of Agriculture, Forest 

Service, Alaska Region. 43 p.
Appendix A

428  Appendix A – Project Reasons Saddle Lakes Timber Sale Final EIS

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Appendix B 

Interrelated Projects

Saddle Lakes Timber Sale Final EIS Interrelated Projects - Appendix B  429

Appendix B – Interrelated Projects

Interrelated projects are defined for the Saddle Lakes EIS as activities that could potentially interact 

with the alternatives in a manner that could result in cumulative impacts. These activities were 

identified by the Saddle Lakes IDT and have been considered in the cumulative effects sections of each 

resource in Chapter 3. The geographic area for the cumulative impacts analysis is determined by each 

resource.

Interrelated projects have been grouped as past, present, and reasonably foreseeable future actions and 

they are listed and described below to ensure that full consideration has been given by each resource. 

Table 117 identifies the potential resource interactions among the interrelated projects and various 

resources. Not all of these activities interact with every resource because the cumulative effects analysis 

area varies by resource. It is important to note that the potential resource interactions among the 

interrelated projects shown in Table 117 may not necessarily contribute to cumulative impacts. Rather, 

Table 117 was developed by the Saddle Lakes IDT to identify the interrelated projects that have the 

potential to interact with the resource.

Past Activities

Timber Harvest within or adjacent to project area (1959 to 2014) 

Approximately 8,952 acres have had timber harvest in or adjacent to the Saddle Lakes project area as a 

result of Forest Service, State of Alaska, and Alaska Native Corporation timber sales (Table 115).

Table 115. Past harvest within the Saddle Lakes project area

Agency

Acres of Harvest by Timeframe Total 

Acres 1959-1969 1970-1979 1980-1989 1990-1999 2000-

2009

2010-

2014

Forest Service 

(NFS lands) 1,140 543 0 2,313 419 36 4,451

State of Alaska 

(Alaska Mental 

Health Trust 

Authority)1/

0 0 0 0 3,726 0 3,726

Cape Fox Native 

Corporation 0 184 0 477 86 28 775

Total 1,140 727 0 2,790 4,231 64 8,952

Sources: USDA Forest Service, GIS; 

1/ Clark 2012, State of Alaska, personal communication

Past Forest Service Timber Harvest in the Saddle Lakes Project Area

(NEPA decision document and acres from the Selected Alternative) 

• Timber Management Plan Record of Approval (10/16/58) – 148 acres

• Ketchikan Pulp Company Timber Sale 1974-1979 Operating Period EIS (1974) – 110 acres

• Shelter Cove EIS (1991) – 2,246 acres
Appendix B

430  Appendix B – Interrelated Projects Saddle Lakes Timber Sale Final EIS

• Upper Carroll EIS (1996) – 54 acres

• Sea Level EIS (1999) – 491 acres

• Salty EA (2000) – 165 acres

• Mop Point/91 Knot EA (2001) – 20 acres

Beaver Falls Hydroelectric Project (FERC P-1922)

The Beaver Falls hydropower plant is owned and operated by the Ketchikan Public Utilities (KPU). 

This project consists of two dams with reservoirs and two powerhouses. Upper and Lower Silvis Lakes 

are formed behind concrete-faced, rock-filled dams which have a separate spillway weir and channel. 

Tunnels and penstocks connect Upper Silvis Lake to the powerhouse located on Lower Silvis Lake, and 

from Lower Silvis Lake to the Beaver Falls powerhouse located on the west side of George Inlet at 

tidewater. The total capacity is 5,000 kW.

Swan Lake Hydroelectric Project (FERC P-2911)

The Swan-Lake Hydroelectric Project is located northeast of the Saddle Lakes project area. It consists 

of a concrete arch dam that is 174 feet high and 430 feet long. The Swan Lake Reservoir, with a surface 

area of 1,500 acres at normal maximum elevation, includes a power tunnel that is 2,200 feet long and 

11 feet in diameter, leading from an intake structure at the north abutment upstream of the dam to the 

powerhouse. An indoor-type remotely controlled concrete powerhouse, containing two generating units 

with a total rated capacity of 22,000 kW is located at Carroll Inlet immediately north of the mouth of 

Falls Creek. It also includes a13.8/115-kV substation, and access facilities comprised of port facilities 

1,000 feet north of the powerhouse. A staging area adjacent to the port facilities has access roads from 

the port facilities to the powerhouse and dam. A 115 kV transmission line extends from the powerhouse 

substation 30.5 miles to the existing S.W. Bailey Substation (see description below).

Swan Lake Powerline

The transmission line extends from the S.W. Bailey Substation in Ketchikan to the switchyard at the 

powerhouse. The 115-kV transmission line is about 30.5 miles in length. The line follows the route of 

the existing 34.5-kV line north from the S.W. Bailey Substation to Ward Cove. From there the line 

extends east along the north side of Connell Lake, then turns to follow the White River Valley to the 

upper end of George Inlet. The powerline extends along the north side of George Inlet (Salt Chuck) 

heading east to the South Saddle Lake area, near Carroll Inlet, where it turns to the north and follows 

the western edge of Carroll Inlet to a location opposite the powerhouse. The line then crosses the inlet 

via an overhead span to the Swan Lake dam, terminating at the switchyard adjacent to the powerhouse. 

Swan Lake dam, associated facilities (on State land) and transmission lines were placed into service 

between 1981 and 1985. The powerline, originally authorized under a special use permit in 1984, is 

currently issued to Southeast Alaska Power Agency (SEAPA). 

Swan-Tyee Powerline

Located outside the project area, the Swan-Tyee Intertie is a 57 mile long, 138-kV transmission line 

interconnecting the electric system of Ketchikan to the Tyee Lake hydroelectric project in Wrangell, 

Alaska. The Forest Service issued a special use permit to Ketchikan Public Utilities (KPU) in

September 2001 for its construction. Clearing of the corridor began in 2003 with line construction in 

2004. The powerline was completed in 2009 when the line was energized. The powerline is currently 

authorized under a special use permit to the SEAPA (September 2001 Decision). 
Appendix B

Saddle Lakes Timber Sale Final EIS Interrelated Projects - Appendix B  431

Timber Stand Improvement 5-Year Plan (2002-2007)

This project involved pre-commercial thinning (PCT) for timber stand improvement and pruning for 

riparian and wildlife habitat values on about 5,000 acres of overstocked young-growth forest on 

Revillagigedo Island (February 2002 Decision).

Timber Stand Improvement 5-Year Plan (2008-2013)

This plan included pre-commercial thinning on about 3,800 acres of overstocked young-growth forest 

(lands suitable for timber harvest and old-growth stands) to enhance timber and wildlife habitat values 

(November 2007 Decision). 

Ketchikan-Misty Fiords Ranger District Access and Travel Management Plan

The Ketchikan-Misty Fiords Ranger District (KMRD) Access and Travel Management (ATM) Plan 

supports the goals and objectives of travel management and road maintenance. The ATM identifies the 

minimal road system required for forest management of public motorized use (July 2008 Decision). 

Ketchikan-Misty Fiords Ranger District Outfitter/Guide Management Plan

The Ketchikan-Misty Fiords Ranger District (KMRD) Outfitter/Guide Management Plan determines 

recreation use levels for outfitters and guides, and allocates approximately 50,671 service days annually 

for outfitter and guide use on KMRD (January 2012 Decision). The highest guided use annually (2005- 

2009) was 2 service days within the project area.

Timber Stand Improvement (2012)

This project included pre-commercial thinning on about 700 acres of overstocked young-growth forest 

(lands suitable for timber harvest and old-growth stands) to enhance timber and wildlife and fish habitat 

values. Thinning was authorized to begin in 2012 in the vicinity of the Fire Cove log transfer facility

(June 2012 Decision). 

Non-NFS Tours and Recreation

There are several non-NFS permitted tours and recreation activities accessed from the Ketchikan road 

system. These activities include, but are not limited to jeep tours, canoeing on Harriett Hunt Lake, and 

paintball (on a paintball field along the Revilla Road). There are also commercial boat-based tours that 

use both George and Carroll Inlets.

Present Activities

Tongass National Forest Timber Sales (Under Contract)

The Buckdance Madder Reoffer Timber Sale is the only open timber sale in the Saddle Lakes project 

area. All timber harvest was completed in 2011, and the only uncompleted activities on that sale are 

contractual road closures. Table 116 shows remaining volume under contract for the Tongass National 

Forest in FY2014. 

Southeast Alaska Timber Sales 

The State of Alaska 5-year schedule of timber sales (FYSTS) identifies areas where the Division of 

Forestry (DOF) is analyzing potential timber sale planning in southern Southeast Alaska (State of 

Alaska Department of Natural Resources, 2014). Timber volume and harvest information in that 

document does not include harvest volumes proposed by the Alaska Mental Health Trust Authority or 

the University of Alaska. The FYSTS is not developed as a decision document for particular timber 
Appendix B

432  Appendix B – Interrelated Projects Saddle Lakes Timber Sale Final EIS

sales, and no public data is available to determine the quantity of timber currently under contract. 

However, in that document the DOF proposed a planning harvest volume of about 19 MMBF in 2012, 

and 27 MMBF in 2013. 

No public data is available regarding timber volume currently under contract on forest lands managed 

by Alaska Native corporations.

Timber Stand Improvement 5-Year Plan (2013-2018)

This plan includes pre-commercial thinning on about 9,060 acres to improve timber production, 

enhance wildlife habitat, and restore riparian ecosystems on the KMRD landbase. These activities 

would take place in previously harvested stands on Revillagigedo and Hassler Islands, Southeast 

Alaska over the next 5 years, and thin approximately 500 to 600 acres annually beginning in 2013 

(March 2013 Decision). 

Whitman Lake Hydroelectric Project (FERC P-11841)

The Forest Service issued a special use authorization to Ketchikan Public Utilities for the construction, 

operation, and maintenance of the hydroelectric project. The project consists of a 4.6 MW hydrostorage facility on an existing dam on Whitman Lake, in the watersheds of Whitman and Achilles 

Creeks, about 4 miles east of Ketchikan. Construction of this project was completed in 2014 (June 

2011 Decision). 

NFS Outfitter Guide Permits

The January 2012 Decision Notice on the Ketchikan-Misty Fiords Ranger District (KMRD) Outfitter 

and Guide Management Plan authorized up to 1,420 service days per year to be issued to outfitter and 

guides in the South Revilla Natural Accessible Use Area, which includes the Shelter Cove road system. 

This use area also includes the Shoal Cove and Thorne Arm (Elf Point) road systems. One outfitterguide has a permit for using the Saddle Lakes project area, and used 3 service days in 2012. 

Non-NFS Tours and Recreation

There are several non-NFS permitted tours and recreation activities accessed from the Ketchikan road 

system. These activities include, but are not limited to jeep tours, canoeing on Harriett Hunt Lake, and 

paintball (on paintball field along Revilla Road). There are also commercial boat-based tours that use 

both George and Carroll Inlets. 

Reasonably Foreseeable Future Activities

Tongass National Forest Five Year Timber Sale Schedule and Contract Plan

The Tongass National Forest Five Year Timber Sale Schedule and Contract Plan (Tongass NF, 

unpublished data, 2014) proposes an annual average timber sale volume of about 127 MMBF (gross) 

for the upcoming 5-fiscal-year-period (fiscal years 2014 through 2018). This includes estimated gross 

volumes of both young-growth and old-growth timber. The table below shows the Tongass National 

Forest Five Year Timber Sale Schedule and Contract Plan.
Appendix B

Saddle Lakes Timber Sale Final EIS Interrelated Projects - Appendix B  433

Table 116. Summary of Tongass National Forest five year timber sale schedule and contract plan

Fiscal Year Young Growth Gross 

Volume (MMBF)

Old Growth Gross 

Volume (MMBF)

Total Gross Volume 

(MMBF)

2014 3 149 152

2015 0 113 113

2016 25 96 121

2017 20 138 158

2018 22 69 91

Annual Average 127

Source: Tongass National Forest Five Year Timber Sale Schedule and Contract Plan, 2014. Unpublished data on file with 

Tongass National Forest Supervisor’s Office

Timber Stand Improvement 5-Year Plan (2013-2018)

This plan includes pre-commercial thinning on about 9,060 acres to improve timber production, 

enhance wildlife habitat, and restore riparian ecosystems on the KMRD landbase. These activities will 

take place in previously harvested stands on Revillagigedo and Hassler Islands, Southeast Alaska over 

the next 5 years, and will thin approximately 500 to 600 acres annually beginning in 2013 (March 2013 

Decision). 

Spit Point Wildlife Habitat Restoration Project

The Spit Point Wildlife Habitat Restoration project proposes the thinning of 21 acres in Stand 75305-

110, and 50 acres in Stand 75306-72. These stands of young-growth timber are approximately 13 miles 

east of Ketchikan, Alaska adjacent to Carroll Inlet. This project was authorized in 2010, but has been 

on hold due to lack of funding and operational technology (barge-based suspended cable operation) 

(February 2010 Decision). 

Southeast Alaska Timber Sales (Planned)

The July 11, 2013 State of Alaska Department of Natural Resources Division of Forestry (DOF) draft 5-

year schedule timber sales (CY 2013-2017) identified areas where the DOF is analyzing potential 

timber sale planning in southern Southeast Alaska. The southern Southeast Area encompasses lands 

from Tracy Arm/Frederick Sound south to Dixon Entrance and Portland Inlet. 

The Leask Cove sale is planned for 2017. Development of this timber sale is dependent on the 

Department of Transportation constructing a connection road between the Leask Lake area and the 

Shelter Cove area; funding was provided for the construction of this road through a Statewide road 

bond initiative in 2012. Proposed sale area consist of ten clearcut areas totaling 88 acres containing an 

estimated 3,300 MBF (3.3 MMBF) of timber. The construction of an additional 1.8 miles of spur road 

will be required access these units.

No public data is available regarding timber volume planned on forest lands managed by Alaska Native 

corporations. 

Ketchikan to Shelter Cove Road 

The Alaska Department of Transportation and Public Facilities (DOT&PF) is in the design and analysis 

phase of the entire Ketchikan to Shelter Cove Road; funding has been secured for its construction. This 

project would connect the currently isolated Shelter Cove road system to the community of Ketchikan 
Appendix B

434  Appendix B – Interrelated Projects Saddle Lakes Timber Sale Final EIS

via the Revilla Road, White River road, and the Leask Lake road systems. The road will be 23.6 miles 

long, require 6 miles of new road construction, and would use 17.6 miles of existing logging roads. 

The State of Alaska began initial scoping for the Ketchikan to Shelter Cove Road project (State 

Project 68405) in November of 2006. In the spring of 2007, the DOT&PF began a reconnaissance 

study, and public meetings were held in September 2011 and March 2012 to discuss highlights of the 

Draft Reconnaissance Report. After receiving and analyzing agency and public comments, DOT&PF 

recommended Alternative II (“Low-Low” Alternative). More information about the Ketchikan to

Shelter Cove Road can be found on the DOT&PF website (see DOT&PF Southeast Region website). 

Construction on the 6 miles of new road is scheduled to occur in 2015. 

The Ketchikan to Shelter Cove Road is listed as the Harriet Hunt - Shelter Cove Connection Road in 

Appendix F of the 2008 Forest Plan (USDA Forest Service 2008b, p. F-23) under “Routes not 

constructed nor NEPA cleared: Planned or Opportunities.” 

Alaska Mental Health Trust Authority Land Exchange

Alaska Mental Health Trust Authority (AMHT) has proposed a land exchange with the Forest Service 

which includes an 8,170 acre parcel within the Saddle Lakes project area. Future AMHT plans for this 

parcel, if approved, are not known at this time. However, revenue-generating uses of AMHT land 

includes land-leasing and sales; real estate investment and development; commercial timber sales; 

mineral exploration and production; coal, oil and gas exploration and development; and sand, gravel 

and rock sales (AMHT Trust Overview brochure – April 2013). The AMHT’s Trust Land Office (TLO) 

stated in their November 2013 Forest Resource Management Plan that “As of May 2013, TLO and 

USFS are working jointly toward the signing of an Agreement to Initiate (ATI) the proposed land 

exchange... TLO will be better positioned to fulfill its mandate of maximizing Trust timber assets after 

the exchange is complete. If successful, The Trust will own forest resources in areas more suitable for 

timber harvest, mitigating the known significant public opposition to monetizing its current assets” 

(Trust Land Office 2013, Forest Resource Management Plan, p. 2). 

Mahoney Lake Hydroelectric Project (FERC P-11393)

The 9.6 MW Mahoney Lake Hydroelectric Project is capable of accommodating the Ketchikan / 

SEAPA region's growing power-load demands. The project consists of a lake tap diversion, reservoir 

(Upper Mahoney Lake), pipeline, upper and lower tunnels, powerhouse, combination of underground 

and overhead transmission lines, and an access road. The project is connected to the Ketchikan road 

system via Cape Fox Corporation's White River road system. The project is located approximately 5 

miles from existing transmission lines (both the Beaver Falls, and the Swan-Tyee Intertie lines). FERC 

granted a stay on the license which expires in October 2015.

Swan Lake Hydroelectric Project License Amendment

The SEAPA is in the process of amending their FERC license. The non-capacity amendment would 

increase the storage capacity at the Swan Lake Hydroelectric Project (FERC P-2911) by increasing the 

dam’s height and establishing a new maximum operating pool. The increase in dam height would flood 

a total of 140 acres including approximately 26 acres of NFS land and increase the lake surface area to 

1,513 acres. The existing access road, camp, and staging areas would be utilized during the expansion. 

NFS Outfitter Guide Permits

Up to 1,420 service days per year are authorized to be issued to outfitter and guides in the South Revilla 

Natural Accessible Use Area, which includes the Shelter Cove road system. This use area also includes 

the Shoal Cove and Thorne Arm (Elf Point) road systems. 
Appendix B

Saddle Lakes Timber Sale Final EIS Interrelated Projects - Appendix B  435

Non-NFS Tours and Recreation

There are several non-NFS permitted tours and recreation activities accessed from the Ketchikan road 

system. These activities include, but are not limited to jeep tours, canoeing on Harriett Hunt Lake, and 

paintball (on paintball field along Revilla Road). There are also commercial boat-based tours that use 

both George and Carroll Inlets. 

Marble Creek Commercial Hydroponic Greenhouse Farm

The Marble Creek Commercial Hydroponic Greenhouse Farm site is located on private land, about 17 

miles northeast of Ketchikan and surrounded by National Forest System (NFS) lands. The owner has 

acquired all permits for the construction of a privately owned and operated hydroelectric plant, with 

power generated from a series of natural waterfalls that fall 150 feet down the mountainside. This 

business plans to deliver organic vegetables to markets and grocery stores across Southeast Alaska, 

reducing the fuel needed to get these products to consumers. 

OceansAlaska Shellfish Nursery

OceansAlaska (OA) plans to meet the shellfish industry’s need for a consistent and sufficient supply of 

shellfish seed by building and operating a land-based shellfish research and production facility on OA 

property at mile 8.9 South Tongass Highway. OceansAlaska currently operates a small floating shellfish 

hatchery built as a “proof-of-concept” hatchery and as a research facility. The current facility is not 

large enough to be self-sustaining or to meet the needs of the shellfish industry. When fully operational, 

the new facility is projected to have an annual production capacity of 50 million oyster seed and 3 

million geoduck seed. 

State Aquatic Permits

There are four 10-acre aquatic farm permit/leases for suspended aquaculture sites available for the 

public in Carroll Inlet south of Shelter Cove LTF. Should these leases be issued, attention/care may be 

needed when barging or rafting logs past this area. 

Table 117 lists potential resource interactions among the interrelated projects. 
Appendix B

436  Appendix B – Interrelated Projects Saddle Lakes Timber Sale Final EIS

Table 117. Potential resource interactions among the interrelated projects

Interrelated Projects1/

Issue 1 

Timber Economics

Issue 2

Timber Availability

Issue 3

Wildlife & Subsistence

Issue 4

Recreation & Scenery

Air Quality & Climate Change

Aquatics

Environmental Justice

Heritage

Invasive Plants

Lands and Minerals

Plants 

Roadless

Silviculture

Socioeconomics

Soils/Wetlands

Transportation

Past Actions

Timber Harvest acres within or adjacent to 

project area (1959-2012) X X X X X X X X X X X X X 

Timber Harvest and Exports volume for 

Southeast Alaska, 1997-2011 X 

Beaver Falls Hydroelectric Project X X 

Swan Lake Hydroelectric Project X X X 

Swan Lake Powerline X X X X X X X X 

Swan-Tyee Powerline X X X X 

Timber Stand Improvement (2002-2007) X X X X X X X 

Timber Stand Improvement (2008-2013) X X X X X X X X 

Ketchikan-Misty Fiords Ranger District 

Access and Travel Management 

Implementation

X X X X X X X X X X 

NFS Outfitter Guide Permits X X X X X X 

Non-NFS Tours and Recreation X X X X X X 

Present Actions

Tongass National Forest Timber Sales 

(Under Contract) X X X X X X X X X X X X X 

Southeast Alaska Timber Sales (Under 

Contract X X X X X X 

Timber Stand Improvement (2013-2018) X X X X X X X X 

Whitman Lake Hydroelectric Project X X X 
Appendix B

Saddle Lakes Timber Sale Final EIS Interrelated Projects - Appendix B  437

Interrelated Projects1/

Issue 1 

Timber Economics

Issue 2

Timber Availability

Issue 3

Wildlife & Subsistence

Issue 4

Recreation & Scenery

Air Quality & Climate Change

Aquatics

Environmental Justice

Heritage

Invasive Plants

Lands and Minerals

Plants 

Roadless

Silviculture

Socioeconomics

Soils/Wetlands

Transportation

NFS Outfitter Guide Permits X X X X X 

Non-NFS Tours and Recreation X X X X X X 

Reasonably Foreseeable Future Actions

Tongass National Forest Five Year Timber 

Sale Schedule and Contract Plan X X X X X X X X X X X X X 

Timber Stand Improvement (2013-2018) X X X X X X X X 

Spit Point Wildlife Habitat Restoration 

Project X X X X X X X 

Southeast Alaska Timber Sales (Planned) X X X X X X X 

Ketchikan to Shelter Cove Road X X X X X X X X X X X X X X X 

Alaska Mental Health Trust Authority Land 

Exchange X X X X X X X X X X X X X X X X 

Mahoney Lake Hydroelectric Project X X X X X 

Swan Lake Hydroelectric Project License 

Amendment X X X 

NFS Outfitter Guide Permits X X X X X X X X 

Non-NFS Tours and Recreation X X X X X X X 

Marble Creek Commercial Hydroponic 

Greenhouse Farm X 

OceansAlaska Shellfish Nursery X 

State Aquatic Permits X X X X 

1/ Interrelated projects are defined for the Saddle Lakes EIS as activities that could interact with the Proposed Action in a manner that could result in cumulative impacts.
Saddle Lakes Timber Sale Final EIS

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438  Appendix B – Interrelated Projects 
Appendix C 

Forest Plan Standards 

and Guidelines, Best 

Management Practices 

(BMPs), Mitigation and 

Monitoring

Saddle Lakes Timber Sale Final EIS Standards & Guidelines - Appendix C  439

Appendix C - Forest Plan Standards and Guidelines, 

Best Management Practices (BMPs), and Mitigation 

and Monitoring

Applicable LUD-specific Standards and Guidelines

Each land use designation (LUD) includes a management prescription that gives general direction on 

what may occur within the area allocated to the corresponding LUD, the standards for accomplishing 

each activity, and the guidelines on how to go about accomplishing the standards. Specific 

management direction (standards and guidelines) for each LUD in the Saddle Lakes project area were 

reviewed by the IDT and have been grouped by resource or category, following the order established 

for the Forest-wide Standards and Guidelines (Table 119). Within the components of the Tongass 

National Forest Land and Resource Management Plan (Forest Plan) management direction, the 

management prescription standards and guidelines for each LUD take precedence over the Forestwide Standards and Guidelines applied to that same designation, should any conflicts occur (USDA 

Forest Service 2008b, p. 1-3). 

Refer to Chapter 3 of the Forest Plan (USDA Forest Service 2008b) for a description of these LUDSpecific Standards and Guidelines. 

Table 118. Land use designation (LUD) Standards and Guidelines for the Saddle Lakes Timber Sale

Category Section Subsection

Old-growth Habitat LUD

Fish Fish Habitat Planning: FISH2 ALL 

Forest Health Forest Health: HEALTH1 A. 

Heritage Heritage Resource Activities: HSS1 Inventory/Evaluation (A. 1-3)

Lands Special Use Administration (NonRecreation): LAND2 B. 

Recreation And Tourism Recreation Use Administration: 

REC3

Recreation Management and Operations 

A. and B.

Scenery Scenery Operations: SCENE1 A. and B.

Timber Timber Resource Planning: TIM4 A., C. and D.

Transportation Transportation Operations: TRAN A. and B.

Wildlife Wildlife Habitat Planning: WILD1 A. and B.(2 and 3) 

Modified Landscape LUD

Forest Health Forest Health Management: 

HEALTH1 ALL 

Heritage Heritage Resource Activities: HSS1 Inventory A. and B.

Lands

Special Use Administration (NonRecreation): LAND2 A. 

Landline Location and Maintenance: 

LAND4 ALL 

Recreation and Tourism Recreation Use Administration: 

REC3 Recreation Settings A. (1-3) and B. 

Scenery Scenery Operations: SCENE1 ALL 
Appendix C

440  Appendix C – Best Management Practices Saddle Lakes Timber Sale Final EIS

Category Section Subsection

Soil and Water Watershed Resource Planning: 

SW3 A and C.

Timber

Timber Resource Planning: TIM4 ALL 

Timber Sale Preparation: TIM5 ALL 

Timber Stand Improvement: TIM10 ALL 

Transportation Transportation Operations: TRAN ALL 

Wildlife Wildlife Habitat Planning: WILD1 ALL 

Timber Production LUD

Forest Health Forest Health Management: 

HEALTH1 ALL 

Heritage Heritage Resource Activities: HSS1 Inventory ALL

Lands 

Special Use Administration (NonRecreation): LAND2 ALL 

Landline Location and Maintenance: 

LAND4 ALL 

Recreation and Tourism Recreation Use Administration: 

REC3 Recreation Settings A. (1-3)

Scenery Scenery Operations: SCENE1 ALL 

Soils and Water Watershed Resource Planning: 

SW3 A. and C.

Timber

Timber Resource Planning: TIM4 ALL 

Timber Sale Preparation: TIM5 ALL 

Timber Resource Coordination: 

TIM7 ALL 

Transportation Transportation Operations: TRAN A. (1-3)

Wildlife Wildlife Habitat Planning: WILD1 ALL 

Source: USDA Forest Service 2008b, Chapter 3

Applicable Forest-wide Standards and Guidelines

Forest-wide Standards and Guidelines are measures of expectations that apply to all, or most, areas of 

the Forest. Each management prescription in Chapter 3 of the Forest Plan includes a list of those that 

apply to that LUD. Table 119 shows the Forest-wide Standards and Guidelines that apply to the 

Saddle Lakes Timber Sale.

Refer to Chapter 4 of the Tongass National Forest Land and Resource Management Plan (USDA 

Forest Service 2008b) for a description of the Forest-wide Standards and Guidelines.
Appendix C

Saddle Lakes Timber Sale Final EIS Best Management Practices - Appendix C  441

Table 119. Forest-wide Standards and Guidelines for the Saddle Lakes Timber Sale

Category Section Subsection

Old-Growth 

Habitat

LUD

Modified 

Landscape LUD

Timber 

Production LUD

Air 

Air Resource Inventory: AIR1 I. Baseline Quality and Values (A.) X X X 

Air Resource Planning: AIR2

I. Objective (ALL) X X X 

II. Planning for the Maintenance of Air

Quality (ALL) X X X 

Beach and 

Estuary Fringe

Beach and Estuary Description: 

BEACH1 I. Objectives and Identification (ALL) X X X 

Beach and Estuary 

Management: BEACH2 II. Management (A. 1, 6, 8, and 9) X X X 

Fish

Fish Habitat Inventory and 

Monitoring: FISH1 Fish Habitat Inventory (ALL) X X X 

Fish Habitat Planning: FISH2

I. Fish Habitat and Channel Processes (ALL) X X X 

II. Channel Classification and Process

Groups X X X 

III. Fish Stream Classification (ALL) X X X 

IV. Objectives/Guidelines for Management

Affecting Fish Habitat (ALL) X X X 

V. Management Indicators (ALL) X X X 

VI. Management Activities (ALL) X X X 

VII. Coordination (A. 2, B. and C.) X X X 

VIII. Projects (A. - D.) X X X 

Fish Habitat Restoration and 

Improvement: FISH3 I. Planning (A. – C.) X X X 

Forest Health Forest Health Management: 

HEALTH1

I. Forest Health Management (A. 1 and 2; B. 

and C.) X X X 
Appendix C

442  Appendix C – Best Management Practices Saddle Lakes Timber Sale Final EIS

Category Section Subsection

Old-Growth 

Habitat

LUD

Modified 

Landscape LUD

Timber 

Production LUD

Heritage 

Resources

and Sacred 

Sites 

Heritage Resource Activities: 

HSS1 

I. Management (ALL) X X X 

II. Project Clearance/Inventory (ALL) X X X 

III. Project Implementation (ALL) X X X 

IV. Mitigation (ALL) X X X 

V. Enhancement X X X 

VI. Site Inspection (ALL) X X X 

Sacred Sites Protection 

Activities: HSS2 

I. Management (ALL) X X X 

II. Project Planning (ALL) X X X 

III. Project Implementation (ALL) X X X 

IV. Mitigation (ALL) X X X 

V. Enhancement (ALL) X X X 

VI. Monitoring (ALL) X X X 

Invasive 

Species

Invasive Species Prevention: 

INV1

I. Invasive Species Inventory (ALL) X X X 

II. Project Planning (ALL) X X X 

Lands

Lands Preparation: LAND1 I. Land Status (ALL) X X X 

II. Coordinating with Others (A. and C.) X X X 

Special Use Administration (nonRecreation): LAND2 I. Special Use Authorizations A. (1 – 5) X X X 

Lands Activity Maintenance and 

Landline Location: LAND4 I. Establishing Forest Boundaries (ALL) X X X 

Rights-of-Way (ROW): LAND5 I. Rights-of-Way Acquired (A. and B. 1 and 

3) X X X 

Plants

Threatened, Endangered, 

Sensitive, and Rare Plants: 

PLA1 

II. Sensitive Plants (A. and B.) X X X 

III. Rare Plants (ALL) X X X 

Invasive Plants: PLA2 I. Invasive Plants (ALL) X X X 

Plant Surveys and Vegetation

Mapping: PLA3 

I. Plant Surveys and Vegetation Mapping (A. 

– E.) X X X 
Appendix C

Saddle Lakes Timber Sale Final EIS Best Management Practices - Appendix C  443

Category Section Subsection

Old-Growth 

Habitat

LUD

Modified 

Landscape LUD

Timber 

Production LUD

Recreation 

and Tourism

Recreation Resource Inventory: 

REC1

I. Recreation Resource Opportunities (A. 1 

and 2) X X X 

Recreation Resource Planning: 

REC2 II. Integrated Resource Planning (A. and B.) X X X 

Recreation Use Administration: 

REC3

III. Recreation Settings (ALL) X X X 

VII. Recreation Use (A.) X X X 

Riparian

Riparian area: RIP1 I. Definition (ALL) X X X 

II. Objectives (ALL) X X X 

Riparian Planning: RIP2

I. Project Planning (A., C.-E.) X X X 

II. General Standards and Guidelines by

Activity (D. 1. a-c; E. 1-6, 8 and 9; F.; and 

G.)

X X X 

Rural

Community 

Assistance

Activities: RUR I. Resource Management Decisions 

Affecting Communities (ALL) X X X 

Scenery

Scenery Operations: SCENE1 I. Scenery Management (ALL) X X X 

Scenery Preparation: SCENE2 

I. Scenery Integrity Objectives: Application 

(ALL) X X X 

II. Scenic Integrity Objectives: Specific

Guidelines (All) X X X 

III. Scenic Integrity Objectives - Silvicultural

Prescriptions Other Than Clearcutting (B.) X X 

Scenery Administration: 

SCENE3 

I. Mitigation, Enhancement, and Monitoring 

(A.) 

Soil and Water

Water Inventory: SW2 I. Inventory and Evaluation (A. and B., 2) X X X 

Watershed Resources Planning: 

SW3

I. Land Use Activities (A., B., D., and F.) X X X 

II. Watershed Analysis and Cumulative

Watershed Effects (B.) X X X 

Watershed Restoration: SW4 I. Soil and Water Quality Protection and 

Restoration (A. 1, 3 and 5) X X X 

Subsistence Subsistence: SUB I. Subsistence (A. – D., I. – K.) X X X 
Appendix C

444  Appendix C – Best Management Practices Saddle Lakes Timber Sale Final EIS

Category Section Subsection

Old-Growth 

Habitat

LUD

Modified 

Landscape LUD

Timber 

Production LUD

Timber

Silvicultural Examination and 

Prescription: TIM3 I. Stage II Intensive Inventory (ALL) X X 

Timber Project Planning: TIM4 I. Information Gathering and Maintenance 

(ALL) X X 

Timber Sale Preparation: TIM5

I. Regeneration Methods (ALL) X X 

II. Even-Aged Systems (ALL) X X 

III. Size of Clearcuts/Even-Aged Openings

(ALL) X X 

V. Uneven-Aged Systems (ALL) X X 

VIII. Utilization Standards (ALL) X X 

IX. Competitive Bidding and Small Business

(ALL) X X 

X. Windthrow (ALL) X X 

Commercial Sale Administration: 

TIM6 I. Contract Administration (ALL) X X 

Other Forest Products: TIM7 I. Personal Use Program (ALL) X X X 

III. Administrative Use of Timber (ALL) X X X 

Reforestation: TIM9 I. Site Preparation, Planting, Stocking (ALL) X X 

Transportation

Transportation System Inventory: 

TRAN1

I. Inventory Updating and Maintenance 

(ALL) X X X 

Road and Bridge Administration: 

TRAN2

I. Road Management (A., B., D. and E.) X X X 

II. Permitting (B.) X X X 

Transportation Improvement 

Planning: TRAN3 I. Planning (ALL) X X X 

Road and Bridge 

Preconstruction: TRAN4

I. Road Standards (ALL) X X X 

II. Location and Design (ALL) X X X 

III. Wetlands, Flood Plains, Estuaries, and

Tidal Meadows (A. 1 and 2) X X X 

IV. Quarry and Borrow Sites (ALL) X X X 
Appendix C

Saddle Lakes Timber Sale Final EIS Best Management Practices - Appendix C  445

Category Section Subsection

Old-Growth 

Habitat

LUD

Modified 

Landscape LUD

Timber 

Production LUD

V. Log Transfer Facilities Siting, 

Construction, Operation, and Monitoring (B. 

and C.)

X X X 

Road and Bridge 

Construction/Reconstruction: 

TRAN5

I. Construction (ALL) X X X 

II. Reconstruction (ALL) X X X 

Road Maintenance: TRAN6 I. Maintenance Levels, Conditions, and 

Inspections (ALL) X X X 

Road Decommissioning: TRAN7

I. Planning (ALL) X X X 

II. Design (ALL) X X X 

III. Review (ALL) X X X 

Wetlands Wetlands: WET 

I. Objectives (ALL) X X X 

II. Inventory and Evaluation (ALL) X X X 

III. Land Use Activities (A., B., E. – G.) X X X 

Wildlife Wildlife Habitat Planning; WILD 1

I. Coordination/ Cooperation with Other 

Agencies, Institutions, and Partners (ALL) X X X 

II. General Habitat Planning/Coordination

(A-C, E and H) X X X 

V. Reserve Tree/Cavity-Nesting Habitat 

(ALL) X X X 

VI. Landscape Connectivity

(ALL) X X X 

VII. Sitka Black-tailed Deer (ALL) X X X 

VIII. Bald Eagle Habitat (ALL) X X X 

IX. Bear Habitat Management (A. 2, 3, 5 and

6) X X X 

X. Marine Mammal Habitats (A. 1 and 2) X X X 

XI Seabird Rookeries (A. 2) X X X 

XII. Waterfowl and Shorebird Habitats (A. 2,

3, 5 and 6; and B.) X X X 
Appendix C

446  Appendix C – Best Management Practices Saddle Lakes Timber Sale Final EIS

Category Section Subsection

Old-Growth 

Habitat

LUD

Modified 

Landscape LUD

Timber 

Production LUD

XIII. Heron and Raptor Nest Protection

(ALL) X X X 

XIV. Alexander Archipelago Wolf (ALL) X X X 

XV. Mountain Goat (ALL) X X X 

XVI. Marbled Murrelet (B.) X X X 

XVIII. American Marten (ALL) X X X 

XIX. Endemic Terrestrial Mammals (A. 1-3) X X X 

Threatened, Endangered, and 

Sensitive Wildlife Species: 

WILD4

I. Threatened or Endangered Species (A. 

and B.) X X X 

II. Sensitive Species (A.) X X X 

Source: USDA Forest Service 2008b, Chapter 4
Appendix C

Saddle Lakes Timber Sale Final EIS Best Management Practices - Appendix C  447

Applicable Site-Specific Best Management Practices (BMPs) 

The purpose of BMPs is to directly or indirectly protect water quality and abate or mitigate adverse 

water quality impacts while meeting other resource goals and objectives. Soil and water resources are 

most efficiently protected from nonpoint sources of pollution by implementation of the iterative BMP

process, and the site-specific application of BMPs. The BMPs presented in FSH 2509.22 (R-10 

AMENDMENT 2509.22-2006-2) were compiled from federal law, Forest Service Manual and 

Handbooks, contract and permit provisions, policy statements, planning documents, Regional guides, 

applicable State laws and regulations, and other pertinent sources. The Forest Plan (USDA Forest 

Service 2008b) has incorporated these BMPs into the standards and guidelines. 

In 2012, the USDA Forest Service published the National BMPs for Water Quality Management on 

National Forest System Lands, Volume 1: National Core BMP Technical Guide that provides 

information for implementing the National Core BMP portion of the Forest Service National BMP 

Program. The National Core BMPs were compiled from Forest Service manuals, handbooks, contract 

and permit provisions, and policy statements, as well as State or other organizations’ BMP 

documents. The National Core BMPs are not intended to supersede or replace existing R10 BMPs. 

Rather; the National Core BMPs provide a foundation for water quality protection on NFS lands and 

facilitate national BMP monitoring.

Forest Service regional guidance (R-10 AMENDMENT 2509.22-2006-2), incorporated into the 

standards and guidelines in the Forest Plan, provides the criteria for site-specific BMP prescriptions. 

Table 120 includes the objectives of the BMPs that would be implemented for the Saddle Lakes 

Timber Sale, and a crosswalk with the applicable National Core BMPs. The unit and road cards 

located in the project record and on the Tongass Planning website (see Tongass planning website) 

provide details on how these BMPs would be applied. 

For more detailed information and descriptions, see FSH 2509.22 (R-10 AMENDMENT 2509.22-

2006-2) and the National Best Management Practices for Water Quality Management on National 

Forest System Lands, Volume 1: National Core BMP Technical Guide.
Appendix C

448  Appendix C – Best Management Practices Saddle Lakes Timber Sale Final EIS

Table 120. Best Management Practices for the Saddle Lakes Timber Sale

R10 BMP National Core BMP Objective

Watershed Management

12.5 –Wetland Identification, Evaluation, 

and Protection

Plan-3 Aquatic Management Zone 

Planning

AqEco-4 Stream Channels & Shorelines

To identify wetland functions and value, and provide appropriate 

protection measures designed to avoid adverse hydrologic impacts.

12.6 –Riparian Area Designation and

Protection

Plan-2 Project Planning and Analysis

Plan-3 Aquatic Management Zone 

Planning

AqEco-4 Stream Channels & Shorelines

Road-7 Stream Crossings

Veg-3 Aquatic Management Zones

To identify riparian areas and their associated management 

objectives.

12.6a – Buffer Design and Layout

Plan-3 Aquatic Management Zone 

Planning

Veg-3 Aquatic Management Zones

To design streamside buffers to meet objectives defined during the 

implementation of BMP 12.6.

12.8 – Oil Pollution Prevention and 

Servicing/Refueling Operations

AqEco-2 Operations in Aquatic 

Ecosystems

Fac-6 Hazardous Materials

Road-10 Equipment Refueling & Servicing

To prevent contamination of surface and subsurface soil and water 

resources from spills of petroleum products.

12.9 – Oil and Hazardous Substances 

Pollution Contingency Planning

Fac-6 Hazardous Materials

Fac-10. Facility Site Reclamation

Road-10 Equipment Refueling & Servicing

To prevent the contamination of waters from accidental spills of oil 

and hazardous substances (including pesticides) at sites where a 

Spill Prevention Control and Countermeasure (SPCC) plan or 

hazardous substances contingency plan is required.

12.15 – Management of Sanitary Facilities 

and Sanitary Guidelines for Temporary 

Camps and Primitive Developments

Fac-4 Sanitation Systems

To comply with regulations for the disposal of sewage at 

administrative sites, facilities under special-use permit, temporary 

camps, and primitive developments of all types.

12.16 – Control of Solid Waste Disposal Fac-5 Solid Waste Management

Veg-3 Aquatic Management Zones

To protect surface and subsurface soil and water resources from 

harmful nutrients, bacteria, and chemicals through proper disposal of 

solid waste and use of alternative construction materials. 
Appendix C

Saddle Lakes Timber Sale Final EIS Best Management Practices - Appendix C  449

R10 BMP National Core BMP Objective

12.17 – Revegetation of Disturbed Areas

AqEco-4 Stream Channels & Shorelines

Fac-2 Facility Construction and 

Stormwater Control

Fac-10. Facility Site Reclamation

Road-6 Road Storage and 

Decommissioning

Veg-2 Erosion Prevention & Control

Veg-4 Ground-based Skidding & Yarding 

Operations

To provide ground cover to minimize soil erosion.

Timber Management

13.1 - Timber Sale Planning Veg-6 Landings To incorporate soil and water resource considerations into timber 

sale planning.

13.2 – Timber Harvest Unit Design Veg-1 Vegetation Management Planning To incorporate site-specific soil and water resource considerations 

into integrated timber harvest unit design criteria.

13.3 – Designating Water Quality

Protection Needs on Sale Area/Unit 

Release Maps

Veg-1 Vegetation Management Planning

Veg-3 Aquatic Management Zones

To delineate the location of protection areas and ensure their 

recognition, proper consideration, and protection on the ground.

13.4 – Timber Sale Operating Schedule Veg-1 Vegetation Management Planning To ensure that erosion control and timing responsibilities are 

incorporated into the Operating Schedule.

13.5 – Identification and Avoidance of 

Unstable Areas

Veg-1 Vegetation Management Planning

Veg-2 Erosion Prevention & Control

Veg-5 Cable & Aerial Yarding Operations

To avoid triggering mass movements and resultant erosion and 

sedimentation by excluding unstable areas from timber harvest.

13.9 – Determining Guidelines for Yarding 

Operations

Veg-2 Erosion Prevention & Control

Veg-4 Ground-based Skidding & Yarding 

Operations

Veg-5 Cable & Aerial Yarding Operations

Veg-7 Winter Logging

To select appropriate yarding systems and guidelines for protecting 

soil and water resources.

13.10 – Log Landing Location and Design Veg-6. Landings To design and construct landings to minimize soil erosion and water 

quality degradation.

