Appendix 3 

Supplemental Information 

to the FEIS 

Appendix 3 

Supplemental Information to the FEIS 

Introduction 

The intention of this appendix is to present the Decision Maker with the most 

up-to-date information concerning this project. Included are the changes that 

have occurred between the earlier analysis of the Action Alternatives used in 

the Central Kupreanof Final Environmental Impact Statement (FEIS) and the 

recent analysis of the Selected Alternative in the Record of Decision (ROD), 

which is a modification of Action Alternative 3. 

Due to the delayed release of the FEIS, some resource information became 

outdated; in addition new analysis was conducted to supplement the wildlife 

portion of the FEIS. Policy changes and changes in agency direction have also 

occurred between the printing of the FEIS and the completion of this Record of 

Decision (ROD). 

All activities proposed in Modified Alternative 3 are analyzed by all resources 

in their associated resource reports and are available in the project record upon 

request at the Petersburg Ranger District. 

Council of Environmental Quality (CEQ) regulations state that agencies shall 

prepare supplements to either draft or final environmental impact statements if 

the agency makes substantial changes in the proposed action that are relevant to 

environmental concerns; or there are significant new circumstances or 

information relevant to environmental concerns and bearing on the proposed 

action or its impacts (CEQ 1502.9). 

The proposed action for the project has not changed and the new analysis 

included in this appendix is related to the Interagency Habitat Capability Model 

(deer model). While the deer model does represent new analysis, the outcome 

supports the analysis presented in the DEIS and FEIS. The deer model was run 

for all Action Alternatives presented in the FEIS and for Modified Alternative 

3. The results are summarized in the wildlife section of this appendix. Further 

information regarding the deer model is in the project record. 

The new information regarding wildlife includes: 

 results of running the deer model for all Action Alternatives and 

modified Alternative 3; 

 comparison of effects of the Deer Model with the POG analysis 

used in the FEIS; 

 updates to the Sensitive Species List. 

On May 28, 2009, the USDA Secretary reserved decision making authority 

over construction and reconstruction of roads and the cutting, sale or removal 

of timber in inventoried roadless area in a memorandum that stated: 

New Information 

Changes in 

Policy/Agency 

Direction 

Central Kupreanof Record of Decision APPENDIX 3 • 1
“The authority to approve road construction and timber harvest in Inventoried 

Roadless Areas is reserved to the Secretary of Agriculture (Secretary’s 

Memorandum 1042-154).” 

The Secretary’s Memorandum is intended to ensure the careful consideration of 

activities in Inventoried Roadless Areas while long term roadless policy is 

developed. 

In the interim the Record of Decision for this project has been completed using 

the most current direction provided. 

 

 The FEIS addresses the issue of IRAs using the 2008 Roadless 

Inventory. Additionally, as interim direction is developed, this 

appendix addresses the issue of IRAs by comparing all Action 

Alternatives, Modified Alternative 3, using the 2001 Roadless Rule 

Inventory. 

Only resources that had updated information to provide, such as updated 

harvest dates due to the delay in printing and distribution of the FEIS and the 

completion of the ROD, were included in this appendix. The effects on all 

resources for the Action Alternatives are disclosed in the FEIS and the 

associated resource reports. All resources also analyzed for the effects of 

Modified Alternative 3; these effects are also detailed in the individual resource 

reports that are located in the project record. 

All information contained in this appendix is within the scope of effects 

presented to the public for comment in the DEIS. New information includes: 

 

 updated Tongass Export Policy; 

 changes in mill infrastructure in Southeast Alaska; 

 new quarterly updates to the tools used in analyzing and comparing 

the economics of a timber sale; 

 updated aquatics numbers and implementation date (2011 rather 

than 2009) based on the harvest units and associated road 

construction chosen for Modified Alternative 3; 

 new numbers of timber acres under litigation and harvest levels for 

the 2010 fiscal year; 

 revised Response to Comments section for any comments that 

needed updating between the printing of the FEIS in October of 

2009 and the completion of this ROD. 

Updated 

Information 

2 • APPENDIX 3 Central Kupreanof Record of Decision Appendix 3
FEIS Chapter 3 

Supplemental Information by Resource

Issue 1-Timber Supply/Sale Economics 

Introduction 

This section updates and serves as a supplement to the Timber Supply/Sale 

Economics section in Chapter 3 of the FEIS (pgs 3-10 to 3-24). 

NEPA Economic Analysis Tool Residual Value 

Updates and Analysis of the Modified Alternative 

The NEPA Economic Analysis Tool Residual Value (NEAT_R version 2.16) is 

the Forest Service, Alaska Region, financial efficiency and economic analysis 

program for use in timber planning. This program uses the same logging costs 

and manufacturing costs developed for the Alaska Region timber sale appraisal 

program. Costs reflect production studies and data collected from timber sale 

purchasers in Southeast Alaska. Values generated by NEAT_R are estimates 

which allow a decision maker an opportunity to compare timber economics 

across all alternatives at a specific point in time. Timber economics at the time 

of actual offering will change during sale packaging as boundaries tend to 

change to conform to localized terrain features and as more accurate cruise 

data, specific to the package, become available. 

If any modification of an established action alternative is to be analyzed, it 

becomes necessary to treat these modifications as a new and separate 

“alternative” in the NEAT_R program to assist forest planners in comparing 

those changes with the original action alternatives. Modified Alternative 3 

analyzes the economics of the project after dropping those units and portions of 

units located within Inventoried Roadless Areas, dropping units due to the high 

cost of helicopter yarding, and dropping units located VCU 0436 or the 

headwaters of the Castle River (also located in an IRA). In addition updates to 

the program were added to reflect current export policy and mill infrastructure 

in the region. 

The NEAT_R analysis for the Central Kupreanof project FEIS (beginning June 

2007 and ending Feb 2010) applied “Lower 48” values to approximate the 

amount of Interstate Shipment of unprocessed hemlock and spruce permitted 

under the March 2007 Limited Interstate Shipment Policy. New updates to the 

NEAT_R program applies “Foreign Market” values to approximate the amount 

of Foreign Market export permitted under the November 2009 Limited Export 

Policy (memo File Code 2420-1-2/2430 November 10, 2009). 

NEAT_R version 2.16 also applies 2nd Quarterly 2009 updates (February 11, 

2009) to pond log value coefficients, wood defect coefficients, logs per tree 

Central Kupreanof Record of Decision APPENDIX 3 • 3

Appendix 3
coefficients, and updates to the logging cost calculations for Base Year 2008 

(NEAT_R 2Q2009 Updates Release Notes.) The NEAT_R update is likely to 

result in volume differences from older versions of NEAT_R because it uses 

the new average tree volumes by species, diameter class, and district from the 

Historic Cruise Database. The Historic Cruise Database is updated annually by 

adding log data from new cruises and deleting log data from the oldest cruises 

for each District. Eventually all of the oldest cruises will be deleted because 

they are not comparable to new cruises (cruising to 32 foot logs from 16 foot 

logs, calculated utility volume, and the addition of Special Mill log grade 6). 

These updates to the NEAT_R program utilized in the analysis of Modified 

Alternative 3 has had a subtle increase on the overall estimated volume across 

all alternatives (see Table A3-4 and Table A3-5 Timber Financial Efficiency 

Analysis below). Conversely, indicated value, indicated bid rate, stump-to-mill 

cost, and estimated project employment and income values in Alaska are 

reflected by the new volume estimates from earlier analysis used in the FEIS. 

(See Tables A3-6, and A3-7). 

Data represented in the FEIS show employment figures through 2007. Updates 

have occurred to forest products employment data showing a continual 

downward trend in the number of logging, sawmill, and related industry jobs 

across Southeast, Alaska from 2002 to 2009 (see Table A3-1). 

 

Forest Products 

Employment 

4 • APPENDIX 3 Central Kupreanof Record of Decision Appendix 3
Table A3-1. Employment in the Wood Products Industry in Southeast Alaska, 2002-2009 

(FEIS Pg. 3-12)

Year1 Tongass 

Logging2

Tongass 

Sawmill

TongassRelated 

Employment3

Other 

Sawmill 

Other 

Logging

Total 

Industry 

Employment

2002 63 110 173 40 299 512 

2003 108 91 199 64 298 561 

2004 82 95 177 53 220 450 

2005 88 96 184 52 263 499 

2006 81 77 158 46 217 421

2007 44 70 114 63 225 402 

2008 52 70 122 24 118 265 

2009 48 39 87 19 110 216 

Source: Alaska Department of Labor, Kilborn et al. (2004), Brackley et al. (2006), Brackley and Crone (2009), 

Alexander and Parrent (2010), and Parrent (2010). Data on file with: Regional Economist, Ecosystems Planning, 

USDA Forest Service, PO Box 21628, Juneau, AK 99802-1628 

1

Reported in calendar years. 

2

Tongass National Forest logging estimated based on the ratio of Tongass timber harvest to total timber harvest in 

Southeast Alaska. Through 2001, it was assumed that all sawmill and pulp mill employment is dependent upon Tongass 

National Forest timber supply. Beginning in 2002, this assumption no longer held. Data from Kilborn et al. (2004), 

Brackley et al. (2006), Brackley and Crone (2009), Alexander and Parrent (2010), and Parrent (2010) show that Federal 

timber supplied 73 percent of the wood sawn in Southeast Alaska mills in 2002, 59 percent in 2003, 64 percent in 2004, 

65 percent in 2005, 62 percent in 2006, 53 percent in 2007, 75 percent in 2008, and 66 percent in 2009. 

3

Tongass National Forest sawmill employment from 2002 through 2009 is estimated based on sawmill employment numbers 

and the ratio of sources of wood (Federal versus the total) reported by Kilborn et al. (2004), Brackley et al. (2006), Brackley and 

Crone (2009), Alexander and Parrent (2010), and Parrent (2010).

Modified Alternative 3 will use the existing road system and the existing Little 

Hamilton LTF. Approximately 38 miles of NFS roads exist in Modified 

Alternative 3 project area. Table A3-2 shows the amount of existing and 

proposed roads by alternative within the project area represented in the FEIS 

compared to Modified Alternative 3. 

 

Road Access and 

Log Transfer 

Facility (FEIS pg 

3-13) 

Central Kupreanof Record of Decision APPENDIX 3 • 5

Appendix 3
Table A3-2. Existing and Proposed Miles by Alternative within the Project Area 

(FEIS Pg. 3-14) 

Miles by Alternative 

1 2 3 4 Modified 

Alternative 3 

Existing NFS Road 79 79 79 79 38.0

Proposed NFS Road 0 7.3 25.1 0 1.8

Proposed NFS Road Reconstruction 0 2.9 9.1 2.6 1.0

Proposed Temporary Road 0 3.9 6.1 2.2 2.3

Source: Tongass GIS 2010 

Quarterly updates to the NEAT_R program reflect changes in logging systems 

and barge cost per $/MBF. The average cost of shovel yarding across all 

alternatives using NEAT_R version 2.16 (August 2010), which adds updates 

concerning Tongass Export Policy, is $173/MBF, an 23$/MBF increase from 

NEAT_R analysis used in the FEIS. The average cost of cable yarding all 

alternatives is $249/MBF, which is a $38/MBF decrease from earlier NEAT _R 

analysis (June 2008 output). Modified Alternative 3 utilizes only ground-based 

cable and shovel yarding systems. All remaining helicopter units and settings 

not located in IRAs were dropped from the project area due to the high cost 

associated with this logging system, specifically settings and Units 5, 203, 208, 

and 901. 

