Tongass National Forest

Proposed Land and Resource 

Management Plan

Final Environmental Impact 

Statement 

Plan Amendment

Volume II – Appendices

2016
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Contents

Volume II

Final EIS Appendices 

CONTENTS

APPENDIX A SCOPING AND COMMENT SUMMARY REPORT ....................................................... A-1 

APPENDIX B MODELING AND ANALYSIS ......................................................................................... B-1 

APPENDIX C CUMULATIVE EFFECTS............................................................................................... C-1 

APPENDIX D EVALUATION AND INTEGRITY OF THE TONGASS NATIONAL FOREST 

OLD-GROWTH HABITAT CONSERVATION STRATEGY............................................ D-1 

APPENDIX E INTERAGENCY OLD GROWTH RESERVE REVIEW ...................................................E-1 

APPENDIX F COMPARISON OF DIRECTION BY ALTERNATIVE..................................................... F-1 

APPENDIX G TIMBER DEMAND AND SUPPLY ................................................................................. G-1 

Final EIS iii Contents

APPENDIX I DEIS COMMENTS AND RESPONSES............................................................................ . I-1 

APPENDIX H LIMITED EXPORT POLICY........... ................................................................................. H-1 
APPENDIX A

SCOPING AND COMMENT

SUMMARY REPORT
Tongass Forest Plan Amendment

Scoping and Comment Summary Report

Tongass National Forest

Prepared by:

Tetra Tech, Inc

19803 North Creek Parkway

Bothell, Washington 98011

August 17, 2015
Tongass Forest Plan Amendment Scoping and Comment Summary Report

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TABLE OF CONTENTS

1.0 Project Summary............................................................................................................................... A-1

2.0 Background ....................................................................................................................................... A-1

3.0 Purpose and Need for Project ......................................................................................................... A-1

4.0 Proposed Action ............................................................................................................................... A-2

5.0 Opportunities for comment and Participation ............................................................................... A-2

5.1 Five-year review ............................................................................................................................A-2

5.2 Scoping Process............................................................................................................................A-3

5.3 Public Meetings .............................................................................................................................A-3

5.4 Consultation with Federally Recognized Tribal Governments and Tribal Corporations................A-3

5.5 Consultation with Other Agencies .................................................................................................A-3

5.6 Tongass Advisory Committee........................................................................................................A-4

5.7 Youth Advisory Comittee...............................................................................................................A-4

6.0 Issue Development ........................................................................................................................... A-4

6.1 Significant Issues...........................................................................................................................A-5

6.2 Other Environmental and Social Considerations...........................................................................A-7

6.3 Five-Year Review comment Summary..........................................................................................A-7

6.4 Scoping Comment Summary.........................................................................................................A-7

6.4.1 Climate Change ...................................................................................................................A-8

6.4.2 Economics............................................................................................................................A-8

6.4.3 Fish ....................................................................................................................................A-10

6.4.4 Karst...................................................................................................................................A-10

6.4.5 Lands .................................................................................................................................A-11

6.4.6 Land Use Designations......................................................................................................A-11

6.4.7 Minerals..............................................................................................................................A-12

6.4.8 Old-Growth Reserves ........................................................................................................A-12

6.4.9 Planning/Alaska National Interest Lands Conservation Act (ANILCA)..............................A-13

6.4.10 Purpose and Need ...........................................................................................................A-14

6.4.11 Plants ...............................................................................................................................A-14

6.4.12 Recreation and Tourism...................................................................................................A-14

6.4.13 Renewable Energy...........................................................................................................A-15

6.4.14 Restoration.......................................................................................................................A-16

6.4.15 Roadless Areas................................................................................................................A-16

6.4.16 Special Uses ....................................................................................................................A-18

6.4.17 Subsistence......................................................................................................................A-18

6.4.18 Timber..............................................................................................................................A-18
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6.4.19 Transportation..................................................................................................................A-19

6.4.20 Tribal Consultation ...........................................................................................................A-19

6.4.21 Water................................................................................................................................A-20

6.4.22 Wildlife..............................................................................................................................A-20

6.4.23 Young-Growth Transition.................................................................................................A-21

7.0 References....................................................................................................................................... A-23
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ACRONYMS/ABBREVIATIONS

Acronyms/Abbreviations Definition

ANILCA Alaska National Interest Lands Conservation Act

ASQ allowable sale quantity

CMAI Culmination of Mean Annual Increment

EIS Environmental Impact Statement

EPA Environmental Protection Agency

FERC Federal Energy Regulatory Commission

Forest Plan Land and Resource Management Plan

Forest Service U.S. Department of Agriculture, Forest Service 

FWS Fish and Wildlife Service

IRA inventoried roadless area

LUD Land Use Designation

MIS Management Indicator Species

NEPA National Environmental Policy Act

NFS National Forest System

NOI Notice of Intent 

OGR old-growth reserve

SOA State of Alaska

TUS Transportation and Utility System

YAC Youth Advisory Council

YG young growth
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1.0 PROJECT SUMMARY

The U.S. Department of Agriculture, Forest Service (Forest Service) is preparing an 

Environmental Impact Statement (EIS) that evaluates an amendment to the 2008 Tongass 

National Forest Land and Resource Management Plan (Forest Plan). The Record of Decision 

will consider and identify changes, if any, to the current 2008 Forest Plan.

2.0 BACKGROUND

On July 2, 2013, Secretary of Agriculture, Thomas Vilsack, issued Memorandum 1044-009, 

Addressing Sustainable Forestry in Southeast Alaska, which expressed the Secretary’s intent to

transition the Tongass National Forest (the Tongass or Forest) to a young growth–based timber 

program in 10 to 15 years, more rapidly than considered in the 2008 Forest Plan. He asked that 

the Forest Service “strongly consider whether to pursue an amendment to the Tongass Forest 

Plan. Such an amendment would evaluate which lands will be available for timber harvest, 

especially young growth timber stands, which lands should be excluded, and additional 

opportunities to promote and speed transition to young growth management.”

In order to achieve the young-growth (YG) transition goal of 10 to 15 years, the initial phase of 

the National Environmental Policy Act (NEPA) documentation has been initiated. Notice of 

Intent (NOI) to prepare an Environmental Impact Statement was originally published in the 

Federal Register on May 27, 2014. On June 23, 2016, a corrected Notice of Intent was 

published modifying the expected timeline, providing details on the objection process under 36 

CFR 219 subpart B, and identifying M. Earl Stewart as the Forest Supervisor.

In addition, the Forest Service completed a 5-year review of the Forest Plan in September 2013. 

There were a total of 257 unique comment submissions and over 152,000 form letters received 

during the comment period for the 5-year review. Many of the comments on the 5-year review 

also requested a transition to young-growth timber harvesting. All of these comments were 

taken into consideration in identifying the scope of this Forest Plan amendment. 

In January and February 2015, open houses were held in Juneau, Sitka, and Ketchikan to share 

information with the public about the progress being made on the Proposed Forest Plan 

Amendment and Draft Environmental Impact Statement, and to provide opportunity for the 

public to comment on the Draft Plan Monitoring Program. An informational newsletter was also 

published in conjunction with the open houses, providing project information and detailing how 

the public can participate.

3.0 PURPOSE AND NEED FOR PROJECT

The Purpose and Need for Action, as defined in the Notice of Intent (NOI), is:

“The Forest Service is preparing an Environmental Impact Statement (EIS) to describe the 

effects of making proposed changes to the Tongass Forest Plan to accomplish the 

transition to young growth management as provided in the Secretary's Memorandum. The 

Forest Service will evaluate which lands should be available for timber harvest, especially 

young-growth timber stands, and any proposed changes to standards and guidelines and 

other management direction to promote and speed the transition to young-growth 
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management while maintaining a viable timber industry in Southeast Alaska. It will also 

evaluate other changes suggested in the 5-year review.”

4.0 PROPOSED ACTION

The Proposed Action, as defined in the Notice of Intent (NOI), is:

“The Forest Service proposes to amend the Tongass Forest Plan, using the 2012 Planning 

Rule, as needed to accomplish the transition to young growth management over the next 

10 to 15 years while retaining the expertise and infrastructure of a viable timber industry in 

Southeast Alaska, as outlined by the Secretary in Memorandum 1044-009. The 

amendment process will address: Identifying areas suitable and not suitable for timber 

harvest to achieve the transition to young growth management; whether the Tongass 

needs to be able to harvest young growth forest stands before they reach their maximum 

rate of growth; what changes in management direction should be made to promote young 

growth management; whether the inventory of roadless areas should be updated, which 

may require additional rulemaking; whether changes are needed to provide for 

development of hydropower; updating the upper limit on the quantity of timber that may be 

sold from the Tongass to reflect other changes made; and how to modify the monitoring 

provisions of the Plan as required by the 2012 Planning Rule, including identifying focal 

species to monitor instead of management indicator species as required by the former 

planning regulations. The amendment process may address other topics relevant to 

promoting and speeding the transition to young growth management. It is not expected 

that changes made to the Tongass Forest Plan will affect the overall integrity of the Plan's 

conservation strategy.”

5.0 OPPORTUNITIES FOR COMMENT AND PARTICIPATION

5.1 FIVE-YEAR REVIEW

The Forest currently operates under the Tongass National Forest Land and Resource 

Management Forest Plan, as amended in 2008. In 2013, the Forest Service completed a 5-

year review to determine whether any actions are needed to clarify or adjust the plan. The 

Tongass solicited comments through public and stakeholders meetings, government-togovernment consultation with Southeast Alaska tribes, and written comments. Press releases, 

radio announcements, project brochures, postcards, letters posters and email notices were 

used to notify the public. Additionally, letters of invitation to participate were sent to 32 tribes in 

16 communities.

Public comments were accepted between January and June 30, 2013. Public meetings were 

hosted in February and March 2013 in the communities of Wrangell, Petersburg, Sitka, Craig, 

Ketchikan, Juneau and Haines. Additionally, Conservation Strategy Summits were hosted in 

June 2013 in the communities of Ketchikan and Juneau. Then Forest Supervisor Cole received 

input on a range of topics, including young-growth management, the Roadless Rule, watershed 

restoration, mining, renewable energy, and local economies. All of the comments received were 

taken into consideration in identifying the scope of this Forest Plan amendment. A detailed 

summary of the Five-Year Review process and comment summary is available online at: 

http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5443864.pdf (USDA Forest Service 

2013)
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In October 2013, the Forest Service announced its intent to modify the Forest Plan based on the 

conditions of the land and the demands of the public. Identification of the timber base suitable 

to support a transition to young-growth management in a way that supports the continued 

viability of the forest industry in Southeast Alaska was noted as a focus area.

5.2 SCOPING PROCESS

The NOI initiated the scoping process, which helped guide the development of the EIS. The NOI 

to prepare an environmental impact statement was published in the Federal Register on May 

27, 2014 (79 FR 30074) initiating a 30-day public scoping period. The NOI asked for public 

comment on the proposal until June 26, 2014. The Forest Service received over 116,000 letters 

and of these, about 250 letters were unique.

5.3 PUBLIC MEETINGS

In January and February 2015, open houses were held in Juneau, Sitka, and Ketchikan to share 

information with the public about the progress being made on the Proposed Forest Plan 

Amendment and Draft Environmental Impact Statement, and to provide opportunity for the 

public to comment on the Draft Plan Monitoring Program. While comments were not solicited on 

the Forest Plan Amendment during these meetings, Forest Service staff were on hand and 

materials were made available to the public to inform them on the amendment process and how 

and when to provide input. Approximately 15-20 people attended each meeting.

5.4 CONSULTATION WITH FEDERALLY RECOGNIZED TRIBAL 

GOVERNMENTS AND TRIBAL CORPORATIONS

The Forest Service invited the following tribal governments and corporations to participate as 

cooperating agencies:

• Angoon Community Association 

• Central Council Tlingit & Haida Indian 

Tribes of Alaska

• Chilkat Indian Village

• Chilkoot Indian Association

• Craig Tribal Association

• Douglas Indian Association

• Hoonah Indian Association

• Hydaburg Cooperative Association

• Organized Village of Kake

• Organized Village of Kasaan

• Ketchikan Indian Community

• Klawock Cooperative Association

• Metlakatla Indian Community

• Petersburg Indian Association

• Organized Village of Saxman

• Sitka Tribe of Alaska

• Skagway Traditional Council

• Wrangell Cooperative Association

• Yakutat Tlingit Tribe

While none of the invited tribal governments or corporations are participating as cooperating 

agencies, all will be engaged with through consultation.

5.5 CONSULTATION WITH OTHER AGENCIES

The Forest Service invited the Environmental Protection Agency (EPA), Fish and Wildlife 

Service (FWS), and the State of Alaska (SOA) to participate as cooperating agencies in the 

development of the EIS. . The FWS accepted this invitation and is participating as a cooperating 
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agency. The EPA formally declined the invitation. The EPA, FWS, and SOA submitted 

comments during the scoping comment period.

5.6 TONGASS ADVISORY COMMITTEE

As a result of both the 5-Year Review and the July memorandum from the Secretary of 

Agriculture, Memorandum 1044-009, a Federal Advisory Committee was established to provide 

advice on identifying ways to support the transition and provide for a viable forest industry in 

Southeast Alaska. The Tongass Advisory Committee (TAC) was federally chartered in 2014 to 

advise the Secretary of Agriculture on developing an ecologically, socially, and economically 

sustainable forest management strategy for the Tongass National Forest. The TAC was tasked 

with developing recommendations about how to transition within 10 to 15 years from old-growth 

to predominantly young-growth timber management in a way that is economically viable for the 

existing industry, while recognizing and balancing the other unique and equally important 

resource values of the Tongass. The TAC was comprised of fifteen members from the timber 

industry, conservation community, Native interests, State and local government, and other 

interests. The TAC provided recommendations to the Secretary of Agriculture in May 2015 and 

the Forest Service developed an alternative based on these recommendations to be included in 

the EIS.

5.7 YOUTH ADVISORY COMITTEE

The 2012 Planning Rule requires the responsible official to provide meaningful opportunities for 

public participation throughout the planning process. It gives direction for providing such 

opportunities, including for outreach. In 2014, Tongass National Forest officials reached out to 

a Ketchikan High School guidance counselor who assembled 8 students to form the Ketchikan 

High School Youth Advisory Council (YAC). Three YAC meetings were held at Ketchikan High 

School from fall 2014 through spring 2015. The objective was to involve the YAC members in 

the public participation process for the proposed Forest Plan Amendment, including having 

them actively participate in a Forest Service public open house meeting in Ketchikan. This 

meeting allowed YAC members to better understand the scope of the Forest Plan Amendment 

and the issues that were raised during the scoping process. They gathered information at each 

station, examined maps, and talked with Forest Service subject matter experts. In May 2015, 

several members of the YAC had the opportunity to meet with Forest Service staff and the 

Tongass Advisory Committee, a Federal Advisory Committee during a social event at Ward 

Lake Recreation Area where they discussed the importance of collaboration and civic 

involvement. 

For the school year 2015-2016, the YAC is comprised of 11 students, both Juniors and Seniors, 

who have demonstrated leadership tendencies, have a high grade point average, and are 

interested in understanding the scope of Forest Planning and how they can participate in the 

effort. A meeting was held on October 21, 2015 to welcome new YAC members. The goal of 

the YAC is to formulate consolidated comments on the proposed Forest Plan and associated 

DEIS during the 90-day comment period. 

6.0 ISSUE DEVELOPMENT

The Interdisciplinary Team identified the significant issues described in the following section. 

These issues consider internal scoping and comments received from federal agencies, the 

SOA, individuals, special interest groups, non-governmental organizations, businesses, and a 
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native corporation. Each comment was reviewed and considered in defining the significant 

issues, other environmental and social considerations, and other considerations for plan 

alternatives. These will guide the analysis throughout the NEPA process. Each comment was 

assigned to one or two themes (e.g., young-growth transition, or climate change) so they could 

be easily evaluation. Additionally, each comment was given one or more of the following 12 

categories relative to how the comment would be addressed (if it needed to be addressed). 

Comments received during the 5-year review were also considered:

• Addressed by Forest Plan and Forest Plan

Land Use Designations (LUD).

• Addressed through implementation of 

Forest Plan standards and guidelines and 

Best Management Practices.

• Addressed through implementation of 

project-specific planning, implementation, 

and mitigation measures.

• Addressed during processes or impact 

analyses routinely conducted by the 

Interdisciplinary Team.

• Addressed through spatial location of 

alternatives.

• Used to drive or partially drive an 

alternative.

• Beyond the scope of the project.

• Support amendment project.

• Oppose amendment project.

• Other request or comment

• Addressed by law, regulation, or 

departmental direction

• Consider recommendation for analysis

6.1 SIGNIFICANT ISSUES

The following are significant issues developed during the scoping process described above, and 

developed in consideration of the purpose and need of this EIS. These issues are used to drive 

or partially drive alternatives or will be analyzed in the greatest detail in the EIS. Section 5.2 

identifies other environmental considerations, which are not considered significant issues for 

this EIS but will also be addressed. Finally, Section 5.3 provides a summary of all comments 

received during scoping.

Issue 1 – Young-Growth Transition

Issue Statement: The Secretary of Agriculture requested the Forest Service to transition to a 

YG–based timber program on the Tongass in 10 to 15 years, more rapidly than considered in 

the 2008 Forest Plan. This transition is intended to move the Tongass National Forest to a 

more ecologically, socially, and economically sustainable forest management program and 

reduce old-growth harvest while providing economic timber to support the local forest products 

industry.

The issue concerns financial efficiency, salability, and volume of future timber sales. It also 

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

area. YG timber growth rates, sustainable harvest rates, the amount of old-growth harvest 

needed during transition to sustain the timber industry, and the locations where young-growth 

harvest would take place are some of the factors to be considered. 

Units of Measure

• Timber volume of young growth vs. old growth
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• Acres of harvest of young growth vs. old growth by harvest and logging system by 

location

• Financial efficiency of young-growth vs. old-growth harvest

• Number of annualized direct jobs supported

• Timber demand vs. amount of harvest made available to meet demand

Issue 2 – Renewable Energy

Issue Statement: The Forest Plan should promote the development of renewable energy 

projects to help Southeast Alaska communities reduce fossil energy dependence, where it is 

compatible with National Forest purposes and to ensure that the planning, construction, and 

operation of projects protect and effectively use National Forest System lands and resources. 

Management of National Forest System (NFS) lands should support the intent of the State of 

Alaska legislature to receive 50 percent of its electrical generation from renewable energy 

sources by 2025 (House Bill 306 [2010]). 

Units of Measure

• Proportion of known potential renewable energy projects potentially allowed under the 

Forest Plan

Issue 3 – Protection of Roadless Areas

Issue Statement: The protection of roadless areas (particularly high-value roadless areas)

from development and timber harvest on the Tongass is of local and national importance, 

particularly relative to wildlife and biodiversity, recreation, and tourism. Whether or not the 

Tongass will be exempt from the 2001 Roadless Rule is not clear. 

Many people believe roadless areas should be allowed to evolve naturally through their own 

dynamic processes and should be afforded protection that ensures this will occur. The Tongass 

includes very large undeveloped land areas with several portions of the Forest consisting of 

contiguous roadless areas that exceed 1 million acres and represent large, unfragmented 

blocks of wildlife habitat. This large scale of roadless lands does not exist on any other National 

Forest, except the Chugach National Forest in Southcentral Alaska.

Roadless areas are considered important because of their wildlife habitat and recreation values 

and their importance for tourism. They are also important because of the passive-use and 

ecosystem services values they provide.

Units of Measure

• Acres of inventoried roadless areas protected under each alternative

• Values of lands protected under each alternative

Issue 4 – Protection of Wildlife Habitat and the Old-growth Conservation Strategy

Issue Statement: The Tongass National Forest supports a unique and important assemblage 

of wildlife including the largest population of brown bears and breeding bald eagles in the world, 

the Alexander Archipelago Wolf, species of high importance for subsistence (e.g., Sitka blacktailed deer), an extensive array of endemic mammals, and a large number of species that are at 

least partially dependent on old-growth habitats (e.g., marten and goshawk). The Tongass Oldgrowth Conservation Strategy is considered important for the continued health of the unique 

wildlife and plant populations in Southeast Alaska. 

Timber harvest and road development can have important effects on populations of many of 

these species and the biodiversity of Southeast Alaska. Although less than 10 percent of the 

productive old-growth habitat on the Tongass has been converted to young growth, the 
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percentage is much higher for certain types of old growth, such as lowland and large-tree old 

growth. In addition, a high percentage of non-NFS lands have been harvested at a much higher 

rate. Therefore, the cumulative effects of harvest and road building on wildlife in Southeast 

Alaska are greater than the effects for the Tongass by itself.

Units of Measure

• Acres of productive old growth protected under each alternative

• Percentage of biogeographic provinces protected in reserves

• Changes in road densities

• Indicators of habitat capability using habitat models

• Cumulative harvest and road development on all Southeast Alaska lands

6.2 OTHER ENVIRONMENTAL AND SOCIAL CONSIDERATIONS

The following list of other environmental and social considerations will be analyzed in the EIS, in 

addition to the significant issues identified in the previous section.

 Air Quality

 Climate Change

 Geology, Karst, and Caves

 Soils

 Water

 Wetlands

 Fish

 Plants (including sensitive plants 

and invasive species)

 Forest Health

 Lands

 Transportation and Utilities

 Minerals

 Recreation and Tourism

 Scenery

 Subsistence

 Heritage Resources and Sacred 

Sites

 Wilderness, Wild and Scenic Rivers, 

and other special LUDs

 Economics and Social Environment

 Environmental Justice

6.3 FIVE-YEAR REVIEW COMMENT SUMMARY

During the comment period for the Five-Year review, 252 unique submissions were received, 

along with 152,182 form letters (some of which contained unique content). The range of topics, 

including young-growth management, the Roadless Rule, watershed restoration, mining, 

renewable energy, and local economies. 

The Forest Service developed 515 Statements of Concern (grouped into 24 topics) based on 

the comments. Among the comments received, some issues were raised more frequently than 

others. The five SOC Topics with the most comments received were Tongass National Forest 

management issues, timber, Land Use Designations, socioeconomics, and energy. A detailed 

summary of the Five-Year Review process and comment summary is available online at: 

http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5443864.pdf (USDA Forest Service 

2013)

6.4 SCOPING COMMENT SUMMARY

The following sections provide a summary of the scoping comments received, sorted by issue 

category. Some comments were identified as part of one or more issue categories and may be 

duplicated. This summary covers comments related to the significant issues as well as the other 

environmental and social considerations. Some comments below have been taken directly from 
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comments received while many have been summarized or paraphrased to represent several 

similar comments. All comments were considered individually. This list is not inclusive; a 

complete record of comments is available in the planning record.

6.4.1 Climate Change

Climate change was a common theme among many comments. Some commenters requested 

that climate change be identified as a significant issue. Others requested that the effects of the 

alternatives on the climate be considered, as well as the effect of climate change on every

resource. Examples of climate change comments include the following:

• EPA recommends that the Forest Plan EIS discuss the anticipated impacts associated 

with past, present, and future changes in climate throughout the forest and provides 

suggested references.

• Please treat climate change as a significant issue in the purpose and need for this 

proposed amendment. All federal agencies must manage for climate preparedness and 

resilience (Executive Order 13653) and Secretary Vilsack has recognized the Tongass’ 

global significance as a carbon-rich reserve.

• The DEIS needs to consider the critical temporal relationship between present carbon 

emissions and the future effects of climate change. The immediate release of carbon 

from logging will have significant impacts compared to the much longer-term release of 

biomass from the death and decomposition of live trees in decades or centuries.

• In addition with the carbon dioxide problem, cutting down forests only accelerates the 

climate problems. Don't make a short-term decision with long-term negative 

consequences. We have too few forests as it is.

• If we want to control global warming, we need to preserve all out healthy trees

• Analyze the effects of alternatives on carbon sequestration and long-term storage 

potential.

• The current Conservation Strategy fails to recognize the role of climate change in the 

maintenance of biodiversity. The effects of climate change must be considered if the 

Conservation Strategy is re-evaluated.

• The alternative that best optimizes carbon and other values on the Tongass is one that 

rapidly transitions out of industrial old-growth logging.

6.4.2 Economics

Many comments addressed issues or concerns related to economics. Comments concerned the 

economics associated with transition to YG management, the economics of the current timber 

program, and the economics associated with non-timber resources. Examples of economic 

comments are provided in the following subsections.

6.4.2.1 Transition Economics

• The analysis should evaluate the economic viability of YG management only, rather than 

a mix of YG and old-growth logging.

• If existing mills close, it will not be possible to maintain the economies of scale to support 

timber operations on the forest or to bring new operators into the region. Forest Service 

needs to invest in transition. 

• Transition should create local jobs and require local, value-added manufacturing.

• The outcome of any “transition” alternative should reward local, value added 

manufacturing and end existing export and transshipment policies on the Tongass. The 
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successful Tongass micro-sale program that currently exists on Prince of Wales Island 

encourages local processing and the manufacture of high value-added wood products. 

• Evaluate the economic outlook for YG forest products and analyze the need to export 

YG materials to build a YG program.

• Emphasize value-added forest product uses.

• The current appraisal system favors large operators and does not fully capture the value 

that YG timber offers the region. The system needs to be revised to encourage business 

investment and development, job growth, and value-added manufacturing in Alaska.

• All alternatives should focus on creating local timber jobs.

• Consider alternatives favoring management for deer and wildlife habitat, healthy salmon 

streams, and a local wood economy for Southeast Alaska.

6.4.2.2 Economics of Current Timber Program

• Criticism of the Tongass timber program as a market failure in which taxpayers and 

other forest users pay for below-cost timber program.

• Recent YG harvests have not been economical.

• The Forest Service is not meeting its annual timber targets and the lack of timber supply 

is responsible for decline of timber manufacturing.

• The Forest Service should update and revise its forecasts for market demand of 

Tongass timber. The economic analysis used by the Forest Service in its timber sale 

planning is inaccurate and outdated, and greatly overestimates market demand for 

Tongass timber. 

• The Forest Service must also revise its forecasts of market demand for timber, which 

have consistently proved to be much higher than actual market results. 

• As part of the Amendment process, the Tongass National Forest needs to revisit its 

methodology for estimating market demand and its series of market demand scenarios, 

because they overestimate actual demand.

• For YG, the Forest Service needs to move away from using export based criteria. In this 

land management plan, the Forest Service needs to analyze what markets for Tongass 

timber they are “seeking to meet.”

• Stop systematically overestimating timber demand.

• Stewardship contracts to not recoup actual cumulative effects and opportunities lost.

6.4.2.3 Non-timber Economics and Competition with Timber Program

• The DEIS should evaluate how Forest Plan Amendment implementation will impose real 

costs, monetary and otherwise, on non-timber forest values and give these values equal 

consideration. 

• The DEIS needs to consider all non-timber-related economics and number of jobs 

supported by forested habitat including: recreation, tourism, hunting, fishing and 

subsistence. 

• Stop giving timber a preference over other Tongass multiple uses by systematically 

overestimating market demand. 

• Support tourism and fishing in place of logging old growth.

• The Forest Service should support local communities by seeking ways to improve 

protections for important fish and wildlife habitat and enhance visitor services. At the 

same time, the Forest Service should end its large-scale old-growth timber sale 

program.
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• As part of the plan amendment, enact sensible budgets for recreation, heritage, and 

wilderness programs in the Tongass that can support diverse and sustainable economic 

opportunities for southeast Alaskans. We urge you to shift resources to support our 

growing tourism and recreation economy.

• Recreation is now bringing in more money than logging, shift the funds to it. Preserve 

the forests so that this remains viable.

• The DEIS should include a detailed public investment analysis that discloses the full cost 

of administering the TLMP timber sale program accompanied by a more thorough

analysis of benefits provided by intact old growth forests to recreation, fisheries and 

subsistence. 

6.4.3 Fish

A number of commenters addressed concerns associated with fish and fish habitat protection. 

Examples of comments related to fish include:

• Refocus resources and management toward projects that protect and restore vital 

watersheds and important fish and wildlife habitat, while promoting a diverse and 

sustainable economy in Southeast Alaska based on fishing, tourism, and recreation.

• Consider alternatives favoring management for deer and wildlife habitat, healthy salmon 

streams, and a local wood economy for Southeast Alaska.

• The EIS should describe the current quality and potential capacity of habitat, its use by 

fish and wildlife throughout the forest, and identify known fish and wildlife corridors, 

migration routes, and areas of seasonal fish and wildlife congregation. 

• The EIS should evaluate effects on fish and wildlife from various management strategies 

as well as any proposed habitat alteration, aquatic and terrestrial habitat fragmentation 

caused by roads, land use, and management activities, and human activity. 

• The Forest Plan currently fails in the area of demonstrating and focusing management of 

Tongass lands as working lands for the production of salmon. An amendment should 

include sufficient study to show what lands on the Tongass are producing fish, the 

baseline production a) currently, b) prior to industrial logging (1954), c) prior to fish traps 

and canneries, and d) projections into the future under various management regimes 

and climate change impacts. Part of the assessment should include calculations of the 

value of contributions to the economy from Tongass National Forest lands and 

management activities. An assessment should be made as to areas that need to be 

designated as salmon producing watersheds and well defined goals should be set for an 

acceleration of restoration activities to bring all salmon systems that have legacy impacts 

from historic industrial logging to be restored to full production capacity.

• Consider alternatives favoring management for deer and wildlife habitat, healthy salmon 

streams, and a local wood economy for Southeast Alaska.

6.4.4 Karst

Several comments were received stressing protection of karst landscapes. Comments relating 

to karst landscapes include:

• Karst protection in south Southeast Alaska should be kept in place or strengthened due 

to past and future corporate big tree logging, from both Native and private corporations. 

Karst is important for maintaining clean water and a healthy Tongass eco-system.

• Preserve all karst areas.

• The richness of our forests, with karst and muskegs and unique soil microbiology and 

salmon streams, is irreplaceable after logging of the old growth.
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6.4.5 Lands 

A number of commenters identified general concerns related to lands, as well as specific 

concerns related to proposed land exchanges and specific land areas. Comments relating to 

lands include:

• Support for efforts of the Alaska Mental Health Trust Authority and the Forest Service 

that resulted in the proposed land exchange document dated September 4, 2012. The 

proposed land swap will provide much needed timber harvest activity for the southern 

southeast region economy.

• Include the Trust Land Exchange as an action common to all alternatives of the Forest 

Plan Amendment. The Trust Land Office manages lands for the Alaska Mental Health 

Trust and has begun the planning process to implement the objectives outlined by 

Secretary Vilsack (Memo 1044-009, July 2, 2013.). It appears that the Trust Land 

exchange creates a positive working solution to support the Secretary's transition plan. 

Identifying the proposed exchange as an alternative in the forest plan amendment would 

promote that potential outcome.

• Recommendation to include land patterns and shared boundaries that would exist upon 

passage of the Sealaska legislation in the amended Tongass Plan.

• A request for analysis and consideration of other unfulfilled Native land entitlements.

• Requests specific to Traitors Cove, Southern Kruzof Island, and Connell Lake. 

• A request for the federal government to turn all federal lands (within the Borough) over to 

the Ketchikan Gateway Borough.

6.4.6 Land Use Designations 

6.4.6.1 Transportation and Utility LUD

Several comments requested modification to or clarification of Transportation and Utility System

(TUS) LUD Standards and Guidelines to remove permitting and development barriers. 

Specifically, it was requested that the current TUS LUD should be amended to change the 

criteria to allow the TUS LUD to apply to hydropower projects and other renewable energy 

projects within TUS Avoidance Areas and to allow for public and private hydropower 

development in all LUDs.

6.4.6.2 Renewable Energy LUD

Several commenters requested or supported the development of a Renewable Energy 

Resource Plan and/or Renewable Energy LUD to facilitate the development of these projects. 

Representative comments include:

• A Renewable Energy Resource Plan, including a Renewable Energy Resource 

Development LUD, should be added to the Forest Plan to promote and support all forms 

of renewable energy development (including geothermal) and related transmission lines 

within the Tongass National Forest

• A Renewable Energy LUD that promotes the development of hydroelectric projects with 

a minimum of regulatory impediment and cost will be the key to a successful transition 

from fossil based fuels in the Tongass to clean renewable energy for all of Southeast 

Alaska.

• The renewable energy LUD should allow development of all clean energy technology 

(wind, biomass, geothermal, tidal) and associated transmission and access roads.
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• Plans for and interest in hydropower development, mining, transmission, geothermal,

and transportation projects exist and should be considered and evaluated in this 

amendment. Necessary changes to Land Use Designations and other use decisions 

present a management challenge that would be appropriate to consider in the LRMP 

revision process. We encourage the Forest Service to consider the potential for project 

right-of-way and siting needs, as land use determinations are established or revised. 

Based on this analysis, it may also be appropriate to expand upon the standards and 

guidelines related to land ownership to include additional standards and guidelines 

related to these types of activities. We recommend that the Forest Service work closely 

with the FWS and the Alaska Department of Fish and Game, as well as other potentially 

affected stakeholders, on these changes."

• Changes to further hydropower development are outside the essential core purpose of 

the amendment and should not be part of the amendment.

6.4.6.3 Tongass Community Economic Development Zone LUD

Some commenters requested a new Tongass Community Economic Development Zone LUD to 

promote and support economic development and activities for communities with lower per 

capita incomes or high energy prices or unemployment. 

6.4.6.4 Minerals and Strategic Minerals LUD

Some commenters requested a new Mineral and Strategic Mineral LUD to promote and support 

mineral and strategic mineral development and related access roads consistent with national 

security and national strategic mineral policies. 

6.4.7 Minerals

In addition to the Mineral and Strategic Mineral LUD recommended by some commenters (see 

Section 5.2.6.4, above), some commenters requested that the term “reasonable access” be 

defined for purposes of the Forest Plan to provide timely (30-day turnaround) issuance of Forest 

Service Special Use Permits for those who hold a mining claim or Federal Energy Regulatory 

Commission (FERC) preliminary permit to authorize these operations to investigate and develop 

lawfully permitted federal resources.

6.4.8 Old-Growth Reserves

Several comments were received specific to old-growth reserves (OGR). These comments 

addressed OGR design criteria, protection of OGRs, and additional evaluation of the efficacy of 

existing OGRs. Example comments include:

• The FWS recommends specific changes to OGR design criteria to ensure comparable 

conservation value within Value Comparison Units when OGRs are proposed to be 

relocated.

• Treatments in OGRs, beach fringe, estuary, riparian, and other buffers, or other areas 

important for conservation should be to improve habitat value.

• Harvests in OGRs should be designed specifically to accelerate succession to oldgrowth conditions and maintain non-timber resources.

• Current OGRs should be reviewed by an interdisciplinary state and federal teams to 

understand how they are working, consider issues associated with altering their 

locations and sizes, how removal of second growth stands from OGRs would affect 
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them, and assess how possible modifications would be expected to affect fish, wildlife, 

and their uses.

• OGRs appear to be located to exclude old-growth habitat (to allow for high-grade 

logging) avoid the most important deer winter habitat to make these areas and trees 

available for logging.

• The scope of the Tongass Forest Plan Amendment needs to be expanded to evaluate 

the entire system of old-growth reserves in order to demonstrate their efficacy. Wildlife 

outputs must be analyzed in the context of projected demand rather than just what is 

needed to meet minimum viable populations.

6.4.9 Planning/Alaska National Interest Lands Conservation Act 

(ANILCA)

Many comments addressed general planning issues, including the 2012 Planning Rule, the 5-

year review, plan revision, ANILCA, multiple-use planning and other issues. Examples of these 

comments include:

• The NOI is disappointingly too broad in scope and lacks appropriate direction for the 

Forest Service to respond urgently to the need to phase out industrial-scale old growth 

logging immediately.

• We are still concerned about the 2012 Planning Rule and its impact on the ability of the 

Forest Service to provide a cost-effective, workable framework for national forest 

planning that is consistent with the National Forest Management Act and other statutory 

direction. The 1982 Rule was used for the 2008 plan and should be used for any 

amendment as well.

• Do not "test drive" the 2012 planning rule on the Tongass until other “early adopters” 

have had a chance to report back

• The Forest Service has yet to outline how the analysis from the five-year TLMP review 

makes the case for amending the forest plan to accomplish a transition to young-growth 

timber harvesting within the next 10 to 15 years.

• Any section of the Forest Plan amended during this planning process must also ensure 

that ANILCA continues to be properly recognized. To help ensure there is no confusion 

during implementation, we request the Forest Plan specifically acknowledge that the 

Forest Service intends for all Forest Plan provisions, including administrative 

designations and prescriptions to be consistent with ANILCA. However, in the event of a 

conflict, ANILCA prevails.

• Consider a process or plan to coordinate its resource harvest and other management

activities with adjacent landowners

• What is needed instead of an amendment to the Forest Plan is a complete revision of 

the 1997 Forest Plan and 2008 Amendment. A full revision of the Forest Plan is long 

overdue.

• Suggest the Forest Service use an analysis approach called OPTIONS that identifies 

eight factors that must be addressed in order to effectively define and implement a 

sustainable, defensible and auditable forest management strategy.

• The scope of the amendment should be narrowed to ensure the Plan is amended during 

the current presidential administration.

• The YG transition should be directed to the Federal Advisory Committee Act committee 

and a future planning process, rather than addressed in the current plan amendment.
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• It is vital that the Forest Service pare the plan amendment process down to its bare 

essentials. Numerous issues that could be dealt with, but can await some future 

process, need to be identified as non-core and deferred.

• We believe that the focus on maintaining the existing timber industry fails to provide for 

multiple uses. The scope of the proposed Amendment does not reflect the broad need 

for changes, does not reflect a realistic assessment of changed conditions, and 

consequently will fail to appropriately guide the achievement of ecological, social and 

economic sustainability in the planning area. [36 Code of Federal Regulations (CFR)

219.8]

6.4.10 Purpose and Need

A range of comments addressed the purpose and need. Examples of these comments include:

• We request that you develop a revised purpose and need for the amendment that does 

not prioritize timber development “over the competing environmental and recreational 

goals without justification sufficient to support the agency’s balancing of these goals.”

• The Forest Service is encouraged to consider expanding scope of analysis.

• Only limited attention should be paid to the suitability or availability of land for logging

• The amendment should focus on the goal to preserve the exceptional natural values on 

the Tongass, rather than the goal of ensuring that communities are economically viable.

• Apply 2012 Planning Rule. TLMP amendment should not thwart the spirit and intent of 

NFMA and further delay a long overdue economic analysis of all the Tongass resources.

• The Forest Service needs a new paradigm where timber is relegated to its economic 

value relative to other forest resources- since other forest uses are productive and above 

cost.

• The Amendment’s limited purpose aimed at timber industry objectives falls short of the 

NEPA obligation to “rigorously explore and objectively evaluate all reasonable 

alternatives.” [40 CFR. § 1502.14(a)]. You could fix this problem by either focusing 

narrowly on alternatives that immediately end old-growth logging, or by broadening the 

scope of the Amendment by developing alternatives that enhance recreation 

opportunities in the Tongass National Forest and alternatives that focus on mitigating 

damage to salmon habitat through an emphasis on completing deferred road 

maintenance.

6.4.11 Plants

Some comments were received stressing that the EIS evaluate impacts on plant species, their 

habitats, and invasive species.

6.4.12 Recreation and Tourism

Several comments were received stressing the importance of other industries, including 

recreation and tourism, to the economic opportunities of communities. Some suggested the 

Forest Service should reallocate its priorities and resources to support these industries and stop 

giving timber a preference over them.
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6.4.13 Renewable Energy

Many comments addressed renewable energy. Some of these comments were general in 

nature, and many dealt with hydropower or biomass. Examples include:

• The EIS should consider alternative investments in efficiency programs, wind turbines, 

tidal energy, and solar and thermal energy.

• The Forest Service should solicit information from the renewable energy industry with 

regard to potential renewable energy sites and utilize that information in the identification 

of specific areas within the Renewable Energy Resource LUD within the Forest Plan.

• Roadless area restrictions negatively impact access to and development of renewable 

energy, in conflict with state and national goals for clean energy

• Ensure that Renewable Energy Resource Policies are promptly included in the Forest 

Plan without the needed for a Plan amendment process.

• The Draft EIS should assess the social and economic impacts of renewable energy 

development

• The amendment should address the needs relating to developing renewable energy 

resource on the Tongass National Forest to the maximum extent possible.

• Recommends that the Plan amendment process be utilized to level the playing field for 

consideration of renewable energy with other important resource values within the TNF.

• The renewable energy component of the plan should encompass both ongoing 

maintenance requirements and the evaluation and development of new renewable 

energy resources.

• The Forest Plan EIS should consider expansion of existing and development of future 

renewable energy facilities and transmission lines.

• Lands permanently cleared for a Renewable Energy project should be considered 

unsuitable for timber production.

• A Renewable Energy Resource Plan, including a Renewable Energy Resource 

Development LUD, should be added to the Forest Plan to promote and support all forms 

of renewable energy development (including geothermal) and related transmission lines 

within the Tongass National Forest

6.4.13.1 Hydropower

• The Forest Service should modify the Tongass Forest Plan in a manner which allows for 

hydropower development within the Tongass National Forest, and provides for equal 

treatment of hydropower development proposals regardless of market location or 

funding source.

• The Forest Plan should consider all known potential hydroelectric energy sources 

located in the Tongass National Forest and provide for their future development.

• Incorporate Lake Grace Hydropower into the Forest Plan.

• Changes to further hydropower development are outside the essential core purpose of 

the amendment and should not be part of the amendment.

• We support development of fish-friendly hydropower to meet local power needs in 

southeast Alaska, and the Tongass Plan already makes ample provision for it.

6.4.13.2 Biomass

• Conversion to biomass for heat and/or potential energy generation is fatally flawed. The 

Draft EIS should disclose impacts to human health and carbon sequestration, as well as 

the cost to taxpayers
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• To consider alternatives that redirect the public investment in alternative energies to 

cleaner and real renewable energy sources, not biomass. Federal investment in biomass 

facilities is a lost opportunity cost that will divert funds from energy alternatives that can 

better meet the region’s needs

• The EIS needs to evaluate the life-cycle greenhouse gas emissions associated with 

biomass industry development

• The Forest Plan should consider biomass heating and energy systems and the potential 

to manufacture biomass-based fuels.