13.11 – Scheduling and Enforcement of 

Erosion Control Measures During Timber 

Sale Operations

Veg-2 Erosion Prevention & Control

To ensure that the Purchaser's operations are conducted according 

to the Timber Sale Contract with respect to soil and water resource 

protection.

13.14 – Completion of Erosion Control for 

Unit Acceptance and Sale Closure

Veg-2 Erosion Prevention & Control

Veg-3 Aquatic Management Zones

To assure that the required erosion control work is completed before 

unit acceptance.
Appendix C

450  Appendix C – Best Management Practices Saddle Lakes Timber Sale Final EIS

R10 BMP National Core BMP Objective

13.16 – Stream Channel Protection 

(Implementation and Enforcement)

AqEco-2 Operations in Aquatic 

Ecosystems

Veg-3 Aquatic Management Zones

To provide site-specific stream protection prescriptions consistent 

with objectives identified under BMPs 12.6 and 12.6a. Objective may 

include: Objectives may include the following:

• Maintain the natural flow regime.

• Provide for unobstructed passage of storm flows.

• Maintain integrity of the riparian buffer to filter sediment and

other pollutants.

• Restore the natural course of any stream that has been

diverted as soon as practicable.

• Maintain natural channel integrity to protect aquatic habitat

and other beneficial uses.

• Prevent adverse changes to the natural stream temperature

regime.

13.18 – Modification of the Timber Sale 

Contract Veg-1 Vegetation Management Planning

To seek an Environmental Modification of the Timber Sale Contract if 

new circumstances or conditions indicate that the timber sale will 

cause irreparable damage to soil, water, or watershed values.

Transportation and Other Facilities Management

14.1 – Transportation Planning Road-1. Travel Management Planning 

and Analysis

To assure soil and water resources are considered in transportation 

planning activities.

14.2 – Location of Transportation Facilities

Road-2 Road Location & Design

Road-4 Road Operations & Maintenance

Road-11 Road Storm-Damage Surveys

To ensure soil and water resources protection measures are 

considered when locating roads.

14.3 – Design of Transportation Facilities

Road-2 Road Location & Design

Road-3 Road Construction & 

Reconstruction

To incorporate site-specific soil and water resource protection 

measures into the design of roads.

14.5 – Road and Trail Erosion Control 

Plan 

AqEco-2 Operations in Aquatic 

Ecosystems

Fac-2 Facility Construction and 

Stormwater Control

Road-2 Road Location & Design

Road-3 Road Construction & 

Reconstruction

To develop Erosion Control plans for road projects to minimize or 

mitigate erosion, sedimentation, and resulting water quality 

degradation prior to the initiation of construction and maintenance 

activities. 

To ensure compliance through effective contract administration and 

timely implementation of erosion control measures.
Appendix C

Saddle Lakes Timber Sale Final EIS Best Management Practices - Appendix C  451

R10 BMP National Core BMP Objective

14.6 – Timing Restrictions for Construction 

Activities

AqEco-2 Operations in Aquatic 

Ecosystems

Road-2 Road Location & Design

Road-3 Road Construction & 

Reconstruction

To minimize erosion potential by restricting the operating schedule 

and conducting operations during lower risk periods.

14.7 – Measures to Minimize Mass 

Failures

Fac-2 Facility Construction and 

Stormwater Control

Road-3 Road Construction & 

Reconstruction

To minimize the chance and extent of road-related mass failures, 

including landslides and embankment slumps.

14.8 – Measures to Minimize Surface 

Erosion 

Fac-2 Facility Construction and 

Stormwater Control

Road-3 Road Construction & 

Reconstruction

Road-6 Road Storage and 

Decommissioning

To minimize the erosion from cut slopes, fill slopes, and the road 

surface and consequently reduce the risk of sediment production.

14.9 – Drainage Control to Minimize 

Erosion and Sedimentation

Fac-2 Facility Construction and 

Stormwater Control

Road-3 Road Construction & 

Reconstruction

Road-6 Road Storage and 

Decommissioning

To minimize the erosive effects of concentrated water flows from 

transportation facilities and the resulting degradation of water quality 

through proper design and construction of drainage control systems.

14.10 – Pioneer Road Construction

Road-3 Road Construction & 

Reconstruction

Road-7 Stream Crossings

To minimize sediment production associated with the pioneer road 

construction.

14.11 – Timely Erosion Control for 

Incomplete Projects

AqEco-2 Operations in Aquatic 

Ecosystems

Road-3 Road Construction & 

Reconstruction

Road-7 Stream Crossings

To minimize erosion of and sedimentation from disturbed ground on 

incomplete projects by completing erosion control work prior to 

seasonal or extended shutdowns.

14.12 – Control of Excavation and 

Sidecast Material

Road-3 Road Construction & 

Reconstruction

Road-7 Stream Crossings

To minimize sedimentation from unconsolidated excavated and 

sidecast material caused by road construction, reconstruction, or 

maintenance activities.

14.14 – Control of In-Channel Operations

AqEco-2 Operations in Aquatic 

Ecosystems

Road-7 Stream Crossings

To minimize stream channel disturbances and related sediment 

production.
Appendix C

452  Appendix C – Best Management Practices Saddle Lakes Timber Sale Final EIS

R10 BMP National Core BMP Objective

14.15 – Diversion of Flows Around 

Construction Sites

AqEco-2 Operations in Aquatic 

Ecosystems

Road-7 Stream Crossings

To identify and implement diversion and de-watering requirements at 

construction sites to protect water quality and downstream uses. 

14.17 – Bridge and Culvert Design and 

Installation

AqEco-2 Operations in Aquatic 

Ecosystems

Road-7 Stream Crossings

To minimize adverse impacts on water quality, stream courses, and 

fisheries resources from the installation of bridges, culverts, or other 

stream crossings. 

14.18 – Development and Rehabilitation of 

Gravel Sources and Quarries

AqEco-3 Ponds & Wetlands

Fac-2 Facility Construction and 

Stormwater Control

To minimize sediment from borrow pits, gravel sources, and quarries, 

and to limit channel disturbance from gravel sources permitted for 

development within floodplains. 

14.19 – Disposal of Construction Slash 

and Stumps

Fac-5 Solid Waste Management

Road-3 Road Construction & 

Reconstruction

To ensure that debris generated during construction is prevented 

from obstructing channels or encroaching on streams.

14.20 – Road Maintenance Road-6 Road Storage and 

Decommissioning

To maintain all roads in a manner which provides for soil and water 

resource protection by minimizing rutting, road prism failures, side 

casting, and blockage of drainage facilities.

14.23 – Snow Removal Operations Chem-1 Chemical Use Planning

Road-8 Snow Removal & Storage

To minimize impacts of snow removal operations on road surfaces 

and embankments and to reduce the risk of sediment production.

14.26 – Daily LTF Cleanup

Fac-2 Facility Construction and 

Stormwater Control

Fac-5 Solid Waste Management

Road-9 Parking & Staging Areas

To assure daily cleanup of bark, debris, or other solid materials being 

introduced into marine waters when accumulations are present. 

To dispose of the materials in an acceptable manner, to prevent 

water quality degradation.

14.27 – Log Storage/Sort Yard Erosion 

Control

Fac-2 Facility Construction and 

Stormwater Control

Road-9 Parking & Staging Areas

To avoid generation of fine particles, and control the overland flow of 

particles carrying hazardous materials into waterways.

Fish and Wildlife Habitat Management

18.3 - In-Channel Excavation or 

Disturbance During Fish and Wildlife 

Habitat Improvement Projects

AqEco-2 Operations in Aquatic 

Ecosystems

To minimize stream channel disturbances and related sediment 

production from fish and wildlife habitat improvement projects 

through identification of, and compliance with, project specifications.

Sources:

USDA Forest Service 2006, FSH 2509.22 – Soil and Water Conservation Handbook Chapter 10 – Water Quality Management for National Forest System Lands in Alaska (R-10 

AMENDMENT 2509.22-2006-2)

USDA Forest Service 2012, FS-990a - National Best Management Practices for Water Quality Management on National Forest System Lands, Volume 1: National Core BMP 

Technical Guide
Appendix C

Saddle Lakes Timber Sale Final EIS Mitigation & Monitoring - Appendix C  453

Mitigation Monitoring, and Design Features

Heritage

Monitoring

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

administrators throughout the duration of the proposed project to ensure protection of the fish trap and 

petroglyph sites. Log rafting and/or storage should only be allowed at approved locations and 

positioned away from the fish trap and petroglyph sites. 

Monitoring proposed activities to ensure they do not affect cultural resources or historic properties 

through soil disturbance, rutting, compaction, and erosion. Monitoring would also address issues of 

additional use of the area that may increase the potential for deliberate looting or inadvertent 

disturbance of fragile sites in or near the project area.

Invasive Species

Mitigation

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

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

constructing new roads. All rock/fill sources would be inspected by certified personnel. 

a. If any rock sources become contaminated with high-priority species and certification

cannot be attained without treatment or avoidance methods, consider the use of weed

infested rock for re-constructing existing roads only.

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

constructions and new landings.

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

after the project for new invasive plant introductions.

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

project area after the project completion, and prior to closing temporary roads as part of the

District 5-year program of work for invasive species management. Prioritize controlling any new

populations relative to other populations of high-priority species needing treatment on the

District. This recommendation could change if the road from Ketchikan is completed, as

eradication may be impossible for some species once the road is connected.

4. Require washing of any off-road equipment and road brushers brought to the LTF from other

locations prior to arrival at the Saddle Lakes project area.

Wildlife

Mitigation 

Black Bears 

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

As a protection measure, unit boundaries should be adjusted to avoid these three known active bear 

dens. The suggested buffer width is 300 feet. 
Appendix C

454  Appendix C – Mitigation & Monitoring Saddle Lakes Timber Sale Final EIS

Transportation

Design Features 

Rock Quarries

There is a need for rock sources during the construction of the new NFS and temporary roads, road 

reconditioning, and general maintenance of the existing NFS roads in this project. Borrow pits and 

quarries would be needed for road construction. It is preferred that the rock source is close to the site 

of road construction or maintenance, usually within 2 miles. 

Where feasible, existing quarries would be used to support new road construction and road 

maintenance; however, new rock quarries may be developed. Quarry sites would be developed within 

500 feet of a road. It is preferred that the rock source is close to the site of road construction or 

maintenance, usually within 2 miles. More details regarding rock quarries can be found in the Draft 

Transportation Report for the Saddle Lakes Timber Sale. All newly developed borrow quarries would 

be reviewed and cleared by resource specialists prior to their development.

Bridges

All existing bridges used for this project would be reviewed and brought to standard prior to haul. 

New bridge construction may be required on new road construction. These bridges would be designed 

and built to a standard that would allow them to support log truck traffic.
Appendix D 

Response to Comments

Saddle Lakes Timber Sale Final EIS Response to Comments - Appendix D  455 

Appendix D – Response to Comments

Commenter ID Commenter Organization

AFA Owen Graham Alaska Forest Association

SOA Kyle Moselle State of Alaska Department of Natural Resources

Artley Richard Artley

KGB Dan Bockhorst Ketchikan Gateway Borough

GP Larry Edwards

NRDC Natural Resource Defense Council

SAF Society of American Foresters

SCS Sitka Conservation Society

SEACC Southeast Alaska Conservation Council

SEC Southeast Conference

T Emily Tarantini

TCS Victoria McDonald Tongass Conservation Society

DOI Philip Johnson U.S. Department of the Interior, 

Office of Policy and Compliance

Z Kyle Zimmer

JP Jean Public

NL Noah Lloyd

EPA Environmental Protection Agency

H Donald Hansen

L Lonnie L. Adams Amak Towing Company

M Bill Mackie, Janice Walker Madisons Hardware

C Tom Craig

Aquatics

BMPs and Stream Buffers

Commenters question the “assumption in the DEIS” that Forest Plan Best 

Management Practices (BMPs) effectively mitigate aquatic effects, and request that

all project area streams be buffered.

“BMPs are not a panacea – please carefully consider actual effects. The DEIS rests on the assumption 

that BMPs will mitigate aquatic effects to the level of insignificance.” 

“Please buffer all streams, or at least consider the impacts of not doing so.” 

Forest Service Response:

The site-specific application of BMPs, with a monitoring and feedback mechanism, is the approved 

strategy for controlling nonpoint source pollution such as timber harvest and roads. The EIS considers 

actual effects based on current peer-reviewed literature as well as findings from studies in the Tongass 

National Forest. BMP implementation and effectiveness are evaluated annually during field reviews 
Appendix D

456  Appendix D – Response to Comments Saddle Lakes Timber Sale Final EIS

of timber harvest and roads in the Tongass National Forest. Corrective actions, when identified, are 

implemented and reported. 

Riparian no-harvest buffers (RMA), along with reasonable assurance windfirmness (RAW) buffers,

along Class I, II, and III streams, would minimize erosion and sediment transport to streams (Rashin

et al. 2006) and maintain cool stream temperatures (Gomi et al. 2006). Although Class IV streams 

within harvest units do not receive buffers, disturbance would be minimized through BMPs. Sitespecific stream buffers are described on the unit cards, BMPs, and on the road cards. This information 

will be added to the FEIS, and can be found in the Aquatics Resource report. 

The DEIS discusses stream buffers on page 242 to 243. 

In-water Log Storage Effects

Commenters have expressed multiple concerns over the impacts of in-water log 

storage. They recommend the use of a barge rather than in-water storage 

referencing Appendix G (siting guidelines) of the Forest Plan, and would like a more 

comprehensive analysis conducted within the FEIS detailing effects to crab, 

commercial fisheries, and aquatic vegetation in the log storage area. 

“The discussion of project area LTFs in different sections of the DEIS does not adequately discuss the 

adverse impacts of in-water log storage at all potential LTF sites given the potential use of the Leask 

Cove and Coon Cove sites...We recommend using a barge for log transfer under all action alternatives 

and that you explicitly consider making direct transfer of logs to barges a condition of the timber sale 

contract. We request that further NEPA analysis include a separate, comprehensive section on LTF 

impacts that addresses the following concerns: Provide more information about dive surveys, permit 

requirements and timber volume: Further NEPA analysis should provide enough information to 

compare dive survey results with volume stored or assess the temporal variability in survey results. 

This information is needed to provide perspective about previous dive surveys in terms of log storage 

days or comparative volumes stored in one of southeast Alaska’s numerous historical Category V 

water quality impaired LTFs. The project record indicates that the amount timber from project 

alternatives may significantly exceed previously permitted amounts, and the DEIS should disclose 

and analyze maximum annual and long-term log storage quantities. Baseline survey and monitoring: 

We are concerned that dive surveys will be limited to measuring bark accumulation. [TLMP Appx. G 

at G-10]. LTF monitoring requirements are to be “site-specific and determined by such factors as 

volume, site characteristics, life of project, and type of operation, because these factors may 

determine the extent of environmental impacts.” [Id.]. Conduct a baseline monitoring survey that 

maps and surveys the LTF area including depth contours, the existing extent and depth of the bark 

accumulation, and the flora and fauna present. The monitoring plan should include consideration of 

dissolved oxygen levels and for leachates or other chemical effects associated with wood debris 

decomposition.” 

“TLMP Appendix G Guidelines: TLMP requires that LTF siting “best avoid or minimize impacts on 

water quality, aquatic habitat, and other resources.” [TLMP at 4-84]. The TLMP and Alaska State 

Forest Resources and Practices Act regulations explicitly specify a preference for onshore storage and 

barging of logs. [TLMP FEIS, Appx. G at G-9]. Further NEPA analysis should evaluate log storage

with respect to applicable guidelines for habitat that provide the “minimum requirements needed to 

mitigate for changes in water quality and adverse impacts on aquatic biota.” [See e.g. TLMP Appx. 

G]. The analysis should explicitly address why this preference is important to protect juvenile salmon, 

crabs, fisheries and tidal habitats.” 
Appendix D

Saddle Lakes Timber Sale Final EIS Response to Comments - Appendix D  457

“Further NEPA analysis should evaluate Pacific Northwest Research Station and other submitted 

references that review levels of woody debris coverage in regional LTFs with reference to log 

volume, type of facility and accumulation depths. [Fisher and Velasquez 2008; Faris and Vaughan 

1985]. It should also consider submersible studies that show that downslope accumulations can 

reduce species diversity and abundance in areas that dive surveys cannot measure. [Kirkpatrick et al 

1998].” 

Forest Service Response:

This project does not propose to construct a new LTF. The LTFs under consideration for use by this 

project are already in place, and the siting guidelines in Appendix G were followed when these LTFs 

were built. The Tongass National Forest works with the State of Alaska on permitting and monitoring 

these sites, and long-term impacts have not been a concern. 

Annual bark monitoring is required for all permit holders whose operations transfer a total of 15 

million board feet or more during the life of the LTF general permit and are located in water depths 

less than 60 feet at mean lower low tide. Annual bark monitoring is only required during the years the 

LTF is used. Submission of an annual dive survey report to DEC and EPA is required to document the 

nature and extent of continuous and discontinuous bark residue accumulations (ADEC 2010). Bark 

accumulation measurements are used as they can be used to easily assess the effects to the marine 

environment, and help maintain compliance with permit requirements. These standards are set by 

State and federal agencies and are based on habitat needs of aquatic species. Dive surveys may be 

requested for shorter intervals according to site conditions. 

Underwater surveys were conducted on May 18, 2009 at the Shelter Cove log transfer facility (LTF) 

to determine the extent of bark debris accumulation. The site surveyed is located in Carroll Inlet, 

Revillagigedo Island, Alaska. This inspection was done to satisfy the bark-monitoring program 

required by the NPDES permit. The survey methods remained in compliance with the standard 

methods that can be found in “Required Method for Bark Monitoring Surveys under the LTF General 

Permits.” The survey documented that the log transfer facility contained both continuous and 

discontinuous bark debris. The survey using the radial transect pattern quantified the extent and type 

of coverage as 0.24 acres continuous bark debris and 0.48 acres of discontinuous bark debris in a 

survey area of 0.72 acres. Additional dive surveys will ensure compliance with APDES permit 

requirements. Dive surveys will be conducted annually and at the end of the timber sale to monitor 

bark accumulation while the LTF is in use. If accumulation exceeds standards, appropriate action will 

be taken. Dive surveys may be requested for shorter intervals according to site conditions. 

The Alaska Department of Environmental Conservation, Division of Water website shows no 

Category V water quality impaired waterbodies in the vicinity of the project area. Dive surveys will 

adhere to the requirements of the APDES, and follow TLMP Appendix G guidance. 

Effects to the marine environment can be found on page 244 of the DEIS and within the Essential 

Fish Habitat Assessment on page 246 of the DEIS. The analysis in the DEIS does not specifically 

mention shellfish (or more specifically crab populations), but acknowledges that bark accumulations 

can impact marine habitats by smothering organisms or creating unfavorable water quality conditions 

(Page 247 of DEIS) and bark accumulations support fewer and less abundant marine species and that 

these accumulations can persist for up to 26 years (Page 248 of DEIS). This information is sufficient 

to provide a credible estimate of the effects, comparison of alternatives, and support an informed 

decision.
Appendix D

458  Appendix D – Response to Comments Saddle Lakes Timber Sale Final EIS

Temperature and Sedimentation

Some commenters requested a more thorough consideration of “long-term sediment 

contribution to streams and increased stream temperature to degraded fish habitat.”

Conversely commenters on this issue requested that the Forest Service consider a 

report that supports the claim that temperature impacts to streams dissipate within a 

few hundred feet of harvested areas, and effects are generally localized and short 

term, and would not lead to a degradation of habitat.

“Please include a thorough cumulative effects analysis with regard to past logging and stream 

temperature effects.” 

“The connection between long-term sediment contribution to streams and increased stream 

temperature to degraded fish habitat...The DEIS fails to consider this effect of sedimentation.” 

“The DEIS recognizes that upland harvest can increase maximum stream temperatures. It cites a 

study from Pollock et al. to suggest total watershed harvest, rather than riparian harvest, is the best 

predictor of such effects. Using that study (apparently), USFS concludes that the most harvested area 

watershed has a 50 percent likelihood of exceeding 7-day average daily maximums. That is 

unacceptable and should be cause for alarm. Also, please explain where this 50 percent number was 

derived from. Please also disclose the calculations for other area watersheds, showing their percent 

chances of exceeding water quality standards for temperature.” 

“Chapter 3, page 234; This section of the DEIS discusses stream temperature and turbidity impacts 

from logging and road building in the Saddle Lakes area. The industry studied both issues in the 

1990s and the reports were given to the Forest Service and the State of Alaska. Basically, the reports 

indicated that the temperature impacts to the streams dissipated within a few hundred feet of the 

harvested areas and the turbidity from road construction was similarly ephemeral and localized. Also, 

most turbidity from traffic on rock roads is very small, suspended sediment that is carried all the way 

to the ocean and does not impact streambeds.” 

Forest Service Response:

The DEIS identifies the units of measure used in the aquatics analysis (page 224). The DEIS 

discloses the potential direct and indirect effects of past riparian harvest on stream temperatures 

(page 242). The use and role of riparian buffers to mitigate potential effects of changes in 

temperature is described on page 234. Timber harvest effects on stream temperature are also 

discussed on page 234. 

The DEIS (Page 232) acknowledges that sediment can be introduced into streams from managementrelated and natural processes, including road building, timber harvest, landslides, debris flows, and 

erosion of stream banks. Pages 232 to 234 and 240 to 241 of the DEIS discuss these factors and the 

effects that can be expected based on current literature. For the Saddle Lakes project specifically, the 

potential effects related to sedimentation and turbidity are discussed on pages 240 to 241. 

Cumulative effects of past logging and stream temperature can be found on page 246. All information 

within Chapter 3 of the DEIS and within the aquatics resource report was used for the cumulative 

effects analysis. This information is sufficient to provide a credible estimate of the effects, 

comparison of alternatives, and support an informed decision. 

The use of Pollock et al (2009) to estimate stream temperature effects has been updated and 

corrected in the FEIS. No watersheds are expected to exceed 7-day average daily maximum stream 

temperatures as a result of the Saddle Lakes Timber Sale project. 
Appendix D

Saddle Lakes Timber Sale Final EIS Response to Comments - Appendix D  459

The DEIS discusses direct and indirect effects to the aquatic ecosystem specifically associated with 

project roads on pages 240 and 241. All applicable Forest Plan Standards and Guidelines, Forest 

Service Manual and Handbooks and BMPs will be incorporated during design, construction and 

maintenance of roads. 

The DEIS also disclosed potential effects from turbidity and sedimentation at logical 

subwatershed and watershed scales on pages 240 to 241. 

Fish Passage

Commenters have questions as to whether stream crossings that are known to not 

pass fish will be corrected before timber sale operations begin, and request that any 

new culvert instillations allow for fish passage at all flows.

“Chapter 3, page 237; The discussion of red pipes should mention that most of the red pipes resulted 

from a change in the fish passage standard, not an improperly installed or maintained culvert. The 

Forest Service and the timber industry have always done a good job complying with State and federal 

fisheries protection measures.” 

“Please repair all fish passage barriers on area roads. At minimum, all roads used for log haul or sale 

access, need to have fish passage barriers repaired.” 

“Since there are already 95 miles of existing road (pg. 233), in addition to 11 red, and 2 gray 

crossings in the project area (Pg. 237), fish crossings must be repaired before new roads are 

built...TCS recommends that restoration of fish crossings be fully funded and road building be 

restricted in this area.” 

“Although the DEIS (page 237) states that the red crossings “are not necessarily complete barriers”, it 

does not mention whether or not the identified red crossings would be corrected as part of the 

proposed Project. DFG-Habitat recommends that the Preferred Alternative in the FEIS include 

corrective actions for all identified red fish stream crossings, such that efficient fish passage is 

provided at all flows.” 

“Additionally, stream crossing structures installed in fish-bearing streams as part of new road 

construction must be designed and installed to allow efficient fish passage at all flows.” 

Forest Service Response:

Road crossings are maintained and repaired in accordance with the Forest Plan. 

The current Forest Plan, directs the FS to "maintain, restore, or improve, where feasible, stream 

conditions that support the migration, or other movement of aquatic organisms inhabiting a 

waterbody." While the current Forest Plan provides more specific guidelines and criteria for 

evaluating fish passage and protecting fish habitat, the core requirement to provide fish passage is not 

new. Previous land management plans and area guides provided direction relative to fish passage 

since 1977. Specifics of the historic passage requirements also included requiring fish passage on 

some Class II streams but allowing fish passage to be restricted based upon benefit cost analysis of 

sites. The current direction states that stream crossing structures requiring aquatic organism passage 

will be designed to current standards by qualified professionals. See page 237 of DEIS. 

Not all red pipes are full barriers, and may be passible during certain life stages of fish, i.e. adults but 

not juveniles. Replacement priority is determined by an ongoing forest priority process based on a 
Appendix D

460  Appendix D – Response to Comments Saddle Lakes Timber Sale Final EIS

variety of metrics including habitat quality and quantity, diversity of fish in the system, amount 

habitat upstream of the culvert, and available funding. An example of this priority process is a red 

pipe with 3 miles of quality upstream habitat may receive priority over a red pipe with only 100 feet 

of upstream habitat. 

This information has been added to the FEIS. 

The Tongass National Forest is concerned about the loss of fish habitat upstream from culverts 

restricting passage and has corrected approximately 329 fish stream crossings throughout the Forest 

since 1998, not including those that have been removed through road storage activities. It may not be 

advisable or feasible to replace all existing red culverts with aquatic organism passage designed 

crossings. Though a crossing may be categorized as red, it may not impede larger fish and may even 

pass fish of all sizes during certain stream flow levels. Furthermore, some of the red crossings in this 

project area have very limited amounts of fish habitat upstream. The replacement of red culverts to 

improve fish passage is prioritized at the Forest level and is anticipated to reflect the best use funds 

allocated by Congress for this purpose. Refer to the fisheries section of the FEIS for more information 

on site-specific impacts of existing red culverts on access to upstream habitat.

The DEIS discusses the Fish Passage Barrier Modification on page 238. The 60-foot long cascade is 

located 0.25 mile above the intertidal zone in T. 73 S., R. 92 E., Section 17 of the Copper River 

Meridian (CRM). The DEIS clearly states that the barrier is already navigable to coho salmon and 

steelhead trout at certain flow levels and that these species are already using the habitat upstream of

the partial barrier. The proposal to modify the partial barrier is to improve passage over a wider range 

of flow conditions allowing coho salmon and steelhead trout to better access the upstream habitat. 

This proposal should not change the overall species composition of the upstream habitat nor would 

any additional usable habitat be created or restored. With the exception of allowing better access over

a wider range of flow conditions existing conditions would remain relatively the same with

implementation of the fish passage improvement proposal.

Clean Water Act

Commenters request further discussion within the EIS of how the project is in 

compliance with the Clean Water Act, which includes “replacing or removing” any 

culverts (“red culverts”) with fish passage issues. 

“Please further consider and discuss, in the EIS, how Clean Water Act §404 compliance is being 

addressed.” 

“Please bring all area roads into compliance with the CWA by replacing or removing all red culverts. 

It is very frustrating that this action, which is consistently urged by involved parties (e.g. ADF&G, 

ADEC, NMFS, EPA) continues to get the stiff-arm from the Forest Service.” 

Forest Service Response:

The DEIS discusses Section 404 of the Clean Water Act on page 14. As stated in the DEIS, all permits

that are required will be obtained prior to project implementation. This information has been updated 

in Chapter 1 of the Final EIS. A finding of compliance with the Clean Water Act will be included in 

the Record of Decision. 

See also response to Fish Passage on page 459 of this Appendix. 
Appendix D

Saddle Lakes Timber Sale Final EIS Response to Comments - Appendix D  461

State of Alaska Concurrence

“The DEIS (Ch. 3, page 238) correctly identifies Salt Creek (Stream No. 101-45-

10380) as a cataloged anadromous fish stream, which requires the Forest Service 

reach concurrence with DFG Habitat before conducting work below the ordinary high 

water level (Ch. 1, page 13).”

Forest Service Response:

All necessary federal and State permits, including Title 16 concurrence with the State of Alaska will 

be completed prior conducting to any instream activities. 

Essential Fish Habitat (EFH) 

Commenters had suggestions for the EFH analysis, and wanted to ensure that the 

required consultation occurs prior to additional NEPA work. 

“The DEIS contains a finding of unavoidable adverse impacts to EFH, which triggers consultation 

with NMFS. Please conduct this consultation prior to additional NEPA work, and integrate NMFS 

recommendations into the proposed action. Please specifically address the mitigation measures 

NMFS proposes.” 

“At a minimum, an adequate EFH should provide a description of the action, analysis of potential 

adverse effects, conclusions regarding the effects and proposed mitigation if applicable. [50 C.F.R. § 

600.920(e)(3)].” 

Forest Service Response:

The Saddle Lakes Timber Sale DEIS containing an Essential Fish Habitat (EFH) Assessment was 

mailed to NMFS on 9/12/14 in both CD and hardcopy format. According to the procedures governing 

the consultation process between the USDA Forest Service, Alaska Region and the National Marine 

Fisheries Service, Alaska Region concerning (EFH): If NMFS does not respond within the 

established comment period [45-days for an EIS], without a FS approved time extension, consultation 

is ended and no further correspondence is necessary (EFH Consultation Process, Item 5). As of 

12/17/14, no response from NMFS was received. NMFS chose not to comment on the Saddle Lakes 

Timber Sale project which, according to the agreement, concludes the consultation.

The EFH Assessment (pages 246 to 252 of the DEIS) contains the full effects analysis for both 

freshwater and marine EFH. The analysis considers potential effects to EFH based on current peerreviewed literature, and findings from studies conducted in Tongass National Forest. All the 

information available in Chapter 3 of the DEIS was used in the Essential Fish Habitat Assessment and 

associated finding, and the full assessment can be found in the Aquatic Resource Report, located in 

the project record, and available upon request. The Forest Service determined that the Saddle Lakes 

project may adversely affect both freshwater and marine EFH (and this is stated on page 251-252 of 

the DEIS). The description of the proposed action for this project is on page 7 of the DEIS, and the 

EFH assessment beginning on page 244 of the DEIS discloses any potential adverse effects and 

conclusions regarding effects. 
Appendix D

462  Appendix D – Response to Comments Saddle Lakes Timber Sale Final EIS

Large Wood Recruitment

Commenter would like the FEIS to “disclose the current situation of streams 

regarding LWD (large woody debris).”

“Please consider and disclose the current situation of streams regarding LWD. Areas such as this, 

which have large amounts of past harvest, commonly have chronic, long-term shortages of LWD in 

streams.” 

Forest Service Response:

Riparian harvest occurred prior to the Tongass Timber Reform Act. Surveys for the Saddle Lakes 

project area between 2012 and 2014 focused on identifying stream protection needs (including 

riparian no-harvest buffers). At this time, no stream restoration needs resulting from LWD shortages 

have been identified in the project area.

Peak Flows

Commenters feel that peak flows were not adequately considered within the DEIS, 

nor are conclusions made regarding peak flows supported by scientific literature.

“Please include citations to scientific studies to support your contentions that lakes and wetlands 

would buffer peak flow effects.” 

“Please disclose the effects of the proposed action on the two vulnerable watersheds. Based on the 

analysis in the DEIS, impacts appear significant, but the DEIS never analyzes those impacts. 

Significantly increased peak flows can be expected to degrade fish habitat.” 

“The DEIS acknowledges that roads can cause peak flow effects. The DEIS largely dismisses 

potential negative impacts on peak flows with reference to general measures of the amount of 

watersheds that are clearcut or roaded. This approach entirely fails to consider the critical factor of 

road-stream connectivity, which directly impacts on peak flows.” 

Forest Service Response:

The DEIS discloses the potential effects of past and proposed timber harvest and roads on streamflow

(DEIS pages 231- 233 and 238 to 241). 

The FEIS includes additional citations and discussion in support of the mitigating features of lakes 

and wetlands likely to buffer peak flow increases in the project area. Additional information has 

been added to the FEIS analysis, conclusions, and alternative comparisons with respect to peak flow 

increases. 

Road Condition Surveys

Commenter questions the accuracy of the Road Condition Survey (RCS) data used 

in the DEIS, and feels that there are critical data gaps in the road-stream crossing

data.

“Road Condition Survey Data is inadequate. The DEIS says transportation effects are based on Road 

Condition Surveys, which have only limited and often-times inaccurate data. It admits that field 

reviews have not been done, and says road-stream crossing data is still being obtained. This data gap 

is a critical omission that could be easily remedied.” 
Appendix D

Saddle Lakes Timber Sale Final EIS Response to Comments - Appendix D  463

“One problem is that the relevant database is not clear. The DEIS refers to an INFRA database, and 

RCS information, but those are not the same thing. It is not clear which is relied on, or which is kept 

up. It is not clear in the project record where this information could be found.” 

“While recognizing the data is flawed, the DEIS doesn’t give any reason why good data hasn’t been 

obtained before. Road condition surveys are simple and inexpensive and ought to be done...It is good 

that the DEIS at least recognizes this data is flawed. However that recognition is not carried over into 

effects analysis...It is a certainty however that, whatever the road condition was ten or twenty years 

ago, it will have developed new problems in the meantime. It should be assumed therefore, and 

disclosed in the EIS, that the RCS data understates the extent of road maintenance problems in the 

project area.” 

Forest Service Response:

The RCS in its original protocol design is no longer performed on the Tongass National Forest. The 

RCS protocol collected an extensive amount of baseline information on existing roads, along with a 

variety of road related items. These included sign and drainage structure inventories, road integrity 

evaluations, access, stream characteristics, fish presence and an assessment of fish passage capability. 

Field reviews of existing roads occur regularly. Field reviews of proposed road locations have also 

occurred. There is extensive stream data available for this area and additional stream surveys occurred 

for the Saddle Lakes EIS between 2012 and 2014. The original baseline RCS survey with the updates 

provides us with enough information to perform our analysis in the EIS and is sufficient to provide a 

credible estimate of the effects, comparison of alternatives, and support an informed decision. 

As described on page 337 of the DEIS, the original RCS database was uploaded into INFRA and is 

maintained in the INFRA database. RCS as a standalone database is no longer being used nor are the 

surveys being performed on the Tongass National Forest in its original protocol design. Road 

information can be found in the GIS databases located in the project record.

Road maintenance occurs on a rotational basis on remote road systems, as the need arises and funding 

allows. Road maintenance and road closures have occurred as recently as 2011 on the Shelter Cove 

road system. Informal road surveys occur each time Forest Service personnel, and sometimes the 

public, travel these roads and report back to the district engineers any new potential maintenance 

issue. These potential issues are then incorporated into the annual maintenance plan and are addressed 

as stated above.

Water Quality

Commenter requests an augmented discussion in the FEIS concerning discharge 

permits from the State of Alaska.

"We request that discussions concerning the EPA's National Pollutant Discharge Elimination 

System authority be augmented with information concerning the State of Alaska's authority to 

permit discharges under its Alaska Pollutant Discharge Elimination System program."

Forest Service Response:

The DEIS discusses Section 404 of the Clean Water Act on page 14. This information has been 

updated in Chapter 1 of the FEIS to better reflect the State of Alaska’s permitting authorities. 
Appendix D

464  Appendix D – Response to Comments Saddle Lakes Timber Sale Final EIS

Watershed Effects Analysis

Commenters question the validity of the watershed effects analysis conducted for 

the DEIS, and specifically question the “lack” of a cumulative effects analysis for this 

project.

“The Tongass National Forest uses a threshold of concern for cumulative watershed effects of 20 

percent of watershed basin area consisting of young-growth less than 30 years old. Watersheds at or 

exceeding this threshold may be experiencing increased peak flows and attendant sediment 

recruitment from stream channel erosion and bed scour. According to the DEIS (Table 90, Ch. 3, page 

240), of the sixteen 7th level HUC watersheds in the project area, only the Hidden Lakes watershed 

currently exceeds this threshold with 20.5 percent of the basin area harvested within the last 30 years. 

Implementation of the Saddle Lakes project would further increase the cumulative harvesting 

percentages above the threshold within this watershed and seven others, depending on alternative.” 

“Cumulative impacts on the aquatic environment need to be considered...The DEIS fails to fulfill 

NEPA’s mandate to consider cumulative effects. Effects and the aquatic environment are segmented 

and reduced to component parts, but those parts are never put back together again...Supplemental 

NEPA analysis should analyze the various factors together.” 

“The DEIS uses Grant (2008) for the proposition that more than 15 percent of watershed harvest can 

lead to effects on peak flow. However it is unclear whether this figure is being applied as a threshold 

for significance, or what its importance is. Please clarify this issue in the FEIS.” 

“The DEIS dismisses the [15 percent threshold] concern based on a few factors. It says that three of 

the watersheds don’t function as true watersheds— although this still doesn’t tell us whether or not 

peak-flow effects could be expected.” 

“...the remaining three, the DEIS says “only” two of them, Upchuck Cr and Rainbow Cr, are 

vulnerable because of steep headwater slopes draining into floodplains or palustrine channels. The 

other, it says, has wetlands that could buffer effects. Despite use of the word “only,” we feel that these 

stated effects are significant and deserve a closer look.” 

Forest Service Response:

The DEIS discloses cumulative effects of past harvest and roads in the Affected Environment section

beginning on page 231. These current effects are combined with potential effects of the Saddle 

Lakes Timber Sale in the Environmental Consequences section beginning on page 238 of the DEIS. 

The FEIS Aquatic Effects conclusions have been updated to respond to these comments. 

Watershed Data

Commenters had concerns related to project stream information and data gaps.

“The Forest Service has elected not to gather even basic information on the impacted watersheds, 

relying on general studies and effectiveness of BMPs. We challenge that basic premise, and point out 

here several datasets that should be gathered and included in further analysis.” 

“According to the DEIS, a huge amount of Class IV stream habitat is currently unmapped and 

unclassified...The failure to survey Class IV streams violates the TLMP. The Forest Plan requires the 

Forest Service to maintain and update stream inventories during site-specific project planning and 

analysis. The Forest Plan also requires recognition and consideration of stream classifications, 

channel classifications and process groups in planning management activities. Please explain how 
Appendix D

Saddle Lakes Timber Sale Final EIS Response to Comments - Appendix D  465

these standards and guidelines are being applied here, and conduct the inventories and analysis that 

are necessary to bring this project into compliance.” 

“A major flaw with the fish passage analysis is that it rests on out-of-date and incomplete surveys. 

The DEIS rests on Road Condition Surveys that were completed from 1995 to 2005. Streams and 

roads are dynamic. The situation nearly twenty years ago is not a reliable guide to the situation 

currently. The lack of updated information is especially puzzling because these surveys are simple 

and inexpensive to do. Please update Road Condition surveys and use them to inform the NEPA 

analysis.” 

“Given the increased level of harvesting that is being considered within these watersheds, (Table 90 

pg240) particularly within the Hidden Lakes and Upchuck Creek watersheds, channel condition 

assessments should be completed, not only for determining existing channel conditions relative to the 

amount of timber harvesting and road construction proposed for the Saddle Lakes project, but also to 

establish a baseline for future monitoring.” 

Forest Service Response:

The project area was first analyzed with existing data and then incorporated onsite data obtained from 

several years of intensive field surveys of all proposed units and road-stream crossings.

If we did miss any streams, we are confident that these are few in nature and will show to be very 

small ephemeral Class IV channels, or non-streams (seeps). Any remaining unmapped Class IV

streams will be documented and mapped prior to implementation. Forest Plan protection measures 

will be applied to these streams. Additional streams added to the data will make such a small

contribution to stream data as to not impact our analysis. With regards to fish streams, the USFS 

aquatics team classified all streams per Tongass stream classification guidance. In the event a new 

fish stream is discovered, appropriate protection measures will be applied and stream maps updated. 

The collection of baseline water quality data is not required for this project. Stream temperature and 

turbidity studies in the Tongass NF indicate that water quality in harvested and roaded areas is within

natural ranges (see Tucker and Thompson 2010 cited in Aquatics Resource Report). The application 

of BMPs will ensure the attainment of State water quality standards.

Page 224 of the DEIS acknowledges the possibility of discovering additional streams during 

project implementation and explains how they will be managed. The text in the FEIS has been 

clarified in response to this comment. 

Your request for channel condition assessments in Hidden Lakes and Upchuck Creek watersheds is 

noted; however, sufficient data was collected to complete our analysis and describes the potential 

impacts relating from this proposed project. Furthermore, the design measures described in unit and 

road cards in the project record, including the implementation of best management practices (BMPs) 

are expected to maintain water quality within standards established by the State of Alaska. 

The Tongass has a high rate of success with BMP implementation and effectiveness, as shown in 

Tongass National Forest, 2013 Annual Monitoring and Evaluation Report and other annual Tongass 

monitoring reports that can be found at http://www.fs.fed.us/r10/tongass/projects/tlmp/ 

See also responses to comments on Road Condition Surveys beginning on page 462. 
Appendix D

466  Appendix D – Response to Comments Saddle Lakes Timber Sale Final EIS

Botany

Commenters are concerned about project impacts to lesser round-leaved orchid 

(PLOR 4) and its habitat.

“In general, we are concerned that project impacts to PLOR 4 are inconsistent with TLMP goals and 

objectives for sensitive species and their habitats and for maintaining viable plant communities and 

populations.” 

“There is also considerable uncertainty about the abundance and distribution of the species [PLOR 4] 

and the validity of survey data. Further work on the EIS should clarify which units are affected, and 

include a map displaying known locations and suitable habitat. Also, the botany survey log was 

incomplete –we request that the final survey log show coverage of all units, including identification 

of suitable habitat.” 

“The cumulative effects analysis should provide a more thorough discussion about risks to PLOR 4 

associated with changes in solar radiation and hydrologic regimes and climate change.” 

Forest Service Response:

The known populations of lesser round-leaved orchid (PLOR 4) containing more than one individual 

are flagged in the project area. The area within the flagging is a zone of no harvest. This means that 

the areas where the plants reside will be directionally felled away from, and trees retained that form 

the canopy around the plants. Therefore, there is intent to protect the larger populations that are 

considered viable which contain flowering individuals. 

There have been 59 botanical surveys over 4 years in the project area, by professional Forest Service 

botanists. This is outlined in the Biological Evaluation (BE). Surveys are mapped in the NRIS 

database for this project. The 2011 survey log was created for one season by the botanist on KMRD. 

Forest Service botanists are not required to complete a survey log for each year; however, they are 

required to enter all surveys into NRIS to indicate where surveys were conducted. Additionally, most 

resource people are knowledgeable of what the PLOR 4 orchid looks like and alert botanists if they 

come across this species, or other unusual flora in the project area. The project area has four units 

that contain this orchid, which are fully identified in the Biological Evaluation for sensitive plants. 

Not all of the alternatives will contain all of these units. Because so few populations are in the 

project area and due to the sake of limited space in the EIS document, a map was not provided of the 

units where these plants reside, but are fully disclosed in the DEIS by unit number. As far as suitable 

habitat for PLOR 4 and other sensitive plants: The pre-field review for this project first consists of 

professional judgment as to which areas may contain sensitive species habitat for all the plants 

suspected in the area. The botanist prioritizes his or her survey route to cover as much area as 

possible at the proper time of year to detect flowering individuals or populations. A botanist uses 

many tools to identify possible suitable habitat for rare plants to survey, including resource maps of 

vegetation, geology, soils, and elevation. The most valuable tool for identifying suitable habitat is 

resource photography (1:15840) once a search image of potential suitable habitat is established. 

Compiling all these tools into one map product in the NEPA document is not a requirement of Forest 

Service policy, in particular for resources that are not identified as "significant issues". At this time, 

there are no peer-reviewed suitable habitat models for sensitive plants on the Tongass. 