Since the publication of the FEIS, there have been changes to the Southeast 

Alaska mill infrastructure in proximity to the project area. The original Central 

Kupreanof NEAT_R economic analysis was designed with an appraisal point 

destination to the Silver Bay mill located on Wrangell Island. Currently, the 

Silver Bay mill is dismantling their operation and is no longer viable. The log 

tow was recalculated for the Viking Mill located in Klawock on Prince of 

Wales Island. The round-trip-tow distance increased substantially which 

significantly affects the stump-to-mill cost across all alternatives. On average, 

the barging costs were estimated to be $99/MBF, a $19/MBF increase over 

previous analysis. 

 

Final Destination 

of Tow and 

Logging Systems 

(FEIS Pg. 3-14) 

6 • APPENDIX 3 Central Kupreanof Record of Decision Appendix 3
Retention of lower-value old growth also improves economics on a stand-bystand basis where it is safe to do so. The prescription changed from clearcut to 

a two aged system, incorporating 30 percent retention on 578 acres. The 

prescription changed from clearcut to incorporate 15 percent retention on 39 

acres within the project area. Table A3-3 displays the acres by yarding system 

for each of the action alternatives and changes that have occurred in Modified 

Alternative 3. 

Table A3-3. Yarding System and Harvest Method (Acres) (FEIS Pg. 3-15) 

Yarding System - Harvest Method 

Alternatives 

Alt. 1 Alt. 2 Alt. 3 Alt. 4 Modified 

Alternative 

Cable - Clearcut 0 981 1,638 567 154

Cable - Clearcut with 10% Retention 0 90 90 26 39

Cable - Clearcut with 15% Retention 0 0 0 0 39

Cable – Clearcut With Reserves (30% 

Retention) 0 0 0 0 80

Shovel - Clearcut 0 934 1,373 721 519

Shovel - Clearcut with 10% Retention 0 26 26 13 0

Shovel - Clearcut with Reserves (30% 

Retention) 0 0 0 0 498

Shovel - Clearcut with Reserves (50% 

Retention) 0 33 0 0 0

Helicopter - Single Tree Selection 

(60% Retention) 0 442 520 0 0

Direction in export of timber sale volume has changed since the FEIS has been 

printed. 

A time limited shipment of unprocessed hemlock and Sitka spruce logs 

approved on August 8, 2008 by the Regional Forester has been extended 

(memo File Code 2420-1-2/2430, November 10, 2009). Under direction of the 

Time Limited Export Policy, a purchaser may request approval to ship 

unprocessed timber outside of Alaska to the most advantageous markets in the 

Lower 48, including foreign markets. Up to 50 percent of the total sale sawlog 

volume (sum of all species) of unprocessed hemlock and Sitka spruce logs may 

be exported. A purchaser may also continue to request a permit to export 

unprocessed cedar to domestic and foreign markets. Timber volume, however, 

is not ‘pre-authorized’ for export. If a purchaser desires to ship timber to 

domestic (Lower 48) destinations outside the state of Alaska or export timber 

overseas, they are required to apply for a permit from the Regional Forester. 

Export Policy 

Central Kupreanof Record of Decision APPENDIX 3 • 7

Appendix 3
This authorization was put in place to offset the dramatic increase in costs, 

coupled with a decline in orders and selling values experienced by Alaska’s 

timber industry at that time. Export permits will be good for the life of the 

contract. The Region will monitor the market conditions on an annual basis 

and adjust the allowable export percentage downward as domestic prices 

improve. These modifications will allow timber sales to have a far greater 

chance of appraising positive, while also allowing local timber purchasers and 

manufacturers options to stay in business and be poised to commence full 

operations when the market improves. Sales from the Central Kupreanof 

project may be offered for sale under this export policy. This project may be 

implemented over a period of several years; during which time market 

scenarios are subject to considerable change. 

Modified Alternative 3 was designed to maximize economic efficiency while 

offering the most flexibility by selecting harvest units adjacent to the existing 

Kake road system. Units requiring extensive road building to gain access were 

dropped from consideration. Units requiring helicopter harvesting system were 

also dropped. Economics were further improved by adding 30 percent retention 

to lower value trees to approximately 578 acres within the project area. 

Dropping road segments and expensive logging systems has improved the 

overall economics, but lengthening the tow to Klawock has raised the overall 

logging cost across all alternatives. Table A3-4 shows the timber financial 

differences that have occurred between the action alternatives analyzed in the 

FEIS, and Modified Alternative 3. 

The overall indicated rate per MBF of Modified Alternative 3 remains 

negative, Modified Alternative 3 will provide enough flexibility for small sales 

and Microsales that typically have improved economics based on lack of barge 

cost equating to short hauls to local small mill operations most likely to the 

community of Kake, and a localized workforce from Kake. Interest to 

purchase small sales and Microsales exist within the community of Kake. 

Microsales will be allowed along existing NFS roads 6040, 6314, 6326, 6328, 

6334, 6336, and 6339 contained within the project area. 

Larger offerings may be offered in the future to meet the timber demands of the 

region as economics improve. Potential small sales however, would not change 

the project’s estimated total volume, number of jobs, direct income, or logging 

systems by harvest method. Further explanation of the differences in indicated 

bid rates among the action alternatives can be found in Chapter 3 of the FEIS in 

the Timber Financial Efficiency Analysis section. 

Updates to the NEAT_R program occur each year which incorporate the latest 

volume estimates per diameter class as determined by the most recent cruise 

information across the Tongass. Recent updates to NEAT_R also include the 

incorporation of Special Mill logs, a grade assigned to higher value trees due to 

less seen defect, which equates to higher volume estimates and improves 

Timber Financial 

Efficiency 

Analysis and 

Opportunities to 

Improve 

Economics 

(FEIS pgs 3-16 - 

3-24)

Basal Area and 

Diameter Class 

Values in 

NEAT_R 

8 • APPENDIX 3 Central Kupreanof Record of Decision Appendix 3
selling value. Overall estimated volume per alternative and per species have 

increased with the incorporation of these updates to the program, having 

changed the basal area per diameter class values of some diameter classes by 

tenths and hundredths of a decimal point (Table A3-4). The variations in basal 

area values will have a subtle effect on estimated volume (see Table A3-5), 

indicated value, indicated bid rate, stump-to-mill cost, and estimated project 

employment and income in Alaska (See Tables A3-6 and A3-7). 

Table A3-4. Timber Financial Efficiency Analysis3 (FEIS pg. 3-16) 

Alt. 1 Alt. 2 Alt. 3 Alt. 4 Modified Alternative 3 

Volume - Sawlog 

(MBF) 

 Sitka Spruce 0 7,085 10,375 3,799 3,682

 Hemlock 0 27,743 42,601 17,213 14,590

Western redcedar 0 154 239 97 98

 Alaska YellowCedar 0 7,327 10,756 3,791 3,907

Total Sawlog Volume 

(MBF) 0 42,310 63,971 25,080 22,278

Pond Log Value 

$/MBF1 $0 $344 $341 $336 $336 

Stump to Mill Cost 

$/MBF $0 $420 $458 $398 $387

Indicated Value2 

($ millions) $0 ($3.2) ($7.5) ($1.6) ($1.1)

Indicated Rate $/MBF $0.00 ($75.99) ($116.63) ($62.44) ($51.17) 1

 Numbers may not add up to the totals shown due to rounding. 

2

 ( ) indicates negative value 

3 NEAT_R v2.16 analysis 2010 output 

Central Kupreanof Record of Decision APPENDIX 3 • 9

Appendix 3
Table A3-5. Estimated Volume in MMBF1 (FEIS Pg. 3-17) 

Estimated 

Volume 

Alternatives 

Alt. 1 Alt.2 Alt. 3 Alt. 4 

Selected 

Alternative 

Sawlog 0 42.3 64.0 25.0 22.3

Utility 0 7.7 11.8 4.7 4.0

Total 0 50.0 75.8 29.8 26.3 1

 NEAT_R v2.16 analysis 2010 output 

Table A3-6. Timber Financial Efficiency Analysis (if public work funds cover NFS 

road construction costs)1 (FEIS Pg. 3-19) 

Alt. 1 Alt. 2 Alt. 3 Alt. 4 Modified 

Alternative 3 

Stump to Mill Cost $/MBF $0 $418 $432 $398 $386

Indicated Value 

 ($ millions) 2 $0 ($3.1) ($5.8) ($1.6) ($1.1)

Indicated Rate $/MBF $0 ($73.85) ($90.37) ($62.44) ($50.35)

1 NEAT_R v2.16 analysis 2010 output 

2

 ( ) indicates negative value 

The number of sawmill jobs and related income is provided as a range in Table 

A3-7 to reflect the variety of options the timber purchaser has under the 

Tongass Export Policy. The purchaser may elect to process all the sawlogs 

locally or to ship up to 50 percent of the total sawlog volume (sum of all 

species) of unprocessed Sitka spruce and western hemlock of the sale to 

domestic and foreign markets outside Alaska. Purchasers may also choose to 

apply for a permit to export all Alaska yellow cedar and western red cedar from 

the sale. The upper range of the figure represents the number of jobs if a 

purchaser chooses to process logs locally. The lower range represents the 

number of jobs if a purchaser exports 50 percent of the total sawlog volume 

from the project. This analysis only provides percent comparison across 

alternatives of the project area as a whole, and does not take into consideration 

small sales and Microsales generated from the project area. 

 

Projected 

Employment and 

Income 

10 • APPENDIX 3 Central Kupreanof Record of Decision Appendix 3
Table A3-7. Estimated Project Employment and Income in Alaska4

 (FEIS Pg. 3-20) 

Employment1 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Modified Alternative 

3 

Logging2 0 98 148 58 51

Sawmills3 0 70-140 106-212 42-83 58-115

Direct Jobs 0 168-238 254-360 99-141 88-125

Direct Income 

( $ millions) 0 $6.5-8.9 $9.8-13.5 $3.8-5.3 $3.4-4.7

1 Number of Job years 

2 Annualized jobs per MMBF based on net sawlog volume sold. 

3 Sawmill jobs range based on 50 percent of net volume shipped to markets outside Alaska to all sawlogs 

processed in Alaska 

4 NEAT_R v2.16 analysis 2010 output 

Table A3-8. Comparison of Alternatives (FEIS Pg. 3-23) 

1 NEAT_R v2.16 analysis 2010 output 

2

 ( ) indicates negative value 

Summary of Changes from the FEIS 

Modified Alternative 3 was designed to maximize timber harvest opportunities 

of the project area located outside of all IRAs while minimizing road building. 

This alternative selects harvest units adjacent to the existing road system from 

Modified Alternative 3. Units that required longer segments of new NFS 

Alt. 1 Alt. 2 Alt. 3 Alt. 4 Modified Alternative 31

Indicated Bid2

Value/MBF 0 ($75.99) ($116.63) ($62.44) ($51.17)

Stump to Mill Cost 

$/MBF 0 $420 $458 $398 $387

Road Costs/MBF 0 $18 $48 $17 $27

Temp Road 

Miles

0 3.9 6.1 2.2 2.3

System Road 

Miles 

0 7.3 25.1 0 1.8

Helicopter Sawlog 

Volume MMBF1 0 3.7 4.8 0 0

Ground Based 

Sawlog Volume 

MMBF 

0 38.7 59.1 25.0 22.3

Modified 

Alternative 3 

Central Kupreanof Record of Decision APPENDIX 3 • 11 Appendix 3
roadbuilding were dropped. Short NFS road extensions and short temporary 

road segments along with approximately one mile of road reconstruction will 

be necessary to facilitate access (See Figure R-2). Modified Alternative 3 will: 

 Designate approximately 26.3 MMBF to meet the Purpose and Need 

for this project from approximately 1,329 acres. 