• The EIS should evaluate health risks associated with increased utilization of biomass for 

energy and heat.

• Recommends the inclusion of biomass as a forest resource.

6.4.14 Restoration

A number of comments concerned forest restoration, watershed restoration, and restoration 

projects in general. Examples of the comments include:

• A Plan “standard” that discloses the costs of restoration projects in all timber sale 

planning documents must be adopted in the Amendment.

• We request that the EIS consider reasonable alternative funding mechanisms for habitat 

amelioration projects rather than an exclusive focus on so-called “stewardship” 

contracting. [40 CFR. § 1502.14(a); Sierra Forest Legacy, 577 F.3d at 1025 – 1027]. The 

Tongass National Forest has never provided a NEPA analysis that evaluates the 

feasibility of stewardship contracting or alternative ways to fund projects for habitat 

mitigation and other remedial forest management needs. Programmatic analysis may 

show that it would be more cost-effective to emphasize service contracts for road 

storage and decommissioning and red pipe remediation, rather than to liquidate oldgrowth forests in order to fund perceived needs for remedial work.

• Refocus resources and management toward projects that protect and restore vital 

watersheds and important fish and wildlife habitat, while promoting a diverse and 

sustainable economy in Southeast Alaska based on fishing, tourism, and recreation.

• The need to work on forest restoration, which duplicates the natural condition rather than 

uniformed canopied, second growth tree farms.

6.4.15 Roadless Areas

Many comments addressed roadless areas. Some comments were of a general nature, many 

supported preserving roadless areas, and many supported exempting activities from the 

roadless rule. Examples include:

• Analysis should consider how the forest should be managed with Roadless Rule not 

enforced and also if it remains in force.

• LUDs that allow logging in inventoried roadless areas (IRA) should be revised.

• Roadless area restrictions negatively impact access to and development of renewable 

energy, in conflict with state and national goals for clean energy

• Updating the roadless area inventory is fine for the amendment exercise, although it may 

or may not be pertinent. 

• The Forest Service should not consider IRAs as a determining factor for amending LUDs 

or defining the suitable and available land base. Update the inventoried roadless area 

maps to omit roaded portions (i.e., “roaded roadless” areas) due to their substantially 

altered condition.
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• Possible rulemaking related to roadless areas should not be allowed to complicate the 

transition amendment.

• The amendment should not include an update to the inventory of roadless areas.

• Decisions regarding IRAs should be addressed in a separate process.

6.4.15.1 Preserve Roadless Areas

• Opposes roads in roadless areas.

• Conservation of inventoried roadless areas should be a significant feature of all 

transition alternatives.

• The plan amendment is not a prudent vehicle for decisions about Tongass roadless 

areas.

• The Forest Service was encouraged to update its LUDs to remove inventoried roadless 

areas from the suitable timber base.

• Conservation of inventoried roadless areas should be a significant feature of all 

transition alternatives.

• If rulemaking is needed it should address only the simple issue of supplying a missing 

end-date for the self-described “temporary” exemption of the Tongass from the Roadless 

Area Conservation Rule. The effects analysis in the EIS for the transition amendment 

should assume that roadless areas will not in any likely scenario be logged.

• Conservation of inventoried roadless areas should be a significant feature of all 

transition alternatives.

6.4.15.2 Favors Exemption to the Roadless Rule

• Consider amending the Roadless Rule as applied to the Tongass to permit the 

development of geothermal power, transmission lines, and access to them.

• The Forest Service should engage in rulemaking to once again exempt the Tongass 

National Forest from the 2001 Roadless Rule.

• The Forest Supervisor and District Rangers should have the authority to permit 

development in IRAs.

• Suggests modification of Roadless Rule to open up viable timber.

• Modification to Roadless Rule needed to allow hydropower.

• Modification to Roadless Rule needed to provide reasonable access to mines.

• Recognize the negative impacts incurred by the restrictive access in roadless areas to 

critical resources within the Ketchikan Borough.

• The EIS should consider appropriate road access in IRAs for timber harvest and other 

management activities, mineral development, and renewable and alternative energy 

• Implementation of the Roadless Rule in Alaska violates ANILCA.

• The Roadless Area Conservation Rule should not inhibit hydropower development in the 

Tongass.

• The Roadless Area Conservation Rule, as an administrative regulation, does not affect 

hydropower applicants’ ability to seek roads pursuant to the Federal Power Act.

• Resolve ambiguities in the preamble to the 2001 Roadless Rule, as applied to the 

Tongass, regarding the Forest Service's authority to permit new hydropower facilities, 

transmission lines and access to them for which application is made after January 12, 

2001.

• Supports Tongass exemption from 2001 Roadless Rule.
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• Limits on access to the Tongass, due to continued application of the 2001 Roadless 

Rule, impede SEAPA's ability to access its facilities to provide core maintenance and 

also hinders the key work necessary to plan and develop future energy resources.

6.4.16 Special Uses

Several commenters requested methods to streamline special use permitting for those that hold 

a mining claim or FERC preliminary permit to authorize these operations to investigate and 

develop lawfully permitted federal resources. These methods included providing a 30-day 

review and issuance of Special Use Permits for exploratory and study activities.

6.4.17 Subsistence

Several commenters stressed the protection of continued subsistence uses on the Forest. 

Examples include: 

• The Tongass Plan EIS should evaluate the best methods and processes for monitoring, 

researching, and sustaining fish and wildlife resources in the Forest. 

• The Forest Plan must provide for continued subsistence and sustainable harvest of 

national forest resources

• Subsistence uses need to be factored into Tongass Forest Plan land use planning from 

the very beginning of the process.

• The EIS should consider road access to resources for subsistence, recreational, cultural,

and social activities important to the southeast communities.

6.4.18 Timber

Many comments were assigned to the timber theme. Some supported an immediate or rapid 

end to old-growth logging, or opposed clearcuts or logging on the Tongass in general. On the 

other end of the spectrum, some supported more timber harvests. Example comments include:

• The Forest Service should quantitatively consider how timber harvest can be 

accomplished while supporting sustainable populations of fish and wildlife that are 

managed for a variety of uses.

• Harvest of old-growth wood in selective harvest regimes and/or wildlife thinning needs to 

be monitored for windthrow and for long-term effects and benefits.

• The Amendment process must revisit, in particular, plan components that allow 

clearcutting and plan components that allow for clearcuts larger than 100 acres. 

Tongass Forest Plan standards and guidelines for clearcutting need to reflect and 

appropriately balance impacts to other resources.

• Request for substantial reduction in lands currently deemed suitable for timber 

production and that the Forest Service develop alternatives that provide primarily for 

non-timber uses.

6.4.18.1 Reduce Old-growth Harvest and Clearcutting

• Preserve old growth; protect all remaining old-growth forests.

• Leave all remaining old growth in the Tongass for the next generations.

• Use selective logging practices - not clear cuts.

• Clearcuts contribute to erosion, flooding, establishment of nonnative and particularly 

invasive and noxious vegetation.

• Stop logging the beautiful rainforest of Alaska, the Tongass National Forest.

• We should be phasing out old growth logging altogether.
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• Stop old growth logging. These forests act as a carbon sink and natural water 

purification system.

• Old growth forests cannot be replaced simply by planting more trees after logging.

6.4.18.2 Increase Harvest Levels

• The Forest Service should make available at least 350 million board feet (MMBF) of 

timber annually.

• Any further removal of Tongass lands from the approved timber base violates ANILCA.

• Need to provide the lumber needed to build houses.

• Please increase old-growth logging immediately. Please support a dual transition in 

which a firm Allowable Sale Quantity is split between old-and second-growth 

components. Old-growth allowable sale quantity (ASQ) should be increased drastically 

and immediately.

• Proposes timber preference over other forest uses.

6.4.19 Transportation

Transportation-related comments include those that encouraged keeping roads open to access 

YG or other resources, addressed water quality or maintenance concerns, or requested specific 

actions, like recognizing proposed roads. Example comments include:

• Stop removing existing road systems that will be needed to harvest YG in the future.

• Recommendation that the road and trail system evaluated through the Forest Plan 

reflect realistic, long-term funding expectations. The NEPA analysis for this planning 

process should discuss resources available to build and maintain the road and trail 

system. Please indicate the likelihood for adequate maintenance funding for each of the 

action alternatives.

• Plan should recognize a land access route to Blank Inlet, providing economic and 

recreational opportunities important to the Ketchikan Borough.

• Encourages the Forest Service to amend the Forest Plan to recognize the proposed 

Vallenar Bay Road and include it on the LUD map.

• Plan amendment should take into better account updates to the State of Alaska's 

Southeast Transportation Plan and the Alaska Energy Authority's 2011 Southeast 

Regional Integrated Power Plan.

• Action alternatives should not propose changes to the Forest Plan that may affect 

existing roads or other transportation facilities.

• The EIS should consider road access to resources for subsistence, recreational, cultural,

and social activities important to our southeast communities.

• The current Tongass Forest Plan fails to provide standards to adequately assess and 

make known the impacts of existing roads and proposed project road activities on 

watersheds, riparian areas, streams, and fish habitats.

• The Forest Plan should be updated to include a non-negotiable standard of every 

Tongass timber project planning process, for assessments of road-stream connectivity 

and consequent impacts on peak flows and sediment delivery from roads.

6.4.20 Tribal Consultation

One comment noted that the Plan should provide a framework for Alaska Native Corporation 

and Tribal participation in implementing access, subsistence, and other important provisions of 

ANILCA. Additionally, EPA provided direction for conducting intergovernmental issues with 

federally-recognized tribes.
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6.4.21 Water

Some comments stressed the protection of watersheds and streams and requested the 

strengthening of Forest Plan requirements to emphasize protection. Example comments

include:

• The forest must also place more emphasis on project level impairment to watersheds.

• Recommendation that Forest Plan revisions address a framework for project level 

watershed and water quality analysis. The EIS should summarize existing baseline 

watershed and water quality conditions.

• Concern over effects of management actions on drinking water sources and lists 

requests for the EIS to identify.

• Concern over effects of management actions on surface water quality.

• Requests revisions to standards and guidelines for stream protection and watershed 

health associated with road-stream connectivity.

• Various watersheds have been identified as especially important for fish and wildlife, and 

should be identified as unsuitable for timber harvest. 

• Protect drainages that are crucial for healthy habitat.

6.4.22 Wildlife

Several comments provided wildlife concerns or management recommendations. A common 

theme was the protection of Alexander Archipelago wolf. Example comments include:

• Recommendation for use of an advisory committee of expert biologists for development 

standards and guidelines to maintain wildlife populations.

• Recommendation that standards designed to conserve wolves (and deer habitat) should 

be strengthened to reduce vulnerability of wolves.

• Current Forest Service old-growth logging practices harm habitat and threaten wolf 

populations.

• Recommendation to use the best available information, including work of the 

Interagency Wolf Task Force.

• FWS requests clarification of when permits are needed for eagle nest disturbance, 

requests to participate in focal species discussion with Forest Service staff, and provides

specific measures for the protection of goshawks.

• Concern for other species, including pollinators (e.g., bees, bats, and butterflies), 

marbled murrelets, Queen Charlotte goshawks, marten, bears, flying squirrel and their 

habitat.

• Impacts to subsistence.

• Requests that any changes to Management Indicator Species (MIS) be made in a 

separate amendment process directed specifically at wildlife conservation and peerreviewed by an independent scientific panel, or part of a full Forest Plan revision.

• Recommendation that the Conservation Strategy not be weakened in any way that could 

reduce species viability or increase risk to vulnerable species. Any modifications should 

be peer reviewed.

• Consider alternatives favoring management for deer and wildlife habitat, healthy salmon 

streams, and a local wood economy for Southeast Alaska.

• The Forest Service should meet future demands for fish and wildlife-beyond providing 

for minimal viable populations.

• Forest Service should review the existing Forest Plan conservation strategy using an 

interdisciplinary approach.
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• The EIS should describe the current habitat capacity and identify known wildlife 

corridors, migration routes, and congregation areas and evaluate the effects of the 

alternatives upon these.

• The EIS needs to evaluate timberland suitability determinations in terms of the 

cumulative loss of habitat that has occurred due to high-grading the better quality old 

growth forests that provide optimum fish habitat and winter carrying capacity for deer. 

We request that your analysis:

o disclose the cumulative effect of continued high-grading across the southern 

Tongass and discuss ending the practice;

o assess potential impacts of any reasonably foreseeable future high-grading on all 

land ownerships;

o consider high-grading at multiple scales and by different land ownerships in light of 

remaining large-tree productive old growth at the stand level relative to past 

selections of large tree and high value species and future harvests of these species, 

at the landscape scale and at the biogeographic landscape scale.

• Potential changes to the conservation strategy should be outside the scope of the plan 

amendment.

• Replacing MIS with focal species should be outside the scope of the plan amendment

• Requests to develop alternatives that maintain well-distributed populations of focal 

species across the Tongass, including those in prior forest plans as MIS.

• Consider alternatives favoring management for deer and wildlife habitat, healthy salmon 

streams, and a local wood economy for Southeast Alaska.

6.4.23 Young-Growth Transition

Numerous comments addressed the transition to young growth. Varying suggestions for oldand young-growth harvest levels over time, methods to open up YG, and suggestions for where 

timber should come from were received. Example comments are provided in the following 

subsections. 

6.4.23.1 Need More Rapid Transition to Young Growth

Many comments were received that supported a transition away from old-growth harvests but at 

a rate faster than 10 to 15 years. Some supported an immediate stop to old-growth harvest 

while others recommended the transition be completed as soon as possible, in 2 years, or no 

more than 5 years or faster than 10 years. Example comments include:

• Support a dual transition in which a firm ASQ is split between old- and second-growth 

components. Old-growth ASQ should be reduced drastically and immediately. The 

young-growth component should support ecological, economic, and community health 

linking restoration and stewardship with local wood product manufacturing.

• Delaying the transition for another 10-20 years or more will result in unacceptable risks.

6.4.23.2 Culmination of Mean Annual Increment (CMAI)

Some comments suggested relaxation of the CMAI standard, or a limited relaxation if necessary 

to facilitate the young growth transition. Others commented that the transition should be delayed 

until more young growth has reached CMAI and allow old growth to be harvested in IRAs in the 

interim or that CMAI relaxation is not needed to secure the desired reduction in old-growth 

logging.
Tongass Forest Plan Amendment Scoping and Comment Summary Report

A-22

6.4.23.3 Effects on Local Industry and Communities

Concerns were raised about the effects of a premature transition to young growth on local mills 

that would require retooling. Others expressed support for small, value-added mills in 

communities.

• Support small value-added mills in our communities. Do not support export-oriented, 

industrial-scale, old-growth clearcuts.

• A premature transition to YG will force mill closures because inadequate supplies are 

available and the transition would require total retooling of existing sawmills.

• The current timber industry can be maintained through the transition through 

implementation of the Tongass Integrated Plan (February 2013).

• Request for alternatives favoring jobs, sustained yield forestry, and a viable wood 

products industry based on 10-year contracts.

6.4.23.4 Location of Young Growth Harvests

• The Forest Service should consider restricting logging, from the time of the Record of 

Decision on, to a subset of the current roaded, suitable, and available timber base to 

reduce potential impacts to other resources.

• Long-term availability of YG should be addressed later. In the meantime, YG harvest 

should be limited to non-controversial LUDs and YG should be separately stated (and 

capped) from old growth.

• YG logging should avoid prime wildlife habitat.

• Post-transition YG logging should be restricted to a subset of the current suitable and 

available land base that the agency identifies as least likely to entail significant 

environmental risks. Obvious exclusions, which could be implemented either through 

standards and guidelines or changes to the designated timber base, include roadless 

areas, karst lands, and high value deer winter habitat.

6.4.23.5 Harvest Volume 

• Forest Service will have to offer substantially more than its recent average of timber and 

will have to build up a stockpile of sales so that commercial financing for a timber 

industry can be attained.

• Reassure the existing timber industry that the Forest Service is committed to providing 

sufficient old-growth timber for a long enough period to permit private commercial-bank 

financing to pay for new mill equipment and to fund the expense of pioneering new 

markets for young-growth timber- all steps vital to support an Alaska timber industry.

• A transition plan for YG that does not provide sufficient timber would violate the 

requirement of the Tongass Timber Reform Act to seek to meet the demand for timber.

• It is unrealistic to expect a widespread YG transition to begin within the next 20 to 30 

years, without continued old-growth sales to make such a transition economic.

• The ASQ should be revised to reflect the sustainable young growth timber base and 

small old growth sale program.

6.4.23.6 Other Young Growth Transition Comments

• Industrial-scale old-growth logging projects are in complete contradiction to the original 

transition plan.

• All transition alternatives should focus on creating Alaskan jobs using Alaskan wood for 

available markets.
Tongass Forest Plan Amendment Scoping and Comment Summary Report

A-23

• The current planning process should consider timber growth rates, the landscape 

logging can occur on, the consequences of logging on ecosystem function, and the 

overall goals of Tongass management activities and how they balance with the strategic 

goals of overall Forest Service land management

• The Forest Service should give consideration to conservation strategies for young 

growth resources and how these stands can be managed to provide for adequate, 

economically viable timber harvests while conserving and facilitating fish, wildlife, and 

their uses.

• Transition alternatives should focus on the least vulnerable types of forest – red alder, 

conifer second growth, and cedar dieback.

• Lands that would be opened up for YG have better use if left to evolve into old-growth 

habitat.

• Both young- and old-growth timber programs are poor vehicles to stabilize communities.

The Tongass Forest Plan amendment must evaluate all other alternatives to diversify 

and strengthen local economies

• Postpone transition decision until results of YG inventory are available.

• USFWS recommends establishing limits on the volume of old growth that may be cut in 

any year, with declining volumes allowed in subsequent years.

7.0 REFERENCES

USDA Forest Service. 2013. Five-Year Review of the 2008 Land and Resource Management Plan: Public 

Outreach and Comment Analysis Report. November 2013. Available online at: 

http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5443864.pdf
APPENDIX B

MODELING AND ANALYSIS
Appendix B

Final EIS B-i Modeling and Analysis

Appendix B

Modeling and Analysis

CONTENTS

Planning Situation ..................................................................................................................................... B-1

Forest Management Modeling .................................................................................................................. B-1

Analysis-related Changes between the 2008 and 2016 EISs .........................................................B-1

The Forest Planning Model Woodstock...........................................................................................B-3

The Tongass Woodstock Models ....................................................................................................B-4

Woodstock Model Components.......................................................................................................B-4

Vegetation Inventory .............................................................................................................B-4

Land Base Analysis Areas ....................................................................................................B-5

Management Prescriptions ...................................................................................................B-7

Minimum Rotation Age..........................................................................................................B-8

Activities and Outputs..........................................................................................................B-11

Woodstock Constraints .......................................................................................................B-12

Woodstock Solution Process .................................................................................................................. B-17

Objective Functions .......................................................................................................................B-18

Iterative Process ............................................................................................................................B-19

Present Net Value..........................................................................................................................B-19

Supplemental Information on Other Model Assumptions ....................................................................... B-19

Stage II Suitability Analysis ...........................................................................................................B-19

The Regulation Class Process ......................................................................................................B-20

Model Implementation Reduction Factors (MIRF).........................................................................B-23

Estimation of Past and Future Harvest and Road Construction for Effects Analysis ............................. B-24

Estimation of Past and Future Harvest..........................................................................................B-24

Vegetation Inventory ...........................................................................................................B-24

Original POG by Category ..................................................................................................B-25

Future Harvest.....................................................................................................................B-26

Estimation of Past and Future Road Construction ........................................................................B-26

Road Inventory ....................................................................................................................B-26

Future Road Construction and Reconstruction...................................................................B-26

Deer Model Assumptions and Application .............................................................................................. B-27

Interagency Deer Model ................................................................................................................B-27

FRESH Deer Model.......................................................................................................................B-28

LIST OF TABLES

Table B-1 Woodstock Themes..............................................................................................................B-6

Table B-2.0 Key for Codes Found in Tables B-2.1-7.............................................................................B-13

Table B-2.1 Compatibility Matrix Alternative 1.......................................................................................B-14

Table B-2.2 Compatibility Matrix Alternative 2.......................................................................................B-14

Table B-2.3 Compatibility Matrix Alternative 3.......................................................................................B-15

Table B-2.4 Compatibility Matrix Alternative 4.......................................................................................B-15

Table B-2.5 Compatibility Matrix Alternative 5.......................................................................................B-16

Table B-2.6 Compatibility Matrix Alternative 6 (State of Alaska alternative – modeled, but not 

analyzed in detail)...............................................................................................................B-16

Table B-2.7 Compatibility Matrix Alternative 7 (Conservation group alternative – two options 

modeled, but not analyzed in detail)...................................................................................B-17
Appendix B

Final EIS B-ii Issue Identification

Table B-3 SIO for Distance Zone/LUD from Scenery Standards and Guidelines for Development 

LUDs ...................................................................................................................................B-21

Table B-4 Maximum Unit Size based on Visual Absorption Capability ..............................................B-21

Table B-5 Percent Allowable Visual Disturbance ...............................................................................B-22

Table B-6 Regulation Class Allocation ...............................................................................................B-22

Table B-7 Generalized Visual Constraints Regulation Class Visual Disturbance Adjacency ............B-23

LIST OF FIGURES

Figure B-1 Frequency Distribution for Age at 95 Percent CMAI for Young-growth Stands....................B-9

Figure B-2 Frequency Distribution for Age when 50% of Volume Comes from Trees with at least 

Two 36-ft. Logs ...................................................................................................................B-10

Figure B-3 Average Age of Young-growth Clearcuts in the Preferred Alternative 5 by 5-year 

Planning Period...................................................................................................................B-10
Appendix B

Final EIS B-1 Modeling and Analysis

Appendix B

Modeling and Analysis

Planning Situation

The National Forest Management Act of 1976 (NFMA) directs each National Forest to prepare a 

comprehensive land and resource management plan. The Tongass National Forest produced its first 

comprehensive Plan in April 1979. The NFMA also directs that these management plans be revised at 

least every 15 years. The Tongass began the Revision process in 1987, published a Draft Environmental 

Impact Statement (DEIS) in June 1990, and prepared the Supplement to the DEIS (SDEIS) as a result of 

the November 1990 Tongass Timber Reform Act (TTRA). The SDEIS was published in August 1991 and 

the Revised SDEIS (RSDEIS) was published in April 1996. The Final EIS (FEIS) for the Forest Plan 

Revision was published in 1997 along with a comprehensive Appendix B that detailed the analytical 

process followed. In 2002 a Draft Supplemental EIS (SEIS) was published and in 2003 a Final SEIS was 

developed; an Appendix B for modeling and analysis also accompanied the Final SEIS. In 2008, the 

Forest Plan was amended and another Appendix B was developed for the FEIS (2008) to describe the 

major analytical processes and models used in the 2008 Forest Plan Amendment EIS. This Appendix B 

is also designed to include descriptions, which document the analytical processes and models used for 

the 2016 Forest Plan FEIS.

Due to the magnitude (17 million acres) and complexity (e.g., 19 land use designations) of the planning 

process, a number of analytical methods are used. This discussion includes basic assumptions, modeling 

components and inputs, rules, methods, and constraints. The information supplements the broader, less 

technical descriptions included in the body of Chapters 2 and 3 and Appendix C of the EIS. Additional 

information and documents used in the analysis process are contained in the planning record. The 

planning record in its entirety is incorporated here by reference.

Forest Management Modeling

Analysis-related Changes between the 2008 and 2016 EISs

As the assessment, development, and analysis of geographic information is a continuous process, 

aspects and attributes of existing databases are continually changing. These improvements and additions 

to the databases often have direct results on models, model results, and the assumptions used within the 

models themselves. A wide range of changes and updates were incorporated during the years between 

the 1997 FEIS and the 2008 FEIS. These covered changes to resource inventories, coefficient 

development, and assumptions, all of which played a role in the recalculation of alternative outputs. 

Appendix B to the 2008 FEIS includes a description of these changes. This section describes the 

changes that occurred since the 2008 FEIS. They include:

Recalculation of the Suitable Land Base for each Alternative—More accurate information about the 

landscape has been captured in the Forest’s GIS resource layers (e.g., streams, slopes, karst). This 

information was used to update the suitable land bases. In addition, the model used in the identification 

of suitable forest lands was refined. See Appendix A of the Forest Plan and Chapter 3 of this FEIS for 

more detailed information on how more current information was included in the suitability analysis.

Changes to Scenery Management System— Scenic Integrity Objectives were mapped for each 

alternative, based on Seen Areas, Distance Zones, and Land Use Designations (LUDs). Seen Areas and 

Distance Zones are based on modeling of these using Visual Priority Routes and Use Areas (see 

Appendix F in the Forest Plan). The Visual Absorption Capability was remodeled and mapped and based 
Appendix B

Modeling and Analysis B-2 Final EIS

on updated GIS layers. Regulation Class layers (see below) were developed for use in Woodstock 

modeling. 

Land Adjustments—Since 2008, a number of land adjustments have occurred; foremost among these 

are the land adjustments resulting from Public Law 113-291 in 2014. These adjustments have been 

incorporated into the current analysis as they have affected the total National Forest System (NFS) land 

base as well as the suitable forest land bases.

Inventory and Data—The inventory step of the planning process consists of the collection, development, 

and documentation of data to address the public issues, management concerns and resource 

opportunities, and planning criteria. Two basic types of information are needed to facilitate the analysis 

and development of alternatives. The first consists of information related to the classification of land into 

categories with unique properties. This classification can be based on any attribute significant to planning 

issues. This type of information is tied directly to the map base. In the case of the Tongass National 

Forest, this map base is its GIS database. The second type of information is not directly tied to a map 

base, but has more to do with the estimation of how land will respond to certain management activities. 

This type of information comes from many sources: Regional procedural handbooks, research studies, 

available literature, etc. The most up-to-date and verifiable information available was used for the EIS. 

Several Forest-wide inventory data sources have been updated and improved for the 2016 FEIS. The 

primary changes and updates to the inventory, data, and modeling include:

• The timber harvest map was updated to reflect timber harvested through 2015. 

• The inventory of young-growth forest stands was updated.

• Forest Planning and Projection System (FPS) model runs were conducted to estimate younggrowth yields, including commercial thins. These runs were based off of a combination of FIA 

and stand-level data collected on young-growth stands.

• New site index information was developed for all stands, young growth and old growth.

• New roads were added to the roads data base. 

• Changes in land ownership due to conveyances to the state and Native corporations and other 

adjustments were addressed in the data base (noted above). 

• Improvements and updates were made to most other resource databases, including suitable 

lands for timber production, streams, slopes, karst, and other data. 

The major modeling changes were:

• The forest management model was built using Woodstock, replacing the Spectrum model used in 

the previous plan (2008).

• The forest management model was run for 20 five-year periods.

• Analysis areas were defined using attributes not used previously (e.g., beach buffers, karst, etc.)

• The updated Tongass young-growth timber inventory was used to model the young-growth land 

base. The Woodstock model maintained stand-level detail for the young-growth acres. Oldgrowth acres were modeled as strata per the 2008 planning analysis.

• All timber values were recalculated to reflect current information.

• Watershed constraints were recalculated based on the suitable acres in each alternative.

• Logging costs for young growth were calculated based on stand characteristics, using the 

equations from the Region 10 appraisal spreadsheets.

• New treatment options including group selection/patch cuts and variable retention harvest were 

developed in some alternatives
Appendix B

Final EIS B-3 Modeling and Analysis

• Minimum rotation ages were established based on log-product objectives, in some alternatives.

• Harvest levels were established at a pre-determined target during the period of transition from 

old-growth to young-growth harvest.

• A broader array and definition of land allocation constraints were developed. 

• Tongass National Forest acres transferred under Public Law 113-291 were removed from the 

model and do not contribute to the outputs, benefits and costs discussed in the EIS. 

• Haul costs were modified to include the costs of constructing and maintaining log transfer 

facilities; camp and commute costs were also added to remote VCUs. 

The Forest Planning Model Woodstock

Woodstock is a commercially available forest management modeling system developed and sold by 

RemSoft (www.remsoft.com). It is widely used by private, state, and federal land managers to develop 

and evaluate long-term timber harvest schedules designed to meet management objectives given 

constraints or limitations on management activities. Woodstock allows planners to create a detailed 

forest management model with the available data. In this planning effort, Woodstock was used to ensure 

that land allocations and output schedules for alternatives are realistic and meet standards and guidelines 

in a cost-efficient manner. 

Woodstock is similar to Spectrum, the modeling system used in the 2008 Forest Plan. Both are linear 

programming models that assume that relationships between outputs and the land base are linear (e.g. 

harvesting twice the number of similar acres yields twice the timber volume). A management objective is 

specified (e.g., maximize present net value of revenues from harvest) as well as any constraints that may 

affect that objective (e.g., land allocations, limits on harvest flow over time, limits on silvicultural choices, 

etc.). An in-depth technical discussion of linear programming and its use in forest management 

applications can be found in Davis et al. (2001).

Woodstock was used instead of Spectrum for several reasons: 

1. Woodstock has a greater capacity than Spectrum. This allowed the use of stand-specific yields 

for the approximately 8,400 young-growth stands. Greater capacity also provided for a single 

model for suitable Tongass National Forest lands, as opposed to the three Spectrum models to 

cover the same land base.

2. Woodstock provides more capacity and flexibility in specifying yields. For the young-growth yield 

tables, for example, volumes were split into five species groups and four size classes. The yield 

tables also contained logging costs specific to stand conditions.

3. Woodstock provides more control for modeling. For example, minimum rotation ages could be 

established such that each stand reached 95 percent of CMAI. 

4. Woodstock provided the solution in both a tabular and a spatial format that was used to drive 

other models. 

5. A previous Woodstock model offered a good starting point. Before beginning work for the 

Tongass National Forest, the modeling subcontractor had already built a Tongass Woodstock 

model under contract to The Nature Conservancy. Most of that model had been constructed in 

coordination with Tongass National Forest staff. It was easier to convert that model to use for the 

Tongass than to start over with a new program.

The Woodstock solution process involves three steps: 1) create a linear programming (LP) model, 2) find 

the optimal solution to the LP model, and 3) prepare reports of the model solution. Woodstock’s matrix 

generator portion translates the management objective, constraints and assumptions about the land base 

into a matrix of coefficients that can be solved with Mosek – a commercial LP solver software package. 

The solver software identifies a set of management prescriptions that results in the highest possible 
Appendix B

Modeling and Analysis B-4 Final EIS

objective function value (e.g., Net Present Value) within the constraint parameters (meeting desired 

conditions and appropriate standards, guidelines, and land allocations). Woodstock’s report writer portion 

then translates the LP output into reports, such as costs, revenues, landscape condition, and long-term 

sustained yield capacity. For some alternatives, Woodstock’s spatial solution generator was used to map 

the solution for use in other analytical tools.

Results from the modeling process are only approximations of what to expect when any given alternative 

is implemented. The main purpose of modeling is to aid planners in estimating likely future 

consequences of management decisions. An informed choice between alternatives can be made even 

though the model may lack precision in describing specific attributes of a given alternative.

The Tongass Woodstock Models

Large LP models can be difficult or impossible to solve. While the Woodstock model offers more capacity 

than the Spectrum model, some of the limitations of the previous Spectrum models were imposed on the 

Woodstock model. Specifically, the Woodstock models for the Tongass only analyze land classified as 

suitable for timber production. Those lands considered "not suitable" for timber production were omitted

from the models since there were no opportunities to schedule management activities. The process for 

determining suitability can be found in Appendix A, " Identification of Lands as Not Suitable and Suitable 

for Timber Production," of the Forest Plan. 

Woodstock Model Components

A Woodstock model has five main components: 1) the objective function, 2) land base development 

types, 3) management prescriptions, 4) activities and outputs, and 5) constraints. The objective function 

provides the model with a way to evaluate management options. Examples of typical objective functions 

are “maximize net present value,” “maximize timber volume,” and “minimize cost.” Only one objective 

function can be used for each model run; however, forests typically find it beneficial to use the results of 

one objective function run to learn about the specific nature of their management problem or to formulate 

desired conditions used with another objective function. Detailed information on objective functions used 

by the Tongass is found in the solution process section of this appendix. 

The management prescriptions and constraints influence how the land base will be defined. The 

Tongass models are designed to analyze the activities and outputs associated with timber harvest 

scheduling; therefore, the land base is defined by those characteristics significant to the timber resource. 

Other resources are dealt with through the LUD allocation process and model constraints. The 

management prescriptions applied to the Forest differ by types of regimes, rotation age and dispersion 

amount (portion of the trees removed from the stand). The costs associated with timber harvesting are 

documented below as are the volumes and value of the wood fiber. The constraints differ by alternative

but often refer to a particular timber classification, specific geographic area, activity or output volumes 

allowed, and management allocation. Constraints are used to ensure desired condition achievement, 

compliance with appropriate standards and guidelines, and that the resultant management strategy is 

feasible.

Vegetation Inventory 

The Tongass Geographic Information System (GIS) library was used as the source of all spatial 

information used in the forest management model. The timber inventory came from two sources:

Old-Growth Inventory – The Woodstock model used the same old-growth inventory data that 

was used for the 2008 Forest Plan, with the updates described above. Specifically, 15 strata are 

used to define timber volumes and yields. They span 3 stocking levels and 5 geographic ranges. 

Young-Growth Inventory – Inventory projections for the young-growth acres were based on the 

young-growth stand-based inventory, and the recently completed site index layer. There are 

about 8,100 young-growth stands in the Tongass inventory. About 40,000 cruise plots were 

established in a subset of the young-growth stands, distributed across the forest. Plot data was 

compiled and average stand conditions expanded to establish inventory on the un-cruised stands 
Appendix B

Final EIS B-5 Modeling and Analysis

using strata based on District, size class and density class. Each stand was grown forward with 

the FPS growth model, using the site index specific for that stand. At each five-year period, the 

stand table was merchandized into six species groups and four size classes. 

Land Base Analysis Areas

Analysis Areas represent unique combinations of the different Identifiers used to stratify the mapped 

suitable land base. The mapped suitable land base is different for each alternative and is displayed in the

EIS. The total land base analyzed amounts to almost one million acres. It is important to note that they 

include the unmapped unsuitable lands accommodated for by the Model Implementation Reduction 

Factor (MIRF – see below for detailed discussion). If information was perfect, and all unsuitable lands 

could be mapped, the actual suitable would be somewhat less than the land base represented by the 

analysis areas.

An analysis area is an operational aggregation of land resource polygons that have the same 

characteristics, are expected to have similar responses management prescriptions, and have similar 

costs and benefits associated with management prescriptions. By an extension of this logic, analysis 

areas differ from each other in management prescription response and the costs and benefits associated 

with those prescriptions. Analysis Areas are unique combinations of the Analysis Area Identifiers 

described below.

Analysis Area Identifiers. Fourteen attributes were used to classify the land base for the Woodstock 

models. An analysis area is a unique combination across all attributes. The attributes describe 

characteristics that: (a) affect timber growth and yield; (b) describe the existing timber stand; (c) affect 

timber management costs and/or revenues; (d) affect land allocation and/or management restrictions in 

some or all alternatives. The attributes are described below.

Stand ID: Existing inventories were used to produce current and future yield values for all current 

young growth stands. These yields were stand based and referenced by Woodstock using the 

Stand ID.

Old Growth Strata: There are 15 strata assigned to the old growth stands. They span 3 stocking 

levels and 5 geographic ranges. In lieu of yield produced at the individual stand level, yields for 

old growth stands are assigned to each of these 15 strata.

Regulation Class: Regulation class is determined by the combination of Scenic Integrity 

Objective, LUD designation, Distance Zone and Visual Absorption Capacity. Regulation class 

affects the intensity of potential harvesting activities and is used to assign management regimes. 

Site Class: There are nine site index classes utilized in this model. The primary use of site index 

is by the growth model when generating future yields. The site index was also used to establish 

minimum rotation ages. All site indices are base age 50, and correspond to the site productivity 

values in FPS.

Timber Phase: Old growth strata and young-growth stands can be categorized in one of 3 land 

phases, based on the Tongass Timber Sale Adaptive Management Strategy. All alternatives can 

access timber in Phase I and some alternatives can access timber in Phases II and III as well.

District: There are 10 districts in this model. District is used for both reporting and for assigning 

regeneration yields. Northern districts did not include cedar as a part of the regeneration species 

mix, while those in the southern districts did.

Steep Slopes: Slopes over 72- percent are considered oversteepened. In some alternatives, 

management is restricted on oversteepened slopes.

Land Use Designation (LUD): There are five LUD classifications in this model. The LUD is a 

factor in identifying appropriate management regimes. 
Appendix B

Modeling and Analysis B-6 Final EIS

Road Classification: Road classification specifies whether an area is presently roaded or 

unroaded. The roaded/unroaded condition of an area influences the cost of harvesting the timber

and is used to determine appropriate management. Unroaded areas require more costly road 

construction; roaded areas require less costly road maintenance and repair when harvesting 

activities are conducted.

Riparian Management Area: Riparian management area (RMA) is used to assign management 

regimes in some alternatives.

Beach Buffer: Stands that border saltwater are designated as within the beach and estuary 

fringe (also referred to as beach buffers). Beach buffers are used to assign management 

regimes. In Alternative 5, a 200-ft fringe right along the water is never planned for treatment.

These stands received a 21-percent reduction in acres to account for a fringe area right along the 

water that will never be assigned management in any alternative addressed by this model. 

Karst: Karst landscapes have been categorized as low, moderate, and high vulnerability. Karst 

is used to assign management regimes.

Value Comparison Unit (VCU): VCUs, which generally represent large watersheds, are used to 

assign hauling costs. VCUs are also used to disperse harvest across the landscape

Logging System: Logging systems consist of the three basic categories of ground, cable, and 

helicopter. Cable and helicopter have additional levels depending on yarding distance. Logging 

systems are used to assign logging costs.

Table B-1

Woodstock Themes

Theme Attributes

Old Growth Strata North Island Low Volume

North Island Medium Volume

North Island High Volume

North Mainland Low Volume

North Mainland Medium Volume

North Mainland High Volume

South Island Low Volume

South Island Medium Volume

South Island High Volume

South Mainland Low Volume

South Mainland Medium Volume

South Mainland High Volume

Yakutat Island Low Volume

Yakutat Island Medium Volume

Yakutat Island High Volume

Regulation Class Ineligible for management

Reg Class 1

Reg Class 2

Reg Class 3

Site Class SI 1 to 35

SI 36 to 45

SI 46 to 55

SI 56 to 65

SI 66 to 75

SI 76 to 85

SI 86 to 95

SI 96 to 105

SI > 105
Appendix B

Final EIS B-7 Modeling and Analysis

Table B-1 (continued)

Woodstock Themes

Theme Attributes

District Admiralty

Craig

Hoonah

Juneau

Ketchikan

Petersburg

Sitka

Thorne Bay

Wrangell

Yakutat

LUD Modified Landscape

Old Growth Reserves

Scenic Viewshed

Timber Management

All Others

Roadless Roadless between 1000 and 5000 acres

Roadless less than 1000 acres

Inventoried Roadless Area – non-roaded

Inventoried Roadless Area – roaded

Roaded

Karst None

Low Vulnerability

Medium Vulnerability

High Vulnerability

Unknown

Logging System Ground

Cable Short span

Cable Long span 

Helicopter Distance <0.75 Mile

Helicopter Distance 0.75-2 Miles

Helicopter Distance >2 Miles

Modeled Analysis Areas. Using the 14 attributes, there were about 120,000 unique combinations 

of acres. Many of these analysis areas were small and we eliminated small polygons in order to make 

the model run more efficiently. Young growth analysis areas that were less than 0.5 acre and old-growth

analysis areas less than 1.0 acre were eliminated. This eliminated about 36,000 potential analysis areas

and about 6,300 acres from the model. 

Management Prescriptions

A prescription is a management practice or group of management practices applied to a specific land 

area. The planning process involves assignment of the land base to the available prescriptions. This is 

facilitated by the Woodstock model and is based on forest constraints specific to each forest plan 

alternative and the objective function. 

Prescriptions were developed by the interdisciplinary team to represent the full range of possible 

management activities and outputs. Since the Tongass models are concerned primarily with timber 

harvest scheduling, only prescriptions related to timber harvest were modeled. The interdisciplinary team 

quantified the outputs, costs, and revenues that would occur when these timber prescriptions were 

applied to a given analysis area. This quantification process produced the output, cost, and revenue 

coefficients that are used in Woodstock yield and economic tables. The interdisciplinary team, during its 

development of standards and guidelines for all prescriptions, ensured that the specific management 

requirements set forth in 36 CFR 219.27 would be met in accomplishing the goals and objectives for the 

Tongass.
Appendix B

Modeling and Analysis B-8 Final EIS

Woodstock prescriptions were developed to allow consideration of a full range of management activities 

in the analysis areas. A grow only or no-harvest prescription was created for each analysis area as well 

as several different harvest options. The only criterion used to eliminate timber options from the models 

was technical feasibility. For example, ground-based/shovel logging was not considered on slopes 

greater than 35 percent. Consideration of timber prescriptions for any given Analysis Area was not 

directly limited by economic efficiency, in order to allow them to be chosen in efficient fulfillment of a 

forest-wide desired condition (CFR 219.14(f)(8)). Available timber options were not eliminated from 

consideration because they produced a negative PNV or even a lesser PNV than some other timber 

option. A full range of timber options with varying levels of economic efficiency was available to the 

model, and the Woodstock model was able to consider the economic efficiency of each prescription 

during the solution process. 

The prescriptions analyzed are briefly described below. Note that all regimes assume natural regen, and 

that all existing young-growth stands 20 years or less, and all regeneration stands are assumed to have a 

precommercial thinning to bring the stands to desirable stocking levels.