The cumulative effects area for sensitive plants is ecologically driven and can be different for each 

species. It does not necessarily require the analysis of the entire range of the species in the planning 

area. A major consideration in cumulative effects analysis is the ability of the species to disperse, 

taking into account any barriers to dispersal. Additionally, the geology on Revillagigedo Island is 
Appendix D

Saddle Lakes Timber Sale Final EIS Response to Comments - Appendix D  467

different than Prince of Wales, and the distribution of PLOR 4 is also different between these two 

large islands. Genetically, the Revilla and POW populations may even be quite different due to the 

island biogeography of the archipelago with dispersal limitations across large water bodies. There 

are 71 populations documented of PLOR 4 on Revilla Island, consisting of approximately 435 plants. 

In the BE for sensitive plants it is stated: The consequences of adverse impacts to this plant due to 

project activities are moderate because these are the only known populations of this orchid on this 

side of Carroll Inlet. However, they are very small number of individuals on each population, so they 

are also threatened by stochastic events such as herbivores or landslides. The likelihood of adverse 

effects are low because design features recommend directional felling and yarding away from the 

locations where the plants grow. In addition, there are over 70 known populations of this orchid in the 

Cumulative Effects area of Revillagigedo Island. Therefore, the overall risk to this species due to

project activities is low. We do not have scientific information at this time that provides a threshold 

of individuals or populations that constitute a viable population of PLOR 4. However, with adequate 

protection measures of known populations, we consider that the risks are low to impacting the 

viability of this sensitive plant with this proposed project in the Cumulative Effects area.

The units which contain more than one individual of PLOR 4 have areas delineated on the ground 

with flagging for the layout crews, buffering the area with about 25 feet or more. These areas will

receive directional felling of trees outside the perimeter of the population away from the orchids, and 

the retention of the canopy where this orchid exists. Measuring possible habitat with GIS contains a 

low confidence value for determination of suitable habitat because the micro-habitat conditions and 

some of the macro-habitat conditions that this orchid and other species may require are not currently 

contained in a GIS layer to determine acreage extent of a certain habitat condition. For example, 

PLOR 4 is an orchid that requires a fungus for the seeds to germinate and grow. The presence of this 

fungus is not well understood or species known, let alone mapped to determine if PLOR 4 would 

germinate and grow in a certain location. The soils, timber type, or other unknown environmental 

factors vary too much in the occupied habitat of this orchid to be able to map with confidence the 

suitable habitat for this and other rare plants at this time. The best method is the botanist uses 

professional judgment to determine the areas where this orchid is known to grow based on experience 

in the field and using aerial photography to pinpoint survey areas. Equally important is for the 

botanist to survey areas that are not expected to be preferred habitat or areas that will not be disturbed

in the project activities.

In the BE for sensitive plants, the following is discussed for all sensitive plants known or suspected in 

the project area. Hydrology—Road building can alter the hydrology, as surface and ground water may 

be redirected and channelized by roadside ditches, altering the hydrologic regime. Increased water 

levels may result in the death or decline in vigor of plants not adapted to a high water table. 

Conversely, plants adapted to wetland conditions may become desiccated by a decrease in water 

availability. Light Levels—Partial or complete removal of the tree canopy results in an increase in the 

light levels in the understory, potentially resulting in light levels beyond the tolerance for shade 

dependent species. Once the stand regenerates, light levels will decrease with increasing canopy cover 

due to high density of small conifers. This too may alter normal light requirements for many species, 

including sensitive plants. As far as climate change, we are not directed to consider the effects of 

climate change on a particular plant in the NEPA process due to project activities. The BE addresses 

the possible impacts to sensitive plants due to the proposed action.
Appendix D

468  Appendix D – Response to Comments Saddle Lakes Timber Sale Final EIS

Climate Change

Several commenters feel that climate change should be treated as a significant 

issue within the NEPA analysis for this project, while some commenters question the 

reality of climate change.

“Chapter 3, page 219; This section should be amended to clarify that the carbon effects on the global 

warming/climate change hysteria are based on a hypothesis. If the Forest Service actually believes 

that a dramatic warming is imminent, then the worries about critical deer winter habitat should be 

minimized.” 

“We reiterate our scoping comments, which requested that the NEPA analysis consider the cumulative 

effects of logging, road construction and climate change as part of this analysis and uncertainties 

about climate change. Instead, the DEIS limited its cumulative effects analysis to a brief and incorrect 

statement about yellow-cedar decline and failed to assess the implications of the changing climate 

were relevant to project area resources and project impacts. [DEIS at 219, 223]. Every section of the 

DEIS, including timber economics, should have considered the impacts of our changing climate.” 

“We appreciate that the DEIS provided a discussion about greenhouse gas emissions associated with 

the project, but think that the analysis overly minimized the relevance of large scale logging projects 

by putting project impacts in the context of global emissions...As noted in our scoping comments, it is 

well-established that optimal carbon storage is best obtained by leaving both old and young-growth 

forests intact to the greatest extent possible.” 

“Stating that climate change is a non-significant issue when the Tongass is one of the world’s most 

significant carbon stores is almost unbelievable. The old-growth forests of Southeast Alaska store vast 

amounts of carbon and sequester more each year. The USFS should strive to fully understand the 

carbon fluxes of old-growth forests, so that their role and effect on global climate can be properly 

understood. The USFS needs to start monitoring and assessing the future impact of climate change, 

looking not just at the physio-ecological changes but also at the social implications.” 

Forest Service Response:

The Forest Service does not consider global climate change to be non-significant. The DEIS on page 

18 states: NEPA documents must concentrate on the issues truly significant to the action in question, 

rather than amassing needless detail (40 C.F.R. § 1500.1(b)). This ensures that the analysis and 

documentation is focused primarily on the issues related to significant or potentially significant 

effects and the decision to be made. 

The CEQ regulations direct the Forest Service to identify and eliminate from detailed study the issues 

which are not significant or which have been covered by prior environmental review (1506.3), 

narrowing the discussion of these issues in the statement to a brief presentation of why they will not 

have a significant effect on the human environment or providing a reference to their coverage 

elsewhere (40 C.F.R. § 1501.7(a) (3))" 

For example, while the total amount of stored carbon from the terrestrial ecosystems on the Tongass 

N.F., or globally may appear to be insignificant relative to that stored in the earth's oceans, the Forest 

Service has the federal requirement to display this information in our NEPA analysis if it is deemed 

useful. We concur that this information does not constitute a NEPA-defined ""significant issue"" for 

the decision maker to make an informed decision on the project as a whole and has therefore, not 

been presented as such. Agencies are encouraged to tier their environmental impact statements to 
Appendix D

Saddle Lakes Timber Sale Final EIS Response to Comments - Appendix D  469

eliminate repetitive discussions of the same issues and to focus on the actual issues ripe for decision 

at each level of environmental review (§ 1508.28). 

The DEIS acknowledges both the possibility and uncertainty of climate change and how the effects 

may occur at the project level. Climate change is a topic that continues to be studied throughout the 

agency, including the Tongass National Forest. While not all science agrees, the Forest Service is 

committed to using the best available science for the Pacific Northwest Coastal ecosystems to

evaluate trends and outlooks to regional climate change. It is generally accepted that greenhouse 

gases (GHGs) are impacting the Earth’s climate by warming the surface and the atmosphere, thus 

affecting current conditions of rainfall, glacier and sea ice retreat, and many other factors. To that end, 

the Forest Service and other federal agencies, non-profit organizations, and the science community in 

general, carry out numerous studies to better understand and quantify the effects of climate change.

The most recent science available for the Alaska region is from the Forest Inventory and Analysis 

(FIA) study on carbon stocks of overstory trees (USDA 2014). Prior to that publication, in 2012, the 

Forest Inventory and Analysis (FIA) program made numerous carbon storage estimates available via

online tools (FIA website) and prepared the first national assessment of the biomass and carbon 

attributes of down woody material (DWM) (USDA 2012). This information, combined with other 

science applicable to the Alaska Region is the basis for how we assess carbon stocks and approach 

our analysis of climate change (DEIS, Table 82, p. 221). Currently the Tongass has not conducted a 

formal climate change vulnerability assessment of terrestrial wildlife species, including deer;

therefore, our understanding of the possible effects of a warming climate on deer winter range is 

currently not fully evaluated. 

The referenced articles are from the Western Forester (September-October 2014), a trade journal 

discussing inputs and outputs of carbon in a forested ecosystem. The article, as a whole, supports 

the uncertainty of the effects of climate change discussed in the DEIS (chapter 3 p 218-223). This 

question continues to be approached differently depending on the methods used to calculate baseline 

carbon for any particular area. In 2013, the Forest Inventory and Analysis (FIA) program made 

numerous carbon storage estimates available via online tools (FIA website) and prepared the first

national assessment of the biomass and carbon attributes of down woody material (DWM) (USDA 

2012). A more recent publication (2014) by FIA provides carbon estimates for live trees. 

The Pacific Northwest Research Station soils and aquatic group continue to address the question of 

total carbon found on the Tongass N.F. This research takes into account not only above-ground 

carbon, but below-ground carbon, which for the Tongass N.F. comprises a major component of total 

carbon stocks since our forests are comprised of deep organic soils and thick organic duff layers. A 

recent publication entitled North Pacific Temperate Rainforests (University of Washington Press 

2013) includes a chapter prepared by PNW scientists Edwards and D’Amore on riparian ecology, 

climate change and management in North Pacific Coastal Rainforest. In this chapter, the authors 

discuss the organic carbon stored in Southeast Alaska ecosystems and the fate of stored carbon in 

headwater riparian zones, downstream deposit zones, the estuarine interface, and terrestrial-marine 

interactions. 

The Forest Service's "Climate Change Considerations in Project Level NEPA Analysis" (2009) 

provides guidance on the level of analysis required for project NEPA for addressing climate change 

NEPA documents. This document is available on the Forest Service public website at 

http://www.fs.fed.us/emc/nepa/climate_change/includes/cc_nepa_guidance.pdf and is considered the 

most current approved direction. For more detailed information on the effects of climate change on 

greenhouse gasses, carbon sequestration, and yellow-cedar regeneration; see the climate change and 
Appendix D

470  Appendix D – Response to Comments Saddle Lakes Timber Sale Final EIS

air resources report in the administrative record. This report goes into greater detail on these topics 

than the NEPA document. 

The Forest Service's "Climate Change Considerations in Project Level NEPA Analysis" (2009) states 

“It is not necessary to calculate greenhouse gas (GHG) emissions for most projects; however, in 

situations where the responsible official finds the information useful for decision making (i.e. 

meaningful), such data and conclusions developed through quantitative analysis would normally only 

be used for comparing alternatives related to direct effects or addressing any applicable regulatory 

requirements related to GHG emissions.” Therefore, we present the effects of climate change on 

GHGs qualitatively whereby we evaluate the relative differences of each alternative based on amount 

of logging and road building proposed. This document is available on the Forest Service public 

website at http://www.fs.fed.us/emc/nepa/climate_change/includes/cc_nepa_guidance.pdf. 

The Tongass is managing its timber and other resources in a manner that accounts for climate change 

by protecting 91 percent of the existing productive old-growth (2008 Forest Plan ROD, p. 21). This 

will provide a resilient ecosystem for plants and animals in the face of uncertain climate change 

(Forest Plan FEIS, p. 296). In its most recent report, the International Panel on Climate Change 

(IPCC) concluded ""[i]n the long term, a sustainable forest management strategy aimed at 

maintaining or increasing carbon stocks, while producing an annual yield of timber, fiber, or energy 

from forests, will generate the largest sustained mitigation benefit"" (IPCC 2007). There is nothing to 

indicate that the Saddle Lakes project area, and the Tongass as a whole, is being managed in a manner 

contrary to the IPCCs findings. 

Additionally, there are other studies happening regionally and nationally addressing climate change. 

For example, ongoing work to develop a dynamic conservation strategy for the long term survival of 

yellow-cedar in Southeast Alaska serves as an example (Hennon et al 2012). Yellow-cedar decline is 

thought to be caused, in part, by a changing climate, and specific actions have been implemented at 

the project level to address yellow-cedar decline.

While there is general agreement among scientists that the climate is warming, there is considerable 

uncertainty concerning the exact effects of climate change on the forests of Southeast Alaska and how 

best to deal with possible changes to the many resources on the Tongass. The state of current 

knowledge and the uncertainty about specific effects of climate change, gives us no reason to believe 

that the Saddle Lakes Timber Sale will exacerbate climate change or its effects. We believe the 2008 

Forest Plan provides for resiliency in the face of uncertain but anticipated change, and ongoing 

studies and models will improve our ability to quantify and predict these changes. Given the 

uncertainties about climate change and its effects on forest ecosystems, policy makers and forest 

managers are reluctant to make decisions or use forest resources to implement adaptation measures 

for forest conservation and management. Hennon, et al (2012) contend that more systematic 

investigations that produce well-documented explanations of climate effects on forest ecosystems are 

needed in order to build the necessary confidence for policy makers and forest managers to intervene.

Alaska Region 10 and the Tongass National Forest monitor potential effects of climate change 

through the existing Forest Plan monitoring programs, and other studies that are happening regionally 

and nationally. In addressing the effects of climate change, there are programs monitoring changes 

related to insects, disease, pathogens and windthrow and the long-term forest inventory system. If 

effects from climate change are detected, they will be addressed through existing planning procedures 

to determine whether changes in management are warranted.

The Tongass is also in the process of organizing a scenario planning effort with key stakeholders, to 

include relevant scientists and other agency personnel, business /community leaders and internal 
Appendix D

Saddle Lakes Timber Sale Final EIS Response to Comments - Appendix D  471

personnel to identify key resources at risk and assessment needs. This effort will provide information 

on the risks and range of change for key resources and prioritize climate-change related issues and 

needs across Southeast Alaska.

The Forest Plan and the Saddle Lakes DEIS acknowledge that forests in Alaska are considered to be 

carbon ‘sinks’ meaning that stands accumulate more carbon than they release. The rapid regeneration 

of trees following timber harvest removes atmospheric carbon from the system. 

When considering the varying degrees of forest site conditions, the lifecycle of wood products, and 

the substitution effect of using wood products over other materials, the point of equilibrium in the loss 

or gain of carbon following old-growth harvest is subject to much uncertainty. “There are many 

factors that affect sequestration and storage; some components of an alternative contribute to a net 

removal of carbon, while some components offset those gains” (Forest Plan FEIS p. 3-17). For the 

purpose of the Saddle Lakes climate change analysis, it is assumed in the short term, that ‘harvesting 

forests with high biomass and planting new forest reduces overall C stocks more in the near term than 

if the forests were retained, even counting the C storage in harvested wood products.’” (Vose et al 

2012). In analyzing climate change among resources in the Saddle Lakes DEIS, fifteen referenced 

documents were used. Carbon Storage is analyzed on page 218 in the Climate Change section. 

Inventoried Roadless Areas

Commenter has questions related to the inventoried roadless area analysis in the 

DEIS, specifically the “zones of influence.”

“Chapter 3, page 269~ The "zones of influence" and roadless discussion is disturbing. It is bad 

enough that the federal government is ignoring ANILCA and is welshing on the 2003 Settlement 

Agreement that exempted Alaska from the roadless rule, but to add a large buffer zone around the 

roadless areas simply worsens the harm done to the timber industry and the communities in Southeast 

Alaska. Please drop this zone concept and fix the error the Forest Service made in implementing the 

2003 Settlement Agreement so that the promises of ANILCA and NFMA and TTRA can be honored.” 

Forest Service Response:

The "zone of influence" is not a buffer zone applied to an inventoried roadless area (IRA). Rather, 

the "zone of influence" describes an area of 600 feet surrounding harvest units, and 1,200 feet 

surrounding roads, thought to experience indirect or cumulative effects from implementation 

activities. Therefore, when a proposed unit is within 600 feet, or a proposed road within 1,200 feet 

of an IRA boundary, timber harvest or road construction activities could cause some indirect effects, 

such as sights and sounds of construction and harvest activities, to that portion of the IRA 

intersecting the "buffer". In order to adequately analyze indirect effects to roadless, these 1,200 and 

600 foot buffers were necessary because areas near roads and harvest units could be indirectly 

nfluenced by development. CEQ requires disclosure of indirect effects (40 CFR §1508.8(b) and 

§1502.16 (b).

When considering cumulative effects, the timeframe is extended to include past, present, and

reasonably foreseeable activities. The geographic area is extended for the cumulative analysis to

include the area that could be affected and the area where activities that might affect resources occur.

Overlapping zones of influence and the incremental contribution of the proposed activity also are

evaluated in the cumulative case. 
Appendix D

472  Appendix D – Response to Comments Saddle Lakes Timber Sale Final EIS

NEPA/Forest Plan/General Analysis

Alternatives

Commenters had various suggestions and comments related to the alternatives 

analyzed in the DEIS. Comments ranged from support of the No-action Alternative, 

questions about Alternative 4 (the environmentally preferred alternative in the DEIS), 

and support for alternatives offering the most volume; to the development of 

alternatives to address “high grading,”, the removal of Pacific Silver Fir, no new road 

building, and microsales.

“Alternative 4 is identified as your environmentally preferred alternative. At page 29 you tell the 

public the alternative violates the Forest Plan Scenery Standards and Guidelines and would require a 

FP amendment to be implemented. “ 

“The commenter supports this timber sale and prefers Alternatives 4 and 6, but particularly 

Alternative 5 for maximum harvest.”

“..Instead, the project has ballooned from the 33 million board feet mentioned in the project’s scoping 

letter to nearly twice as much in the maximum alternative in the DEIS, and with no alternatives 

provided for a small project we asked for as an alternative to the proposed purpose and need.” 

“The commenter requests that the FEIS Analyze an Alternative in Detail that does not Construct or 

Reconstruct any New Roads.” 

“The commenter considers alternative 3 as the best option, as mentioned in the DEIS it maintains the 

connectivity between habitat and landscape, minimizing its negative impacts on the wildlife. 

Alternative 1 (no action) should not be considered since it would not help the local economy in any 

way. Alternatives 2, 4, 5 and 6 have the largest effect on wildlife habitat and scenic integrity which I 

believe will largely affect the potential for fishing and tourism industries in the Tongass National 

Forest.” 

Forest Service Response:

Commenters had a variety of comments related to the alternatives present in the Saddle Lakes DEIS. 

The DEIS was prepared to meet CEQ guidelines and the 2008 Forest Plan, and the DEIS provides a 

reasonable range of alternatives as defined in 40 CFR § 1501.1 Each of the five action alternatives 

were designed to respond to the purpose and need of the project, which is: to provide a reliable, 

economic supply of sawtimber to meet market demand, support employment and benefit local and 

regional economies. 

Using a systematic approach for analyzing the effects (both beneficial and adverse) of alternatives 

and incorporating relevant Forest Plan goals and objectives, the interdisciplinary team (IDT) 

comprised of 29 individuals assessed the existing conditions in the Saddle Lakes project area,

analyzing 18 resources and considering five action alternatives each with an area of emphasis that 

examined identified issues and cumulative effects. You can refer to the section in the DEIS regarding 

alternatives considered but eliminated on pages 24 and 25; and the alternative development section on 

page 23. 

“No roads” does not meet the purpose and need for this project or the goals and objectives described 

in the Forest Plan. Construction of new road increases volume available for timber sales of varying 

sizes including micro sales and small sales. The volume of timber accessible from existing roads is 
Appendix D

Saddle Lakes Timber Sale Final EIS Response to Comments - Appendix D  473

limited and does not provide sufficient opportunities for timber sales of varying size and complexity. 

It also does not meet the need for a long-term, stable supply of timber for local operators. 

Alternative 4 is not an "environmentally preferred alternative"; rather it is identified as the alternative 

that best addresses Issue 1, Timber Economics and Issue 2 Timber Availability. The environmentally 

preferred alternative will be identified in the Record of Decision for the Saddle Lakes Timber Sale 

FEIS in accordance with 40 CFR §1505. 2 (b). 

The effects to wildlife, fish habitat, rare and sensitive plants and other affected resources are 

addressed by resource area in Chapter 3 of the DEIS on pages 51 through 360. Specifically, 

transportation effects to fish habitat is discussed in detail in both the Transportation (page 336) and 

Aquatics (page 224) sections of Chapter 3 in the DEIS. Potential to improve fish habitat is also 

identified among opportunities in the purpose and need (Chapter 1, page 6) and removal of partial 

barriers to fish passage is discussed on p 26 of the DEIS. Aquatic habitat was identified as a nonsignificant issue or concern (Chapter 1, pg. 19). Please also refer to the Aquatics section in Chapter 

3, which states that Alternative 5, with the greatest amount of road construction, would not produce 

measurable amounts of sediment or turbidity. See also response to Temperature/Sedimentation on 

page 458 of this Appendix. Rare and Sensitive Plant Species are discussed in Chapter 3, page 293 

and is a component of the emphasis area of Alternative 2 (proposed action). 

Consideration of Public Comments and Submitted Literature

Commenter questions how the Forest Service is responding to public comments and 

submitted literature, as well as questions the use of “best science” within the NEPA 

analysis for this project.

“The commenter requests that the FEIS explain why the recommendations of over 500 Ph.D. 

scientists represented in Opposing Views Attachments #1 and #10 aren’t applicable to the Saddle 

Lakes sale area.”

“The commenter requests that the Responsible Official respond to comments and "allow the public to 

read your responses they don’t know if their comments were read and considered."

“The commenter states that a single response attempting to deal with all opposing views 

simultaneously does not respond to opposing views as required by law.” 

“The commenter requests that the FEIS Include the source literature for particularly relevant science 

quotes contained in the Opposing Viewpoint Attachments in the References section of the final EIS 

and cite the quotes contained in the attachments in the body of the final EIS and includes benefits and 

drawbacks of project implementation.” 

“The majority of your references are biased, since they were authored by forest service employees.

Even random selection of science literature related to logging would have included several of the 

hundreds of science documents contained in the Opposing Views Attachments. To offer the Saddle 

Lakes timber sale in spite of the scientist’s conclusion ignores best science”
Appendix D

474  Appendix D – Response to Comments Saddle Lakes Timber Sale Final EIS

Forest Service Response:

The body of the EIS should be a succinct statement of all the information on environmental impacts 

and alternatives that the responsible official needs in order to make an informed decision, to ascertain 

that every significant factor has been examined, and to inform the public. 

Elements incorporated into the DEIS and FEIS address 40 CFR 1500.4 (b) Preparing analytic rather 

than encyclopedic EISs; 40 CFR 1500.4 (c) Discussing only briefly issues other than significant ones; 

40 CFR 1500.4 (f) Emphasizing the portions that are useful to decision makers and the public and 

reducing emphasis on background material; 40 CFR 1500.4 (g) ...deemphasize insignificant issues; 

40 CFR 1502.2 (b) Impacts shall be discussed in proportion to their significance, and include only 

brief discussions of non-significant issues. The environmentally preferred alternative will be 

identified in the Record of Decision for the Saddle Lakes Timber Sale FEIS in accordance with 40 

CFR §1505. 2 (b).

An EIS is required to explain or summarize methodologies of research and modeling, and the results 

of research that may have been conducted to analyze impacts and alternatives. Lengthy technical 

discussions are best reserved for an appendix or the project record. In other words, if only technically 

trained individuals are likely to understand a particular discussion, then it should go in the appendix 

or project record, and a plain language summary of the analysis and conclusions of that technical 

discussion should go in the text of the EIS. 

The analysis for this project was performed by an interdisciplinary team (in accordance with 40 CFR 

§§ 1502.6 and 1507.2) comprised of 29 individuals representing 13 disciplines whose specialties 

and credential are summarized on page 361 of the DEIS. 

The Saddle Lakes DEIS is tiered to the 2008 Forest Plan, and in addition references over 460 peerreviewed documents and site specific studies (see reference list beginning on page 370). All 

supporting documents related to this EIS, including public comments, references, and literature 

submitted by the public can be found in the project record, which is available upon request. 

Comments, and the Forest Service responses to those comments are a part of the project record , 

which is available for public review upon request, and are part of the FEIS in accordance with 40 

CFR § 1505.1 (c and d). 

The “Opposing Views Attachment #10” referenced by a commenter is a collection of 16 polls. Links 

are provided to the polls, but data found on the website is limited and left open to interpretation with 

only summary numbers provided and no demographic specifics. Of the polls, only eight involve 

western forests, and none are specific to Alaska. 

Document Corrections/Map Request

Commenters had questions or map requests based on their review of the DEIS.

“The commenter requests that the FEIS include data, text and maps demonstrating that protection is 

provided for streams, stream-banks, lakes, wetlands, and other bodies of water from detrimental 

changes in water temperatures, blockages of water courses, and deposits of sediment.” 

“In closely comparing the Fig. 7 map to the maps of the alternatives, we note that many of the second 

growth patches do not match-up in size or shape with the white areas on Fig. 7. This prevents reliably 

assessing where corridors exist and should be preserved. Also, Fig. 7 does not explicitly disclose the 

locations of second growth. Its white areas apparently include non-productive forest and non-forest. A 
Appendix D

Saddle Lakes Timber Sale Final EIS Response to Comments - Appendix D  475

further difficulty is that on the alternative maps the shading for second growth is so pale that it is 

difficult to distinguish from the color of the paper. Finally, comparing Google Earth imagery to the 

Fig. 7 map and the alternative maps shows that the mapping of second growth is inaccurate on all the 

maps.” 

“...we request that the omission of the (-) on page 33 under the Alternative 3 column, Black Bear 

Habitat-Historic POG Within 500-feet of Class I Fish Streams, be corrected.” 

“Under the Employment section the measures are “Total Jobs Estimated (Current R10 Policy)” and 

“Limited Export Policy & Domestic Processing.” Are these labels correct?” 

Forest Service Response:

Thank you for helping us identify editorial errors and information that would benefit from 

amendment or clarification. Please refer to the introductory section of the FEIS entitled ‘Changes 

Between the DEIS and FEIS’ for a narrative of edits that have been made.

Aquatics survey data can be found in the project record, maps and additional information can be 

found in the Aquatics Resource Report. Chapter 3 of the DEIS states the existing conditions and 

discloses the direct, indirect, and cumulative effects of the action alternatives. The road and unit 

cards located in the project record and on the project website give site-specific protection measures. 

With regards to Figure 7, SDM is a corporate ARC/MAP GIS layer and was used electronically by the 

project wildlife biologist to facilitate zooming to multiple scales. All map areas may not align 

between maps due to differences in scale. Maps of resulting POG and Interior POG by alternative are 

included in the Wildlife Resource Report Figures 14 - 27. A map can be included in the project record 

for the FEIS. 

The table should show -21.1 percent for Alternative 3. This is correct in the bear cumulative effects 

section of the Wildlife Resource Report. It will be corrected in the FEIS. 

Insufficient Information/Analysis 

Commenter felt that the DEIS did not meet NEPA requirements in relation to 

providing information to the reader, scope of analysis, or disclosure of impacts.

The commenter requests that the “FEIS discuss energy requirements and conservation potential of 

various alternatives and mitigation measures.” 

“The commenter requests that the FEIS discuss urban quality, historic and cultural resources, and the 

design of the built environment, including the reuse and conservation potential of various alternatives 

and mitigation measures.” 

The commenter requests that the “FEIS discuss means to mitigate adverse environmental impacts (if 

not fully covered under §1502.14(f)). [43 FR 55994, Nov. 29, 1978; 44 FR 873, Jan. 3, 1979].” 

The commenter requests that the “FEIS 1) remove all of the goals and objectives on pages 4 and 5 

describing the need to log. OR 2) offer the sale as an SBA sale, OR3) include the following papers: 

"The Economic Impact of Trails-Forest Recreation’s Growing Impact” and “Seeing Forests for their 

Green: Economic Benefits of Forest Protection, Recreation, and Restoration”, “The Economic 

Impact of Preserving Washington’s Roadless National Forests” in their entirety in an Appendix to the 

NEPA document: The Economic Impact of Preserving Washington’s Roadless National Forests” in 

their entirety in an Appendix to the NEPA document.” 
Appendix D

476  Appendix D – Response to Comments Saddle Lakes Timber Sale Final EIS

Forest Service Response:

The Climate Change section in Chapter 3 of the FEIS addresses energy use in relation to 

greenhouse gas emissions. 

Energy (fuel) would be required to perform management activities proposed in all action alternatives, 

including but not limited to: harvesting and transportation of timber products, road reconstruction 

activities, road decommissioning and storage and fish barrier modification. The proposed project 

would not involve construction or maintenance of any new facilities. Overall, energy requirements for 

the project are relatively minor. The activities for the project involve a short-term and non-significant 

expenditure of energy and do not lend themselves to particular energy conservation measures. 

This project does not have an urban and built environment component, and the historic and cultural 

resource effects, and applicable mitigation, are discussed in the appropriate sections of the FEIS and 

ROD.

A commenter’s request to remove the goals and objectives describing the need to log is not 

consistent with the purpose and need for the project. The No-action Alternative addresses the 

commenters request for no logging. 

Issues

Commenter feels that “aquatic habitat” should be considered an issue within the 

NEPA analysis for this project.

“The DEIS considers aquatic habitat a “non-significant” issue, and does not predict any significant 

effects to aquatic habitat. Given the high importance of aquatic habitat to the local economy and 

environment, and the cumulative effects on that habitat, aquatic habitat should be considered a 

significant issue.”

Forest Service Response:

The DEIS discusses direct, indirect, and cumulative effects to aquatic habitat on pages 238 to 252 of 

the DEIS. Aquatic habitat was not considered a significant issue because Forest Plan Standards and

Guidelines and best management practices (BMPs) will be implemented to mitigate and reduce 

effects to the aquatic ecosystem. The rationale for aquatics being a non-significant issue can be found 

on page 19 of the DEIS. 

Monitoring

The commenters have various, specific, recommendations related to monitoring for 

this project.

“We recommend that the final EIS contain information that clearly identifies Forest Service resources 

for monitoring and enforcement, as recommended by the Council on Environmental Quality's 

Memorandum on Appropriate Use of Mitigation and Monitoring, January 14, 2011. We believe that 

robust implementation and enforcement of the standards and guidelines, best management practices, 

and mitigation measures identified in Appendix C is necessary to ensure that predicted impacts are 

accurate and that mitigation is adequate.” 

“An adaptive management strategy should be included in the Final EIS and adopted in the Record of 

Decision to allow the Forest Service to quickly change mitigation efforts if monitoring reveals that 

the mitigation is not fully successful.” 
Appendix D

Saddle Lakes Timber Sale Final EIS Response to Comments - Appendix D  477

“The project should include management of the area after the logging has been completed to ensure 

that any negative impacts on the surrounding area are kept as low as possible. I think that more 

information addressing this issue should be included in the EIS.” 

Forest Service Response:

The Saddle Lakes Timber Sale is tiered to the 2008 Forest Plan in accordance with 40 CFR 

§1508.28. The Timber Sale Program Adaptive Management Strategy can be found on P 64-66 of the

2008 Forest Plan ROD. 

BMP and Forest Plan Standards and Guidelines implementation monitoring is required and continues 

to occur throughout the Tongass. Appendix C (p.444) of the DEIS lists all standards and guidelines, 

BMPs, mitigation and monitoring for all alternatives. The FEIS will identify what Forest Service 

resources will be monitored and what mitigation measures will be implemented based on the 

alternative selected. 

An annual monitoring report is done for the Tongass and can be found on the public website at 

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

Decommissioned temporary roads are monitored in conjunction with their associated units. The 

annual BMP monitoring plan is determined after the units are harvested and cannot be predetermined 

at the time of the FEIS. However, monitoring will occur as part of the Tongass monitoring program. 

NEPA Cumulative Effects Analysis 

Commenters felt that the cumulative effects analysis for this project was not 

conducted properly, and omitted items, such as the Alaska Mental Health Trust land 

exchange (AMHT), and the Shelter Cove Road, from consideration.

“In all sections of this EIS, please incorporate an understanding of the range of different types of 

cumulative effects. The DEIS unfortunately treats cumulative effects analysis as a simple matter of 

addition: predicted effects of the proposed action, plus effects from other projects. Please consider all 

of these sorts of cumulative effects: time crowding, space crowding, compounding effects, 

thresholds, and nibbling.” 

“The DEIS failed to fully incorporate the ongoing development of the AMHT land exchange and 

Shelter Cove Road into the analysis. The impacts of the land exchange in particular –right in the 

middle of the project area –significantly changes the cumulative effects of the project with regard to 

nearly every resource issue, from wildlife to timber availability and supply to scenery to watersheds 

to public recreation and subsistence resource access...The omission was so substantial as to preclude 

meaningful analysis, requiring a revised DEIS...NEPA requires that you consider all “connected 

actions,” “cumulative actions,” and “similar actions” in determining the scope of an environmental 

impact statement.” 

Forest Service Response:

CEQ (40 CFR § 1508.7) provides a definition by which cumulative effects are analyzed in federally 

prepared NEPA documents: Cumulative impact is the impact on the environment which results from 

the incremental impact of the action when added to other past, present, and reasonably foreseeable 

future actions regardless of what agency (federal or non-federal) or person undertakes such other 

actions. Cumulative impacts can result from individually minor but collectively significant actions 

taking place over a period of time.
Appendix D

478  Appendix D – Response to Comments Saddle Lakes Timber Sale Final EIS

Effects and impacts as used in these regulations are synonymous (40 CFR 1508.8). Effects includes 

ecological (such as the effects on natural resources and on the components, structures, and

functioning of affected ecosystems), aesthetic, historic, cultural, economic, social, or health, whether

direct, indirect, or cumulative. Effects may also include those resulting from actions which may have 

both beneficial and detrimental effects, even if on balance the agency believes that the effect will be 

beneficial. There is no CEQ requirement to have a "range of different types of cumulative effects".

Spatial, temporal aggregative and incremental effects are types of effects that are included by

inference in the above definition, and consistent with CEQ. 

Each resource in Chapter 3 includes an explanation of effects and the level and type of effects (direct,

indirect, cumulative) in proportion to their level of significance (40 CFR § 1502.1) that can be 

reasonably expected to occur and referring the reader to Appendix B (see page 282 for an example). 

Appendix B (page 421) describes all known or reasonably foreseeable projects that would be 

considered in the cumulative effects analysis for this project. 

Neither the AMHT Land Exchange nor the Ketchikan to Shelter Cove Road project is considered a 

connected action (40 CFR § 1508.25(a) (1)) with the Saddle Lakes Timber Sale. There is no 

interdependency and any of the three projects may move forward, or cease without impacting another. 

However, the CEQ is clear that based on proximity, type and other factors, these projects are within 

the scope of the Saddle Lakes Timber Sale under (a)(2) cumulative actions, and should be considered 

in the analysis for the Saddle Lakes Timber Sale. To that end, each project has been analyzed in this 

DEIS based on known and reasonably assumed possibilities as having cumulative effects.

The Alaska Mental Health Trust Authority (AMHT) proposed (in 2009) an administrative land 

exchange with the USDA Forest Service that includes lands nearby the project area. The proposed 

exchange is in development with an unknown timeframe and outcome. During development of the 

Saddle Lakes FEIS, the exchange had not yet been approved to proceed toward the NEPA analysis. 

There is no proposed action nor identified alternatives. The IDT, using the AMHT website and other 

records made reasonable assumptions; including clearcutting lands potentially exchanged, as to 

potential outcomes should the exchange occur. These assumptions were used in analyzing 

cumulatively the effects of both the exchange and timber sale. If agreed upon, completion of the 

AMHT land exchange would require its own NEPA analysis as described in 40 CFR § 1500 and 

consider in its own analysis the effects of the Saddle Lakes Timber Sale.

Cumulative effects analysis for recreation did consider the proposed AMHT land exchange (page 

214). This analysis states that the proposed exchange is likely to affect recreation opportunities: 

current AMHT public use policy is non-commercial, non-motorized, and day use only which would 

be a change from what is currently allowed by the Forest Service. The exchange would also reduce 

semi-primitive motorized and semi-primitive nonmotorized opportunities in the project area. 

The Ketchikan to Shelter Cove Road project is being undertaken by the State of Alaska in cooperation 

with the U.S. Army Corps of Engineers. Planning for this project has been ongoing since at least 2004 

when the project was identified as part of the State's 2004 Southeast Alaska Transportation Plan. Parts 

1500 through 1508 of 40 CFR provide regulations applicable to and binding on all Federal agencies 

[emphasis added] for implementing the procedural provisions of the National Environmental Policy 

Act of 1969, as amended (Pub. L. 91–190, 42 U.S.C. 4321 et seq.) (NEPA or the Act) except where 

compliance would be inconsistent with other statutory requirements. Analysis carried out for the road 

project, in order to meet federal standards must meet these requirements. 40 CFR § 1506.5 (a) 

(Agency Responsibility) directs agencies that “work not be redone, but verify (ied)” by the agency. 

The Forest Service, as the land manager of portions of the proposed road, is part of that planning 

process and directed under § 1506.5 (a) to review that analysis, when complete. 
Appendix D

Saddle Lakes Timber Sale Final EIS Response to Comments - Appendix D  479

Even though no alternative or financial analysis includes overland transport of timber out of the 

project area, the road project is "reasonably foreseeable" and its proximity to and timing (40 CFR § 

1508.7) of the Saddle Lakes Timber Sale project.

Old Growth Reserves (OGRs)

Commenters had various comments and concerns regarding relocating an OGR, 

and the effects of road building within an OGR, as proposed in the DEIS.

"The proposal to put new road through an OGR is inconsistent with the Forest Plan, and should not 

be approved. According to the DEIS, the ROW would involve 0.3 miles of road in OGR 7470, in 

violation of the TLMP S&G. Under this provision, road should not be built through OGR unless there 

is no feasible alternative. The DEIS doesn’t give any reason why there aren’t feasible alternatives."

"The Forest Plan is a contract with the public. NFMA contains a process to amend the forest plan 

for individual projects to maintain ecological integrity of the area if conditions had changed since 

the forest plan went into effect. Amending the Forest Plan to allow resource damage to occur in 

order to make it possible for you to implement a commodity output project with no ecological 

benefits is unacceptable to the vast majority of Americans."

"We disagree that the ROW would have “minimal effect on wildlife habitat.” To the contrary, the 

road link alone would appear to threaten viability of wolves."

"Relocating the OGR in VCU 7470 would reduce the volume of old-growth habitat in the project 

area and conflict with USFS Old-Growth Habitat LUD goals and objectives."

Forest Service Response:

The proposed road in the existing small OGR is not in violation of the Forest Plan. Although new 

road construction is generally inconsistent with old growth habitat LUD objectives, new roads may be 

constructed if no feasible alternative is available (Forest Plan. p. 3-61)." 

This road is identified in the Alaska Department of Transportation and Public Facilities (AK DOT & 

PF) Southeast Alaska Transportation Plan and is identified in the Forest Plan as a Transportation and 

Utility system (TUS) overlay LUD. A discussion related to feasible alternatives for locating this road 

is included in the Wildlife Resource Report (p. 1). This discussion states “Topography, including 

deeply incised drainages, may preclude alternative locations. Road survey engineers were aware of 

the restriction and spent considerable time attempting to avoid the OGR. The road was moved out of 

the OGR as much as feasible. However, topography prevented alternative road locations.” 

The Roadless OGR proposed under Alternative 5 in the DEIS would not include any miles of road 

within the OGR boundary and would increase the separation between the road and OGR. Under this 

alternative, the Roadless OGR would be more isolated from the new road construction and existing 

roads and reduce disturbance to wildlife and effects to important wildlife habitat associated with the 

OGR. 

The 2008 Forest Plan, Chapter 5 provides direction related to Forest Plan amendments. Nonsignificant changes to the Forest Plan can result from the following (Forest Plan p. 5-3) and require:

1. Actions that do not significantly alter the multiple-use goals and objectives for long-term land

and resource management.
Appendix D

480  Appendix D – Response to Comments Saddle Lakes Timber Sale Final EIS

2. Adjustments of management area boundaries or management prescriptions resulting from

further on-site analysis when the adjustments do not cause significant changes in the

multiple-use goals and objectives for long-term land and resource management.

3. Minor changes in Forest-wide Standards & Guidelines.

4. Opportunities for additional projects or activities that will contribute to achievement of the

management prescription.

The Responsible Official has the discretion to determine whether and how to amend the Plan (36 CFR 

§ 219). Forest Plan Amendments that affect the acres of POG in non-development LUDS, including

the Old-growth Habitat LUD, are monitored as part of Forest Plan Monitoring and these impacts are 

evaluated every 5-years to determine if changes in management direction are necessary. 

While relocating the OGR will reduce the total acres and acres of POG located within the OGR, it 

still exceeds the minimum acreage required under 2008 Forest Plan Old-Growth Habitat LUD goals 

and objectives. 

The Responsible Official can modify a proposed action or alternatives as the analysis progresses as 

long as the analysis is done collaboratively and it is clear and obvious to anyone interested (DEIS 

p.7). It must also be properly documented (36 C.F.R. § 220.5 (e) (1)). Modifications to the proposed

action are discussed and documented in Chapter 2. The amendments proposed in the DEIS are 

discussed in the Decision Framework (p.10), under Issue 2 Timber Availability (p.16) and are 

analyzed throughout the document by affected resources under Alternatives 4, 5 and 6. 

The Ketchikan to Shelter Cove Road right-of-way (ROW) is an administrative action. The Wildlife 

Resource Report (p. 1) states that an estimated 9 acres of ground disturbance would occur within the 

ROW which is minimal compared to the scale of WAA 407. Impacts of the road connection related to 

wolves is discussed under Cumulative Effects on page 124 of the DEIS and additional discussion 

from the Wildlife Resource Report (wolf section p. 56-70) is provided below. 

Person (2006) updated the relationship between road density and wolf mortality related to 

legal and illegal hunting and trapping. Results indicated that the probability of overkill was 

40 percent for WAAs with total road density greater than 0.7 mile per square mile if the 

WAA is connected to a main road system, but 13 percent if the roads were not connected to 

a community or ferry. Therefore, results indicated that roads exerted a strong influence on 

wolf mortality, particularly when connected to main road systems. Wolf mortality from road 

density has not been an issue for the Saddle Lakes area since Saddle roads are not connected 

to a community (13 percent probability of overkill from above relationships). The Ketchikan 

to Shelter Cove Road would increase the open and total road miles in WAA 407. Total road 

densities in WAA 407 would equal 1.0 miles per square mile under all action alternatives. 

While wolf mortality has not been identified as a concern in the past, completion of the 

Ketchikan to Shelter Cove Road could lead to wolf mortality concerns in the future. Using 

the regression information from Person (2006), the probability of overkill (i.e., 

unsustainable harvest) of wolves would increase from 13 percent to 40 percent with 

completion of the Ketchikan to Shelter Cove Road. 

Current Forest Plan Standards and Guidelines (USDA 2008c, WILD1.XIV, p. 4-9) states that 

total road densities of 0.7 to 1.0 mile/mi2 or less may be necessary to address mortality 

concerns. Road density effect on wolf mortality has not been an issue in WAAs 406 and 407 

in the past due to the lack of road connection to a community. 
Appendix D

Saddle Lakes Timber Sale Final EIS Response to Comments - Appendix D  481

It is uncertain what, if any, regulatory changes on wolf harvest limits would occur given 

the State of Alaska’s intensive management goals for GMU 1A and/or the 90-day finding 

on wolves by USFWS. 

Wolf populations within GMU 1A are currently thought to be stable with unlimited 

trapping allowed. Regulatory processes are currently in place to deal with human caused 

mortality. There are currently no restrictions on the number of wolves that can be trapped 

in either WAA 406 or 407. 