 Proposes approximately 4.1 miles of new road construction. New road 

construction miles would be 44 percent NFS roads (1.8 miles) and 56 

percent temporary roads (2.3 miles). Approximately 1 mile of road 

reconstruction will be necessary. 

 Utilizes shovel and cable yarding systems (clearcut and clearcut with 

reserves 30 percent). 

 Has an indicated bid value of (-51.17/MBF). 

 Has an estimated logging and transportation cost of $387/MBF. 

 Provides an estimated 88-125 direct annualized jobs. 

A comparison of unit specific and road activity changes between Modified 

Alternative 3 (Selected Alternative) for the ROD and Action Alternative 3 of 

the FEIS see Figure R-2 in the ROD and Figure 3-3 of the FEIS. 

 

 

12 • APPENDIX 3 Central Kupreanof Record of Decision Appendix 3
Issue 2-Inventoried Roadless Areas 

The Roadless analysis in the Central Kupreanof FEIS is based on the 2008 

Roadless Inventory. The purpose of this section is to provide the same 

information as presented in the FEIS concerning roadless areas using the 

roadless inventory of the 2001 Roadless Rule to compare all Action 

Alternatives and Modified Alternative 3. The intention is to provide a 

comparison of each roadless area until long term policy is developed. 

One of the major differences between the 2001 and 2008 roadless inventories, 

in relation to this project, other than slight differences in their boundaries (see 

Figure R-2) is the implementation of the Shamrock Record of Decision. 

Activities associated with this decision were not considered in the 2001 

Roadless Rule Inventory but were included as part of the 2008 Roadless 

Inventory. The decision cleared 38 MMBF of timber harvest and 33.8 miles of 

road. 

Other differences between the 2001 Roadless Rule and 2008 Roadless 

Inventories in relation to this project are: 

 acerage differences between each of the three Inventoried Roadless 

Areas; 

 total number of acres harvested; 

 total acres affected. 

Table A3-9. Comparison of Inventoried Roadless Areas using the 2001 Roadless Rule Inventory and 

the 2008 Roadless Inventory

Inventoried 

Roadless 

Area (IRA) 

Total Acres 

2001 

Roadless 

Rule 

Inventory 

Total 

Acres 2008 

Roadless 

Inventory 

Total 

Proposed 

Acres of 

Harvest 

2001 

Roadless 

Rule 

Inventory 

Total 

Proposed 

Acres of 

Harvest 

 2008 

Roadless 

Inventory 

Total Acres that 

would be 

Affected(including 

buffers) 2001 

Roadless Rule 

Inventory 

Total Acres 

that would 

be Affected 

(including 

buffers) 

2008 

Roadless 

Inventory 

North 

Kupreanof 

IRA 

114,637 99,566 111 242 490 715 

South 

Kupreanonf 

IRA 

216,774 213,122 2,975 1,525 15,353 6,257 

Rocky Pass 

IRA 78,148 79,103 10 6 163 216 

TOTALS 409,559 391,791 3,096 1,773 16,006 7,188 

Central Kupreanof Record of Decision APPENDIX 3 • 13 Appendix 3
Direct, Indirect and Cumulative Effects using the 

2001 Roadless Rule Inventory 

(Addition to FEIS pgs 3-30 to 3-35) 

Temporary roads and NFS 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 wildlife, watershed and 

recreation resources after the timber harvest is complete. Temporary roads in 

particular will continue to have a diminishing effect on inventoried roadless 

areas over time as natural revegetation and water drainage are established. 

In all action alternatives, the majority of effect to the IRA size is created by the 

600-foot buffer and 1,200-foot buffer around harvest units and roads. These 

buffers account for the main indirect effects to IRAs. 

While the overall roadless characteristic of each inventoried roadless area 

would remain unchanged, individually identified roadless values would either 

remain unchanged or be minimally influenced by the proposed activities. Soil, 

water and air quality would remain unchanged. There would be no effect to 

public drinking water. Each roadless area would still be able to support a 

diversity of plant and animal communities and provide habitat for sensitive 

species (no threatened or endangered species exist within the project area). 

While there may be some change, all areas would continue to provide for a 

variety of recreation experiences including primitive, semi-primitive nonmotorized and semi-primitive motorized classes. All inventoried roadless areas 

would still provide large areas in natural settings that could serve as reference 

landscapes. While there would be limited visible changes to the inventoried 

roadless areas, overall scenic qualities would not change. No traditional or 

cultural properties or sacred sites would be affected by the proposed activities. 

In all alternatives, the North Kupreanof, South Kupreanof, and Rocky Pass 

Inventoried Roadless Areas would remain greater than 5,000 acres in size and 

eligible for Wilderness consideration in subsequent forest planning. 

A greater number of acres would be affected under the 2001 Roadless Rule 

inventory than the 2008 Roadless Inventory. The direct effects of all 

alternatives would not change from the FEIS analysis, and the cumulative 

effects of the 2001 Roadless Rule inventory differs by 0.1 percent from the 

2008 Roadless Inventory. 

The indirect effects for each Action Alternative are greater using the 2001 

Roadless Rule inventory due to the 600’ and 1200’ foot buffers (these were 

applied to the analysis in the FEIS as well) applied around harvest units and 

roads. These overlap IRAs and influence the indirect effects for each IRA. 

Alternatives 2 and 3 include timber harvest within the boundaries of the North 

Kupreanof, South Kupreanof, and Rocky Pass IRAs. The predominant effects 

would be to the South Kupreanof IRA with approximately 866 acres of timber 

Effects Common 

to all Action 

Alternatives 

Comparison of 

Alternatives 

14 • APPENDIX 3 Central Kupreanof Record of Decision Appendix 3
harvest and one mile of new NFS road in Alternative 2 and the harvest of 1,842 

acres and 15 miles of road construction in Alternative 3. In comparison, the 

North Kupreanof IRA acres of harvest would vary from 25 acres in Alternative 

2 to 86 acres in Alternative 3. No new roads are proposed within the North 

Kupreanof or Rocky Pass IRAs. Both Alternatives 2 and 3 propose 5 acres of 

timber harvest within the Rocky Pass IRA. 

Of the three action alternatives, Alternative 3 would affect the most roadless 

acres. Up to 9,789 acres would be treated in the South Kupreanof IRA. The 

affected acres represent about five percent of the South Kupreanof IRA. 

Alternative 4 avoids timber harvest and road building within the boundary of 

IRAs. However, the application of the 600 feet and 1,200 feet around harvest 

units and roads would overlap the IRA boundaries. Alternative 4 affects the 

least total roadless acres of any action alternative. 

Table’s 3A-10 through 3A-12 below display the effects to IRAs by Alternative. 

This alternative does not propose road construction or timber harvest and 

would have no effect on any inventoried roadless areas. 

In the North Kupreanof IRA, approximately 25 acres of timber harvest is 

proposed, with no NFS or temporary road construction. In Unit 216 

approximately 32 acres of harvest by single tree selection and helicopter 

yarding is proposed. In Units 215 and 903, harvest is proposed on 

approximately 58 acres by clearcut methods and conventional yarding. 

Approximately 135 total roadless acres (0.1%) would be affected with the 600 

foot delineation around harvest units (Table A3-10). 

In the South Kupreanof IRA, approximately 866 acres of timber harvest and 

one mile of NFS road construction is proposed. In Units 218, 219, 222, 223, 

224, 232, 233, 234, 235, and 249 approximately 211 acres of harvest is 

proposed by single tree selection and helicopter yarding. Approximately 130 

acres of harvest is proposed by clearcut methods and conventional yarding in 

Units 250, 252, 253, 270, 282, 284, and 285. Approximately 3,922 total acres 

(1.8%) of IRA would be affected with application of the buffers of 600 feet 

around harvest units and 1,200 feet for road construction (Table A3-11). 

In the Rocky Pass IRA, approximately five acres of timber harvest (Unit 310 

by clearcut methods) is proposed.. No road construction would occur inside 

the IRA boundary. Approximately 67 acres (0.08%) of the IRA would be 

affected (Table A3-12). 

For all IRAs in Alternative 2, the characteristic values for availability as 

wilderness would remain unchanged. No unique attributes would be affected. 

The biological value of old-growth forest would be reduced proportionally by 

the amount of timber harvest in each IRA. Proposed timber harvest activities 

outside the Rocky Pass IRA would have minimal effects on the scenic quality 

of this IRA. 

In the North Kupreanof IRA, approximately 86 acres of timber harvest is 

proposed. No road building is proposed. Approximately 32 acres (Unit 216) of 

harvest is proposed by single tree selection and helicopter yarding. In Units 

Alternative 1 

Alternative 2 

Alternative 3 

Central Kupreanof Record of Decision APPENDIX 3 • 15 Appendix 3
215 and 903, approximately 58 acres of harvest is proposed by clearcut 

methods and conventional yarding. Approximately 296 total acres (0.3%) of 

the IRA would be affected. 

In the South Kupreanof IRA, approximately 1,842 acres of timber harvest, 13 

miles of NFS road, and two miles of temporary road are proposed. All or 

portions of Units 218, 219, 221, 222, 223, 224, 232, 233, 234, 235, 236, 239, 

241, 243, 246, 248, 249, 250, 252, 253, 254, 257, 258, 260, 261, 262, 263, 264, 

265, 266, 267, 268, 270, 272, 274, 275, 276, 277, 279, 280, 281, 282, 284, 285, 

and 286 would be within the IRA. With the application of the 600-foot and 

1,200-foot buffers around harvest units and roads, approximately 9,789 total 

acres (4.5%) of the IRA would be affected. 

In the Rocky Pass IRA five acres of timber harvest is proposed in Unit 310 by 

clearcut methods. No road construction would occur inside the IRA boundary. 

Approximately 67 total acres (0.08%) of the IRA would be affected. 

For all inventoried roadless areas in Alternative 3, the characteristic values for 

availability as wilderness would remain unchanged. The biological value of 

old-growth forest would be reduced proportionally by the amount of timber 

harvest in each roadless area. The scenic conditions to the Rocky Pass IRA 

would only be slightly changed by timber harvest activities outside the IRA. 

Alternative 4 proposes 267 acres of timber harvest within the South Kupreanof 

IRA. With the application of the 600-foot and 1,200-foot buffers around 

harvest units and roads, total acres affected would include 25 acres (0.02%) in 

the North Kupreanof IRA, 1,544 acres (0.7%) in the South Kupreanof IRA, and 

0 acres in the Rocky Pass IRA. 

For all IRAs, the characteristic values for availability as wilderness would 

remain unchanged. No unique attributes would be affected. 

Modified Alternative 3 proposes no timber harvest or road building within the 

North Kupreanof, South Kupreanof, or Rocky Pass IRAs. However, when the 

600-foot and the 1,200-foot buffers are applied to harvest units and roads 

proposed outside and adjacent to the inventoried roadless areas, the IRAs 

would be influenced by proposed activities. Total acres affected would include 

34 acres (0.02%) in the North Kupreanof Inventoried Roadless Area, 98 acres 

(0.04%) in the South Kupreanof Inventoried Roadless Area, and 29 acres 

(0.03%) in the Rocky Pass Inventoried Roadless Area. 

For all IRAs, the characteristic values for availability as wilderness would 

remain unchanged. No unique attributes would be affected. The biological 

value of old-growth forest would not be reduced as no timber harvest would 

occur within any Inventoried Roadless Area. 