Grow only or Minimum Level/Maintenance. Applies minimum custodial direction for the timber 

resource. There is no commercial timber harvest and no production of outputs related to timber 

harvest. This is the prescription assigned to lands not scheduled for timber harvest

Clearcut. Removal of all merchantable commercial trees within a stand in one operation. This 

prescription is only available for old-growth stand and existing young-growth stands past the age 

of precommercial thinning.

Precommercial thinning and clearcut. All young-growth stands 20 years old and younger

received a precommercial thinning. Final harvest removes all merchantable commercial trees 

within a stand in one operation. This prescription is available for young-growth stands 20 years 

and less, and regenerated stands.

Commercial thinning and clearcut. One commercial thin at age 60, 65, 70, 75, 80 70, 75, or 

80. Clearcut at choice of rotation ages. 

Precommercial thinning, commercial thinning and clearcut. Young-growth stands 20 years 

old and less receive a precommercial thinning. One commercial thin at age 60, 65, 70, 75, 80 70, 

75, or 80. Clearcut at choice of rotation ages. This prescription is available for young-growth 

stands 20 years or less and regenerated stands.

Commercial thinning, no subsequent harvest. One commercial thin at age 60 or older; no 

further entries are allowed. This prescription is available for young-growth stands in certain land 

allocations, defined for each alternative.

Young Growth Patch Cuts. This regime creates an uneven-age class distribution across space 

by creating smaller even-aged openings. Up to 35 percent of the stand is harvested in small 

openings, no larger than 10 acres in size. Openings will naturally regenerate, and precommercial 

thinning may be scheduled to coincide with a subsequent harvest entry. This prescription is 

available for young-growth stands in certain land allocations, defined for each alternative.

Old Growth Partial Cut. On first entry into old-growth stands, 75 percent of the standing volume

is harvested. The remaining 25 percent of the stand is harvested every 50 years. This 

prescription is available for old-growth stands in Regulation Class 3.

Minimum Rotation Age

The National Forest Management Act establishes the minimum rotation age for even-aged harvest as the 

age at which stands have “generally reached culmination of mean annual increment (CMAI)”. The 

planning regulations define this more specifically as the time that stands reach 95 percent of mean annual 

increment.
Appendix B

Final EIS B-9 Modeling and Analysis

To define this for modeling, young-growth stands were grown forward to project the age at which each 

stand would reach CMAI. The results indicated that most stands would not reach 95 percent CMAI prior 

to age 90, and many stands would take considerably longer than that, as shown in Figure B-1 below.

Public Law 113-291 of 2014 made provision for shorter rotations on a limited basis – up to 1,500 acres 

per year in the first 10-year period, and no more than 50,000 acres in the first 20 years, could be 

harvested at ages less than 95 percent CMAI. This standard was used as the basis for Alternative 1. 

However, after 20 years, minimum harvest age was defined by 95 percent CMAI. 

To increase the transition speed to a young-growth harvest program, rotations shorter than 95 percent 

CMAI were used in Alternatives 2, 3, 4, 5, and 7 (Alternative 7 is the very short-rotation alternative, which 

was evaluated but not analyzed in detail), and in calculation of the Sustained Yield Limit. Alternative 6 

(the State-recommended alternative, which was evaluated but not analyzed in detail) used 95 percent 

CMAI exclusively.

Figure B-1 Frequency Distribution for Age at 95 Percent CMAI for Young-growth Stands

0

2,000

4,000

6,000

8,000

10,000

12,000

14,000

16,000

18,000

6

37505962656871747780838689929598

101104107110

113116119122125128131134137140143146149152

155158161164167173179186194206

YG Acres

Age

Age at 95% CMAI

Minimum rotations less than 95 percent CMAI were based on an analysis of the log products that could 

be made from young-growth stands. A number of different standards were evaluated. Ultimately, 

minimum rotation ages for young-growth stands were set at the age at which at least 50 percent of the 

total volume comes from trees with at least two full 36-ft. logs. Comparing Figure B-2 with Figure B-1

shows that this standard reduces the minimum rotation age for most stands. 
Appendix B

Modeling and Analysis B-10 Final EIS

Figure B-2 Frequency Distribution for Age when 50% of Volume Comes from Trees with at least

Two 36-ft. Logs

0

2,000

4,000

6,000

8,000

10,000

12,000

14,000

16,000

18,000

20,000

6

3741475053565962656871747780838689929598

101104107110113116119122125128131134137140143146149152155158161164167170177182189195

Acres

Age

Age When 50% of Volume Comes From Trees With At Least Two 36' Logs

Further analysis indicated that most young-growth stands with a site index of 90 or greater would reach 

this standard at age 65, and that most stands with site index less than 90 would reach this standard by 

age 75. 

Minimum rotations in the harvest scheduling model were set at 65 for higher site stands (site index 90+) 

and at 75 for lower site stands (site index less than 90). These minimum rotation ages establish the first 

time that a young-growth stand could be considered for harvest. Due to the current young-growth ageclass distribution, much of the harvest in the early planning periods would come from stands harvested at 

these minimum rotation ages, as shown in Figure B-3.

Figure B-3 Average Age of Young-growth Clearcuts in the Preferred Alternative 5 by 5-year 

Planning Period

50

55

60

65

70

75

80

85

90

95

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20

Age

Planning Period

Average Age of YG Clearcut

Alternative 5
Appendix B

Final EIS B-11 Modeling and Analysis

Activities and Outputs

Management activities create costs and produce outputs, both of which are reflected in the Woodstock 

model. Each Activity and Output used in the model is described below.

Activity Costs. All costs and values used in the Woodstock are based on the current USFS Region 10 

appraisal system. Costs in the model include costs incurred by the timber sale purchaser – logging, haul 

and presale costs. The Forest Service costs for timber sale preparation and harvest administration are 

also included in the model, but do not contribute to the Present Net Value objective function. The actual 

cost figures used in the analyses are available in the planning records.

Coefficient Development and Estimation of Effects. The GIS enables identification and stratification 

of land into logical groupings. The response of these groups to management activities was determined 

from a wide variety of existing data. All coefficients and assumptions made in the modeling process have 

been developed from the following information sources.

Yarding/Logging Costs 

Information Source: Calculated using equations from USFS Region 10 timbers sale appraisal 

spreadsheets.

Occurs With or Varies By: For old growth, varies by volume class, logging operability, geographic 

zone, productivity group, stand age, and prescription. This cost is incurred according to net 

sawlogs removed per acre. For young growth, varies by volume per acre, logging operability and 

harvest method.

Assumptions: These costs include road maintenance relative to logging, profit and risk relative to 

yarding, landing construction, and yarding. Logging costs increase as operability becomes more 

difficult. The logging operability classification of the area heavily influences the logging costs due 

primarily to the different harvest systems required. The size of the logs influences logging costs. 

Typically, larger logs result in less logging cost per 1,000 board feet. For old growth, volume 

class and productivity group are used to estimate the average log size and volume per acre for 

each unit. For young growth, pieces per thousand are used in the young growth logging cost 

equations to estimate logging costs specific to each stand at each time period.

Logging systems include ground-based/shovel, short-span cable and long-span cable. Helicopter 

costs will also be determined by three categories of distance (0.5 mile, 1.25 mile, and 2+ mile). 

Helicopter costs are constant costs independent of volume strata and geographic zone, so they 

can be applied wherever helicopter logging must be used. Young-growth harvest costs were 

determined initially from FVS outputs at age 80. They were then adjusted for geographic zone, 

age, and prescription (i.e., clearcut or thin) using South Islands (POW, where the data was 

collected) as a reference point. Cost curves from 1996 were used as the basis of this adjustment.

Felling and bucking coefficients

Information Source: Based on most recent USFS Region 10 appraisal spreadsheets.

Occurs With or Varies By: Tracked on a per volume basis (MBF). For old growth, varies by 

volume class. For young growth, coefficients are based on projected yields for each stand.

Assumptions: Felling and bucking costs were split out separately from logging costs. Old-growth

costs varied by Geographic Zone and volume strata. 

Outputs (Benefits). The economic benefits associated with timber harvest are based on appraised 

value. Value is based on tree size, species composition, amount of defect, and assumptions about 

domestic manufacture and export. Timber benefits are measured as pond log value. Pond log values 

used in the Woodstock model are the estimates of price a timber buyer would pay for a log at the mill site, 

less the markup charged by the logger (profit and risk). To get the stumpage value of this log, all 
Appendix B

Modeling and Analysis B-12 Final EIS

estimated costs that are incurred to get the log to the mill must be subtracted from the pond log value. 

The resulting stumpage price is assumed to be the price the timber buyer pays for the log (bid price). Bid 

price represents money to the U.S. Treasury. 

Sawtimber (board feet and cubic feet)

Information Source: Timber values were determined using timber appraisal methodologies for 

Southeast Alaska (FSH 2409.22) as reflected in the most recent USFS Region 10 appraisal 

spreadsheets. 

Merchantable volume of existing old growth timber stands was based on FIA plot analysis by 

volume strata within each identified Geographic Zone and are the same volumes used in the 

2008 Plan. 

Yields for existing young-growth timber stands were derived from a recent young growth

inventory and a recently updated site index map. In the Woodstock model, each of the 

approximately 8,100 young-growth stands were grown forward and those unique yield projections 

were each used in the model. Stands 20 years old and younger were assumed to have a 

precommercial thin to achieve desirable stocking levels.

Yields for future regenerated stands were based on a subset of the young growth yields. All 

future stands are assumed to have desirable stocking due to precommercial thinning.

Occurs With or Varies By: At harvest, the old-growth volume of merchantable timber produced 

generates a revenue per mbf that varies by Geographic Zone and volume class. Geographic 

zone affects this revenue due to differences in species composition and wood quality. Young 

growth harvest revenue is based on the species and size class of the harvested logs.

Assumptions: For existing old-growth stands, piece size and species composition is determined 

from a tree-by-tree analysis of the FIA plot summary data. For young growth and regenerated 

stands, piece size and species composition is based on a tree-by-tree analysis of the FPS model 

outputs. It is assumed that existing old-growth volumes are constant (i.e., through time, growth 

equals mortality). Young- growth (regenerated) stands grow at a rate determined by the FPS

model. Pond values are based on the assumption that for species that are exported, half of the 

volume will be exported, and half will be processed by domestic manufacturers.

Woodstock Constraints

Constraints in a linear programming model are the rules that must be followed when determining an 

optimal problem solution. Without constraints, the solution of a Woodstock model may represent a 

management strategy that is impractical, inconsistent with the forest plan, or in conflict with Forest 

Service policy. Thus, constraints are included in Woodstock models to ensure that their results are useful 

and meaningful.

There are two categories of constraints within a Woodstock linear programming matrix: implicit and 

explicit. Implicit constraints are common to all Woodstock models. For example, all acres in the model 

must be allocated to some prescription (even if it is the “no management” prescription), or the number of 

acres assigned to each prescription must not be negative. These types of constraints are exercises in 

logic and need not be discussed further. 

Explicit constraints are those constraints added to Woodstock models by planners. These constraints 

come in many forms and are applied to mimic regulations and laws such as NFMA, standards and 

guidelines set forth in the forest plan, and on-the-ground operating conditions. An example is the nondeclining yield constraint. Proven ability to maintain a constant flow (non-declining yield) of harvested 

timber volume in perpetuity is Forest Service policy. A constraint is added to the Woodstock data set that 

forces all timber harvest volumes to be at least as great as the previous decade's harvest volume (see 

below for further discussion). Another example may be a constraint that forces a certain area to be 
Appendix B

Final EIS B-13 Modeling and Analysis

managed specifically for wildlife habitat. There are many explicit constraints in the Tongass models. They 

vary by land attributes, geographic area, and by management alternative. The explicit constraints used in 

the Woodstock models fall into two categories: timber policy constraints and operational constraints. A 

detailed discussion of the intent of these constraints follows. They are summarized in Table B-2 for 

comparison of their application across the alternatives.

Timber policy constraints. These constraints are included in the Woodstock models to represent legal 

or policy requirements of national forest timber management. The primary requirements regarding timber 

management incorporated into Tongass Woodstock models are:

Non-declining Yield. The Tongass models have a constraint that ensures harvest volume (in 

board feet) will not decline in any period over the 100-year planning horizon per national policy. 

Harvest volumes may increase, but all subsequent harvests must be at least as much as the 

previous decade’s harvest. 

Sustained Yield. The harvest in any decade of the planning horizon must not exceed the LongTerm Sustained Yield that can be maintained on the forest. Long-term sustained yield is 

measured in cubic feet. It is calculated as the average yearly volume yielded from a chosen

management action, summed across all management actions for all stands chosen by the model. 

For instance, if a management action yields 50 cubic feet every 100 years, the Long-Term 

Sustained Yield for that management action is 0.5 cubic feet per year.

Minimum harvest age. The age at which a managed stand is harvested is called the rotation 

age. Agency policy has been that rotation age can be no earlier than the age at which 95% of 

culmination of mean annual increment (CMAI) occurs. As discussed above, because of this 

transition to young-growth management, most alternatives in this plan amendment allow harvest 

at ages younger than 95% CMAI (based on legislative and NFMA exceptions).

Constraints Common Across All Alternatives. There are four constraints common to all seven 

alternatives. They are: (1) Non-declining yield, (2) Harvest during the first three periods – can 

only come from Craig, Thorne Bay, Ketchikan, Petersburg, and Wrangell Districts; after that, all 

nine timber districts are available become available, (3) Normal operability constraints, and (4) 

Old growth high volume strata constraints.

Compatibility Matrices Specific to Each Alternative. The Tables below show which 

management regimes are compatible with each land use allocation, under each alternative. 

These “compatibility matrices” were used to build the land allocation constraints into the 

Woodstock models.

Table B-2.0

Key for Codes Found in Tables B-2.1-7

Code Description

NH No Harvest

CC Clearcut

GS Group Selection and Patch Cut

VR Variable Retention

CT Commercial Thin

Par Partial Harvest

YG Young Growth

OG Old Growth

x1 x1 = Phase 1 only

x2 Remove 33% of volume

x3 Only CC harvest in Period 1-3, then CT but no CC

x4 Patch cutting in Moderate, clearcut in Low

x5 Minimum age 60/70

x6 Where also OG and RMA, minimum age 65/75
Appendix B

Modeling and Analysis B-14 Final EIS

Table B-2.1

Compatibility Matrix Alternative 1

YG OG

NH CC CT CC CT NH CC Par

Roadless x - - - x - -

Phase I, II and III x x - x x x

Roaded Roadless x - - - x - -

Beach Buffer x - - - x - -

Karst - High x - - - x - -

Karst - Moderate & Low x x - x x x

LUD - Non Development x - - - x - -

RMA outside TTRA Buffer x - - - x - -

Steep Slope, MMI 4 x x - - x - -

LUD - Modified Landscape x x - - x x x

LUD - Scenic Viewshed x x - - x x x

LUD - Timber Production x x - - x x X

*Relax CMAI on 50,000 acres in first 20 yrs (1st decade 15,000 ac, no more than 1500 ac per year)

*FP Scenery Standards apply (Reg class constraints by VCU)

*YG use 2 log trigger

*If YG+OG > 46, then OG volume = 5, else OG+YG = 46

*Total harvest during transition <= 46

Table B-2.2

Compatibility Matrix Alternative 2

YG OG

NH CC CT CC CT NH CC Par

Roadless x - - - x - -

Phase I, II and III x x - x x x

Roaded Roadless x x - - x x x

Beach Buffer x x3 - x x - -

Karst - High x - - x x - -

Karst - Moderate & Low x x - x x x

LUD - Non Development x x - - x - -

RMA outside TTRA Buffer x - - x2 x - -

Steep Slope, MMI 4 x x - - x - -

LUD - Modified Landscape x x - - x x x

LUD - Scenic Viewshed x x - - x x x

LUD - Timber Production x x - - x x X

*Relax CMAI on 50,000 acres in first 20 yrs (1st decade 15,000 ac, no more than 1500 ac per year)

*FP Scenery Standards apply (Reg class constraints by VCU)

*YG use 2 log trigger

*If YG+OG > 46, then OG volume = 5, else OG+YG = 46

*Total harvest during transition <= 46
Appendix B

Final EIS B-15 Modeling and Analysis

Table B-2.3

Compatibility Matrix Alternative 3

YG OG

NH CC CT CC CT NH CC Par

Roadless x x - - x x x

Phase I, II and III x x - x x1 x1

Roaded Roadless x x - - x x x

Beach Buffer x - - x x - -

Karst - High x - - x x - -

Karst - Moderate & Low x x - x x x

LUD - Non Development x x - - x - -

RMA outside TTRA Buffer x - - - x - -

Steep Slope, MMI 4 x x - - x - -

LUD - Modified Landscape x x - - x x x

LUD - Scenic Viewshed x x - - x x x

LUD - Timber Production x x - - x x X

*Relax CMAI on 50,000 acres in first 20 yrs (1st decade 15,000 ac, no more than 1500 ac per year)

*FP Scenery Standards apply (Reg class constraints by VCU)

*YG use 2 log trigger

*If YG+OG > 46, then OG volume = 5, else OG+YG = 46

*Total harvest during transition <= 46

Table B-2.4

Compatibility Matrix Alternative 4

YG OG

NH CC CT CC CT NH CC Par

Roadless x - - - x - -

Phase I, II and III x x1 - - x x1 x1

Roaded Roadless x - - - x - -

Beach Buffer x - - x x - -

Karst - High x - - x x - -

Karst - Moderate & Low x x - x x x

LUD - Non Development x - - - x - -

RMA outside TTRA Buffer x - - - x - -

Steep Slope, MMI 4 x x - - x - -

LUD - Modified Landscape x x - - x x x

LUD - Scenic Viewshed x x - - x x x

LUD - Timber Production x x - - x x X

*Relax CMAI on all acres and time periods

*FP Scenery Standards apply (Reg class constraints by VCU)

*YG use 2 log trigger

*If YG+OG > 46, then OG volume = 5, else OG+YG = 46

*Total harvest during transition <= 46
Appendix B

Modeling and Analysis B-16 Final EIS

Table B-2.5

Compatibility Matrix Alternative 5

YG OG

NH CC CT CC GS VR CT NH CC Par

Roadless x - - - - - x - -

Phase I, II and III x x - - - - x x x

Roaded Roadless x - - - - - x - -

Beach Buffer x - - - x6 x x - -

Karst - High x - - - - - x -

Karst - Moderate & Low x x4 - - x x x

LUD - Non Development x - - x5 - - x - -

RMA outside TTRA Buffer x - - x5 - x x - -

Steep Slope, MMI 4 x - - - - - x - -

LUD - Modified Landscape x x - - x6 - x x x

LUD - Scenic Viewshed x x - - x6 - x x x

LUD - Timber Production x x - - - - x x X

*Relax CMAI on all acres and time periods

*FP Scenery Standards apply (Reg class constraints by VCU)

*YG use 2 log trigger

*If YG+OG > 46, then OG volume = 5, else OG+YG = 46

*Total harvest during transition <= 46

Table B-2.6

Compatibility Matrix Alternative 6 

(State of Alaska alternative – modeled, but not analyzed in detail)

YG OG

NH CC CT CC CT NH CC Par

Roadless x x - - - x x

Phase I, II and III x x - - - x x

Roaded Roadless x x - - - x x

Beach Buffer x - - - - - -

Karst - High x - - x x - -

Karst - Moderate & Low x x - x x x

LUD - Non Development x - - - x - -

RMA outside TTRA Buffer x - - - x - -

Steep Slope, MMI 4 x - - - x - -

LUD - Modified Landscape x x - - x x x

LUD - Scenic Viewshed x x - - x x x

LUD - Timber Production x x - - x x X

*95% CMAI on all acres and time periods

*No FP Scenery Standards in this alternative

*Total acreage in even-aged stands less than 150 years would be limited to 33% of the forested acres within 

a VCU. 

*If YG+OG > 46, then OG volume = 5, else OG+YG = 46

*Total harvest during transition <= 46
Appendix B

Final EIS B-17 Modeling and Analysis

Table B-2.7

Compatibility Matrix Alternative 7

(Conservation group alternative – two options modeled, but not analyzed 

in detail)

YG OG

NH CC CT CC CT NH CC Par

Roadless x - - - x - -

Phase I, II and III x x x x x x

Roaded Roadless x - - - x - -

Beach Buffer x - - - x - -

Karst - High x - - - x - -

Karst - Moderate & Low x - - x x x

LUD - Non Development x - - - x - -

RMA outside TTRA Buffer x - - - x - -

Steep Slope, MMI 4 x - - - x - -

LUD - Modified Landscape x x x - x x x

LUD - Scenic Viewshed x x x - x x x

LUD - Timber Production x x x - x x X

*Relax CMAI on all acres and time periods

*FP Scenery Standards apply (Reg class constraints by VCU)

*Short log min CC age = 55

*Long log min CC age = 65/75

*Transition ends @ 5 years-OG harvest levels out at 3.5 MMbf/year

*If YG+OG > 46, then OG volume = 5, else OG+YG = 46

*Total harvest during transition = 35

Model Implementation Reduction Factor Constraints (MIRF). These constraints are designed 

to accommodate for unmapped unsuitable lands that were missed during the suitability 

determination. It is assumed that when harvest activities occur, a certain percentage of the 

assumed suitable land will be off-limits for management due to several economic or ecological 

considerations. These constraints are applied to each old-growth volume strata of each of the six 

operability harvest systems as well as to young-growth stands. The constraint is implemented by 

forcing the model to never harvest a certain percentage of the acres in the model. The effect is to 

control the maximum amount of acres from the suitable land base that are actually harvested.

See below for a discussion of how MIRF factors were determined.

Dispersion and Adjacency Constraints. To meet visual quality and Regulation Class 

objectives, dispersion and adjacency constraints were incorporated into the models. “Dispersion” 

refers to spreading harvests across the landscape rather than focusing all activities in a 

concentrated area. The dispersion limits are taken from proxies developed by Tongass 

landscape architects for each LUD. These visual guidelines estimate how much of a viewshed 

can be "disturbed" at any one time and still meet the adopted scenic integrity objectives of the

area. They also specify length of time before harvest of adjacent units is permissible and the 

maximum size of these harvest units. Table B-7 (below) shows the constraints that were used for 

each Regulation Class. The “Visual Disturbance” factors were used in the constraints section of 

the model and the “Adjacency” definitions were defined in the outputs section of the model. 

Together, these two definitions (as well as treatment options available to each regulation class) 

distinguish the regulation classes in the model. Detailed information about these constraints is 

found in the “Regulation Class” section of this appendix (below).

Woodstock Solution Process

The following sections describe some of the steps involved in solving the Woodstock models. Following 

that is a brief discussion of how the Tongass evaluated economic efficiency of the alternatives. 
Appendix B

Modeling and Analysis B-18 Final EIS

Objective Functions

The objective function of a linear programming model allows the model to determine the “best” set of 

management actions that meet the constraints. It is generally expressed as a “minimize” or “maximize” 

function. The LP solution software finds the largest (or smallest) value possible of the objective function 

within the boundaries of the model constraints. Linear programming principles guarantee that the solution 

is optimal; that is, the best answer possible. Different objective functions were used to explore the 

Tongass management problem. While the “maximize present net value” objective function was used for 

the final results, the others were used at intermediate steps in the analysis process. Some of the objective 

functions used in the modeling process include:

Maximize Net Present Value. Present Net Value (PNV) is defined as the benefits less the costs of a 

management prescription, discounted at 4 percent annually to the present day, summed over all 

management prescriptions of all Analysis Areas. Because the model is formulated in 5-year time periods, 

discounting is done from the middle of each period. This is the objective function that was used for all 

final model runs presented in this FEIS. This ensures that the final harvest schedule is the most 

economically efficient approach to meeting the constraints with the available stands.

Maximize Discounted Timber Volume. Timber volume is tracked for each management action of each 

Analysis Area in each period. Each volume is discounted to the present and the total amount is 

maximized. The Woodstock model was used to determine how quickly the Tongass could transition to a 

sustainable timber sale program comprised primarily of young-growth harvest, and how high the younggrowth harvest could be, given the land allocation and other management constraints. Maximizing 

discounted volume ensured that the model had the incentive to get as much young-growth volume as 

possible, early in the harvest schedule. The non-declining yield constraint ensure that the young-growth 

harvest was sustainable, and allowed the harvest to increase over time as the young-growth age class 

distribution was regulated. The discount rate used for this calculation was 16 percent. This objective 

function was used only in the initial run. 

The solution process for each alternative consisted of making a set of Woodstock model runs designed to 

find the most cost efficient way to transition to a young-growth harvest program as rapidly as possible. 

The general procedure was as follows:

Initial Run - Determine the highest level of sustainable young-growth harvest, given the land 

allocation constraints. This model includes only the young-growth acres. Management regimes 

are limited to those compatible with the land allocation. Harvest is limited to non-declining flow –

harvest may increase from one period to the next, but may not decrease. The objective function 

maximizes discounted harvest volume. This run produces the highest level harvest in the early 

periods that is sustainable through time. 

First Old-growth Run – the old-growth acres are added to the model. Young-growth harvest is 

constrained to meet the level established in the initial run through the transition period. Oldgrowth harvest is constrained such that total harvest meets the target volume during the transition 

period (46 MMbf per year, in most alternatives). After the transition period, old-growth harvest is 

established at 5 MMbf per year. The maximize PNV objective function was used on this an all 

subsequent runs.

Intermediate Old-growth Runs – Constraints affecting the selection old-growth harvest are added 

sequentially to ensure that the model results are in the expected range. These constraints 

include the old-growth operability constraints, the constraints limiting the harvest of RegClass 3 

old-growth acres, and constraints limiting the harvest of high volume old-growth stands.

Final Run – All constraints are included and the model is run to maximize PNV. This ensures that 

the objectives and constraints are met in a cost efficient manner.

At each step, the Woodstock model results are evaluated to ensure that the solutions are consistent with 

the design of each Alternative.
Appendix B

Final EIS B-19 Modeling and Analysis

Iterative Process

The Woodstock model was used to test the assumptions and problem formulation strategies used in this 

analysis. The final solution for each alternative is often the result of several runs that were used to test to 

test the solution space given the land allocation constraints, and to observe the impact that the 

implementation constraints had on the solution. Early on, model runs were made to validate the model 

and compare it to previous models. A number of runs were made to test the solution space, especially 

around the question of potential young-growth harvest levels under different potential harvest policies.

Present Net Value 

Economic benefits from the Woodstock model were calculated as Present Net Value, or PNV, of the 

scheduled timber management activities. This calculation was done by the Woodstock model using pond 

log values and costs to the logger. The formula used to calculate the PNV of each potential management 

prescription is:

PNV = [PLV – LC]/(1 + d )

t

where:

PLV = pond log value (adjusted to exclude logger profit and risk)

LC = Logging costs (operability, haul, LTF, camp/commute, felling and bucking, road building)

t = time (year) of harvest into the future

d = discount rate (4% annually)

The dollar values of outputs used to calculate PNV in the Woodstock model are pond log values 

measured at mill sites less the profit and risk to the seller. The costs weighed against these values 

included all of the expenses incurred from removing the timber from the site to the mill (including logging 

costs, haul costs, LTF costs, road building costs, as described above in the Activities and Output

subsection). This is done to account for the variability in stumpage values that occur over such a large 

land area that is the Tongass National Forest. Stumpage value is the value of the timber at the site and is 

considered receipts to the federal government for a timber sale. In other words, it is what a purchaser will 

pay for the timber after considering all of the expenses (LC in the equation above) that are incurred in 

removing it to the mill. Stumpage, while not explicitly calculated before it is entered into the Woodstock 

model, it is an inherent part of the above equation [PLV – LC] that is calculated by Woodstock for all 

potential management prescriptions.

See the above section on Activities and Outputs for more detailed information on each of the costs and 

timber values used in the Woodstock model.

Supplemental Information on Other Model 

Assumptions

Stage II Suitability Analysis 

Each acre classified as suitable for timber harvest was analyzed to determine the costs and benefits for a 

range or management intensities (36 CFR 219.14(b)). For the purpose of this analysis, the planning area 

was stratified into categories of land with similar costs and returns according to the Analysis Area 

Identifiers described above. The stratification also took into account those factors that influence costs and 

returns such as physical and biological conditions of the site (affecting logging system) and transportation 

requirements (by VCU).

Stage II analysis is used to identify management intensities of timber production for each category of land 

that results in the largest amount of discounted net revenues. Stage II analysis provides insight into the 

overall economic condition of the suitable land base and what types of land are most cost efficient for 

management. The costs and benefits used for this analysis are described above and include pond log 
Appendix B

Modeling and Analysis B-20 Final EIS

value, the cost of logging, removing, and transporting the timber to the mill. This analysis does not 

account for the utility volume costs or revenues, as the current market conditions do not favor its removal.

Stage II analysis was conducted for all applicable management intensities: Intensive even-aged 

management with thinning regimes to very small clearcuts and group selection/patch cut prescriptions 

(regulation class 3 areas). 

The Regulation Class Process

To recognize the varying intensities of timber harvests that may occur on the landscape, the regulation 

class concept was developed. Regulation Class is a methodology developed to distill the unique 

combinations of Land Use Designation (LUD), Distance Zone (DZ), Scenic Integrity Objective (SIO), and 

Visual Absorption Capacity (VAC) into four management categories, or Regulation Classes. These

classes group lands that allow similar allowable harvest unit size, visual disturbance, and re-entry times 

(adjacency). Regulation Classes are numbered 0 to 3, with 0 being ineligible for management. Most of the 

following discussion is focused on Regulation Classes 1-3. 

Land Use Designation (LUD). For each alternative, a unique assignment and map of Land Use 

Designations was developed. Every Land Use Designation, or LUD, delineates a unique set of standards 

and guidelines that apply to that area. For each alternative, up to 19 LUDs were recognized, but only a 

subset of these were allowed to produce commercial timber that contributed to the PTSQ. Scenic 

Viewshed, Modified Landscape, and Timber Production LUDs were available in all alternatives and 

represent the primary LUDs for timber management. These three LUDs were evaluated in the Regulation 

Class process. In addition, several alternatives allow young-growth harvest in specific natural setting 

LUDs, such as Old-Growth Habitat and Semi-Remote Recreation. See the supplemental alternative LUD 

maps, the alternative descriptions in Chapter 2 of the FEIS, and Chapter 3 of the Forest Plan for more 

specific information on LUDs.

Distance Zone (DZ). The amount of allowable timber harvesting also is affected by distance zone (DZ). 

Distance zone is the proximity of an area to a view-point. Distance zone varies from Foreground (within a 

0.25 mile), Middle Ground, Background, to Seldom Seen, which is completely out-of-view from selected 

viewing points. Again, available treatment intensity is usually greater on lands with more hidden Distance 

Zones.

Scenic Integrity Objectives (SIO). Scenic Integrity Objectives are a function of LUD and Distance Zone 

and describe the desired quality of the scenery to be maintained in each classification. The categories 

include “High,” “Moderate,” “Low,” and “Very Low” objectives. Further description of SIOs is found in the 

“Scenery” section of Chapter 4 in the Forest Plan. SIOs for each of the LUD/Distance Zone combinations 

in the development LUDs are shown in Table B-3.

Visual Absorption Capability (VAC). The VAC is a measure of an area's ability to "absorb" (make 

visually less noticeable) ground disturbing activities (i.e., timber harvesting). VAC is simplified to three 

categories: Low, Interim, and High. VAC is used to define the intensity of management treatments that 

can be used to maintain each SIO. Generally, areas with greater VAC can sustain a more intensive 

treatment while still maintaining the desired SIO. Table B-4 shows the management unit size allowed for 

each SIO/VAC combination.

Tongass landscape architects developed some general timber harvesting guidelines, or proxies, for 

various VACs, SIOs, and LUDs. Although the exact harvest intensity an area receives is determined 

during the timber sale layout stages, estimates of allowable disturbance were needed in order to facilitate 

modeling. Each LUD has a series of adopted SIO and VAC objectives. Associated with these objectives 

are the estimated allowable disturbance factors. The proxies for each LUD and SIO/VAC setting were 

grouped by similar harvest method and unit size, cumulative visual disturbance, and height to adjacent 

stand criteria. Grouping the proxies of similar standards resulted in the creation of four distinct 

categories. These groups became the four regulation classes used in Woodstock modeling. These 

groups range from no harvest allowed to large clearcutting with minimal visual concerns. The GIS is then 

used to provide Woodstock with the regulation class allocations by alternative for each Analysis Area. 

Table B-5 summarizes the approximate disturbance factors by LUD, Distance Zone, SIO, and VAC.
Appendix B

Final EIS B-21 Modeling and Analysis

Table B-3

SIO for Distance Zone/LUD from Scenery Standards and Guidelines for Development 

LUDs

LUD Foreground Middle Ground Background Not Seen

Scenic Viewshed Retention Partial Retention Partial Retention Max Modification

Modified Landscape Partial Retention Modification Modification Max Modification

Timber Production Modification Max Modification Max Modification Max Modification

Table B-4

Maximum Unit Size based on Visual Absorption Capability

SIO Low VAC Interm. VAC High VAC

High < 2 5-15 15-30

Moderate 5-10 15-40 40-60

Low 15-40 40-60 80-100

Very Low 50-75 80-100 80-100

The percentages in Table B-5 are rough estimates intended to depict the possible level of disturbance 

one may encounter when viewing these areas. For modeling purposes, these visual disturbance zones 

were aggregated into groups with similar standards and economic response (e.g., logging costs). 

Because the percent of visual disturbance includes all visible terrain, tests had to be conducted to 

“recalculate” disturbance thresholds since only suitable lands are being modeled. These tests involved a 

series of iterative mapping exercises where varying levels disturbance factors were applied to the 

separate groups. The feasibility of the harvest level was then compared to the standards and guidelines 

and reviewed by Tongass National Forest landscape architects. This work was conducted under the 

following assumptions:

1. The items in the database (e.g., distance zone, visual absorption capability) were correct,

2. The standards and guidelines are modeled to their limits, and

3. The “viewshed” was a large area (e.g., as viewed from a boat).

This work indicated a need to further review the scenery components of the database but in general the 

process worked well in terms of modeling the intent of the standards and guidelines. This work resulted 

in three distinct regulation classes that permit timber harvest activities. The final allocation of regulation 

classes to the various disturbance zones is shown in Table B-6.
Appendix B

Modeling and Analysis B-22 Final EIS

Table B-5

Percent Allowable Visual Disturbance

Land Use

Designation

Distance

Zone SIO

Low

VAC

Interm.

VAC

High

VAC

Scenic Viewshed Foreground H 8 10 10

Mid. Ground M 8 15 20

Background M 20 20 20

Not Seen VL 20 20 20

Modified Landscape Foreground M 8 15 20

Mid. Ground L 15 20 25

Background L 25 25 25

Not Seen VL 25 25 25

Timber Production Foreground L 15 20 25

Mid. Ground VL 50 50 50

Background VL 50 50 50

Not Seen VL 50 50 50

1H = High, M = Moderate, L = Low, VL = Very Low

Table B-6

Regulation Class Allocation

Land Use

Designation

Distance

Zone SIO1

Low

VAC

Intermediate

VAC

High

VAC

Scenic Viewshed Foreground H 3 3 2

Mid. Ground M 3 3 2

Background M 3 2 1

Not Seen VL 1 1 1

Modified Landscape Foreground M 3 3 1

Mid. Ground L 2 2 1

Background L 2 1 1

Not Seen VL 1 1 1

Timber Production Foreground L 2 2 1

Mid. Ground VL 2 1 1

Background VL 1 1 1

Not Seen VL 1 1 1

1H = High, M = Moderate, L = Low, VL = Very Low

There are two main components of scenery constraints applied to the Regulation Classes in each VCU:

the total visual disturbance and adjacency considerations. Total visual disturbance is the percent of land 

within a viewshed (VCU) that is classified as disturbed (Table B-7). Adjacency refers to the amount of 

time required before a harvest unit can be placed immediately next to an existing harvest unit (often 

referred to as the “green-up” period). These constraints are shown in Table B-7.

There are several important things to remember regarding the above table:

1. Disturbance percent is applied to suitable lands only, not the entire viewshed.

2. These values are entered into the models as constraints for each VCU.

3. The disturbance and adjacency factors for Regulation Class 3 are based on the use of small 

patch cutting (less than 2 acres). Optimally, disturbance and adjacency would not be an issue 

with carefully planned uneven-aged management (i.e., partial stand removal). 
Appendix B

Final EIS B-23 Modeling and Analysis

Variation by Alternative. Because LUD is one factor in determining Regulation Class, the breakdown of 

each of the seven alternatives into regulation class was recalculated for each alternative. A GIS map of 

Regulation Class was developed and used to intersect with the other layers used in Analysis Area 

development. Regulation Class was then used as an attribute to help define Analysis Areas.

Table B-7

Generalized Visual Constraints

Regulation Class Visual Disturbance Adjacency

Regulation Class Visual Disturbance Adjacency 

1 40% 20 Years

2 30% 35 Years

3 20% 50 Years

Model Implementation Reduction Factors (MIRF)

To reiterate what was stated in the “Constraints” section (above), the use of MIRF is designed to 

accommodate for unmapped unsuitable lands that cannot be directly eliminated from the suitable land 

base but should be. It is known that when harvest activities occur, a certain percentage of the assumed 

suitable land will be ineligible for management (unsuitable) due to a number of physical, biological, or 

economic considerations. However, reasonable assumptions can be made to estimate the average 

amounts of these elements on the ground. Their effect on actual suitable land can be incorporated into 

the Woodstock model as constraints. Constraints are applied to each old-growth volume strata of each of 

the six operability harvest systems as well as to young-growth stands. The constraints are implemented 

by forcing the model to never harvest a certain percentage of the acres in the model. The effect is to 

control the maximum amount of acres from the “pre-MIRF” suitable land base that are actually harvested. 

A discussion of these elements and their estimated amounts follows.

MIRF Elements. Each of the nine MIRF subfactors used in the 1997 FEIS (Riparian Habitat was 

previously divided into two subfactors so there were 10 identified in 1997) was re-evaluated for the 2008

FEIS. This review was conducted again for the current Forest Plan Amendment EIS and it was decided to 

leave the subfactors alone, as defined for the 2008 FEIS. A detailed description of the derivation of MIRF 

is presented in Appendix B of USDA Forest Service (2008). Each of the subfactors and their values are

described in the following paragraphs.

Land Selections – This subfactor is the reduction in suitable lands due to the conveyance of selected 

lands to the State of Alaska and Native interests. In 2008 the value of this subfactor was calculated as 

1% for old growth and young growth. Public Law 113-291 significantly affects the number of acres to be 

conveyed in the future; however, because the factor is already small and because it is believed that the 

percentage of suitable in remaining acres of potential conveyance lands could be larger than previously 

assumed, it was left alone.

TTRA Stream Buffers – This subfactor estimates the reduction in the suitable land base due to unmapped 

Class I and II stream buffers. It is assumed that the percentage reduction due to this subfactor is 2% for 

old growth and 1% for young growth. 

Non-Commercial Forest – This subfactor estimates the reduction in the suitable land base due to volume 

class mapping errors. It is associated with the low-volume stratum and is defined as the net percent 

change in suitable acres due to low-volume productive old growth (POG) being mapped as noncommercial (unsuitable) and non-commercial forest being mapped as low-volume POG. It is estimated 

as a 10% reduction in suitable for old growth and no reduction for young growth.

Slope/Soil Hazard – This subfactor estimates the reduction in the suitable land base due to unmapped 

steep slopes. It represents the additional acreage of steep slopes identified during project 

implementation that is not already mapped, divided by the mapped suitable acres. This subfactor varies 

according to administrative area: the Chatham MIRF for this subfactor is estimated at 26% for old growth 
Appendix B

Modeling and Analysis B-24 Final EIS

and 10% for young growth and the Ketchikan and Stikine MIRFs are estimated at 1% for both old growth 

and young growth.

• Cost Efficiency – This subfactor excludes the stands with the lowest economic potential from the 

suitable land base. It varies with operability class and volume stratum and the reduction is 

estimated at 25% for Difficult/Low Volume and Isolated/Medium Volume and 50% for 

Isolated/Low Volume. For young growth, no reduction is assumed.

Riparian Habitat (Class III streams) – This subfactor estimates the reduction in the suitable land base due 

to unmapped Class III stream buffers. It is estimated at 8% for old growth and 4% for young growth.

Karst/Caves – This subfactor estimates the reduction in the suitable land base due to a change in karst 

classification from low – moderate to high vulnerability. This subfactor varies according to administrative 

area: the Ketchikan, Stikine, and Chatham reductions are estimated at 6%, 0%, and 1% for old growth 

and 3%, 0%, and 1% for young growth, respectively.

• Remaining Standards and Guidelines – This subfactor estimates the reduction in the suitable land 

base due to unmapped eagle/osprey nests, goshawk nests, murrelet nests, wolf dens, goat 

habitat, and other factors. It is estimated at a 1% reduction for both old growth and young growth.

Overall Results. The sum of these subfactors produces the overall MIRF for each category 

(Administrative Area, volume strata, operability class). MIRFs were applied identically for all alternatives. 

Specific calculated MIRF values are in the planning record. The range of MIRFs (varying with operability 

class) for the different volume strata and Administrative Areas are as follows:

Low Volume Medium Volume High Volume

Chatham 49% – 99% 39% – 64% 39%

Stikine 23% – 73% 13% – 38% 13%

Ketchikan 29% – 79% 19% – 44% 19%

Estimation of Past and Future Harvest and Road 

Construction for Effects Analysis

The quantification of the direct, indirect, and cumulative effects of the alternatives on fish, wildlife, plants, 

and other resources was based heavily on the estimation of past and future harvest of old growth and 

young growth and the amount of road construction. These tasks were conducted for both National Forest 

System (NFS) and non-NFS lands. This section describes the process followed and the major 

assumptions.