Purpose and Need

Commenters feel that the purpose and need, as written, is too narrow to provide for 

a reasonable range of alternatives.

“The Purpose & Need is written so narrowly that it excludes all alternatives that do not log the area. 

This includes alternatives suggested by the people you supposedly serve by placing them in the 

“Alternatives considered but eliminated from detailed study.” 

The commenter requests that the FEIS include a new (expanded) purpose and need that allows 

reasonable alternatives to the Proposed Action to be analyzed in detail. This purpose and need must 

describe goals that can be achieved at different levels by different actions ... specifically actions that 

don’t include timber harvest. If this cannot be done, the timber harvest purpose and need goal must be 

totally eliminated.

"Indeed, there are other needs identified in the purpose and need that could be satisfied without 

commercial logging. In fact, commercial logging will exacerbate these amenity resource 

problems. The current purpose and need forecloses on these other “Reasonable Alternatives.”" 

Forest Service Response:

The CEQ regulations require agencies to “briefly specify the underlying purpose and need to which 

the agency is responding in proposing the alternatives including the proposed action” (40 CFR 

1502.13). Other resources are not mentioned in the purpose and need as there is no requirement in the 

CEQ regulations (40 CFR 1500-1508) or NEPA (42 U.S.C. 4321 et seq.) to include a broad array of 

considerations, or activities as the commenter suggests. Rather, analysis of the effects to the human 

environment (40 CFR 1508.08 and 1508.14) by the proposed action and alternatives, are consolidated 

in discussions of issues and resources impacted by the project (40 CFR 1502.16).

The Forest Service remains committed to providing a diversity of opportunities for resource uses as 

part of its mission, and supplying a reliable economic supply of timber is part of that mission. The 

commenter fails to disclose specific other needs identified in the purpose and need. From Chapter 1 

p.5 of the DEIS "The purpose of the Saddle Lakes Timber Sale is to respond to the goals and

objectives identified by the Forest Plan (USDA 2008b) that guide timber management to support the 

local and regional economies of Southeast Alaska." And from Page 6 of the DEIS "The underlying 

need for the Saddle Lakes Timber Sale comes from the Forest Service’s obligation under the TTRA. 

Forest-dependent communities in Southeast Alaska are facing social, economic, and environmental 

challenges." Included in the "need" are opportunities identified by the IDT that could occur 

concurrently with the proposed timber sale. Where these opportunities do not meet the "purpose" of 

the project, they were not considered as projects or actions independently of the proposed timber sale.

With the completion of the Ketchikan to Shelter Cove Road access methods for trapping 

could shift from boats to vehicles and/or snowmobiles making trapping less weather 

dependent. 
Appendix D

482  Appendix D – Response to Comments Saddle Lakes Timber Sale Final EIS

The purpose and need of the project was developed to analyze a timber sale to meet program 

responsibilities defined in the above statements taken from, and expanded upon in Appendix A of the 

DEIS. Consequently, only alternatives including timber harvest would meet the purpose and need of 

the project. 

Specifically for the Saddle Lakes Timber Sale, the analysis describes consequences to five different 

action alternatives all including some level of timber harvest, but each with areas of emphasis 

described on pages 27-30 of the DEIS. A no-action alternative (Alternative 1) is also included that 

would not harvest timber in the area of analysis. To expand upon or modify the Purpose and need 

would change the nature and scope of the project. The single alternative that would not meet (making 

it unreasonable) the purpose and need is the No-action Alternative. 

The Saddle Lakes Timber Sale DEIS was designed to meet direction in the Multiple-Use Sustained 

Yield Act of 1960, National Forest Management Act (1976), directs the Forest Service to administer 

federal lands for “outdoor recreation, range, timber, watershed, and wildlife and fish purposes. NFMA 

directs the Forest Service to complete land management plans for all units of the National Forest 

System. Forest plans are developed by an interdisciplinary team to provide for the coordination of 

outdoor recreation, range, timber, watershed, wildlife and fish, and wilderness. Forest plans designate 

areas of national forest where different management activities and uses are considered appropriate, 

including those areas suitable for timber harvest. The National Forest Management Act (NFMA) of 

1976 states that “the Secretary of Agriculture...may sell, at not less than appraised value, trees, 

portions of trees, or forest products located on National Forest System Lands.” Although the heart of 

the Act is the land management planning process for national forests, the Act also sets policy direction 

for timber management and public participation in Forest Service decision making. Under NFMA, the 

Forest Service was directed to “limit the sale of timber from each national forest to a quantity equal to 

or less than a quantity which can be removed from such forest annually in perpetuity on a sustainedyield basis.” 

The Alaska National Interest Lands Conservation Act (ANILCA) and the Tongass Timber Reform Act 

(TTRA) provide direction on the issue of Tongass timber supply. TTRA, Section 101 deleted 

ANILCA, Section 705 (a), which mandated a fixed timber supply and fixed budget appropriations, 

and inserted the following : “Sec. 705 (a) Subject to appropriations, other applicable law, and the 

requirements of the National Forest Management Act of 1976 (P.L. 94-588); except as provided in 

subsection (d) of this section, 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.”

Recreation

Effects of Logging to Recreation Use

Commenters had conflicting views of how logging and the associated road building 

may affect recreation use within the project area.

“The Saddle Lakes Timber Sale will promote better hunting opportunities for hunters in the 

Ketchikan area. This timber sale will also provide better access for hunting and other recreational 

opportunities.” 

“Most tourists and recreationists don’t want their public lands logged. When they find out it is 

occurring on the Tongass National Forest they will go elsewhere to spend their money.” 
Appendix D

Saddle Lakes Timber Sale Final EIS Response to Comments - Appendix D  483

“There is no definition of “high concern” within the DEIS. The DEIS does not list the metrics that a 

proposed harvest unit must meet to become a “high concern to recreation.” What criteria were used to 

support the decision to list a unit as a “high concern to recreation”?” 

“The new road connection also would have impacts on recreational opportunities. By bringing the 

project area into the road-accessible recreation network, this link would increase recreational use of 

the area, thereby increasing the importance of sustaining a nice landscape.” 

“The commenters ask that the document should also point out that the existing scenery and 

undeveloped experience is not currently available or appreciated by most people because the area is 

currently only accessible by plane or boat via the boat dock in Carroll Inlet and then requires a long 

walk into the Saddle lake vicinity. In addition, in many areas the logging will open up vistas that do 

not currently exist.” 

“The commenter suggests that the DEIS does not acknowledge that community stability is at least as 

dependent on the recreation/tourism related businesses in the local communities” 

Forest Service Response:

Pages 201-217 of the DEIS describe the affected environment for recreation and the direct, indirect 

and cumulative effects of the proposed timber harvest on recreation. 

Throughout the Recreation analysis (pages 201-217) recreation use of the project area is 

acknowledged. Page 205 states that roads allow easier access to and throughout the project area. The 

Shelter Cove road system / Saddle Lakes area is within the home range recreation use area of 

Ketchikan (page 207). Pages 206 and 208 identify an increase in use and access to recreation and 

subsistence activities with the proposed Ketchikan Shelter Cove Road connection. Page 210 states 

that units harvested as part of this sale would be used for berry-picking, hunting, and firewood 

gathering. 

Page 201 - last paragraph of "Methodology" - acknowledges that scenery is an important aspect of the 

recreation analysis and that scenery has a direct relationship with outdoor recreation opportunities. 

Pages 206-207 note that the visitor industry plays a large role in the Southeast Alaska economy and 

discusses the number of visitors to Ketchikan. Page 216 - first three full paragraphs - discusses scenic 

integrity around the lakes and the important role of tourism and identifies which alternatives will 

have the most impact to recreation resources in the project area. 

The recreation analysis considers information regarding tourism (pages 206-207: tourism and visitor 

use / recreation places / outfitter and guide use) and the importance of scenery (page 201 - 

methodology). It also considers temporary impacts to recreation users during active logging 

operations (pages 209-210 effects common to all, and also mentioned under Alternatives 4, 5, and 6 

on pages 211-212). Page 213 - paragraph 5 - considers the possibility of outfitter and guide use of the 

project area once proposed connection road is in. Cumulative effects (pages 214-215) also discusses 

scenery impacts as they relate to recreation. Conclusion (pages 215-216) also emphasizes the 

importance of tourism to Ketchikan and SE AK and maintaining scenic integrity.

Page 208 - paragraph just above Table 80 - "Important units to the recreation resource include units 

within the Saddle Lakes viewshed and units along the road in the small Old-Growth Habitat LUD."

We agree with increased use and this is acknowledged in several locations. Page 206 - second 

paragraph under "Tourism and Visitor Use" - states there is a high likelihood of increased use by both 

residents and visitors once the proposed road is built. Page 208 - first full paragraph - acknowledges 
Appendix D

484  Appendix D – Response to Comments Saddle Lakes Timber Sale Final EIS

the road connection would increase access to the project area. Page 213 - nearly entire page discusses 

road connection and anticipated recreation uses of the project area once the road is complete. The 

sixth paragraph acknowledges a concern for future maintenance of the OHV trail / enforcement 

concerns (GP-11 that did not have recreation identified as a resource). Addressed in Chapter 3, Issues 

4A & 4B, of the DEIS. 

Logging may open up areas for views along the road, which already has several views that are a result

of previous harvest. New harvest along the road, as stated in the DEIS, will not have as great an 

impact to scenery as harvest around the lakes. Logging is unlikely to open up views from the lakes, 

or George or Carroll Inlets, because the viewing distance and angles are different. The existing 

scenery of the project area is analyzed in accordance to the scenery management system, which 

classifies areas as seen or unseen, and does not classify any areas as "unavailable". 

Page 206 (Recreation section - first paragraph under the heading "Tourism and Visitor Use") says 

"Because the Saddle Lakes area is remotely located (only boat and plane accessible) from Ketchikan, 

large numbers of people do not frequent the area at this time." The second paragraph also notes 

"Although current use of the project area is fairly low..."

The contribution of differing industries that make up the economy of Southeast Alaska is described 

in detail in the Socioeconomic section beginning on page 319 in Chapter 3 of the DEIS. This section 

describes the area of analysis and explores current conditions and trends. The Socioeconomic 

Resource Report includes more detailed information.

Scenery

Effects of Logging to Scenery

Commenters expressed concerns about how logging may impact the scenery 

resource within the project area.

The commenter acknowledged that “clearcut areas are an "eyesore", the areas quickly green up 

making room for healthier vigorous forests.” 

“We do, however, request that the Forest Service continue to work to achieve further reductions in 

potential impacts to visual resources...” 

The commenter questions “whether or not the visible outcome of the planned clearcut units on the 

Saddle Lakes timber sale will be different that those pictured in Opposing Views Attachment #26.” 

Forest Service Response:

Clearcuts do regenerate and the impact of regrowth is factored into our scenery analysis.

For any alternative that is selected, the Record of Decision (ROD) will identify mitigation measures 

that may be implemented to reduce impacts to scenery.

The referenced photos are of various even-aged prescriptions from varied distance zones, none from 

the Tongass. The units planned for even-aged management will share some of the same visual traits, 

though there is variation on size, location, slope, visibility, shape and other traits that cannot be 

exactly compared. This project would be more accurately compared to other recent projects 

implemented on the Tongass. 
Appendix D

Saddle Lakes Timber Sale Final EIS Response to Comments - Appendix D  485

Scenery Analysis

Commenters had questions about the treatment of planned visual priority routes

(VPRs) in the DEIS as related to the Forest Plan, and wanted to know if any 

consideration was given to public perception of the scenic impacts of clearcuts within 

the scenery analysis.

“DNR-DOF questions the validity of treating “Planned” visual priority routes (VPRs) “as though they 

were existing and given equal weight as VPRs” for the purposes of the Scenery analysis. With the 

exception of the Harriet Hunt–Shelter Cove Connection Road, none of the VPRs listed in the TLMP

(January 2008) under Routes not constructed nor NEPA cleared: Planned or Opportunities (Appendix 

F, page F-23) are actually being planned or have had NEPA documents written for them. DNR-DOF 

believes these VPRs do not meet the criteria of proposed actions or foreseeable future actions under 

NEPA, and therefore, inclusion of them in any analysis connected with the Saddle Lakes project is 

inappropriate.” 

“The commenter requests that the FEIS include an explanation describing how and why the Saddle 

Lakes clearcuts will be more pleasing to the public than the clearcut photos in Opposing Views 

Attachment #26.” 

Forest Service Response:

The "Planned" VPRs are listed in the Forest Plan as visual priority routes; none of them will need 

development (or NEPA) to see increased use if the road connection is completed. Their inclusion in 

the Forest Plan conveys the intent to include them in analysis. 

Silviculture

Justification for Clearcutting

Commenters believe that the justification for the use of clearcutting provided in the 

DEIS is not adequate, and that using clearcuts as a silvicultural prescription should 

be used on in “exceptional circumstances.” Commenters also request a map 

“demonstrating that clearcutting is the optimum silvicultural prescription in the area, 

“and believe that clearcutting will lead to irreversible damage in the project area.

“Our scoping comments explained that clearcuts are only acceptable “in exceptional circumstances” 

and when these exceptional circumstances exist, the Forest Service must closely examine effects on 

other forest resources.............. However, the justification provided in the DEIS relied primarily on 

considerations related to factors related to the commercial viability of the stands such as hemlock 

dwarf mistletoe. The DEIS needs to revisit the justification for clearcut prescriptions by incorporating 

the requisite consideration of other environmental values, particularly as described in our comments 

pertaining to wildlife and aquatic habitat.” 

“The commenter requests that the FEIS include data and maps demonstrating that cut blocks, patches, 

or strips are shaped and blended to the extent practicable with the natural terrain, demonstrating that 

clearcutting is the optimum silvicultural prescription for the area.” 

“The commenter requests that the FEIS include data and text demonstrating that soil, slope, or other 

watershed conditions will not be irreversibly damaged by clearcutting.” 
Appendix D

486  Appendix D – Response to Comments Saddle Lakes Timber Sale Final EIS

Forest Service Response:

The National Forest Management ACT (NFMA), Forest Service Manual 2470-R-10- 2400-2005-1, 

Forest Service Handbook 1909.12-2008-1, Forest Service Handbook 2409.26d-2009-1 and the 2008 

Tongass Land and Resource Management Plan all give direction on the use of the even-aged 

clearcutting regeneration method. 

All harvests regardless of regeneration method must follow applicable standards and guides. Timber 

harvest is only prescribed where standards and guidelines for the protection of resources as stated in 

the 2008 Forest Plan Chapter 4 pages 4-1 thru 4-87 can be met. The Issue 4: Scenery and Recreation 

opportunities section in Chapter 3 of the DEIS (pages 179 to 200) describes how Forest Plan Standard 

And Guidelines related to scenery were addressed and the potential effects to scenic integrity 

objectives. See the alternative maps for the shape and location of units on the landscape and the unit 

card maps for site specific unit shapes and locations. The Aquatics and Soils sections in Chapter 3 of 

the DEIS (pages 224 to 252 and 331 to 335) describe how Forest Plan Standards and Guidelines for 

these resources were met in relation to clearcutting and the potential effects by alternative. 

Both even-aged and uneven-aged regeneration methods were considered for all the stands proposed 

for harvest in the Saddle Lakes project. Average growth in these stands is either offset or exceeded by 

decay. This condition conflicts with the basic goals and objectives of the land use designations where 

they occur. The even-aged method has been proven across the Tongass to be the optimum system to 

consistently produce timber stands that meet timber production goals and objectives.

Silvicultural systems that maintain varying levels of defective and diseased residual trees compromise 

the objective of producing an industrial timber supply from healthy forests. The DEIS (pages 308 to 

318) explains the effects of uneven-aged management on the timber resource in contrast to even-aged 

management. This discussion further supports the conclusion that the even-aged method is the 

optimum method and meets the criteria required for its use. 

The Silviculture effects section (DEIS Chapter 3 pages 307-318) along with the Silviculture Resource 

Report and individual unit silvicultural prescriptions (available in the project record) provides 

information on the changes to forest vegetation resulting from even-aged management and how evenaged forests will grow and change over time. Each resource specialist has considered these changes in 

developing the effects section for their particular resource. 

The detailed diagnoses of stand conditions in each unit are documented in the silvicultural 

prescriptions. This is the information the silviculturist uses to determine if clearcutting is justified 

based on direction outlined in the Forest Service Manuals and Handbooks, the Forest Plan, and the 

NFMA. The DEIS page 309 and 310 explains the justification for clearcutting. Clearcutting must be 

justified before it becomes a potential harvest method for consideration by the IDT. The silviculturist 

assists the IDT in determining the harvest methods for each unit based on the issues identified by 

alternative along with the other multiple use objectives considered by the IDT and described on page 

308 in the DEIS. 

Natural Disturbance

Commenters disagree with how natural disturbances, such as windthrow, was 

considered within the DEIS, and specifically in the cumulative effects analysis.

“Failing to tell the public that many natural resources in the forest not only benefit from tree mortality 

caused by natural disturbance events, but depend on these natural disturbance events occurring to 

function properly does not serve the public.” 
Appendix D

Saddle Lakes Timber Sale Final EIS Response to Comments - Appendix D  487

“Remove all text from the NEPA document that infers action should be taken as part of the Saddle 

Lakes timber sale to reduce the occurrence of natural disturbance events (fire, insect activity, disease 

etc.), or include a detailed description of how natural disturbance events benefit natural resources and 

define the resources that benefit.” 

“Despite noting the effect that natural causes such as windthrow can have on the amount of habitat 

and the quantity or quality of connectivity, the DEIS fails to take the cumulative effect of such natural 

losses over the coming centuries, even though the project’s impacts will be additive to those impacts 

(and may even contribute to them). Although it is not possible to predict where blowdown or a 

landslide will occur, it should be possible to predict statistically how much natural loss should be 

expected over a centuries-long period.” 

Forest Service Response:

The Silviculture section of the DEIS on page 306 describes the role of wind as the major natural 

disturbance agent affecting forest dynamics in Southeast Alaska and contrary to the commenters 

assertion describes the important role it plays in development of Southeast Alaska’s forests. The 

benefits of natural disturbance are recognized in the Old-growth Habitat Conservation Strategy 

adopted by the Forest Plan where natural disturbance processes largely occur uninterrupted. The 

Forest plan also recognizes the benefits of natural disturbance by precluding or limiting salvage or 

other harvest in non-development LUDs. Additionally, Forest-wide Standards and Guidelines 

preclude or limit harvest in other areas such as beach and estuary fringe, riparian areas, steep slopes, 

high hazard soils, karst terrain, visually sensitive travel routes, and areas technically not feasible for 

harvest. 

The discussion of environmental consequences in the Silviculture section of Chapter 3 in the DEIS 

(pages 313 and 318) describes the potential effect of clearcut and partial harvest methods on 

windthrow risk and the considerations used to minimize the potential for increasing windthrow risk 

from timber harvest . 

The wind risk rating for each proposed harvest unit was determined from individual tree and stand 

level characteristics and observed windthrow history. These ratings are summarized in the DEIS on 

page 306 and were used in development of the silvicultural prescriptions to minimize potential 

windthrow that could negatively affect timber production goals and objectives or other resource 

values. Within the project area, 60 units were rated high, 93 units were rated moderate and 8 units 

were rated low. The units with a high or moderate risk rating are most susceptible to windthrow loss. 

However, the frequency or severity of stand replacing wind events cannot be predicted. The overall 

influence of wind on stand structure in the project area typically predates any past harvest activities. 

Statistically predicting (if even possible) the amount of natural loss that could be expected over a 

centuries-long period from landslides or blowdown is not necessary for a reasoned choice among 

alternatives. See discussion pertaining to incomplete and unavailable information addressed on page 

3-54 of the DEIS. 

The silvicultural prescriptions found in the project record specify that the boundaries of even-aged 

openings are to be located where a windfirm edge will be maintained if possible. Where this edge 

cannot be located and resources are determined to be at risk, special measures to assure reasonable 

resistances to windthrow will be applied. 

Regarding the direct and indirect effects of the No-action Alternative on stand structure, the last 

sentence on page 311 of the DEIS states “no opportunity would exist to modify the stand structure to 

achieve a more diverse landscape that more closely mimics historical stand structure”. This sentence 
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488  Appendix D – Response to Comments Saddle Lakes Timber Sale Final EIS

incorrectly implied old-growth was not the historical stand structure and has been removed in the 

FEIS.

Opening Size

Commenter would like to see an expanded discussion of the factors used in deciding 

to exceed the 100 acre opening standard for several units in the project.

“The DEIS identifies three large openings [over 100 acres][DEIS at 310] but failed to discuss all of 

the relevant factors used to reach the decision to exceed the size limit for several units. Again, 

because of the particular risks associated with expanding clearcut sizes in this project area, we request 

a site-specific discussion in further NEPA analysis.” 

Forest Service Response:

As discussed in the DEIS (p. 310) there are three different groups of units proposed under Alternative 

5 that collectively could create opening sizes greater than 100 acres (135, 143 and 108 aces). This is 

the only alternative that proposes harvest opening greater than 100 acres. The discussion in the DEIS 

provides site-specific reasons that are consistent with the factors listed in Forest Plan (page 4-72) 

that allow created openings to be increased in size when larger units will produce a more desired 

contribution of benefits. 

Pacific Silver Fir

Commenter feels that the DEIS did not adequately demonstrate how adverse 

impacts to silver fir were avoided, mitigated, or minimized as per TLMP Standard 

and Guideline direction.

“The DEIS should have provided more detail about Pacific silver fir status and regeneration...The 

DEIS acknowledged that logging the species could be a significant issue, but then stated that TLMP 

standards and guideline directing the Forest Service to “avoid, minimize, or mitigate adverse impacts 

to rare populations” would minimize impacts...However, the DEIS did not adequately show how the 

project would meet this standard...” 

Forest Service Response:

Pacific silver fir (PSF) was included in the Saddle Lakes effects analysis for plants because of its 

scattered presence in the project area and the likelihood of its habitat and individuals impacted due to 

project activities. Its current S3 ranking in Alaska is rare or uncommon, with moderate population 

size. It is not a Forest Service designated sensitive plant, nor threatened or endangered. Proposed 

harvest of Pacific silver fir is minimal under the Saddle Lakes project with harvest occurring within

only 16 units of the approximately 200 harvest acres. Only 9 of the 16 units (containing PSF) are 

proposed for clearcutting. Pacific silver fir is known to be present in other areas within the project 

area outside of proposed harvest units. There is an equally or possibly greater northern population of 

this tree in British Columbia, although disjunct from the archipelago population in Southeast Alaska. 

Additionally the PSF Research Natural Area roughly 20 miles from the Saddle Lakes area contains 

the largest contiguous population of this species in Southeast Alaska, with over 8,000 acres of

protected forest. Additionally, the uneven-aged prescription (single tree section with 33 percent basal

area removal) was partially designed to minimize potential effects to PSF and could increase the 

abundance of PSF in these stands DEIS (page 317). Pacific silver fir is shade-tolerant much like 

hemlock and can regenerate and grow in shady conditions or in open sunlight. 
Appendix D

Saddle Lakes Timber Sale Final EIS Response to Comments - Appendix D  489

Regarding the commenter’s reference to clearcutting damaging understory regeneration, it is 

important to clarify that this refers to advanced PSF regeneration that currently exists and not new 

regeneration that is expected to occur following harvest. The DEIS states that PSF is expected to 

regenerate following clearcutting in similar proportions prior to harvest (DEIS p.317). This refers to 

new regeneration established following proposed harvest and would be in addition to advanced 

regeneration that survives harvest activities. 

All stands harvested by this project will be monitored by conducting regeneration surveys after the 

third growing season to ensure that pre-harvest species mixes are maintained where appropriate.

The commenter’s reference to Saddle Lakes project area containing 96 percent of the known 

population at the northern range of this tree is possibly a miscalculation. As stated above there are 

several populations of PSF outside the cumulative effects area of Revilla Island which are part of the 

northern edge of the range including on Prince of Wales Island, and in British Columbia, Canada. 

It is unknown exactly how many acres of PSF are in the portion of the Alaska Mental Health land 

exchange area inside the project area. Although there are 109 known locations of this tree in the 

existing project area, it is understandable that some may be within the land exchange boundary. Since 

this plant is not FS Sensitive, nor has a high State rank of rarity, an analysis of how many acres of 

PSF is possibly within the proposed land exchange boundaries was not considered an issue during the 

effects analysis.

Partial Harvest Prescriptions

Commenters have varying views on the use of partial-harvest prescriptions. Some 

believe that clearcutting is the best method to use in Southeast Alaska as it aids in 

regeneration, while others question the effectiveness of partial harvest, and whether 

it leads to “high-grading” within stands.

 “The DEIS relies on partial harvest to prevent silver fir from becoming a significant issue.” 

“The DEIS suggests that uneven-aged harvest results in a better understory, citing Deal et al. (2009) 

and Deal (2001).” 

“Decaying old-growth stands within the project area do not respond well to uneven aged management 

proposed by the other alternatives. Clear cut harvest is the preferred method for timber stand 

regeneration in Southeast Alaska.” 

“[c]lear cutting by conventional methods best utilizes the existing USFS road infrastructure. This 

remote road system is ideal for the management activities proposed by this timber sale alternative.” 

“The partial harvest of timber is encouraging to see, but do we really KNOW the effectiveness or 

robustness of stands that have already undergone 33 percent basal removal area. They are likely to 

retain some ecological function but has the USFS undergone a thorough monitoring and evaluation of 

this harvest regime?” 

“The very nature of single-tree selection will surely only lead to the high-grading of the biggest and 

best trees in these stands? Surely, this will effectively lead to a similar impact as clearcutting?” 

“Our scoping comments requested that the DEIS include alternatives that rely on light-touch partial 

cutting prescriptions that fully address wildlife and watershed concerns and provide a detailed 

explanation of the reasons for implementing clearcut prescriptions.” 
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490  Appendix D – Response to Comments Saddle Lakes Timber Sale Final EIS

Forest Service Response

The DEIS on page 310 and 311 explains that the objective of uneven-aged management is to provide 

structure for wildlife habitat and reduce visual impacts. Uneven-aged management is also considered 

when helicopter yarding is more economical than higher-cost road construction. The DEIS also 

explains that healthy young trees in the intermediate crown classes would be the priority for retention 

and older trees with lower timber value, but high wildlife value would also be a priority for retention. 

The biggest trees are often the oldest, contain the highest defect, and are not the highest value. The 

DEIS further explains how canopy gaps created through harvest will promote the growth of 

understory plants important for wildlife.

The Tongass has experience with implementing partial-harvest prescriptions. Most recently the 

Tonka Timber Sale implemented approximately 1,000 acres of 66 percent retention partial-harvest 

prescriptions. The resulting openings created from implementation of this prescription are 

predominantly from the removal of individual and/or small groups of trees with the majority of

openings being less than 1/4 of an acre in size. Larger openings up to the maximum size of 2 acres are 

the exception rather than the rule and are generally widely scattered. Experience with implementing

these types of prescriptions has also shown that the larger openings also tend be long, narrow “snakelike” openings rather than circular.

The 66 percent retention prescription, which will predominantly remove individual or small groups of 

trees, is considered a light touch relative to clearcut harvest and creates canopy gaps favorable for 

understory plant growth as well as new tree regeneration. Deal 2001 found that “light (1-25 percent 

BA) and medium (26-50 percent BA) cutting intensity plots were similar to the uncut plots for both 

the recently harvested and older sites, and they did not differ significantly in community structure 

from uncut plots.” The stand initiation and stem exclusion phases of stand development characterized 

by dense conifer regeneration would generally not occur under this prescription since the majority of 

openings are expected to be less than 1/4 acre in size as described above. The change in stand 

structure from the 66 percent basal area retention prescriptions is expected to be minor and generally 

consistent with Ott and Juday 2002 and Kirchhoff and Thompson 1998. These stands are expected to 

remain in the old-growth structural stage after harvest as well as through the next entry (DEIS, page 

312). 

Regarding concerns about relying on partial harvest to mitigate impacts to other resources, the IDT

developed these prescriptions in direct response to identified resource concerns and to Forest Plan 

Standards and Guidelines (DEIS pages 310 and 311). 

The Forest Service agrees that clearcut harvest is the preferred method for timber stand regeneration. 

The Saddle Lakes EIS includes five action alternatives with clearcut harvest ranging from 48 percent 

of the proposed harvest under Alternative 2 to 91 percent under Alternative 5. The alternatives utilize 

varying amounts of even-aged and uneven-aged management in response to the significant issues 

identified in Chapter 1. See the DEIS, Chapter 3, Table 9 page 65. 

Past Harvest

“The commenter is very disappointed that the proposed Saddle Lakes Timber Sale is taking place in 3 

VCUs: 7470, 7460 and 7530, that have all been heavily logged already. Documented harvests in 

each, amount to 7,500, 5,900 and 9,700 acres respectively. The commenter goes on to state that it is 

not justifiable to re-enter previously logged areas to cut away the last remaining areas of habitat for a 

multitude of species.” 
Appendix D

Saddle Lakes Timber Sale Final EIS Response to Comments - Appendix D  491

“This region can and should produce timber, but it should do so on the basis of long-term sustained 

yield of what the land base can offer. Instead, it feels like the forest service is scrambling just to 

provide stop-gap supply to current operators without thinking of the most basic of silvicultural theory 

of long-term sustainable yield.” 

Forest Service Response:

The purpose and need for the of the Saddle Lakes Timber Sale is described in Chapter 1 of the DEIS 

on pages 5 and 6 and is in response to the goals and objectives identified by the Forest Plan that guide 

timber management to support the local and regional economies of Southeast Alaska.

The Saddle Lakes EIS includes five action alternatives each with varying amounts of harvest. 

Alternatives 2 and 3 were both designed to specifically address Issue 3 (wildlife and subsistence use) 

in consideration of past harvest levels. Alternative 2 was developed to maintain old-growth 

connectivity corridors between OGRs and wildlife elevational connectivity in the Modified 

Landscape LUD. Alternative 3 further emphasized wildlife and was specifically developed to 

maintain wildlife habitat and landscape connectivity. See the DEIS, Chapter 2, pages 28 and 29. 

Transition to Young-growth

Commenters feel that the Saddle Lakes project is not in line with the Forest 

Service’s goal of transitioning to young-growth.

“The commenter asks that USFS provide some clarity and design timber sales that truly consider the 

many users of the Tongass and actively promote the transition toward young growth.” 

“As other states and nations are planting trees, the Tongass maintains a l 950's vision that trees 

regenerate quickly and the forest will recover in a few years. When will the Forest Service recognize 

that the Tongass regenerates slowly and many second growth areas are not ready for harvest in 80-100 

year rotations?” 

“[t]he USFS is effectively liquidating the potential future old-growth timber stock at an alarming rate. 

Whilst also neglecting to focus on a true transition to young-growth, effectively shutting out those 

who are proactively seeking to support it.” 

“The USFS needs to start incentivizing in-region processing of our timber, harvesting in a sensible 

manner and at a sustainable rate. The Tongass Transition cannot begin without the USFS taking action 

to initiate it and stimulate local industry into preparing and re-tooling for the future. USFS is merely 

maintaining the status quo. It is clear we are not using our current old-growth to its maximum 

capability and in region benefit. The current large volume sales do nothing to prepare for the 

transition, they only temporarily prop-up the already shaky industry.” 

“The majority of the profits of this timber will follow this wood as it is exported abroad. This does 

nothing to aid the Tongass Transition. Also, specifically designing timber sales that only ‘sustain’ the 

one or two large operators in the region offers them an unfair market advantage.” 

Forest Service Response

The transition from a dependence on old-growth timber to a program that is primarily supported by 

young growth improves the chances of timber industry’s long-term survival in Southeast Alaska. 

Retaining the existing industry is critical to this approach as described below; therefore, the transition 

to young growth will be managed at a pace that allows operators to adjust, adapt, and develop markets 

for new products. The duration and scale at which old-growth harvest will be needed is unclear. 
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492  Appendix D – Response to Comments Saddle Lakes Timber Sale Final EIS

Factors such as the role of State and private land in contributing wood supply to a viable industry; the 

availability of suitable young growth that is mature and economic to harvest; export and domestic 

processing policies; and fluctuations in domestic and world markets for forest products must be 

considered but are unpredictable, and will influence the timeframe for transition. The long-term goal 

for the timber program is for the majority of active forest management on the Tongass to be 

comprised of ecological restoration, precommercial thinning, small and microsale old-growth timber 

sales focused on niche markets, and young-growth forest management. 

These projects would, in turn, supply local and regional wood products markets (Leader Intent: 

Forest Stewardship and Young Growth Management on the Tongass National Forest” R10-MB-777 

letter, January 2013). This letter is located at http://www.fs.usda.gov/tongass/ under Young Growth 

Management on the Tongass and is in the project record.

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

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

with a vibrant timber industry today. Elsewhere in the country, communities have seen the timber 

industry and its associated economic support fade as milling infrastructure disappeared. Retaining the 

existing logging and milling infrastructure in Southeast Alaska, and therefore the old-growth timber 

program, is essential until enough young-growth forest is available for harvest. In the meantime, we 

need to offer young-growth contracts as they become available to begin the transition and/or 

incorporate a young-growth treatment component in proposals where it is silviculturally and 

economically feasible to do so. In addition, management of young-growth forests has been occurring 

through precommercial thinning since the 1980s. While this does not produce commercial products, it 

accelerates the development of young-growth stands, possibly reducing the time period needed for 

those stands to provide commercial value.

Analysis on several scenarios of transitioning to young growth was reviewed (Alexander, et al., 2010) 

concluding that “Ending old growth timber harvest after 5 or 10 years, even with considerable public 

investments in young growth management, will not maintain a timber industry in Southeast Alaska.” 

Several things may need to happen before this transition can occur: the trees in young-growth stands 

need to be large enough to provide a merchantable product, sawmills in Southeast Alaska will need to 

be re-fitted to effectively process young-growth logs or new industry needs to be developed and 

markets need to be available for these industries to make a profit. Currently the young-growth stands 

with merchantable products can only make a profit if exported. 

The Tongass is currently in the process of amending the 2008 Forest Plan with a primary focus on 

changes necessary to advance the transition to young-growth management as directed in the 

Secretary’s Memorandum (1044-009). Maintaining the existing workforce and retaining local 

knowledge and experience so businesses can retool is essential during the transition to young growth. 

A transition strategy is being developed that allows for the industry to adjust, adapt, and develop 

markets for new products. In order to do this and keep ahead of the yearly demand, the goal is to have 

at least three years of old-growth wood under contract for each mill. This equates to having 105 to 

120 MMBF under contract each year. The Saddle Lakes project is designed to contribute to this goal. 

In addition to amending the Forest Plan, the Tongass Advisory Committee (TAC) was established 

through the Federal Advisory Committee Act to inform the agency’s transition to young-growth forest 

management. The committee consists of 15 members representing a diverse and balanced range of 

perspectives and expertise. The committee will advise the Secretary of Agriculture, through the Chief 

of the Forest Service, by providing advice and recommendations for developing an ecologically, 

socially, and economically sustainable forest management strategy on the Tongass National Forest. 
Appendix D

Saddle Lakes Timber Sale Final EIS Response to Comments - Appendix D  493

The recommendations and advice from the TAC should inform the amendment of the 2008 Forest 

Plan. 

Young-growth stands account for 2,986 acres of the suitable forest land in the Saddle Lakes project 

area (DEIS p. 73). However, approximately 85 percent of the available young-growth in the project is

less than 25 years old and comprised of trees that are too small and young to be commercially

harvested. The remaining stands range from 45-56 years old, have not been precommercially thinned 

and are either completely or partially within the beach fringe. Young-growth stand conditions that 

influence readiness for commercial harvest vary widely depending on stand age, site productivity and

past harvest methods and intermediate treatments. On-the-ground examinations are necessary to 

evaluate young-growth stands based on these factors. For the Saddle Lakes project, these older

young-growth stands were examined prior to alternative development and were determined to contain 

predominantly sub-merchantable timber and have limited or only water access. One unit contained a

pocket of merchantable volume; however, the volume did not economically support the cost of 

access. For the above reasons, young-growth harvest was not proposed in the project area at this 

time. 

Alaska Yellow-cedar and Western Redcedar

Commenters believe that the FEIS needs to “address the high-grading of red and 

yellow-cedar, consider yellow-cedar decline and climate change, and provide 

information about regeneration in logged areas.”

“Our scoping comments requested that the DEIS address the high-grading of red and yellow-cedar, 

consider yellow-cedar decline and climate change, and provide information about regeneration in 

logged areas...For these reasons, we hoped that the DEIS would provide a more thorough analysis and 

include alternatives that avoid healthy yellow-cedar stands.” 

“The NEPA analysis should revisit projected climate change impacts on yellow-cedar through a more 

thorough discussion and literature review. Scientists project a 75 percent decline in the frequency of 

the species over the next century due to climate change alone...further NEPA analysis should disclose 

and discuss this risk.” 

“The NEPA analysis should disclose or evaluate the extent to which project alternatives are 

highgrading both cedar species at multiple scales.” 

“Further NEPA analysis should discuss the cumulative impacts of logging and cedar decline and 

disclose indirect effects of logging yellow-cedar. For example, the DEIS should also discuss how 

logging can exacerbate cedar decline by creating canopy gaps that exacerbate the freeze/thaw cycle 

responsible for yellow-cedar decline by creating conditions that cause more extreme temperature 

fluctuations. It should also consider whether logging healthy yellow-cedar stands will reduce genetic 

diversity and further fragment the landscape, hindering yellow-cedar adaptation and migration to 

suitable areas.” 

“The analysis in the DEIS acknowledges that yellow-cedar regeneration is poor but then the direct 

effects conclusion asserts that regeneration in clearcuts “is expected to be ...representative of the 

species mixture of the former stands.” Further NEPA analysis should revisit the conclusion in the 

DEIS and disclose likely changes in post-harvest species composition. In particular, further NEPA 

analysis needs to more clearly identify barriers to regeneration and discuss any recent research.” 

“Because of the extent of cedar decline in the project area, further NEPA analysis should include 

alternatives that avoid taking healthy yellow-cedar stands. The DEIS should also provide a 
Appendix D

494  Appendix D – Response to Comments Saddle Lakes Timber Sale Final EIS

description of specific cutting units for alternatives that do involve taking yellow-cedar and 

particularly consider whether cutting units occur in areas of adequate soil drainage where cedar 

decline is less likely to occur.” 

Forest Service Response

Yellow-cedar is common in mixed conifer stands and as a component of productive old-growth stands 

in both development and non-development LUDs within the project area. Of the approximately 

20,000 acres of productive old-growth within the project area, about 8,000 acres are either unsuitable 

or unavailable for timber harvest (DEIS page 304). In addition, yellow-cedar is a component of 

approximately 12,000 acres of unproductive old-growth forest in the project area, which is also not 

subject to timber harvest. 

Regarding high-grading, the yellow-cedar or redcedar component of a unit or presence of cedar 

decline was not a determining factor for the IDT in whether or not to include a unit in any of action 

alternatives. Additionally, trees remaining after uneven-aged harvest will generally be about the 

same species mix as the original stand, including yellow-cedar and redcedar (DEIS page 311). 

The Silviculture section in Chapter 3 of the DEIS (p.306 to-307) provides the areas of mapped 

yellow-cedar decline in the Saddle Lakes project area and summarizes the severity of decline within 

proposed harvest units. Approximately 90 percent of the units were rated either moderate or low for 

yellow-cedar decline or had no yellow-cedar decline present. 

The IDT considered yellow-cedar and yellow-cedar decline as a potential alternative driving issue in 

response to public comments. However, it was determined that an alternative that avoided healthy 

yellow-cedar stands was not warranted. The Forest Plan provides protection to approximately 20,000 

acres of productive and unproductive forest that contains yellow-cedar in the project area and the 

amount of yellow-cedar within proposed harvest units comprises only a fraction of the yellow-cedar 

within the project area. 

The Silviculture resource report includes a yellow-cedar severity rating by unit and discusses 

ongoing efforts in developing a conservation and management strategy for yellow-cedar in Southeast 

Alaska.

This strategy, which is nearly complete, provides:

• a thorough review of the knowledge on the extensive mortality to yellow-cedar, including the role

of climate

• options for the conservation and active management of yellow-cedar on lands that are considered

either suitable or unsuitable for yellow-cedar

• the use of risk models and yellow-cedar distribution to evaluate, quantify, and map areas of

habitat suitability for yellow-cedar, both now and in the future century

Risk of decline to yellow-cedar by the year 2080 varies considerably by geography in coastal Alaska. 

Some areas are already heavily impacted by decline and risk is not expected to increase appreciably; 

other areas are currently unimpacted, but are expected to develop decline; still other areas are 

expected to remain healthy Hennon Et.al [n.d]. 

The commenter references Hamman and Wang 2006 stating that “scientists project a 75 percent

decline in the frequency of the species over the next century due to climate change alone”. Hamman 

and Wang 2006 use a bioclimate envelope approach to predict a potential range shift in yellow-cedar 
Appendix D

Saddle Lakes Timber Sale Final EIS Response to Comments - Appendix D  495

distribution in British Columbia. The study does not address the direct effects to climate change or 

any particular injury. The authors (Hamman and Wang) suggest caution when interpreting these 

potential distribution shifts. In their study, most of the projected lost habitat for yellow-cedar involves 

competition with tree species which are currently more abundant at lower elevations. The actual 

response of yellow-cedar and other species to shifts in climate in these zones may be exceedingly 

slow, especially if the transition relies mainly on competition among species and not direct injury. 

Unless established yellow-cedar trees are directly injured by climate (e.g., by freezing or drought), or 

killed by something else such as fire or beetles they could survive many centuries. There are about 2.3 

million acres of yellow-cedar in Alaska (some estimates are higher) and most of the acreage is 

currently unimpacted by cedar decline (Hennon et.al [n.d]). The commenter states “there are roughly 

500,000 acres of cedar decline across the forest, with 70 percent of the mature trees dead and [sic] 

locations of more concentrated mortality”. It is important to clarify that on average 70 percent of 

yellow-cedar trees have died in the obvious patches, and the 30 percent of survivors appear stable or 

even vigorous once the pulse of mortality has occurred (Beier et al. 2008). 

The Forest Plan does not include specific management direction pertaining to yellow-cedar 

regeneration. Rather, the Forest Plan ROD identifies that the best course of action, in light of 

uncertain but anticipated change, is continued management for resiliency with a robust monitoring 

program that allows for adaptive management intervention (Forest Plan ROD, p. 50). Active forest 

management through timber harvest or other silvicultural treatments provides the ability to establish 

or favor cedar on more favorable sites. Activities such inter-planting of cedar following even-aged 

harvest and favoring cedar during thinning are effective strategies to promote or increase the relative 

abundance of yellow-cedar on favorable sites and where it is not prone to decline. Alaska yellowcedar regeneration is found in regenerated units within the project area. (The project record contains a 

sample of regeneration surveys conducted previously in the project area). 

It is fully expected that yellow-cedar will naturally regenerate in the Saddle Lakes project area 

following harvest in the units where it currently exists (DEIS p. 312 to 317). All stands harvested by 

this project will be monitored by conducting regeneration surveys after the third growing season to 

ensure that pre-harvest species mixes are maintained where appropriate.