 

Alternative 4 

Modified 

Alternative 3 

16 • APPENDIX 3 Central Kupreanof Record of Decision Appendix 3
Table 3A-10. North Kupreanof Inventoried Roadless Area – 2001 Roadless Rule Inventory 

 (114,637 acres) 

Measure of Direct and Indirect Effects By 

Alternative 1 2 3 4 

Modified 

Alternative 

3 

Acres of timber harvest 0 25 86 0.24 0 

Miles of NFS roads (closed after harvest) 0 0 0 0 0 

Miles of temporary roads (decommissioned after 

harvest) 0 0 0 0 0 

Total acres affected including buffers (600' for 

harvest units, 1200' for roads)1 0 135 296 25 34 

Percent of North Kupreanof Inventoried Roadless 

Area affected 0% 0.1% 0.3% 0.02% 0.02% 

1 Helicopter Units do not receive buffers 

Table 3A-11. South Kupreanof Inventoried Roadless Area- 2001 Roadless Rule Inventory 

(216,774 acres) 

Measure of Direct and Indirect Effects By 

Alternative 1 2 3 4 

Modified 

Alternative 

3 

Acres of timber harvest 0 866 1,842 267 0 

Miles of NFS roads (closed after harvest) 0 1 13 0 0 

Miles of temporary roads (decommissioned after 

harvest) 0 0 2 0 0 

Total acres affected including buffers (600' for 

harvest units, 1200' for roads)1 0 3,922 9,789 1,544 98 

Percent of South Kupreanof Inventoried Roadless 

Area affected 0% 1.8% 4.5% 0.7% 0.04% 

1 Helicopter Units do not receive buffers 

 

Central Kupreanof Record of Decision APPENDIX 3 • 17 Appendix 3
Table 3A-12. Rocky Pass Inventoried Roadless Area- 2001 Roadless Rule Inventory (78, 148 acres) 

Measure of Direct and Indirect Effects By 

Alternative 1 2 3 4 

Modified 

Alternative 

3 

Acres of timber harvest 0 5 5 0 0 

Miles of NFS roads (would be closed after harvest) 0 0 0 0 0 

Miles of temporary roads (would be closed after 

harvest) 0 0 0 0 0 

Total acres affected including buffers (600' for 

harvest units, 1200' for roads)1 0 67 67 0 29 

Percent of Rocky Pass Inventoried Roadless Area 

affected 0% 0.08% 0.08% 0% 0.03% 

1 Helicopter Units do not receive buffers 

18 • APPENDIX 3 Central Kupreanof Record of Decision Appendix 3
Issue 3-Road Management/Access 

Road building, reconstruction and closures associated with the timber sale may 

change access within the project area. Roads influence wildlife populations, 

water quality, subsistence use, and the type of recreational opportunities 

available. Comments ranged from requesting no more new roads and closure 

of most existing roads, to requests to increase access by building new roads and 

opening more existing roads. Concerns were also expressed over the ability to 

maintain open roads due to lack of funding. 

Modified Alternative 3 will construct 1.8 miles of NFS road, reconstruct 1.0 

mile of NFS road and build about 2.3 miles of temporary road to access timber. 

All newly constructed and reconstructed NFS roads will be closed after timber 

harvest activities. Specific information regarding these roads can be found in 

Appendix 2 of this ROD. Temporary roads will be decommissioned after 

timber harvest. See Unit Cards in Appendix 1 for temporary road site-specific 

details. Road costs are expected to be about $696,700. Modified Alternative 3 

may use the Little Hamilton Bay Log Transfer Facility. 

Petersburg Ranger District Access and Travel Management 

The Decision Notice for the Petersburg Ranger District Access and Travel 

Management Environmental Assessment was signed September 11, 2009. The 

road management decisions in this ROD are consistent with the ATM decision. 

Appendix 2 in this ROD contains the road management objectives for the NFS 

roads associated with the timber harvest in the Selected Alternative. 

Central Kupreanof Record of Decision APPENDIX 3 • 19 Appendix 3
Other Resources Considered 

Wildlife 

This appendix provides up-to-date wildlife resource information since the 

printing of the FEIS. This additional information includes the run of the deer 

model and 2009 updates to the Sensitive Species List.

Deer Model 

In the Wildlife Resource Report (July 2009) analysis for the DEIS and FEIS, 

the deer model was not run. In the past, the deer model was the primary method 

used to assess the effects of planning alternatives to deer habitat capability by 

comparing them to each other; this analysis compares theoretical habitat 

carrying capability and not actual deer population numbers. The design of the 

model was developed to assess the effects of forest management over a large 

geographical area (Forest Plan level) and was not intended to be used at the 

project scale (G. DeGayner personal communication 2005). The use of the deer 

model at the project-scale was identified as a concern (Item 04-7) identified in 

the 1997 Forest Plan 5-year review and is being further refined. 

Currently, the 2008 Tongass Land and Resource Management Plan specifies to 

use the most recent version of the Interagency Habitat Capability Model, unless 

alternate analysis tools are developed. The Central Kupreanof Timber Harvest 

Environmental Impact Statement developed an alternate analysis tool to 

evaluate the effects of alternatives on winter habitat, as explained below. 

Therefore, the deer model was not run for the Central Kupreanof DEIS and 

FEIS. 

For the Central Kupreanof DEIS and FEIS, the Productive Old- growth (POG) 

analysis was used, and it utilizes the size density model (SDM) categories 

described in the Tongass National Forest Land Management Plan (USDA 

2008). Forest Service managers and planners have revised and refined forest 

mapping on the Tongass NF by creating a tree size and density mapping model 

(SDM) for POG forests (Caouette and DeGayner 2005 and 2008). This 

information is more applicable for assessing conservation of biodiversity, 

estimating timber values and developing wildlife habitat models. The Tongass 

National Forest has developed this approach (SDM) that uses tree size and 

density to model structural diversity in order to better define and describe forest 

structural attributes (Caouette and DeGayner 2005). This model has proven to 

be the best tool for representing forest structure (USDA 2008). The Central 

Kupreanof DEIS and FEIS analysis uses a quantitative approach that uses SDM 

to look at the reduction of productive old-growth (POG). POG is the habitat 

used by many animals because it provides cover and herbaceous forage. POG is 

old-growth forest capable of producing at least 20 cubic feet of wood fiber per 

acre per year or having greater than 8,000 board feet per acre. 

 

20 • APPENDIX 3 Central Kupreanof Record of Decision Appendix 3
The reduction of POG was used in this analysis to provide a way to measure 

effects to wildlife and display the amount of habitat that is no longer available 

to a suite of wildlife species. 

During the DEIS scoping period, comments were received from Alaska 

Department of Fish and Game and Green Peace requesting that we expand the 

discussion relating to deer habitat capability, including running the Forest Plan 

deer model. Sitka Conservation Society requested use of the 1997 deer model 

running on Size Density data. To accommodate this request, the deer model 

was run for each alternative; results are displayed here. 

The Forest Service realized that running the deer model would help the public 

understand the relationship between the model analysis and the newer 

alternative analysis as presented in the DEIS and the FEIS. The deer model is 

what the public is accustomed to seeing and has some utility as an index of 

effects only – not however as a means of comparing effects to absolute 

numbers of deer. It is an interim solution between final authorization to use 

newer models (i.e., Hanley, et al. 2006. Forage Resource Evaluation System for 

Habitat – Deer (FRESH-DEER) http://cervid.uaa.alaska.edu/Home.aspx.) and 

the discontinued use of the old model. In the interim the use of the Forest Plan 

description of Productive Old Growth (POG) and the SDM analysis in the 

Forest Plan, are being used for deer evaluation. SDM is a refinement of POG. 

As the Forest Service transitions to a newer, more robust and meaningful 

analytical process (the FRESH deer model), it is important for the public to be 

able to compare the old way of running the deer model. 

The deer model uses four discrete variables (four levels of snow depth, three 

elevation zones, four aspects, and seven vegetation/successional stages) and the 

following assumptions to predict a habitat suitability index (USDA 2008). 

 HSI values were standardized to range from 0 to 1.0, by dividing all 

values by 1.3, because outputs from such model represent a range from 

0 to 100 percent habitat suitability, with higher values indicating higher 

habitat capability. 

 To estimate the 1954 condition, previously harvested stands were 

assumed to be medium (SD4N, SD4S, SD5H categories) and high 

(SD5N, SD5S, and SD67 categories) volume forest; stands with a date 

of origin prior to 1954, were not changed. 

 This analysis evaluated relative changes in habitat capability; actual 

habitat capability may be more or less than model predictions. 

Consistent with the approach taken in the 2008 Forest Plan, direct effects to 

deer habitat capability are assessed on NFS lands only; non-NFS lands are not 

included in the analysis (Table A3-13). The output is intended to represent 

effects to habitat capability on NFS lands only within each WAA and is not 

intended to applied at the scale of the WAA across all ownerships. Included in 

this approach are those WAAs within the project area (WAAs 5133, 5130 and 

5131). 

Central Kupreanof Record of Decision APPENDIX 3 • 21 Appendix 3
For cumulative effects on deer habitat capability, the deer model was run two 

ways: 1) including acres on all land ownerships (NFS and non-NFS) (Table 

A3-14); and 2) NFS lands only as in the 2008 Forest Plan (Table A3-13). 

Included in these approaches are those WAAs located on Kupreanof Island and 

Kuiu Island (WAAs 5012, 5013, 5018) Rocky Pass/Keku Strait is a narrow 

body of water that separates Kupreanof Island and Kuiu Island. This body of 

water does not impede large animals such as deer, wolves and bear between 

island groups and it is adjacent to the Central Kupreanof Project Area so it was 

included in the analysis. 

Table A3-13. Winter Habitat Capability for Sitka black-tailed Deer on only NFS Lands in 

Wildlife Analysis Areas (WAAs) 5130, 5131 and 5133 based on Deer Model 

Results.1 Alternatives 1-4 and Modified Alternative 3 also shows Percent Change 

from the Existing Condition. 

Analysis 

Area 

2008 

Condition 

Calculated 2

Forest 

Plan 2008 

Condition 

Forest Plan Alt. 

6 end of rotation 

(After 100+ 

Years) 

Alt. 1 Alt. 2 Alt. 3 Alt. 4 Modified 

Alt. 3 

WAA 

5130 19.6 19.1 17.0 

19.6 

(0%) 

19.5 

(0.5%) 

19.5 

(0.5%) 

19.6 

(0%) 

19.5 

(0.5%) 

WAA 

5131 17.4 17.0 15.6 

17.4 

(0%) 

17.2 

(1.1%) 

17.1 

(1.7%) 

17.2 

(1.1%) 

17.3 

(0.6%) 

WAA 

5133 17.7 16.6 14.4 

17.7 

(0%) 

17.6 

(0.6%) 

17.5 

(1.1%) 

17.7 

(0%) 

17.7 

(0%)

1 Deer Model results are expressed as habitat capability with higher values indicating higher habitat capability. Deer Model results are 

rounded to the nearest tenth. Model results are typically expressed as whole number of deer. 2

The numbers calculated for the 2008 condition are different from the 2008 Forest Plan because there are inherent rounding errors 

associated with the process. The Forest Plan was run using 2006 as the current condition year and this project was run using 2010 as the 

current condition year. The acres that were harvested between these time intervals changes the results slightly and explains the difference 

in numbers. 

 

The results displayed above in Table A3-13 are not an actual population 

number but a theoretical long-term carrying capacity for the habitat in the 

Analysis Area (Wildlife Analysis Areas 5130, 5131 and 5133) and under 

normal winter conditions. Deer model results are typically rounded to the 

whole number; this is due to the low precision of the model. However, the 

table displays the model outputs to one decimal point so the difference between 

the No Action Alternative and the action alternatives are more clearly stated. 