Estimation of Past and Future Harvest

The estimation of the direct, indirect, and cumulative effects of the alternatives on POG habitats and the 

fish, wildlife, and plants that use these habitats required three major steps. First, it was necessary to 

assemble the inventory of existing vegetation on both NFS and non-NFS lands. The second step was the 

estimation of the original POG (existing in 1954, prior to large-scale commercial timber harvest) on NFS 

and non-NFS lands and the classification of this original POG into POG types for the purpose of 

evaluating the level of disproportionate past harvest. The third step was the estimation of future harvest 

and the amount of POG in various POG categories that would be remaining after future harvest on NFS 

lands under each alternative, and for all lands combined, including factors for future harvest on non-NFS 

lands. 

Vegetation Inventory 

For NFS lands, the existing vegetation information from the Tongass Geographic Information System 

(GIS) library was used. Specifically, the Size Density Model (SDM) (see Affected Environment in the 

Biodiversity section) was used for the classification of existing vegetation on the Tongass. Using this 
Appendix B

Final EIS B-25 Modeling and Analysis

model, POG is defined by seven old-growth types: SD67, SD5N, SD5S, SD5H, SD4N, SD4S, and SD4H. 

Young growth is defined by six types, depending on the approximate age and origin of the stand; natural 

young growth (e.g., young growth originating from blowdown) is divided into three types (S1, S2, and S3) 

and young growth that originated from timber harvest is classified into three types (HS1, HS2, and HS3). 

It is noted that the stands covered by these young-growth categories are not all even-age stands. Younggrowth under even-aged management was identified separately using harvest activity information.

For non-NFS lands, a number of sources of information were used to produce the most updated and 

accurate mapping available for non-NFS lands in Southeast Alaska. These sources included:

• Sealaska Regional Corporation provided updated GIS layers for vegetation and harvest on their 

lands throughout Southeast Alaska; these layers were used for mapping all Sealaska lands.

• The State of Alaska provided GIS layers for harvesting on state lands in Southeast Alaska. 

These layers were used for most state lands.

• Audubon Alaska and The Nature Conservancy completed a conservation assessment for 

Southeast Alaska (Albert and Schoen 2007) that included the development of a reasonably 

accurate vegetation map of the entire region based on Tongass GIS vegetation data (SDM 

mapping), augmented with timber inventory data from Haines State Forest and with classified 

Landsat Multi-spectral Scanner (MSS) imagery from the Interim Landcover Mapping Program of 

the U.S. Geological Survey, and 1997 aerial photography. This mapping was used for most of 

the remainder of Southeast Alaska.

• Forest Service orthophotography and aerial photography was interpreted in some areas to fill in 

gaps in the above layers.

• The Working Forest Group provided more recent southeast Alaska harvest mapping.

Based on the above information, a Catalogue of Past Harvest for all of Southeast Alaska was developed 

that itemizes the acres harvested for each land ownership category, landowner, and biogeographic 

province, and breaks this harvest down by approximate decade, where the decade of harvest is known or 

can be reasonably estimated. In addition to the spatial information described above, statistics on the 

implementation of the Alaska Forest Resources and Practices Act and information on State timber sales 

in Southeast Alaska were collected from the Alaska Department of Natural Resources, Division of 

Forestry. This information is presented in Appendix C.

Original POG by Category

Next, the original POG was estimated on NFS and non-NFS lands in each biogeographic province and 

ecological subsection by category. This was done for the purpose of evaluating the level of 

disproportionate past harvest. 

Original POG is defined in this EIS as the POG that existed, outside of the developed areas associated 

with towns, prior to all mapped timber harvest. Therefore, all young growth originating from timber 

harvest (mapped as HS1, HS2, and HS3 on NFS lands) was assumed to be original POG. Natural young 

growth (mapped as S1, S2, and S3 on NFS lands) was assumed to be in a steady state of succession 

and replacement; therefore, it was not assumed to be original POG. On the Tongass, about 570 acres of 

young growth were mapped as having been harvested between 1750 and 1900 and a total of about 

10,800 acres were mapped as having been harvested after 1900 but prior to 1954, which is generally 

accepted as the approximate year that large-scale logging began. The vast majority (about 410,200 

acres on the Tongass) of the harvest occurred from 1954 through the present. In addition, about 39,000 

additional acres are mapped as young growth, but do not have a year of origin. These stands are 

primarily partial cut stands and are considered in the identification of original POG.

In addition to total POG (represented by the seven SDM types), two other categories of POG were used 

to represent the larger tree types: high-volume POG, which includes the three types with the largest trees 

(SD5S, SD5N, SD67), and large-tree POG, which is defined as SD67 by itself. To estimate original high 

volume- and large-tree POG, an estimate was first made of the percentage of past harvest in these 
Appendix B

Modeling and Analysis B-26 Final EIS

categories using the SizeDensity1954 layer, which was based on timber type mapping from the mid1980s and other GIS layers. The following compositions of harvest were conservatively determined for 

NFS and non-NFS lands:

• For NFS lands, prior harvest was estimated to have been 30 percent large-tree POG and 75

percent high-volume POG.

• For non-NFS lands, prior harvest was estimated to have been 37 percent large-tree POG and 65

percent high-volume POG.

Future Harvest

The estimation of future harvest on non-NFS lands was made by examining the amount of POG 

remaining on these lands and making reasonable assumptions regarding the percentage of that POG that 

would be harvested in the future. It was conservatively estimated that 60 percent of all existing POG on 

state, private, other federal, and other non-NFS lands would be harvested within 100 years. All existing 

young growth and future harvest are expected to be harvested in the future and remain as young-growth.

Estimation of Past and Future Road Construction

The estimation of the direct, indirect, and cumulative effects of the alternatives associated with road 

construction required two major steps. First, it was necessary to assemble the inventory of existing roads 

on both NFS and non-NFS lands. The second step was the estimation of future road development for 

NFS lands under each alternative, and for all lands combined, including factors for future road 

development on non-NFS lands. 

Road Inventory 

For NFS lands, the existing road information from the Tongass GIS library was used. The “roads with 

core attributes RSW” layer was used for the inventory of system roads and the definition of maintenance 

levels to determine whether they were open or closed. The “non-routed other roads” layer was used to 

estimate additional unauthorized roads. For non-NFS lands, existing roads were inventoried using the 

following sources:

• Tongass GIS non-routed other roads layer, which contains most roads on non-NFS lands.

• Mapping of roads on Sealaska lands provided by Sealaska Regional Native Corporation.

• GIS layers for roads on many non-NFS lands in Southeast Alaska provided by State of Alaska. 

• Other available GIS layers (e.g., ESRI’s StreetMap) were used for urban and rural areas around 

towns and settlements.

• Orthophoto and aerial photograph interpretation were used to “fill in holes” in other sources.

Based on input from the State of Alaska, it was assumed that half of the non-NFS road miles would 

remain open and half would

Future Road Construction and Reconstruction

Future road construction/reconstruction assumptions were different for old-growth versus young-growth 

harvest. The ratios derived are based on a review of Big Thorne and other recent timber sale projects. 

For young growth, it was first assumed that 100% of all Maintenance Level 1 (ML 1) roads (closed roads)

would be reconstructed if all young growth on the Forest were to be harvested. Then the miles of 

reconstruction for each alternative was extrapolated from this by using the proportion of young-growth to 

be harvested in that alternative. In addition, it was assumed that in some young-growth stands, 

construction of new roads would have less impact than reconstruction of old roads; thus an additional one 

mile of new road per 400 acres of young-growth harvest and one mile of new road over previously 

decommissioned road per 600 acres of harvest was assumed. It was also assumed that 10% of new 
Appendix B

Final EIS B-27 Modeling and Analysis

roads and new roads over decommissioned road grades would remain open, while the remaining 90% 

would be closed.

For old-growth harvest, future road construction was estimated based on the ratio of one mile of new road 

construction per 150 acres of harvest plus one mile of new road construction over previously 

decommissioned road grade per 800 acres of harvest. In addition, one mile of road reconstruction per 

300 acres of harvest was assumed. Further, it was assumed that 10% of new roads and new roads over 

decommissioned road grades would remain open, while the remaining 90% would be closed. 

On non-NFS lands, future increases in road density were projected after examining existing road 

densities and making reasonable assumptions regarding the additional road density that would be 

developed in the future. Estimates were conservatively high. Existing road density on non-NFS lands is 

2.29 miles per square mile and the assumption was made road densities would increase by 1.3 miles per 

square mile within 100 years. All future non-NFS roads were assumed to remain open.

Deer Model Assumptions and Application

Interagency Deer Model

Forest Plan standards and guidelines require the use of the most recent version of the interagency deer 

winter habitat capability model to assess impacts to deer habitat (WILD4.XIV.A.2; USDA Forest Service 

2008a). The interagency deer model was used in the EIS to (1) evaluate changes in deer winter habitat 

capability under each alternative, and 2) estimate the number of WAAs across the Tongass that meet the 

18 deer per square mile index under the wolf standards and guidelines under each alternative. 

The deer model was run for historic (1954) and current conditions, and to assess effects in 25 years 

(when harvested stands would reach the stem exclusion stage) and in 100 years (to encompass longterm effects over the planning horzon). Changes in winter habitat capability under the alternatives were 

based on comparisons to existing conditions for the analysis of direct effects (NFS lands only). For the 

analysis of cumulative effects changes in deer habitat capability were compared to historic (1954) 

conditions, the point at which large-scale timber harvest began (NFS and non-NFS lands). Analyses 

were run at the WAA scale, as this is the land division used by the ADF&G for deer inventories and 

planning, and the biogeographic province scale. 

For the 2008 Forest Plan EIS a cross-walk was developed to reclassify the SDM model into the deer 

model vegetation categories (high-, medium-, low-volume old-growth). High-volume stands included

SDM vegetation categories SD5N, SD5S, and SD67; medium volume stands include SD4N, SD4S, and 

SD5H; and low volume stands include SD4H. HSI scores from this model range from 0 to 1.3 but were 

standardized to range from 0 to 1.0 by dividing all values by 1.3, because outputs from such models 

represent a range from 0 to 100 percent habitat suitability, with higher values indicating higher habitat 

capability. Greater details are documented in the project planning record.

To estimate 1954 winter habitat capability, it was necessary to “grow back” the vegetation in previously 

harvested units. For this purpose, the recently developed volstrata1954 layer was used, which covered 

NFS and non-NFS lands. For all existing and future estimates on non-NFS lands deer habitat capability 

was set at zero, in order to be conservative and given that good quality and updated vegetation data in 

the correct format does not exist for non-NFS lands.

Future winter habitat capability was based on maximum timber harvest after full implementation of the 

Forest Plan under each alternative. For POG, it was assumed that the harvested acreage would be in the 

stand initiation (I) stage of stand development for 25 years and then remain in the stem exclusion stage 

(E) of stand development until it was harvested again. Intermediate stand treatments such as precommercial and commercial thinning are not reflected in the interagency deer model results because the 

model only assigns one value to harvested stands. That is, the model does not account for the conversion 

of stands currently in the stem exclusion stage back into the stand initiation stage, or account for the 

potentially beneficial effect of thinning treatments on deer winter habitat capability.
Appendix B

Modeling and Analysis B-28 Final EIS

To describe existing conditions, an estimate of the percentage of 1954 habitat capability currently 

remaining was calculated by dividing the current HSI score for each WAA and biogeographic province by 

the 1954 HSI score. Likewise, to evaluate the effects of the alternatives, the future HSI score was divided 

by the current HSI score (direct and indirect effects) or by the 1954 HSI score (cumulative effects) for that 

WAA or biogeographic province, respectively. This was done at the 25- and 100-year time steps.

Modeled deer densities, in terms of deer per square mile, were calculated to evaluate the ability of the 

alternatives to comply with the wolf standard and guideline of maintaining habitat sufficient to support 18 

deer per square mile. For this analysis, habitat capability in terms of modeled deer density was 

calculated by assuming a density of 100 deer per square mile for an HSI of 1.0. Only WAAs where 

wolves potentially occur (GMUs 1, 2, 3, and 5) were included and WAAs with naturally very low deer 

densities (WAAs 4302-4607) were excluded from the analysis. 

FRESH Deer Model

The Forage Resources Evaluation System for Habitat (FRESH) model developed by the USDA Forest 

Service Pacific Northwest Research Station (Hanley et al. 2012) was also used to quantify the value of 

available deer habitat in the planning area (http://cervid.uaa.alaska.edu/deer/Home.aspx). The FRESH 

model is a food-based model that takes into account the quantity (biomass) and quality (digestible energy 

and digestible protein, two of the most common nutritional limiting factors for deer) of the available food 

resources in relation to user-specified metabolic requirements of deer (which depend on age, sex, 

season, and reproductive status). The model uses a linear algorithm to determine the suitable forage that 

can sustain deer at this metabolic requirement, and produces the number of deer days per unit area that 

the available food resources (within the habitat patch or landscape) are capable of supporting. One deer 

day represents the food required to support one animal for one day at the specified level of nutritional 

requirements. The output of the model is a “snapshot” of habitat conditions at one point in time which can 

be used to make a relative comparison of conditions within a habitat patch or landscape under different 

conditions (i.e., before and after implementation of a management activity). 

Values for the available forage biomass and its nutritional quality (digestible energy and digestible protein 

concentrations) on the Tongass were based on a variety of sources including the Tongass Wide YoungGrowth Study (2007, 2008, 2010, 2011, 2012, 2013), Prince of Wales Commercial Thin Study (Forest 

Sciences Lab Juneau 2014, unpublished), 2011 Tongass Young-growth Inventory (2011), Second Growth 

Management Project, Size-Density Accuracy Assessment and other unpublished studies from southeast 

Alaska (see the Project Record for more information). It is assumed that all available vegetation is 

potential food, and there is no accounting for long-term herbivore-plant dynamics (i.e., the effects of 

overbrowsing; Hanley et al. 2012). Thinning and logging slash have the potential to inhibit deer access; 

however, the current body of literature does not provide sufficient information for making adjustments to 

FRESH model output to reflect these limitations.

For this analysis, forage resources were analyzed with the GIS-based model application for the winter 

season. Spatial results from the Woodstock model were used directly in the GIS-based model. Deer 

metabolic requirements for winter were the following: dry matter digestibility directly 48 percent, digestible 

protein 1.8 percent and dry matter intake 525 g/day (see Hanley et al. 2012 for rationale and sources). 

The FRESH model requires an estimate of snow depth on February 1 at sea level in a level open area. 

To reflect the geographic variation in snow depth in Southeast Alaska, the planning area was divided into 

six snow zones with average snow depth estimated for each under current climate conditions. Climate 

data from 1981-2010 were used to model PRISM-based “precipitation as snow” which was then 

converted to snow depth using the relationship of snow depth and elevation in the FRESH model snow 

sub-model (see metadata in the project record for additional information). The FRESH model then 

reduces the biomass of each forage in proportion to its height profile that is “buried” in snow (see Hanley 

et al. 2012 for details).
APPENDIX C

CUMULATIVE EFFECTS
Appendix C

Final EIS C-i Cumulative Effects

Appendix C

Cumulative Effects

CONTENTS

Introduction ............................................................................................................................................... C-1

Assumptions.............................................................................................................................................. C-1

Timeframe for Analysis ............................................................................................................................. C-1

Analysis Area ............................................................................................................................................ C-1

Relevant Past, Present, and Reasonably Foreseeable Actions ............................................................... C-2

TABLES

Table C-1 Past Actions and Projects Considered in Cumulative Effects Analyses ............................ C-3

Table C-2 Present and Reasonably Foreseeable Actions and Projects Considered in Cumulative 

Effects Analyses................................................................................................................. C-8

Table C-3 Interactions Between Resources and Actions or Projects ............................................... C-22

ATTACHMENT

Attachment 1 Catalog of Past Harvest
Appendix C

Final EIS C-1 Cumulative Effects

Appendix C

Cumulative Effects

Introduction 

Cumulative effects are defined in the Council on Environmental Quality (CEQ) regulations as “the impact 

on the environment which results from the incremental impact of the action when added to other past, 

present, and reasonably foreseeable future actions regardless of what agency (Federal or non-Federal) 

or person undertakes such other actions. Cumulative impacts can result from individually minor but 

collectively significant actions taking place over a period of time” (40 CFR 1508.7). Cumulative actions 

are defined as “actions, which when viewed with other proposed actions, have cumulatively significant 

impacts and should therefore be discussed in the same impact statement” (40 CFR 1508.25). 

Cumulative effects are discussed in detail for each resource in the Environmental Impact Statement (EIS). 

This document discusses the projects considered and records which projects were considered for each 

resource.

Assumptions 

Projects and actions included int the cumulative effects analysis were identified by reviewing past 

records, reviewing scoping comments, interviewing knowledgeable individuals, analyzing the existing 

condition of the project area using the Tongass and other geographic information system (GIS) layers, 

reviewing current plans, and, where necessary, making reasonable assumptions. These assumptions 

sometimes permit quantitative assessments.

Major assumptions used in this analysis are documented in Appendix B of the EIS, which also documents 

assumptions used for analyzing direct and indirect effects. Many of these assumptions are related to past 

and reasonably foreseeable timber harvest and road construction and reconstruction.

Timeframe for Analysis

The timeframe for this cumulative effects analysis encompasses past and future activities. Past activities 

include timber harvest and other activities that date back over 70 years, while future activities consider 

timber harvest at 25 years into the future, as well as at 100 years in the future. Most other future activities 

can only be considered as reasonably foreseeable about 25 years into the future because of uncertainties 

beyond that point.

Analysis Area

The area considered for cumulative effects analyses varies according to the resource being assessed. 

For most aquatic or watershed-related resources, the area within the proclaimed Forest boundary 

(approximately 17.9 million acres, including 1.2 million acres of non-National Forest System [NFS] lands) 

is used. For aquatic and watershed-related resources, this area is subdivided by 6th-field watersheds. 

For wildlife and other terrestrial resources, all of Southeast Alaska from Yakutat Bay southeast to the 

southeastern end of Alaska (approximately 21.6 million acres, including 4.8 million acres of non-NFS 

lands) is used as the study area for some analyses, although some analyses are based on the area within 

the Forest boundary, depending on the availability and quality of information. The Southeast Alaska area 

includes all of Glacier Bay National Park and the State, Bureau of Land Management, and other lands in 

the vicinity of Haines and Skagway. Often Wildlife Analysis Areas (WAAs) are used to summarize 

information within these study areas. In addition, biogeographic provinces are used to summarize 

cumulative effects information for biodiversity and some wildlife resources. For social and economic, 

recreation, and related human uses, all of Southeast Alaska and beyond, is given consideration for 

cumulative effects, especially regarding economic, market, and other factors.
Appendix C

Cumulative Effects C-2 Final EIS

Relevant Past, Present, and Reasonably Foreseeable Actions

Based on a review of published material and available information about the Tongass National Forest and 

adjoining lands on various agency websites and the scoping process, an initial list of existing, proposed, 

and reasonably foreseeable actions was compiled to be assessed for inclusion in this cumulative effects 

evaluation. Resources drawn from include the Forest Service Schedule of Proposed Actions (SOPA)

report, April 2015 through March 2015 (Forest Service 2015); Tongass Integrated Plan (TIP) 2015-2019; 

the Alaska Department of Transportation and Public Facilities Project Statewide Transportation 

Improvement Program and Southeast Alaska Transportation Plan (ADOT&PF 2004, 2014); the Energy 

Resource Report for the Tongass National Forest (Tetra Tech 2015) the results of the scoping process, 

and other sources. In the case of timber harvest, this cumulative effects analysis attempts to quantify the 

effects of past human actions by adding up all prior actions on an annual or decadal basis (see 

Attachment 1). It also examines other past projects, but most importantly, by looking hard at current 

conditions, residual effects of past human actions and natural events are captured, regardless of which 

particular action or event contributed those effects. The Council on Environmental Quality issued an 

interpretive memorandum on June 24, 2005 regarding analysis of past actions which states, “agencies 

can conduct an adequate cumulative effects analysis by focusing on the current aggregate effects of past 

actions without delving into the historical details of individual past actions.” For these reasons, the 

primary method of analyzing past actions is based on the cumulative change in environmental conditions 

to the present, as described in the affected environment sections of the EIS. To keep the cumulative 

effects analysis useful, manageable, and concentrated on the effects that are meaningful, greater effort is

given to future activities that are more certain and geographically close to the project with a focus on 

issues of greatest concern.

Table C-1 lists and describes the past projects and actions that are considered for analysis of cumulative 

effects. An updated catalog of past timber harvest is also provided in Attachment 1. Table C-2 lists the 

present and reasonably foreseeable projects and actions that are considered for cumulative analysis. 

Some projects or actions could be listed as past and present, as well as reasonably foreseeable (e.g., a 

currently operating mine that was built 20 years ago and is expected to continue operating into the 

reasonably foreseeable future). These projects are listed in Table C-2 and only completed projects or 

actions are listed in Table C-1. Table C-3 identifies the primary areas with potential interactions among 

the identified projects and actions and the primary resource areas.
Appendix C

Final EIS C-3 Cumulative Effects

Table C-1

Past Actions and Projects Considered in Cumulative Effects Analyses

Past Actions Location Year(s) Description

Climate Change and Natural Processes

Climate Change -

General

Throughout Southeast 

Alaska

Past 25 

years

Some climate models for Southeast Alaska have predicted rising temperatures, a 10 

percent decrease in summer precipitation in portions of the region, and decreased soil 

moisture due to increased evaporation during warmer, dryer summer weather. These

climate change-related processes may have already been initiated.

Yellow Cedar Decline Primarily in a wide band 

from western Chichagof 

and Baranof Islands to the 

Ketchikan area

Past 50 

years

Yellow-cedar decline and mortality, has dramatically changed many of the forests of 

Southeast Alaska and this decline is believed to have been climate related. Aerial 

surveys have mapped approximately 585,000 acres of decline in a wide band from 

western Chichagof and Baranof Islands to the Ketchikan area (USDA Forest Service and 

ADNR 2015). In 2014, approximately 20,000 acres of dying (i.e., active decline) yellowcedar trees were mapped (USDA Forest Service and ADNR 2015). 

Fire Throughout Southeast 

Alaska

Historical Because of high precipitation levels, fire has not been a major factor in shaping the forests 

of Southeast Alaska. However, approximately 400 to 500 acres have burned annually on 

the Tongass. 

Insects and Disease Throughout Southeast 

Alaska

Historical A range of insects and diseases have taken their toll in Southeast Alaska forests; 

however, their severity has varied substantially over the years. Surveys have documented 

that individual insect pest species typically affect a few thousand acres to hundreds of 

thousands of acres each year. In addition to insects, stem decays cause substantial loss 

in all tree species in unmanaged stands. Tree death and stem breakage resulting from 

decay contribute to the structural diversity in stands and may be a major factor in smallscale disturbance in Southeast Alaska (Hennon and McClellan 2003). Dwarf mistletoe 

has also had high infestation levels in many hemlock stands below 500 ft in elevation 

(Shaw and Hennon 1991, Shaw et al. 2008). 

Windthrow Events Throughout Southeast 

Alaska

Historical Small-scale windthrow events are very common throughout Southeast Alaska forests. 

These small events involve individual trees or small groups of trees. The open gaps in 

the canopy that result, allow young trees to colonize and fill the openings. Therefore, 

over time, complex, mixed-aged stands are produced. Insect and disease infestations are 

major contributing factors. These small-scale openings cover about 6 to 13 percent of 

Southeast Alaska forest canopies (Nowacki and Kramer 1998). Areas not protected by 

topographic barriers from the severe effects of infrequent, major storms are subject to 

large-scale windthrow events that cause catastrophic damage. Entire stands have blown 

down in the past, resulting in the regeneration of more even-aged stands with more 

uniform canopies (Nowacki and Kramer 1998). Both forms of windthrow are a part of the 

natural forest generation, growth, and development. Juday et al. (1998) concluded that 

there was a high risk of increased large-scale blowdown across Southeast Alaska as well 

as increased windthrow around harvest units as a result of climate change. 

Watershed Effects Throughout Southeast 

Alaska

Past 25 

years

Climate change effects on water quality, water quantity, and fish to date are not clear, if 

they have occurred at all.
Appendix C

Cumulative Effects C-4 Final EIS

Table C-1 (continued)

Past Actions and Projects Considered in Cumulative Effects Analyses

Past Actions Location Year(s) Description

Timber Harvest Activities 

Past Harvest –

Tongass National 

Forest

Throughout Southeast 

Alaska, but concentrated 

on Prince of Wales and 

adjacent islands with large 

portions on Wrangell, 

Mitkof, Kupreanof, Kuiu, 

Revillagiggedo, and 

Baranof Islands.

Mostly 

1954 to 

present

Approximately 462,000 acres of forest land have been harvested on the Tongass National 

Forest. Of these, about 422,000 acres were clearcut and are in even-aged management. 

Close to 70 percent of this harvest took place in the 1960s, 1970s, and 1980s; therefore 

the majority of young growth originating from harvest is 25 to 55 years of age. Less than 

10 percent is greater than 55 and less than 4 percent is greater than 65 years of age. 

Attachment 1 to this appendix is a Catalog of Past Harvest for Southeast Alaska and is 

broken down by ownership and year/decade. 

Past Harvest – State 

and Private Lands 

(non-NFS)

Throughout Southeast 

Alaska, wherever private or

state lands are present; 

mostly on Prince of Wales 

and adjacent islands, 

Kupreanof, and Baranof 

Islands.

Mostly 

1975 to 

present

Approximately 453,000 acres of forest land have been harvested on non-NFS lands within 

the Tongass National Forest boundary. The vast majority of this harvest took place in the 

1980s and 1990s, so it is mostly younger than the young growth on NFS lands. 

Attachment 1 to this appendix is a Catalog of Past Harvest for all of Southeast Alaska and 

is broken down by ownership and year/decade. 

Past Road 

Construction for 

Timber Harvest

Throughout Southeast 

Alaska, but concentrated 

on Prince of Wales and 

adjacent islands along 

Wrangell, Mitkof, 

Kupreanof, Kuiu, 

Revillagiggedo, Baranof, 

and other islands.

Mostly 

1950s to 

present

To date, approximately 9,351 miles of road have been constructed on the Tongass 

National Forest and adjacent non-NFS lands within the Tongass boundary; 5,093 miles are 

on NFS land and 4,258 miles are on non-NFS land. The vast majority of these roads were 

developed for timber harvest purposes although these miles include state highways and 

local roads, in and around communities. 

Of the 9,351 miles, about 6,101 miles are open roads (2,321 miles on NFS land and 3,780

miles on non-NFS land). The remaining 3,249 miles are either closed roads or 

decommissioned roads.

Past Log Transfer 

Facility (LTF)

Construction

Throughout Southeast 

Alaska, but concentrated 

on Prince of Wales and 

adjacent islands along 

Wrangell, Mitkof, 

Kupreanof, Kuiu, 

Revillagiggedo, Baranof, 

and other islands.

Mostly 

1950s to 

present

LTFs are used to transfer logs to barges or rafts for towing. About 116 LTFs currently exist 

on the Tongass and there are 55 marine access points suitable for transferring logs to 

barges that have current permits on NFS lands. Another 10 marine access points no 

longer have permits. In addition, there are about 126 LTFs on State land and another 

group of LTFs exist on private lands.

Land Adjustments

Misty Fjords National 

Monument Wilderness 

Inholdings

Ketchikan Misty Fjords 

Ranger District (KMRD)

2012 The 68-acre inholding located on the Eulachon River was acquired in 2012.
Appendix C

Final EIS C-5 Cumulative Effects

Table C-1 (continued)

Past Actions and Projects Considered in Cumulative Effects Analyses

Past Actions Location Year(s) Description

Public Law 113-291 Many parts of the Tongass, 

but especially Prince of 

Wales and adjacent islands

2015 Public Law 113-291 amended ANCSA and provided Sealaska Regional Corporation final 

Section 14(h)(8) ANCSA entitlement. On March 9, 2015, Sealaska Corporation received its 

final ANSCA entitlement and conveyance of 70,075 acres. This conveyance affected 

multiple areas, LUDs and ranger districts on the Tongass. Public Law 113-291 also 

amended Section 508 of ANILCA by adding 8 new LUD II areas, containing 152,000 acres. 

The new LUD II designations changed the previous LUD designations for these lands (both 

development and non-development LUDs) to LUD II. 

Other land adjustments Tongass-wide Prior to 

2015

National Forest System Lands have been conveyed to Non-Federal parties under the 

Native Allotment Act, Alaska Native Claims Settlement Act (ANCSA), Alaska National 

Interest Lands Conservation Act (ANILCA) and other authorities. 

Mining 

Various Mines Tongass-wide From 

1867 to 

present

Mining history in Southeast Alaska dates back to the first mineral location in 1867, prior to 

the existence of the Tongass. During the late 1800s, gold was discovered in Southeast 

Alaska and mining ventures began to pop up. Historic mines include the Treadwell Mine 

and the Alaska Juneau Mine in Juneau; the Kensington and Jualin mines north of Juneau 

(recently reopened); the Ross-Adams uranium mine on Prince of Wales Island; the 

undeveloped Quartz Hill molybdenum deposit in the non-Wilderness Misty-Fjord National 

Monument; copper mines in the Ketchikan area; and many other deposits that were 

explored or developed throughout the Tongass. Mineral exploration and extraction has 

continued, at some level, since the first discoveries.

Energy

Swan Lake 

Hydroelectric Project 

expansion

KMRD 2016-2017 In August 2015, the Federal Energy Regulatory Commission issued an order amending 

SEAPAs license for the project. SEAPA will expand the reservoir raising the spill elevation 

15 feet and add 25% additional storage for winter hydropower generation, displacing up to 

12,000 MWhrs of diesel generation (800,000 gallons) annually. The project will inundate 

about 93 acres of additional land of which about 26 acres is federal lands within the 

Tongass National Forest.

Recreation and Tourism

Cruise Ships Tongass-wide, especially 

the major ports

Late 

1880s to 

present

The Southeast Alaska cruise ship industry has developed and grown to substantial levels. 

The first cruise ships sailed in the late 1880s and the number of passengers now numbers 

about one million per year. Modern cruise ships began sailing to Alaska in the 1970s and 

the number of passengers reached about 500,000 in 1995 and the number of passengers 

doubled in the next 20 years. These ships use the major ports of Southeast Alaska.

Outfitter Guides Tongass-wide Mostly 

1920s to 

present

Outfitters and guides have provided services throughout Southeast Alaska for many years, 

beginning as hunting and fishing guides in the early years, they have expanded the 

services they provide. The Forest Service issues special use permits to manage the 

number and distribution of outfitters and guides.
Appendix C

Cumulative Effects C-6 Final EIS

Table C-1 (continued)

Past Actions and Projects Considered in Cumulative Effects Analyses

Past Actions Location Year(s) Description

Helicopter Landings 

and Tours

Mostly the Juneau Ranger 

District

With the advent of the cruise ship industry, helicopter tours and landings developed into a 

secondary industry. The majority of these occur in the Juneau Icefield. Helicopter landing 

tours also occur in a number of locations elsewhere on the Forest, including the Skagway 

Icefield and Baird Patterson Glaciers. These tours involve high volumes of people 

concentrated at specific locations for short periods of time, typically two to four hours.

Dispersed Recreation 

and Subsistence 

Gathering

Tongass-wide Mostly 

1920s to 

present

Dispersed recreation has steadily increased in Southeast Alaska along with the growth of 

the tourism industry, the growth of communities, and the development of roads. Gathering 

of subsistence resources has also increased, although more slowly, with the growth of 

subsistence communities.

Fishing and Recreation 

Lodges

Tongass-wide Mostly 

1940s to 

present

Numerous lodges have been developed on private lands adjacent to the Tongass National 

Forest. Some of these have gone out of business but most continue to operate. 

Recreation site 

development and 

closure

Tongass-wide Mostly 

1960s to 

present

A wide range of recreation facilities have been developed on the Tongass. They include 

25 campgrounds and camping areas, 10 day-use areas, 35 picnic sites, 155 

cabins/lookouts, 44 shelters, 68 trailheads and 885 miles of trail, and many other facilities.

Community Development

Community 

Development

Tongass-wide Mostly 

1890s to 

present

Settlement and community development in Southeast Alaska occurred primarily from the 

late 1800s to the present. Mining, fishing, and fish canneries were the primary early 

factors encouraging settlement, later followed by logging. Today there are 32 communities 

in Southeast Alaska. Eleven of these communities have less than 100 people ranging up 

to Juneau with over 33,000. The footprint of these communities ranges in size from a few 

acres to several thousand acres. Road development is associated with community 

development and is covered above under timber harvest activities.

Wildlife Habitat Enhancement and Regulatory Actions

Habitat Enhancement Tongass-wide Mostly 

1960s to 

present

A range of wildlife habitat enhancement projects has occurred throughout Southeast 

Alaska. These projects were designed to improve forest and riparian habitats for wildlife. 

They include extensive pre-commercial thinning, some with wide-spacing, riparian thinning 

and snag creation.

State Hunting and 

Trapping and Federal 

Subsistence 

Regulations

Tongass-wide Mostly 

1959 to 

present

State regulations have been in place since shortly after Statehood (1959) to control hunting 

and trapping activities. These regulations set bag limits and seasons and limit the hunting 

and trapping methods that can be used in pursuit of game animals, game birds, and 

furbearers. Prior to Statehood, federal regulations governed hunting and trapping. In 

addition, a Federal Subsistence Board establishes subsistence regulations for many areas 

of the State.
Appendix C

Final EIS C-7 Cumulative Effects

Table C-1 (continued)

Past Actions and Projects Considered in Cumulative Effects Analyses

Past Actions Location Year(s) Description

Watershed and Aquatic Habitat Improvement and Aquatic Regulatory Actions

Restoration Projects Tongass-wide Mostly 

1960s to 

present

The Forest Service has conducted numerous watershed improvement projects including: 

watershed monitoring and assessments; instream and riparian rehabilitation; placement of 

large woody debris in streams; conducting landslide assessments; improving fish passage 

in streams (creating jump pools, barrier modifications, culvert replacements); stream and 

lake stocking, and lake fertilization; decommissioning roads; and maintaining fish passage 

structures. The number and locations of projects have varied year to year based on 

funding and need.

State Fishing and 

Federal Subsistence 

Regulations

Tongass-wide Mostly 

1959 to 

present

State regulations have been in place since shortly after Statehood (1959) to control fishing 

and shellfish collecting. These regulations set bag limits and seasons and limit the 

methods that can be used to pursue resources. Prior to Statehood, federal regulations 

governed fishing. In addition, a Federal Subsistence Board establishes subsistence 

regulations for many areas of the State.
Appendix C

Cumulative Effects C-8 Final EIS

Table C-2

Present and Reasonably Foreseeable Actions and Projects Considered in Cumulative Effects Analyses

Present/Reasonably 

Foreseeable Actions Location Year(s) Description

Climate Change and Related Natural Perturbations

General – Climate 

Change

Throughout Southeast 

Alaska

2016 and 

beyond

Some climate models for Southeast Alaska predict rising temperatures, a 10 percent 

decrease in summer precipitation in portions of the region, and decreased soil moisture 

due to increased evaporation during warmer, dryer summer weather. These factors may 

lead to an increase in fire frequency and severity, further yellow-cedar decline, higher 

rates of insect and disease infestations, more severe windthrow events, and effects on 

stream flows, water temperature, and fisheries.

Yellow Cedar Decline Primarily in a wide band 

from western Chichagof and 

Baranof Islands to the 

Ketchikan area

2016 and 

beyond

As the climate continues to warm, cedar decline is likely to continue to spread, especially 

in the south and east. Conversely, yellow-cedar appears to be spreading northward as 

climate warms, into areas that retain snow longer into the spring.

Fire Throughout Southeast 

Alaska

2016 and 

beyond

Approximately 400 to 500 acres burn annually on the Tongass National Forest. Due to 

climate change, there may be an increased risk of forest fires but the effects are likely to 

be minor at the forest level.

Insects and Disease Throughout Southeast 

Alaska

2016 and 

beyond

If the warming trend continues, damage to trees from insects and rot are likely to 

increase, both from species currently present in Southeast Alaska and from new species 

invading the area from other parts of North America or elsewhere. Consider stem and 

root decay, hemlock dwarf-mistletoe; heart rot; spruce beetle; spruce aphids; and species 

not yet present.

Windthrow Events Throughout Southeast 

Alaska

2016 and 

beyond

Both small-scale and large-scale forms of windthrow are a part of the natural forest 

generation, growth, and development. Juday et al. (1998) concluded that there was a high 

risk of increased large-scale blowdown across Southeast Alaska as well as increased 

windthrow around harvest units as a result of climate change. 

Watershed Effects Throughout Southeast 

Alaska

2016 and 

beyond

Climate change will likely produce increases in air temperature in the winter months with 

increases in precipitation expected in the fall and winter, with much of the precipitation 

occurring as rain instead of snow (EcoAdapt 2014). The warmer air temperatures would 

contribute to the melting of glaciers, higher peak flows in the fall and winter in most 

streams other than glacier-fed streams, and lower summer flows primarily in snow-melt 

and rain dominated watersheds (Shanley and Albert 2014, Shanley et al. 2015). In 

addition, the warmer air temperatures may result in increased stream temperatures, but 

the degree this would occur depend greatly on local factors and any potential increase 

may be lessened by the potential increases in rainfall occurring in the summer and fall 

(EcoAdapt 2014). Climate change could also result in sea-level rise, which could 

inundate estuarine rearing areas for fish. Other effects on fish are likely to be both 

positive and negative and have a high degree of uncertainty.
Appendix C

Final EIS C-9 Cumulative Effects

Table C-2 (continued)

Present and Reasonably Foreseeable Actions and Projects Considered in Cumulative Effects Analyses

Present/Reasonably 

Foreseeable Actions Location Year(s) Description

Timber Harvest Activities including roads and other actions on NFS lands (thinning and commercial thinning not differentiated)

Forecasted acres to be harvested and roads to be constructed during the next 25 years and during the next 100 years for each alternative. 

Projected Future 

Harvest and Road 

Construction and 

Reconstruction over 25 

years for Each 

Alternative

Lands suitable for timber 

productions on the Tongass 

under each alternative (see 

suitable land maps)

2016 -

2040

Alternative 1: YG Harvest = 9,669 acres Road Construction = 345 miles

OG Harvest = 38,527 acres Road Reconstruction = 160 miles

Alternative 2: YG Harvest = 63,787 acres Road Construction = 385 miles

OG Harvest = 15,027 acres Road Reconstruction = 256 miles 

Alternative 3: YG Harvest = 53,734 acres Road Construction = 355 miles

OG Harvest = 16,599 acres Road Reconstruction = 229 miles

Alternative 4: YG Harvest = 40,760 acres Road Construction = 354 miles

OG Harvest = 23,255 acres Road Reconstruction = 209 miles

Alternative 5: YG Harvest = 43,316 acres Road Construction = 369 miles 

OG Harvest = 23,813 acres Road Reconstruction = 219 miles

(Young growth = YG; Old growth = OG)

Projected Future 

Harvest and Road 

Construction and 

Reconstruction over 

100 years for Each 

Alternative

Suitable forest lands on 

Tongass under each 

alternative (see suitable land 

maps)

2016 -

2115

Alternative 1: YG Harvest = 209,882 acres Road Construction = 1,372 miles

OG Harvest = 62,851 acres Road Reconstruction = 887 miles

Alternative 2: YG Harvest = 335,344 acres Road Construction = 1,656 miles

OG Harvest = 32,609 acres Road Reconstruction = 1,191 miles

Alternative 3: YG Harvest = 313,216 acres Road Construction = 1,586 miles

OG Harvest = 35,568 acres Road Reconstruction = 1,129 miles

Alternative 4: YG Harvest = 234,885 acres Road Construction = 1,316 miles

OG Harvest = 42,597 acres Road Reconstruction = 900 miles

Alternative 5: YG Harvest = 284,144 acres Road Construction = 1,520 miles

OG Harvest = 42,479 acres Road Reconstruction = 1,058 miles

(Young growth = YG; Old growth = OG)

Timber harvest projects that are being implemented or are in planning stages for the next five years. These are included within the 25-year and 100-year 

estimates above.

Big Thorne Thorne Bay Ranger District 

(TBRD)

2015-

2019+ 

100-150 MMBF offered for sale. 70 miles of roads maintained and 64 miles of roads 

restored. Restore and enhance 4.6 miles of stream; thin 10 riparian acres and 1,000 

upland acres. Remove 8 fish barrier culverts. (Approximately 98 MMBF has already been 

sold as of November 2015)

Greater Staney Area TBRD 2016-

2019+

47 MMBF offered for sale. Restore and enhance 2 miles of stream; thin 54 riparian acres 

and 1,500 upland acres. Remove or replace 28 fish barrier culverts.
Appendix C

Cumulative Effects C-10 Final EIS

Table C-2 (continued)

Present and Reasonably Foreseeable Actions and Projects Considered in Cumulative Effects Analyses

Present/Reasonably 

Foreseeable Actions Location Year(s) Description

Wrangell Island Wrangell Ranger District 

(WRD)

2016-

2019+

70 MMBF offered for sale and 1,300 acres for precommercial thinning. 52 miles of roads 

maintained; 9.5 miles of roads reconstructed; 12 miles of roads stored; and 2.5 miles of 

road decommissioned. Remove or replace 9 fish barrier culverts.

Zarembo WRD 2016-

2019+

60 MMBF offered for sale and 2,000 acres for precommercial thin. 80 miles of road 

maintained; 18 miles of road stored. Restore and enhance 7.6 miles of stream; thin 162 

riparian acres and 1,460 upland acres. Replace 48 fish barrier culverts.

TwelveMile CRD 2017-

2019+

13 miles of roads maintained. Restore and enhance 2.5 miles of stream; thin 40 riparian 

acres and 65 upland acres. Remove or replace 10 fish barrier culverts.

Neck Lake/Alder Creek TBRD 2016-

2019+

40 MMBF offered for sale. 18 miles of roads maintained and 29 miles or roads stored. 

Restore and enhance 1.5 miles of stream; thin 50 riparian acres and 300 upland acres. 

Replace 4 fish barrier culverts.

Kuiu Roaded Petersburg Ranger District 

(PRD)

2016-

2019+

25 MMBF offered for sale. 5 miles of roads maintained; 18 miles of roads reconstructed; 9 

miles of roads stored; and 7 bridges replaced. Restore and enhance 3 miles of stream. 