Regarding canopy gaps and the potential to intensify yellow-cedar decline, the research indicates that 

there is cascade of factors responsible for yellow-cedar decline. Soil drainage is the most important 

factor to consider, along with snow. The association of yellow-cedar decline with wet soils has been 

well documented. Yellow-cedar trees growing on poorly drained soils have shallow root systems that 

are predisposed to freezing when snow is not present. Poor soil drainage, particularly where the soil 

has become wetter since yellow-cedar became established on the site, forces the majority of fine roots 

of these trees to be shallow (Hennon, et.al 2007). Open canopy conditions increase exposure but do 

not alone result in yellow-cedar decline. The decline does not appear to occur on better-drained sites 

even in areas of low snow. Within a few years following harvest activities, we expect ample tree 

regeneration to occupy the openings created by both even-aged and uneven-aged harvests. This cover 

will provide an insulating effect not found within the open-canopied old-growth cedar stands where 

decline-related mortality opens the canopy and predisposes adjacent trees to decline. For this reason, 

openings created by uneven-aged or even-aged harvest would not be expected to predispose residual 

yellow-cedar to decline in a manner that would defeat the objectives of the silvicultural prescription.
Appendix D

496  Appendix D – Response to Comments Saddle Lakes Timber Sale Final EIS

Socioeconomics

Ecosystem Services

Commenter would like the Forest Service to identify adverse impacts to ecosystem 

services that support the fishery, recreational and subsistence economies. 

“We also reiterate the request made in our scoping comments to fully assess ecosystem services

identified on the Forest Service’s national website as an important consideration...The DEIS and 

socio-economic report failed to identify adverse impacts to ecosystem services that support the 

fishery, recreational and subsistence economies identified in our scoping comments, resulting in a 

flawed project and range of alternatives characterized by excessive timber volumes.”

Forest Service Response:

The commenter is correct that the Socioeconomic Report or DEIS do not identify ecosystem services

to fisheries, recreation, and subsistence economies. Ecosystem services are those services and benefits 

provided by healthy ecosystems. Definitions of ecosystem services can be broad and include both use 

and non-use values. To include the level of detail necessary to adequately describe effects to each 

resource would amount to repetitive documentation and would be contrary to 40 CFR § 1500.4 (b), (i) 

and others. Page 326 of the DEIS states "Potential impacts to ecosystem services other than timber 

are not addressed in monetary terms, but are discussed in the other resource-specific sections in 

Chapter 3 of this EIS. The effects of the action alternatives on these types of services and benefits are 

assessed in the sections of this DEIS that address watersheds, fisheries, soils, wildlife and subsistence 

use, heritage resources, and timber and vegetation, among others. Monetary values are not assigned to 

these services, but this does not lessen their importance in the decision making process. The 

Responsible Official will consider the economic values presented under the Issue 1: Timber 

Economics section in this chapter within the context of the information presented elsewhere in this 

document, much of which cannot readily be translated into economic terms." Much of the discussion 

regarding ecosystem services occurs in the 2008 Forest Plan from which this document is tiered (40 

CFR § 1502.20). Additional detail may be found in the reports for the specific resources. 

The Forest Service does not believe that the project or range of alternatives is flawed. The alternatives 

developed for the Saddle Lakes Timber Sale were designed to meet the purpose and need for the 

Saddle Lakes Timber Sale. The purpose of the Saddle Lakes Timber Sale is to respond to the goals 

and objectives identified by the Forest Plan (USDA 2008b) that guide timber management to support 

the local and regional economies of Southeast Alaska (DEIS P. 7). Forest-wide multiple-use goals and 

objectives that apply to this project and are available for review on page 5 in Chapter 1 of the DEIS. 

The need for the project comes from the Forest Service’s obligation under the TTRA. Forestdependent communities in Southeast Alaska are facing social, economic, and environmental 

challenges. Six alternatives ranging from zero to 60.7 MMBF of harvest with various road packages 

(including no roads) were developed and analyzed, each emphasizing differing resources, and all 

available for choice by the decisionmaker.
Appendix D

Saddle Lakes Timber Sale Final EIS Response to Comments - Appendix D  497

Soils

Logging on slopes over 72 percent

Commenters expressed concern related to slope stability in units that contain slopes 

over 72 percent, and request that “steep slope logging” should be eliminated from 

the project, or at a “minimum” the FEIS should provide a more “detailed explanation 

of potential adverse impacts.”

“Our scoping comments requested that the DEIS provide textual analysis and disclose the risks 

associated with this practice, even if there will be partial-cut helicopter logging. The DEIS disclosed 

that action alternatives will include a substantial amount of steep slope logging, but it failed to 

provide detailed analysis. Studies show that it is difficult to assess landslide risks and that even 

partial-cut helicopter harvests does not eliminate these risks, particularly at higher elevations. 

[Swanston 2006]. Our scoping comments thus requested that you observe the recommendations of 

leading scientists and the EPA and “[p]prohibit harvest from slopes greater than 72 percent, even if an 

on-site slope stability analysis has been conducted.” [Navy FEIS, Appx. B at B-53]. We request that 

either eliminate steep slope logging from the project, or at a minimum provide a more detailed 

explanation of potential adverse impacts.” 

“The DEIS contains conflicting information regarding the amount of timber harvesting that is 

proposed on slopes greater than 72 percent gradient.” 

Forest Service Response:

The Aquatics section referencing slopes greater than 72 percent will be corrected in the FEIS to say: 

“Alternatives 4 and 5 propose the most harvest acres on unstable soils; however, only 123 and 163 

acres respectively out of 4,441 acres of unstable soils are proposed for harvest on slopes greater than

72 percent”. This discrepancy was the result of a GIS analysis used for the aquatics report and field

data used for the soils report. The aquatics analysis will be adjusted to match the field data from the 

soils report. 

The Forest Service agrees that partial cutting does not eliminate landslide risks. The Forest Service 

does believe that partial cutting with strategically placed reserves can reduce, but not eliminate the 

risk of management-related landslides. The IDT soil scientist followed Forest Plan direction when 

conducting on-site slope stability analysis on the project area. That analysis considers slope stability 

factors and downslope resources at risk. 

Subsistence

Subsistence Use

Commenters suggest that timber harvest proposed in the project area will have a 

negative impact on the subsistence use of deer; while other commenters believe that 

the increased access provided by the timber sale and associated road building will 

have a beneficial effect to subsistence use.

“With the communities of Ketchikan and Saxman so close, it is essential that these areas be managed 

to ensure a healthy, viable deer population. Subsistence is important to residents of Ketchikan and 

Saxman. To jeopardize subsistence rights and livelihoods would be a terrible injustice to residents of 

Ketchikan and Saxman would be a terrible injustice. Stating that the proposed harvest ‘could’ affect 
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subsistence is an understatement; the loss of habitat will undoubtedly affect subsistence resources. 

This has been identified as one of the ‘Significant Issues’ of the project, yet all of the action 

alternatives contain units in elevational corridors and former leave strips.” 

“[t]he Forest Service is approving old-growth logging that will even further compromise the area’s 

ability to support subsistence deer hunting. See DEIS at 177 (“. . . Saddle Lakes Project may have a 

significant possibility of a significant restriction of subsistence use of deer due to changes in 

abundance and competition.”). Cumulative effects of project area logging will be exacerbated by the 

proposed Ketchikan to Shelter Cove road which “would make the Saddle Lakes project area more 

accessible to hunters and would likely increase hunting pressure in WAA 406 west of Carroll Inlet 

and WAA 407.”........see also 175 (Ketchikan to Saxman Road “is expected to increase hunting 

pressure within the Saddle Lakes project area and could lead to increased competition between user 

groups”).” 

“The commenters feel that the sale will increase access into the forest, which will increase 

recreational, hunting, and subsistence opportunities.” 

“As a further note on the subsistence analysis, the bullets at the top of DEIS page 173 are made 

without citation, and we believe they are misleading. Although the city of Ketchikan is not designated 

as a subsistence community, many Ketchikan hunters are de facto subsistence hunters. The 

subsistence needs of individual resident hunters are irrespective of the designations of the 

communities in which they live, because the economic factors involved and the desire for wild, 

untainted or traditional food exists regardless of a rural or non-rural designation. Even though resident 

hunters designated as non-rural cannot benefit from the protections ANILCA provides if the resource 

becomes scarce (and cannot hunt subsistence rules or exclusively subsistence seasons), for purposes 

of NEPA impact assessment of whether the available supply of deer is and will be adequate and 

whether any of the action alternatives are acceptable, all non-rural resident deer hunters should be 

considered, de facto, to be subsistence hunters...” 

“The Saddle Lakes Wildlife and Subsistence Report on page 12 states "past actions, along with action 

alternatives with the potential for future projects raise the possibility of significant deer restrictions" 

Projected hunter demand exceeds 20 percent of habitat capability in WAA 407 and between 10-20 

percent of habitat capability in WAA 406, continuing with the warning that "sport hunting restrictions 

may be necessary in the future followed by subsistence reductions". Tongass Conservation Society 

recommends that habitat protection and subsistence use be primary goals on Revillagigedo Island.” 

“We do, however, request that the Forest Service continue to work to achieve further reductions in 

potential impacts to subsistence...” 

Forest Service Response:

Testimony provided by subsistence users supported the increase in infrastructure provided by the 

project. The comment stating that this project would be a “terrible injustice to subsistence users” was 

not made by a known subsistence user, nor was the commenter present at the subsistence hearing 

held in Ketchikan on October 16, 2014. 

The Ketchikan to Shelter Cove Road system is a State of Alaska Project and is not an action 

connected to the Saddle Lakes Timber Sale. The proposed road is recognized as having cumulative 

effects and has been analyzed as such. That road project is being analyzed and is ongoing in 

coordination between the State of Alaska and The US Army Corps of Engineers who have sought 

public input for that project specifically. 
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Saddle Lakes Timber Sale Final EIS Response to Comments - Appendix D  499

Effects to wildlife, subsistence, soils, wetlands and other resources have been analyzed in the 

DEIS Chapter 3 and in more detail in the resource reports available in the project record. 

Please refer to page 26, State of Alaska Right-of-Way on NFS Lands and Table 111 on page 342. The 

increase in access on this road system may vary from 0 miles, up to 1 mile of open road, depending 

on the alternative. The open miles of road coincide with the Ketchikan to Shelter Cove Road and are 

needed for timber harvest and log haul. 

The citation Wolfe (2004) is on the previous page: DEIS page 172. Because the project area is 

important to Ketchikan hunters, all hunters were used to estimate demand (DEIS page 176). It is 

outside the scope and jurisdiction of the Saddle Lakes project to change ANILCA designations.

Timber

Competitive Bidding

Commenter would like more information concerning the completive bid process used 

by the Forest Service.

“The DEIS and project record makes clear that this project is intended for the largest timber sale 

purchaser in Alaska which operates a logging company and have operated in the project area for the 

last seven years. [DEIS at 58; PR 740_0792]. Further NEPA analysis should explain how this type of 

project provides for competitive bid sales and identify alternative buyers.” 

Forest Service Response:

The purpose of the DEIS is to disclose and compare the effects of the project alternatives. The units in 

an alternative that are subsequently “cleared” through the NEPA process do not necessarily equal the 

same units that would make up the timber contract package. The Forest Service may choose to offer 

multiple contracts of various sizes to match the interest of potential bidders or to improve the 

economics of the sale (FSM 2431.13). These factors can include different yarding methods, road 

construction requirements, or the total volume of the offering. The number and size of timber sale 

offerings are determined at the time of implementation. Several units from the Selected Alternative 

within the project area may be offered as small sales or microsales. Small sale opportunities from the 

Saddle Lakes project are discussed in the DEIS, page 60. Volume proposed for harvest along existing 

roads using conventional logging systems is most advantageous to small mills. Construction of new 

roads in larger sales can also benefit small timber sale operators by increasing access to other 

roadside timber volume. 

All timber harvest contracts offered by the Forest Service are required to be advertised and awarded 

through a competitive bid process, unless conditions stated in 36 CFR 223.85- “Noncompetitive sale 

of timber” apply. The competitive bidding process is outlined in Forest Service Manual 2400 and 

Forest Service Handbook 2409.18 (pursuant 36 CFR 223.88- “Bidding Methods”). Timber sale 

purchasers are not limited to those who own or operate sawmills or even those located in Alaska. 

Timber harvests are advertised in the paper of record, which is the same paper used for NEPA 

notifications (Ketchikan Daily News). Persons, businesses, or organizations interested in submitting 

bids for purchase may obtain a prospectus for National Forest timber contracts from the unit offering 

the contract. The minimum period for advertisement and bid submission is 30 days. 

To comply with national and regional direction, the action alternative volumes must be analyzed to a 

location with the capability and capacity to mill that volume during a normal contract lifespan (FSH 

2409.18, section 45 and FASTR spreadsheet, section RV Input PG 1). Therefore, for the financial 
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500  Appendix D – Response to Comments Saddle Lakes Timber Sale Final EIS

efficiency comparison of Saddle Lakes’ alternatives, the closest medium-sized mill in Southeast 

Alaska was used for this analysis.

Economics of Helicopter Yarding

Commenters had suggestions to improve the economics for the proposed helicopter 

logging in this project.

“The current Alternative 2 unit layout designates too many helicopter units in better timbered areas, 

areas that could be, and should be, more economically clearcut logged instead of partial cut.” 

“The helicopter logging prescription for this timber sale should also be reconsidered. In recent timber 

sales, the Forest Service has been allowing the purchaser to select the trees to be removed from a 

helicopter partial cut unit as long as the targeted basal area standards are met. This practice was 

adopted in part by the FS in recognition of the high cost of operating a helicopter and the subsequent 

need to maximize the value of the harvested timber. This practice should be taken one step further in 

regards to this timber sale; similar to the now current Forest Service standard of leaving utility grade 

logs behind in a sale, timber to be removed by helicopter should be subject to agreement by the 

purchaser. To help meet the basal area removal quotas set by the FS, the low value Scribner sawlog 

timber could be felled but left on the ground so that the purchaser can forgo the immense operating 

loss involved in removing this volume from the sale area. This would help ensure a positive appraisal 

for the sale.” 

“Chapter 3, page 65 states that the financial analysis uses a helicopter logging cost of $399.09. We 

checked with the helicopter outfit that does virtually all of the helicopter logging in Southeast Alaska 

and their cost are currently about $485 to $490.” 

Forest Service Response:

From a logging engineering and feasibility point of view, this is a valid point about clearcutting 

instead of partial cutting “better timbered” helicopter units in the proposed action, Alternative 2. 

However, this project was developed through an interdisciplinary process and multiple goals and 

objectives must be achieved for various resources to meet the direction in the Forest Plan. In 

alternatives to the proposed action, clearcutting has been proposed instead of partial harvest. See the 

map for Alternative 4, the Preferred Alternative. Many of the units proposed for partial harvest in 

Alternative 2 are proposed for clearcutting in Alternative 4. In order to achieve these changes, there 

needs to be amendments to the designations for the visual priority routes identified for the Forest 

Plan. See explanation in the DEIS, pages 29, 192-194. 

In multiple alternatives, there are examples of different silvicultural prescription (clearcut or partialcut), logging system changes for units adjacent to existing roads (conventional to helicopter) or the 

construction of additional roads. These alternatives were developed and agreed upon by the IDT in 

order to mitigate certain areas of impact or maintain specific Forest Plan Standards and Guidelines 

resulting in a range of alternatives. While a single road-side helicopter unit may cause the “logging 

engineer” to question the economics, the partial-harvest opportunity provided by the helicopter 

yarding method was utilized to meet scenery standards for visual absorption capability (VAC). 

However, through the range of action alternatives, the most logical and feasible harvest method for 

each unit has been presented in at least one alternative.

The Forest Service has been monitoring the implementation of partial harvest via helicopter yarding 

for several years and have been working collaboratively with industry to develop a mutually 

beneficially method of designating included timber in uneven-aged harvest units. There are multiple 
Appendix D

Saddle Lakes Timber Sale Final EIS Response to Comments - Appendix D  501

methods to designate or select which trees are cut in a partial-harvest scenario. These methods 

include single-tree selection, designation by cutting area boundary, designation by description, and 

designation by prescription (Timber Cruising Handbook, FSH 2409.12, 71.1 & 71.4). 

If the purchaser is allowed to fell and not yard low-value trees to forego operating losses, there may 

be effects to other resources. For example, leaving the amount of slash that would be created by this 

practice may impede the movement of animals throughout the unit. In recognition of these low-value 

materials, the Forest Service offers the opportunity to the purchaser upon request to export these logs 

to foreign markets where there is higher demand for low-value timber.

Currently, there are contract provisions that allow for optional removal of utility grade timber (C (T) 

2.11). However, if the commenter’s request is to forego the yarding of sawlog volume that meets 

contract utilization specifications the Forest Service does not anticipate modifications to these 

specifications. It is mandatory, even if those logs are undesirable by a particular purchaser. In the 

future, designation of trees may meet the needs for industry and meet the Forest Service silvicultural 

prescription, but for now the iterative process of developing implementation guidelines, policy, and 

regulations is still ongoing.

The costs used for helicopter yarding are developed by the Region 10 Timber Valuation team and are 

distributed and updated through the approved NEPA financial efficiency analysis program, FASTR 

(Financial Analysis Spreadsheet Tool – Residual Value). The Timber Valuation team collects data 

from previous timber sales and private timber operators to calculate the average operating costs. Due 

to the time associated with collecting and analyzing the data, plus the differences in each contract, 

there may be a difference with the costs used. The average helicopter yarding cost is $399.09 per net

MBF removed for the action alternatives. The estimated costs are based on the amount of volume 

removed, average yarding distance, elevation change, and the amount of retention (since a higher 

amount of tree retention results in higher costs due to increased difficulty for mobility). The most 

recent logging costs will be used when preparing the appraisals for the timber harvest contracts. 

However, the bidder is responsible for using costs that they think are appropriate when submitting 

bids. 

Economics of Small/Isolated Units

A commenter had a concern that too many small and isolated units will lead to high 

operating costs, and affect the overall economics of the project.

“The timber availability issues could be better addressed; there are too many small, isolated units that 

contribute little to the harvestable volume but much to the operating costs.” 

Forest Service Response

Optimum unit size is the ultimate goal for every unit. However, the optimum size must be a balance 

for multiple goals and interdisciplinary resource benefits. The size of many Saddle Lakes units are 

affected by suitable commercial timber stocking, previously harvested stands, riparian management 

area buffers, logging feasibility (blind leads), wildlife corridors and habitat, limited road access, 

scenery/visuals standards and guidelines, and LUD restrictions. Also, the natural condition of the 

landscape is fragmented with non-forested habitats. The resources and goals listed above are not 

comprehensive. A comprehensive list of considerations is located in the Tongass Forest Plan, Chapter 

4- Standards and Guidelines.

The financial efficiency of the project as a whole includes many of these small and/or isolated units. 

During contract package development and appraisal, the timing of offer and the selection of the units 
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502  Appendix D – Response to Comments Saddle Lakes Timber Sale Final EIS

for the offer may be able to improve or at least lessen the overall burden of operating costs of 

small/isolated harvest units.

The Financial Efficiency Analysis is inadequate

“[t]he public costs disclosed in the FEIS are critical to the analysis.................The failure to disclose 

true public costs associated with the Saddle Lakes timber sale project undermines a fundamental 

purpose of NEPA – ensure the agency takes a hard look at, as well as makes available to the public, 

detailed information concerning significant environmental impacts to the human environment. Given 

that entire purpose and need for the Saddle Lakes project, and for the Tongass timber sale program in 

general, is economic: the timber sale is justified solely on the ground that it will ostensibly produce 

economic opportunity for Southeast Alaska residents. The failure to disclose the true costs of the 

proposed Saddle Lakes project and the Tongass timber sale program as a whole renders inadequate 

both the DEIS and the TLMP FEIS.” 

“The "Proposed Action" {Alternative 2) does not go far enough to address what is inherently wrong 

with this timber sale. There are many small settings requiring downhill yarding and involving tight 

landings, so the cable logging portion will be relatively expensive.” 

“Under both the Export Policy Scenario and the Domestic Processing Scenario subsections total 

production costs are less than Total Selling Value for all alternatives; yet, the Indicated Advertised 

Rate is negative for all alternatives. How is that possible?” 

“Our scoping comments requested a detailed public investment analysis that discloses the full public 

cost associated with administering this project. The DEIS estimated administrative costs of 

$104/MBF, and further NEPA analysis needs to correct these estimates. [DEIS at 67]. We think the 

disclosed costs were inaccurate and misleading, based on Mehrkens 2013 Declaration...” 

“The Saddle Lake DEIS and TLMP FEIS Present Unsupported and False Information About the Cost 

of Tongass Timber Sales in Violation of NEPA..............the only information provided about the 

economic cost of Tongass timber sales to taxpayers is unsupported and false. The numbers reported in 

the DEIS are unsupported in the record and represent less than 10 percent of costs as determined by a 

review of actual Forest Service budget expenditures. The Forest Service has failed repeatedly to come 

clean with the public about the true cost of its timber sale program..............The DEIS does not 

disclose the actual cost of the timber sale program directly Those costs have been derived from 

publicly available Forest Service financial documents by Joe Mehrkens, the former Regional 

Economist for the Alaska Region of the Forest Service.............In short, while the Forest Service fails 

to disclose anywhere in the record the basis for its assertions regarding costs, Mehrkens has provided 

a detailed, fully supported accounting, upheld in court as a reliable source. Lacking a basis in the 

record, the Forest Service estimate is arbitrary.” 

Forest Service Response:

A financial efficiency analysis was conducted with the approved Region 10 Financial Analysis 

Spreadsheet Tool- Residual Value (FASTR). This tool is developed and maintained by the Region 10 

Timber Valuation team to meet the requirements of FSH 2409.18, section 32.1. FASTR uses the 

official R10 Residual Value bulletin and project specific information to calculate the indicated bid 

value of an alternative. Cost estimates for timber sale preparation, sale administration, engineering 

support, and environmental analysis (NEPA) are incorporated into FASTR, as are the jobs multipliers. 

The valuation team collects proprietary information in order to calculate these values and updates 

FASTR each quarter. 
Appendix D

Saddle Lakes Timber Sale Final EIS Response to Comments - Appendix D  503

Estimating timber sale program costs requires judgment regarding which activities are directly 

associated with producing timber sales, and which are not. This analysis excluded costs of other 

vegetation management projects, SO program management, Forest Service operations support, Gate 1 

activities (pre-NEPA), facilities maintenance, training, travel not related to producing timber outputs, 

and generic supply costs. 

In regards to Forest Service costs, the Mehrkens’ declaration was based on the timber program as a 

whole and included some budget line items that are not solely associated with timber harvest 

contracts. The most recent analysis by the Forest Service (Vermillion 2013) is based on a "snapshot" 

review of fiscal years (2010, 2011, and 2012), to obtain an average cost for MBF for various stages as 

the timber project moves through the process explained in Appendix A. These stages include NEPA, 

sale preparation, sale administration, and engineering support to the timber program. Engineering 

support can occur at any stage of the overall process and funded by CMRD budget line item. A review 

of work plans developed for the NFTM budget line item was completed for each of the past three 

fiscal years. Although each project incurs cost during the entire multi-year planning process, a 

snapshot of costs is representative of average costs for producing a thousand board feet (MBF) of 

timber. In any given year a number of timber sale projects are progressing through each stage of the 

planning and implementation process. 

For example, the cost estimates for timber sale preparation or timber sale administration used by 

FASTR are aligned with the personnel on-the-ground required to implement that task. The $23/MBF 

for sale preparation estimate is based on the field crew and supplies needed to layout that sale. A field 

crew may be 5-10 individuals ranging from GS-4 to GS-7, with one or two GS-9 or GS-11 to 

supervise. Personnel costs include overhead (or cost pools) for these employees, which in turn 

drastically reduces the program costs associated with District support staff (partially funded by 

NFTM but also other resource codes), Supervisor’s Office program management staff, and Regional 

Office program director’s staff.

Logging Feasibility

Commenter questions the lack of road building within partial harvest units with the 

use of a shovel as the designated logging system.

“Alternative 2 calls for 50 percent of the partial cut acres to be removed by shovel logging, but with 

only minor exceptions there are no roads designated on the map to allow for this logging method.” 

Forest Service Response:

Refer to DEIS Table 9. Acres by silvicultural system, prescription, and logging system for the 

Saddle Lakes Timber Sale at page 65. A total of 1,152 acres are proposed for partial-cut harvest in 

Alternative 2, of which 52 acres harvested using a shovel (4.5 percent) and 1,100 acres by helicopter 

(95.5 percent). The units without proposed roaded access on the Alternative 2 map are those units 

proposed for helicopter yarding since cable or shovel logging would not be feasible. Several of these 

units can be accessed by roads as proposed in other alternatives. However, clearcut prescriptions are 

not feasible unless the visual priority routes and use areas, as designated in the Forest Plan, are 

removed. The acres proposed for shovel logging are those adjacent to existing roads. The remaining 

shovel logging acres are proposed for clearcut. 
Appendix D

504  Appendix D – Response to Comments Saddle Lakes Timber Sale Final EIS

Timber Demand and Export

Commenters believe that the export policy is not consistent with the goals and 

objectives of this project, namely to support “a wide range of natural resource 

employment opportunities within Southeast Alaska communities.”

“The DEIS identifies a goal of “[p]roved[ing] a diversity of opportunities for resource uses that 

contribute to the local and regional economies of Southeast Alaska” and an objective of 

“[s]upport[ing] a wide range of natural resource employment opportunities within Southeast Alaska 

communities.” [DEIS at 5]...it is unclear how a massive export-driven timber sale meets the local 

economy goals and objectives for the project. Further NEPA analysis should reassess how the Forest 

Service can best contribute to recreation and fishing-based economies, and modify the range of 

alternative accordingly. The federal government, and thus American taxpayers, are losing money by 

subsidizing an industry whose resources are finite and limited, and whose raw materials are often 

exported to foreign markets without local retention of wealth associated with processing raw 

materials. If Tongass Forest Plan goals and objectives include local and regional economies, then 

these realities should be made clear.” 

“Most small mills in the region heavily rely upon redcedar, yellow-cedar, or a combination of the two 

to stay in business. Removing the supply of one of these species to regional mills would create 

unnecessary and potentially insurmountable obstacles for local, small businesses.” 

“In our scoping comments, we requested that the Forest Service update programmatic and projectarea economic analyses as part of the process involved with the DEIS. This project will entail 

considerable expenditures of real and natural capital based on several critical flawed assumptions and 

errors that include the relationship between the export program and local wood products industry, the 

public costs of financing the timber export program and the underlying methodology for determining 

the volume of timber produced for sale from public lands within the Alexander Archipelago.” 

“Our scoping comments requested that the DEIS consider local processing as a significant issue in 

light of longstanding federal policy on timber supply for local use as set forth in the Organic Act. It is 

clear that this project is infeasible under a domestic processing scenario, with negative bid values 

ranging from -$70.73 per mbf to - $104.52 per mbf that are more deficit than processing under an 

export policy scenario by an order of magnitude under most alternatives. [DEIS at 62].” 

“Our scoping comments requested that the DEIS discuss the relative values of timber targeted for 

local processing versus timber targeted for export or transshipment. Further NEPA analysis should 

take another step with the data from Tables 5 and 8 and break down the respective contributions of 

different tree species harvested under the export and domestic policy processing scenarios.” 

“Yellow cedar, "considered surplus" (page 58) will be 100 [percent] exported. Yellow cedar is having 

difficulty regenerating due to warming winter temperatures, yet all of it will be exported. This is 

illogical. Local mills are unable to bid on yellow-cedar because the amount of timber offered is too 

large for a small mill to utilize. Although the DEIS states, "Exceptions can be made for export when 

no local mill exists for the type timber in a contract", not allowing small mills access to local 

resources resembles the monopolistic practices of the pulp mills.” 

Forest Service Response:

The export of Forest Service timber involves multiple aspects of the environmental analysis phase, as 

well as the contract preparation, offering, and administration phases. The comments listed above are 

responded to in four categories: 1) direct and indirect contributions of the project, 2) financial 
Appendix D

Saddle Lakes Timber Sale Final EIS Response to Comments - Appendix D  505

efficiency analysis (FEA) domestic and foreign market manufacturing scenarios, 3) authorization for 

export and the determination of Alaska yellow-cedar (AYC) as a “surplus species”, and 4) domestic 

processing incentives.

The Forest Plan is designed to meet multiple goals and objectives through a variety of projects. A 

single project is not required to achieve all goals or contribute to several resource areas. This project 

was designed to address Issues 1-4 (see DEIS 16). Direct and indirect contributions of this project are 

anticipated for the timber industry and local economies. Only indirect contributions or affects are 

anticipated for the economies of recreation and fisheries, as identified in the comments. Projects must 

be aligned with goals. A timber harvest project with goals focused on contributions to recreation 

and/or fisheries would be misaligned and would violate NEPA guidelines. Additionally, this project is 

tiered to the Forest Plan FEIS which is based on Regional and National policy and federal law. These 

programmatic documents authorize project-level decisions to make certain modifications (e.g.

removal of visual priority routes), but including an economic analysis of real and natural expenditures 

is not authorized since it includes non-market or non-monetary values (FSH 2409.18, 32.1). Refer to 

“Financial Efficiency Analysis and Forest Service Costs” discussion on pages 61-64 of the DEIS. 

Furthermore, the export policy is incorporated into the FEA by including two scenarios. These two 

scenarios either maximize domestic processing or maximize exported volume, according to Regional 

policy. Even though the project appears to be uneconomical with maximized export and even more 

deficit under the domestic process scenario, the exact value is unknown at this time due to regular and 

unpredictable market fluctuations. Therefore, even marginal projects continue through the planning 

process since the duration of the planning stage can encompass multiple shifts in the market. It is not 

possible to predict the market for the time of the offer. A sale that is deficit in one year may be 

positive in the next.

The key difference in the FEA is the maximized exported volume scenario incorporates foreign 

market manufacturing costs that are two to three times less expensive than domestic (Alaska) 

manufacturing costs. This is due to a market for these products and less expensive foreign market 

manufacturing costs (FASTR and RV Appraisal Bulletin, June 2014). The FEA is comparative tool 

designed for the NEPA process. The FEA and FASTR do not deviate from policy. 

The Forest Service does not intend to restrict access of a species, such as AYC, to local or small mills 

(also refer to response topic “Competitive Bidding”). In preparing a timber sale, the agency is 

directed to offer all designated timber in accordance with the silvicultural prescription from an entire 

harvest unit. It is infeasible, impractical, and unsafe to subdivide the sale of a particular species from 

a given unit. Further analysis of relative values or respective contributions by individual species is not 

pertinent or feasible. Contrary to restricting local mills access to AYC, there are incentives in place 

for the domestic processing of cedar species. These incentives are discussed below in this response.

The Forest Service has identified allowances for export under certain situations. The agency does not 

“insist” that timber is exported; rather, it develops and administers policy and evaluates allowable 

export of timber if the purchaser chooses to apply. The export policy was designed to allow 

purchasers the option to find a market for the lower-grade sawtimber, which was used in the pulp 

mills in the past. DEIS Chapter 3, page 58 explains that “Timber volume is not pre-authorized for 

export. If a purchaser desires to ship timber to domestic destinations outside the State of Alaska or 

export timber overseas, they are required to apply for a permit from the Regional Forester after the 

contract is awarded.” For the Alaska Region (R10), “export” includes timber shipped to the Lower 48 

states as well as foreign market destinations. Lower 48 destinations are considered export since the 

timber must cross international waters. No Forest Service timber volume may be exported without an 

application by the purchaser to request the export and approval by the Regional Forester. Each request 
Appendix D

506  Appendix D – Response to Comments Saddle Lakes Timber Sale Final EIS

must be specific to the timber sale contract and species (e.g. to export AYC and SS from one timber 

sale, the purchaser must submit two application for export to the Regional Forester, one per species). 

Alaska yellow-cedar is analyzed for 100 percent export under both FEA scenarios because it is a 

“surplus species.” The determination of “surplus species” is the responsibility of the Secretary of 

Agriculture (36 CFR § 220.200 (c)). Alaska yellow-cedar was found to be surplus to domestic 

processing needs in Alaska in 1990. The withdrawal of such determination shall be made in 

accordance with Title 5, United States Code, Section 553 (36 CFR § 223.200(a)). However, some of 

the smaller mills manufacture products from yellow-cedar and tend to purchase small sales as close as 

possible to their mills. The Tongass, as dictated by the Alaska Region, must analyze 100 percent AYC 

for export because of federal code, but is able to incentivize the local processing of sawlogs via the 

timber harvest contract. 

Financial incentives for domestic processing of AYC were in place before the inception of the limited 

export policy. When/if a Record of Decision is signed that authorizes timber harvest in Saddle Lakes 

project area; the implementation would occur through a timber sale contract. Various contract types 

exist based on the amount of volume and road construction, the method of volume 

estimation/determination, and general complexity of the required work. Contract forms include 2400-

2, 2400-3, 2400-4, 2400-6, and 2400-13. The contracts are comprised of provisions that describe how 

to administer specific situations. Provision “C (T) 4.13#- Domestic Processing Adjustment for Alaska 

Yellow Cedar” defines the incentive for purchasers. If a purchaser chooses to domestically process 

any Alaska yellow-cedar from the timber harvest contract volume, the “Current Contract Rates for 

AYC sawlogs receiving primary manufacture in Alaska are adjusted downward by [dollar amount] 

per [unit of volume]... (C (T) 4.13#).” The downward adjustment amount is updated quarterly. As of 

June 2014, the amount was $194.06 per net MBF and is subject to the $6.00 per net MBF minimum 

rate. When applicable to a specific timber sale contract, the “Purchaser may not receive a domestic 

processing adjustment for AYC more than one year after the Termination Date.” 

Timber Economics/Jobs

Some commenters feel that the economic analysis presented in the DEIS was 

incomplete, flawed, and that an “improper” multiplier was used to determine jobs per 

MMBF of timber, while one commenter expressed support for jobs created by the 

timber industry as an important support to the Southeast Alaska economy.

“The DEIS contains no economic analysis to determine if the USFS will spend more money planning, 

preparing and administering the sale than they receive from the timber purchaser who buys the 

sale. The USFS must complete an economic analysis for all proposed projects using tax dollars to 

show the public if they are receiving an adequate return on their dollar. The public wants to know if 

this timber sale is a below-cost sale.” 

“The commenter requests that the FEIS include a complete economic analysis including projected 

revenues and agency costs associated with the timber sale (with overhead and travel costs). Costs 

associated with sale administration throughout the life of the sale.” 

“The DEIS uses a multiplier of 2.68 sawmill jobs per MMBF under both domestic and local 

processing scenarios. [DEIS at 68]. We think the employment estimates need to be corrected, both in 

terms of using an improper multiplier that improperly includes indirect and induced jobs, and because 

the estimates reflect incorrect assumptions about local mill utilization –particularly for this project. 

See Declaration of Joe Mehrkens...” 
Appendix D

Saddle Lakes Timber Sale Final EIS Response to Comments - Appendix D  507

“The Ketchikan area needs every logging job it can get. Our business and many others will continue 

to suffer unless we can find ways to bring back the timber industry in Southeast Alaska.” 

Forest Service Response

The economic analysis for the Saddle Lakes Timber Sale can be found in Chapter 3 beginning on p. 

55. FASTR outputs (dated December 2013-January 2014) are intended for initial planning purposes,

and provide a useful gauge of current economic conditions for a timber sale. The FASTR model was 

used to provide an indication of the indicated advertised rate, sawlog and utility volume by species, 

road construction/reconstruction and LTF costs, logging costs, total selling value (lumber and export 

log sales) and total production costs. These data are useful as units of measure to compare relative 

differences between alternatives and may not reflect absolute values (p. 56 DEIS). 

The average Forest Service costs used in this analysis were calculated within the FASTR program 

(version April 5, 2013) and are about: $48 /MBF for environmental analysis and documentation 

(NEPA planning), $21 /MBF for sale preparation, $12 /MBF for sale administration and $23 /MBF 

for engineering support (Timber Economics Resource report p. 14). 

The Saddle Lakes Timber Sale project was designed to meet the goals and objectives of the Forest 

Plan with regard to the timber resource. Alternatives were specifically designed to meet the purpose 

and need for the project and to be consistent with all applicable forest-wide standards and guidelines. 

Each alternative made a concerted effort to meet the purpose of supplying timber (including young 

growth in three alternatives), while mitigating impacts to other resources.

The Saddle Lakes DEIS, specifically states in the purpose and need (p. 5 Chapter 1) that among the 

goals and objectives (page 5) of the proposed project are development to "respond to the need for a 

stable supply of timber from the Tongass National Forest" and provide a steady, economical supply of 

timber that would support local jobs, and help maintain a sustainable wood products industry in 

Southeast Alaska (page 6). 

The job multipliers from Mehrkens’ declaration were derived from a wider range of years (2002 

through 2011) than the multipliers determined by the Forest Service 2012 (2007 through 2010). The 

declaration also refers to multipliers from before 2002 (years 1991 through 2000) as being lower than 

the current ones. This would be true because of the transition of the Tongass timber program from the 

long-term contracts which included large logging operations and pulp mill employment. Now the 

timber program supports more small operators and the labor associated with each board foot increases 

both in logging an individual tree or a small sale and the manufacture of the trees into more valueadded products at a family-based business. 

Timber Supply and Demand

Commenters addressed numerous items that they believe are flawed in 

determination of demand for timber from the Tongass, both negative and positive. 

They also felt that there were several issues with the information and calculations 

contained in Appendix A of the DEIS.

“Our scoping comments requested an assessment of the acreage that could be sold from the project 

area from other sources, reducing the timber availability concerns that prompted the development of 

this as a significant issue. The DEIS failed to provide this analysis with respect to the AMHT land 

exchange, which significantly overlaps with areas affected by the OGR modification and VPR routes. 

It does not make sense to proceed with a federal timber sale and land exchange from the same area, 

and the timber availability issue should be eliminated along with the proposed TLMP amendments.” 
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508  Appendix D – Response to Comments Saddle Lakes Timber Sale Final EIS

“Using past harvest levels or even the Morse calculation, which is heavily impacted by past harvest 

levels will result in a severe underestimate of demand, because the past harvest levels have been 

heavily constrained by the inadequate supply of timber.” 

“Chapter 3, page 57 seems to suggest that the housing market decline in 2007 reduced the demand for 

Tongass timber. That is incorrect; our larger hemlock trees are used primarily for shop-grade lumber 

that is used for both new construction and remodeling. When housing demand is down, remodeling is 

the alternative and consequently the demand and prices are pretty stable. Much of our spruce is 

custom cut for Pacific Rim customers who did not suffer the 2007 US housing decline. Similarly our 

yellow-cedar is mostly sold to Pacific Rim customers and our redcedar lumber has greatly increased 

in both demand and price; it is currently sold in over 30 states.” 

“The methodology for determining market demand relies on projects in Brackley et al. 2006. [DEIS at 

410]. It is unreasonable to continue to rely on the four demand scenarios, all of which increase over 

time –even the “limited lumber” scenario reflects a demand rising from 49.8 MMBF in 2007 to 55.8 

in 2013...The reliance on these scenarios is unreasonable, and should not be used to justify the timber 

volumes proposed for action alternatives.” 

“The first error in Appendix A is that the Forest Service continues to rely critically on market demand 

projections made in 2006, just before the collapse in housing markets that have proven to be much too 

high.” 

“The second error in Appendix A is its reversion from “limited lumber” to the “expanded lumber” 

scenario from the Brackley report....................This was arbitrary. As described above, the Forest 

Service completely failed to check whether the “expanded lumber” projections comported with actual 

recent cut levels. To reach the expanded lumber projections would require a sudden, massive leap in 

logging levels to heights not seen in well over a decade, and continued rapid growth thereafter. There 

is nothing in the record to support such a sudden change. To fail even to acknowledge this problem 

ignores a critical part of the question before the Forest Service. Further, the two reasons given for the 

change are unsupported by the record. The first reason given was “the export policy,” App. A at 411, 

but the export policy has not changed since 2009. The EA offers no explanation, in Appendix A or 

elsewhere, why a 2009 change in the export policy would suddenly cause an exponential increase in 

demand in 2014. The second reason, “good overseas markets,” id., is simply unexplained in the 

record. The agency’s most recent analysis finds that “exports are not likely to keep prices from 

falling,” a significant problem for an industry already suffering from “low cost margin issues.” 

“The third error in Appendix A is that it fails to calculate the “volume under contract” goal accurately. 

As discussed above, the objective stated in the Forest Plan is, “Provide 2 to 3 year’s supply of volume 

under contract to local mills....” This goal is a “ratio of contract volume to harvest....” In the past, the 

Forest Service has calculated the volume under contract goal as a function of recent past logging 

levels. In Appendix A, however, the Forest Service states that the goal is three years of “annual 

projected harvest.” App. A at 415. Unfortunately, the actual calculation in Appendix A was based on 

neither actual levels cut nor projected cut levels.” 

Forest Service Response

The Forest Service is aware of opposing views, and the Tongass Forest Plan FEIS has addressed 

Brackley and Haynes (2008) in Appendix G and Appendix H (pp. H-26 to H-36). The Saddle Lakes 

Timber Sale project tiers to the Forest Plan FEIS which disclosed and analyzed the timber supply and 

demand issues for the Tongass NF as a whole. The analysis in DEIS Appendix A and the Forest Plan 
Appendix D

Saddle Lakes Timber Sale Final EIS Response to Comments - Appendix D  509

FEIS represent the best available science and have been extensively peer-reviewed. All documents are 

available in the respective project records.

Appendix A- Reasons for Scheduling the Environmental Analysis of the Saddle Lakes Project was 

commented on with opposing views. Some commenters believe the methods used over-predict 

demand, while others argue under-prediction. The fact is these are models and equations that are used 

to “predict”. Appendix A is a management strategic planning tool and should be applied as such. The 

forest-wide planning cycle demand is summarized by four scenarios (Brackley 2006). The DEIS 

Appendix A specified the “expanded lumber” scenario as the prediction model (Alexander 2014). 

This selection is supported by the Forest Plan FEIS and subsequent Pacific Northwest Research 

Station addendums to Brackley and Haynes work. Regardless of the scenario, limited lumber or 

expanded lumber selected, neither exceeds the annual sale quantity 267 MMBF established by the 

Forest Plan. Timber demand calculation for the Forest Service is not based on actual harvest volume 

as a predictor. 

The text in the DEIS on the bottom of page 57 has been updated to read: “Market demand for 

softwood logs and lumber is highly variable. For instance, the U.S. economic downturn that began in 

2007, and the concurrent decline in the U.S. housing market resulted in a dramatically unstable 

market for U.S. logs and lumber. Similarly China’s economic growth slowed in 2011, resulting in 

reduced demand for U.S. log exports (Flynn, 2012).” However, in 2014, the Alaska Regional 

Economist noted that “[d]ue to the export policy and good overseas markets, in addition to recovering 

domestic markets, we are in a medium-low market situation, so use the "Expanded Lumber" estimate 

of 142 MMBF as your guide.” (Alexander 2014) 

While the Forest Service uses the Brackley report to predict long-term demand for the planning cycle 

in the Forest Plan context, the Forest Service uses the Morse methodology to determine the volume of 

timber that should be offered for sale in a given year. This volume is an amount the Forest plans to 

offer in the current year, pending sufficient funding and sufficient NEPA-cleared volume. The Morse 

methodology considers factors such as market conditions and mill capacity and utilization of that 

capacity and seeks to build and maintain sufficient “volume under contract” of timber (i.e. timber 

purchased but not yet harvested) to allow the industry to react promptly to market fluctuations. 