These numbers, however, are not statistically different. The model shows 

Alternative 3 as having the greatest reduction in approximate habitat capability 

in all three WAAs, followed closely by Alternative 2, then Alternative 4 with 

Modified Alternative 3 providing the least impact. The Forest Plan Standards 

and Guidelines state: provide where possible, sufficient deer habitat capability 

22 • APPENDIX 3 Central Kupreanof Record of Decision Appendix 3
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 biogeographic provinces where deer are the 

primary prey of wolves. The numbers generated by the Deer Model are 

calculated at the WAA level. The results displayed from the model show there 

is not an appreciable difference in model output numbers as compared to the 

No Action Alternative (Alt. 1). 

The Deer Model results indicate there is less than a 0.4 difference for all action 

alternatives including Modified Alt. 3. The relative results of this model are 

consistent with the POG analysis used for deer in the FEIS in that they show a 

fraction of a percent difference in the effects of the action alternatives on deer 

habitat. The results presented in the model are consistent with the Wildlife 

Productive Old Growth Analysis (Central Kupreanof FEIS page 3-88 Table 3-

20). The model results and Productive Old Growth Analysis both show a small 

difference between alternatives. The Productive Old Growth Analysis shows a 

small reduction in habitat between the alternatives and the model results show 

no statistical difference in habitat capability expressed as an output of the 

model. The results of the model do not change the effects analyzed in the 

Productive Old Growth Analysis and are still within the range of what the 

public reviewed and commented on in the DEIS. 

A summary of deer model results for cumulative effects are displayed in Table 

A3-14 (private lands included) and Table A3-15 (only NFS lands). 

 

Central Kupreanof Record of Decision APPENDIX 3 • 23 Appendix 3
Table A3-14. Winter Habitat Capability for Sitka black-tailed Deer within 

WAAs 5012, 5013, 5018, 5132, 5131, 5130 and 5133 based on 

Deer Model Results for Cumulative Effect including Non-NFS 

Lands1, 2

Analysis Area 

1954 Deer 

Density as 

Determined 

in the 1997 

Forest Plan3

Alt. 1 

and 

2008 

Current 

Condition4

Alt. 2 Alt. 3 Alt. 4 Modified Alt. 

3 

WAA 5012 33 19.7 

(0%) 

19.7 

(0%) 

19.7 

(0%) 

19.7 

(0%) 

19.7 

(0%) 

WAA 5013 30 23.6 

(0%) 

23.6 

(0%) 

23.6 

(0%) 

23.6 

(0%) 

23.6 

(0%) 

WAA 5018 10.74 19.3 

(0%) 

19.3 

(0%) 

19.3 

(0%) 

19.3 

(0%) 

19.3 

(0%) 

WAA 5132 10.1 6.3 

(0%) 

6.3 

(0%) 

6.3 

(0%) 

6.3 

(0%) 

6.3 

(0%) 

WAA 5130 

26.6 19.0 

(0%) 

18.9 

(0.5%) 

18.9 

(0.5%) 

19.0 

(0%) 

19.0 

(0%) 

WAA 5131 

21.0 16.7 

(0%) 

16.5 

(1.2%) 

16.5 

(1.2%) 

16.6 

(0.6%) 

16.5 

(1.2%) 

WAA 5133 

18.6 16.5 

(0%) 

16.4 

(0.6%) 

16.3 

(1.2%) 

16.5 

(0%) 

16.5 

(0%) 

1 Deer Model results are expressed as habitat capability with higher values indicating higher habitat capability. 

Deer Model results are rounded to the nearest tenth. Model results are typically expressed as whole number of 

deer as deer/mi2. 

2When private lands occur in the WAA they are set equal to zero (e.g., assigned zero habitat capability) and 

included to calculate total area (miles2), which is used to calculate deer/mi2 for the entire WAA, across all 

ownerships. 

3

The 1954 condition is taken from unpublished Appendices to the 1997 FEIS Appendix N. Densities are shown 

for combined federal and non-federal lands that are less than 1500 feet in elevation representing deer winter 

range. Densities represent deer habitat capability from federal lands only and conservatively assume no deer 

production from non-federal lands (USDA 1997). 

4 It is unclear why the 2008 current condition and model outputs are larger than the 1954 condition as it is 

calculated in the1997 Forest Plan. The Forest Plan 2008 condition is consistent with the 2008 Forest Plan 

Revision. 

24 • APPENDIX 3 Central Kupreanof Record of Decision Appendix 3
Table A3-15. Winter Habitat Capability for Sitka Black-tailed Deer within WAAs 5012, 

5013, 5018, 5132, 5131, 5130 and 5133 based on Deer Model Results for 

Cumulative Effects on NFS Lands1, 2

Analysis Area 

NFS Lands 

Only 

1954 Deer 

Density as 

Determined 

in the 2008 

FP2

Forest Plan 

2008 

Condition 

Forest 

Plan 

Alt. 6 

end of 

rotation 

Alt. 1 Alt. 2 Alt. 3 Alt. 4 Modified 

Alt. 3 

WAA 5012 

27.7 20.9 16.2 20.2 

(0%) 

20.2 

(0%) 

20.2 

(0%) 

20.2 

(0%) 

20.2 

(0%) 

WAA 5013 

25.2 23.8 21.2 23.6 

(0%) 

23.6 

(0%) 

23.6 

(0%) 

23.6 

(0%) 

23.6 

(0%) 

WAA 5018 

21.2 19.7 17.1 19.3 

(0%) 

19.3 

(0%) 

19.3 

(0%) 

19.3 

(0%) 

19.3 

(0%) 

WAA 5132 

20.2 14.7 13.5 14.5 

(0%) 

14.5 

(0%) 

14.5 

(0%) 

14.5 

(0%) 

14.5 

(0%) 

WAA 5130 

19.5 19.1 17.0 19.0 

(0%) 

18.9 

(0.5) 

18.9 

(0.5) 

19.0 

(0%) 

19.0 

(0%) 

WAA 5131 

19.0 17.0 15.6 16.7 

(0%) 

16.5 

(1.2%) 

16.5 

(1.2%) 

16.6 

(0.6%) 

16.5 

(1.2%) 

WAA 5133 

16.9 16.6 14.4 16.5 

(0%) 

16.4 

(0.6%) 

16.3 

(1.2%) 

16.5 

(0%) 

16.5 

(0%) 

1 Deer Model results are expressed as habitat capability with higher values indicating higher habitat capability. Deer Model results 

are rounded to the nearest tenth. Model results are typically expressed as whole number of deer expressed as deer/mi2. Zero values 

were used to calculate total area (miles2) for cumulative effects. 

2

The 1954 condition is taken from unpublished Appendices to the 1997 FEIS Appendix N. Densities are shown for combined 

federal and non-federal lands that are less than 1500 feet in elevation representing deer winter range. Densities represent deer 

habitat capability from federal lands only and conservatively assume no deer production from non-federal lands. 3

The numbers calculated for the 2008 condition are different from the 2008 Forest Plan because there are inherent rounding errors 

associated with the process. The Forest Plan was run using 2006 as the current condition year and this project was run using 2010 as 

the current condition year. The acres that were harvested between this time intervals would change the results slightly and explain 

the difference in numbers. 

The goal of the standard and guideline is to provide where possible 18 

deer/mi2. Because of naturally occurring conditions some WAAs are not able 

to support 18 deer/mi2

. This is the true in WAA 5132 which was not able to 

support 18 deer/mi2

 prior to wide-scale timber harvest (i.e., 1954) (USDA FS 

1997). The 1997 Forest Plan reports WAA 5018 as also not being able to 

support 18 deer/mi2

 in 1954. However, the 2008 Forest Plan model outputs for 

Central Kupreanof Record of Decision APPENDIX 3 • 25 Appendix 3
WAA 5018 in 1954 and 2008 show it as capable of supporting 18 deer/mi2. 

The reason for this discrepancy is not known. 

The results of these model runs are consistent (they fall within the predictions 

of the current 2008 condition and the predictions of the Forest Plan Alternative 

6 at the end of rotation) with the predictions of the 2008 Forest Plan Revision, 

as well as the 1997 Forest Plan Revision. The deer model results for cumulative 

effects (including non-forest lands) is consistent with the 1997 Forest Plan 

Revision used to calculate the 1954 deer density in all WAAs in the project 

area except for WAA 5018. This WAA has a lower deer density (as calculated 

from the 1997 Forest Plan) than calculated for the 2008 condition. 

The results from Table A3-14 for the alternatives are calculated using the same 

methods as the 2008 Deer Model. The 1954 condition (deer density) is 

determined from the 1997 Forest Plan. The 1954 condition is taken from 

unpublished Appendices to the 1997 FEIS Appendix N. Densities are shown 

for combined federal and non-federal lands that are less than 1,500 feet in 

elevation representing deer winter range. Densities represent deer habitat 

capability from federal lands only and conservatively assume no deer 

production from non-federal lands. These two processes used to determine deer 

density are calculated differently using different layers and elevations but they 

are both used to approximate deer density for cumulative effects including nonNFS lands. Table A3-14 shows the same values for the current condition and 

the Alternative 1 (the No Action Alternative) for four of the WAAs (5012, 

5013, 5018, 5032) as there is no timber harvest proposed in these WAAs in this 

project. The action alternatives for WAAs 5130, 5131 and 5133 are different 

than the No Action Alternative (Alternative 1) because there is timber harvest 

planned in these WAAs. 

Species Screen 

In Table 3-19, FEIS page 3-73, the wildlife species screen analysis includes 

wildlife species from the Regional Foresters 2002 Sensitive Species List, as 

well as from the Regional Foresters 2009 Sensitive Species List. The updated 

Table A3-16 below reflects the 2009 Regional Foresters Sensitive Species List 

only. The effects are discussed in the Biological Evaluation dated July 2, 2009. 

Three sensitive species, trumpeter swan, American osprey and Peale’s 

Peregrine falcon, were removed from the table. 

26 • APPENDIX 3 Central Kupreanof Record of Decision Appendix 3
Table A3-16. Species Screen Analysis 

Species Probability of 

Occurrence 

Potential for 

Measurable Effects 

to Habitat in 

Analysis Area? 

Need for Further 

Analysis? 

Sensitive 

Kittlitz’s murrelet 

(Brachyramphus brevirostris) Low No No* 

Aleutian Tern 

(Sterna aleutica) Low No No* 

Queen Charlotte goshawk 

(Accipiter gentilis laigni) High Yes Yes* 

Black oystercatcher 

(Haematopus bachmani) Mod No No* 

*See Biological Evaluation for further analysis 

Table 3-19 of the FEIS addresses the species screen analysis by rating the 

probability of occurrence, the potential for measurable effects to habitat in the 

analysis area and the need for further analysis. The Peale’s peregrine falcon, 

trumpeter swan, American osprey were deleted from the species screen. The, 

Kittlitz’s murrelet, yellow-billed loon, Aleutian Tern, Black Oystercatcher and 

may occur in the project area but the potential for measurable effects to the 

habitat in the analysis area is very low. The Queen Charlotte goshawks have a 

moderate to high probability of occurring in the project area and have a 

potential for measurable effects to habitat in the analysis area. For more 

information about these species refer to the Biological Evaluation in Appendix 

E of the FEIS.

Productive Old Growth Analysis 

This alternative will directly affect approximately 1,265 acres of POG. This 

does not include an additional 64 acres of harvest of habitat considered by the 

SDM as non-POG. The alternative will directly affect 1,265 acres of POG out 

of 57,628 acres of POG within the project area. The area displayed in this 

project area analysis is different than the area displayed by other resources 

because this analysis used SDM and the other resources used volume strata. 