Remove or replace 10 barrier culverts.

Thomas Bay PRD 2017-

2019+

15 MMBF offered for sale (5 MMBF young growth). 4 miles of roads maintained and 4 

miles or roads stored. Replace 2 bridges. Restore and enhance 1 mile of stream; thin 

1,000 riparian acres and 312 upland acres. Replace 2 fish barrier culverts.

Traitors Cove KMRD 2017-

2019+

10 MMBF offered for sale. 4 miles of roads maintained and 4 miles of roads stored. 

Restore and enhance 3 miles of stream; thin 100 riparian acres. Remove or replace 8 

barrier culverts.

Kosciusko Vegetation 

Management & 

Watershed 

Improvement Project

TBRD 2016-

2019+

Manage roughly 1,500 acres of young-growth for multiple resource objectives and harvest 

an estimated 75 acres of old-growth, to meet Forest Plan objectives and assist in the 

transition to a young-growth industry.

Iris and Shelikof Sitka Ranger District (SRD) 2015-2019 Restoration and Enhancement thinning. 20 miles of roads stored. Restore and enhance 4 

miles of stream; thin 500 riparian acres and 3,500 upland acres. Remove one fish barrier 

culvert.

Saddle Lakes KMRD 2016-2019 47 MMBF offered for sale. 17 miles of new NFS road, 10 miles of temporary road and 

reconditioning 10.5 miles of existing NFS roads.. Restore and enhance 3 miles of stream. 

Remove or replace 28 barrier culverts.

Shrimp Bay KMRD 2015-2018 10 MMBF offered for sale and 1,000 acres precommercial thin. 3 miles of roads 

maintained. Remove or replace 5 barrier culverts.

Kennel Creek Hoonah Ranger District 

(HRD)

2015-2018 Restoration and Enhancement thinning. 4 miles of road maintained. Restore and enhance 

0.5 miles of stream; thin 350 upland acres. Remove 4 barrier culverts.

Sitka Ranger District SRD 2017-2019 Precommercial thin 400 acres. Watershed restoration including riparian thinning, instream 

work, and pond and road work.

Mitkof PRD 2015 10 MMBF offered for sale.

Control Lake-Angel 

Wings

TBRD 2015 0.5 MMBF offered for sale.
Appendix C

Final EIS C-11 Cumulative Effects

Table C-2 (continued)

Present and Reasonably Foreseeable Actions and Projects Considered in Cumulative Effects Analyses

Present/Reasonably 

Foreseeable Actions Location Year(s) Description

Control Lake – Rush 

Firewood

TBRD 2015 0.2 MMBF offered for sale.

Navy WRD 2015 10 MMBF offered for sale.

Elf Point KMRD 2017 10 MMBF offered for sale.

Heceta TBRD 2018 5 MMBF offered for sale.

Vallenar KMRD 2019 20 MMBF offered for sale.

No Name Bay PRD 2020+ 70 MMBF offered for sale.

Frosty Bay WRD 2020+ 10 MMBF offered for sale.

Timber Harvest Activities – State and Private Lands

Forecasted acres to be harvested and roads to be constructed during the next 25 years and during the next 100 years for each alternative. These sales will be 

governed by the Alaska Forest Resources and Practices Act which is designed to protect fish habitat, water quality and promote reforestation.

Projected Future 

Harvest and Road 

Construction and 

Reconstruction over 25 

years for Each 

Alternative

Almost all State and Private 

Lands within the proclaimed 

Tongass Boundary

2016 -

2040

The majority of State and Private harvest will be old growth

Alternative 1: Harvest = 56,234 acres Road Construction = 584 miles

 Road Reconstruction = 61 miles

Alternative 2: Harvest = 56,234 acres Road Construction = 584 miles

 Road Reconstruction = 61 miles

Alternative 3: Harvest = 56,234 acres Road Construction = 584 miles

 Road Reconstruction = 61 miles

Alternative 4: Harvest = 56,234 acres Road Construction = 584 miles

 Road Reconstruction = 61 miles

Alternative 5: Harvest = 56,234 acres Road Construction = 584 miles

 Road Reconstruction = 61 miles
Appendix C

Cumulative Effects C-12 Final EIS

Table C-2 (continued)

Present and Reasonably Foreseeable Actions and Projects Considered in Cumulative Effects Analyses

Present/Reasonably 

Foreseeable Actions Location Year(s) Description

Projected Future 

Harvest and Road 

Construction and 

Reconstruction over 

100 years for Each 

Alternative 

Almost all State and Private 

Lands within the Tongass 

Boundary

2016 -

2115

The majority of State and Private harvest will be old growth

Alternative 1: Harvest = 224,937 acres Road Construction = 2,335 miles

 Road Reconstruction = 245 miles

Alternative 2: Harvest = 224,937 acres Road Construction = 2,335 miles

Road Reconstruction = 245 miles

Alternative 3: Harvest = 224,937 acres Road Construction = 2,335 miles

Road Reconstruction = 245 miles

Alternative 4: Harvest = 224,937 acres Road Construction = 2,335 miles

Road Reconstruction = 245 miles

Alternative 5: Harvest = 224,937 acres Road Construction = 2,335 miles

Road Reconstruction = 245 miles

Specific State of Alaska timber sales that are being implemented or are in planning stages for the next five years. These are included within the 25-year and 100-

year estimates above.

Coffman Cove Prince of Wales Island 2015+ 1,628 acre sale. 13.1MMBF. 5.8 mile of road. Approximately 412 acres of old growth 

timber with an estimated volume of 7,177 MBF will be sold in 2015.

South Thorne Bay 

Area

Prince of Wales Island 

(Kasaan Peninsula)

2015+ 153 acre sale. 3.0MMBF(Active)

North Thorne Bay Prince of Wales Island 

(Thorne Bay)

2015+ 300-acre sale. 5.8MMBF

North Hollis Prince of Wales Island 

(Hollis)

2015+ 263 acres of old growth; 108 acres of young growth. 5.3 MMBF old growth; 2.2 MMBF 

young growth.

Kosciusko Island Kosciusko Island (Prince of 

Wales)

2015, 

2016

1,383 acres; 28 MMBF. New log transfer facility and sort yard. 

Heceta Heceta Island (Prince of 

Wales)

2015, 

2016

2,600 acres. 30 MMBF. (10 MMBF old growth, 20 MMBF young growth)

El Capitan Prince of Wales Island 2016 1,700 acres; 5 miles of new road. 17 MMBF.

Whale Pass Prince of Wales Island 2016 441 acres; 2 miles new road; 6.6 MMBF.

Exchange Cove Prince of Wales Island 2016 116 acres.1.2 MMBF.

Bostwick Bay Gravena Island (Ketchikan) 2017 583 acres. 5 miles new road. Road to cross Bostwick Creek. 8.9MMBF.

Vallenar Gravena Island (Ketchikan) 2017 300 acres old growth. 300 acres young growth. 12 MMBF. 8 miles new road; 1.5 mile 

reconstructed road. 

Little Coal Bay Prince of Wales (Kasaan 

Bay)

2017 1,000 acres. 5.2 MMBF
Appendix C

Final EIS C-13 Cumulative Effects

Table C-2 (continued)

Present and Reasonably Foreseeable Actions and Projects Considered in Cumulative Effects Analyses

Present/Reasonably 

Foreseeable Actions Location Year(s) Description

Kitkun Bay Prince of Wales 

(Cholmondeley Sound)

2017 1,051 acres. Volume not reported. 

Port Dolores Prince of Wales (Sumez 

Island)

2018 1,109 acres 12.2 MMBF Old Growth; 3.8 MMBF young growth.. 4.7 miles of new road on 

state land. 1,500 feet of new road on NFS land.

Hook Arm Dall Island 2018 960 acres. 11.5MMBF. 4.4 miles new road.

Naukati Prince of Wales (Naukati) 2018 162 acres. 3.7MMBF. Short spur roads.

Control Lake Prince of Wales (Control 

Lake)

2018 170 acres 3.4MMBF. 1.4 miles new road.

Mitkof Island Mitkof Island

(Petersburg)

2019 210 acres; 4.0 MMBF

Thomas Bay Thomas Bay

(Petersburg)

2019 816 acres; 20.2 MMBF (4.9 MMBF old growth; 15.3 MMBF young growth). 3.7 miles new 

road; 1.7 Miles road reconstructed.

Earl West Cove Wrangell Island 2019 700 acres; 12.5 MMBF; 5.0 miles new road

Leask Cove Revillagigedo Island 

(George Inlet)

2019 316 acres; 6.3 MMBF; 1.8 mile spur road

Small Sales and Other 

Sales

Variable 2016 and 

beyond

Right-of-way sales; blowdown sales; sales less than 10 acres. Five to 10 small sales 

totaling approximately 2.0 MMBF will be offered for Calendar Year 2018. 

Alaska Mental Health 

Trust Commercial 

Forestlands

Variable 2015 and 

beyond

The Alaska Mental Health Trust Land Office is comparable to a private forestland 

manager. Approximately 265 million board feet of the Trust's commercial forestland lies in 

southeast Alaska. A large portion of this forestland is community and environmentally 

sensitive. The Trust will be looking at these sensitivities in more detail in the future. The 

Trust Land Office is currently overseeing a timber sale contract near Icy Cape (18,000 

acres). To better understand the forestland assets owned by the Trust, forest resource 

inventory work is currently underway in the vicinity of Wrangell and Thorne Bay.

Sealaska and other 

Alaska Native 

Corporations

Native Corporation Lands 2015 and 

beyond

Projected harvest of 6.2 MMBF in 2016 increasing annually to 7.2 MMBF by 2030.

Land Adjustments

Alaska Mental Health 

Trust land exchange

Ketchikan, Petersburg, 

Wrangell, Sitka, Juneau, 

Myers Chuck, Naukati, and

Hollis, Alaska

2015-2020 

or later

The Alaska Mental Health Trust is working with the Tongass National Forest on a land 

exchange proposal involving 18,000 acres of Non-Federal lands in scenic viewsheds and 

approximately 20,000 acres of NFS land across eight communities in Southeast Alaska. 

In order to better align land ownership patterns with the inherent missions of both the 

Forest Service and the Alaska Mental health Trust Authority. An equal value land 

exchange has been proposed. In 2015, A Feasibility Analysis was completed, and both 

parties signed an Agreement to Initiate.
Appendix C

Cumulative Effects C-14 Final EIS

Table C-2 (continued)

Present and Reasonably Foreseeable Actions and Projects Considered in Cumulative Effects Analyses

Present/Reasonably 

Foreseeable Actions Location Year(s) Description

Remaining land 

conveyances due to 

the Alaska Statehood 

Act

Tongass-wide 2015-2025 

or later

The State of Alaska was granted and entitled to select up to 400,000 of National Forest 

Lands in Alaska for the purpose of furthering the development of and expansion of 

communities under the Alaska Statehood Act (43 CFR 2627.1(a)) On the Tongass 

National Forest, the State of Alaska has approximately 12,145 acres remaining of land 

entitlement under the Act. The adjudication process and conveyances are initiated by the 

Bureau of Land Management, Alaska State Office. 

Cube Cove land 

acquisition

Admiralty Island 2016 or 

later

The 22,890 acres of surface estate within the Admiralty Island National Monument and 

Kootznoowoo Wilderness would be purchased from Shee Atiká, Inc. The purpose of this 

acquisition is to conserve and enhance significant scenic, recreation, cultural and 

wildlife/plant resources within National Monument/Wilderness and to protect wilderness 

values from development. In addition to the surface land purchase between the Forest 

Service and Shee Atika, the subsurface estate owner, Sealaska Regional Corporation, 

has expressed interest to potentially exchange the subsurface estate at Cube Cove for 

other Surface Estate on the Tongass National Forest.

Sealaska Land 

Entitlement Finalization 

Act

Tongass-wide 2015-2017 Within two years of enactment of the "Carl Levin and Howard P. 'Buck' McKeon National 

Defense Authorization Act for Fiscal Year 2015", Sealaska may submit applications for 

the conveyance under section 14(h)(1)(A) of the Alaska Native Claims Settlement Act (43 

U.S.C. 1613(h)(1)(A)) of not more than 76 cemetery sites and historical places, amounting 

to approximately 500 acres.

Boomer land donation Sitka Ranger District, 

Chichagof Island

2016+ In 2012, the Federal Energy Regulatory Commission (FERC) issued an order amending 

the license for the Blue Lake Hydroelectric Project. FERC’s environmental assessment 

for the project identified 362 acres of National Forest System lands inundated by the 

raising of water levels in the reservoir as an unavoidable impact that would require 

mitigation. The mitigation was needed to offset the permanent loss of the timber, 

recreation, subsistence, wildlife habitat, and botanical resources around the Blue Lake 

Creek valley and other areas of the lakeshore. The City of Sitka proposed to donate 48 

acres of land on Chichagof Island as mitigation for the inundated area. The lands 

proposed for donation are three parcels known as “Basoiniuer No. 1, Basoiniuer No. 2, 

and Golden West” on City planning documents. These three parcels are municipalowned lands within the West Chichagof-Yakobi Wilderness. These lands are referred to 

as the Boomer lands. 

Alaska Veteran Native 

Allotment Land Equity 

Act

Tongass-wide Not 

scheduled

The proposed legislation is specific to National Forest Lands in Alaska, but includes a 

clause regarding approval of formerly rejected Native Allotment Cases under the “Shields

v. USA” case. The Shields case closed 200 Native allotment cases under the 1906 

Native Allotment Act which were applied for under ancestral uses v. individual use and 

occupancy. Most Shield’s cases were previously identified on the Tongass. Native 

Allotment applications are 160 acres each and thus approximately up to 32,000 acres 

of the Tongass that could become private lands in the future. This legislation was 

introduced in May 2015 and has not become law.
Appendix C

Final EIS C-15 Cumulative Effects

Table C-2 (continued)

Present and Reasonably Foreseeable Actions and Projects Considered in Cumulative Effects Analyses

Present/Reasonably 

Foreseeable Actions Location Year(s) Description

Unrecognized 

Southeast Alaska 

Native Communities 

Recognition and 

Compensation Act

Native Villages of Haines, 

Ketchikan, Petersburg, 

Tenakee, and Wrangell

Not 

scheduled

The proposed legislation would amend the Alaska Native Claims Settlement Act to permit 

the Native residents of each of the Native Villages of Haines, Ketchikan, Petersburg, 

Tenakee, and Wrangell, Alaska, to organize as Urban Corporations and to receive certain 

settlement land pursuant to this Act. The entitlement would consist of one township of 

land or 23,040 acres (total approximate acres are 184,320) and require the conveyance 

of all roads, trails, log transfer sites, leases, and appurtenances on or related to the land 

conveyed to the new urban corporations. This legislation was introduced in May 2015 and 

has not become law.

Alaska State Forest 

Proposal

Prince of Wales Island Not 

scheduled

State officials or interests have at times advocated the establishment of an additional 

Alaska State Forest to be managed to provide income for state government programs. 

One concept for such a management unit was for a 2-million-acre area on or near Prince 

of Wales Island, which would require transfer of extensive areas of current Tongass 

National Forest System lands to the State. To date, no federal legislation to implement 

such a proposal has been introduced in Congress and this action is not considered 

reasonably foreseeable.

Alaska Native 

Allotment Act 

conveyances

Tongass-wide Unknown The Alaska Native Allotment Act provided for Native individuals who had occupied lands 

prior to their designation as national forest to apply for conveyance of up to 160 acres, 

under conditions prescribed by the Act and federal regulations. As of August 2015, about 

45 Native allotment cases remain on the Tongass National Forest and are pending 

adjudication by the Bureau of Land Management. This number may increase due to

unknown circumstances by either quite title action, re-instatement applications, or new 

legislative proposals.

Mining (Tongass)

Greens Creek Mine 

(Active)

Admiralty Island Present –

2025 or 

beyond 

Underground polymetalic mine. Ore is processed on site and exported by sea. Waste 

water, waste rock and tailings are managed onsite. Power is supplied by hydroelectric 

infrastructure and diesel generators. The Greens Creek Land Exchange Act of 1995

allows mining to continue through 2095. Annually, the mine continues exploration in and 

around the mine.

Kensington Mine 

(Active)

Juneau Present2025 or 

beyond

Underground gold mine. Waste water, waste rock and tailings are managed onsite. Power 

is provided diesel generators. Annually, the mine continues exploration in and around the 

mine.

Bokan Mountain Prince of Wales (Kendrick 

Bay)

Unknown Bokan Mountain is a potential rare earth mine. Developers estimate 190 employees. It 

would be powered by liquid natural gas (LNG) generators.

Niblack Prince of Wales (Moira 

Sound)

Unknown Niblack Project is a potential polymetalic mine. Developers estimate 200 employees.

Other Locatable 

Minerals

Tongass-wide Continual Mining exploration is expected to continue in many areas of the Forest. Existing projects 

submit annual operating plans that describe exploration activities.

Mineral Materials Various Continual New and existing mineral materials sources will be developed. Stone, crushed rock, 

gravel and other saleable materials will be used for road building and maintenance and 
Appendix C

Cumulative Effects C-16 Final EIS

Table C-2 (continued)

Present and Reasonably Foreseeable Actions and Projects Considered in Cumulative Effects Analyses

Present/Reasonably 

Foreseeable Actions Location Year(s) Description

other purposes. Materials may be used in-service (by the Forest Service) or sold to 

private parties.

Mining (Canada)

Kerr-SulphuretsMitchellUnuk River watershed Present2068 or 

beyond

Seabridge Gold proposes to reopen this polymetallic mine in northwest British Columbia 

about 18 miles east of the Alaska/B.C. border. These deposits would be mined as open pits 

until later in the project when the Mitchell deposit would continue as an underground mine. 

Red Chris Stikine River Watershed 2015-2045 Imperial Metals recently opened the Red Chris copper/gold mine in northwest British 

Columbia.

Tulsequah Chief Taku River Watershed Unknown Chieftan Metals Inc. seeks to open this underground polymetallic mine in northwest British 

Columbia about 40 miles northeast of Juneau.

Energy

Angoon Hydroelectric

Project

Admiralty Island, Thayer 

Creek, (Angoon

Unknown The Alaska National Interest Lands Conservation Act (ANILCA), Section 506(a)3(B) 

granted Kootznoowoo Inc. the right to develop hydroelectric resources on Admiralty Island 

at Thayer Creek. The Forest Service completed a final environmental impact statement 

(FEIS) to disclose the effects of the proposed project. A record of decision (ROD) was

released in May 2009. 

The ROD authorizes the construction of a 1 megawatt run of river hydroelectric facility on 

Thayer Creek, approximately six miles north of Angoon that includes a diversion dam, 

penstock, powerhouse, underground transmission lines and access roads.

Bell Island Geothermal KMRD Unknown No specific projects are proposed at this time, although SEAPA is conducting preliminary 

investigations for geothermal power generation.

Crooked Creek/Jim’s 

Lake Hydroelectric 

Project

Elfin Cove 2017 In February 2015, the community of Elfin Cove proposed to develop a project that 

consists of two hydroelectric systems in series with a total capacity of about 140 kilowatts 

(kW). Common to both systems is about 12,000 feet of power line. 

The upper system is a run‐of‐river hydroelectric project that would include the following 

major components: 1) A natural water feature diversion on Crooked Creek that is about 

20 feet long by 4 feet tall by 4 feet wide diversion. 2) 

About 1,250 foot long 12‐inch diameter penstock 3) about 14‐foot by 14‐foot powerhouse 

4) A tailrace measuring about 3 feet deep by 8 feet wide by 50 feet long. 5) Access trails, 

temporary construction roads, and other appurtenant features necessary to provide a 

complete and functional system.

The lower system is a storage hydroelectric project that would include the following major 

components: 1) a siphon intake 2) about 2,050 foot long 14‐inch diameter penstock 3) an 

approximately 24‐foot by 24‐foot powerhouse. 4) a tailrace measuring 3 feet deep by 8 

feet wide by 150 feet long. 5) Access trails, temporary construction roads, and other 

appurtenant features necessary to provide a complete and functional system.

The project would occupy about 60 acres of federal lands.
Appendix C

Final EIS C-17 Cumulative Effects

Table C-2 (continued)

Present and Reasonably Foreseeable Actions and Projects Considered in Cumulative Effects Analyses

Present/Reasonably 

Foreseeable Actions Location Year(s) Description

Indian River

hydroelectric 

Tenakee Springs 2017-2018 The community of Tenakee Springs has been developing a 180 kilowatt run-of-river 

hydroelectric project on Indian River. The Project will supply approximately 90% of the 

city’s electricity, reducing diesel use by about 31,400 gallons annually. The project does 

not occupy federal lands, 

Kake-Petersburg 

Transmission Line 

Intertie

Mitkof and Kupreanof 

Islands, Petersburg and 

Wrangell Ranger Districts

2016 and 

beyond

The Southeast Alaska Power Agency (SEAPA) proposed to build a new electric 

transmission line that would connect the isolated electric system presently serving the city 

of Kake with SEAPA’s interconnected electric network, in or near Petersburg. The 

November 2014 Draft EIS analyzed three action alternatives that range from 52 miles to 

60 miles in total length, with 82 to 88 percent of their total length located on NFS lands. 

The proposed transmission line would be built to transmit power at either 69 - or 138–

kilovolts. All three action alternatives follow existing NFS system roads to the extent 

possible, with the length along existing roads ranging from 58 percent to 72 percent of the 

total. The action alternatives all cross Inventoried Roadless Areas. No new roads would 

be built under any of the alternatives. Construction access in unroaded areas would be 

via temporary shovel trails and matting panels, with helicopter support, as needed. The 

action alternatives would all involve marine crossings. 

Soulé River 

Hydroelectric Project

KMRD Unknown In February 2011, Soule Hydro, LLC filed an application for an original license with the 

Federal Energy Regulatory Commission for its proposed 77MW hydropower project on 

the Soule River, about nine miles southwest of Hyder, Alaska (FERC Project No. 13528). 

Major project features include: (1) a main dam 265-feet-tall by 903-feet-long; (2) a saddle 

dam about 2,024 feet long; (3) an intake structure; (4) a reservoir with a surface area of 

about 1,072 acres (5) an 16-foot-diameter by 11,400-foot-long water conduit tunnel; (6) a 

3.1-mile-long access road; (7) a 80-foot-wide by 160-foot-long powerhouse; a tailrace that 

will discharge into the river mouth; (8) three 138 kilovolt substation next to the 

powerhouse; (9) marine access facilities that include a staging area, boat ramp, barge 

basin for offloading barges, and float for small watercraft; (10) temporary log transfer 

facility; (11) a 10-mile-long, 138 kilo-volt submarine cable to Stewart, B.C. (about two 

miles will be in Canadian waters) to connect with a BC Hydro substation. 

The project would occupy 1,257 acres of federal lands within the Tongass National 

Forest. 

Sweetheart Lake 

Hydroelectric Project

Juneau Ranger District Unknown In October 2015 the Federal Energy Regulatory Commission released the draft EIS for 

the proposed project located on Lower Sweetheart Lake and Sweetheart Creek, (FERC 

Project No. 13563). Major project features include: (1) A 280-foot-wide, 111-foot-high 

dam; (2) a 525-foot-long, 10-foot-high, 10-foot-wide arched reservoir outlet tunnel; (3) a 

45-foot-long, 25-foot-wide, 16-foot-high intake structure; (4) a 9,612-foot-long, 15-footwide, 15-foot-high underground power tunnel; (5) an 896-foot-long, 9-foot-diameter 

penstock; (6) three 160-foot-long, 7- to 9-foot-diameter buried penstocks (7) a 160-foot-
Appendix C

Cumulative Effects C-18 Final EIS

Table C-2 (continued)

Present and Reasonably Foreseeable Actions and Projects Considered in Cumulative Effects Analyses

Present/Reasonably 

Foreseeable Actions Location Year(s) Description

long, 60-foot-wide, 30-foot-high powerhouse; (8) three 7.1-MW Francis turbines with 6.6-

MW generators with a total installed capacity of 19.8 MW; (9) a 541-foot-long, 30- to 90-

foot-wide rock tailrace; (10) a 4,400-foot-long coastal road from the powerhouse to a 

dock/landing site, located on the east shore of Gilbert Bay; (11) an 8.69-mile-long, 138-

kilovolt (kV) transmission line traversing Gilbert Bay, the Snettisham Peninsula, and Port 

Snettisham, consisting of: (a) two buried segments, totaling 4,800 feet in length; (b) two 

submarine segments; and (c) one 15,400-foot-long overhead segment; (12) a 22,000-

square-foot fenced switchyard adjacent to the powerhouse; (13) a 4,225-square-foot 

caretaker’s facility near the dock; (14) a 4,800-foot-long, 12.47-kV service transmission 

line extending from the powerhouse to the dock and caretaker’s facility; (15) a 10,000-

foot-long, 12.47-kV service transmission line; and (16) a 400-square-foot shelter at the 

dam site. 

The project would occupy 2,058.24 acres of federal lands within the Tongass National 

Forest and 131.18 acres of tideland and submerged lands of the state of Alaska.

Communication Sites

Existing and Future 

Communications Sites

Tongass-wide Present 

and 

continuing

Sites approved for telecommunication facilities are characterized by antennas, electronic 

transmitters, equipment shelters, and a variety of electronic communication support 

equipment. Proposals for new communications uses on the Tongass National Forest will 

be encouraged to co-locate on an approved communications site, unless the proponent 

demonstrates that communication sites approved in the Forest Plan are not technically 

feasible due to geographic location, or are incompatible with the requested use. Currently, 

there are 75approved communication sites on the Tongass.

Transportation

Regional 

Transportation 

Systems

Tongass-wide 2015 and 

continuing

The State of Alaska will continue to maintain and improve its regional transportation 

system including road and marine systems. 

Angoon Airport Angoon 2016 The Alaska Department of Transportation and Public Facilities proposed a land-based 

airport for Angoon. In January 2015 the Federal Aviation Administration released a Draft 

Environmental Impact Statement (EIS) for public comment. The preferred alternative 

identified in the DEIS is on private lands. . Two alternative airport locations being 

considered are within the Admiralty Island National Monument and Kootznoowoo 

Wilderness. ADOT&PF submitted an ANILCA Title XI application for the alternative in 

Wilderness.

Clark Bay Ferry 

Terminal Parking 

Expansion

Hollis (Prince of Wales) Est. 2016 The Alaska Department of Transportation and Public Facilities intends to expand the 

existing parking area at the Clark Bay (Hollis) ferry terminal by about 50 parking spaces.
Appendix C

Final EIS C-19 Cumulative Effects

Table C-2 (continued)

Present and Reasonably Foreseeable Actions and Projects Considered in Cumulative Effects Analyses

Present/Reasonably 

Foreseeable Actions Location Year(s) Description

Juneau Access

Improvement Project

(ADOT&PF Federal 

Highway 

Administration)

Juneau/Haines 2016 or 

later

Extend Glacier Highway/State Route 7 northward from its current terminus to the north 

side of the Katzehin River delta, in a series of stages, under the preferred alternative in 

the Final Environmental Impact Statement (EIS) and construct terminal near Katzehin 

River. 

Gravina Access Gravina and Revillagigedo 

Islands

2016 or 

later

Design and construct improved access to Gravina Island

Ketchikan to Shelter 

Cove Road

(Cleveland Peninsula 

Shelter Cove D1 

easement)

KMRD, Cleveland Peninsula 2015?? Construct between 9 and 10 miles of new, single lane, unpaved roadway and bridges and 

upgrade between 10 and 19 miles of existing logging roads to connect Revilla Road near 

Ketchikan to the Forest Service Road system at Shelter Cove on Carroll Inlet.. 

Approximately 1.61 miles of road would be routed through wetlands or other jurisdictional 

waters of the United States, while the other 5.68 miles would be routed through uplands. 

The project is an identified road segment supporting implementation of the 2004 

Southeast Alaska Transportation Plan 

Naukati Bay Road Naukati (Prince of Wales) 2015? Upgrade and pave Naukati West Access Road to a two lane road between the North 

POW Road and the Naukati Seaplane Float. 

Sitka-Katlian Bay Road Sitka 2016 or 

later

In 2010 the State of Alaska Department of Transportation and Public Facilities (DOT&PF) 

was granted a D-1 easement for highway and utility planning purposes (Sitka – Rodman 

Bay). This road corridor was identified as a Proposed State Road Corridor in the 2008 

Forest Plan Land Use Designations map and given a Transportation and Utility System 

LUD. DOT&PF is preparing a “...State Projects Environmental Checklist to address 

impacts and issues associated with...” building about nine miles of unpaved single-lane 

road from the end of the existing Sitka road system at Halibut Point Road, extending east 

along the south shoreline of Katlian Bay, crossing the Katlian River, and ending four miles 

east of the Katlian Bay. Two and one-half miles of this proposed road crosses National 

Forest System lands. Some of the road is in the Sitka Urban Inventoried Roadless Area 

(331).

Kake Access Project Kake (Kupreanof Island) unknown In January 2013 the Western Federal Lands Highway Division of the Federal Highway 

Administration (FHWA) issued a notice to advise the public that FHWA would prepare an 

Environmental Impact Statement (EIS) for a proposed transportation project to improve 

access to and from the community of Kake in Southeast Alaska

Construct approximately 27 miles of new single lane, unpaved roadway and bridges and 

improve approximately 26 miles of existing logging roads on the north end of Kupreanof 

Island to provide Kake road access to Petersburg via a short shuttle ferry link. The very 

low volume road is intended to improve Kake's surface transportation access to 

Petersburg, the regional transportation system. 
Appendix C

Cumulative Effects C-20 Final EIS

Table C-2 (continued)

Present and Reasonably Foreseeable Actions and Projects Considered in Cumulative Effects Analyses

Present/Reasonably 

Foreseeable Actions Location Year(s) Description

Sandy Beach Road Thorne Bay (Prince of Wales 

Island)

2015? Reconstruct and realign FSR30 from the intersection of Freeman Drive MP 0.0 in Thorne 

Bay to MP 0.5 at the City of Thorne Bay's Bypass Loop Road and city limits. This is the 

first phase of the fully designed 6.58 miles of trails and roadwork to the Sandy Beach.

Alaska Marine 

Highway and 

Interisland ferry

Southeast Alaska (non-NFS) 2016 and 

beyond

Construction of new passenger terminal buildings and other improvements in Angoon and 

Kake; various marine terminal improvements in Ketchikan, Skagway, Gustavus, Sitka, 

Juneau, Tenakee Springs, and Haines; maintenance and refurbishment of vessels.

Other Transportation 

Projects

Southeast Alaska (NFS and 

non-NFS)

2016 and 

beyond

The Forest Service will conduct transportation projects which will vary year to year based 

on funding and need. These include maintaining or improving existing roads and bridges, 

placing roads in storage, paving existing dirt roads, and improving fish passage at 

culverts. The State and local communities will also implement various transportation 

projects such as paving or resurfacing roads, road realignments, safety improvements, 

vessel and marine terminal improvements, etc.

Recreation and Tourism

Cruise Ships Tongass-wide 2015 and 

beyond

Expected growth in recreation and tourism businesses based on continued growth in the

cruise ship industry

Outfitter Guides Tongass-wide 2015 and 

beyond

Outfitter guide services may include guided hunts or trapping, camping, fishing, cross 

country skiing, hiking or other commercial recreational activities. Outfitter and guide 

services are generally provided within 1⁄2-mile inland of the shoreline but extend further for 

some activities (e.g. goat hunting, canoeing, freshwater fishing). 

Helicopter Landings 

and Tours

Mostly the Juneau Ranger 

District

2015 and 

beyond

About 17,000 landings occur on the Juneau Icefield for tours and activities annually 

(based on 2004-2007 data), which accounts for about 75% of the helicopter 

tours/landings in Southeast Alaska. Helicopter landing tours also occur in a number of 

locations elsewhere on the Forest, including the Skagway Icefield and Baird Patterson 

Glaciers. 

Dispersed Recreation 

and Subsistence 

Gathering

Tongass-wide 2015 and 

beyond

There may be increasing recreational demand as the tourism industry continues to grow 

and increasing recreation around communities with population growth. Gathering of 

subsistence resources is also expected to increase, although more slowly than recreation, 

with the growth of subsistence communities.

Fishing and Recreation 

Lodges

Tongass-wide 2015 and 

beyond

Numerous lodges occur on private lands adjacent to the Tongass. It is expected that 

most of these lodges will continue to operate, and new lodges will be opened, providing 

additional recreational opportunities.

Recreation site 

development and 

closure

Tongass-wide 2015 and 

beyond

Continued use, maintenance and improvement of existing developed recreation sites 

(e.g., cabins, campgrounds, visitor centers, trails, and viewing areas, and other facilities), 

closures of such sites, or creation of new may occur. Similarly, the State or communities 

may develop, improve, or modify recreation sites.

Communities

Population changes Tongass-wide Ongoing Human settlement expansion is expected to occur around the region’s larger cities, such 

as Juneau and Sitka, with residential expansion also expected as a result of state land 

auctions.
Appendix C

Final EIS C-21 Cumulative Effects

Table C-2 (continued)

Present and Reasonably Foreseeable Actions and Projects Considered in Cumulative Effects Analyses

Present/Reasonably 

Foreseeable Actions Location Year(s) Description

State land Offerings Tongass-wide Ongoing The State periodically offers land for settlement and development. Often, these lands are 

adjacent to NFS lands. No NFS lands are included in these State land offerings.

POW Borough Prince of Wales Island unknown The Prince of Wales Community Advisory Council is investigating the formation of a 

Prince of Wales Borough. (speculative)

Wildlife

Pre-commercial 

thinning

2016 and 

beyond

The Tongass Integrated Plan provides details on planned precommercial thinning projects 

that would benefit wildlife. A summary of acres by Ranger district is below. HRD: About 

2,270 acres; JRD: About 640 acres (Couverden); KMRD: About 2,780 acres; PRD: About 

3,890 acres; TBRD: About 6,000 acres (Big Thorne Stewardship); WRD: About 1,460 

acres.

Mitkof Island Deer 

Habitat Enhancement

Petersburg Ranger District 2016 Treat up to 1,114 acres of young-growth stands to benefit deer.

Sport and Subsistence 

Harvest

Tongass-wide 2016 and 

beyond

Sport and subsistence harvests will continue throughout the forest. Prediction of the 

future extent and intensity of such activities has a high degree of uncertainty associated 

with it on a Forest-wide basis over a broad time scale.

Watershed Restoration

Restoration Projects Tongass-wide 2016 and 

beyond

Annually, the Forest Service will conduct watershed improvement projects including: 

watershed monitoring and assessments; instream and riparian rehabilitation; placement of 

large woody debris in streams; conducting landslide assessments; improving fish passage 

in streams (creating jump pools, barrier modifications, culvert replacements); 

decommissioning roads; and maintain fish passage structures. The number of locations 

and number of projects will vary year to year based on funding and need.
Appendix C

Cumulative Effects C-22 Final EIS

Table C-3

Interactions Between Resources and Actions or Projects

Actions or Projects

Climate and AirGeology/KarstSoilsWaterWetlandsFishPlantsForest HealthBiodiversityWildlifeLandsTimberTransportationEnergy/Utility LinesMineralsRecreation/TourismScenerySubsistenceHeritageRoadlessWildernessSocioeconomicCommunities

PAST ACTIONS

Climate Change and Natural Processes

Climate Change - General x x x

Yellow Cedar Decline x x x

Fire x x x x

Insects and Disease x x x

Windthrow x x x

Watershed Effects x x x x

Timber Harvest Activities

Past Harvest - NFS x x x x x x x x x x x x x x x

Past Harvest – non-NFS x x x x x x x x x x x x x x x

Past Road Construction/Use x x x x x x x x x x x x x x x x

Past LTF Construction/Use x x x x x x x x x x x x x

Land Adjustments

Misty Fjords National Monument Wilderness 

Inholdings (2012) x x

Public Law 113-291 x x x x x x x x x x x x x x x x x x

Boomer Land Donation x x x

Other land adjustments x x x x x x x x x x

Mining 

Various Mines x x x x x x x x x x x x

Recreation and Tourism

Cruise Ships x x x x x x

Outfitter Guides x x x x

Helicopter Landings and Tours x x x x x

Dispersed Recreation and Subsistence 

Gathering x x x x x x

Fishing and Recreation Lodges x x x x x x x x x

Recreation site development and closure x x x x x x x x x
Appendix C

Final EIS C-23 Cumulative Effects

Table C-3 (continued)

Interactions Between Resources and Actions or Projects

Actions or Projects

Climate and AirGeology/KarstSoilsWaterWetlandsFishPlantsForest HealthBiodiversityWildlifeLandsTimberTransportationEnergy/Utility LinesMineralsRecreation/TourismScenerySubsistenceHeritageRoadlessWildernessSocioeconomicCommunities

Community Development

Community Development x x x x x x x x x x x

Wildlife Habitat Enhancement and Regulatory Actions

Habitat Enhancement x x x x x x

State Hunting/Trapping and Federal 

Subsistence Regulations x x

Watershed and Aquatic Habitat Improvement and Aquatic Regulatory Actions

Restoration Projects x x x x

State Fishing and Federal Subsistence 

Regulations x x x

PRESENT AND REASONABLY FORESEEABLE ACTIONS

Climate Change and Natural Processes

General – Climate Change x x x x x x x x x x x

Yellow Cedar Decline x x x

Fire x x x x

Insects and Disease x x x

Windthrow Events x x x

Watershed Effects x x x x

Timber Harvest Activities

Future Harvest - NFS x x x x x x x x x x x x x x x

Future Harvest – non-NFS x x x x x x x x x x x x x x x

Future Road Construction/Use x x x x x x x x x x x x x x x x

Future LTF Construction/Use x x x x x x x x x x x x x

Land Adjustments

Land Adjustments x x x x x x x x x x x x x x x x x x

Mining 

Various Mines x x x x x x x x x x x x

Energy

Hydroelectric Projects x x x x x x x x x x x x x x x x x

Other Renewable Energy Projects x x x x x x x x x x x x x x x x x
Appendix C

Cumulative Effects C-24 Final EIS

Table C-3 (continued)

Interactions Between Resources and Actions or Projects

Actions or Projects

Climate and AirGeology/KarstSoilsWaterWetlandsFishPlantsForest HealthBiodiversityWildlifeLandsTimberTransportationEnergy/Utility LinesMineralsRecreation/TourismScenerySubsistenceHeritageRoadlessWildernessSocioeconomicCommunities

Transmission Lines x x x x x x x x x x x x x x x x

Communication Sites

Existing and Future Communications Sites x x x x x x

Transportation

Regional Transportation Systems x x x x x x x x x x x x x x x x x

Local Transportation Systems x x x x x x x x x x x x x x x x x

Alaska Marine Highway & Interisland Ferry x x x x x x x

Recreation and Tourism

Recreation Developments/Actions x x x x x x x x x x x x x

Communities

Community Expansion/Development x x x x x x x x x x x x x x x x x

Wildlife

Pre-commercial thinning & habitat 

enhancement x x x x x

Sport and Subsistence Harvests x x

Watershed Restoration

Restoration Projects x x x x x x x

Appendix C

Final EIS Catalog of Past Harvest

Attachment 1

Catalog of Past Harvest

CONTENTS

Introduction ..............................................................................................................................................A1-1

Part I – Acreage of Past Harvest by Ownership Category, by Landowner, by Biogeographic Province, by 

Approximate Decade................................................................................................................................A1-1

Part II – Statistics on the Alaska Forest Resources and Practices Act Implementation and State Timber 

Sales in Southeast Alaska .......................................................................................................................A1-8

TABLES

Table I-1 Acreage of Past Harvest by Landowner........................................................................... A1-1

Table II-1 Forest Practices Act – Summary Statistics for Southeast Alaska, 1991–1998................ A1-8

Table II-2 Forest Practices Act – Summary Statistics for Southeast Alaska, 1999–2006................ A1-8

Table II-3 Forest Practices Act – Summary Statistics for Southeast Alaska, 2007–2014................ A1-9

Table II-4 Forest Practices Act – Road Miles Summary for State of Alaska, 1997–2006................ A1-9

Table II-5 Forest Practices Act – Road Miles Summary for State of Alaska, 2007-2014............... A1-10

Table II-6 State Timber Sales Sold................................................................................................. A1-10

Table II-7 FY 97 State Timber Sales Sold – Southeast.................................................................. A1-11

Table II-8 State Timber Sales Sold – FY 98 – Southeast .............................................................. A1-12

Table II-9 State Timber Sales Sold – FY 99 Coastal Region ......................................................... A1-13

Table II-10 State Timber Sales Sold – FY 00 – Southeast .............................................................. A1-13

Table II-11 State Timber Sales Sold – FY 01 – Southeast .............................................................. A1-14

Table II-12 State Timber Sales – FY 02 – Southeast....................................................................... A1-15

Table II-13 State Timber Sales Sold – FY 03 – Southeast .............................................................. A1-16

Table II-14 State Timber Sales Sold – FY 04 – Southeast .............................................................. A1-17

Table II-15 State Timber Sales Sold – FY 05 – Southeast .............................................................. A1-18

Table II-16 State Timber Sales Sold – FY 06 – Southeast .............................................................. A1-19

Table II-17 State Timber Sales Sold – FY 07 – Southeast .............................................................. A1-20

Table II-18 State Timber Sales Sold – FY 08 through 14 – Southeast ............................................ A1-21
Appendix C

Final EIS A1-1 Catalog of Past Harvest

Attachment 1

Catalog of Past Harvest

Introduction

This appendix presents a catalog of past harvest for Southeast Alaska. It is based on updated and 

extensive mapping of past harvest based on the Tongass GIS library, GIS data layers provided by 

Sealaska Regional Native Corporation, the State of Alaska, and Audubon Alaska/The Nature 

Conservancy, as well as supplemental interpretation of orthophotography and other aerial photography. 

It is also based on tabular information collected from the State of Alaska, Department of Natural 

Resources regarding state harvests and harvests under the Alaska Forest Resources and Practices Act. 