The Forest Service estimates the amount of timber needed to replace volume harvested from year to 

year. This process is adaptive: if harvest levels drop below expectations while other factors remain 

constant, future timber offerings would be reduced to levels needed to maintain the target level of 

volume under contract. On the other hand, if harvest levels rise unexpectedly, future timber volume 

targets would also increase sufficiently to ensure that the inventory of volume under contract is not 

exhausted. The Morse methodology contains detailed, comprehensive monitoring criteria that the 

Forest Service periodically reviews with scientists at the Pacific Northwest Research Station to assure 

they remain up to date. 

Thus, the Morse methodology deals with uncertainty in a flexible, science-based manner. Using the 

Brackley report’s expanded lumber scenario as an input for the Morse methodology, the Forest 

Service determined a timber offer volume of 142 MMBF in FY 2014. Then, in accordance with 

Forest Plan objectives of providing a 2–3 year supply of volume under contract, the Forest Service 

multiplied this amount by three to arrive at 429 MMBF for the long-term volume under contract goal. 
Appendix D

510  Appendix D – Response to Comments Saddle Lakes Timber Sale Final EIS

Transportation

ATM

Commenters had comments related to the ATM and how it would affect the 

cumulative effects analysis for this project as well requested the disclosure of all 

future road closures.

“The DEIS says the transportation system is tiered with the Forest and Regional level roads analyses, 

and the ATM plan. Please carefully consider the proposed action for consistency with the ATM plan. 

Please disclose the relevant portions of those analyses and plans, as they will inform cumulative 

effects analysis.” 

“Road closures should be carefully implemented. All foreseeable uses for project area roads for the 

next thirty years (e.g. thinning) should be disclosed, and roads should be planned to maximize 

efficiency.” 

Forest Service Response:

The existing roads are being managed in accordance with the KMRD ATM decision under all 

alternatives. Proposed roads under all alternatives would also be managed consistent with the KMRD 

ATM decision, with the exception of up to approximately 1 mile of open road on Road 8300280 

which coincides with the DOT&PF's Ketchikan to Shelter Cove Road. Please also refer to page 10 of 

the DEIS, Relationship to the Access and Travel Management Plan.

The road management objectives of these project area roads (both existing and proposed roads) 

are tiered to the District's ATM. The road cards contain the proposed road RMOs. 

Road Design

Commenter suggests modifications to the alignment of several proposed roads, and 

requests that stream crossings be minimized as feasible.

“The Alaska Department of Transportation and Public Facilities requests that the FEIS incorporate a 

slightly modified road alignment in all action alternatives for the proposed one mile of new NFS 

Road 8300280.” 

“Road 8300320: According to the Aquatics section of the road card, this road will cross two Class II 

streams, though, as mapped, the road will cross one Class II stream and one Class III stream. The 

narrative for the second crossing listed (B) states "Road can avoid class II crossing by moving further 

upstream." Therefore, in order to avoid directly impacting resident fish habitat, the crossing site 

should be relocated upstream to the Class IV reach as indicated in the Aquatics narrative.” 

“Road 8330413: As depicted on the road card map, it appears that this road alignment could be 

relocated a few hundred feet west to avoid crossing the mapped Class II stream and its riparian buffer. 

The terrain in this area does not appear to limit doing so. Therefore, if feasible, this road should be 

relocated to avoid resident fish habitat.” 

“Road 8340416: As mapped, this road will cross a Class II stream and run parallel to it through its 

riparian buffer. The Aquatics narrative states "Fish presence verified, lots of Class II tributaries 

mapped during field visit in 2014; Road and Unit 65 should be dropped due to TTRA/RMA buffer.” 

“However, despite this concern and recommendation, this road and Unit 65 remain in Alternatives 2, 
Appendix D

Saddle Lakes Timber Sale Final EIS Response to Comments - Appendix D  511

4, 5, and 6. Therefore, further consideration of the alignment of this road should be given prior to 

approving its construction.” 

“Road 8340500: This road will cross three Class III streams, one Class IV stream, and four Class II 

streams. The Aquatics narrative for one of the Class II crossings (E) states "Class 2 fish stream can be 

avoided if road moved upstream above end of fish habitat." Therefore, if feasible, this should be done 

to avoid impacting resident fish habitat.” 

Forest Service Response:

The effects of existing roads have been analyzed by past NEPA documents and IDT specialists and 

have also been taken into account in this analysis. Existing roads needed for the long-term 

management of the Forest have been identified in the KMRD ATM. 

The road right-of-way will match the final alignment.

Road alignment will be reassessed given the updated aquatics information. If feasible and practicable, 

alignment will be adjusted to avoid the second Class II stream. 

The actual road alignment, as determined in the field after the analysis for the DIES, avoids the Class 

II stream.

8330410 is the road crossing the Class II stream. Crossing and alignment will be reassessed and if 

needed and feasible, alignment will be relocated to minimize stream crossing and buffer impacts. 

Road 8340416 and Unit 65 will be reassessed given the updated aquatics information. 

If feasible and practicable, alignment will be adjusted to avoid the second Class II stream.

Temporary Roads

Commenter believes temporary roads should be obliterated after use and their beds 

deconstructed to prevent sediment from entering waterways.

The commenter requests that the FEIS indicate in the final EIS that all newly constructed temporary 

roads will be obliterated after use and apply the obliteration method that returns the ground to the 

natural angle of repose and eliminates the running surface. 

Roads that will be used again in the future must be constructed to system road standards with 

surfacing and a ditch to reduce sediment generation. If the final EIS does not clearly indicate that 

your proposed temporary roads will be obliterated such that a running surface no longer exists, it will 

show you plan to allow these temporary roads to pump sediment for decades until the so-called 

temporary road is used again for the next timber sale. 

Forest Service Response:

Road decommissioning is defined as activities that result in the stabilization and restoration of 

unneeded roads to a more natural state. (36 CFR 212.1) Each road segment is reviewed to determine 

the appropriate decommissioning strategy. Road decommissioning is preferred because the removal 

of all road material, as in obliteration, causes additional environmental damage. On the Tongass, an 

old roadbed with material in place typically grows over with trees within a decade. There are some 

instances where removal of road material is required or desirable. An example may be where fill is 

needed for another section of road and a decommissioned road is obliterated for that purpose. A 

secondary reason for not obliterating roads is that it is a better expenditure of tax dollars to leave the 
Appendix D

512  Appendix D – Response to Comments Saddle Lakes Timber Sale Final EIS

road in place while mitigating resource concerns through decommissioning activities. The cost of 

removal of the roadbed material can be more costly than that of the original construction. 

Temporary roads are planned for a single use and foreseeable use of the road is not anticipated. Road 

decommissioning is defined as activities that result in the stabilization and restoration of unneeded 

roads to a more natural state. (36 CFR 212.1) Each road segment is reviewed to determine the 

appropriate decommissioning strategy. When roads are decommissioned, all drainage structures will 

be removed. Waterbars and cross drain spacing is determined on an as needed basis. Generally, 

waterbars are placed 150 to 200 feet apart depending on road gradient. Road access is blocked to 

prevent motorized vehicle access. Other measures may be incorporated as necessary. 

Road Maintenance

Commenter believes that deferred maintenance should be treated as a significant

issue, and that there is inadequate information provided within the DEIS related to 

road maintenance.

“The DEIS considers deferred maintenance to be a non-significant issue, and does not discuss it in the 

transportation or aquatic environment sections. This is a major oversight.” 

“However, the DEIS does not describe this system, and no annual maintenance plan was found in the 

project record. Please disclose and consider actual road maintenance plans. This information is 

critical to showing the current condition vis-à-vis aquatic habitat, wildlife and costs, among other 

issues. Please fully incorporate realistic information regarding the maintenance backlog into this 

analysis, and assure that any action does not make the maintenance backlog any worse than it actually 

is.” 

“There is no such thing as a “self-maintaining” road. Please stop planning them. All roads require, at 

minimum, annual monitoring.” 

Forest Service Response:

Please refer to page 20, Deferred Road Maintenance, and page 338, Road Maintenance and 

Reconditioning for information on road maintenance. 

The 2014 Annual Maintenance Plan for the Shelter Cove road system has been added to the project 

record. 

The Forest Plan (p. 4-86) provides direction for roads identified through environmental analysis as 

needed on an intermittent basis to be placed into storage (Maintenance Level I) as funding permits. 

Maintenance Level 1 roads are defined to be in a “self-maintaining status”. A self-maintaining road is 

achieved using the following criteria under National BMP Road-6: Use suitable measures to reduce 

the risk of flow diversion onto the road surface. (1) Consider leaving existing crossings in low-risk 

situations where the culvert is not undersized, does not present an undesired passage barrier to aquatic

organisms, and is relatively stable. (2) Remove culverts; fill material, and other structures that present 

an unacceptable risk of failure or diversion. (3) Reshape the channel and stream banks at the crossingsite to pass expected flows without scouring or ponding, minimize potential for undercutting or 

slumping of stream banks, and maintain continuation of channel dimensions and longitudinal profile 

through the crossing site. (4) Use suitable measures to avoid or minimize scour and downcutting. (5) 

Use suitable measures to ensure that the road surface drainage system will intercept, collect, and 

remove water from the road surface and surrounding slopes in a manner that reduces concentrated 

flow in ditches, culverts, and over fill slopes and road surfaces without frequent maintenance. (6) Use 
Appendix D

Saddle Lakes Timber Sale Final EIS Response to Comments - Appendix D  513

suitable measures to stabilize unstable road segments, seeps, slumps, or cut or fill slopes where 

evidence of potential failure exists.

Road Reconstruction

Commenter requests that road reconstruction be consistent with Forest Plan 

direction, and also requests the clarification several terms such as reconstruction, 

routine maintenance, and obliteration.

“With regard to road reconstruction, the Forest Plan requires repair of situations where use will cause 

environmental impacts inconsistent with Forest Plan direction, and that reconstruction apply BMPs. 

Please be sure to diligently implement this direction on proposed reconstructed roads. Please also 

apply this direction on roads that are not being called “reconstructed,” but that actually have 

conditions that are inconsistent with the Forest Plan.” 

“Please also address how the Forest Service arrives at whether to call roadwork “reconstruction” or 

“routine maintenance.” 

“The commenter requests that the FEIS indicate all temporary roads will be obliterated after use 

making sure to define road obliteration using the statement below (or something similar) to eliminate 

confusion.” 

Forest Service Response:

All applicable Forest Plan Standards and Guidelines, Forest Service Manual and Handbooks and 

(BMPs) are incorporated during the construction, reconstruction, and maintenance of roads. 

Routine maintenance and reconditioning generally refers to work occurring within the disturbed areas 

of the road right-of-way. The term reconstruction is often used inconsistently within the Forest 

Service, but generally refers to work outside of the disturbed areas, such as road realignment.

Road decommissioning is defined as activities that result in the stabilization and restoration of 

unneeded roads to a more natural state. (36 CFR 212.1) Each road segment is reviewed to determine 

the appropriate decommissioning strategy. See response to Temporary Roads page 511. 

Shelter Cove Road

Commenters had numerous questions about the Shelter Cover road connection 

ranging from a lack of consideration of the effects within the DEIS, whether 

alternatives to this road were considered, and questions as to why, or what the 

purpose would be of granting this right-of-way to the State of Alaska to construct this 

road. One commenter feels that providing this road connection is a positive incentive 

for the Forest Service to offer a “profitable timber sale as soon as possible.”

“The Shelter Cover road connection is a major federal action that demands NEPA analysis. The DEIS 

treatment of the issue is inadequate and inconsistent. Please prepare a supplemental DEIS to allow 

public and agency consideration and comment on the issue.” 

“The Shelter Cover road connection is a major federal action that demands NEPA analysis. The DEIS 

treatment of the issue is inadequate and inconsistent. Please prepare a supplemental DEIS to allow 

public and agency consideration and comment on the issue.” 
Appendix D

514  Appendix D – Response to Comments Saddle Lakes Timber Sale Final EIS

“The DEIS fails to present any purpose or need of the road connection. Please fully disclose and 

consider the purpose behind this project, and the reasonably foreseeable outcomes of granting the 

ROW the State is asking for.” 

“The DEIS also fails to provide any alternatives (Road routes), or even discuss consideration of 

alternatives.” 

“[p]roject-level effects (of the timber sale) will be further aggravated if the Ketchikan to Shelter Cove 

road is constructed and the proposed AMHT exchange proceeds as proposed. This is unlawful, and 

the Forest Service should not proceed with the Saddle Lakes project.” 

“The connection is also very relevant to impacts on the transportation system and aquatic habitat. 

Increased traffic on roads is known to increase sediment delivery to streams, and to require more 

frequent maintenance. Traffic in fall (i.e.. deer hunters, firewood gathering) when roads are wettest is 

particularly bad. Yet this major effect is not considered in the transportation or aquatic sections of the 

EIS.” 

“A related concern to the timber sale is the construction of the adjacent State access road from Leask 

Lakes. The Proposed Action includes a section of new road to be built specifically to provide an 

access corridor through to State land to the west, and completing this concept should be added 

incentive for the Forest Service to offer a viable and profitable timber sale as soon as practical.” 

Forest Service Response:

40 CFR § § 1500 through 1508 provide regulations applicable to and binding on all federal agencies 

for implementing the procedural provisions of the National Environmental Policy Act of 1969, as 

amended (Pub. L. 91–190, 42 U.S.C. 4321 et seq.) (NEPA or the Act) except where compliance 

would be inconsistent with other statutory requirements. 40 CFR § 1506.2 Elimination of duplication 

with State and local procedures (b) "Agencies shall cooperate with State and local agencies to the 

fullest extent possible to reduce duplication between NEPA and State and local requirements...such 

cooperation shall to the fullest extent possible include as it says in (b)(2) joint environmental research 

and studies.. The Ketchikan to Shelter Cove road project involves analysis of effects of the entire 

proposed road meeting analysis requirements for this project.

Analysis for the construction of the Shelter Cove Road is being prepared by the State of Alaska 

following the permitting processes outlined by the US Army Corps of Engineers. An opportunity for 

comment and public review of the Ketchikan to Shelter Cove Road project was offered by ACOE, it 

was noticed December 16, 2014, and expired January 15, 2015. 

The purpose and need of the Saddle Lakes Timber Sale does not include the Ketchikan to Shelter 

Cove Road because the projects are not connected. The Ketchikan to Shelter Cove Road project has 

been planned by the State of Alaska since at least 2004 and precedes planning for the Saddle Lakes 

Timber Sale. Planning and permitting for that project is being carried out and analyzed by the State of 

Alaska in coordination with the US Army Corps of Engineers. 

40 CFR § 1502.14 requires that an EIS examine all reasonable alternatives to a proposal, including 

those beyond the jurisdiction of the lead agency, further 40 CFR § 1508.25 (a) (2) directs agencies to 

analyze cumulative actions, which when viewed with other proposed actions have cumulatively 

significant impacts and should therefore be discussed in the same impact statement. Because the road 

project was known and a reasonable foreseeable future action during development of the DEIS, the 

effects of the road project are being analyzed for cumulative effects to resources under the Saddle 

Lakes DEIS. For the purpose and need for the road project, please contact the State of Alaska.
Appendix D

Saddle Lakes Timber Sale Final EIS Response to Comments - Appendix D  515

Four route alternatives were analyzed. Maps and discussion can be found at: 

(https://omb.alaska.gov/ombfiles/13_budget/GO_Bonds/proj59036.pdf). The Saddle Lakes DEIS 

does not consider the use of any of these routes since the road does not exist at this point and has no 

authority to direct development of planning efforts or alternatives of that project. However, the 

potential for connectivity to the Saddle Lakes Timber Sale area was deemed adequate to include 

cumulative effects of this State project in this analysis.

The DEIS pages 26 and 27 states "Connecting to the Shelter Cove road system (to the Ketchikan 

road system) is not necessary for the Saddle Lakes Timber Sale project." Since there is already 

access to the Shelter Cove LTF, it is not a connected action. 

According to 40 CFR § 1508.25 (a) (i,ii,iii), actions are considered connected if they : 

(i) Automatically trigger other actions which may require environmental impact statements.

(ii) Cannot or will not proceed unless other actions are taken previously or simultaneously. 

(iii) Are interdependent parts of a larger action and depend on the larger action for their justification. 

All analyses contained in the Saddle Lakes DEIS for removing harvested timber are specific to the use 

of the Shelter Cove LTF and do not include overland transport outside of the project area. The Shelter 

Cove Road project was proposed by the State of Alaska as an "identified road segment supporting 

implementation of the 2004 Southeast Alaska Transportation Plan". The road project would continue 

even in the absence of any proposed timber sale in the area of analysis and conversely, the proposed 

timber sale would continue in the absence of the road. The State project is "reasonably foreseeable" 

and the potential for use by contractors operating under the Saddle Lakes Timber Sale was enough to 

include consideration of cumulative effects of this State project in this analysis. 

Direct impacts (direct effects) are those which are caused by the action and occur at the same time 

and place (40CFR § 1508.8). The Ketchikan to Shelter Cove Road project is not a connected action 

and analysis is cumulative. Analysis of direct impacts would be carried out in the analysis being 

carried out by the State of Alaska.

Included in the interdisciplinary team were two State employees (via a Memorandum of 

Understanding) who participated in the development of the DEIS (including alternatives). The State 

voiced no concerns over the proposed Ketchikan to Shelter Cove connection road. The Ketchikan to 

Shelter Cove Road crosses multiple land ownerships. The State submitted an application for an 

ACOE permit and the ACOE is analyzing the request.

The Forest Service notifies tribal governments in the region of pending actions through formal

consultation and information sharing meetings. Additionally, tribal governments receive copies 

of documents (including this EIS) and are notified of opportunities to comment. 

Mailing and scoping efforts specifically included individuals, organizations, subsistence users etc., 

holding property or having any interest in the area of analysis. The mailing list is available in the 

project record. 

A subsistence hearing and open house were held during the comment period for the DEIS to provide 

subsistence users an opportunity to review alternatives, discuss the project and provide testimony 

regarding the impacts of the project. Comments received during that process were supportive of the 

Ketchikan to Shelter Cove Road. 
Appendix D

516  Appendix D – Response to Comments Saddle Lakes Timber Sale Final EIS

Please refer to page 346 of the DEIS. Although this effect has been discussed under the No-action 

Alternative, it is described as an effect common to all alternatives.

The proposed Ketchikan to Shelter Cove Road connection is discussed in Chapter 3 in the 

Aquatics section on page 236 under Cumulative Effects Common to all Action Alternatives. “The 

proposed Ketchikan to Shelter Cove Road connection could increase traffic resulting in 

increasing sediment delivery potential. The road would need to be maintained and resurfaced 

more often to minimize sediment delivery to streams and erosion”. In addition to cumulative 

effects listed above for the proposed Ketchikan to Shelter Cove Road, the DEIS also discusses 

direct and indirect effects associated with project roads on page 240 and 241. 

Currently the Shelter Cove road system receives little use by the public (approximately seven groups, 

varying in size from two to five people, were seen using the system this last year). Leask Lake road 

receives no public use as it is still closed to the public. Because the system would be connected, we 

may see an increase in use. Many residents have never visited this area and so once the connection is 

made, we may likely see an increase in use from people exploring the area. However, because it is not

a short drive, mass traffic in this area is not expected. Should this connection be made, a travel

analysis may be warranted as well as an update to the District's ATM Plan, as stated on page 346, but

that is not part of this project.

Please refer to page 26, State of Alaska Right-of-Way on NFS Lands. Roads constructed by the Forest 

Service under this project would be for the specific purpose of accessing harvest units.

The Ketchikan to Shelter Cove Road is proposed by the State of Alaska with permitting carried out by 

the US Army Corps of Engineers, the Forest Service, and AKDNR. Approval/denial of the project is 

not part of the decision for this project since most of the road is not on the National Forest System 

lands. Analysis performed in the Saddle Lakes Timber Sale DEIS was done as part of the cumulative 

effects analysis since the project was determined to be a possible reasonably foreseeable future action. 

Wildlife

Black Bears 

Commenters felt that the black bear analysis did not “adequately address potential 

adverse impacts” of the proposed project activities on black bear habitat. Primarily 

commenters were concerned about the removal of old growth, effects to riparian 

habitat utilized by black bears, and increased road densities within the project area. 

“ADF&G expects black bear densities in GMU 1A to decline in the long term as a result of land 

management activities carried out by the Forest Service and private and state landowners. [Id.] In 

general, we are concerned about the project’s impacts to black bear viability in light of these 

conclusions, and the analysis in the DEIS did not adequately address potential adverse impacts.” 

“We requested that the DEIS clarify whether black bear foraging areas will receive additional 

protections, citing experts recommendations for 500 foot riparian buffers to meet foraging needs. We 

further requested a discussion of impacts to bear habitat at a fine scale, and requested that the DEIS 

do more than catalog old-growth removals at broad scales...But then it failed to respond to the 

substantial cumulative loss of riparian habitat –nearly 40 percent. The DEIS also minimized the 

cumulative loss by excluding potential impacts from the AMHT land exchange, and the DEIS is not 

clear whether or not the analysis factors habitat loss associated with the Leask Lakes project....” 
Appendix D

Saddle Lakes Timber Sale Final EIS Response to Comments - Appendix D  517

“The DEIS should include information about black bear utilization of and impacts to large tree oldgrowth forest, which is the most used habitat type by all bears in all seasons.” 

“The DEIS identifies significant impacts to denning habitat in terms of direct habitat loss and 

clearcutting confirmed den sites, forcing bears to find alternative sites. The analysis fails to disclose 

that black bears in southeast Alaska select for specific denning habitats, meaning that further NEPA 

analysis should consider site-specific features, and avoid clearcutting in areas that provide suitable 

denning habitat...In light of the likely importance of adequate den sites to black bear survivability and 

reproductive success, further analysis and consideration of mitigation measures are needed.” 

 “The DEIS does not adequately address road density impacts to bears, particularly how the Shelter 

Cove Road will change wildlife use patterns. [See, e.g. PR 740_0030]. Additional NEPA analysis 

should be provided.” 

Forest Service Response:

Part of the decision space of the Responsible Official is whether to increase buffers. The importance 

of riparian habitat and effects of harvest within 500 feet of Class I streams is disclosed. “No harvest

within 500 feet of Class I streams” could be proposed as mitigation in the FEIS for the Responsible 

Official to adopt or not. The DEIS on page 3-131 acknowledges that if the land exchange is approved, 

8,170 acres would be taken out of NFS ownership and Forest Plan Standards and Guidelines, 

including beach buffers and RMAs, would no longer apply. Effect of land exchange on denning 

habitat (POG) on NFS land for WAA 406 and WAA 407 combined would be reduced by 23 percent 

from 1954 instead of 19 percent; under Alternative 5 it would be reduced by 9 percent from current 

instead of 3 percent; cumulatively the difference would be a reduction of 26 percent instead of 22 

percent. The wildlife resource report on page 77 says that the Leask lakes results in an additional 4 

percent reduction on denning habitat for combined WAAs. 

Although some wildlife species make higher use of the larger forest types defined by high-volume 

and large tree POG, none of the wildlife species of concern are restricted to these habitats (Forest 

Plan FEIS p. 3-294). 

The wildlife resource report page 20 provides more information on the potential land exchange. 

The commenter did not provide further information on the citation of Dillman, M. 2009. If the 

commenter is referencing the Logjam Wildlife Resource Report written by M. Dillman in 2009, then 

the comment is out of context. Dillman states: "A black bear telemetry study conducted by Erikson

(1982) on Mitkof Island showed high volume old-growth (commercial timber) as the most used 

habitat type by all bears in all seasons..." Commercial timber is POG, not strictly large-tree POG. 

Bear use of POG was analyzed in the Saddle Lakes DEIS. Impacts to the large-tree component 

(SD67) are displayed in the Wildlife Resource Report in the Marbled Murrelet Section. Currently 

there are 1,927 acres of SD67 in the combined project area VCUs. Under the Preferred Alternative, 

there would be about 1,719 acres - a resuction of about 11 percent. HPOG is analyzed under Hairy 

Woodpecker. 

Species viability is addressed at the scale of the Tongass National Forest and not for each project. 

Impacts to black bear denning habitat from Leask Lakes harvest are discussed qualitatively in the

DEIS pages 3-131. 
Appendix D

518  Appendix D – Response to Comments Saddle Lakes Timber Sale Final EIS

The current Forest Plan does not provide any requirements for black bear denning sites. However, 

protecting known active bear den sites with a 300-foot buffer was identified as a possible mitigation 

measure. 

Some of the highest bear harvest continues to come from WAAs 406 and 407 because of its close 

proximity to Ketchikan (Bethune 2011). Due to concerns over the amount of non-resident bear 

harvest, the Alaska Board of Game, at the November 2010 Region I meeting, changed to a drawing 

permit for non-resident black bear hunters hunting without a guide in GMUs 1-3. The Board also took 

the mean annual number of bears harvested by each individual guide from 2007-2009, and used this 

mean to set annual bear harvest limits for each guide.

Road construction removed denning habitat and foraging habitat where roads were constructed 

through POG. The planned Ketchikan to Shelter Cove Road construction would remove additional 

habitat. This road connection is likely to increase hunting pressure within the portions of WAAs 406 

and 407 that can be accessed from the road system. 

The Ketchikan to Shelter Cove Road, if built, could change hunter access and could further reduce 

bear populations within WAAs 407 and 406 west of Carroll Inlet. Regulatory processes limit the 

impacts from hunting within GMU 1A, but localized impacts could occur. No road density thresholds 

for black bears have been identified. 

A Commenter wants the Forest Service to use the interagency habitat capability 

model. 

“Please use the interagency habitat capability model in further analyses in order to systematically 

assess project impacts to black bears. [TLMP at 4-89].” 

Forest Service Response:

The black bear model is not used because black bears are considered habitat generalists.

Brown Creeper Habitat

Commenters expressed concern that fragmentation of brown creeper habitat could 

lead to localized extirpations, and that further NEPA analysis should be considered.

“The DEIS identifies substantial impacts to brown creeper habitat, with up to a 76 percent cumulative 

habitat loss under implementation of Saddle Lakes action alternatives. [DEIS at 149]. There will be 

practically no habitat remaining except in reserves or non-development LUDs.” 

“This project appears likely to create levels of habitat fragmentation and interior forest habitat loss 

that will result in localized extirpations of the brown creeper. Further NEPA analysis should discuss 

the 1997 wildlife viability panel assessments and consider the overall long-term persistence risks, 

including the possible need to designate the species as a sensitive species. [TLMP at 4-89-4-90].” 

“Further NEPA analysis should include a review of possible habitat mitigation measures that include 

reducing interior forest habitat loss and maintaining critical nesting and foraging habitat features.” 

Forest Service Response:

The hairy woodpecker, red-breasted sapsucker, and brown creeper were selected as MIS to represent 

old-growth-associated and snag-dependent species. Although no historic population estimates exist, it 

is likely that timber harvest and associated activities have reduced populations from current levels 

(Raphael 1988; Hejl et al. 2002). North American Breeding Bird Survey (BBS) data collected 
Appendix D

Saddle Lakes Timber Sale Final EIS Response to Comments - Appendix D  519

between 1966 and 2005 suggest populations of all three species are increasing in Alaska, although 

statistically significant State-wide trends have only been detected for the red-breasted sapsucker and 

results maybe confounded by inadequate sample sizes (Sauer et al. 2005). 

The brown creeper requires large diameter old-growth trees (large-tree POG; SD67 type). 

Under all alternatives, the Forest Plan conservation strategy would maintain habitats for these species.

All harvest prescriptions and methods would reduce the number of large trees; however, unevenaged and two-aged harvest would retain some structural components suitable for these species. 

It is the Responsible Official's decision space on which alternative to select. The analysis disclosed 

the habitat loss and potential effects to interior forest species such as brown creepers.

The 1982 Forest Service planning regulations directed that “fish and wildlife habitat shall be managed 

to maintain viable populations of existing native and desired non-native vertebrate species in the 

planning area” 36 C.F.R. §§ 219.19, 219.27(a)(6). For planning purposes, a viable population was 

defined as “one which has the estimated numbers and distribution of reproductive individuals to 

insure its continued existence is well distributed in the planning area.” Id. When preparing the 1997 

Forest Plan and 2008 Forest Plan Amendment, the Tongass National Forest evaluated the Forest Plan 

for compliance with the viability requirements of 36 C.F.R. Part 219. 

Population viability is addressed at the Forest Plan level to comply with NFMA. 

The Forest Service manual directs the Regional Forester to identify sensitive species for each 

National Forest where species viability may be a concern and requires the Forest Service to manage 

the habitat of the species listed in the Regional Sensitive Species List (USDA Forest Service 2009d) 

to prevent further declines in populations, which could lead to Federal listing under the ESA. 

Viability and persistence is a forest-level determination and outside the scope of the Saddle Lakes 

project. The Saddle Lakes project would have localized effects. Habitat for the red-breasted 

sapsucker, hairy woodpecker, and brown creeper would be maintained in the project area under the 

Forest Plan conservation strategy.

Carrying Capacity

Comment: There is a concern carrying capacity modeling does not effectively 

address impacts to subsistence.

“Assumption #2 (that the impact to subsistence can be judged by comparing harvest to carrying 

capacity) falls apart because it is irrespective of the magnitude of the carrying capacity and the size of 

the population (especially a problem when chronically or frequently low) in relation to the carrying 

capacity. Perhaps the approach makes sense in places where the carrying capacity and the deer 

population are ample. However, neither is the case in WAAs 406 and 407 or generally in GMU1A...A further problem is that the analysis has relied only on the reported harvest of deer, but the 

unreported, illegal harvest of deer in GMU-1A is substantial and must also be accounted for...Finally, 

Assumption #2 does not take into account that the impact of habitat loss on the deer population is 

non-linear, with each successive increment of carrying capacity loss having a more negative effect on 

deer numbers than implied by direct consideration of deer model results...... 
Appendix D

520  Appendix D – Response to Comments Saddle Lakes Timber Sale Final EIS

Forest Service Response:

Limitations on using the deer model are disclosed in the wildlife resource report. The reader is 

directed to additional model discussions in the Forest Plan FEIS. Analysis is consistent with Forest

direction. 

The commenter is correct in stating that the subsistence analysis does not take into account that the 

impact of habitat loss on deer populations is non-linear. The fact that the analysis does not take this 

into account does not change the determination of a significant possibility of a significant restriction 

on deer. 

The estimated deer number in both WAA 406 and 407 are discussed and analyzed; there is no data on 

estimated illegal deer and thus no way to account for this. 

Shortcomings of the deer model are discussed on p. 40 of the wildlife resource report and in the 

Forest Plan FEIS on pages 3-231 and 3-323, p. 3-265 to 3-267, and in Appendix B to the Forest Plan

FEIS on p B-1 and B-2. 

Comment: 

Assumption #3 has no scientific basis and its use is specifically precluded by a directive of the 

Tongass forest supervisor. (Puchlerz 2002,98 FY 2000 Monitoring & Evaluation Report at 2-155).” 

Forest Service Response:

Assumption #3 is that predation can adequately be accounted for reducing the modeled carrying 

capacity by 36 percent. There is no scientific basis for 36 percent and its use is precluded by directive 

in the FY 2000 monitoring report. 

According to the FY 2000 Monitoring & Evaluation Report, the 36 percent reduction is not applied 

when calculating the number of deer available to wolves, but is applied to the subsistence calculation. 

Comment: The Forest Service should conduct a whole-island rather than 

biogeographic province analysis for Revilla Island.

“Either the biogeographic province analysis should be abandoned, in favor of instead doing a wholeisland analysis for Revilla Island as advocated below, or the Forest Service should make the effort to 

develop the necessary data to do the all-lands modeling of the carrying capacities that is necessary for 

a valid assessment of the cumulative impacts.” 

Forest Service Response:

The wildlife biologist has pursued this as a data need. The wildlife resource report pages 66-68 

contains a risk assessment for wolf harvest for all WAAs on Revillagigedo Island. 

The deer model was run at the scales as directed by 2011 deer model letter (WAA scale). 

At a meeting on August 23, 2011 Tongass National Forest and ADFG personnel met to ensure 

consistent assessment of deer habitat for project-level analyses related to deer and wolf populations. 

As a result of that meeting, the "2011 Direction for Project-level Deer, Wolf, and Subsistence 

Analysis" was developed. This document clarifies that deer model results do not represent actual 

population density and are not directly related to wolf population viability. Model results represent 

the functioning of the predator-prey system dynamic (Forest Plan FEIS, p. 3-282), and can be used to 

estimate the effects of the project on the availability of deer as food for wolves and for subsistence 

users. The 2011 guidance was used for the Big Thorne Project. The direction in this document is to 
Appendix D

Saddle Lakes Timber Sale Final EIS Response to Comments - Appendix D  521

analyze the direct and indirect effects of the proposed timber harvest on National Forest System land 

only and cumulative effects on lands in all ownerships. 

The deer model was run for the Big Thorne Project according to latest interagency direction. The 

Forest Plan, p. 4-95 says to “conduct analysis at smaller island scale, portions of larger islands or 

among multiple WAAs”. 

The commenter’s concern is that analysis is inadequate without data for other lands. Since there is no 

data or inconsistent or inadequate data for lands in other ownerships the interagency deer model 

assumes that these lands are providing no value at all to deer and assigns them a value of zero. This 

results in the deer model calculations at the cumulative scale are likely to be a conservative number 

and not an over estimation. 

Comment: There is a concern that the carrying capacity for wolf viability is 

inaccurate.

“The DEIS and the Wildlife Report claim that a carrying capacity of only 5 deer/mi2 is needed to 

provide for wolf viability, instead of the Forest Plan’s standard and guideline establishing this 

threshold as 18 deer/mi2...It is apparent from the above facts that the Forest Service’s contention that 

the Suring et al. 1993 proposal of a 5 deer/mi2 criterion should be used is specious. That quantity has 

appeared only in a draft document has been replaced through more refined, peer reviewed science. 

The currently used quantity (18 deer/mi2 carrying capacity) was adopted through a deliberative 

process within the Forest Service, and has been accepted by all agencies.” 

“A TLMP standard and guideline and the science behind it specify that a carrying capacity of at least 

18 deer per square mile is needed to support a viable deer population, added to the demand by deer 

hunters bear and wolves...The carrying capacities for all Action Alternatives in 2014 show an already 

reduced deer population, well below the standard and guideline, even before the timber sale proceeds. 

TCS objects to any further reduction of deer carrying capacity in the project area, even reductions that 

the deer model may not be sensitive enough to detect.” 

Forest Service Response:

The 5 deer/mi2 in Suring et al. (1993) was suggested for viable populations whereas the 18 deer/mi2 

relates to populations capable of sustaining wolves and current hunter demand. Regardless, the DEIS 

clearly identifies that the Saddle Lakes alternatives would reduce densities and increase the risk that 

an insufficient number of deer would remain to sustain both wolves and hunter demand (DEIS page 

3-128). 

Viability is addressed at the scale of the Tongass National Forest. 

The provision (WILD1.XIV p. 4-95) in the 18 deer/mi2 is a guideline and not a standard. The Forest 

Plan directs, but does not require, the Forest Service to: 

Provide, where possible, sufficient deer habitat capability adhere to first maintain 

sustainable wolf populations, and then to consider guidelines but we try meeting estimated 

human deer harvest demands. This is generally considered to equate to the habitat 

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

biogeographical provinces where deer are the primary prey of wolves. 

It is noted that TCS is opposed to any further reduction in the estimated deer carrying capacity. 

(Forest Plan page 4-95). 
Appendix D

522  Appendix D – Response to Comments Saddle Lakes Timber Sale Final EIS

Comment: The Forest Service should revisit subsistence calculations for deer 

numbers in Unit 1A.

“Assumption #1 is clearly incorrect because predation on deer is known to be significant in WAAs 

406 and 407, which normally holds populations at levels below carrying capacity, and deer 

populations on Revilla Island have been specifically identified as being below modeled carrying 

capacity. The subsistence section failed to disclose that “[d]eer numbers are currently at very low 

levels throughout most of Unit 1A.” (ADF&G 2011 and 2013 Deer Management Report[s], both at 

1).” 

Forest Service Response:

Assumption #1 is we have no research that deer are at carrying capacity

The wildlife resource report page 43 shows predation is the primary cause of mortality in adult 

females and yearlings; hunting for adult males and malnutrition for juveniles. 

The GMU 1 intensive management plan says the both wolves and black bears are known to occur in 

GMU 1A and prey on deer. It is unknown if these predators are holding Unit 1A deer population at 

low levels.

No research was provided to support commenters claim that predation is significant in WAAs 406 and 

407 or that predation is the only factor holding deer populations below carrying capacity. Information 

from the deer management report was disclosed. See DEIS Subsistence Section page 3-174: "Deer 

populations on Revillagigedo Island are thought to be at very low levels (Porter 2013a)." 

The GMU 1a Intensive Management operational plan states: “Both wolves and black bears are 

present in Unit 1A and both species are known to prey on deer, however, whether these predators are 

holding Unit 1A deer populations at low levels remains unknown.” 

Deer Habitat Capability

Comment: The deer habitat capability population modelling is incorrect. 

“The Wildlife Report states, “[ ] DHC is essentially the population that could be sustained each year 

through the most restricted period of the year, generally mid to late winter.” (Wildlife Report at 40, 

emph. added). This is fundamental misconception. Deer habitat capability, otherwise known as 

carrying capacity, is the maximum population the habitat can be habitat can be expected to sustain 

under the circumstances in question. In practice, the carrying capacity is rarely attained by an actual 

deer population, particularly in places where there is predation. Certainly the carrying capacity cannot 

be expected “each year,” and moreover because the deer model (which determines DHC) gives values 

for an average winter, severe winter result in populations that are far below carrying capacity. Further, 

habitat loss to logging generally increases the shortfall of an actual population from the carrying 

capacity that would be expected in the absence of the habitat loss.”

Forest Service Response:

The 1997 Forest Plan Appendix N p. N-33 b. states that “The deer model estimates long term carrying 

capacity and assumes that winter range is the limiting factor to deer populations in Southeast Alaska. 

Thus, deer habitat capability is essentially the population that could be sustained each year through 

the most restricted period of the year, generally mid to late winter.”

The Forest Service acknowledges that the deer model accounts for average winters and not severe 

winters and that is why analysis of deep snow deer habitat is included. 
Appendix D

Saddle Lakes Timber Sale Final EIS Response to Comments - Appendix D  523

The wildlife report states "According to the 1997 Forest Plan FEIS (USDA 1997b, Appendix N, p. 

N-33): the deer model estimates long-term DHC and assumes that winter range is the limiting factor

to deer populations in Southeast Alaska. Thus DHC is essentially the population that could be 

sustained each year through the most restricted period of the year, generally mid to late winter. The 

model does not consider annual deer demographics and does not include the annual increment of 

annual spring fawn production that may represent a 20-40 percent increase in population size until 

mid to late winter." Because of identified deer model limitations, the project wildlife biologist also

analyzed changes to deep snow and average snow winter habitats and non-winter habitat based upon 

Tongass and/or Southeast Alaska research. Regardless of methodology used, the bottom line is 

consistent - all action alternatives would reduce existing deer habitat capability or actual habitat

which could lead to reductions in actual deer populations. 

Comment: Reducing deer below 18 inconsistent with Forest Plan determination of 

likelihood of maintain wolf viability. 

“Logging old-growth in derogation of the 18 deer per square mile habitat capability requirement is 

flatly inconsistent with TLMP’s wildlife viability strategy and related claims.............Entering an 

area already deficient in deer winter habitat, measured by the TLMP standard, and substantially 

degrading that habitat further cannot be squared with the agency’s assertions about the benefits and 

assurances provided by the 2008 TLMP amendment.” 

Forest Service Response:

The provision (WILD1.XIV p. 4-95) in the2008 Forest Plan directs the Forest Service to: 

Provide, where possible, sufficient deer habitat capability to first maintain 

sustainable wolf populations, and then to consider meeting estimated human deer 

harvest demands. This is generally considered to equate to the habitat capability 

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

biogeographical provinces where deer are the primary prey of wolves. 

Appendix C Wolf Sustainability, Viability, and Deer Density from the Deer Model 2012 SIRs 

discussion:

Falling below the 18 deer/mi2 does not in itself imply viability concerns for wolves. The above 

standard and guideline was designed to maintain equilibrium populations of wolves and deer while 

also providing for a sustainable harvest of deer by humans (Person et al. 1996). To maintain viable 

wolf populations under the Forest Plan, the VPOP committee recommended that a deer density of at 

least five deer/mi2. This number should be maintained in areas where deer are their primary prey. This 

is well below the standard and guideline of 18 deer/mi2

. In addition, both the 1997 and 2008 Forest 

Plans disclose that deer density, as measured using habitat capability model outputs5

, in a number of 

WAAs may fall below the standard after full implementation of the Forest Plan (Table 3-111, USDA 

1997, pp. 3-77 through 3-79 and Table 3.10-9, USDA 2008, pg. 3-284) and that the deer density in 

many of these WAAs is naturally low because of poor deer habitat. In these areas, wolves may persist 

on other prey such as mountain goats, moose, salmon, beaver, and bear (Person et al. 1996). This 

information was taken into account as part of the wolf viability panel assessment conducted in 1997, 

which concluded there is a high relative likelihood that wolf populations would remain viable and 

well-distributed even with gaps in wolf distribution caused by locally low deer populations or high 

5

 Although deer density outputs from the deer model are useful for estimating changes that result from proposed 

projects, they do not reflect actual known deer numbers. They do represent the functioning of the predator-prey 

system dynamic (2008 Forest Plan FEIS, p. 3-282). 
Appendix D

524  Appendix D – Response to Comments Saddle Lakes Timber Sale Final EIS

harvest of wolves (see Iverson 1997 for a more detailed discussion). The wolf viability panel agreed 

that interactions between wolf population centers would continue with only slight and insignificant 

limitations due to a gap of the size of a pack home range (roughly 100 mi2 or the size of a typical 

WAA); however they did not agree on the definition of well-distributed wolf populations, but did 

agree that the combined implementation of the system of large old-growth reserves that serve as 

source populations of wolves, Forest Plan Standards and Guidelines that promote deer habitat 

capability in the matrix and limit road densities, and planned level of timber harvest would have a 

high likelihood of maintaining viable and well-distributed populations of wolves. 

Comment: The Forest Service should include the AMHT logging and potential land 

exchange in the cumulative effects analysis.

“The Forest Service fails to adequately assess cumulative effects to deer habitat capability. It doesn’t 

include Leask Lake clearcut logging by the Alaska Mental Health Trust Authority (AMHT) or 

identified future projects, including the potential exchange of 8,170 acres.” 

“The Forest Service informs reviewers of the proposed land exchange with AMHT, but they fail to 

provide quantified or detailed information on the cumulative impacts to deer habitat capability if the 

exchange proceeds. Although the DEIS provides general statements, it fails to give a detailed look at 

the cumulative or synergistic impact of land management activities on other and adjacent 

landownerships when combined with past and proposed clearcut logging of old-growth on this project 

area.” 

Forest Service Response:

The AMHT land exchange was not included in the cumulative effects analysis because at the time of 

the analysis the land had not been conveyed. 

The wildlife resource report discloses the unavailable information (i.e., POG breakdown) and the 

assumptions used for Leask Lakes. Although AMHT has indicated in their 2014 Management Report 

that they would log the area if the exchange is approved, no specific details are available at this point.

Effects are discussed qualitatively under Deer Cumulative Effects in the DEIS page 3-118. 

The deer model assigns all non-NFS lands, including Leask Lakes, zero habitat capability and may 

overestimate the degree of effects. 

No decision has been made on the exchange. If it moves forward, NEPA would be required and 

commenters will have a chance to submit comments on the exchange. 