These numbers are different because volume strata define some area as POG 

where SDM considers some of this habitat as non-forested. The SDM layer is 

not run from the same macro as volume strata. These are two different layers 

that are similar but classify habitat differently. This would be about 2.2 percent 

of the project area POG and 0.4 percent of the available POG in the 

biogeographic province. The 2.2 percent reduction of POG habitat may have an 

effect on individuals but will not affect wildlife populations. The remaining 

97.8 percent of the project area would remain unaffected by proposed activities. 

 

Effects to POG 

for Modified 

Alternative 3 

Central Kupreanof Record of Decision APPENDIX 3 • 27 Appendix 3
Part of this remaining habitat is made up of non-developmental LUDs 

including riparian corridors, beach fringe, the matrix, as well as areas of partial 

harvest that can be used as wildlife habitat. 

Table A3-17. Changes in POG for Modified Alternative 3 

(FEIS Table 3-20) 

Alt. 1 Alt. 2 Alt. 3 Alt. 4 Mod. Alt. 

3 

Acres of POG Habitat harvested 0 2,427 3,568 1,261 1,265 

Percent change from current 

condition within project area 

(57,628 acres of POG) 

0% 4.2% 6.2% 2.2% 2.2% 

Percent change from current 

condition (2008) within WAA 

(269,593 acres of POG) 

0% 0.9% 1.3% 0.5% 0.5% 

Percent change from current 

condition (2008) within 

biogeographic province 

(307,710 acres of POG) 

0% 0.8% 1.2% 0.4% 0.4% 

Modified Alternative 3 has an open road density of 0.28 mi/mi2 in the project 

area. The total road density for the project area is 0.34 mi/mi2

 and the total road 

density for Kupreanof Island Is 0.23 mi/mi2. 

Table A3-18. Road Densities within the Project Area 

Road densities 

(mi/mi2) Alt. 1 Alt. 2 Alt. 3 Alt. 4 Mod. Alt 3 

Project Area Open 

Road 0.27 0.31 0.41 0.28 0.28 

Project Area Total 

Road 0.33 0.36 0.44 0.33 0.34 

Kupreanof Island 

Total Road * 0.22 0.23 0.25 0.22 0.23 

* Includes cumulative road densities

Cumulative Effects 

Biogeographic Province 

There will be a cumulative reduction of approximately 29.4 percent of POG 

with Modified Alternative 3 in all land ownerships and a reduction of 11.4 

percent of POG on Forest Service lands (since 1954) within the biogeographic 

province considering these action alternatives. This reduction of POG will 

reduce habitat capability for a range of wildlife species but is well within the 

predictions of habitat loss generated by the Forest Plan (FEIS pg 3-178). In 

Modified Alternative 3 there will be 70.6 percent of POG in the biogeographic 

Effects to Road 

Density for 

Modified 

Alternative 3 

Effects for 

Modified 

Alternative 3 

28 • APPENDIX 3 Central Kupreanof Record of Decision Appendix 3
province remaining considering all lands in the biogeographic province as well 

as 88.6 percent of POG remaining on Forest Service Lands. The POG 

remaining includes 44.8 percent of the province in non-development LUDs. 

This includes 14.1 percent of the province in Old-growth reserves (OGRs) that 

is part of the conservation strategy. Non-developmental LUDs include riparian 

corridors, beach fringe, the matrix as well as areas of partial harvest that can be 

used as wildlife habitat. 

Multiple WAAs 

There will be a cumulative reduction of approximately 26.5 percent of POG in 

all land ownerships within the WAAs (5012, 5013, 5018, 5132, 5131, 5130 and 

5133) considering these action alternatives. This reduction in habitat may affect 

individual animals but will not affect populations. This reduction of POG will 

reduce habitat capability for a range of wildlife species. In Modified 

Alternative 3 there will be 73.5 percent of POG in the WAAs remaining 

considering all lands in the WAAs. The POG remaining includes 46.8 percent 

of the WAAs in non-development LUDs this includes 11 percent of the 

province in OGRs that is part of the conservation strategy that provides for 

species conservation at the population level. Non-developmental LUDs include 

riparian corridors, beach fringe, the matrix as well as areas of partial harvest 

that can be used as wildlife habitat. 

Table A3-19. Cumulative Reduction of POG within the Biogeographic Province 

Current 

Condition Alt. 1 Alt. 2 Alt. 3 Alt. 4 Mod. Alt. 3 

Percent Reduction From 

Historic/Original 

Condition Biogeographic 

Province 

(431,217 acres of POG)* 

-28% -29% -29.8% -30.2% -29.4% -29.4% 

Percent Reduction From 

Historic/Original 

Condition WAA 

(359,445 acres of POG) 

-25% -26% -26.9% 27.3% 26.5% -26.5% 

* These numbers are lands of all ownership in the biogeographic province. The cumulative harvest on Forest Service 

lands ranges from 11% - 12.2% and is within the prediction of the Forest Plan. 

Conclusion 

In comparison to all Action Alternatives Modified Alternative 3 would remove 

the second lowest amount of POG from the area. Modified Alternative 3 would 

remove approximately 1.4 percent of POG habitat in the biogeographic 

province and 1.5 percent of the POG habitat in the WAA. This is not 

considered a significant impact to POG (wildlife habitat). Cumulative impacts 

would be slightly higher due to the amount of harvest on other Forest Service 

and non-Forest Service Lands. 

Effects for 

Modified 

Alternative 3 

Central Kupreanof Record of Decision APPENDIX 3 • 29 Appendix 3
Hydrology/Fisheries 

Cumulative Watershed Effects 

(FEIS pg 3-124) 

The effects of Modified Alternative 3 on aquatic resources were reviewed and 

summarized below and in the ROD, Table R-1 and Table A3-20. This summary 

does not represent “new” analysis, as all activities proposed in Modified 

Alternative 3 were analyzed in the Aquatics Resource Report and Chapter 3 of 

the Central Kupreanof Timber Sale FEIS. Table A3-20 reflects updated 

numbers based on the harvest units and associated road construction chosen for 

Modified Alternative 3, as well as an updated implementation date. 

Generally, effects to aquatic resources would be greater than those in 

Alternatives 1 and 4, and less than those in Alternatives 2 and 3 due primarily 

to relative amounts of proposed road miles and subsequent number of stream 

crossings, as well as total number of harvest acres. 

Thirty year cumulative harvest levels have remained the same or decreased 

from those in the FEIS. The cumulative harvest percentages in the FEIS table 

assume all proposed acres are harvested and a 2009 implementation date. The 

updated numbers also assume all proposed acres will be harvested, but reflect a 

2011 implementation date. 

Proposed harvest levels in all watersheds are lower with Modified Alternative 3 

than all other action alternatives. Direct, indirect, and cumulative watershed 

effects were analyzed by quantifying previous and future harvest levels in 

project area watersheds (assuming a 30 year timeframe for total hydrologic 

recovery), dominant sediment transport regimes of streams (e.g. transport, 

depositional), amount and location of high hazard soils within each watershed 

and proposed harvest units, number of existing and new stream/road crossings, 

and density and location of existing and proposed roads. 

Appendix C of the FEIS was reviewed and all foreseeable activities in the 

affected watersheds were considered during cumulative effects analysis. 

Additional impacts from foreseeable activities related to harvest, roads, and 

stream crossings result in no or negligible increases in effects on water yield, 

water quality, and fish habitat. These effects are discussed in the Aquatics 

Resource Report located in the project record. 

Cumulative watershed effects are minimized in Modified Alternative 3, which 

proposes no harvest in four of the seven watersheds analyzed for the FEIS. 

Modified Alternative 3 will increase cumulative harvest levels in the Hamilton 

Creek and Big John watersheds, which may result in increased water yield and 

sediment delivery to streams. However, trends in 30-year cumulative harvest 

levels are declining in all watersheds due to the ongoing re-growth of trees 

harvested over a period of decades. The resulting trend is toward hydrologic 

30 • APPENDIX 3 Central Kupreanof Record of Decision Appendix 3
recovery and improving condition in all project area watersheds. For example, 

30-year cumulative harvest levels in the McNaughton Point watershed have 

decreased even though 465 acres are proposed for harvest in Modified 

Alternative 3. This reflects continued hydrologic recovery in the watershed, 

with 590 acres harvested in 1980 no longer included in the 30-year cumulative 

harvest calculation. If Modified Alternative 3 was implemented in 2011, 30-

year cumulative harvest levels in all watersheds would remain less than eight 

percent, and by 2021 would be less than five percent. 

Total number of stream crossings, as well as those on Class I and Class II 

streams is greater than in Alternatives 1 and 4, and less than Alternatives 2 and 

3 (Table A3-20). This reflects new NFS and temporary road building 

associated with the harvest units chosen in Modified Alternative 3. Currently, 

an estimated 63 red pipes exist on Forest Service Roads that will remain open 

following the implementation of the Petersburg Ranger District Access Travel 

Management Plan. These culverts will be prioritized for replacement based on 

site specific habitat assessment. Cumulative effects of roads and closures 

associated with the Petersburg ATM are discussed in the Aquatics Resource 

Report located in the project record. 

Table A3-20. Effects on Hydrology/Fisheries 

30 year Cumulative Harvest Percentage by Alternative 

(Assuming a 2011 implementation date and that all proposed acres are harvested) 

ALT. 11 ALT. 2 ALT. 3 ALT. 4 

Modified 

Alternative 3 

Hamilton Creek 1.9% 4.0% 4.1% 3.2% 3.5% 

McNaughton Point 2.9% 7.8% 8.6% 5.9% 7.4% 

Big John Creek 4.5% 6.8% 7.1% 5.8% 5.2% 

West Duncan Canal 0.4% 1.3% 2.5% 0.6% 0.4% 

Keku Creek 0.2% 0.4% 0.4% 0.2% 0.2% 

Castle River 1.3% 1.5% 2.7% 1.5% 1.3% 

Tunehean Creek 1.2% 1.9% 1.9% 1.5% 1.2% 

 

Central Kupreanof Record of Decision APPENDIX 3 • 31 Appendix 3
Table A3-20. Effects on Hydrology/Fisheries (continued) 

Total Number of Proposed Stream Crossings by Alternative 

Alt. 1 Alt. 2 Alt. 3 Alt. 4 Modified 

Alternative 3 

Hamilton Creek 0 22 31 2 5 

McNaughton Point 0 14 14 1 7 

Big John Creek 0 6 13 1 1 

West Duncan Canal 0 5 43 0 0 

Keku Creek 0 4 4 0 0 

Castle River 0 4 29 4 0 

Tunehean Creek 0 4 5 0 0 

Total 0 59 139 8 13 

Total Number of New Class I Crossings 0 4 4 0 1 

Total Number of New Class II 

Crossings 0 5 12 4 1 

1 Values indicated under Alternative 1 reflect cumulative percentages in 2011 assuming no timber harvest.

32 • APPENDIX 3 Central Kupreanof Record of Decision Appendix 3
Reasons for Scheduling the 

Environmental Analysis of the Central 

Kupreanof Timber Harvest 

Appendix A of the FEIS 

This section updates Appendix A of the Central Kupreanof FEIS (Volume B). 

All sections included here have been updated or added to include current 

agency direction as of October 2010. For the complete Appendix A, please 

refer to the FEIS. 

How Does the Forest Service Decide where 

Timber Sale Projects should be Located? How 

Does the Central Kupreanof Timber Harvest 

Project Fit into the Tongass Timber Sale 

Program? 