Appendix B provides more detailed information on the inventory methodology.

Part II presents a tabular summary of information provided by the State of Alaska Department of Natural 

Resources, Division of Forestry.

Part I – Acreage of Past Harvest by Ownership Category, by Landowner, 

by Biogeographic Province, by Approximate Decade

Table I-1

Acreage of Past Harvest by Landowner

Ownership Category Landowner

Est. Approx. 

Harvest 

Decade

Acres 

Harvested

Yakutat Forelands Biogeographic Province

Tongass National Forest Tongass National Forest 1950s 28

Tongass National Forest 1970s 553

Tongass National Forest 1980s 1,812

Tongass National Forest 1990s 229

Tongass National Forest 2000s 987

Tongass National Forest -- 18

Total NFS Lands 3,627

State of Alaska State of Alaska 1970s–1990s 1,315

Total State Lands 1,315

Yak-tat Kwaan Village Corporation 1980s 12,541

Other -- 134

Private & Other Lands Total Private/Other Lands 12,675

TOTAL PROVINCE HARVEST 17,618

Yakutat Uplands Biogeographic Province

Tongass National Forest Tongass National Forest 1980s 665

Tongass National Forest 1990s 173

Tongass National Forest 2000s 552

Tongass National Forest -- 21

Total NFS Lands 1,411

State of Alaska Total State Lands 0

Private & Other Lands Total Private/Other Lands 0

TOTAL PROVINCE HARVEST 1,411

East Chichagof Island Biogeographic Province

Tongass National Forest Tongass National Forest <1950 1,016

Tongass National Forest 1950s 1,527

Tongass National Forest 1960s 6,053
Appendix C

Catalog of Past Harvest A1-2 Final EIS

Table I-1

Acreage of Past Harvest by Landowner

Ownership Category Landowner

Est. Approx. 

Harvest 

Decade

Acres 

Harvested

Tongass National Forest 1970s 13,232

Tongass National Forest 1980s 10,501

Tongass National Forest 1990s 11,713

Tongass National Forest 2000s 60

Tongass National Forest -- 105

Total NFS Lands 44,207

State of Alaska State of Alaska 1980s 200

State of Alaska 1990s 227

State of Alaska 2000s 70

Total State Lands 497

Private & Other Lands Hoonah -- 252

Huna Totem Village Corporation -- 11,449

Sealaska Regional Corporation 1970s 1,352

Sealaska Regional Corporation 1980s 7,670

Sealaska Regional Corporation 1990s 6,400

Sealaska Regional Corporation 2000s 6,825

Other Private Owners -- 81

Total Private/Other Lands 37,007

TOTAL PROVINCE HARVEST 81,711

West Chichagof Island Biogeographic Province

Tongass National Forest Total NFS Lands 0

State of Alaska Total State Lands 0

Private & Other Lands Total Private/Other Lands 0

TOTAL PROVINCE HARVEST 0

East Baranof Island Biogeographic Province

Tongass National Forest Tongass National Forest <1950 197

Tongass National Forest 1950s 223

Tongass National Forest 1960s 8,158

Tongass National Forest 1970s 2,725

Tongass National Forest 1990s 2,227

Total NFS Lands 13,530

State of Alaska Total State Lands 0

Private & Other Lands Other Private Land Owners -- 2

Total Private/Other Lands 2

TOTAL PROVINCE HARVEST 13,532

West Baranof Island Biogeographic Province

Tongass National Forest Tongass National Forest 1950s 1,085

Tongass National Forest 1960s 9,812

Tongass National Forest 1970s 5,556

Tongass National Forest 1980s 10

Total NFS Lands 16,978

State of Alaska State of Alaska 1980s 696

State of Alaska 1990s 204

Total State Lands 900

Private & Other Lands Shee Atika Village Corporation 1980s 1,184

Other Private Owners -- 271

Total Private/Other Lands 1,455

TOTAL PROVINCE HARVEST 19,332
Appendix C

Final EIS A1-3 Catalog of Past Harvest

Table I-1

Acreage of Past Harvest by Landowner

Ownership Category Landowner

Est. Approx. 

Harvest 

Decade

Acres 

Harvested

Admiralty Island Biogeographic Province

Tongass National Forest Tongass National Forest Prior to 1950 3,202

Tongass National Forest 1950s 771

Tongass National Forest 1960s 3,305

Tongass National Forest 1970s 1,108

Tongass National Forest 1990s 17

Tongass National Forest 2000s 105

Tongass National Forest -- 88

Total NFS Lands 8,595

State of Alaska Total State Lands 0

Private & Other Lands Shee Atika Village Corporation 1980s–1990s 20,080

Other Private Owners -- 110

Total Private/Other Lands 20,190

TOTAL PROVINCE HARVEST 28,785

Lynn Canal Biogeographic Province

Tongass National Forest Tongass National Forest 1960s 2,129

Tongass National Forest 1970s 1,177

Tongass National Forest 1980s 545

Tongass National Forest 1990s 1,527

Total NFS Lands 5,377

State of Alaska State of Alaska 1980s 214

Total State Lands 214

Private & Other Lands Other Private Owners 1990s 335

Total Private/Other Lands 335

TOTAL PROVINCE HARVEST 5,926

North Coast Range Biogeographic Province

Tongass National Forest Tongass National Forest 1950s 221

Total NFS Lands 221

State of Alaska State of Alaska -- 24

Total State Lands 24

Private & Other Lands Goldbelt Village Corporation 1980s 20,389

City and Borough of Juneau -- 1

Other Land Owners -- 147

Total Private/Other Lands 20,537

TOTAL PROVINCE HARVEST 20,782

Kupreanof/Mitkof Biogeographic Province

Tongass National Forest Tongass National Forest <1950 1,573

Tongass National Forest 1950s 1,096

Tongass National Forest 1960s 6,781

Tongass National Forest 1970s 10,183

Tongass National Forest 1980s 8,335

Tongass National Forest 1990s 5,539

Tongass National Forest 2000s 2,234

Total NFS Lands 35,742

State of Alaska State of Alaska 1980s 3,648

State of Alaska 1990s 884

State of Alaska 2000s 54

Total State Lands 4,587

Private & Other Lands Kake -- 126
Appendix C

Catalog of Past Harvest A1-4 Final EIS

Table I-1

Acreage of Past Harvest by Landowner

Ownership Category Landowner

Est. Approx. 

Harvest 

Decade

Acres 

Harvested

Petersburg -- 484

Kake Village Corporation 1970s–1990s 17,471

Sealaska Regional Corporation <1980 3,755

Sealaska Regional Corporation 1980s 1,831

Sealaska Regional Corporation 1990s 551

Sealaska Regional Corporation 2000s 6,009

Other Private Owners -- 823

Total Private/Other Lands 31,050

TOTAL PROVINCE HARVEST 71,379

Kuiu Island Biogeographic Province

Tongass National Forest Tongass National Forest <1950 2,570

Tongass National Forest 1950s 344

Tongass National Forest 1960s 3,428

Tongass National Forest 1970s 8,989

Tongass National Forest 1980s 7,852

Tongass National Forest 1990s 4,644

Tongass National Forest 2000s 667

Total NFS Lands 28,494

State of Alaska State of Alaska -- 9

Total State Lands 9

Private & Other Lands Sealaska Regional Corporation <1980 22

Other Private Owners -- 113

Total Private/Other Lands 135

TOTAL PROVINCE HARVEST 28,638

Central Coast Range Biogeographic Province

Tongass National Forest Tongass National Forest <1950 159

Tongass National Forest 1950s 910

Tongass National Forest 1960s 3,574

Tongass National Forest 1970s 1,087

Tongass National Forest 1980s 164

Tongass National Forest 1990s 586

Total NFS Lands 6,479

State of Alaska State of Alaska 1970s–1980s 1,421

Total State Lands 1,421

Private & Other Lands Other Land Owners -- 13

Total Private/Other Lands 13

TOTAL PROVINCE HARVEST 7,913

Etolin Island and Vicinity Biogeographic Province

Tongass National Forest Tongass National Forest <1950 2,565

Tongass National Forest 1950s 1,728

Tongass National Forest 1960s 2,593

Tongass National Forest 1970s 12,666

Tongass National Forest 1980s 8,964

Tongass National Forest 1990s 6,532

Tongass National Forest 2000s 1,016

Tongass National Forest -- 4

Total NFS Lands 36,066

State of Alaska State of Alaska 3,764

Total State Lands 3,764
Appendix C

Final EIS A1-5 Catalog of Past Harvest

Table I-1

Acreage of Past Harvest by Landowner

Ownership Category Landowner

Est. Approx. 

Harvest 

Decade

Acres 

Harvested

Private & Other Lands Wrangell 643

Other Land Owners 68

Total Private/Other Lands 712

TOTAL PROVINCE HARVEST 40,542

North Central Prince of Wales Island Biogeographic Province

Tongass National Forest Tongass National Forest <1950 1,772

Tongass National Forest 1950s 11,460

Tongass National Forest 1960s 50,216

Tongass National Forest 1970s 47,190

Tongass National Forest 1980s 35,623

Tongass National Forest 1990s 33,507

Tongass National Forest 2000s 4,343

Tongass National Forest -- 15

Total NFS Lands 184,125

State of Alaska State of Alaska -- 15,384

Total State Lands 15,384

Private & Other Lands Hydaburg -- 48

Kasaan -- 16

Thorne Bay -- 180

Haida Village Corporation 1980s–1990s 2,465

Kavilco Village Corporation 1990s 11,811

Klawock-Heenya Village Corporation 1980s–1990s 12,073

Sealaska Regional Corporation <1980 3,240 

Sealaska Regional Corporation 1980s 32,741 

Sealaska Regional Corporation 1990s 24,452 

Sealaska Regional Corporation 2000s 22,835 

Shaan Seet Village Corporation 1980s–1990s 6,858

Other Private Land Owners -- 3,304

Total Private/Other Lands 120,022

TOTAL PROVINCE HARVEST 319,531

Revilla Island/Cleveland Peninsula Biogeographic Province

Tongass National Forest Tongass National Forest <1950 2,181

Tongass National Forest 1950s 6,812

Tongass National Forest 1960s 6,389

Tongass National Forest 1970s 8,443

Tongass National Forest 1980s 5,827

Tongass National Forest 1990s 11,477

Tongass National Forest 2000s 4,470

Tongass National Forest -- 60

Total NFS Lands 45,658

State of Alaska State of Alaska 4,043

Total State Lands 4,043

Private & Other Lands Ketchikan -- 39

Sealaska Regional Corporation <1980 151

Cape Fox Village Corporation 1980s–1990s 13,266

Other Land Owners 1980s–1990s 7,406

Total Private/Other Lands 20,862

TOTAL PROVINCE HARVEST 70,563
Appendix C

Catalog of Past Harvest A1-6 Final EIS

Table I-1

Acreage of Past Harvest by Landowner

Ownership Category Landowner

Est. Approx. 

Harvest 

Decade

Acres 

Harvested

Southern Outer Islands Biogeographic Province

Tongass National Forest Tongass National Forest 1950s 569

Tongass National Forest 1960s 3,737

Tongass National Forest 1970s 3,058

Tongass National Forest 1980s 5,737

Tongass National Forest 1990s 1,683

Tongass National Forest 2000s 354

Total NFS Lands 15,138

State of Alaska State of Alaska 1990s 2,102

Total State Lands 2,102

Private & Other Lands Haida Village Corporation -- 4

Klawock-Heenga Village Corporation -- 366

Sealaska Regional Corporation 2000s 31

Shaan Seat Village Corporation 1980s–1990s 3,324

Total Private/Other Lands 3,725

TOTAL PROVINCE HARVEST 20,965

Dall Island and Vicinity Biogeographic Province

Tongass National Forest Tongass National Forest <1950 77

Tongass National Forest 1950s 79

Tongass National Forest 1960s 213

Total NFS Lands 369

State of Alaska Total State Lands 0

Private & Other Lands Haida Village Corporation 1980s–1990s 365

Klukwan Villa Village Corporation 1980s–1990s 17,265

Sealaska Regional Corporation <1980 630

Sealaska Regional Corporation 1980s 4,549

Sealaska Regional Corporation 1990s 1,831

Sealaska Regional Corporation 2000s 8,011

Other Land Owners -- 265

Total Private/Other Lands 32,916

TOTAL PROVINCE HARVEST 33,285

South Prince of Wales Island Biogeographic Province

Tongass National Forest Tongass National Forest <1950 410

Tongass National Forest 1950s 60

Tongass National Forest 1960s 467

Tongass National Forest 1970s 368

Tongass National Forest 1980s 276

Tongass National Forest 1990s 994

Tongass National Forest 2000s 716

Tongass National Forest -- 1

Total NFS Lands 3,292

State of Alaska State of Alaska -- 351

Total State Lands 351

Private & Other Lands Sealaska Regional Corporation <1980 79

Sealaska Regional Corporation 2000s 79

Haida Village Corporation 1980s–1990s 589

Kootznoowoo Village Corporation 1980s–1990s 13,491

Other Land Owners -- 25

Total Private/Other Lands 14,184
Appendix C

Final EIS A1-7 Catalog of Past Harvest

Table I-1

Acreage of Past Harvest by Landowner

Ownership Category Landowner

Est. Approx. 

Harvest 

Decade

Acres 

Harvested

TOTAL PROVINCE HARVEST 17,827

North Misty Fiords Biogeographic Province

Tongass National Forest Tongass National Forest 1950s 81

Tongass National Forest 1960s 960

Tongass National Forest 1980s 68

Tongass National Forest -- 260

Total NFS Lands 1,370

State of Alaska State of Alaska -- 818

Total State Lands 818

Private & Other Lands Sealaska Regional Corporation 1980s 16

Sealaska Regional Corporation 2000s 8

Total Private/Other Lands 23

TOTAL PROVINCE HARVEST 2,211

South Misty Fiords Biogeographic Province

Tongass National Forest Total NFS Lands 0

State of Alaska Total State Lands 0

Private & Other Lands Total Private/Other Lands 0

TOTAL PROVINCE HARVEST 0

Ice Fields Biogeographic Province

Tongass National Forest Tongass National Forest 1960s 1,732

Tongass National Forest 1970s 1,311

Tongass National Forest 1980s 996

Tongass National Forest 2000s 5

Total NFS Lands 4,044

State of Alaska Total State Lands 0

Private & Other Lands Total Private/Other Lands 0

TOTAL PROVINCE HARVEST 4,044

Glacier Bay/Fairweather Range Biogeographic Province

Tongass National Forest Total NFS Lands 0

State of Alaska Total State Lands 0

Private & Other Lands Glacier Bay N.P. -- 200

Total Private/Other Lands 200

TOTAL PROVINCE HARVEST 200

Chilkat River Complex Biogeographic Province

Tongass National Forest Total NFS Lands 0

State of Alaska State of Alaska 1980s–2000s 17,069

Total State Lands 17,069

Private & Other Lands BLM -- 136

Glacier Bay N.P. -- 568

Private/Other -- 2,864

Total Private/Other Lands 3,568

TOTAL PROVINCE HARVEST 20,637
Appendix C

Catalog of Past Harvest A1-8 Final EIS

Part II – Statistics on the Alaska Forest Resources and Practices Act 

Implementation and State Timber Sales in Southeast Alaska

Part II presents a tabular summary of information provided by the State of Alaska Department of Natural 

Resources, Division of Forestry. Statistical information is not available for harvests prior to the Alaska 

Forest Resources and Practices Act (AFRPA), nor for some years since the Act. Tables II-1 through II-5 

provide statistics regarding the AFRPA, as it has been applied to private and other lands in Southeast 

Alaska. Tables II-6 through II-18 provide information on State timber sales in Southeast Alaska.

Table II-1

Forest Practices Act – Summary Statistics for Southeast Alaska, 1991–1998

1991 1992 1993 1994 1995 1996 1997 1998

New Notifications

SSE 103 117 145 124 131 146 123 87

NSE 2 0 8 0 3 1 0 0

TOTAL 105 117 153 124 134 147 123 87

Harvest Acreage in New Notifications Received

SSE 21,016 37,971 28,769 33,038 22,745 30,509 26,034 16,291

NSE 110 0 824 100 227 80 0 0

TOTAL 21,126 37,971 29,593 33,138 22,972 30,589 26,034 16,291

# Inspections

SSE 146 134 98 119 93 90 42 56

NSE 2 0 8 1 5 0 0 0

TOTAL 148 134 106 120 98 90 42 56

# Variation Trees Reviewed (=approved, denied, and other (e.g., withdrawn)

SSE 350 1,344 3,581 1,660 1,054 1,116 2,571 4,113

NSE 83 0 0 0 0 0 0 0

TOTAL 433 1,344 3,581 1,660 1,054 1,116 2,571 4,113

Table II-2

Forest Practices Act – Summary Statistics for Southeast Alaska, 1999–2006

1999 2000 2001 2002 2003 2004 2005 2006

New Notifications

SSE 79 104 36 43 51 47 43 51

NSE 0 0 19 10 6 6 5 3

TOTAL 79 104 55 53 57 53 48 54

Harvest Acreage in New Notifications Received

SSE 11,705 20,542 5,599 7,667 12,197 30,488 27,733 37,313

NSE 0 3,779 9,619 5,839 1,780 1,969 344 413

TOTAL 11,705 24,321 15,218 13,506 13,977 32,457 28,077 37,726

# Inspections

SSE 32 89 44 43 58 35 59 20

NSE 0 0 25 24 11 9 13 9

TOTAL 32 89 69 67 69 44 72 29

# Variation Trees Reviewed (=approved, denied, and other (e.g., withdrawn)

SSE 1,522 330 103 58 336 948 411 0

NSE 0 0 144 20 199 17 0 0

TOTAL 1,522 330 247 78 535 965 411 0
Appendix C

Final EIS A1-9 Catalog of Past Harvest

Table II-3

Forest Practices Act – Summary Statistics for Southeast Alaska, 2007–2014

2007 2008 2009 2010 2011 2012 2013 2014

New Notifications

SSE 34 27 32 61 54 32 14 14

NSE 7 2 8 8 6 3 5 0

TOTAL 41 29 40 69 60 33 19 14

Harvest Acreage in New Notifications Received

SSE 10,263 18,988 7,752 17,532 5,577 8,373 4,717 1,724

NSE 1,039 211 1,858 1,740 2,241 6,379 40 0

TOTAL 11,302 19,199 9,610 19,272 7,818 14,752 4,757 1,724

# Inspections (Department of Forestry)

SSE 39 42 29 37 18 6 20 31

NSE 8 5 3 1 2 1 3 3

TOTAL 47 47 32 38 18 7 23 34

# Variation Trees Reviewed (=approved, denied, and other (e.g., withdrawn)

SSE 0 538 222 14 6 46 312 202

NSE 0 0 0 0 0 0 243 0

TOTAL 0 538 222 14 6 46 555 202

NR=Not reported in ADOF Annual Report

Table II-4

Forest Practices Act – Road Miles Summary for State of Alaska, 1997–2006

Road Miles Notified 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006

SSE 156 104 101 130 39 58 71 69 34 25

NSE 0 0 0 0 104 20 10 3 4 3

Mat-Su/SW 13 3 28 0 0 3 5 13 12 46

Kenai-Kodiak 195 50 146 44 65 146 96 57 25 11

COASTAL 364 157 275 174 208 227 182 142 75 85

Fairbanks 1 0 0 3 0 1 7 3 0 0

Delta 0 0 0 0 0 0 0 0 4 0

Tok 3 0 0 0 0 0 0 60 58 0

Copper R. 7 5 0 0 0 0 0 46 0 0

NORTHERN 11 5 0 3 0 1 7 109 62 0

TOTAL 375 162 275 177 208 228 189 251 136 85
Appendix C

Catalog of Past Harvest A1-10 Final EIS

Table II-5

Forest Practices Act – Road Miles Summary for State of Alaska, 2007-2014

Road Miles Notified 2007 2008 2009 2010 2011 2012 2013 2014

SSE 23 23 30 55 28 15 15 16

NSE 1 0 0 0 10 16 0.3 0

Mat-Su/SW 2 1 0 0 61 64 0 0

Kenai-Kodiak 24 16 3 66 0 0 6 44

COASTAL 50 40 33 122 99 95 21 60

Fairbanks 0 0 0 3 0 6 4 2

Delta 0 1 0 0 0 0 0 0

Tok 0 0 0 0 27 31 0 1

Copper R. 0 0 0 0 1 0 0 0

NORTHERN 0 1 0 3 28 37 4 3

TOTAL 50 41 33 124 127 132 26 63

Table II-6

State Timber Sales Sold 

Year

Volume sold (MBF1)

North-Central South-Central Southeast

1983 5,964 51,985 54

1984 14,735 4,445 1,907

1985 12,182 4,698 3,298

1986 4,450 2,587 424

1987 9,352 3,081 7,174

1988 16,510 4,513 6,452

1989 13,872.5 1,990 5,738

1990 14,317.9 3,398.8 18,064.5

1991 9,519 565 72.2

1992 20,613 3,306 186

1993 17,208 1,020 9,065

1994 1,569 5,564 8,903

1995 107,521 28,332 4,455

1996 182,131 9,368 1,109

FY97 15,528 129 5,942

FY98 13,211 17,754 14,623

FY99 6,836 2,803 4,797

FY00 6,637 5,774 8,365

FY01 6,064 1,857 954

FY02 4,207 1,333 11,340

FY03 4,813 3,779 4,094

FY04 2,708 957 8,064

FY05 5,594 4,934 16,003

FY06 12,478 6,638 10,777

FY07 6,420 30,110 24,437

FY08 7,163 4,316 4,059

FY09 11,036 1,451 5,597

FY10 5,445 2,460 4,626

FY11 7,281 3,913 12,865

FY12 8,815 11,067 1,346

FY132 2,662 1,918 4,976

FY14 19,621 379 8,512 1 Converted from Mcf.

2 FY13 values are timber volume offered. 

Note: data collection changed from calendar year (CY) to fiscal year (FY) with some overlap between 1996 and 