Deer Habitat/Deer Winter Range

Comment: Commenters disagree with the relevance of literature cited in the DEIS 

related to deer habitat and winter range.

“With regard to the stated 50-year timeframe for deer habitat impacts in partially harvested stands, we 

cannot tell where this number came from. It is not found in any of the studies...No citation or analysis 

is given to support that figure. Additionally, if 50 years were the correct figure, then DEIS statements 

that habitat effects of partial harvest would be “short-term” should be removed. Fifty years is not 

“short-term.”

“According to the DEIS, those stands will result in a 50-year reduction in deer winter habitat quality, 

citing Deal (2001), Deal & Tappeiner (2002), and Deal et al. (2009). However, these studies do not 

fully support the contentions for which they are cited.” 
Appendix D

Saddle Lakes Timber Sale Final EIS Response to Comments - Appendix D  525

“Deal (2001) investigated the effect of various retention levels on the production of deer browse. 

However, it has little relevance to deer winter range issues because it considered only browse 

production generally and not winter conditions in the managed stands, and because one of site 

selection criteria was that the partial cut areas be at least 10 hectares (25 acres) in size.”

“Deal (2007) is largely about red alder, and it is concerned with biological diversity and focuses deer 

and what it loosely calls “habitat capability.” However, a thorough read shows that this paper has little 

applicability to the deer winter range issues...” 

“Hanley et al. (2006), ... determined “the number of deer-days that the food base could support at that 

specified level of nutritional requirements,” and then explained: For simplicity, we termed that 

number “carrying capacity” (deer-days per hectare) while fully realizing that our value does not 

involve any consideration whatsoever of the dynamics of plant–herbivore interactions or the longterm sustainability of that level of use. Our estimates of food biomass in winter were the summer 

values minus all deciduous species or plant parts; we did not include any effect of snow. In contrast, 

the term carrying capacity (or habitat capability) for deer as conventionally used on the Tongass, 

including for the Saddle Lakes project, is very much about the effect of snow.” 

Forest Service Response:

"Roughly" 50 years was used as a timeframe based upon information in Deal et al. (2009) as cited. 

Using the available research, the effect of partial cutting is "shorter-term" than the 150 year to 

permanent impact of clearcutting. Deal 2009 says “Fifty years after partial cutting, tree diameters, 

large tree numbers, species composition, stand complexity, and understory diversity were similar to 

original stand conditions.” 

The permanent effect of clearcutting is due to the fact that the stand could be re-harvested before 

regaining old-growth characteristics. The effects of snow and the ability of the canopy to intercept 

snow were considered in the analysis.

Stand structural diversity and plant composition and abundance were much greater in partially cut 

stands than in young-growth stands developing after clearcutting (Deal, 2001, Deal and Tappeiner 

2002). The stand structures that develop after partial cutting create structurally complex, multilayered forest canopies that are much more similar to old-growth stands than to the uniform younggrowth stands that develop after clearcutting. The presence of large and small residual trees left after 

partial cutting creates structural heterogeneity and complex overstory–understory interactions, and 

these structures may be important for maintaining abundant and diverse understory plant 

communities" Deal et al. (2009). Based upon this information, the wildlife biologist concluded that 

partial cutting would affect deep snow and intermediate winter habitat until sufficient canopy closure 

occurred to provide snow interception. Timeframe would be influenced by removal pattern and 

silvicultural prescription (Wildlife Resource Report pages 43 and 44). Page 41 discusses partial 

harvest and effects of retention. Deep snow is discussed on pp. 42 and 43. 

The DEIS page 3-112 acknowledges that "... partial cutting, at least in the short-term, opens the 

overstory canopy and thus provides less snow interception. Actual change in canopy depends upon 

the intensity of the treatment and individual stand prescription ..." . Winter conditions are considered 

in the deep snow and intermediate snow deer sections. 

The Forest Service disagrees that the reference Deal 2001 is not relevant. Partial-cut units retain some 

trees (66 percent) in the managed stands that and be capable of intercepting snow and making forage 

available in the winter. Fifty years after partial cutting, tree diameters, large-tree numbers, species 
Appendix D

526  Appendix D – Response to Comments Saddle Lakes Timber Sale Final EIS

composition, stand complexity, and understory diversity were similar to original stand conditions 

(Deal 2009). 

A comment above stated a concern with Deal 2007. The Deal (2007) reference is not part of the 

Saddle Lakes deer winter range discussion. DEIS, page 3-128 under Black Bear states "Partial-cut 

units would continue to provide forage (Deal 2007); actual change in available forage would depend 

upon individual stand removal pattern." According to Deal 2007, page 529 "Overall, partial cutting 

maintained diverse and abundant plant understories comparable to the plant communities typically 

found in old-growth stands." 

Hanley et al. (2006) was neither listed in Greenpeace reference section or exhibits so an assumption 

was made that commenter meant Thomas A. Hanley, Robert L. Deal, and Ewa H. Orlikowska. 2006. 

Relations between red alder composition and understory vegetation in young mixed forests of 

southeast Alaska. Since the Saddle Lakes project is not proposing planting alder after harvest, this 

research was not considered essential to the analysis. The analysis includes effects of timber harvest 

on forage abundance and availability. According to the Forest Plan FEIS, page 3-230, the quantity, 

quality, distribution and arrangement of winter habitat are considered the most important limiting 

factors for Sitka black-tailed deer in Southeast Alaska. The effects of snow and the ability of the 

canopy to intercept snow were considered. Deal provides evidence that old-growth stand structure 

returns in approximately 50 years (from the resource report “Fifty years after partial cutting, tree 

diameters, large tree numbers, species composition, stand complexity, and understory diversity were 

similar to original stand conditions (Deal 2009).” The stand structure is what provides snow 

interception. 

Comment: The Forest Service should clarify modeling of the stem exclusion stage 

of young-growth forests on slopes over 35 percent. 

“Chapter 3, page 79; The discussion about the stem exclusion stage of a young-growth forest makes 

it sound like an young-growth stands or the average young-growth stand progresses through the stem 

exclusion stage as described. The reality is that the description on page 79 might be accurate for 

highly productive stands on gentle slopes, but not on most slopes greater than 35

percent...............................The entire stem-exclusion, critical deer winter range issue has been greatly 

exaggerated by activist biologists and I encourage you to put the issue in perspective in the final 

Saddle Lakes EIS and I also encourage you to sponsor some unbiased research into the issue of stemexclusion and critical deer winter range, because there are lots of deer, bears, wolves and other 

wildlife thriving in and around our young-growth stands.” 

Forest Service Response: 

See cited research in the DEIS and Wildlife Resource Report and EIS. This research includes Alaback 

1984, Alaback 2010; Deal and Tappeiner 2002; Person and Brinkman 2013; Cole 2010, Hanley et al. 

2013; Alaback 2010; Cole 2010; McClellan et al. 2014; Alaback et al. 2013; USDA 2008c, p. 3-2; 

Person et al. 1996; Hanley 1984; Parker et al.1999. 

Stands not in stem exclusion due to low site productivity appear to be the exception. 

A search of a silvicultural bibliographic database showed no records containing slope and thinning 

(personal communication S. Spores 24 April 2015). 

Studies like the Common Stand Density Study and TWYGS do show that stem exclusion intensity 

varies by site productivity. There is no literature regarding stem exclusion by slope percent.
Appendix D

Saddle Lakes Timber Sale Final EIS Response to Comments - Appendix D  527

Comment: The Forest Service assertion that logging causes a permanent loss of 

winter deer forage is unsupported.

“Chapter 3, page 111; The document provides a quote - "Although during summer and mild winter 

conditions, deer may benefit from young clearcuts, the long-term prognosis is permanent loss of 

suitable foraging habitat'. This assertion that a permanent loss of winter deer forage results from

logging is simply an unsupported opinion, not a fact........ Again, we urge you to keep in mind that the 

increased winter deer mortality hypothesis has never occurred after more than 60-years of logging 

and the two most heavily logged watersheds on Prince of Wales - Harris River and Staney Creek - 

still have abundant deer, bear and wolves some 50+ years after the initial logging took place.” 

Forest Service Response:

The quote is from published scientific literature (Person and Brinkman 2013) and their conclusion is 

based on the data collected for this study. No opposing research or ADFG management reports were 

provided to support the commenters claim. Additional published research on the effects of stem 

exclusion were included in the DEIS and Wildlife Resource Report. See response above for citations 

of literature on stem exclusion. No opposing research or ADF&G management reports were provided 

to support commenters claim. 

Deer Model

Commenters believe the deer model was run incorrectly, and question the validity of 

the model in general.

Comment: The size density model is not accurate enough to assess actual impacts.

“[t]he DEIS indicates that the Size Density Model used in the deer model is only 70 percent accurate; 

maybe good enough for comparative purposes, but not good enough to assess actual impacts...” 

Forest Service Response:

The deer model is described in detail in the wildlife resource report. It states that model results do 

not represent actual deer populations. The deer model was run as directed and uses the best data 

available at the time of the analysis. The size density information is not the only input into this 

model. 

The size density model (SDM) being 70 percent accurate is a result of how the SDM was developed,

not a product of the deer model. The deer model uses the SDM as directed. The size density model 

(SDM) GIS layer was used to classify wildlife habitat. This model has been shown to be 70 percent 

accurate at the forest level. Caouette and DeGayner 2008 states “We estimate the predictive qualities 

of the size density model to range between 60 and 80 percent comparable with the estimated 65-70 

percent forest-mapping accuracy rates reported in other parts of the Pacific Northwest (Spies and 

Cohen 1999).” 

Comment: The Forest Service has underestimated deer densities by assuming nonfederal lands have no value for deer.

“Page v states that modeled deer densities will fall below the Forest Plan Standard and Guideline of 

18-deer per square mile, but it should also state that the deer model overstates the actual impacts 

because it assumes almost no deer habitat on young-growth stands or on private lands and we know 

that there are good populations of deer and other wildlife in both the young-growth stands and on 

private timberlands.” 
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528  Appendix D – Response to Comments Saddle Lakes Timber Sale Final EIS

Forest Service Response:

Young-growth habitat is discussed in the DEIS page 3-107 "Young-growth thinning can delay the 

onset of stem exclusion or temporarily improve low light conditions, but thinning benefits typically 

last 15 to 20 years (Alaback 2010, Cole 2010, McClellan et al. 2014)." Deer model assigns younggrowth a very low value for deer due to the lack of forage species present; the deer model assigns all 

lands that are not in federal ownership a value of zero. As a result of the deer model assigning a zero 

value to non-NFS lands the resulting calculation is a conservative value and likely underestimates the 

modeled deer density. The current interagency approved deer model also likely underestimates the 

value of young CC based on TWYIGS study. Some forage species, such as Vaccinium, likely are 

present in these young stands even with snow. 

 The deer model is discussed in both the DEIS and the Wildlife Resource Report. 

Comment: The Forest Service should include non-Federal lands in the deer model. 

 “In the section of the DEIS on cumulative impacts to wolves there are two tables which give the 

model results for two or three of those time periods, Tables 44 and 45. However, it is obvious that 

there is a significant difference in the historic and current time period results in the two tables, for the 

two WAAs that are of primary interest for this project, WAAs 406 and 407. The reason for this 

difference is given in a footnote to Table 45: “All non-NFS lands were assigned zero habitat 

capability (historic and present) due to lack of non-NFS data at the biogeographic province scale and 

to be consistent with Forest Plan methods.” That is, the entirety of each WAAs was not considered, 

and in fact for some WAAs the consideration of a large proportion of the habitat land area was 

omitted. Simply put, this practice fails to provide a reasonable baseline for determining cumulative 

impacts, nor can it be used in determining the cumulative impacts at present or in the future.” 

“Table 45 compares the above current modeling for biogeographic province to other modeling done 

for the province’s WAAs for the 1997 and 2008 Forest Plans. All three sets of model results are 

invalid...The 1997 model results are invalid for two reasons. A misuse of the conversion factor (called 

the “deer multiplier”) caused an across-the-board 30 percent overestimation of carrying capacity. The 

conversion factor renders the model’s native output (a unitless quantity) to a value with units of deer 

per square mile. The second problem was that the vegetative dataset that was used (called VolStrata) 

has no correlation to habitat quality, as the Forest Service discovered in 2000...The 2008 model 

results in Table 45 are invalid for two reasons. In this modeling (as in the current modeling shown in 

table), non-federal lands were scored as having zero carrying capacity. While this assumption is 

reasonable for looking ahead to the future (when essentially all of commercial timber on non-federal 

forestlands is likely to be logged), it is unrepresentative of the historic condition of the WAA. In some 

WAAs it is also unrepresentative of the current condition. A further error in the 2008 modeling is that 

the land area of non-federal lands in a WAA was not included in the denominator when calculating 

the carrying capacity.”

Forest Service Response:

The entirety of each WAA was included (i.e., all land acres included), but non-NFS lands were 

assigned zero habitat capability. The Forest Service acknowledges that the lack of data on Non-NFS

lands and that the results may be an unrepresentative analysis of historic conditions but we simply do 

not have that data and are using the best information that is available. 

The best available information was used for the project analysis. Differences between the methods are 

disclosed. The differences in how the model has been run over the years have resulted in different 

outputs. Each version of the model over the years has been based on the best available information at 
Appendix D

Saddle Lakes Timber Sale Final EIS Response to Comments - Appendix D  529

that time. The commenter is incorrect in the interpretation of the model that the deer multiplier

converts deer to deer density and that the vegetative dataset was used. Court rulings state that there 

is no difference between VC 6 and 7, which resulted in it being collapsed into SD67. 

Regardless of method, the number of WAAs below 18 deer/square mile are relatively similar. The 

wildlife resource report concludes on page 70: "The above data suggests that, based on modeled deer 

densities, Saddle Lakes area WAAs and the Revilla Island/Cleveland Peninsula Biogeographic 

Province may not be capable of sustaining wolf populations and meeting hunter demand." The EIS 

should identify the differences in how the deer model was between years and that needs to be taken

into consideration when comparing data. The 1997 model was revised due to the misuse of the 

conversion factor (called the “deer multiplier”) that caused an across-the-board 30 percent

overestimation of carrying capacity. The second problem was that the vegetative dataset that was used

(called VolStrata) has no correlation to habitat quality. This was also addressed and the current deer

model uses the size density model instead of VolStrata.

The concern that the 2008 model results are invalid because the land area of non-NFS lands in a WAA

were not included in the denominator when calculating the carrying capacity has also been addressed. 

The 2008 deer model was revised to include all non-NFS lands in the denominator when calculating 

carrying capacity. The remaining concern with the 2008 model runs that the non-NFS lands were 

scored as having zero carrying capacity which is unrepresentative of the historic condition of the 

WAA and may also be unrepresentative of the current condition has not yet been addressed. 

Deer/Wolf Populations

Commenters question the stability of the deer and wolf populations within the project 

area.

“Population “stability” and equilibrium between deer and wolves cannot be assumed...Predator-prey 

equilibrium needs different treatment in the EIS...Nonetheless, it is not known whether there is a 

“current equilibrium” between deer and wolves on Revillagigedo Island...material from page 15 of 

Person et al. should not stand alone, and from a few pages later this crucial clarification (which 

follows a discussion of the effect of a changing equilibrium ratio) should be added to the DEIS.” 

“The DEIS concludes that the wolf population in GMU-1A “appears to be stable” (at 92) and “is 

thought to be stable (at 128), on the basis of wolf harvest records and the fact that the Board of Game 

allows unlimited trapping. This information is not specific to the WAAs affected by the project, and 

despite the lack of “statistically reliable population estimates” even for whole GMU. (Id. at 92)...We 

caution that the word and concept of stability can well be misused in a situation such as exists in the 

management unit and the project’s WAAs, where deer and wolf numbers are both believed to be low 

and there has been substantial habitat loss and roading. Even if the deer and wolf populations have 

been steady for a period of years (no one knows for sure), that is no assurance that the dynamic 

predator-prey system is stable...The DEIS and the decision maker should not rely on a notion of 

stability unless it can be firmly demonstrated, in view of the cumulative impacts in the project area 

and island-wide. The assumption of stability is also undercut by the recent ESA listing finding by Fish 

& Wildlife Service (740_0810).” 

“The cumulative effects of any action alternative combined with past and future logging will cause 

further declines in deer populations as referenced throughout the DEIS. This is true not only of lands 

currently managed by the Forest Service, but also of lands managed for clearcut logging by the 

AMHT...............To omit these realities when reporting cumulative impacts is to tell an incomplete 
Appendix D

530  Appendix D – Response to Comments Saddle Lakes Timber Sale Final EIS

story, ultimately failing to analyze the actual impacts to deer habitat that any Saddle Lakes action 

alternatives will have.” 

“Tongass Conservation Society is concerned about deer and wolf populations in the Saddle Lake area. 

Because of past logging on Revilla Island, the deer numbers in the Saddle Lakes region are 

insufficient to provide for hunting, subsistence and maintaining sufficient numbers for wolf 

predation...Past harvests combined with this sale, in addition to increased road building will result in 

steeply decreased deer populations.” 

“In the DEIS page 174, it states that "changes in deer abundance from timber harvest and increased 

road access to deer by both rural and non-rural hunters would affect competition for deer", continuing 

with the statement that less expensive access by vehicles results in increased competition. The DEIS 

fails to remediate concerns beyond timber cutting, ignoring the uses placed on the area by humans 

and wildlife.” 

Forest Service Response:

The wildlife resource report discloses impacts to equilibrium and increased instability on pages 55 

and 69. 

Although AMHT has indicated in their 2014 Management Report that they would log the area if the 

exchange is approved, no specific details are available at this point. No decision has been made on the 

exchange. If the land exchange moves forward, NEPA would be required and the public given a 

chance to submit comments. See response above.

Each alternative was analyzed for its effects on subsistence resources and the effects acknowledged in 

the subsistence section of the FEIS. 

A deer population at carrying capacity should be able to support a hunter harvest of approximately 10 

percent of the habitat capability that is sustainable and provides a reasonably high-level of hunter 

success (USDA 1997b, p. 3-596, USDA 2008c, pp. 3-428). Hunter success can be expected to decline 

when demand represents 10 to 20 percent of habitat capability and hunters may experience moderate 

difficulty in obtaining deer. Hunter may have to spend more time and effort and/or success may 

decline. If demand exceeds 20 percent of habitat capability, harvest of deer by hunters may be 

restricted, either directly through restrictions in seasons and bag limits, or indirectly through reduced 

hunter efficiency and increased difficulty in obtaining deer relative to historical rates. 

A demand of 190 deer equates to 8 percent of the historic habitat capability in WAA 406 (Table 58). 

Hunter demand equates to 12 percent of the existing habitat capability in WAA 406. A demand of 142 

deer equates to 9 percent of the historic habitat capability in WAA 407. Demand equates to 21 percent 

of the existing habitat capability in WAA 407. 

All alternatives would have less than 1 percent change initially and at stem exclusion in WAA 406. 

Demand would remain at approximately 12 percent of habitat capability but this percentage could 

increase with the State road connection. Actual increase may be offset by already low deer 

populations in GMU 1A that are causing some hunters to hunt elsewhere (see Porter 2013a). 

All alternatives would have a 1 percent change initially in WAA 407. Demand would increase initially 

from 21 to 22 percent of habitat capability. Over the long-term, the proposed harvest would develop 

into stem exclusion and further reduce habitat capability. Assuming demand remains relatively stable, 

demand at stem exclusion would equal 22 to 23 percent of habitat capability within WAA 407. 

However, similar to WAA 406, demand may increase with increased access. 
Appendix D

Saddle Lakes Timber Sale Final EIS Response to Comments - Appendix D  531

Current and projected deer demand in WAA 407 is at the level (>20 percent) at which deer harvest 

may be restricted, either directly through restrictions in seasons and bag limits, or indirectly through 

reduced hunter efficiency and increased difficulty in obtaining deer relative to historical rates. This 

appears to fit with the harvest survey data in that WAA 407 has a lower success rate than WAA 406. 

Based upon the 2002-2011 harvest data averages (Porter 2013b), 38 percent of all hunters were 

successful in WAA 406 whereas only 23 percent were successful in WAA 407. These numbers should 

be used with caution, however, since hunters may not hunt for a variety of reasons. 

According to the 2013 ADF&G Deer Management Report, GMU 1A deer numbers are no longer 

meeting local hunter demands (Porter 2013a). 

Trends are not likely to change as a result of the Saddle Lakes project. Non-rural Ketchikan hunters 

are expected to harvest the majority of deer taken from WAAs 406 and 407. Therefore, reductions in 

habitat capability to support deer could lead to increased competition between rural and non-rural 

hunters for available resources. With additional loss of habitat due to timber harvest, ADF&G expects 

to see long-term negative effects on deer numbers and hunter success in most areas near Ketchikan 

(Porter 2013a). 

Demand may also increase with the road connection to Ketchikan. Use from Metlakatla may increase 

causing additional completion between rural subsistence users. Additional non-rural and non-resident 

hunters may hunt the area given the easy access to and from Ketchikan. If future restrictions are 

necessary due to increased demand and less deer, then Ketchikan and other non-rural hunters would 

be restricted first. If further restrictions become necessary, then a positive “customary and traditional 

use” determination could be made for Saxman and potentially Metlakatla restricting other 

subsistence. 

Impacts to deer and wolves are disclosed in the wildlife resource report and summarized in the EIS. 

All relevant information and best available science was applied and incorporated into the analysis. It 

is the Responsible Official's decision space on which alternative to select. 

Comment: The road density standard and guide should be triggered due to 

concerns regarding the accuracy of the overkill analysis. 

The DEIS offers no convincing analysis on why Forest Plan standard and guideline XIV.A.1 should 

not be triggered. The overkill analysis (Wildlife Report at 65-67) has not been peer reviewed, relies 

on scanty data, and applies directly a calculation that was developed for a different game management 

unit where the circumstances differ from Revilla Island. The calculation does not take into account 

the illegal take of wolves...Give the acknowledged low wolf population and the existing problems 

with at least unsustainable or chronically unsustainable harvest in project area WAAs, and the high 

road density, the road density standard and guideline should be triggered for this project. We believe it 

is clear that there is a conservation concern in fact.

Forest Service Response:

Wolf populations within GMU 1A are currently thought to be stable with unlimited trapping allowed. 

Intensive management for deer by ADF&G could further decrease wolf populations in the project 

area if expanded to the Saddle Lakes WAAs. 

The analysis in the wildlife resource report pages 66 -67 used Person and Logan 2012. The resource 

report analysis says that in looking at individual years between 2000 and 2013 (Table 20), WAA 406 

had annual harvests of ≥three wolves eight times during the 14-year reporting period indicating that 

WAA 406 is at risk for chronic unsustainable mortality. WAA 406 also showed pack depletion 
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532  Appendix D – Response to Comments Saddle Lakes Timber Sale Final EIS

(harvest rates ≥seven wolves) twice during the reporting period. WAA 407 had annual harvests of 

≥three wolves three times during the 14-year reporting period indicating risk of unsustainable 

mortality, but not chronic unsustainable mortality. No pack depletion (≥seven wolves harvested) 

occurred in WAA 407. As with WAA 406, boats have been the most commonly used access method in 

WAA 407, but access could change with the completion of the Ketchikan to Shelter Cove Road and 

mortality could increase. The resource report also acknowledges that the average wolf pack size on 

Prince of Wales (seven to eight wolves plus one to two non-resident wolves) is slightly higher than 

the average of 5.4 wolves/pack reported by Smith (1987) for Revillagigedo Island; therefore, risk may 

be higher. 

The standard and guideline above is for the wolf habitat management program (WHMP) and it states 

that where wolf mortality concerns have been identified develop and implement a WHMP in 

conjunction with ADFG. 

The Saddle Lakes area is not part of the State of Alaska’s wolf eradication intensive management 

proposal, but it does fall within the same Revilla/Cleveland biogeographic province and same GMU. 

ADFG is currently analyzing the feasibility of intensive management (predator control) within 

portions of GMU 1A in an attempt to increase deer populations (Alaska Statute AS 16.05.255(e)). 

It is uncertain what, if any, regulatory changes on wolf harvest limits would occur given the State of 

Alaska’s intensive management goals for GMU 1A and/or the positive 90-day finding on the wolf 

recently released by USFWS.

Person and Logan urged caution about inferring the sustainability of wolf harvest for any particular 

WAA without considering neighboring areas. Wolf harvest was analyzed for Revillagigedo Island to

determine widespread risk of unsustainable mortality (Table 21 and Figure 13). Revillagigedo Island 

consists of 8 WAAs. For the timeframe that was analyzed (2000-2013) WAA has experienced a risk 

for pack depletion (> seven wolves/pack harvested) two times. None of the other 7 WAAs have 

experienced a risk of depletion. The risk for unsustainable harvest has been experienced in 6 of the 

WAAs but only WAA 406 experienced the risk of chronic unsustainable harvest. Three of the WAAS 

on Revillagigedo Island have no development LUD acres in the WAA. Two of these three WAAs did 

not experience unsustainable harvest for the years 2000 -2013. 

The wildlife resource report pages 66-67 identified potential differences between Prince of Wales 

and Revillagigedo Island wolf packs. The DEIS pages 3-126 and 3-128 discuss effects of high 

road densities and that cumulative impacts could lead to a wolf mortality concern. The decision 

maker must consider all relevant information and best available science was applied and 

incorporated into the analysis. 

The wildlife resource report p. 56, states, “Where road access and associated human-caused mortality 

has been determined, through an interagency analysis, to be a significant contributing factor to locally 

unsustainable wolf mortality, incorporate this information into Travel Management planning and 

hunting/trapping regulatory planning.” The objective is to reduce mortality risk and a range of options 

to reduce this risk should be considered. In these landscapes, both open and total road density should 

be considered. Total road densities of 0.7 to 1.0 mile per square mile or less may be necessary. 

Options shall likely include a combination of Travel Management regulations, establishing road 

closures, and promulgating hunting and trapping regulations to ensure locally viable wolf 

populations. p. 59-60 Road density effect on wolf mortality has not been an issue in WAAs 406 and 

407 in the past due to the lack of road connection to a community. Since the project area would be 

road accessible from the communities of Ketchikan and Saxman in the near future, I calculated road 

densities below 1,200 feet in elevations to determine the effects of road access on potential wolf 
Appendix D

Saddle Lakes Timber Sale Final EIS Response to Comments - Appendix D  533

harvest (see Table 17). Wildlife resource report page 65 also states: “While mortality of wolves 

from higher road densities has not been a concern in the past, dynamics could shift with the 

completion of the Ketchikan to Shelter Cove Road.” 

Fragmentation and Connectivity

Commenters have multiple concerns related to fragmentation and connectivity within 

the project area due to past harvest.

Comment: There should be no concerns regarding connectivity.

“Connectivity concerns are silly, given that none of the wildlife in Southeast Alaska has 

any difficulty walking or flying through or across young-growth stands.” 

Forest Service Response:

The Forest Service believes that there is a connectivity concern (see Forest Plan FEIS Chapter 3 and 

Appendix D) for species with limited mobility such squirrels. 

We have used the best available science on connectivity in our analyses. Further information, 

including citations, are provided in the wildlife resource report page 13 and included in the project 

record. 

The wildlife resource report discusses that within the matrix, components of the old-growth 

ecosystem are maintained by standards and guidelines to protect important areas and provide 

old-growth forest habitat connectivity (USDA 2008d, Appendix D, p. D-3). 

This topic was of notable concern to the Pacific Northwest Research Station Review scientists who 

suggested that more attention be directed to this component of landscape conservation planning. They 

particularly noted the need to provide enhanced landscape connectivity and to manage human 

disturbance of the land similar to natural disturbance regimes (Kiester and Eckhardt 1994). Person 

and Brinkman (2013) state that the matrix will likely play a critical role in sustaining wildlife habitat 

and subsistence uses.

Landscape connectivity is defined as the degree to which the structure of a landscape helps or hinders 

the movement of wildlife species (Taylor et al. 1993). On the Tongass, landscape connectivity 

between old-growth forest patches or between high- and low-elevation habitats is important to 

maintaining well-distributed, viable wildlife populations (USDA 2008c, p. 2-54). 

The percentage of the original POG forest no longer in an old-growth condition can serve as an 

indicator of the potential effect on several biodiversity aspects, including structural (within-stand) 

diversity, connectivity (unfragmented, continuous old-growth blocks), and overstory and understory 

species composition (USDA 2008c, p. 3-151). 

Comment: There is a lack of connectivity.

The DEIS and record clearly indicate that connectivity is already lacking due to the large amount of 

private land, significant past harvest, and lack of intact beach fringe, and that the majority of action 

alternatives include units that further eliminate key corridors –thus, the project appears almost certain 

to be inconsistent with the guideline...Thus, it appears that a substantial amount of units should be 

dropped to meet the guideline. 
Appendix D

534  Appendix D – Response to Comments Saddle Lakes Timber Sale Final EIS

Forest Service Response:

See connectivity discussion, wildlife resource report page 31. This comment is referring to a Forest 

Plan Guideline which states "design projects to maintain landscape connectivity” p. 4-91. However,

these guidelines and objectives apply to maintenance of corridors at the landscape scale. 

The DEIS states 1. Landscape Corridor between Medium OGRs and other non-development LUDs 

(WILD1.VI, p. 4-91). Connectivity currently exists between the medium OGR partially within the 

north end of the project area and Naha LUD II through the North Revilla Inventoried Roadless Area 

(#526). The planned corridors are in compliance with Forest Plan landscape connectivity direction 

(USDA 2008b, WILD1.VI, p. 4-91). Connectivity is not expected to not change as a result of Saddle 

Lakes. 

Comment: This project will further impair lateral and elevational connectivity.

 “In our scoping comments we highlighted the problem of the close proximity of proposed units to 

previous logging units, a practiced which would further impair the already highly degraded lateral and 

elevational connectivity in the affected WAAs. Alternatives 4, 5 and 6 should be deleted from the EIS 

because they fail to implement the Forest Plan management prescription requiring elevational 

connectivity to be maintained in Modified Landscape LUDs. Alternative 2 should also be eliminated 

because it impairs connectivity. Connectivity is a critical issue on the peninsula between George and 

Carroll inlets because it is already highly impaired by past actions on federal and non-federals lands. 

Further fragmentation of the peninsula’s productive old-growth habitat and loss of connectivity will 

be highly detrimental to the resiliency of the deer population, the stability and resiliency of the 

predator-prey system, and the ability to (to the present, already diminished extent) meet the needs of 

subsistence hunters, other personal use hunters, and sport hunters.”

“Both the proposed and preferred alternatives will result in the loss of several key wildlife corridors 

and former leave strips in these VCUs. The commenter is also concerned that even the Wildlife 

Alternative removes elevational corridors.” 

Forest Service Response:

Impacts to connectivity and existing leave strips are discussed in the DEIS pages 3-110 and 3-111 and 

under individual MIS. Connectivity is not a requirement except between large and medium OGRs. 

Forest Plan direction (USDA 2008b, WILD1.B.2 p. 3-115) states that projects are to consider 

opportunities to allow for the elevational migration of wildlife within the Modified Landscape LUD. 

Based on knowledge of the Saddle Lakes project area, elevational connectivity corridors were 

identified in the Modified Landscape LUD where additional harvest could reduce natural connectivity 

and limit the ability of land-based species to disperse or migrate. Connectivity would be reduced 

further or eliminated under Saddle Lakes alternatives (see Table 9 and Figure 8 in the DEIS). 

Alternatives 1 and 3 maintain the eight identified elevational corridors. Alternative 2 reduces four

corridors and Alternatives 4, 5 and 6 reduce five corridors. Effects of all alternatives on identified 

corridors are disclosed and analyzed. It is the Responsible Official's decision space on which 

alternative to select.

See Subsistence discussion above.
Appendix D

Saddle Lakes Timber Sale Final EIS Response to Comments - Appendix D  535

Comment: The Forest Service should take into consideration connectivity from 

beach buffer to old-growth.

 “The Wildlife Report notes that, “[n]o connectivity exists through the beach buffer on National 

Forest Service (NFS) lands due to past timber harvest.” (Wildlife Report at 31). This pertains to other 

species and to some degree to deer. Although productive old-growth is no continuous along the beach 

buffer, connectivity still exists if an animal’s route deviates inland a short distance and in some 

locations upward to about 1000 feet elevation. However, all of the action alternatives impair or 

eliminate this connectivity, and all units which do should be removed from the unit pool.” 

Forest Service Response:

This is a decision for the Responsible Official. The cited comment only addresses the beach buffer 

and not areas outside the beach buffer.

Comment: The Forest Service should revisit wildlife connectivity taking into account 

the proposed AMHT land exchange.

 “Our scoping comments requested that the DEIS consider the impacts of additional logging and other 

developments on wildlife connectivity. Further NEPA analysis should explicitly factor in the potential 

AMHT exchange lands, which would clearly impact critical wildlife corridors, and then revisit 

wildlife connectivity.” 

Forest Service Response:

The wildlife resource report page 20 discloses that the land exchange would delete the small OGR 

connection between Naha and George Inlet. 

Goshawks

Commenters have concerns about habitat loss, the analysis of project impacts on 

goshawks, and the effectiveness of the conservation strategy in regard to goshawks.

Comment: The goshawk analysis should revisit habitat loss and species viability. 

 “Our scoping comments requested that the DEIS provide comprehensive analysis of project impacts 

on the QCG...The project record indicates that the species itself is highly vulnerable, meaning that 

further habitat loss in high risk VCUs implicates species viability concerns and request you revisit 

DEIS’ second conclusion with further NEPA analysis...” 

Forest Service Response:

The scoping comment requested further NEPA analysis of the following 1) additional surveys 2) 

consider specific habitat features of goshawk including a review of the relevant literature 3) fully 

identify risk of population decline associated with habitat loss 4) identify risk thresholds for VCUs 5) 

uncertainty of Forest Plan Conservation Strategy. Goshawk surveys were done according to the latest 

approved survey protocol; relevant literature and a detail analysis of the effects and associated risk, to 

the goshawk are included in the Biological Assessment/Biological Evaluation; risk thresholds have 

been identified for VCUs-30 percent of the original POG harvested (see 1997 Forest Plan Appendix N 

and 2008 Forest Plan Appendix D); the uncertainty of the Conservation Strategy is beyond the scope 

of this analysis.

The comment was about the conclusion that project alternatives may adversely impact individuals but 

not likely to adversely affect the species. The determination for the goshawk made in the Biological 
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536  Appendix D – Response to Comments Saddle Lakes Timber Sale Final EIS

Assessment/Biological Evaluation was “May adversely impact individuals, but not likely to result in a 

loss of viability in the Planning area, nor cause a trend toward federal listing.” 

Currently none of the project area VCUs have had more than 30 percent of the original (1954) POG 

harvested and as such are not considered high risk VCUs. The 2008 Forest Plan Legacy Standards 

and Guidelines do not apply to the Saddle Lakes project area VCUs (USDA 2008b, WILD1.IV.D., pp. 

4-90 & 4-91). 

The goshawk sightings within the project area are disclosed and discussed in the Biological 

Assessment/Biological Evaluation.

Goshawks were analyzed in detail in the Biological Evaluation and a determination was made in 

regards to their viability in the planning area. The determination made was that the proposed activity 

“May adversely impact individuals, but not likely to result in a loss of viability in the Planning area, 

nor cause a trend toward federal listing.” 

Despite multiple years of surveying, no nests have been identified within the project area nor have 

any consistent observations occurred. Suitable habitat occurring outside proposed units has not been 

fully surveyed, but would not be affected by Saddle Lakes alternatives. All survey data is included in 

the planning record. 

Comment: The Forest Service should modify the project design based on the 2012 

QCG sightings.

 “Our scoping comments requested information about potential nest locations and other observations 

of QCG habitat use. The DEIS failed to disclose two QCG sightings in 2012 –at least one of the 

sightings occurred in area of proposed intensive clearcutting. [PR 740-0032]. These sightings should 

be discussed in further NEPA analysis along with an evaluation of project design, QCG habitat 

features in the vicinity of the sightings and ways to modify project design so as to minimize the risks

to potential but undiscovered nest areas.” 

Forest Service Response:

The goshawk information and detailed discussion of habitat in the area of the sightings is provided in 

the Saddle Lakes Biological Evaluation beginning on page 19. No nests have been found despite 

repeated searching over multiple years, but two sighting were recorded in 2012. One sighting 

occurred near the Shelter Cove LTF in early spring and another occurred near North Saddle Lakes in 

October. These areas were surveyed multiple times with no response. No goshawk sightings occurred 

in the project area in 2013. Should an active goshawk nest be discovered at any time prior to harvest 

the required Forest Plan nest buffer Standard and Guideline will be implemented. This may require 

modifying unit design or dropping planned harvest areas. 

The Saddle Lakes project is consistent with Forest Plan Goshawk Standards and Guidelines. 

Comment: There should be additional QCG analysis due to uncertainties regarding 

the effectiveness of TLMP conservation measures.

 “Further NEPA analysis should discuss the findings provided in PR 740_1180 (Smith 2013), which 

identifies significant uncertainties regarding whether TLMP conservation measures provide the 

habitat features needed to sustain well-distributed QCG populations in the project area and across the 

southern half of the Alexander Archipelago. Smith’s analysis indicates that risks to QCGs under the 

TLMP are likely even greater than anticipated under the 1996 risk assessments, which assumed that 

the reserve system would in part mitigate habitat loss.” 
Appendix D

Saddle Lakes Timber Sale Final EIS Response to Comments - Appendix D  537

Forest Service Response:

Smith's findings on the uncertainties are acknowledged in the Biological Evaluation page 17. Smith 

(2013) is cited multiple times in the goshawk section. The uncertainties of the Conservation Strategy

are beyond the scope of this analysis.

MIS and Sensitive Species

Commenter requests that a “comprehensive analysis of project impacts on project 

area MIS and sensitive species,” as well as requests specific mitigation measures.

“Our scoping comments requested that the DEIS provide comprehensive analysis of project impacts 

on project area MIS and sensitive species and consider measures that will mitigate adverse impacts 

such as increased buffers, increased forest structure retention requirements and effective road 

closures. We requested that the DEIS document surveys for wildlife species present in the project area 

and discuss their locations and preferred habitat uses and that the analysis do more than a quantitative 

assessment of productive old-growth losses at various scales.” 

Forest Service Response:

MIS and TES are analyzed in detail in the Wildlife Resource Report, and Biological Evaluation DEIS 

and Biological Assessment/Biological Evaluation. Specific types of old-growth habitat, based upon 

SDM, were identified for each species based on habitat preferences and used in the analysis. The 

Wildlife Resource acknowledges long-term to permanent loss of habitat would occur based on 

knowledge of habitat preferences. The black bear and river otter MIS sections analyze impacts within 

500 feet of streams. This information can be used to assess the benefits of wider buffers. Likewise, 

proposed partial cutting maintains additional forest structure. It is the Responsible Official's decision 

space on which alternative to select. 

Forest Plan Standards and Guidelines were formulated to mitigate of reduce effects. This direction 

was applied in the development of the project alternatives and in development of roads and units. 

The Saddle Lakes EIS unit and road cards display mitigation measures. 

Marten

Commenters believe that the analysis included within the DEIS does not provide a 

full discussion of the habitat features important to marten viability, and fails to 

identify “relevant” road density thresholds. Commenters also question the exclusion 

of certain lands from the cumulative effects analysis.

Comment: There should be additional analysis of road density thresholds and 

population vulnerability.

 “The DEIS discusses road density, but fails to identify relevant thresholds or to what extent road 

density increases would result in the entire population being vulnerable to overharvest. [DEIS at 137-

138]...Further NEPA analysis should provide a more detailed assessment of road density risks, 

particularly the potential for local extirpations.” 
Appendix D

538  Appendix D – Response to Comments Saddle Lakes Timber Sale Final EIS

Forest Service Response:

Research thresholds and effects of road density are discussed under Marten Direct Effects (DEIS 

beginning on p. 3-137) and Cumulative Effects (DEIS beginning on p. 3-140). Additional analysis 

includes research thresholds for clearcut tolerance on the landscape and patch size analysis. 

Comment: “Further NEPA analysis should include some additional discussion of 

trapping refugia and prey availability [for marten].” 

Forest Service Response:

The wildlife resource report contains extensive discussion on marten including trapping and prey. 

Please see the red squirrel and small mammal sections for prey availability. The OGRs are refugia. 

Small OGRs were designed specifically with marten in mind. 

Comment: The marten analysis should use a marten habitat capability model.

 “As noted in our previous comment, the model, using a road density factor, indicated a 90 percent

habitat capability decline – a number much greater than even the cumulative habitat loss disclosed 

using the methodology in the DEIS. In light of this finding we reiterate our request to revisit the use 

of a habitat capability model to analyze project risks to marten.” 

Forest Service Response:

Rationale on why the marten model was not used was provided in the wildlife resource report. 

While the original Suring et al. (1992) model included road density factors, the more recent 

models do not include road density. 

Comment: The marten analysis should include the cumulative effects of the AMHT 

harvest and potential land exchange.

 “The cumulative effects analysis improperly excludes the 3,276 acres lost due to the recent AMHT

harvest and the proposed AMHT exchange which could affect over 4,000 acres of marten habitat. 

[DEIS at 140-141].” 

Forest Service Response:

The DEIS on 140 states "An additional 3,726 acres of timber harvest recently occurred on the Trust 

Leask Lake parcel that is not reflected in the Forest Service GIS data for WAA 407. The proposed 

AMHT land exchange, if approved, could affect over 4,000 acres marten habitat in VCUs 7460 and 

7470. Therefore, impacts to marten would be higher than shown in Table 51." The effects are not 

excluded, but could not be classified in GIS due to identified missing information. 

Road Density

Comment: Project-related road construction would fragment habitat and threaten 

wildlife numbers.

“Roads have been repeatedly proven to reduce the numbers of wildlife. The amount of roads that will 

be upgraded or built for each alternative will further degrade deer, wolf and bear numbers. (pg. 94) 

There is no need for further road building in this area, requiring gravel pits, huge machines and big 

fiscal expenditures. Connecting the project area to Ketchikan with roads will increase the legal and 

illegal take of wolves, and will create a mortality concern where wolf numbers are already believed to 

be low.” 
Appendix D

Saddle Lakes Timber Sale Final EIS Response to Comments - Appendix D  539

“We disagree that the ROW would have “minimal effect on wildlife habitat.” To the contrary, the road 

link alone would appear to threaten viability of wolves.” 

“”Timber operations and road building add to the fragmentation" and that "AH action alternatives 

would remove leave strips left by previous timber sales making it harder for deer to move up and 

slopes" (pg. 3) and affect habitat for species such as squirrels, voles, marten while isolating 

salamanders, gastropods and arthropods.” 

Forest Service Response:

The Ketchikan to Shelter Cove Road right-of-way (ROW) is an administrative action. The wildlife 

resource report page 1 states that an estimated 9 acres of ground disturbance would occur within the 

ROW, which is minimal compared to WAA 407 as a whole. Impacts of the road connection related to 

wolves is discussed under Cumulative Effects on page 3-124 of the DEIS "While wolf mortality has 

not been identified as a concern in the past, completion of the Ketchikan to Shelter Cove Road could 

lead to wolf mortality concerns in the future...."

Effects of roads are analyzed in the wolf and marten sections. This is a decision for the Responsible 

Official.

Size Density Model Data

Commenters had questions about the use of the Size Density Model (SDM) data as 

portrayed in the DEIS.

“This is the only Tongass timber project NEPA document, since the time the Size Density Model was 

adopted, that has not had the data for at least the higher SDM classes (or a simplified set in the case of 

deer analysis mapped.” 