(Updates FEIS pg A-1) 

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 amount of 

volume considered for harvest under the Modified Alternative 3 for the 

decision on the Central Kupreanof Timber Harvest FEIS would be 26.3 

MMBF, with harvest potentially beginning in 2011. This volume would 

contribute to the Tongass timber sale program. A no-action alternative was 

also analyzed in the FEIS. If an action alternative is selected in the decision for 

this project, this volume will be added to the volume available for sale. 

Why is This Project Occurring in This Location? 

(Updates FEIS pgs A-2 through A-3)

Areas are selected for environmental analysis for timber harvest projects for a 

variety of reasons. The reason this project was considered in this area include:

 The Central Kupreanof project will implement the new USDA 

objectives associated with the Transition Framework for Southeast 

Alaska and provide economic opportunities to the community of Kake. 

 The project area offers economic timber that currently meets local 

demand, while transitioning to a viable timber economy. 

 The project area contains many stewardship contracting opportunities 

for the nearby community of Kake. 

Central Kupreanof Record of Decision APPENDIX 3 • 33 Appendix 3
 The Central Kupreanof Timber Harvest 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 seek to provide a supply of timber from the 

Tongass National Forest which (1) meets the annual market demand 

from such forest, and (2) meets the market demand from such forest for 

each planning cycle, pursuant to Section 101 of the Tongass Timber 

Reform Act (TTRA). The WAAs within this project area have had low 

levels of past harvest.

 The Central Kupreanof Timber Harvest will use many existing roads to 

provide access to many of the proposed timber harvest units, and to 

transport harvested logs. 

 The Central Kupreanof Timber Harvest project will use the existing and 

currently permitted LTF at Little Hamilton Bay. 

 The proposed harvest units are within the Timber Production land use 

designation as allocated by the Forest Plan.

 The Central Kupreanof Timber Harvest project area is completely 

within Phase 1 lands as identified by the Timber Adaptive Management 

Strategy in the 2008 Forest Plan Record of Decision. 

 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 be consistent with 

the direction in the Forest Plan. 

Tongass National Forest Land and Resource 

Management Plan (Forest Plan as amended) 

(Updates FEIS pgs` A-4 and A-5 to include 2009 and 2010 harvest levels) 

The Tongass Land Management Plan was completed in 1979 and revised in 

1997. The Record of Decision (ROD) for the 2008 Tongass Land Management 

Plan Amendment (Forest Plan) 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 

2008 Forest Plan defines appropriate activities within each of 19 land use 

designations (LUDs). Approximately 79 percent of the Tongass was allocated 

to LUDs where scheduled commercial timber harvest is not allowed. 

 

34 • APPENDIX 3 Central Kupreanof Record of Decision Appendix 3
The decision for the 2008 Forest Plan establishes the annual average allowable 

sale quantity (ASQ, the maximum amount of timber that may be offered for 

sale) 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 sale volume, in effect the ASQ also limits the 

amount of timber that may be harvested on the Tongass National Forest.

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 A3-1). Thus, the effects on 

resources are expected to be less than projected in the 2008 Final EIS for the 

Forest Plan Amendment.

Figure A3-1 

Tongass Timber Harvest, Fiscal Years 2001-2010

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 this project as being in Category 3, which requires the 

project to be based on the Forst Plan as amended in 2008 and be consistent with 

all applicable management direction.

Roadless Area Conservation Rule 

(Updates FEIS pg A-6 with 2010 information) 

The Roadless Area Conservation Final Rule, which prohibits road building and 

logging within national forest inventoried roadless areas, was issued in 2001. 

The 2001 Roadless Rule has been - and remains - the subject of a number of 

lawsuits. Currently there are conflicting 9th and 10th Circuit Court opinions on 

the 2001 Roadless Rule. To ensure the USFS does not violate either of these 

Circuit Court opinions and to assure the careful evaluation of actions in 

47.8

33.8

50.8 46.0 49.6 43.1

18.7

28 28.0

36

0

10

20

30

40

50

60

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010

Timber Harvest - mmbf per year

Central Kupreanof Record of Decision APPENDIX 3 • 35 Appendix 3
Inventoried Roadless Areas (IRAs) on National Forest lands, the Secretary of 

Agriculture issued several memos (1042-154, 1042-155, re-delegation of 

authority) reserving his authority to approve certain projects involving road 

construction and/or reconstruction and timber harvest on lands included in the 

2001 Roadless Rule Inventoried Roadless Areas. Such activities; however, 

may occur on the Tongass where allowed by the 2008 Forest Plan. 

An analysis of the effects to roadless areas within the project area has been 

included as part of the analysis for this project. This project is consistent with 

agency policy and procedures and has been designed to meet the management 

direction, goals and objectives, and standards and guidelines in the Forest Plan. 

Transition Framework 

(Addition to FEIS Pg. A-6) 

The USDA is developing a "Transition Framework" program to help Southeast 

Alaska Communities transition to a diverse economy with jobs in renewable 

energy, forest restoration, timber and other sectors. The Alaska Region 

believes the transition can be made without entering into roadless areas (USDA 

2010). The "Transition Framework" supports the USDA Strategic Plan for 

FY 2010-2015 , and is strongly aligned with Pillar 5 in the Strategic Plan, 

namely "Generate and Retain Green Jobs and Economic Benefits through 

Natural Resource and Recreation (USDA 2005).” 

The Transition Framework will help Southeast Alaska communities transition 

to a diversified economy by providing jobs associated with renewable energy, 

forest restoration, fisheries, mariculture, tourism, recreation, multi-year 

stewardship contracts, and young growth management. This project 

incorporates viable timber opportunities, forest restoration projects, and 

recreation enhancement projects providing the opportunity to pursue 

implementing these projects through stewardship contracts. 

The annual market demand forecast is a methodology used to set the short-term 

goals for the Tongass timber sale program, volume the Forest plans to offer for 

sale in the current year pending sufficient funding.

Annual Market Demand 

(FEIS pg A-9 updated with 2010 information) 

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.

36 • APPENDIX 3 Central Kupreanof Record of Decision Appendix 3
 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 levels drop below expectations and other factors 

remain constant, future timber sale offerings would also be reduced to levels 

needed to maintain the target level of volume under contract. Conversely, if 

harvest levels rise unexpectedly, future timber sale targets would also 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 recently 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.

The planned annual timber volume offer could include a combination of new, 

previously offered, and reconfigured timber sales. Both green timber and 

salvage will be components of the 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.

Using the updated annual market demand procedures, the Forest Service has set 

a goal for volume to be offered in FY 2010 of 211 MMBF. This figure was 

calculated using the Brackley et al. 2006 “expanded lumber scenario.” Due to 

the Region 10 shipment policy and the success of Alaska producers in niche or 

specially markets, Brackley et al 2008 determined that demand for National 

Forest timber in Alaska is on a trajectory most similar to the Scenario 2 

(expanded lumber production). 

 

Central Kupreanof Record of Decision APPENDIX 3 • 37 Appendix 3
The actual volume of timber offered for sale reflects a combination 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 enjoined from being offered 

because of litigation. The spreadsheet displaying the annual demand 

calculation and a summary of the factors used in these calculations are in the 

project record.

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.

Both the “annual market demand” and the “planning cycle market demand” 

projections are important for timber sale 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 thus provide an important source 

of information for establishing the schedule of probable future sale 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 in the 2008 TLMP FEIS (USDA Forest Service 2008c).

38 • APPENDIX 3 Central Kupreanof Record of Decision Appendix 3
Table A3-21. Accomplishments in Gate System and Timber Pools (MMBF) 

Pipeline Pool Volume 2010 Goal FY 10 (as of 

September 30, 2010)

Pool 1

Volume Under Analysis

 (Gate 1 and 2) 

 3531 483

Pool 2

Volume Available for Sale 

 (Gate 3, Gate 4 and Gate 5)

102 2 563

Pool 3 

Volume Under Contract

 (Gate 6)

 235 4 985

 1The goal for volume under analysis is approximately 4.5 times the projected harvest for the current year 

( 78.5MMBF for 2010 based on expanded lumber scenario). Volume under analysis includes all timber 

volume in projects with a completed project plan (Gate 1) or a Notice of Intent through completion of the 

environmental analysis (Gate 2). This figure inlcudes about 98 mmbf of young-growth and stewardship 

projects. 2

 The goal for volume available for sale is to have at least 1.3 times the projected harvest for the 

current year (78.5MMBF) in sales that have approved NEPA and completion of timber sale preparation. 3 This is the estimated volume that is not slated for multiple small sales over a period of years. Some 

projects (73 mmbf) will have only small sales offered first and the total volume from these projects is not 

be available in any given year. This includes volume that appraises deficit to the point it can not be 

offered. This figure also includes volume under litigation – see Table A3-23. 4

 The goal for volume under contract is for purchasers to have three times the volume under contract as 

projected for harvest for the Fy 2010 (78.5 MMBF). 

5 Estimated volume under contract available for harvest estimated Spetember 2010 

How Appeals and Litigation Affect the Timber Sale 

Program 

(Updates FEIS pg A-15) 

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 and file an appeal on 

decisions. The administrative appeal process for most timber harvest projects 

takes up to 105 days before implementation to occur. 

When decisions are appealed and affirmed through the administrative appeal 

process, the project can still be litigated. Litigation can be a lengthy process. 

Although litigation does not preclude offering timber for sale, the Forest 

Service and potential purchasers are often reluctant to enter into a contract 

where the outcome is uncertain. Recently, sales were enjoined from harvest 

after the contracts were awarded. The outcome of litigation affects the Forest’s 

ability to provide a reliable timber supply. 

Central Kupreanof Record of Decision APPENDIX 3 • 39 Appendix 3
Table A3-22. Timber Volume Involved in Appeals and/or Litigation 1

Timber volume with decision reversed on appeals 2 83.0 MMBF

Timber volume involved with litigation 117 MMBF

Timber volume involved with litigation, enjoined. 8.3 MMBF 1

 As of October 2010. 

2

 Decision overturned during internal review. Does not include volume in decisions currently in the 

appeal period or undergoing an appeal review. 

 

40 • APPENDIX 3 Central Kupreanof Record of Decision Appendix 3
Response to Comments 

Appendix D of the FEIS 

All letters received during the 45-day comment period for the Draft EIS from 

Federal and State agencies, organizations, and individuals were published in 

Appendix D (Response to Comments) of the FEIS. All Interdisciplinary team 

members have reviewed the responses published in the FEIS and provided 

updated information to any comments that had become out-of-date as this 

Record of Decision was being completed. 

SCS IV-3, GP XIV-1

Concerns were expressed whether it was legal to build roads and harvest 

in Inventoried Roadless Areas under the temporary exemption from the 

2001 Roadless Rule. Due to the legal conflicts associated with the Roadless 

Rule the commenter feels that no entries should occur until the Rule is 

finalized. 

FEIS Response: 

The DEIS (p. 3-24) provides an explanation of the regulatory framework 

guiding roadless. 

On May 28, 2009 the USDA Secretary reserved decision-making authority over 

construction and reconstruction of roads and the cutting, sale or removal of 

timber in Inventoried Roadless Areas. 

The Secretary’s Memorandum 1042-154 is intended to ensure the careful 

consideration of activities in Inventoried Roadless Areas while long-term 

roadless policy is developed. The effects on the Roadless Areas are described 

in the Final EIS. 

Update: 

Recent national direction concerning Inventoried Roadless Areas (IRAs) 

reserves to the Secretary of Agriculture the decision making authority over the 

construction and reconstruction or roads and the cutting, sale, and removal of 

timber in IRAs as included in the 2001 Roadless Rule. To address concerns 

over timber harvest and road construction activities in designated IRAs, 

Modified Alternative 3 was created by removing all units and associated road 

building activities falling completely within an IRA as delineated by the 2001 

Roadless Rule. 