FY97.
Appendix C

Final EIS A1-11 Catalog of Past Harvest

Table II-7

FY 97 State Timber Sales Sold – Southeast

Area Sale Name Acres Sale Date Use Vol MBF

Ketchikan Ronald Brown 6 7/22/1996 local 37

Ketchikan Pat Richter 4 8/21/1996 local 43

Ketchikan Ernie Eads 9 8/22/1996 local 34

Ketchikan Last Chance Enterprises 5 1/13/1997 local 55

Ketchikan Ernie Eads 1 2/3/1997 local 8

Ketchikan Pat Richter 1 3/3/1997 local 4

Ketchikan Warren Jones 2 3/7/1997 local 46

Ketchikan Norman Canaday 5 3/18/1997 local 14

Ketchikan Ralph Porter 1 5/26/1997 local 34

Ketchikan Daryl Tinkness 1 6/16/1997 local 19

Ketchikan Ernie Eads 9 6/9/1997 local 228

Ketchikan Pete Smit 8 5/30/1997 local 54

SUBTOTAL 12 52 576

Haines Pond View 22 10/14/1996 local 249

SUBTOTAL 1 22 249

Juneau Shadow 45 7/26/1996 Export 1,455

Juneau Corner 12 9/30/1996 local 141

Juneau Blackheart 14 11/7/1996 local 425

Juneau Nufie 79 2/11/1997 local 1,700

Juneau Thumb Nail 45 2/11/1997 local 802

Juneau Pt. Frederick #6 9 3/7/1997 Export 446

Juneau Silas Triangle 6 6/30/1997 mixed 106

Juneau Magazine Road 3 6/30/1997 Export 42

SUBTOTAL 8 213 5,117
Appendix C

Catalog of Past Harvest A1-12 Final EIS

Table II-8

State Timber Sales Sold – FY 98 – Southeast

Area Sale Name Acres Sale date Use Vol MBF

Ketchikan Fleenor 5 7/25/1997 local 178

Ketchikan Sneather 0 10/21/1997 local 7

Ketchikan Whale pass assoc. I 0 11/3/1997 local 55

Ketchikan Whale pass assoc. Ii 0 2/26/1998 local 67

Ketchikan Tinkess 1 11/14/1997 local 5

Ketchikan Trumble 1 11/24/1997 local 1

Ketchikan Fleenor #2 8 3/6/1998 local 147

Ketchikan Gray 1 12/8/1997 local 2

Ketchikan Smith 3 PENDING local 16

Ketchikan Eads 2 5/12/1998 local 44

Ketchikan Hammar 3 5/12/1998 local 21

Ketchikan Hollis Comm. Council 0 5/12/1998 local 74

Ketchikan Kitkun 160 6/29/1998 local 4,300

Subtotal 13 184 4,917

NSE Thunder Creek 565 7/15/1997 export 4,331

NSE Buster Benson 7 8/18/1997 local 80

NSE Highline 8 9/2/1997 local 244

NSE Alaska Power & Tele. 0 9/18/1997 local 6

NSE Fred Strong 4 10/9/1997 local 32

NSE Scott Rossman 5 5/8/1998 local 23

NSE Scott Rossman #2 2 5/28/1998 local 12

NSE Scott Rossman #3 2 6/15/1998 local 58

NSE Banana Pt. Salvage 2 7/9/1997 local 40

NSE Roy's Breakdown 41 7/23/1997 local 1,339

NSE Silas 14 7/23/1997 local 466

NSE Roy Sokol Salvage 1 7/29/1997 local 9

NSE Thumbnail Unit 3 2 9/12/1997 local 229

NSE Thumbnail ii 29 9/15/1997 local 607

NSE Mitkof Hwy Row 1 11/21/1997 local 16

NSE Hemlock Salvage 0 11/21/1997 local 9

NSE Shadow Salvage 0 11/24/1997 export 120

NSE Hermit Creek 4 12/22/1997 local 102

NSE Pt. Frederick #6 0 6/5/1998 local 58

NSE Eastern Passage I 83 2/23/1998 local 1,681

NSE Nufie II 19 6/9/1998 local 244

Subtotal 21 788 9,706
Appendix C

Final EIS A1-13 Catalog of Past Harvest

Table II-9

State Timber Sales Sold – FY 99 Coastal Region

Area Sale Name Acres Sale Date MBF Use

Ketchikan Fleenor No. 3 6 07/27/98 125 Local

Ketchikan Small #2 4 08/17/98 123 Local

Ketchikan Small #3 3 09/28/98 68 Local

Ketchikan Small #4 6 11/30/98 382 Local

Ketchikan Small #5 4 11/30/98 308 Local

Ketchikan Small #6 1 11/24/98 18 Local

Ketchikan Small #7 3 12/11/98 80 Local

Ketchikan Small #8 3 12/24/98 67.7 Local

Ketchikan Small #9 0.1 03/26/99 10 Local

Ketchikan Small #10 9.9 05/19/99 357 Local

Ketchikan Small #11 4.7 06/01/99 150 Local

Subtotal 11 44.7 1,688.7

NSE Thumbnail III 74 09/21/98 1,613 Local

NSE Eastern Passage I 52 06/01/99 1,429 Local

NSE

McCormack Creek 

Rd. Project ROW 0 08/03/98 37.25 Local

NSE Del Mikkelsen 5 12/03/98 29 Local

Subtotal 5 131 3,108

Table II-10

State Timber Sales Sold – FY 00 – Southeast

Area Sale Name Acres Sale Date MBF Mcf Use

Ketchikan SE-959K 1 07/13/99 3 Local

Ketchikan Coffman Cove 214 07/27/99 5,515 Local

Ketchikan SE-960K 1 09/21/99 14 Local

Ketchikan SE-962K 5 09/21/99 117 Local

Ketchikan SE-1019K 1 03/13/00 12 Local

Ketchikan SE-1021K 5 04/07/00 491 Local

Ketchikan SE-970K 2 05/22/00 27 Local

Ketchikan SE-971K 1 06/08/00 8 Local

Ketchikan SE-1020K 1 34 Local

Ketchikan SE-972K 5 468 Local

Ketchikan SE-973K 8 257 Local

Subtotal 11 244 6,945.9

NSE Small #1, SE-474J 3 07/19/99 139 Local

NSE

Eastern Passage I, 

Unit 4 24 12/30/99 656 Local

NSE Devils Elbow 2 07/19/99 24 Local

NSE Porcupine Snow 12/22/99 41 Local

NSE High Extension 8 02/01/00 49 Local

NSE Porcupine Wings 24 03/28/00 419 Any

NSE Porcupine Heights 5 04/05/00 38 Local

NSE Roy's Favorite 3 06/02/00 53 Local

Subtotal 8 69 1,419
Appendix C

Catalog of Past Harvest A1-14 Final EIS

Table II-11

State Timber Sales Sold – FY 01 – Southeast

Area Sale Name Acres

Sale 

Date MBF Purchaser Use

SSE SE-979-K 1 01/12/01 20 Jack Dupertuis local

SSE SE-983-K 2 03/14/01 28 Sealaska export

SSE SE-1020-K 2 10/16/00 34

Naukati 

Adventures local

SSE SE-976-K 7 10/03/00 391 Pat Richter local

SSE SE-980-K 0 12/08/00 10

Evergreen 

Timber export

SSE SE-981-K 2 12/08/00 30

Hummer 

Enterprises local

SSE SE-982-K 4 05/16/01 80 B&W Lumber local

SSE SE-984-K 0 05/17/01 10

Hummer 

Enterprises local

Subtotal 8 17 603

NSE Ski Hill 5 07/29/00 34 The Stump Co. local

NSE 37Mile 6 04/10/01 104 The Stump Co. local

NSE Chilkat Lake 2 04/10/01 19 Bob Jensen local

NSE Knob 4 2 04/10/01 28 Tophat Logging local

NSE Birch Hill 1 04/30/01 9 Eager Beaver local

NSE

Knob 

Extension 1 06/18/01 1 Sage Thomas local

NSE

Knobs 

Backside 5 06/25/01 24 Carl Smith local

NSE Half Load 1 01/18/01 11 Hidden Valley local

NSE

Knob 3 

Extension 2 02/05/01 16 Green Diamond local

NSE Daisy 3 02/23/01 65 Hidden Valley local

NSE SE-741 1 02/26/01 11 Don Peterson local

NSE Three Peaks 2 03/12/01 20 Green Diamond local

NSE Knob ABC 2 03/21/01 9 Green Diamond local

Subtotal 13 33 351
Appendix C

Final EIS A1-15 Catalog of Past Harvest

Table II-12

State Timber Sales – FY 02 – Southeast

Area Sale Name Acres Sale Date MBF Use

SSE Naukati West 70 04/29/02 2,685 V-A

SSE East Pass #5 50 04/01/02 1,110 V-A

SSE Tuxecan 134 04/15/02 4,018 V-A

SSE Richter #2 4 07/09/01 187 V-A

SSE Richter #3 3 02/08/02 90 V-A

SSE Jones 1 0 09/18/01 13 V-A

SSE Sunde 1 0 05/30/02 7 V-A

SSE Clark Bay Group 3 11/02/01 26 V-A

SSE Gildersleeve1 1 09/17/01 24 V-A

SSE Thorne Bay #1 80 09/14/01 2,539 V-A

Subtotal 10 345 10,699

NSE 37.5 Mile Fall 4 10/25/01 51 V-A

NSE 37-Mile Addition 4 07/24/01 28 V-A

NSE Daisy Salvage 1 10/16/01 31 V-A

NSE Birch Road A 2 07/13/01 17 V-A

NSE Birch Pole 1 01/08/02 3 V-A

NSE Backside 2 3 07/10/01 19 V-A

NSE Daisy 2 7 05/24/02 117 V-A

NSE Birch road 2 07/06/01 10 V-A

NSE Daisy Dead 2 06/06/02 9 V-A

NSE LS Mountain 10 07/09/01 357 V-A

Subtotal 10 36 641
Appendix C

Catalog of Past Harvest A1-16 Final EIS

Table II-13

State Timber Sales Sold – FY 03 – Southeast

Area Sale Name Acres Sale Date MBF Use

SSE Yatuk Creek #1 4 10/15/02 179 VA

SSE Yatuk Creek #2 5 10/15/02 228 VA

SSE Yatuk Creek #3 2 10/15/02 80 VA

SSE Yatuk Creek #4 4 10/15/02 41 VA

SSE Yatuk Creek #5 6 10/15/02 205 VA

SSE Yatuk Creek #6 4 10/15/02 112 VA

SSE Yatuk Creek #7 4 10/15/02 308 VA

SSE Yatuk Creek #8 3 10/15/02 151 VA

SSE Yatuk Creek #9 64 01/06/03 2,064 VA

SSE Frederick Rd. #1 4 10/14/02 125 VA

SSE Thorne Bay Burn #4 2 11/01/02 53 VA

SSE Thorne Bay Burn #5 2 11/01/02 40 VA

SSE Sandy Road #1 6 11/01/02 87 VA

SSE Sunde #2 <1 05/06/03 10 VA

Subtotal 14 110 3,683

NSE Starigavin ROW NSE1026 1 09/27/02 6 VA

NSE Tidy Stump SE-759 1 08/23/02 25 VA

NSE Farm Wood 3 01/17/03 50 VA

NSE Jensen Skid Road 3 02/18/03 19 VA

NSE Hemlock Switch 5 02/10/03 67 VA

NSE Spruce Addition 1 02/04/03 10 VA

NSE 20 Mile Xing 2 02/26/03 13 VA

NSE Half Dozen 1 02/28/03 4 VA

NSE Wolf Pack 1 03/10/03 13 VA

NSE Chilkat Lake Road 2 03/27/03 5 VA

NSE Spruce Log 2 01/03/03 10 VA

NSE Hemlock Home 1 01/13/00 13 VA

NSE Porcupine Clean 1 11/04/02 11 VA

NSE Farm Birch 2 12/17/02 6 VA

NSE Wolf Skid 2 04/04/03 4 VA

NSE Spruce Tap 2 05/05/03 7 VA

NSE Hemlock Corner 2 05/05/03 41 VA

NSE 37 Mile Patch 1 05/19/03 10 VA

NSE 38 Mile Draw 9 05/21/03 84 VA

NSE Daisy Cleanup 3 06/13/03 64 VA

Subtotal 20 45 462
Appendix C

Final EIS A1-17 Catalog of Past Harvest

Table II-14

State Timber Sales Sold – FY 04 – Southeast

Area Sale Name Acres Sale Date MBF Use

SSE Boy Scout 19 08/21/03 990.18 local

SSE Intertie ROW n/a 07/21/03 172.00 local

SSE Coffman Cove R 1 08/18/03 40.40 local

SSE Kasaan 1 149 10/21/03 3,238.00 local

SSE East Naukati 135 05/06/04 3,164.00 local

SSE Thorne Bay ROW 1 12/12/03 42.43 export

Subtotal 6 305 7,647.01

NSE Deats 1-N. Douglas 1 03/14/04 1.00 local

NSE Little Salmon Mt. 8 10/03/03 357.00 local

NSE 38-mile Draw 5 1 10/02/03 10.00 local

NSE Spruce Rose 1 07/08/04 11.00 local

NSE Big Hemlock 2 07/23/03 34.00 local

NSE Boulder Spruce 3 08/10/03 52.00 local

NSE Boulder Spruce 2 10 10/30/03 24.00 local

NSE 38 Mile Pocket 1 11/25/03 33.00 local

NSE Stretch Time 2 12/10/03 29.00 local

NSE Ice Road 2 02/06/04 28.00 local

NSE Boulder 6 x 6 1 05/03/04 21.00 local

NSE Stretch Melt 2 06/10/04 31.00 local

NSE Nataga Skid 3 06/10/04 5.24 local

NSE Stretch 6 11/28/03 53.00 local

NSE 38 Mile Extension 1 12/09/03 22.00 local

Subtotal 15 44 711.24
Appendix C

Catalog of Past Harvest A1-18 Final EIS

Table II-15

State Timber Sales Sold – FY 05 – Southeast

Area Sale Name Acres Sale Date MBF Use

SSE 2058 Road 1/Jones #2 3 07/09/04 36 local

SSE 2058 Road 2/Jones #3 2 07/09/04 28 local

SSE 2058 Road 4/Jones #1 2 07/09/04 19 local

SSE 2058 Road 5/Thorne Bay WP 6 07/27/04 107 local

SSE 2058 Road 6/Thorne Bay WP 3 07/21/04 65 local

SSE Sandy Road 2 20 08/20/04 419 local

SSE Coffman Cove ROW #2 1 08/23/04 8 local

SSE Thorne Bay 2 130 10/30/04 4130 local

SSE Control Lake 1-mid 112 11/15/04 3627 local

SSE Shady Tie-in 40 11/29/2004 987 local

SSE Kasaan 6 6 11/17/04 179 local

SSE Control Lake 2 5 12/03/04 121 local

SSE Control L. 3 8 12/03/04 189 local

SSE Control L. 4 17 12/09/04 491 local

SSE Kasaan 2 108 12/17/04 4028 local

SSE Mt. Point #1 3 05/12/05 149 export

SSE Choker Setter Cir. 1 06/28/05 23 local

Subtotal 17 466 14,606

NSE Boulder Load 1 7/6/2004 8 local

NSE Boulder Six X Six 2 1 7/12/2004 8 local

NSE Alder Rerun 2 7/23/2004 27 local

NSE Alder Rerun 2 2 9/1/2004 41 local

NSE Nataga Skid 2 1 8/12/2004 17 local

NSE Alder III 2 9/17/2004 59 local

NSE Porcupine Mining 1 9/10/2004 20 local

NSE Porcupine Mining II 1 9/10/2004 23 local

NSE Klehini U14 Corner 2 12/11/2004 32 local

NSE Porcupine Mining III 1 10/15/2004 13 local

NSE Takshanuk Trail 3 11/7/2004 14 local

NSE 37 Mile Ridge 2 11/11/2004 15 local

NSE Porcupine Low Road 1 11/12/2004 10 local

NSE Battleship Island 1 12/12/04 2 local

NSE West Herman 2 9 1/3/2005 185 local

NSE 37 Mile Bowl 2 1/4/2005 27 local

NSE 37 Mile Bowl 2 1 1/24/2005 38 local

NSE Purlin 1 02/16/05 1 local

NSE Pondside 2 02/28/05 31 local

NSE West Draw 2 03/14/05 21 local

NSE West Herman 1 23 03/01/05 594 local

NSE West Draw #2 1 04/01/05 21 local

NSE Knobs Rerun 2 05/21/05 49 local

NSE Fabrizio Mining 6 05/27/05 82 local

NSE Birch Reload 1 05/18/05 6 local

NSE Nataga Sky 1 06/10/05 22 local

NSE Dunit Bench 2 06/20/05 31 local

Subtotal 27 74 1,397
Appendix C

Final EIS A1-19 Catalog of Past Harvest

Table II-16

State Timber Sales Sold – FY 06 – Southeast

Area Sale Name Acres Sale Date MBF Use

SSE 2058 Rd 8 small/Gutchi Creek #2 5 08/02/05 108 local

SSE SSE 1230/2058 Rd 8 mid 18 10/01/05 588 local

SSE Eastern Passage units 6-12 395 11/01/05 9110 local

SSE Steep Drive 1 10/19/05 20 local

SSE South Thorne Arm #1 0 10/01/05 2 local

SSE Leask Lake Sort Yard 5 09/22/05 60 export

SSE Kasaan 6 6 3/28/2006 179 local

Subtotal 7 430 10,067

NSE Tatshunak Trail 1 8/2/2005 5 local

NSE Knobs B-C Timber 1 7/25/2005 16 local

NSE Nataga Stretch 18 7/25/2005 173 local

NSE Glacier Salvage 10 10/1/2005 100 local

NSE Spruce Corner 1 10/3/2005 27 local

NSE KB West Spur 1 10 10/10/2005 144 local

NSE 1424 Hemlock Ridge 1 12/29/2005 46 local

NSE 1425 Porcupine Salvage 3 1/6/2006 25 local

NSE 1426 Billy Goat 3 1/6/2006 24 local

NSE 1427 Farm Special 5 2/1/2006 38 local

NSE 1428 Farm Spur 2 3 03/15/06 37 local

NSE 1429 Billy Goat 2 3 04/11/06 55 local

NSE Boulder Firewood 1 04/11/06 10 local

NSE Porcupine Firewood 2 06/26/06 10 local

Subtotal 14 62 710
Appendix C

Catalog of Past Harvest A1-20 Final EIS

Table II-17

State Timber Sales Sold – FY 07 – Southeast

Area Sale Name Acres Sale Date MBF Use

SSE Bostwick #1 362 11/29/06 12,687 local

SSE 2058 Road Small 6 07/10/06 182 local

SSE 2058 Road Small 4 07/10/06 98 local

SSE Control Lake Fir 1 08/25/06 0 local

SSE Leask Lake Aide 1 08/25/06 19 research

SSE South Thorne Bay 128 07/02/06 3,330 local

SSE D-1 #1 1 04/02/07 7 export

SSE 20 Road 26 05/29/07 5,145 local

SSE Whipple Creek 26 04/02/07 2,334 export

SSE Bostwick Trail Lo 0 6/20/2007 13 local

Subtotal 10 555 23,815

NSE KB2 1 7/28/2006 17 local

NSE Cabin Log 4 8/10/2006 41 local

NSE Spur Road 1 8/10/2006 12 local

NSE West Herman 3 4 8/25/2006 105 local

NSE Porcupine Spruce 3 9/12/2006 132 local

NSE Hemlock Spruce 3 9/12/2006 55 local

NSE KB3 6 10/26/2006 42 local

NSE Winds 2 11/2/2006 119 local

NSE Porucpine Road 1 11/7/2006 5 local

NSE Warm Springs 5 10/01/06 1 local

NSE Hidden 2 01/03/07 16 local

NSE 35 Mile Snow Co 10 04/09/07 9 local

NSE Sunlight Salvage 2 05/11/07 45 local

NSE Ski Hill 3 06/05/07 23 local

Subtotal 14 47 622
Appendix C

Final EIS A1-21 Catalog of Past Harvest

Table II-18

State Timber Sales Sold – FY 08 through 14 – Southeast

Area Sale Name Acres Sale Date MBF Product

Fiscal Year 2008

SSE Java 44 12/14/2007 1,325 Sawlog

SSE Gutchi Creek 24 12/14/2007 34 Sawlog

SSE Squirrel 72 04/07/2008 - Sawlog

SSE Kasaan Small Sale #2 5 04/16/2008 26 Sawlog

SSE Kasaan Small Sale #3 6 04/16/2008 8 Utility

SSE Indian Creek 72 07/14/2008 111 Sawlog

SSE Limestone Place 1 07/14/2008 0.4 Sawlog

SSE Mountain Pt. #2 2 08/13/2008 14 Sawlog

SSE Jinhi Bay 10 08/13/2008 54 Utility

SSE Kasaan Small Sale 5 09/17/2008 4 Utility

Subtotal 10 241 1,576 

NSE Old Highway 3 4 10/24/2007 21 Sawlog

NSE Revetment 3 01/18/2008 10 Sawlog

NSE Old Highway #4 2 04/16/2008 1 Utility

NSE Old Highway #5 2 05/09/2008 16 Sawlog

NSE Sunshine LSM Salvage 2 07/15/2008 100 Utility

NSE KB 6 14 07/21/2008 12 House Log

NSE Billy Goat Cleanup 2 08/06/2008 29 Sawlog

NSE Roads End 5 08/14/2008 95 Utility

NSE West Herman 4 5 09/04/2008 50 Sawlog

NSE Glacier Side Salvage 9 09/15/2008 100 Sawlog

NSE KB Firewood 8 09/25/2008 2 Utility

Subtotal 11 52 436 

Fiscal Year 2009

SSE Squirrel Export 15 01/06/2009 137 Sawlog

SSE Kasaan #2 Export 10 02/17/2009 105 Sawlog

SSE Jinhi Bay Export - 02/17/2009 93 Sawlog

SSE Java Export - 02/18/2009 0.2 Sawlog

SSE 20 Road Export - 02/18/2009 47 Sawlog

SSE S.Thorne Bay #1 Export - 03/04/2009 4 Sawlog

SSE Heceta #2 1 04/02/2009 1 Sawlog

SSE S. Thorne Bay #2 107 06/10/2009 2,149 Sawlog

SSE Indian Creek - Export - 07/02/2009 185 Sawlog

Subtotal 9 133 2,720 

NSE Gustavus Gravel FC 1 10/20/2008 8 Sawlog

NSE Big Spruce 1 03/03/2009 3 Sawlog

NSE KB-7 10 07/02/2009 25 Sawlog

NSE Jim Nail Mining Claim 2 08/15/2009 5 House Log

NSE Porcupine Bear II - 09/02/2009 13 Sawlog

Subtotal 5 14 54 
Appendix C

Catalog of Past Harvest A1-22 Final EIS

Table II-18

State Timber Sales Sold – FY 08 through 14 – Southeast

Area Sale Name Acres Sale Date MBF Product

Fiscal Year 2010

SSE Kasaan #7 Export 1 11/07/2009 18 Sawlog

SSE Zarembo 175 12/17/2009 1,803 Sawlog

SSE Kasaan Closout 21 04/26/2010 22 Utility

SSE S. Thorne Bay #2 Export - 04/26/2010 242 Sawlog

SSE Bradford Yellow Cedar - 08/05/2010 3 Sawlog

SSE Acorn 5 09/22/2010 73 Sawlog

Subtotal 6 202 2,161 

NSE Glacier Creek Rd Salvage 5 10/02/2009 100 Utility

NSE Elbow 5 10/20/2009 100 Utility

NSE Porcupine Bear III 2 10/25/2009 2 Sawlog

NSE Flower 5 10/25/2009 100 Utility

NSE State 38 3 12/09/2009 12 Sawlog

NSE 38 Mile South 3 04/28/2010 2 House Log

NSE 35 Times 2 07/15/2010 10 Utility

NSE West Herman Cleanup 1 07/15/2010 5 Utility

Subtotal 8 26 331 

Fiscal Year 2011

SSE D1 #2 7 02/01/2011 9 Utility

SSE D1 Heli-Dup1 8 02/17/2011 353 Sawlog

SSE D1 Heli-Dupe2 8 02/18/2011 360 Sawlog

SSE R/W Spruce Log - 03/18/2011 4 Sawlog

SSE North Thorne Bay #3 122 04/22/2011 3,063 Sawlog

SSE Indian Creek #2 230 06/21/2011 11 Sawlog

SSE East Pass Units 9-12 194 08/28/2011 250 Sawlog

Subtotal 7 569 4,050 

NSE 39 Mile ROW 2 11/17/2010 9 House Log

NSE 37.5 Salvage 5 12/17/2010 50 Utility

NSE North 38 1 03/25/2011 3 House Log

NSE Bear Creek 2 05/13/2011 10 House Log

NSE Billy Goat Clean Up #2 1 06/13/2011 40 Utility

NSE Assisted Migration 4 06/17/2011 19 Sawlog

NSE Billy Goat Cleanup #3 1 06/27/2011 1 House Log

NSE Bear Creek 2 3 07/07/2011 13 Utility

NSE Jim Nail Salvage 1 07/18/2011 50 Utility

NSE Bear Creek SMZ 1 07/20/2011 11 Sawlog

NSE 35 Times 2 2 07/21/2011 10 Sawlog

NSE Bear Creek SMZ 2 1 08/08/2011 1 Sawlog

Subtotal 12 24 217 
Appendix C

Final EIS A1-23 Catalog of Past Harvest

Table II-18

State Timber Sales Sold – FY 08 through 14 – Southeast

Area Sale Name Acres Sale Date MBF Product

Fiscal Year 2012

SSE Chopsticks - 10/14/2011 4 Sawlog

SSE Blind Slough Salvage 1 01/30/2012 2 Sawlog

SSE Beach Road #1 23 05/07/2012 191 Sawlog

Subtotal 3 24 197 

NSE 38 Mile Salvage 4 02/07/2012 100 Utility

NSE 37 Mile Creek 9 03/30/2012 4 Sawlog

NSE KB7 Leftovers 3 07/03/2012 12 House Log

NSE 35 x 3 2 08/13/2012 5 Sawlog

NSE Houselog Bonanza 3 08/22/2012 4 Sawlog

NSE 211 Road Salvage 3 08/24/2012 30 Fuel Wood

NSE Windthrown 3 08/28/2012 6 Sawlog

Subtotal 7 27 161 

Fiscal Year 2013

SSE S. Thorne Bay #3 196 11/17/2012 30 Sawlog

SSE Whitman Lake Penstock 1 02/12/2013 0.2 Sawlog

SSE Colier Tree 1 03/13/2013 8 Sawlog

SSE Heceta Second Growth 137 07/22/2013 301 Utility

Subtotal 4 335 339 

NSE Hemlock Revetment 3 10/08/2012 32 Sawlog

NSE 13 Mile Bench #2 3 02/22/2013 2 Utility

NSE 13 Mile Bench #2 Addition 1 03/14/2013 1 Sawlog

NSE KB9 3 06/04/2013 7 House Log

NSE KB 10 2 07/15/2013 19 Sawlog

NSE Tenekee Hydro 4 09/09/2013 55 Sawlog

Subtotal 6 16 116 

Fiscal Year 2014

SSE Whitman Lake Penstock #2 0.1 02/21/2014 2 Sawlog

SSE Control Lake Timber Sale 10 02/28/2014 46 Sawlog

SSE Hollis Slide USFS Wood - 03/06/2014 4 Unknown

SSE Blankenship ROW - 03/11/2014 4 Sawlog

SSE South Thorne Bay 4 98 03/12/2014 35 Sawlog

SSE Naukati Decks - 06/10/2014 2 Sawlog

Subtotal 6 108 93 

NSE 13 Mile Bench #5 1 02/12/2014 26 House Log

NSE 13 MIle Bench #6 1 03/14/2014 1 Sawlog

NSE 13 Mile Bench Birch 1 03/19/2014 2 Sawlog

NSE KB14 5 07/15/2014 25 Utility

Subtotal 4 8 54 
APPENDIX D

EVALUATION AND INTEGRITY OF

THE TONGASS NATIONAL FOREST

OLD-GROWTH HABITAT 

CONSERVATION STRATEGY
Appendix D

Final EIS D-i Old-growth Habitat Conservation Strategy

Appendix D

Tongass National Forest

Evaluating Integrity of the Tongass National Forest

Old-growth Habitat Conservation Strategy

CONTENTS

Introduction .................................................................................................................................... D-1

Old-growth Habitat Conservation Strategy ........................................................................................ D-2

Scope of the Analysis and Acknowledgement of New Science........................................................... D-3

Current Status of Land Management on the Tongass........................................................................ D-5

Projected Versus Actual Timber Harvest Levels ............................................................................D-5

Ongoing GIS Mapping Updates.................................................................................................... D-6

Modifications to the Conservation Strategy Since 2008..................................................................D-6

External Factors that Have Affected the Conservation Strategy Since 2008 ....................................D-6

Proposed Modifications to Contributing Elements of the Conservation Strategy .................................. D-7

Overall Approach to Young-growth Management...........................................................................D-7

Old-growth Habitat LUD and Other Non-Development LUDs..........................................................D-8

Proposed Modifications to Forest Plan Standards and Guidelines ................................................ D-13

Beach and Estuary Fringe.................................................................................................... D-13

Riparian Management Areas ................................................................................................ D-17

Legacy Forest Structure ....................................................................................................... D-19

Wildlife................................................................................................................................ D-19

Other Non-wildlife Standards and Guidelines......................................................................... D-20

Integrity of the Conservation Strategy............................................................................................. D-20

References................................................................................................................................... D-24
Appendix D

Final EIS D-1 Old-growth Habitat Conservation Strategy

Introduction

This appendix provides an overview of the rationale and assumptions used for evaluating proposed 

changes to the 2008 Tongass Land and Resource Management Plan (2008 Forest Plan) in relation to the 

Tongass Old-growth Habitat Conservation Strategy (conservation strategy). The conservation strategy, 

built from current conservation science, provides for an ecological approach to conservation of old-growth

forest and associated species in the Forest Plan, and consists of a system of old-growth reserves (OGRs) 

and management restrictions on matrix lands (non-reserve areas). Riparian, beach, and estuary habitats 

are considered contributing elements to the OGR component of the strategy in that they were designed to 

maintain landscape connectivity among large and medium OGRs and non-development LUD 

designations. An intensive scientific evaluation of the Conservation Strategy and species-specific viability 

assessments were included in the 1997 Forest Plan planning efforts (USDA Forest Service 1997b, 

Appendix N). This appendix builds on Appendix N of the 1997 Forest Plan and considers Appendix N a 

foundation and primary reference for the science behind the conservation strategy.

On May 27, 2014, the Tongass National Forest initiated an amendment designed to transition from timber 

harvest dominated by old-growth to young-growth over the next 10 to 15 years (79 FR 30075). The need 

for change comes from a July 2013 memo from U. S. Department of Agriculture Secretary Tom Vilsack 

(Secretary’s Memorandum 1044-009). In this memo, the Secretary directs the Tongass to transition its 

forest management program to be more ecologically, socially, and economically sustainable by 

transitioning to young-growth harvest at the end of this 10 to 15 year period.

In response, the Forest Service is proposing to amend the 2008 Forest Plan and prepared this

Environmental Impact Statement (EIS) to evaluate the proposed changes. Five alternatives were 

developed for detailed analysis, including the No Action (Alternative 1). Alternative 1 represents current 

management (i.e., the 2008 Forest Plan). Alternatives 2, 3, 4, and 5 (the Preferred Alternative) were 

designed to accomplish a more rapid transition to young-growth management than considered in the 

2008 Forest Plan, while maintaining a viable timber industry in Southeast Alaska. The alternatives vary in 

how quickly the transition is reached, with some alternatives allowing young-growth harvest in nondevelopment LUDs and modifying other contributing elements of the conservation strategy to accomplish 

the transition in a shorter time frame than the current Forest Plan. Alternative 5 is the proposed Forest 

Plan, and the Preferred Alternative. It was developed by the Tongass Advisory Committee, a FACA 

committee. Each of these alternatives is described in detail below.

New direction in the proposed Forest Plan was developed to facilitate this transition including the 

identification of lands suitable for timber production employing young-growth management. Under some 

alternatives, young-growth stands in the beach buffer and in RMAs outside of Tongass Timber Reform 

Act (TTRA) buffers or in non-development LUDs are considered suitable for timber production. The Forest 

Service has the dual responsibility of ensuring that the transition to young-growth management maintains 

a viable timber industry, while also maintaining the integrity of the conservation strategy. Other recent 

occurrences which affect the conservation strategy include the Carl Levin and Howard P. “Buck” McKeon 

National Defense Authorization Act for Fiscal Year 2015 (hereafter referred to as the National Defense 

Authorization Act for Fiscal Year 2015) and changes in the 2001 Roadless Rule. These factors, which are 

outside of the authority of the Forest Service, are also described below.

The remainder of this appendix is broken into five major sections. They (1) provide an overview of the 

current conservation strategy (2) describe the scope of the analysis and discuss new science relevant to 

the conservation strategy since 2008, (3) summarize the status of land management on the Tongass and 

changes to the conservation strategy since 2008, (4) describe proposed modifications to contributing 

elements of the conservation strategy and evaluate these modifications in the context of maintaining a

functioning conservation strategy, and (5) present a summary of the findings of this evaluation which can 

be used to support the analysis of effects to biodiversity and wildlife presented in Chapter 3 of the EIS.
Appendix D

Old-growth Habitat Conservation Strategy D-2 Final EIS

Old-growth Habitat Conservation Strategy

The conservation strategy was designed to maintain the integrity of the old-growth forest ecosystem (see 

USDA Forest Service 1997b, Appendix N pp. N-20 to N-24). This appendix presents the results of an

evaluation of the ability of each of the alternatives analyzed in the EIS to maintain the integrity of the 

conservation strategy. Integrity is defined here based on standard language as ‘an unimpaired condition’ 

or “the quality or state of being complete or undivided” (http://www.merriamwebster.com/dictionary/integrity). It is assumed that integrity is maintained when the conservation strategy 

is expected to continue to function effectively regardless of alteration or modification of individual parts, 

that is, its functioning as a whole remains unimpaired. Accordingly, throughout this evaluation, focus is 

placed on the proposed modifications to any contributing elements of the conservation strategy, such as 

the beach and estuary fringe and RMAs, and the associated potential to affect the functioning of the 

conservation strategy. 

The 1997 Tongass National Forest Plan established a comprehensive, science-based conservation 

strategy to provide for wildlife sustainability and viability across the Tongass. The conservation strategy 

was developed to maintain a functional and interconnected old-growth forest ecosystem on the Tongass 

by retaining intact, largely undisturbed habitat. In doing so, it was also intended to ”[P]rovide sufficient 

habitat to preclude the need for listing of species under the Endangered Species Act, or from becoming 

listed as Sensitive due to National Forest habitat conditions” (USDA Forest Service 1997c, p.34). Its 

development is described in detail in Appendix N of the 1997 Forest Plan FEIS (USDA Forest Service 

1997a, 1997b) which is the foundation for this current analysis and will not be cited repeatedly but is 

incorporated throughout by reference. The conservation strategy was subsequently reviewed to confirm 

its validity given any new conservation science since 1997 and the proposed changes to the Old-growth 

Habitat LUD and amended for incorporation into the 2008 Forest Plan (USDA Forest Service 2008a, 

2008b; see below for additional discussion). 

The conservation strategy includes two major components: (1) a forest-wide network of large, medium 

and small OGRs allocated to the Old-Growth Habitat LUD and other non-Development LUDs plus all 

islands less than 1,000 acres, and (2) a series of standards and guidelines applicable to lands where 

timber harvest is permitted (the matrix; USDA Forest Service 2008a, 2008b). 

The system of OGRs was designed to maintain habitats of the species that have the most viability 

concerns (USDA Forest Service 2008b). Other forested non-development LUDs such as Wilderness, 

LUD II, Remote Recreation, and Semi-Remote Recreation contribute in a substantial way to the oldgrowth ecosystem. The intent of the reserve system was to ensure the maintenance of well-distributed,

viable populations of all old-growth associated wildlife species across the Tongass, with focus on those 

species that are most sensitive to habitat loss and fragmentation. In general, the home range and 

dispersal capabilities of old-growth associated species were considered in determining the size, number 

and spacing of reserves. For the most recent complete review of the Forest Plan Conservation Strategy, 

including assumptions underlying the design of the OGR system, refer to Appendix D of the 2008 Forest 

Plan Final EIS (USDA Forest Service 2008b). 

Within the matrix (areas outside of reserves), components of the old-growth ecosystem are maintained 

through standards and guidelines designed to provide for important ecological functions such as dispersal 

of organisms, movement between forest stands, and maintenance of ecologically valuable structural 

components such as down logs, snags, and large trees (USDA Forest Service 2008b). Matrix lands 

include Timber Production, Modified Landscape, and Scenic Viewshed, LUDs. Matrix management 

complements the reserve system by providing habitat at finer spatial scales, enhancing the effectiveness 

of reserves, and providing for landscape connectivity (USDA Forest Service 2008b). Standards and 

guidelines applicable to these lands include the 1,000-foot beach and estuary fringe, variable-width 

stream buffers (Riparian Management Areas (RMAs), TTRA buffers, etc.), project-level legacy old-growth 

forest structure retention requirements, and species specific standards and guidelines. In addition, other 

Forest-wide standards and guidelines preclude or limit timber harvest in areas of high-hazard soils, steep 

slopes, karst terrain, and visually sensitive travel routes and use areas, and require projects to be 

designed to maintain landscape connectivity (i.e., maintain corridors of forest among large and medium 

OGRs and other non-development LUDs at broad spatial scales). Additional detail on the rationale 
Appendix D

Final EIS D-3 Old-growth Habitat Conservation Strategy

behind the standards and guidelines within the matrix is provided in Appendix D of the 2008 Forest Plan 

FEIS (USDA Forest Service 2008b).

Young-growth forest stands within the matrix and within reserves have ecological values which contribute 

to the functioning of the reserve system. However, at the time of its development in 1997 it was assumed 

that the conservation strategy would maintain a functional and interconnected old-growth forest 

ecosystem without the additional contribution of previously harvested areas, either as young-growth or 

over time as these stands matured to old-growth condition. That is, it was designed acknowledging the 

consequences of past harvest and harvest proposed under the 1997 Forest Plan to ensure that an 

adequate amount of old-growth forest was protected within the planning area to maintain a functional and 

interconnected old-growth forest ecosystem, capable of supporting viable, well-distributed wildlife 

populations.

The 1982 Planning Rule stated that the maintenance of a viable population requires providing habitat to 

support “at least a minimum number of reproductive individuals and that habitat must be well distributed 

so that those individuals can interact with others in the planning area” (36 CFR 219.19). In the context of 

the development of the conservation strategy, this was interpreted to mean that the condition of viable 

and well distributed allows for gaps within a species distribution as long as the population segments of the 

species continue to interact and are distributed throughout the planning area. (Appendix N (p. N-3), 

USDA FS 1997). The 2012 Planning Rule now requires that the responsible official determine whether or 

not the plan components ‘‘provide the ecological conditions necessary to contribute to the recovery of 

federally listed threatened and endangered species, conserve proposed and candidate species, and

maintain a viable population of each species of conservation concern within the plan area” (36 CFR 

219.9). The 2012 Planning Rule defines a viable population as: ‘‘A population of a species that continues 

to persist over the long-term with sufficient distribution to be resilient and adaptable to stressors and likely 

future environments’’ (§ 219.19) (emphasis added). Therefore, the ability of the conservation strategy to 

function as intended can be gauged on the scale of the Forest and beyond; however, it is acknowledged 

that some portions of the Forest may be better meeting the intent of the conservation strategy than 

others. It should be noted that the wildlife components of the Forest Plan remain under the 1982 Planning 

Rule, and specific updates to meet 2012 Planning Rule requirements are not proposed under this Forest 

Plan Amendment.

Scope of the Analysis and Acknowledgement of New Science

The scope of this analysis is the individual proposed modifications to the contributing elements of the 

conservation strategy and the associated potential to affect its functioning. The proposed Forest Plan 

amendment does not propose changes to the framework of the conservation strategy or the size or 

spacing of OGRs except for adjustments due to the National Defense Authorization Act for Fiscal Year 

2015. The proposed OGR modifications compensate for portions of individual OGRs that were located on 

National Forest System (NFS) lands that were conveyed to the Sealaska Native Corporation (see below).

Therefore, this analysis is not a review of the underpinnings of the current conservation strategy. .

Recent advancements in the fields of conservation science and landscape ecology and new knowledge of 

individual species’ biological needs is included in the following discussion. Some of these topics and 

others (described below) were identified during the original development of the conservation strategy for 

the 1997 Forest Plan and considered again during the Interagency Forest Plan Conservation Strategy 

Review (USDA Forest Service 2007) conducted for the 2008 Forest Plan Amendment (see New Relevant 

Science Since 1997 in Appendix D, USDA Forest Service 2008b). The following discussion touches on 

some of the new science related these topic areas relevant to conservation planning on the Tongass 

National Forest.

Recent research confirms the importance of including freshwater systems in conservation strategy design

(Nislow et al. 2010). The Tongass National Forest supports some of the most productive salmon 

spawning habitats in North America and salmon-derived nutrients are recognized as playing an important 

role in the productivity of coastal temperate forests (Hood et al. 2007; Fellman et al. 2008, 2009, D’Amore 

et al. 2011). The strong connections between aquatic and terrestrial ecosystems, as well as upstream 

and downstream linkages within stream and river systems, are also susceptible to disruption by human 
Appendix D

Old-growth Habitat Conservation Strategy D-4 Final EIS

actions and are therefore important elements to be considered in conservation planning (Nislow et al. 

2010). Aquatic systems and hydrologic connectivity are afforded protection by Forest Plan Riparian and 

Beach and Estuary standards and guidelines which were developed in part based on recommendations 

put forth in an Anadromous Fish Habitat Assessment (AFHA 1995). Best management practices for 

riparian and stream management, implemented at the project level, also provide protection to these 

resources.

The contribution to conservation by matrix lands, or areas where active land management can occur, is 

receiving even greater emphasis. Matrix lands are critical to maintaining the connectivity of ecological 

flows across a landscape (e.g., flows of disturbance agents, organisms, water, and nutrients) and are also 

essential to the ability of protected areas to achieve their mandates for ecosystem conservation 

(Schmiegelow et al. 2006, Schmiegelow and Lisgo 2014). Conservation focused on the management of 

matrix lands is referred to as the reverse-matrix model of conservation design. Under this paradigm, the 

concept of habitat reserves as nodes of conservation land within a largely degraded environment is 

inverted, such that conservation lands are, in fact, the matrix within which development activities are 

carefully managed so as not to erode other values (Schmiegelow et al. 2006). More intensive activities 

would occur on “islands” within the sea of conservation land (Schmiegelow et al. 2006). Schmiegelow et 

al. (2006) identify four contributions of matrix lands to conservation goals including supporting populations 

of species, regulating the movement of organisms, buffering sensitive areas and reserves, and 

maintaining the integrity of aquatic systems. Thus, the ability to achieve conservation goals is clearly 

dependent in part on the management of activities within matrix lands. 

The Tongass conservation strategy is a reserve-based design, recognizing different functions of the 

reserve system and matrix lands. Ecological values within the matrix are protected by standards and 

guidelines, such as the beach and estuary fringe and riparian buffers, which provide physical connectivity 

via protected forested corridors. Matrix lands are also protected by standards and guidelines implemented 

at the project-level which contribute to functional connectivity through the additional retention of oldgrowth forest in areas where timber harvest is restricted including areas of high-hazard soils, steep 

slopes, karst terrain, and visually sensitive travel routes and use areas (USDA Forest Service 1997c, 

p.32). However, the ecological functions of most upland young-growth stands were largely 

unacknowledged in the development of the conservation strategy except where they contributed to the 

beach and estuary fringe and riparian buffers.

Young-growth stands can provide a range of functions including serving as dispersal corridors between 

old-growth stands as well as providing buffers between areas of suitable habitat and human activity (e.g., 

buffering forests from edge effects). Although immediately after harvest and until they become more 

structurally complex, young-growth stands can create dispersal barriers for certain old-growth associated 

species, over time, young-growth stands have the potential to return to old-growth conditions, a process 

that can be accelerated through active management such as thinning. The Old-growth Habitat LUD 

standards and guidelines call for actions that would facilitate the transition to old-growth conditions. 

Similarly, Forest-wide standards and guidelines for landscape connectivity call for actions in younggrowth stands to accelerate the development of old-growth characteristics in order to increase 

connectivity for wildlife and to provide higher quality habitat within the matrix lands. The transition to 

young-growth management under the proposed Forest Plan amendment has the potential to both 

positively and negatively affect the condition and quality of matrix lands, and thus their contribution to the 

conservation strategy. This topic is addressed below in the context of the proposed modifications to 

contributing elements of the conservation strategy.

Finally, the design of the original conservation strategy in 1997 was based in part on the needs of oldgrowth associated species (see Appendix N of the 1997 Forest Plan FEIS). In general, the home ranges 

and dispersal capabilities of these species were taken into account during the design of the reserve 

system, including reserve size, spacing, and number, as well as in the development of provisions for 

matrix management (USDA 1997b). Since 2008, there have been research publications that address 

some of these species including goshawks (Smith 2013), wolves (Person and Russell 2008, 2009; 

Weckworth et al. 2010, 2011; ADF&G 2012; Person and Logan 2012), brown bears (Flynn et al. 2009),

marten (Flynn and Schumacher 2009, Pauli et al. 2015), deer (White et al. 2009) and flying squirrels 
Appendix D

Final EIS D-5 Old-growth Habitat Conservation Strategy

(Flaherty et al.2008, 2010; Pyare et al. 2010; Shanley et al. 2013; Smith 2012; Smith et al. 2011) which 

provide additional considerations regarding their conservation needs. Information from these studies, 

other relevant studies and other best available science would be used to review the conservation strategy 

design if, in the future, data from various sources suggest that the conservation strategy is no longer 

functioning as originally intended. However the results of the analysis in this appendix indicate the 

conservation strategy currently functions as intended and is expected to function regardless of which 

alternative is selected.

The conservation strategy was designed to maintain a resilient old-growth forest ecosystem in the face of 

uncertainty, including uncertainty associated with climate change. Climate change in Southeast Alaska

may result in increased blowdown, increased tree mortality from insects and disease, increased fire 

frequency and severity, warmer temperatures and changes in precipitation patterns, and greater weather 

extremes (Haufler et al. 2010, Shanley et al. 2015). These effects are anticipated to result in changes to 

vegetation and thus, the suitability of wildlife habitats protected by the conservation strategy. Although the 

extent of changes in vegetation expected as a consequence of climate change is unknown, analysis on 

the neighboring Chugach National Forest suggests that the temperate coastal rainforest is expected to be 

resilient (see Hayward et al. in prep). 

Current Status of Land Management on the Tongass

This section describes the land management activities that have altered the context within which the 

conservation strategy was designed. These include actual timber harvest levels, mapping updates that 

have resulted in a net increase in the amount of productive old-growth (POG) forest estimated on the 

Tongass, modifications to the conservation strategy since 2008, and Non-NFS land management 

decisions.

Projected Versus Actual Timber Harvest Levels

The design of the conservation strategy was intended to achieve multiple use objectives by allowing for 

activities such as timber harvest, recreation, and infrastructure development. Therefore, it was developed 

in the context of maintaining a robust timber harvest program over the life of the approved Forest Plan, 

while conserving old-growth forest and associated species. However, market conditions and other factors 

have resulted in harvest levels (in both spatial extent and volume) that are much lower than anticipated. 

Both the 1997 and 2008 Forest Plan EISs include projections of the amount of original productive oldgrowth (POG) forest1 (existing in 1954 prior to large-scale timber harvest) remaining after 100 years 

(timber sale rotation) based on a decadal Allowable Sale Quantity (ASQ). The conservation strategy was 

based on an assumed harvest rate of about 83,400 acres per decade. If harvest took place at this 

decadal rate from 1998 to 2015 and then continued until 2041, approximately 334,600 acres will have 

been harvested. In contrast, combining the actual acres harvested from 1998 to 2015 with the projected 

harvest of old-growth under each of the alternatives would produce a total of 54,400 to 81,600 acres of 

POG harvest through 2041. The acreage difference between these scenarios would result in between 

253,000 and 280,200 fewer acres of harvested POG by 2041. Thus, matrix lands contain a substantially 

greater amount of POG than was assumed in the 1997 Forest Plan revision and many OGRs and nonDevelopment LUDs are surrounded by additional unharvested areas.

Road construction on the Tongass has occurred primarily to access timber resources and future new road 

construction is anticipated to be similarly motivated. Future road construction will vary among alternatives 

by the amount of old-growth harvest. The cumulative extent of roads after implementation of any of the 

action alternatives, however, will be lower than anticipated under the 1997 Forest Plan. The additional 

old-growth harvest that would have occurred under full implementation of the 1997 Forest Plan was 

474,000 acres of old-growth forest after 100 years. This harvest would have resulted in the need to 

construct nearly 4,000 miles of new road. As a result, NFS lands on the Tongass would have about 

8,500 miles of road. This level of new road construction would create greater human access, increase 

 1 Productive forest is 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. 
Appendix D

Old-growth Habitat Conservation Strategy D-6 Final EIS

road densities, and result in additional habitat fragmentation compared with the present and future under 

the current alternatives. Instead, only about 440 miles of new road have been constructed during the 

past 20 years; about 1,800 miles of new road were expected to be constructed by the 1997 Forest Plan 

during the first two decades at full implementation. Further, the total road mileage on NFS lands under 

the current alternatives would be a maximum of 6,148 after 100 years from the present. This is 2,000 

miles less than predicted by the 1997 Forest Plan, used in the evaluation of the conservation strategy. In 

other words, the miles of new road constructed under the current alternatives after 100 years, would be 

less than half the additional new miles expected to be constructed by the 1997 Forest Plan.

Overall, the conservation strategy protects slightly more than 90 percent of all existing POG forests on the 

Tongass National Forest. This percentage assumes that old-growth forest is harvested at the maximum 

allowable rate in each future decade before sufficient young-growth forest has reached harvestable size 

and can replace old-growth in the harvest. If this maximum rate does not occur, then the percentage of 

POG retained will be higher.

Ongoing GIS Mapping Updates

GIS mapping updates have resulted in substantial changes in estimated extent of the Tongass land base 

and vegetation mapping categories since 2008. The Tongass land base acreage changed as a result of 

two factors. First, updates were made to improve the accuracy of shoreline mapping and to reflect the 

land adjustments that occurred since 2008, in particular the land adjustments in the National Defense 

Authorization Act for Fiscal Year 2015 discussed below. These land base changes have directly affected 

the acreages in each vegetation category. Second, vegetation mapping is continually being updated; 

these updates have occurred both opportunistically in association with individual projects and forest-wide. 

A January 2015, forest-wide update corrected the mapping of a large number of polygons that were 

incorrectly mapped as size class 3 (young-growth sawtimber, less than 150 years old). As these 

polygons were older than 150 years old, they were corrected to size class 4, which converted them to 

productive old growth.

Modifications to the Conservation Strategy Since 2008

Modifications to the strategy from 1997 to 2007 were incorporated into the 2008 Forest Plan Amendment. 

Since 2008, one project has included modifications to the system of old-growth reserves. The Big Thorne 

Timber Sale project, located in north central Prince of Wales Island within the Thorne Bay Ranger District 

included small old-growth reserve boundary modifications intended to trade areas of inventoried roadless 

area (which would become Old-growth Habitat LUD) for roaded portions of old-growth reserves (which 

would become a development LUD and available for timber harvest). Small OGRs were modified in Value 

Comparison Units (VCU) 5790, 5800, 5810, 5820, 5830, 5850, and 5950, resulting in a net increase of 

645 acres of Old-growth Habitat LUD. The Big Thorne FEIS analysis concluded that the old-growth 

reserve modifications would provide comparable achievement of Old-growth Habitat LUD goals and 

objectives, and therefore assumed that the functioning of the conservation strategy (USDA Forest Service 

2013) would be maintained. These modifications amended the 2008 Forest Plan

A correction to the 2008 Forest Plan was made in 2012 (Forest Plan Errata, February 6, 2012), to correct 

a mapping error for a small OGR in VCU 7470 on the Ketchikan-Misty Fiords Ranger District. As a result 

of the correction, the size of the small OGR, as well as the acres of POG contained within, increased. No 

other changes to the spatial distribution, size, and composition of the Old-growth Habitat LUD or other 

non-development LUDs have occurred since approval of the 2008 Forest Plan Amendment.

External Factors that Have Affected the Conservation Strategy Since 2008

The National Defense Authorization Act for Fiscal Year 2015 conveyed 69,585 acres of NSF forest lands

to the Sealaska Native Corporation to fulfil the commitment in the Alaska Native Claims Settlement Act

(Public Law 113-2910). The conveyance affected old-growth reserves on Prince of Wales Island and in 

VCUs 5900, 5940, 6160, 6170, 6180, 6190, 6200, 6750, 6760 and 6850, and two smaller islands to the 

west (Kosciusko Island [VCUs 5450 and 5460] and Tuxekan Island [VCUs 5560, 5570, 5600 and 5872]). 

These areas are now non-NFS lands which are managed for timber production. In an effort to address 
Appendix D

Final EIS D-7 Old-growth Habitat Conservation Strategy

these effects under the proposed Forest Plan amendment, the Forest Service elected to propose 

boundary modifications to compensate for the loss of OGR acres. An Interagency Old-growth Reserve 

Review report is included in Appendix E of this EIS which outlines the proposed OGR modifications and 

rationale. Collectively the boundary modifications result in a net increase in 6,171 acres of OGR and 

7,148 acres of POG forest included in the reserve system from existing (post-conveyance) levels. These 

modifications are part of Alternatives 2, 3, 4, and 5.

Another factor affecting the conservation strategy is the 2001 Roadless Area Conservation Rule 

(Roadless Rule). Inventoried roadless areas provide large, relatively undisturbed blocks of important 

habitat for a variety of terrestrial and aquatic wildlife and plants. Since its adoption in 2001, the Roadless 

Rule has been the subject of litigation concerning how it is to be applied to the Tongass. The suitable land 

base where timber harvest can occur has continually decreased over the years on the Tongass. One 

reason for the decrease is the withdrawal of inventoried roadless areas from lands suitable for timber 

production (see Forest Plan Appendix A). 

When the 2008 Forest Plan was approved, the Tongass National Forest was temporarily exempted from 

the Roadless Rule per the 2003 Tongass Exemption (68 FR 75136). Exempting the Tongass from the 

application of the roadless rule left intact all old-growth reserves, riparian buffers, beach fringe buffers, 

and other protections contained in the 1997 Forest Plan, but made approximately 300,000 roadless acres 

available for forest management, including lands in development LUDs.

In 2011, the United States District Court, District of Alaska set aside the 2003 Tongass Exemption and 

reinstated the Roadless Rule with respect to the Tongass. A March 2014 ruling by the Ninth Circuit Court 

of Appeals reversed that decision. The Ninth Circuit Court of Appeals subsequently granted a petition for 

rehearing en banc, held in December 2014 before an eleven judge panel. On July 29, 2015, a six judge 

majority of the en banc panel held that USDA’s justification for the Tongass Exemption was inadequate 

under the Administrative Procedure Act, holding it did not provide a reasoned explanation for 

contradicting the findings in the 2001 Record of Decision for the Roadless Rule. The majority upheld the 

District Court’s reinstatement of the Roadless Rule. Consequently, the Roadless Rule remains in effect in 

Alaska and the Forest Service continues to apply the Rule to the Tongass National Forest. Therefore, 

inventoried roadless areas maintain additional old-growth forest that augment the amount maintained by 

the contributing elements of the conservation strategy (USDA Forest Service 2008c, page 21).

Proposed Modifications to Contributing Elements of the 

Conservation Strategy

This section describes the proposed modifications to the contributing elements of the conservation strategy.

The Tongass National Forest timber program has historically focused on economical harvest of old-growth 

to “seek to meet” demands as directed by TTRA and to provide jobs to local communities in Southeast 

Alaska. The 2008 Forest Plan (Alternative 1) would transition to young-growth timber program in about 32 

years, which reflects when the oldest young-growth stand within the development LUDs reach Culmination 

Mean Annual Increment (CMAI). On the Tongass National Forest, the CMAI occurs in stands at 

approximately 80 to 100 years. Therefore, to speed the transition to young-growth management over the 

next 10 to 15 years, the action alternatives propose young-growth harvest within non-development LUDs, 

the beach and estuary fringe, RMAs, and other areas within the matrix where suitable young-growth is 

available in order to get the necessary timber volume to meet these demands, such that at the end of this 

period the vast majority of timber sold by the Tongass National Forest will be young-growth. Anticipated 

transition times range from 12 years under Alternative 2 to 16 years under Alternatives 4 and 5.

Overall Approach to Young-growth Management

The general approach to young-growth management proposed under the alternatives is to speed the 

transition to a young-growth timber program. Young-growth harvest activities would occur within a 

previously disturbed footprint in areas of past timber harvest, and would maximize the use of existing or 

decommissioned roads to access harvest units where possible. The associated shift away from POG forest 

harvest would reduce the amount of future timber harvest and associated activities within intact and/or 
Appendix D

Old-growth Habitat Conservation Strategy D-8 Final EIS

unroaded areas. The alternatives that propose the fastest transition through more aggressive harvest 

strategies would result in less new road construction and less timber harvest in untouched areas; that is 

more timber harvest/road building would occur within previously disturbed areas, than alternatives with 

longer transition times. This tradeoff is the paramount difference among the alternatives.

Over half of the past timber harvest on the Tongass National Forest occurred when relatively few 

restrictions were in place in the 1960s and 1970s during the initial period of commercial-scale timber 

harvest and prior to the adoption of the first Forest Plan in 1979. Little protection was afforded to features 

such as the beach and estuary fringe, RMAs, and other sensitive areas identified now at the project level, 

such as karst and steep slopes, during this time. Future young-growth management activities would be 

required to comply with requirements for maintaining landscape connectivity, scenery, protecting steep 

slopes, high vulnerability soils, karst, and TTRA buffers under the proposed Forest Plan. Thus, younggrowth harvest unit size in most cases would be smaller than the original units. Created openings within 

the beach and estuary fringe, RMAs, and OGRs proposed under the alternatives have the potential to 

reduce the functioning of these areas (discussed in detail below); however commercial thinning would 

enhance the habitat value of these areas by promoting the development of fewer, larger trees.

Old-growth Habitat LUD and Other Non-Development LUDs

The system of old-growth reserves (Old-growth Habitat LUD) and other non-development LUDs was 

established for the purpose of maintaining a functional and interconnected old-growth ecosystem (p. 3-11, 

USDA Forest Service 1997c). Of the 5.4 million acres of original (1954) POG that occurred on NFS lands 

on the Tongass National Forest about 92 percent remains in 2015. About 67 percent of the original 

acreage is protected within the reserve system. No changes are proposed to the size or spacing of the 

reserve system or the productive old-growth forest within these areas under the proposed Forest Plan 

amendment. Moreover, under all of the action alternatives the transition to young-growth management

would substantially reduce the long-term POG forest harvest levels, with all of the alternatives retaining 

approximately 91 percent of the original POG after 100 years of plan implementation. 

Currently, limited management of young-growth stands within the Old-growth Habitat LUD and some 

other non-development LUDs is allowed under the Forest Plan (Alternative 1) when conducted for the 

purpose of habitat enhancement (e.g., pre-commercial thinning to accelerate stand development toward 

old-growth conditions and other young-growth treatments to increase connectivity for wildlife). Under 

Alternatives 1 and 4, forest land in the non-development LUDs is identified as not suited for timber 

production. Under Alternatives 2, 3, and 5 (Old-growth Habitat LUD only), forest land in non-development 

LUDs is identified as suited for young-growth timber production. Even-aged commercial young-growth 

harvest in these LUDs could increase habitat fragmentation or perforation and reduce the ecological 

contribution of young-growth stands to the reserve system by setting back the trajectory toward late seral 

forest condition by delaying the development of old-growth stand characteristics such as snags, downed 

logs, and diverse tree canopy layers required by some POG-associated species (e.g., marten, goshawks, 

flying squirrels). Effects would be greatest under Alternatives 2 and 3 which allow multiple entries into 

harvested stands which would intensify and prolong the effects; the size of created openings are limited 

by only by scenery issues, similar to the current Forest Plan . Effects would be less under Alternative 5 

which includes a one-time entry constraint and limits the size of created openings to less than 10 acres

with maximum removal of up to 35 percent of the area of the original harvested stand, allowing the 

majority of each stand to mature to old-growth conditions after harvest (Tables 1 and 2). Thinning the 

entire stand could also be used to accelerate old-growth characteristics. Under Alternatives 2, 3, and 5, 

individual small OGRs could be modified to compensate for young-growth harvest. No harvest, except 

personal use and potentially salvage, would occur in OGRs or other non-development LUDs under 

Alternatives 1 and 4.

Young-growth forest comprises a relatively small proportion of the total area of these LUDs. The majority 

of the young-growth acres in the Old-growth Habitat LUD are concentrated in the North Central Prince of 

Wales and East Chichagof Island biogeographic provinces. The majority of the suitable young-growth 

acres in other non-development LUDs concentrated in the North Central Prince of Wales, West Baranof 

Island, and Kuiu Island biogeographic provinces (Table 3). These biogeographic provinces are therefore 

also where past timber harvest was concentrated.
Appendix D

Final EIS D-9 Old-growth Habitat Conservation Strategy

Under Alternatives 2, 3, and 5 the maximum amount of young-growth harvest in the Old-growth Habitat 

LUD would comprise approximately 3.3 percent, 2.8 percent, and 0.2 percent of the forest land (younggrowth, POG, and unproductive forest) within the Old-growth Habitat LUD Forest-wide, respectively 

(Table 3). By biogeographic province, maximum young-growth harvest would comprise 0 to 13.5 percent 

of forest land within the Old-growth Habitat LUD under Alternative 2, 0 to 7.8 percent under Alternative 3, 

and 0 to 0.8 percent under Alternative 5 (Table 3). Under Alternatives 2 and 3, the maximum amount of 

young-growth harvest in other non-development LUDs would comprise less than 1 percent of the forest 

land within these LUDs (Table 4). By biogeographic province, maximum young-growth harvest would 

comprise 0 to 9.7 percent of forest land within these LUDs under Alternative 2 and 0 to 8.8 percent under 

Alternative 3 (Table 4). 