“Some SDM data is presented in DEIS Table 17, giving historic and current conditions only. No SDM 

data is presented in the DEIS or Wildlife Report that shows the impact of the project alternatives on 

the SDM classes.” 

“The DEIS says, “[f]ield reconnaissance identified several inconsistencies with the SDM database, 

but data is anticipated to fall within the 70 percent accuracy range.” (DEIS at 76). Full disclosure of 

the inconsistencies is necessary, as well as an explanation of why a 30 percent error rate is considered 

acceptable, whether this significant deviation is common on the Tongass, what its consequences are, 

and if mappable within the analysis area, where the greatest deviations occur and for what reason. 

The DEIS also says, “[i]nformation for non-NFS (state or private) lands is based upon the best 

information available, but data is lacking for some areas.” (Id.). The areas where data is lacking 

should be mapped, including identification of what kind of data is lacking at the various locations. We 

note that this affects deer modeling and other wildlife analysis, as well as the assessment of 

connectivity.” 

“In our view this undercuts entirely the reliability of the wildlife, subsistence and recreation (also 

including hunting) sections of the DEIS, and the lack of attention to SDM data and impacts fully 

merits the preparation of a Supplemental DEIS for this project. Multiple issues are affected by this 

deficit.” 

Forest Service Response:

The wildlife resource report and DEIS analyze by alternative SDM classes as they relate to a 

specific MIS. This approach focuses the "so what" rather than merely showing change in the 

number 
Appendix D

540  Appendix D – Response to Comments Saddle Lakes Timber Sale Final EIS

of acres. For example, measurement criteria for hairy woodpecker included acres of high-POG 

(SD5N, SD5S, SD67) all elevations (DEIS page 149). Changes to large-tree SD67 habitat is 

analyzed under Marbled Murrelet and displayed by alternative in Table 56, wildlife resource report. 

The size density model (SDM) being 70 percent accurate is a result of how the SDM was developed, 

not a product of the deer model. The SDM GIS layer was used to classify wildlife habitat. This model 

has been shown to be 70 percent accurate at the forest level. Caouette and DeGayner 2008 stated, 

“We estimate the predictive qualities of the size density model to range between 60 and 80 percent

comparable with the estimated 65-70 percent forest-mapping accuracy rates reported in other parts of 

the Pacific Northwest (Spies and Cohen 1999).” 

Additional information on SDM, including model development citations, is provided in the DEIS, 

page 79. (USDA 2008c, pp. 3-139 through 3-142 and 3-231, Caouette and DeGayner 2008, Krosse 

and O’Connor 2009). Lack of non-NFS information was identified in the Wildlife Resource Report 

page 7: "Recent Alaska Mental Health Trust (AMHT) harvest at Leask Lakes was not available in 

GIS. I assumed that all harvest was within POG, but the Forest Service does not have specific 

information on specific POG classifications within harvest units."

Data limitations are identified and effects were discussed qualitatively where information was lacking 

for GIS analysis; however, the best available information was used.

Biological Diversity/Habitat Loss

“The commenter asked that the FEIS explain that young growth habitat is good for some wildlife and 

a matrix of young and old growth timber in an area like Saddle Lakes will actually result in improved 

habitat for deer, wolves, bears and birds in both winter and summer.” 

“If this sale is allowed, 82 percent of the area will either be new growth or soon to be entering the 

stem exclusion stage which eliminates sites necessary for survival of resident species.” 

“Commercial rotation lengths of 80-120 years, the forests will not maintain at either stand or 

landscape level the full complement of species characterized by a seral (series) or structural stage. It 

continues, "biological diversity associated with old-growth is important to the Tongass and that old 

growth is most affected by timber cutting.” 

"Major landscape disturbance poses an increased risk of local extirpation of resident species; the 

greater the disturbance process deviates from natural disturbance processes, the greater the risk, 

particularly in the highly fragmented archipelago ecosystems" (pg. 12). "Instead of the likely outcome 

of a "sink" population of various species where deaths exceed births, a preferred scenario is a 

"source" habitat where births exceed deaths, allowing for migration and genetic variation. This will 

only be possible with the No Action Alternative.” 

“The Saddle Lake DEIS describes how the loss of habitat will affect populations of birds, "Impacts to 

brown creeper interior habitat from past management activities have been substantial (over 72 percent

loss) and would be further reduced with implementation of the Saddle Lakes timber sale, and 

identifiable future management activities (up to 76 percent loss)" (Page 148, 149 ) , "hairy 

woodpeckers depend on cavities in large-diameter trees and hard snags characteristic of high 

productive old-growth (Page 149), with 38 to 51 percent of the historic VCU habitat lost long-term 

from harvesting large diameter, high-POG habitat" (Page 153); redbreasted sapsucker would suffer 

similar effects to hairy woodpeckers (Page 153). Decreased numbers in bird, deer and wolf numbers 

are unacceptable. There are no Standards and Guidelines for what is allowable for any species in a 

given area, nor on a forest wide scale.” 
Appendix D

Saddle Lakes Timber Sale Final EIS Response to Comments - Appendix D  541

“River otter can be found in this area; old growth forests with canopy cover and large diameter trees 

and snags provide habitat for burrows and den sites. The small old growth reserve above George Inlet 

Salt Chuck provides some habitat for river otters. However, otters require an unaltered area outside 

the old-growth reserve which can be achieved only with the No Action alternative.” 

Forest Service Response:

Young-growth habitat is discussed in the DEIS page 3-107 "Young-growth thinning can delay the 

onset of stem exclusion or temporarily improve low light conditions, and may benefit some wildlife 

species. Thinning benefits typically last 15 to 20 years (Alaback 2010, Cole 2010, McClellan et al. 

2014)."

Not all land within the Modified Landscape or Timber LUD is being proposed for harvest under the 

Saddle Lakes project. Please see Issue 3a for effects wildlife habitat. Forest Plan Standards and 

Guidelines in the matrix, non-development LUDs and roadless areas in the project area and the 

conservation strategy will all contribute to the viability of species. 

The wildlife analysis discloses that timber harvest under current rotations could cause a permanent 

loss of habitat for old-growth related species. The risk of local extirpation was considered and is 

disclosed. 

Alternative selection is the decision of the Responsible Official.

Establishing standards and guidelines and /or thresholds is outside the scope of the Saddle Lakes 

project.

River otters generally use habitat that is protected by Forest Plan Standards and Guidelines. Effects to 

river otter are disclosed in the wildlife section of the DEIS.

Wolf Effects Analysis

Commenters feel that the effects analysis for wolves was lacking in the DEIS, and 

request updates to the wildlife analysis in the FEIS based on their comments.

Comment: The Forest Service needs to clarify the interface between the deer model

and wolf viability.

 “The statement in the DEIS that “[m]odel-defined deer densities (deer per square mile) ... are not 

related to wolf viability, but represent the functioning of the predator-prey system dynamic (USDA 

2008c, p. 282)” comes almost directly from the 2008 Forest Plan FEIS, but it is facially incorrect in 

both respects. (DEIS at 93).” 

Forest Service Response:

Consistent with use in the Forest Plan, model derivatives describes carrying capacity, not actual 

numbers of deer. The wildlife resource report discusses deer/wolf interactions outside the use of 

the deer model and identifies that as habitat decreases, the more unstable and less resilient the 

predator/prey relationship (i.e., the "ball in the box" presented in Person 2006). 
Appendix D

542  Appendix D – Response to Comments Saddle Lakes Timber Sale Final EIS

Comment: The Forest Service should analyze direct effects to wolves on all land 

ownerships, not just NFS.

“Only National Forest System (NFS) lands were used for direct effects analysis.” (Wild. Rept. at 2). 

For wolves, this limited means of analyzing direct and indirect impacts is executed on pages 60-63 of 

the Wildlife Report and pages 121-124 of the DEIS. It is a plainly inadequate and misleading way to 

evaluate the project’s direct (and indirect) impacts to wolves. This is because wolf pack home ranges 

and journeys of dispersing wolves do not heed property boundaries. For the existing condition and the 

project’s direct additions to it, all road density within the home range and all loss of carrying capacity 

for prey is material to the conditions wolves do now or will –as a direct result of the project - face. 

The scope and direct effects of the project and the existing condition that is relevant to them is WAAs 

406 and 407 in their entireties, irrespective of which particular plots may be in federal or non-federal 

ownership.” 

“Wolf packs utilize the landscape within their home range without regard to land ownership

boundaries, and it has been broadly recognized in the planning of timber projects on the Tongass that 

assessment of the availability of the primary prey –deer –needs to be done by modeling at the WAA 

scale. In analyzing the cumulative impact to deer availability, deer habitat capability is evaluated for 

the historic, current and future periods. For the evaluation to have any bearing, it must encompass all 

the lands in the WAA.” 

“To be clear, the distinction we make regarding analysis of wolf impacts is this: (1) direct and 

indirect impacts need to be assessed relative to the baseline of the current condition and the present 

situation for wolves, with all lands considered; and (2) cumulative impacts need to be based on the 

historic, pre-industry 1954 baseline, considering –also in view of all land ownerships - the project’s 

additional effects, and separately looking ahead to the additional impact that may be caused by other 

foreseeable actions. Analyses of cumulative impacts to wolves at the scale of the affected WAAs and 

of Revilla Island as a whole are the important scales. Analysis at the province scale seems superfluous 

to us, since the Cleveland Peninsula is across a large body of water and is mainland territory. Its 

inclusion in the biogeographic province seems arbitrary with respect to wolf analysis.” 

Forest Service Response:

These factors are considered under cumulative effects, which take into account the effects of the 

proposed alternatives in addition to past, present, and foreseeable future actions on all lands. This 

presents the "big picture" of impacts to wolves. The deer model and effects are analyzed per direction

(deer model 2011) which says to use NFS lands only for direct and indirect effects analysis.

40 C.F.R. § 1508.7 says that “The impacts on the environment which result from the incremental 

impacts of the action when added to other past, present, and reasonably foreseeable future actions 

regardless of what agency or person undertakes such other actions.” 

Current Tongass interpretation is to analyze at WAA and biogeographic province scales. The Saddle 

Lakes wildlife biologist included additional analysis on wolves at the Revillagigedo Island scale in 

the wildlife resource report. A subset of Revillagigedo Island WAAs can be derived from DEIS 

Table 45. 

Comment: The Forest Service should more fully analyze the role of Revillagigedo 

Island in the viability, distribution and persistence of wolves on the Forest.

 “We believe the situation for the viability, wide distribution and persistence of wolves on the Tongass 

National Forest is more tenuous than the Forest Service has recognized. There is strong evidence that 
Appendix D

Saddle Lakes Timber Sale Final EIS Response to Comments - Appendix D  543

the predator-prey systems in at least Revillagigedo and Gravina Islands, the Prince of Wales Island 

archipelago and the island group from Mitkof Island to Kuiu Island are perturbed, and have 

significantly degraded resilience, and have diminished stability. It is crucial that roles of 

Revillagigedo Island and of the project in that context be fully explored in the EIS.” 

Forest Service Response:

The viability of wolves in Southeast Alaska is beyond the scope of this project. Wolf viability is

addressed at the scale of the Tongass National Forest in the 2008 Forest Plan FEIS and Forest Plan.

Predator/prey interactions and risk of chronic unsustainable mortality of wolves on Revillagigedo 

island are discussed in the wildlife resource report on pages 60 -70 and displayed in Figure 13 of 

the DEIS. 
Saddle Lakes Timber Sale Final EIS Standards & Guidelines - Appendix C  544

Letters from Federal, State, and local agencies and elected officials

The text of these letters is reproduced here. The originals of these letters can be found in the project 

record.

Ketchikan Gateway Borough

Jeff DeFreest

1900 First Avenue, Suite 210, Ketchikan, Alaska 99901 

•Telephone: (907) 228-6625 •Fax (907) 228-6684

Office of the Borough Manager

September 25, 2014 

Ketchikan-Misty Fjords District Ranger

USDA Forest Service, Ketchikan-Misty Fjords Ranger District

3031 Tongass Avenue

Ketchikan, AK 99901 

Subject: "Saddle Lakes Timber Sale Draft EIS"

Dear Mr. DeFreest:

This letter provides support on behalf of the Ketchikan Gateway Borough for Alternative 4, the USFS 

preferred alternative, for the Saddle Lakes Timber Sale. The Ketchikan Gateway Borough Assembly 

supports the timber industry and the USFS's efforts to achieve the multiple use goals and objectives 

for timber and local and regional economies as outlined by the USFS Forest Plan. The Assembly does 

not dispute or have concerns regarding the draft EIS for the timber sale.

Alternative 4 would produce about 51 MMBF of timber, supporting 203 to 243 jobsyears. Alternative 

4 is recognized as maximizing timber harvest from an economical unit pool outside of Inventoried 

Roadless Areas and Old-Growth Reserves. 

On a related note, the Assembly also supports the Saddle Lakes Timber Sale because it will assist the 

Alaska Department of Transportation and Public Facilities project to develop a public use road to 

Shelter Cove.

Ketchikan Gateway Borough officials look forward to the Saddle Lakes Timber Sale and your 

consideration of our support. 

Dan Bockhorst 

Borough Manager 
Appendix D

Saddle Lakes Timber Sale Final EIS Response to Comments - Appendix D  545

United States Environmental Protection Agency

Region 10

1200 Sixth Avenue, Suite 900 

Seattle, WA 98101-3140 

Jeff DeFreest, District Ranger

Ketchikan-Misty Fiords Ranger District

3031 Tongass Avenue

Ketchikan, Alaska 99901 

October 24, 2014 

OFFICE OF ECOSYSTEMS, TRIBAL AND PUBLIC AFFAIRS

RE: EPA comments on the Saddle Lakes Timber Sale Draft Environmental Impact Statement (EIS), 

EPA Project #12-0023-AFS.

Dear Mr. DeFreest:

We have reviewed the above-referenced EIS (CEQ No. 20140262) proposed for Revillagigedo Island 

in Southeast Alaska. Our review was conducted in accordance with our responsibilities under the 

National Environmental Policy Act (NEPA) and Section 309 of the Clean Air Act. Section 309, 

independent of NEPA, specifically directs the EPA to review and comment in writing on the 

environmental impacts associated with all major federal actions. Under our policies and procedures, 

we evaluate the document's adequacy in meeting NEPA requirements.

The draft EIS proposes a no action alternative and five action alternatives that include varying levels 

of timber harvest and road construction, as well as the reconstruction of the Shelter Cove log transfer 

facility and modification of a fish passage barrier. The project area includes National Forest System 

and private lands. The Forest Service has identified Alternative 4, which would produce about 51 

mmbf of timber from 2,875 old growth acres and will support up to 243 jobs, as its preferred 

alternative. 

Overall, we support the selection of this alternative given the greater benefits to the local economy 

and comparable impacts to most resources as the alternatives impacting fewer old growth acres. We 

commend the Forest Service and its partners for identifying a more economically feasible alternative 

that does not substantially increase impacts in comparison to other lower yield alternatives. We 

believe this alternative provides a reasonable balance in implementing the Forest Service's mandates 

under the Tongass Timber Reform Act of 1990, compliance with the Tongass Land and Resource 

Management Plan goals and objectives and support of the project's purpose and need. We also 

appreciate the EIS's succinct analysis, detailed alternatives maps, index and acronym list inside the 

front cover.

We do, however, request that the Forest Service continue to work to achieve further reductions in 

potential impacts to visual resources, deer habitat (and subsequent impacts to subsistence), as well as 

impacts to water quality from new and temporary road miles. Given the known impacts of road 

construction and stream crossings on water quality, particularly due to sediment loading, and the lack 

of data for many of the water bodies within the project area, we believe monitoring of road impacts is 

critically important. We recommend that the final EIS contain information that clearly identifies 

Forest Service resources for monitoring and enforcement, as recommended by the Council on 

Environmental Quality's Memorandum on Appropriate Use of Mitigation and Monitoring, January 
Appendix D

546  Appendix D – Response to Comments Saddle Lakes Timber Sale Final EIS

14, 2011. We believe that robust implementation and enforcement of the standards and guidelines, 

best management practices, and mitigation measures identified in Appendix C is necessary to ensure 

that predicted impacts are accurate and that mitigation is adequate. An adaptive management strategy 

should be included in the Final EIS and adopted in the Record of Decision to allow the Forest Service 

to quickly change mitigation efforts if monitoring reveals that the mitigation is not fully successful.

We request that discussions concerning the EPA's National Pollutant Discharge Elimination System 

authority be augmented with information concerning the State of Alaska's authority to permit 

discharges under its Alaska Pollutant Discharge Elimination System program. Finally, we request that 

the omission of the(-) on page 33 under the Alternative 3 column, Black Bear Habitat-Historic POG 

Within 500-feet of Class I Fish Streams, be connected.

Based on our review, we have assigned a rating of "LO" (Lack of Objections) to the draft EIS. A 

description of out rating system is enclosed. Please contact Jennifer Curtis of my staff in Anchorage at 

(907) 271-6324 or curtis.jennifer@epa.gov with any questions you have regarding our comments. 

Sincerely,

Christine B. Reichgott, Manager 

Environmental Review and Sediment Management Unit 

Enclosure 
Appendix D

Saddle Lakes Timber Sale Final EIS Response to Comments - Appendix D  547

United States Department of the Interior 

OFFICE OF SECRETARY 

Office of Environmental Policy and Compliance 

1689 C Street, Room 119 

Anchorage, Alaska 99501-5126 

VIA ELECTRONIC MAIL, NO HARD COPY TO FOLLOW

9043.1 

ER14/0591 October 24, 2014 

PEP/ANC

Daryl Bingham

U.S. Forest Service

3031 Tongass Avenue

Ketchikan, AK 99901-5743 

Subject: Comments on the Draft Environmental Impact Statement (DEIS) for Saddle Lakes Timber 

Sale, Tongass National Forest, Alaska

Dear Mr. Bingham: 

The U.S. Department of the Interior has no comments to offer on the subject document at this time. 

Thank you for the opportunity to review this DEIS. 

Sincerely,

Philip Johnson

Regional Environmental Officer - Alaska
Appendix D

548  Appendix D – Response to Comments Saddle Lakes Timber Sale Final EIS

State of Alaska, Department of Natural Resources

October 27, 2014 

Jeff DeFreest

Ketchikan-Misty Fiords Ranger District

3031 Tongass Avenue

Ketchikan, AK 99901-5743 

Submitted via comments-alaska-tongass-ketchikan-mistyfiord@fs.fed.us 

Re: Saddle Lakes Timber Sale Draft Environmental Impact Statement

Dear Mr. DeFreest,

The State of Alaska (State) has reviewed the Draft Environmental Impact Statement (DEIS) for the 

U.S. Forest Service’s proposed Saddle Lakes Timber Sale on the Ketchikan-Misty Fiords Ranger 

District, Tongass National Forest.

The State appreciates the opportunity provided by the Ketchikan-Misty Fiords Ranger District for a 

state forester with the Alaska Department of Natural Resources, Division of Forestry (DNR-DOF) 

and a state habitat biologist with the Alaska Department of Fish and Game, Division of Habitat (DFGHabitat) to participate as members of the Saddle Lakes Timber Sale Project Interdisciplinary Team 

(IDT). Many of the State’s technical questions, concerns and suggestions were addressed during IDT 

meetings.

Please consider the following consolidated comments in your decision for this project. 

Project Description 

The Saddle Lakes Timber Sale Project proposes to harvest between 17.1 and 60.7 million board feet 

(MMBF) of timber from approximately 1,012 to 2,875 acres, and to construct up to 20.6 miles of new 

National Forest System (NFS) roads, up to 11.7 miles of temporary roads, and to recondition up to 

11.1 miles of existing roads, depending on alternative. All project-related new and reconditioned NFS 

roads would be closed to public motor vehicle traffic and all new temporary roads would be 

decommissioned upon completion of timber sale activities. Associated with this project is the use of 

the existing permitted log transfer facility at Shelter Cove, which will be reconstructed by replacing 

the log bulkhead. In addition, under all the action alternatives, a barrier to fish passage at lower Salt 

Creek would be modified to improve access to about five (5) miles of upstream habitat and 106 acres 

of lake habitat. 

The DEIS identified Alternative 4 as the Forest Service’s preferred alternative for this project. This 

alternative proposes to harvest approximately 51.0 MMBF of timber from an estimated 2,424 acres, 

and would involve the reconditioning of 10.8 miles of existing roads, and the development of 19.6 

miles of new NFS road and 9.8 miles of temporary road. 

Timber Economics

Please provide clarification or necessary corrections in the Final Environmental Impact Statement 

(FEIS) in response to the following questions. 

Chapter 2, page 32, Table 3. Comparison of alternatives by issue: 
Appendix D

Saddle Lakes Timber Sale Final EIS Response to Comments - Appendix D  549

Under the Employment section the measures are “Total Jobs Estimated (Current R10 Policy)” and 

“Limited Export Policy & Domestic Processing.” Are these labels correct? DNR-DOF believes the 

labels are different ways to say the same thing. Current R10 policy allows for limited export of round 

logs and requires domestic processing. Later in the DEIS (Ch. 3, page 61), the Timber Sale Financial 

Efficiency Analysis compares the “Alaska Region Limited Export Policy and 100 percent domestic 

processing.” Are these two categories what is being shown in Table 3 under the Employment section? 

Chapter 3, page 62, Table 5. Timber financial efficiency analysis for the Saddle Lakes Project Area: 

Under both the Export Policy Scenario and the Domestic Processing Scenario subsections total 

production costs are less than Total Selling Value for all alternatives; yet, the Indicated Advertised 

Rate is negative for all alternatives. How is that possible? Total Selling Values that are higher than the 

Total Production Cost should yield positive value stumpage rates. Are there costs not included in 

Total Production Costs? If so, what are they? 

Fish Passage

Road Condition Surveys (RCS) have determined that there are 11 red, 2 gray, and 9 green fish 

crossings located within the project area. Collectively, for the project area, there are approximately 15 

linear miles of Class I and II habitat upstream of the red crossings. Additionally, there are 508 acres of 

Class II lakes upstream of red crossings (DEIS, Ch. 3, page 237). Although the DEIS (page 237) 

states that the red crossings “are not necessarily complete barriers”, it does not mention whether or 

not the identified red crossings would be corrected as part of the proposed Project. DFG-Habitat 

recommends that the Preferred Alternative in the FEIS include corrective actions for all identified red 

fish stream crossings, such that efficient fish passage is provided at all flows. Additionally, stream 

crossing structures installed in fish-bearing streams as part of new road construction must be designed 

and installed to allow efficient fish passage at all flows.

The DEIS (Ch. 3, page 238) correctly identifies Salt Creek (Stream No. 101-45-10380) as a cataloged 

anadromous fish stream, which requires the Forest Service reach concurrence with DFG-Habitat 

before conducting work below the ordinary high water level (Ch. 1, page 13). DFG-Habitat looks 

forward to working with district staff during the concurrence process to review designs for the 

proposed fish passage improvement on Salt Creek and any fish stream crossing structures. Please 

contact Mark Minnillo (Area Habitat Biologist) at (907) 826-2560 or mark.minnillo@alaska.gov. 

Cumulative Watershed Effects

The Tongass National Forest uses a threshold of concern for cumulative watershed effects of 20 

percent of watershed basin area consisting of young growth less than 30 years old. Watersheds at or 

exceeding this threshold may be experiencing increased peak flows and attendant sediment 

recruitment from stream channel erosion and bed scour. According to the DEIS (Table 90, Ch. 3, page 

240), of the sixteen 7th level HUC watersheds in the project area, only the Hidden Lakes watershed 

currently exceeds this threshold with 20.5 percent of the basin area harvested within the last 30 years. 

Implementation of the Saddle Lakes project would further increase the cumulative harvesting 

percentages above the threshold within this watershed and seven others, depending on alternative. 

These include the following (percentages above the threshold are shown in bold):
Appendix D

550  Appendix D – Response to Comments Saddle Lakes Timber Sale Final EIS

Watershed

Alt 1. 

Harvest 

since 1984 

(%)

Alt. 2 Basin 

area harvest

Alt. 3 Basin 

area harvest

Alt. 4 Basin 

area harvest

Alt. 5 Basin 

area harvest

Alt. 6 Basin 

area harvest

North Saddle 

Lake 9.0 15.2 11.3 21.1 23.3 16.2

Gunsight 

Creek 14.8 20.1 19.1 22.4 22.5 22.4

Shelter 

Cove-B 15.1 23.7 23.7 23.7 23.7 23.7

Hidden 

Lakes 20.5 25.4 25.4 26.6 28.4 25.4

California 

Cove-E 14.7 18.6 15.1 23.7 26.9 23.8

Lemon Lake 14.2 19.6 17.8 22.5 22.5 18.8

Upchuck 

Creek 18.0 26.1 23.5 26.7 32.9 24.6

Rainbow 

Creek 13.5 19.4 16.9 23.0 23.1 22.4

Given the increased level of harvesting that is being considered within these watersheds, particularly 

within the Hidden Lakes and Upchuck Creek watersheds, channel condition assessments should be 

completed, not only for determining existing channel conditions relative to the amount of timber 

harvesting and road construction proposed for the Saddle Lakes project, but also to establish a 

baseline for future monitoring.

Harvest on Steep Slopes

The DEIS contains conflicting information regarding the amount of timber harvesting that is proposed 

on slopes greater than 72 percent gradient. Specifically, The DEIS (Ch. 3, page 241) states that 

“Alternatives 4 and 5 propose the most harvest on unstable slopes, however, only 12 acres out of 

4,441 acres are proposed on slopes greater than 72 percent.” That statement conflicts with the 

information provided later on (Ch. 3, page 335), which indicates that 42 acres of slopes greater than 

72 percent would be harvested under Alternative 4, and 163 acres of such slopes would be harvested 

under Alternative 5. Please correct this discrepancy in the FEIS.

Scenery and Recreation

Please provide clarification or necessary corrections in the FEIS in response to the following 

questions. 

Chapter 3, page 183, Issue 4A. Scenery: 

National Environmental Policy Act (NEPA) documents are required to consider proposed actions and 

foreseeable future actions when analyzing affects to the human environment. DNR-DOF questions 

the validity of treating “Planned” visual priority routes (VPRs) “as though they were existing and 

given equal weight as VPRs” for the purposes of the Scenery analysis.

With the exception of the Harriet Hunt–Shelter Cove Connection Road, none of the VPRs listed in the 

Tongass Land and Resource Management Plan (January 2008) under Routes not constructed nor 

NEPA cleared: Planned or Opportunities (Appendix F, page F-23) are actually being planned or have 

had NEPA documents written for them. DNR-DOF believes these VPRs do not meet the criteria of 
Appendix D

Saddle Lakes Timber Sale Final EIS Response to Comments - Appendix D  551

proposed actions or foreseeable future actions under NEPA, and therefore, inclusion of them in any 

analysis connected with the Saddle Lakes project is inappropriate.

Chapter 3, page 209, Table 81. Harvest units of high concern to recreation by alternative (acres and 

prescription) for the Saddle Lakes Timber Sale Project: There is no definition of “high concern” 

within the DEIS. The DEIS does not list the metrics that a proposed harvest unit must meet to become 

a “high concern to recreation.” What criteria were used to support the decision to list a unit as a “high 

concern to recreation”?

Shelter Cove Road

The Alaska Department of Transportation and Public Facilities requests that the FEIS incorporate a 

slightly modified road alignment in all action alternatives for the proposed one mile of new NFS 

Road 8300280 (see enclosed map). GIS data files will be provided to Jason Powell (Forest Service 

Transportation Planner). 

Unit and Road Cards

Unit and road cards were not distributed with the DEIS. Although a CD containing an electronic 

version of the DEIS was included with the distributed print version, the unit and road cards were only 

available for download from the Forest Service’s project website at 

http://www.fs.usda.gov/projects/tongass/landmanagement/projects. In the future, if unit and road 

cards are not printed as part of the DEIS, please include them in electronic format on a CD, as is done 

for the DEIS.

Road 8300320: According to the Aquatics section of the road card, this road will cross two Class II 

streams, though, as mapped, the road will cross one Class II stream and one Class III stream. The 

narrative for the second crossing listed (B) states “Roads can avoid class II crossing by moving 

further upstream.” Therefore, in order to avoid directly impacting resident fish habitat, the crossing 

site should be relocated upstream to the Class IV reach as indicated in the Aquatics narrative.

Road 8330413: As depicted on the road card map, it appears that this road alignment could be 

relocated a few hundred feet west to avoid crossing the mapped Class II stream and its riparian buffer. 

The terrain in this area does not appear to limit doing so. Therefore, if feasible, this road should be 

relocated to avoid resident fish habitat.

Road 8340416: As mapped, this road will cross a Class II stream and run parallel to it through its 

riparian buffer. The Aquatics narrative states “Fish presence verified, lots of Class II tributaries 

mapped during field visit in 2014; Road and Unit 65 should be dropped due to TTRA/RMA buffer.” 

However, despite this concern and recommendation, this road and Unit 65 remain in Alternatives 2, 4, 

5 and 6. Therefore, further consideration of the alignment of this road should be given prior to 

approving its construction. 

Road 8340500: This road will cross three Class III streams, one Class IV stream, and four Class II 

streams. The Aquatics narrative for one of the Class II crossings € states “Class 2 fish stream can be 

avoided if road moved upstream above end of fish habitat.” Therefore, if feasible, this should be done 

to avoid impacting resident fish habitat.

In closing, the State appreciated the opportunity to review and comment on the Saddle Lakes Timber 

Sale Project DEIS. If you have any questions, or would like to discuss the above comments in greater 

detail, please contact me.
Appendix D

552  Appendix D – Response to Comments Saddle Lakes Timber Sale Final EIS

Sincerely, 

Kyle Moselle

Large Project Coordinator 

Enclosure: Shelter Cove Road Map

CC:

State Tongass Team

Daryl Bingham, NEPA Planner, KMRD 

Jason Powell, Transportation Planner, Sitka SO
Appendix D

Saddle Lakes Timber Sale Final EIS Response to Comments - Appendix D  553
Appendix D

554  Appendix D - Response to Comments

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Saddle Lakes Timber Sale Final EIS
Saddle Lakes Timber Sale Final EIS Index  555

Index

A

Affected Environment and Environmental 

Consequences, iii, x, 1, 2, 25, 53 

air quality, xi, 20, 21, 56, 218, 223, 360, 364, 

371, 436, 441 

Alaska yellow-cedar, 61, 64, 66, 67, 68, 220, 

308, 309, 310, 311, 312, 316, 390, 505, 506 

alternative development, x, 25 

Alternatives, 25

annualized jobs, iii, 17, 58, 66, 67, 72, 73, 74 

assumptions for analysis, x, 54

B

best management practices (BMP), vi, x, xiii, 

xviii, 29, 402, 406, 439, 447, 448, 452, 455 

biodiversity, 81, 108, 397, 409

black bear, xiv, 36, 97, 134, 453, 475, 516, 

526, 546 

C

carbon sequestration, 220, 221, 222 

climate change, xi, xiii, 20, 21, 56, 218, 219, 

220, 221, 222, 223, 277, 360, 364, 370, 381, 

384, 396, 405, 406, 407, 436, 468, 469, 470, 

471 

commercial seafood industry, 328

connectivity/fragmentation (old-growth 

habitat), 18, 79, 115 

conservation strategy, 84, 99, 101, 103, 377, 

383, 386, 390, 392, 396, 397, 487, 535, 537 

corridors (old-growth connectivity), xiv, xv, 

18, 39, 79, 85, 87, 88, 110, 115, 116, 149, 

163, 445, 533, 534 

D

deer, 91, 117, 445 

deer model, 2, xiv, 36, 39, 80, 92, 93, 94, 95, 

96, 97, 119, 121, 122, 124, 126, 127, 128, 

131, 132, 133, 177, 519, 520, 521, 522, 523, 

524, 527, 528, 529, 539, 540, 541, 542 

design criteria, 31, 32, 110, 115 

E

ecosystem services, xiv, 266, 324, 331, 389, 

496 

elevational corridor (wildlife), vii, 31, 39, 88, 

92, 121, 122, 123, 124, 498, 534 

employment, 17, 35, 58, 59, 60, 66, 67, 329, 

376, 379, 403, 475, 549 

endemic species, iv, 391 

environmental justice, xi, 21, 22, 56, 257, 324, 

360, 383, 436 

essential fish habitat (EFH), 2, xiii, 12, 247, 

250, 385, 457, 461 

F

fish crossing, xvii, xviii, 227, 229, 236, 237, 

238, 246, 345, 349, 350, 351, 459, 549 

fish habitat

degraded, 458 

fish passage, i, viii, x, xiii, xiv, 13, 26, 28, 

107, 190, 236, 237, 246, 251, 262, 269, 284, 

295, 301, 332, 338, 341, 345, 353, 358, 459, 

460, 463, 465, 473, 545, 548, 549 

fish passage barrier modification, x, 28, 107, 

190, 246, 460 

fish species, xvii, 235, 236, 250, 252, 278, 

279, 281, 282 

fisheries, 2, 12, 13, 19, 22, 179, 250, 253, 328, 

367, 368, 369, 370, 371, 381, 385, 390, 395, 

461 

floodplains, 21, 56, 57, 234, 243, 268, 269, 

360, 364, 369, 452, 464 

forest health and productivity, 305, 316, 318, 

320, 322 

G

game management unit (GMU), 2, x, 54 

goshawk, vi, xvi, 38, 79, 91, 106, 107, 110, 

112, 115, 124, 165, 167, 168, 169, 170, 171, 

172, 278, 281, 352, 377, 385, 386, 391, 394, 

395, 402, 408, 535, 536, 537 

greenhouse gasses, 221, 223, 469 
Index

556  Index Saddle Lakes Timber Sale Final EIS

H

heritage resources, xi, 21, 56, 258, 260, 261, 

442 

I

income, ii, xv, xvii, 58, 66, 67, 72, 73, 74, 206, 

257, 324, 328, 329, 332, 333, 335, 559 

incomplete and unavailable information, x, 56, 

80, 173, 181, 201, 224, 259, 266, 283, 288, 

306, 342, 487 

interior habitat, xvi, 86, 87, 102, 110, 115, 

116, 151, 152, 153, 154, 540 

interrelated projects, xii, 429, 436 

invasive plants, 266, 267, 268, 269, 270, 271, 

364, 453 

inventoried roadless area (IRA), 2, iv, xviii, 4, 

26, 32, 77, 88, 108, 111, 123, 153, 273, 277, 

278, 279, 280, 281, 282, 283, 284, 285, 286, 

287, 320, 367, 471 

irreversible and/or irretrievable commitments, 

xi, 362 

issues, v, ix, x, xiii, 7, 15, 16, 19, 27, 192, 309, 

476, 484, 498, 505 

J

justification for clearcutting, xiii, 20, 314, 485, 

486 

K

karst, 56, 264, 279, 282, 487

L

land ownership, xv, xvi, 35, 36, 37, 38, 59, 80, 

86, 124, 125, 126, 127, 130, 131, 132, 138, 

141, 145, 146, 148, 153, 154, 156, 157, 158, 

160, 161, 164, 171, 215, 288, 289, 515, 542 

land use designation (LUD), 2, ii, v, xiii, xvii, 

xviii, 8, 17, 20, 26, 31, 32, 39, 76, 77, 84, 

87, 88, 107, 109, 110, 111, 112, 113, 114, 

121, 122, 123, 124, 132, 134, 135, 136, 137, 

149, 150, 163, 166, 182, 183, 189, 191, 192, 

194, 197, 198, 199, 200, 205, 206, 208, 212, 

214, 215, 216, 271, 278, 279, 280, 281, 283, 

285, 286, 306, 313, 331, 351, 352, 412, 439, 

440, 441, 479, 480, 483, 491, 501, 532, 534, 

541 

landings, xv, 62, 69, 70, 207, 268, 269, 271, 

272, 280, 449, 453, 502 

landslides, 233, 336, 337, 338, 340 

limited export policy, 34, 35, 475, 549 

log storage, 15, 247, 290, 344, 456 

log transfer facility (LTF), 2, i, x, 7, 14, 25, 

28, 62, 71, 205, 247, 266, 288, 332, 344, 

354, 431, 445, 457, 545, 548 

logging systems, i, xviii, 7, 17, 29, 30, 31, 32, 

58, 59, 61, 67, 68, 69, 72, 73, 74, 224, 268, 

269, 305, 314, 349, 350, 351, 369, 499 

long-term productivity, xi, 361 

M

management indicator species (MIS), 2, 91, 

117 

marten, 36, 99, 142, 382, 399, 446 

Metlakatla, 12, 173, 174, 176, 178, 257, 260, 

281, 325, 330, 372, 373, 374, 375, 531 

migratory birds, 166

minerals, xi, 21, 56, 277, 288, 290, 294, 345, 

360, 364, 367, 369, 436 

mitigation and monitoring, vi, xiii, 270, 439, 

476, 545 

O

old-growth reserves (OGR), vii, 84, 99, 113, 

303, 387, 524 

P

past activities, xii, 429

patch size, 85, 86, 102, 103, 116, 148 

preferred alternative, iii, ix, x, 25, 31, 75, 459, 

472, 473, 474, 500, 534, 544, 545, 548, 549 

present activities, xii, 262, 431

productive old growth (POG), 82 

proposed action, iii, ix, x, 1, 6, 10, 31, 437, 

481, 502, 514 

public involvement, ix, 1, 10, 53, 62, 413 

Purpose and Need for the Action, ii, iii, iv, ix, 

1, 5, 6, 7, 16, 25, 26, 27, 30, 206, 332, 472, 

473, 476, 481, 482, 491, 496, 502, 507, 514, 

545 

R

rare plants, 19, 300, 442 

reasonably foreseeable future activities, xii, 

432 
Index

Saddle Lakes Timber Sale Final EIS Index  557 

recreation, 18, 180, 201 

recreation opportunity spectrum (ROS), 2, v, 

xviii, 40, 201, 203, 205 

References Cited, xi, 376 

Regeneration and Species Composition, 305, 

316, 317, 318, 319, 320, 322 

road construction, 34, 35, 40, 65, 70, 189, 347, 

353, 450, 451, 452 

road density, xiv, 36, 37, 96, 97, 100, 101, 

129, 130, 131, 143, 146, 147, 233, 538 

road maintenance and reconditioning, 343, 

512 

rock quarries, 62, 70, 242, 243, 269, 270, 352, 

353, 365, 454 

S

sawmills, 327

Saxman, 12, 18, 79, 96, 126, 134, 146, 149, 

173, 174, 175, 176, 178, 257, 259, 260, 263, 

281, 325, 330, 375, 377, 497, 498, 531, 532 

scenery, 180 

scenic integrity objective (SIO), 2, v, xvi, 17, 

19, 31, 35, 39, 40, 76, 180, 181, 182, 190, 

215, 216, 280, 443, 486 

scoping, ix, 10, 408 

sedimentation and turbidity, 242, 458 

short-term use, xi, 361 

silvicultural systems, i, 7, 20, 29, 61, 68, 78, 

305, 312, 313, 349, 350, 380, 394, 398 

size of even-aged openings, 314 

size-density model, 18, 79, 82, 393 

slopes greater than 72 percent gradient, 337, 

339, 497, 550 

small sales, x, 27, 63, 334, 347, 421, 422, 472, 

499, 506 

soil productivity, 55, 336, 337, 338, 339, 340, 

362, 365 

soils, xi, xiv, 21, 221, 234, 243, 269, 270, 277, 

279, 282, 336, 357, 361, 365, 436, 440, 486, 

497 

State of Alaska right-of-way (ROW), i, v, 29, 

107, 181, 210, 290, 338, 358 

stream buffers, 28, 109, 314, 318, 322, 323, 

352, 456 

stream class, xvii, xviii, 227, 229, 242, 464, 

465 

stream crossing, xvii, 28, 224, 236, 239, 242, 

243, 244, 246, 247, 248, 251, 255, 268, 270, 

271, 342, 345, 347, 452, 459, 460, 462, 465, 

510, 511, 545, 549 

streamflow, viii, 224, 231, 238, 239, 248, 390, 

392, 462 

subsistence, i, iv, ix, xi, xiv, 10, 18, 31, 35, 39, 

53, 79, 173, 175, 176, 178, 179, 262, 281, 

287, 302, 330, 331, 335, 343, 361, 365, 412, 

491, 496, 497, 498, 515, 520, 531, 533 

suitable and available forest land, 306, 320, 

326, 335, 412 

suitable forest land, 5, 77, 493 

T

timber availability, i, iv, ix, x, 17, 26, 27, 31, 

32, 53, 76, 77, 78, 306, 333, 436, 473, 477, 

480, 501, 507 

timber economics, i, ii, iv, ix, x, xiv, 17, 31, 

32, 34, 53, 58, 74, 324, 326, 327, 328, 331, 

332, 333, 334, 436, 468, 473, 496, 506, 507, 

548 

timber market demand, xi, 411, 416 

tourism, 206, 216, 328, 329, 439, 440, 443, 

483, 484 

tow costs, 64, 71 

U

unavoidable adverse impacts, xi, 256, 360, 

461 

V

value comparison unit (VCU), 2, i, vii, x, xv, 

xvi, 2, 18, 26, 32, 35, 36, 37, 38, 39, 53, 77, 

79, 80, 84, 86, 87, 88, 101, 102, 103, 104, 

107, 108, 109, 110, 111, 112, 113, 115, 122, 

123, 124, 132, 135, 136, 137, 142, 143, 144, 

145, 146, 147, 148, 149, 150, 152, 153, 154, 

155, 156,157, 158, 159, 160, 161, 162, 163, 

164, 165, 166, 168, 169, 170, 171, 172, 198, 

200, 279, 285, 286, 479, 540 

vegetation, 268, 278, 305, 308, 312, 338, 340, 

358, 442, 449, 450 

visual priority route (VPR), 2, i, v, vii, xvi, 

xviii, 10, 17, 18, 19, 31, 32, 35, 40, 76, 78, 

180, 181, 183, 185, 189, 190, 191, 192, 193, 

194, 197, 199, 205, 214, 215, 216, 285, 333, 

360, 364, 485, 500, 503, 505, 507, 550 
Index

558  Index Saddle Lakes Timber Sale Final EIS

W

water quality, xiii, 13, 15, 232, 243, 369, 376, 

402, 406, 443, 447, 449, 452, 463 

watershed, xiii, xiv, 225, 232, 233, 235, 236, 

238, 241, 243, 245, 369, 380, 385, 393, 395, 

398, 440, 443, 448, 464, 549, 550 

wetlands, xi, 21, 239, 268, 277, 279, 282, 338, 

354, 356, 358, 361, 365, 436, 444, 445, 452 

wildlife analysis area (WAA), 2, x, xv, xvi, 

18, 35, 36, 39, 54, 79, 83, 86, 92, 94, 96, 97, 

98, 99, 108, 120, 121, 123, 125, 126, 127, 

128, 129, 130, 131, 132, 133, 136, 138, 139, 

140, 141, 146, 147, 148, 149, 154, 156, 157, 

160, 164, 171, 174, 175, 176, 177, 480, 481, 

498, 517, 520, 524, 528, 529, 530, 531, 532, 

538, 539, 542 

windthrow, vi, viii, x, 28, 85, 135, 155, 231, 

234, 246, 255, 305, 306, 309, 310, 311, 314, 

316, 317, 318, 319, 320, 322, 323, 444, 470, 

486, 487 

wolf, 94, 128, 397, 446 

Y

young growth, 82, 83, 105, 120, 125, 134, 

135, 150, 158, 162, 166, 312, 322, 337, 388, 

415, 416, 491, 492, 507, 540, 549 
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