SCS IV-1

The DEIS should analyze economic costs and benefits specific to the 

Roadless Area as timber harvested from Roadless Areas greatly increase 

logging costs. 

Central Kupreanof Record of Decision APPENDIX 3 • 41 Appendix 3
FEIS Response: 

As stated, when timber is harvested in roadless areas, generally more roads 

need to be built adding to the costs of the timber sale. However, this is true 

whenever new roads are needed, even in roaded areas, and the development of 

infrastructure reduces costs for future timber sales. In Chapter 2 of the DEIS, 

Table 2-1 compares the effects of the Alternatives. Under Issue 1 for Timber 

Supply and Sale Economics, it shows that the alternative with the most 

proposed road miles has the lowest indicated bid value economics associated 

with it. It contrasts against Alternative 4 which minimized new road 

construction and specifically does not build any new road in roadless. The table 

shows how the alternatives affect roadless areas as well and that can be 

compared to the economics for each alternative. 

Update:

A modification of Alternative 3 was developed in which units that are located 

in an Inventoried Roadless Area (IRA) were removed from the unit pool. 

Additionally, those units requiring extensive road building for access were 

removed from the unit pool in portions of the project area not located in an 

IRA. While removing units from IRAs improves economics as seen in Table 

A3-6 in Appendix 3 of this ROD by limiting road building, there is also a 

direct correlation to improved economics by a decrease in log haul distances as 

compared to greater log haul distances from the project area that remain in 

IRAs. The Central Kupreanof project area does contain units located in IRAs 

that are directly adjacent to an existing and open road system. While these units 

have increased log haul distances, volume from these units could be offered as 

a small sale or Microsale opportunity where local haul to small mills located 

within the community of Kake could offset the higher logging cost associated 

with longer haul time. 

AFA-3

Commenter believes that the discussion of forest products employments 

does not adequately describe the “massive decline” in industry 

employment. 

FEIS Response: 

The discussion of forest products industry employment on page 3-11 of the 

DEIS is intended to provide an overview of recent trends. It is not intended to 

illustrate the full extent of the reduction in wood products employment that has 

occurred since it peaked in 1990. The Purpose and Need for the Central 

Kupreanof EIS tier to the Tongass Land and Resource Management Plan FEIS 

(January 2008) which provides a more detailed discussion of the wood products 

industry including employment data from 1986 to 2006 (Figure 3.22-6). 

Update: 

Employment data had been updated and includes data from 2002-2009 (Table 

A3-1 Appendix 3 of the ROD). Data collected from this period demonstrates a 

decline in total timber industry employment figures. 

42 • APPENDIX 3 Central Kupreanof Record of Decision Appendix 3
State EC-1, GPII-1, SCS III-4 

Commenter does not agree with using the Wrangell mill as an appraisal 

point. 

FEIS Response: 

An appraisal point is the most advantageous location where raw materials or 

products can be sold (FSH 2409.18, 45.11). The Wrangell mill was used as 

the appraisal point for the Central Kupreanof EIS since the annual market 

demand for 2007, 2008 and 2009 included the Wrangell sawmill. Silver Bay 

Logging, Inc., owner of the sawmill, was logging and processing logs at the 

mill in those years, although has not utilized any Forest Service wood in 2008 

or 2009. Instead they purchased sales from State of Alaska Mental Health 

Land that was extremely close to the mill. However, the mill capacity still 

remains at 65,000 MBF and could successfully mill a sale the size of the 

Central Kupreanof alternatives. In order to compare alternatives, the sale is 

considered as one sale although the volume may be sold in either one sale or 

multiple sales. The appraisal done prior to offering the sale for bid may be to 

the Wrangell mill or another mill depending on the size of the sale and whether 

the mill in Wrangell is operating. Since one of the values of the financial 

efficiency analysis is the relative ranking of alternatives, if another appraisal 

point is chosen, such as Klawock or Ketchikan, then all alternatives would 

decrease in value based on barging costs per MBF and show the same relative 

ranking. 

Although there are several sales available in the vicinity of the Wrangell mill, 

they do not currently represent the amount of timber volume necessary for a 

purchaser to make the investment in equipment and to obtain financial backing. 

Alcan is logging the Skipping Cow sale and began after the roads finished 

construction this season. 

Logging costs and road costs are updated with information collected annually 

from operating mills across the Tongass. This information is used to update the 

RV appraisal program and the NEAT-R program. 

Update: 

Currently the Silver Bay mill has closed and is dismantling their mill. The 

appraisal point was recalculated to Klawock where the Viking mill remains one 

of the only viable larger mills operating in the region. Though the overall 

logging cost increased substantially due to longer tow distances to the mill 

(Table A3-4 Appendix 3 of the ROD), the rankings of the alternatives for 

financial efficiency remain essentially the same. In order to compare 

alternatives, the sale is considered as one sale although the volume may be sold 

in either one sale or multiple sales. The appraisal done prior to offering the sale 

for bid may be to the Klawock mill or another mill located in the vicinity of 

Kake depending on the size of the sale. 

 

Central Kupreanof Record of Decision APPENDIX 3 • 43 Appendix 3
SCS III-1 

Commenter requested an accurate assessment of the number of jobs and 

the amount of revenue that the project will generate. 

FEIS Response: 

Approval of export or interstate shipping is only granted after the sale is 

awarded. No timber volume is ‘pre-authorized’ for export or interstate 

shipping. If a purchaser wants to export timber overseas or ship out of Alaska; 

they are required to apply for a permit from the Regional Forester. Because of 

these uncertainties of what may be exported in the future what the operator 

would want to export, an accurate estimate of jobs in not available at this time. 

Therefore, the sawmilling jobs are displayed as a range of possibilities with the 

actual number of jobs supported probably somewhere within this range. 

However, the jobs per MBF used for this estimate is based on an average from 

operators and may vary depending on who buys the sales. 

Timber sales are sold to purchasers with differing business goals under 

changing market scenarios. Historically, the percentage of the volume 

harvested on the Tongass that has been shipped out of state has fluctuated 

widely. Given those variables, it is not possible to precisely predict what will 

be manufactured locally; hence, a range of employment and income figures is 

considered the most reasonable approach to display potential effects on jobs 

and income. 

The limited interstate shipment policy described in the Draft EIS (P. 3-19) 

allows shipment of small-diameter low-grade, unprocessed western hemlock 

and Sitka spruce logs to the lower 48 states (Bschor 2007) and no more than 50 

percent of the total sale volume can either be exported or shipped to the lower 

48 states. These requests must be approved by the Regional Forester and have 

been granted in the past on a case-by-case basis. 

On August 8, 2008, the Regional Forester issued a time-limited authorization to 

export western hemlock and Sitka spruce which only applied to timber sales 

under contract as of June 30, 2008 and was not an addendum to the limited 

export policy. No more than 50 percent of the total sale volume may be 

exported or shipped to the lower 48 states. This authorization was put in place 

to offset the dramatic increase in costs, coupled with a decline in orders and 

selling values experienced by Alaska’s timber industry at that time. It is 

difficult to determine whether these conditions will exist when timber from the 

Central Kupreanof project is offered for sale. This project may be implemented 

over a period of several years; during which time fuel costs, market scenarios 

and logging costs are subject to considerable change. 

The economic analysis for the Central Kupreanof project does not include 

adjustments to selling values based on this time-limited authorization. 

The amount of export is reported on this public website: 

http://www.fs.fed.us/r10/ro/policy-reports/for_mgmt/

The actual appraised sale value will be determined at the time of sale based on 

a statistically accurate cruise and the appraisal bulletin costs and revenues at 

44 • APPENDIX 3 Central Kupreanof Record of Decision Appendix 3
that time. Many of the factors that will determine the exact amount of revenue 

will be dependent on the purchaser’s efficiency and business expertise and 

therefore not available at this time. 

Update: 

A time-limited shipment of unprocessed hemlock and Sitka spruce Logs 

approved on August 8, 2008 by the Regional Forester has been extended 

(memo File Code 2420-1-2/2430 November 10, 2009). Under direction of the 

Time Limited Export Policy, a purchaser may request approval to ship 

unprocessed timber outside of Alaska to the most advantageous markets in the 

lower 48, including foreign markets. Up to 50 percent of the total sale sawlog 

volume (sum of all species) of unprocessed hemlock and Sitka spruce logs may 

be exported. A purchaser may also continue to request a permit to export 

unprocessed cedar to domestic and foreign markets. Table A3-7 Appendix 3 of 

the ROD depicts the estimated range of direct jobs associated with the Central 

Kupreanof project area. The lower range depicted in the table assumes export 

of volume if a prospective purchaser so chooses. 

Beebe-1, SCS II-5

Discuss what the local demand is for timber from this sale area. 

Commenters feel there is not demand for this much timber, and only 

alternatives to offer small sales should have been analyzed. 

FEIS Response: 

Since 2007, five residents of Kake have expressed interest in purchasing small 

sales and Microsales from the Central Kupreanof project area. The 6367 

Timber Sale, located in close proximity to the Central Kupreanof project area, 

was offered and sold to a resident of Kake in 2008. A second small sale, as well 

as a Microsale along the Kake road system, is scheduled to be advertised in 

2009. More information regarding small sales and Microsales has been added 

to the FEIS. 

All action alternatives provide small sale and Microsale opportunities. These 

opportunities include offering a subset of units from the larger unit-pool or by 

providing Microsales through salvaging dead or down trees along said roads. 

Microsales were analyzed by each resource for each action alternative (see 

DEIS Chapter 3). The DEIS (pg 3-17) discusses opportunities for small sales. 

As documented in Appendix C (Catalog of Events) of the DEIS, examples of 

projects where a subset of units were offered as small sales include; Bohemia 

Mountain Timber Sale EIS (1991 and FSEIS 1995), and the South Lindenberg 

EIS (1996). 

Update: 

Since 2007, five residents of Kake have expressed interest in purchasing small 

sales and Microsales from the Central Kupreanof project area. The 6367 

Timber Sale #1 and #2, located in close proximity to the Central Kupreanof 

project area, were offered and sold to two residents of Kake in 2008 and 2010. 

A Microsale along the Kake road system, is scheduled to be advertised in 2010. 

Central Kupreanof Record of Decision APPENDIX 3 • 45 Appendix 3
More information regarding small sales and Microsales has been added to the 

ROD. 

GP XV-4

Build no new roads within Roadless Areas. 

FEIS Response: 

Alternative 4 builds no new roads in any inventoried roadless area as well as 

avoids harvest within their boundaries. The Tongass is currently exempt from 

the prohibition of timber harvest and building roads in inventoried roadless 

areas. While these activities would reduce roadless acres within the project 

area, the roadless values would remain unchanged or be minimally influenced 

by the proposed activities in all action alternatives. 

The effects of alternatives on roadless acres and values are disclosed on pages 

3-23 to 3-35 of the DEIS. 

Update:

Recent national direction concerning Inventoried Roadless Areas reserves to 

the Secretary of Agriculture the decision making authority over the 

construction and reconstruction or roads and the cutting, sale, and removal of 

timber in IRAs as included in the 2001 Roadless rule. To address concerns 

over timber harvest and road construction activities in designated IRAs, 

Modified Alternative 3 was created that removes all units and associated road 

building activities falling completely within an IRA as delineated by the 2001 

Roadless Rule. 

46 • APPENDIX 3 Central Kupreanof Record of Decision Appendix 3
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