Suitable young-growth stands within OGRs and other non-development LUDS are typically located along 

the shoreline or adjacent to existing road systems. These easily accessible stands, particularly when 

located near other suitable young-growth stands in development LUDs, may be selected to avoid indirect 

effects to intact, relatively undisturbed POG forest within OGRs and other non-development LUDs.

Table 1

Proposed Young-growth Harvest after 100 Years in the Old-growth Habitat LUD and 

Other Non-Development LUDs by Alternative

Alternative

Proposed Young-growth Management in Non-development LUDs

Total Projected 

Young-growth 

Harvest (Acres)

Non-Development 

LUDs where Younggrowth Harvest 

Allowed

Number 

of Entries

Harvest 

Opening 

Limits

Stand Retention 

Limits

Alternative 1 NA NA NA NA 0

Alternative 2 Non-development LUDs1 Multiple Limited by 

Scenery only None 44,507 

Alternative 3 Non-development LUDs1 Multiple Limited by 

Scenery only None 39,043 

Alternative 4 NA NA NA NA 0

Alternative 5 Old-growth Habitat LUD One-time 10 acres or 

less

Maximum removal of 

35 percent of original 

harvested stand 

acres

1,811 

Note: NA = not applicable

1 Does not include Experimental Forest, LUD II, Municipal Watershed, National Monument, Research Natural Area, Wilderness 

Monument, Wild River, and Wilderness

Young-growth forest stands have ecological values which contribute to the functioning of the reserve 

system. However, at the time of its development in 1997 it was assumed that the conservation strategy 

would maintain a functional and interconnected old-growth forest ecosystem without the additional 

contribution of previously harvested areas, either as young-growth or over time as these stands matured to 

old-growth condition. For this reason, and due to the spatial distribution and quantity of suitable younggrowth, harvest in the Old-growth Habitat LUD and other non-development LUDs proposed under 

Alternatives 2, 3, and 5 would be expected to have a zero risk for Alternatives 1 and 4, a very low risk for 

Alternatives 2 and 3, and an almost zero risk for Alternative 5 of reducing the ability of the reserve system to 

maintain a functional and interconnected old-growth ecosystem, Therefore, all of the alternatives would 

maintain the integrity of the conservation strategy by maintaining the functioning of the reserve system.
Appendix D

Old-growth Habitat Conservation Strategy D-10 Final EIS

Table 2

Proposed Young-growth Harvest by Treatment by Alternative

Category Period

Acres by Treatment

Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5

Old-growth 

Habitat LUD

1st 15 years 0 ac 2,477 CC ac 2,181 CC ac 0 ac 1,811 PC ac

Last 85 years 0 ac 29,163 CC ac 24,005 CC ac 0 ac 0 ac

Other NonDev. LUDs 1st 15 years 0 ac 810 CC ac 726 CT ac 0 ac 0 ac

Last 85 years 0 ac 12,058 CT ac 12,131 CT ac 0 ac 0 ac

Beach and 

Estuary Fringe

1st 15 years 0 ac 8,791 CC ac 7,819 CT ac 4,436 CT ac 3,903 PC ac

Last 85 years 0 ac 13,079 CT ac 22,950 CT ac 6,678 CT ac 0 ac

RMA 1st 15 years 0 ac 2,327 CT ac 0 ac 0 ac 1,089 PC ac

Last 85 years 0 ac 23,703 CT ac 0 ac 0 ac 0 ac 1 CC = Clearcut;; CT = Commercial Thin

Note:

For CT, only 33% of the stand is removed; therefore, 1,000 ac of CT is roughly equivalent to removing 333 ac of trees spread over 

1,000 ac

For PC under Alternative 5, only 35% of the stand is removed in patches no larger than 10 ac; so 1,000 ac of these created 

openings is roughly equivalent to removing 350 acres of trees in patches spread over 1,000 ac
Appendix D

Final EIS D-11 Old-growth Habitat Conservation Strategy

Table 3

Distribution of Young-growth Harvest Acres (over 100 years) within the Old-growth Habitat LUD by 

Biogeographic Province and Alternative

Biogeographic 

Province

Estimated Maximum Young-growth1 Harvest

in the Old-growth Habitat LUD

(Young-growth Harvest Acres / % of Forest Land Acres in LUD)

Forest Land 

Acres2

Alts 1 

and 4 Alt 2 Alt 3 Alt 5

1 Yakutat Forelands 8,386 0 0% 8 0.1% 7 0.1% 0 0.0%

2 Yakutat Uplands 2,336 0 0% 0 0.0% 0 0.0% 0 0.0%

3 East Chichagof Island 150,445 0 0% 6,121 4.1% 5,045 3.4% 360 0.2%

4 West Chichagof Island 21 0 0% 0 0.0% 0 0.0% 0 0.0%

5 East Baranof Island 35,255 0 0% 1,198 3.4% 978 2.8% 66 0.2%

6 West Baranof Island 65,340 0 0% 2,038 3.1% 1,309 2.0% 124 0.2%

7 Admiralty Island 0 0 0% 0 0.0% 0 0.0% 0 0.0%

8 Lynn Canal 19,541 0 0% 855 4.4% 549 2.8% 51 0.3%

9 North Coast Range 58,511 0 0% 0 0.0% 0 0.0% 0 0.0%

10 Kupreanof/Mitkof Island 85,029 0 0% 2,470 2.9% 2,145 2.5% 129 0.2%

11 Kuiu Island 24,071 0 0% 938 3.9% 818 3.4% 55 0.2%

12 Central Coast Range 30,526 0 0% 48 0.2% 43 0.1% 3 0.0%

13 Etolin Island & Vicinity 95,865 0 0% 2,406 2.5% 2,133 2.2% 132 0.1%

14 North Central Prince of 

Wales 203,406 0 0% 10,844 5.3% 9,312 4.6% 622 0.3%

15 Revilla Island/ 

Cleveland Pen. 103,574 0 0% 2,445 2.4% 2,265 2.2% 131 0.1%

16 Southern Outer Islands 13,263 0 0% 573 4.3% 508 3.8% 34 0.3%

17 Dall Island and Vicinity 2,776 0 0% 0 0.0% 0 0.0% 0 0.0%

18 South Prince of Wales 35,627 0 0% 290 0.8% 313 0.9% 15 0.0%

19 North Misty Fiords 5,072 0 0% 227 4.5% 83 1.6% 14 0.3%

20 South Misty Fiords 0 0 0% 0 0.0% 0 0.0% 0 0.0%

21 Ice Fields 8,702 0 0% 1,177 13.5% 679 7.8% 74 0.8%

Forest-wide 947,746 0 0% 31,640 3.3% 26,186 2.8% 1,811 0.2%

1 For modeling purposes, it was assumed, based on an evaluation of economics, that the minimum harvestable age for young growth is 65 to 75 years 

old, depending on site index.

2 Includes young-growth, productive old-growth, and unproductive forest; note that existing acreage does not include minor changes in the North Central 

Prince of Wales biogeographic province resulting from the proposed OGR modifications (Appendix E).
Appendix D

Old-growth Habitat Conservation Strategy D-12 Final EIS

Table 4

Distribution of Young-growth Harvest Acres (over 100 years) within Other Non-Development LUDs Allowing Harvest1 by 

Biogeographic Province and Alternative

Biogeographic Province

Estimated Maximum Young-growth2 Harvest

in Other Non-Development LUDs

(Young-growth Harvest Acres / % of Forest Land Acres)

Forest Land

Acres3 Alts 1, 4, and 5 Alt 2 Alt 3

1 Yakutat Forelands 34,086 0 0% 13 <0.1% 13 <0.1%

2 Yakutat Uplands 5,763 0 0% 218 3.8% 216 3.8%

3 East Chichagof Island 22,368 0 0% 186 0.8% 159 0.7%

4 West Chichagof Island 20,992 0 0% 0 0% 0 0%

5 East Baranof Island 51,589 0 0% 90 0.2% 90 0.2%

6 West Baranof Island 164,412 0 0% 2,508 1.5% 2,302 1.4%

7 Admiralty Island 55,246 0 0% 19 <0.1% 64 0.1%

8 Lynn Canal 112,641 0 0% 27 <0.1% 27 <0.1%

9 North Coast Range 173,152 0 0% 0 0% 252 0.1%

10 Kupreanof/Mitkof Island 68,844 0 0% 516 0.8% 498 0.7%

11 Kuiu Island 114,990 0 0% 618 0.5% 602 0.5%

12 Central Coast Range 141,205 0 0% 477 0.3% 415 0.3%

13 Etolin Island & Vicinity 7,722 0 0% 0 0% 0 0%

14 North Central Prince of Wales 60,718 0 0% 5,890 9.7% 5,326 8.8%

15 Revilla Island/ Cleveland Pen. 240,157 0 0% 983 0.4% 1,670 0.7%

16 Southern Outer Islands 24,468 0 0% 810 3.3% 764 3.1%

17 Dall Island and Vicinity 76,236 0 0% 242 0.3% 240 0.3%

18 South Prince of Wales 62,168 0 0% 128 0.2% 127 0.2%

19 North Misty Fiords 58,540 0 0% 49 0.1% 49 0.1%

20 South Misty Fiords 0 0 0% 0 0% 0 0%

21 Ice Fields 122,223 0 0% 92 0.1% 43 <0.1%

Forest-wide 1,617,519 0 0% 12,868 0.8% 12,857 0.8%

1 Includes Semi-Remote Recreation, Remote Recreation, Special Interest Area, Recreational River, and Scenic River. 2 For modeling purposes, it was assumed, based on an evaluation of economics, that the minimum harvestable age for young growth is 65 to 75 years old, depending on site index. 3 Includes young-growth, productive old-growth, and unproductive forest.
Appendix D

Final EIS D-13 Old-growth Habitat Conservation Strategy

Proposed Modifications to Forest Plan Standards and Guidelines

This section describes the proposed modifications to contributing elements of the conservation strategy 

that are specifically addressed through Forest Plan standards and guidelines. 

Beach and Estuary Fringe

The beach and estuary fringe is a 1,000-ft wide corridor adjacent to saltwater shorelines; it is consists of 

POG, but is also comprised of unproductive forest, previously harvested forest, and non-forest types. It 

serves as a transition zone between upland forest and saltwater influences, and as such is distinguished

as a separate ecosystem (microclimate) within the larger old-growth forest ecosystem. The beach and 

estuary fringe is considered a high value habitat for many species including brown bears, black bears, 

bald eagles, goshawks, deer, marten, and others (Appendix D, USDA Forest Service 2008b). The beach 

and estuary fringe also provides horizontal or low-elevation connectivity between watersheds, many of 

which otherwise have very steep slopes and/or non-forested ridge tops, offering important travel corridors 

for wildlife. Although not explicitly discussed in the conservation strategy, the beach and estuary fringe 

also provides an important function to the marine and estuarine environment by reducing downslope 

effects to marine waters (e.g., sediment runoff), shading shoreline beach areas, providing large-woody 

debris and other organic inputs to the marine and estuarine systems, and providing bank stability (root 

system of large trees). The beach and estuary fringe is particularly critical on the Tongass National Forest 

given the extensive amount of shoreline (more than 17,000 miles) that exists on more than 22,000 

islands. 

Young-growth stands within the beach and estuary fringe are lower value habitat for old-growth 

associated wildlife species because they do not possess the stand characteristics required by some 

species (snags, downed logs, large trees). However, they contribute to functional connectivity for the 

movement and dispersal of wildlife and serve as buffers between areas of suitable habitat and human 

activity. It can be assumed that the integrity of the conservation strategy is maintained when the beach 

and estuary fringe continues to provide the functions of a transition zone between interior forest and 

saltwater influences, landscape connectivity, and water quality and habitat benefits to the marine 

environment.

The 2008 Forest Plan, Alternative 1, includes forest-wide Beach and Estuary Fringe standards and 

guidelines that prohibit timber harvest within 1,000 feet inland from mean high tide. This buffer was 

intended to provide effective landscape linkages to enhance the reserve system, protect bald-eagle 

habitat, buffer the primary beach fringe zone (0 to 500 feet of the shoreline) from wind throw, maintain a 

functional interior forest zone within the beach fringe, and sustain habitats for goshawks (Appendix D, 

USDA Forest Service 2008b). Currently, limited management of young-growth stands within the beach 

and estuary fringe is allowed under the Forest Plan for the purpose of habitat enhancement (e.g., precommercial thinning to accelerate stand development toward old-growth conditions). 

Under Alternatives 2, 3, 4, and 5 forest land in the beach and estuary fringe is identified as suitable for 

young-growth timber production, and commercial young-growth harvest and road 

construction/reconstruction in the beach and estuary fringe is allowed under these alternatives (Table 5).

Young-growth harvest in the beach and estuary fringe has the potential to locally decrease buffer width 

and reduce its effectiveness in facilitating the movement of organisms across the landscape and 

providing habitat for wildlife species that are negatively affected by edge. Alternatives that allow 

clearcutting (Alternatives 2 and 5), or the greatest amounts of road construction/reconstruction 

(Alternatives 2 and 3) are most likely to increase habitat fragmentation if openings are too large to be 

crossed by species with limited dispersal capabilities. Young-growth harvest may also delay the 

development of old-growth stand characteristics in the beach and estuary fringe or may enhance the 

growth of the remaining trees through thinning.
Appendix D

Old-growth Habitat Conservation Strategy D-14 Final EIS

Table 5

Proposed Young-growth Harvest after 100 Years in the Beach and Estuary Fringe by 

Alternative

Alternative

Beach and Estuary Fringe Management Approach

Projected 

Harvest over 

100 yrs

(Acres)

Number 

of Entries

Harvest 

Opening 

Limits

Stand 

Treatments 

and Timing 

Restrictions1

Timber Removal 

Limits

Additional 

Measures

Alternative 1 NA NA NA NA NA 0

Alternative 2 Multiple

Limited by 

Scenery 

only

CC for first 15 

years; CT 

thereafter

None

1,000-footwide corridor 

adjacent to 

even-aged 

harvest units

21,871

Alternative 3 Multiple NA CT only (no 

time limit)

Maximum removal of 

33 percent basal 

area

None 30,769

Alternative 4 Multiple NA CT only (no 

time limit)

Maximum removal of 

33 percent basal 

area

None 11,114

Alternative 5 One-time 10 acres or 

less

PC or CT for 

first 15 years

Maximum removal of 

up to 35 percent of 

original stand acres

200-ft buffer 

adjacent to 

shoreline

3,903

Note: NA = not applicable 1 CC = Clearcut; PC = Patch Cut; CT = Commercial Thin

The most intensive young-growth harvest in the beach and estuary fringe would occur under Alternative 2 

which proposes the greatest amount of harvest and would allow clearcutting to the shoreline during the 

first 15 years after plan approval and commercial thinning thereafter (Table 2). Alternative 2 includes the 

following management approach: When even-aged management of young growth occurs in the beach 

and estuary fringe, the intent is to maintain an approximate 1,000-foot wide protected corridor adjacent 

inland of the harvest unit to function as alternate, low elevation, forested habitat and corridor. This 

corridor should be in POG or young-growth, where present, that meets the objectives of the beach fringe, 

and should be located less than 800 feet in elevation. Beach and estuary standards and guidelines would 

apply as if this were the original beach buffer. Effects under this alternative would be long-term as 

multiple entries into stands, or reharvesting the same stand, would be allowed over the planning horizon.

Under Alternative 2, shifting the beach and estuary fringe inland would maintain some level of 

connectivity between watersheds but would locally reduce the ability of the buffer to serve as a 

transitional zone between interior forest and marine influence.

Less intensive effects to the beach and estuary fringe would occur under Alternatives 3 and 4 (second 

and third most young-growth acres proposed for harvest, respectively) which would allow commercial 

thinning (multiple entries) throughout Forest Plan implementation (Tables 2 and 5). Commercial thinning 

would maintain more of the functions of the beach and estuary fringe than clearcutting or group selection; 

however, some harvested stands would be managed (i.e., could have more than one entry) over the longterm (i.e., 60 or more years after initial entry). 

The effects would be even lower to the beach and estuary fringe under Alternative 5 which proposes the least 

amount of harvest. Although Alternative 5 would allow created openings of up to 10-acre or commercial 

thinning, harvest would be limited to the first 15 years after Forest Plan approval (Tables 2 and 5) and only 

3,550 acres of young-growth are projected to be managed with no more than 35 percent of each stand 

harvested). Alternative 5 also includes a 200-foot-wide forested buffer along the shoreline adjacent to harvest 

units which would continue to protect forestin the beach and estuary fringe for connectivity and habitat while 

the harvested stand matures. Thus, the functioning of the beach and estuary fringe may be reduced in places 

due to the reduced buffer, but effects would be long-term and more localized.
Appendix D

Final EIS D-15 Old-growth Habitat Conservation Strategy

Overall, suitable young-growth comprises a small portion of the total amount of beach and estuary fringe 

within each biogeographic province, most of which occurs in the Etolin Island and Vicinity, North Central 

Prince of Wales, and Revilla Island/Cleveland Peninsula biogeographic provinces (Table 6). Forest-wide 

maximum young-growth harvest would affect approximately 2.4 percent, 3.3 percent, 1.2 percent, and 0.4

of the forest land within the beach and estuary fringe (all acres included) under Alternatives 2, 3, 4, and 5, 

respectively (Table 6). By biogeographic province, maximum young-growth harvest would affect 0 to 5.6 

percent of forest land within the beach and estuary fringe under Alternative 2, 0 to 8.1 percent under 

Alternative 3, 0 to 3.5 percent under Alternative 4, and 0 to 1.1 percent under Alternative 5. Due to the 

localized nature of anticipated effects, under all of the alternatives the beach and estuary fringe would 

continue to act as a transition zone between interior forest and saltwater influences, maintain landscape 

connectivity, and provide benefits to the marine environment across the planning area. Therefore, it would 

be expected that there may be localized reductions in the ability of the beach and estuary fringe to 

function as intended under the conservation strategy under each of the alternatives but Forest-wide 

effects would not measurably reduce the functioning of this contributing element of the conservation 

strategy. 
Appendix D

Old-growth Habitat Conservation Strategy D-16 Final EIS

Table 6

Distribution of Young-growth Harvest Acres (over 100 years) within the Beach and Estuary Fringe by Biogeographic 

Province and Alternative

Biogeographic Province

Forest Land 

Acres in Beach 

& Estuary 

Fringe2

Estimated Maximum Young-growth Harvest1 in the Beach Fringe

(Young-growth Harvest Acres / % of Forest Land Acres))

Alt 1 Alt 2 Alt 3 Alt 4 Alt 5

1 Yakutat Forelands 6,467 0 0% 7 0.1% 11 0.2% 3 <0.1% 2 <0.1%

2 Yakutat Uplands 8,397 0 0% 0 0% 0 0% 0 0% 0 0%

3 East Chichagof Island 63,036 0 0% 2,087 3.3% 2,470 3.9% 741 1.2% 420 0.7%

4 West Chichagof Island 37,246 0 0% 0 0% 0 0% 0 0% 0 0%

5 East Baranof Island 30,341 0 0% 1,513 5.0% 2,103 6.9% 992 3.3% 314 1.0%

6 West Baranof Island 79,821 0 0% 1,168 1.5% 1,525 1.9% 177 0.2% 80 0.1%

7 Admiralty Island 79,128 0 0% 12 <0.1% 54 0.1% 0 0% 0 0%

8 Lynn Canal 17,923 0 0% 261 1.5% 231 1.3% 13 0.1% 58 0.32%

9 North Coast Range 46,054 0 0% 44 0.1% 227 0.5% 0 0% 8 0.0%

10 Kupreanof/Mitkof Island 38,537 0 0% 2,165 5.6% 3,135 8.1% 450 1.2% 398 1.0%

11 Kuiu Island 70,721 0 0% 944 1.3% 1,351 1.9% 266 0.4% 175 0.2%

12 Central Coast Range 23,755 0 0% 584 2.5% 788 3.3% 211 0.9% 74 0.3%

13 Etolin Island & Vicinity 54,051 0 0% 2,922 5.4% 4,247 7.9% 1,874 3.5% 594 1.1%

14 North Central Prince of 

Wales 88,369 0 0% 4,856 5.5% 6,872 7.8% 2,946 3.3% 815 0.9%

15 Revilla Island/ Cleveland 

Pen. 84,629 0 0% 3,957 4.7% 5,892 7.0% 2,588 3.1% 728 0.9%

16 Southern Outer Islands 44,539 0 0% 779 1.7% 1,062 2.4% 683 1.5% 164 0.4%

17 Dall Island and Vicinity 22,452 0 0% 89 0.4% 132 0.6% 0 0% 0.0%

18 South Prince of Wales 48,991 0 0% 438 0.9% 605 1.2% 169 0.3% 68 0.1%

19 North Misty Fiords 26,483 0 0% 44 0.2% 64 0.2% 0 0% 4 0.0%

20 South Misty Fiords 53,091 0 0% 0 0% 0 0% 0 0% 0 0.0%

21 Ice Fields 0 0 0% 0 0% 0 0% 0 0% 0 0%

Forest-wide 924,030 0 0% 21,871 2.4% 30,769 3.3% 11,114 1.2% 3,903 0.4% 1 For modeling purposes, it was assumed, based on an evaluation of economics, that the minimum harvestable age for young growth is 65 to 75 years old, depending on site index. 2 Includes young-growth, POG, and unproductive forest.
Appendix D

Final EIS D-17 Old-growth Habitat Conservation Strategy

Riparian Management Areas

Riparian areas are the corridors along streams and rivers which provide an interface between upland

forests and riverine influences, distinguishing them as a unique ecosystem within the larger forest 

ecosystem. Riparian areas support some of the most productive stands of old-growth on the Tongass 

National Forest, and provide habitat for species associated with aquatic environments (e.g., amphibians 

and furbearers such as river otters) and terrestrial species for which fish are an important food sources 

(e.g., brown bears and black bears). Riparian areas follow the dendritic nature of river systems and 

provide forested corridors connecting higher elevation regions in upper watersheds with lower elevation 

forests in the valley bottoms, providing connectivity within watersheds. Young-growth stands within the 

riparian areas comprise lower value habitat for old-growth associated wildlife species; however, they 

maintain functional connectivity for the movement and dispersal of wildlife and serve as buffers between 

areas of suitable habitat and human activity. 

Riparian areas are protected through use of the Fish and Riparian Standards and Guidelines that prohibit 

timber harvest within a certain distance of streams (depending on stream type or process group). These 

areas include the 1990 TTRA 100-foot-wide buffers and additional distances intended to preserve the 

functions of the riparian areas with the sum of both designated as RMA (Section 102 of TTRA). They are

intended to maintain anadromous fish habitat (e.g., supplying large-woody debris), maintain water quality

(shading, reducing sediment runoff), and provide elevational connectivity within watersheds (Appendix D, 

USDA Forest Service 2008b). It can be assumed that the integrity of the conservation strategy is 

maintained when riparian areas continue to support aquatic and terrestrial habitats, maintain water quality

and provide landscape connectivity. Currently, limited management of young-growth stands within RMAs 

is allowed under the 2008 Forest Plan (Alternative 1) when conducted for the purpose of habitat 

enhancement (e.g., pre-commercial thinning to accelerate stand development toward old-growth 

conditions). 

Commercial young-growth harvest and road construction/reconstruction in the RMA (outside of TTRA 

buffers), is proposed under Alternatives 2 and 5 within the development LUDs and those nondevelopment LUDs discussed above; no young-growth harvest would occur in the RMA under 

Alternatives 1, 3, and 4 (Tables 2 and 7). Alternative 2 would allow commercial thinning throughout the 

life of the Forest Plan. Alternative 5 could be more intense in that it would allow clearings of up to 10 

acres or commercial thinning within RMAs, but only during the first 15 years after Forest Plan approval. 

Young-growth harvest in the RMA has the potential to locally decrease buffer width and reduce its 

effectiveness in facilitating the movement of organisms across the landscape and reduce the function of 

riparian areas. Young-growth harvest may also delay the development of old-growth stand characteristics 

in RMAs. Effects to the conservation strategy would be least under Alternative 5 due to the one-time entry 

constraint and limited number of harvested acres (Table 7). Under both alternatives, TTRA buffers would 

continue to protect aquatic systems and maintain functions such as large-woody debris input, shading, 

and nutrient inputs to streams. Additionally TTRA buffers would maintain elevational connectivity, though 

potentially through narrower corridors where young-growth harvest units occur. 

Overall, suitable young-growth comprises a small portion of the total amount of RMA (outside of TTRA 

buffers) within each biogeographic province (Table 8). Suitable young-growth in RMAs is spread 

throughout the forest, with larger concentrations occurring in the North Central Prince of Wales, West 

Baranof Island, and East Baranof Island biogeographic provinces (Table 8). Forest-wide maximum 

young-growth harvest would affect approximately 6.7 percent and less than 1 percent of the forest land 

within RMAs, outside of TTRA buffers under Alternatives 2 and 5, respectively (Table 8). By 

biogeographic province, maximum young-growth harvest would affect 0 to 17.2 percent of forest land 

within RMAs (outside of TTRA buffers) under Alternative 2 and 0 to 0.8 percent under Alternative 5 (Table 

8). Due to the localized nature of anticipated effects, under all of the alternatives riparian areas would

continue to maintain aquatic and terrestrial habitats, maintain water quality, and provide landscape 

connectivity across the planning area. Therefore, it would be expected that there may be localized 

reductions in the ability of the RMAs to function as intended under the conservation strategy under each 

of the alternatives but Forest-wide effects would not measurably reduce the functioning of this 

contributing element of the conservation strategy. 
Appendix D

Old-growth Habitat Conservation Strategy D-18 Final EIS

Table 7

Proposed Young-growth Harvest after 100 Years in Riparian Management Areas (Outside 

of TTRA buffers) by Alternative

Alternative

RMA Management Approach Total 

Projected 

Harvest 

(Acres)

Number 

of 

Entries

Harvest 

Opening 

Limits

Stand Treatments 

and Timing 

Restrictions1

Timber Removal 

Limits

Additional 

Measures

Alternative 1 NA NA NA None NA 0

Alternative 2 Multiple NA CT only (no time 

limit) None NA 26,030

Alternative 3 NA NA NA None NA 0

Alternative 4 NA NA NA None NA 0

Alternative 5 Onetime < 10 acres PC or CT for first 15 

years

Maximum removal of 

up to 35 percent of 

original harvested 

stand acre

NA 1,089

Note: NA = not applicable 1 CC = Clearcut; PC = Patch Cut; CT = Commercial Thin

Table 8

Distribution of Young-growth Harvest Acres (over 100 years) in Riparian Management 

Areas by Biogeographic Province and Alternative

Biogeographic 

Province

Forest 

Land 

Acres in 

RMAs 

Outside 

of TTRA 

Buffers)2

Estimated Maximum Young-growth Harvest1 in RMAs

(Young-growth Harvest Acres / % of Forest Land Acres))

Alts 1, 3, and 4 Alt 2 Alt 5

1 Yakutat Forelands

 

28,564 0 0% 36 0.1% 1 <0.1%

2 Yakutat Uplands

 

4,059 0 0% 28 0.7% 1 <0.1%

3

East Chichagof 

Island

 

41,682 0 0% 5,040 12.1% 222 0.5%

4

West Chichagof 

Island

 

4,388 0 0% 0 0.0% 0 0%

5

East Baranof 

Island

 

8,949 0 0% 1,540 17.2% 68 0.8%

6

West Baranof 

Island

 

17,541 0 0% 2,725 15.5% 113 0.6%

7 Admiralty Island

 

16,096 0 0% 0 0.0% 0 0%

8 Lynn Canal

 

16,156 0 0% 1,551 9.6% 70 0.4%

9

North Coast 

Range

 

22,508 0 0% 12 0.1% 0 0%

10

Kupreanof/Mitkof 

Island

 

18,557 0 0% 637 3.4% 25 0.1%

11 Kuiu Island

 

14,984 0 0% 867 5.8% 38 0.3%

12

Central Coast 

Range

 

27,947 0 0% 945 3.4% 38 0.1%

13

Etolin Island & 

Vicinity

 

11,947 0 0% 797 6.7% 33 0.3%
Appendix D

Final EIS D-19 Old-growth Habitat Conservation Strategy

Table 8 (continued)

Distribution of Young-growth Harvest Acres (over 100 years) in Riparian Management 

Areas by Biogeographic Province and Alternative.

Biogeographic 

Province

Forest 

Land 

Acres in 

RMAs 

Outside 

of TTRA 

Buffers)2

Estimated Maximum Young-growth Harvest1 in RMAs

(Young-growth Harvest Acres / % of Forest Land Acres))

Alts 1, 3, and 4 Alt 2 Alt 5

14

North Central 

Prince of Wales

 

49,627 0 0% 7,842 15.8% 314 0.6%

15

Revilla Island/ 

Cleveland Pen.

 

36,834 0 0% 2,017 5.5% 82 0.2%

16

Southern Outer 

Islands

 

5,553 0 0% 431 7.8% 16 0.3%

17

Dall Island and 

Vicinity

 

2,830 0 0% 4 0.1% 0 0%

18

South Prince of 

Wales

 

10,457 0 0% 183 1.7% 7 0.1%

19 North Misty Fiords

 

16,858 0 0% 320 1.9% 15 0.1%

20

South Misty 

Fiords

 

17,462 0 0% 0 0.0% 0 0%

21 Ice Fields

 

17,489 0 0% 1,056 6.0% 46 0.3%

Forest-wide

 

390,490 0 0% 26,030 6.7% 1,089 0.3%

1 For modeling purposes, it was assumed, based on an evaluation of economics, that the minimum harvestable age for young growth is 

65 to 75 years old, depending on site index.

2 Includes young-growth, productive old-growth, and unproductive forest.

Legacy Forest Structure

The Legacy Forest Structure (Legacy) standard and guideline was added to the Forest Plan in 2008, and 

was intended as an ecological approach to Forest-wide retention of old-growth habitat characteristics 

(e.g., large trees, downed logs, and snags) in high risk biogeographic provinces. The Legacy standard 

and guideline evolved from considerations presented at the Interagency Conservation Strategy Review 

workshop (USDA Forest Service 2007) and replaced species-specific goshawk foraging and marten 

standards and guidelines. It applies to those VCUs that have had or are anticipated to have high levels of 

timber harvest (a list is provided in the Forest Plan; USDA Forest Service 2008a) for old-growth harvest 

openings greater than 20 acres in size. 

Alternative 1 includes the current Legacy standard and guideline. Alternatives 2, 3, 4, and 5 include the

current Legacy standard and guideline with a proposed clarification that the VCUs where the Legacy 

standards and guidelines apply should be verified during project-specific planning and analysis based on 

harvest standards listed in the Forest Plan. The Legacy Forest Structure standard and guideline would 

continue to maintain habitats used by old-growth associated species in the VCUs where it applies.

Wildlife

Alternatives 2, 3, 4, and 5 propose a revision to the Goshawk standards and guidelines which address 

nesting habitat. These standards and guidelines expand the requirement to maintain 100 acres of POG 

forest surrounding a nest tree or nest site to include the largest diameter young-growth forest if POG 

alone is not sufficient. The proposed modification would provide greater protection to goshawks and their 

habitat, and therefore would strengthen this standard and guideline because goshawks will nest in 

maturing young-growth forest with sufficient structure, if mature and old-growth forest is unavailable, and 

will also forage in these areas (Reynolds et al. 2006; Boyce et al. 2006). Therefore, the proposed 
Appendix D

Old-growth Habitat Conservation Strategy D-20 Final EIS

modification would provide enhanced protection to goshawk habitat in situations where there are less 

than 100 acres of POG surrounding a nest tree or nest site.

Other Non-wildlife Standards and Guidelines

The current Forest Plan includes a number of other standards and guidelines which preclude or 

significantly limit timber harvest to protect resources other than wildlife. They apply to areas of high 

hazard soils, steep slopes, karst terrain, scenic integrity objectives (SIOs) for visually sensitive travel 

routes and use areas, and timber stands that are technically not feasible to harvest. The retention of oldgrowth forest provided by these standards and guidelines enhances the conservation strategy, although 

they were designed with effects to visual resources in mind rather than their potential benefits to wildlife 

exclusively (Appendix D, USDA Forest Service 2008b). 

Alternatives that modify the current standards and guidelines to make young-growth available for harvest 

would reduce the amount of “additional” retention of forest within the matrix; however, they would not 

result in additional POG harvest. Alternatives 2, 3, and 4 would allow commercial thinning of younggrowth in high vulnerability karst areas. Alternatives 2, 3, and 5 would change the SIO to low SIO for 

young-growth harvest which allows for larger openings. 

Integrity of the Conservation Strategy

Land management on the Tongass National Forest presents a careful balance between ecological, 

economic, and social (community) values. The conservation strategy is intended to maintain ecological 

values and certain economic and social values, while allowing other multiple uses (e.g., timber 

production, renewable energy/infrastructure development, recreation, tourism, mining, and subsistence) 

to occur on the Tongass National Forest. As such, the conservation strategy is not “risk free” but is 

intended to balance an acceptable level of risk in ensuring support of well-distributed, viable wildlife 

populations while meeting the requirements of the National Forest Management Act (PL 86-517; 16 USC 

§528) and Multiple Use Sustainable Yield Act (PL 94-588; 16 USC §1600).

Overall, the conservation strategy is functioning under conditions that represent stronger conservation practice 

than anticipated at the time of its development. Actual and projected old-growth harvest under the existing

Forest Plan are far below levels predicted under the 1997 Forest Plan, which formed the context within which 

the conservation strategy was analyzed and intended to function. This has occurred because of economics 

and a significant decline in the timber industry due to various factors. But most importantly, with the 2001 

Roadless Rule in effect, inventoried roadless areas (approximately 2,143,000 acres of development LUDs in 

roadless areas containing about 823,000 acres of POG) make a major contribution to the maintenance of 

ecological function on the Tongass National Forest but do so outside of the elements of the conservation 

strategy. Under the 1997 Forest Plan, it was projected that 84 percent of the original (1954) POG forest would 

remain in 100 years (Table 9). Under the preferred alternative (Alternative 5) and the other action alternatives, 

91 percent of the original POG forest is anticipated to remain. This equates to approximately 400,000 acres of 

additional old-growth than were assumed during the development and evaluation of the conservation strategy. 

Likewise, under the 1997 Forest Plan approximately 8,500 miles of roads were anticipated to exist by 2095, 

whereas under the current Forest PlanAmendment alternatives less than 6,200 miles of roads are anticipated

by 2095. This translates to substantially lower road densities under the current Forest Plan and the action 

alternatives, compared to the 1997 Plan (Table 9). The additional area of POG will function as additional 

reserves, enhancing the existing reserves, and increasing the effectiveness of the matrix when located around 

harvest units. As such, the substantially greater spatial extent of old-growth forest on the landscape and fewer 

roads across the planning area would outweigh the local, adverse effects of young-growth harvest proposed in 

the Old-growth Habitat LUD, the beach and estuary fringe, and RMAs that would result under the action 

alternatives as described below.

Proposed modifications to contributing elements of the conservation strategy (e.g., beach and estuary 

fringe, RMAs, and non-development LUDs) under Alternatives 2, 3, 4, and 5 have the potential to result in 

localized reductions in the functioning of these elements. That is, young-growth harvest will locally alter 

forest structure and may reduce connectivity, but the beach and estuary fringe and RMAs would continue 

to function as intended across the planning area by serving as ecological transition zones, maintaining 

freshwater and marine aquatic and terrestrial habitat, and providing landscape connectivity. Therefore, 
Appendix D

Final EIS D-21 Old-growth Habitat Conservation Strategy

none of the alternatives, when considered in whole, would reduce the ability of the conservation strategy 

to maintain a functional and interconnected old-growth ecosystem across the planning area and the 

overall functioning of the conservation strategy in terms of its ability to maintain viable, well-distributed 

populations of wildlife across the planning area would remain. 

Under all of the alternatives the extent of localized effects to contributing elements of the conservation 

strategy would depend on project-level decisions and strategic implementation of standard and 

guidelines, such as the landscape connectivity standard and guideline, which are intended to provide 

important safeguards towards ensuring the sustainability of populations of old-growth associated species. 

The consideration of geographic scale is important on the Tongass National Forest because it is an island 

ecosystem, with individual islands at times functioning as metapopulations (many independent 

populations with limited interchange) for some species that do not frequently disperse between islands. 

The responsibility for ensuring the effectiveness of the conservation strategy at finer scales (i.e., 

biogeographic provinces or groups of island), falls on decisions made at the project scale taking into 

account the configuration of individual landscapes. All projects must demonstrate consistency with Forest 

Plan components, such as the Landscape Connectivity, Legacy, and species-specific standards and 

guidelines. This ensures that the Forest Plan is implemented effectively across the planning area, 

including portions, such as the North Central Prince of Wales biogeographic province which have 

experienced larger amounts of timber harvest and associated developments than other areas. Thus, the 

primary difference among alternatives is how the transition to young-growth management would be 

reached, including the timing, intensity, and extent of old-growth versus young-growth harvest; therefore, 

the alternatives vary in the approach employed to maintain the integrity of the conservation strategy. 

However, under all alternatives the integrity of the conservation strategy would be maintained. 

The following paragraphs summarize characteristics of each alternative and review how each maintains 

the integrity of the conservation strategy, beginning with the current Forest Plan (Alternative 1). The 

action alternatives are then described in order of the level of risk they present to localized reductions in 

the functioning of contributing elements of the conservation strategy, from greatest to least risk. 

Under Alternative 1, the current Forest Plan, the integrity of the conservation strategy would be 

maintained because no modifications to its contributing elements are proposed. The conservation 

strategy would continue to function as designed. As outlined above, the history of old-growth harvest 

since 1997 results in a stronger conservation environment than anticipated when the Forest Plan was 

developed and analyzed. Therefore, under Alternative 1 it is expected that viable, well-distributed wildlife 

populations would be maintained across the planning area (USDA Forest Service 2008b). The level of 

old-growth harvest would be much lower than allowed by the existing Forest Plan, in order to transition 

toward a greater level of young-growth harvest. However, Alternative 1 would not expedite the transition 

to young-growth management to the degree of the action alternatives, and therefore, would result in the 

greatest amount of old-growth timber harvest among the alternatives. 

Alternative 2 would have the greatest risk of localized reductions in the functioning of contributing 

elements of the conservation strategy because it would result in the most young-growth harvest, would 

allow clearcutting young growth in non-Development LUDs, would allow clearcutting young growth in the 

beach and estuary fringe for the first 15 years after Forest Plan approval, and would allow commercial 

thinning of young growth in RMAs (Table 9). Alternative 2 would mitigate beach fringe harvest by shifting

the beach and estuary fringe inland, maintaining elements of horizontal connectivity between watersheds 

but reducing effectiveness to serve as a transitional zone between interior forest and marine influence in 

those areas of harvest. Alternative 2 would result in the shortest transition time (about 12 years) and 

would therefore result in the lowest amount of old-growth harvest, minimizing the amount of new road 

construction and POG harvest in undeveloped/intact areas.

Alternative 3 would have the second greatest risk of localized reductions in the functioning of contributing 

elements of the conservation strategy. It would result in the second highest amount of young-growth 

harvest, but unlike Alternative 2 would not allow clearcutting in the beach and estuary fringe (commercial 

thinning only) or any harvest in RMAs. However, this alternative would involve the greatest amount of 

road construction/reconstruction some of which would occur within the beach and estuary fringe. 
Appendix D

Old-growth Habitat Conservation Strategy D-22 Final EIS

Alternative 3 would result in the second shortest transition time (about 13 years), and therefore would 

result in the second lowest amount of POG harvest (Table 9).

Alternative 5 would have the third greatest risk of localized reductions in the functioning of contributing 

elements of the conservation strategy. It would allow created openings of less than 10 acres or 

commercial thinning of young growth in the beach and estuary fringe and RMAs but only during the first 

15 years after Forest Plan approval; effects to wildlife habitat and connectivity would be minimized by 

limiting the size of harvest openings, allowing removal of a maximum of 35 percent of a previously 

harvested stand, and implementing a one-time entry stipulation. Additionally, Alternative 5 would maintain 

a beach and estuary buffer, albeit at a reduced width (200-feetwide), adjacent to the shoreline, which 

would maintain some connectivity. Alternative 5 would allow young-growth harvest in the Old-growth 

Habitat LUD during the first 15 years after Forest Plan approval, but would not allow harvest in any other 

non-development LUD (Table 9). Alternative 5 would result in the third shortest transition time (about 16 

years), and would result in the third lowest amount of POG harvest. 

Alternative 4 would have the lowest risk of localized reductions in the functioning of contributing elements of 

the conservation strategy because no harvest would occur in any non-development LUD or within RMAs, and 

only commercial thinning of young growth would be allowed within the beach and estuary fringe. Alternative 4 

would affect the smallest land base (Phase I lands only), and would result in the third shortest transition time 

(about 16 years; same as Alternative 5), but with the least amount of total harvest (Table 89). 

One of the objectives of the Forest Plan was to “”[P]rovide sufficient habitat to preclude the need for listing of 

species under the Endangered Species Act, or from becoming listed as Sensitive due to National Forest 

habitat conditions” (USDA Forest Service 2008a p. 2-4). Although no terrestrial species in Southeast Alaska 

are listed under the ESA, petitions have been filed for the Alexander Archipelago wolf (2011), Queen Charlotte 

goshawk (1994), and Prince of Wales flying squirrel (2011). The conservation strategy was designed to 

conserve, and thereby avoid the need to list these and other old-growth associated species. All of the 

alternatives are expected to maintain a functional and interconnected old-growth ecosystem, capable of 

supporting well-distributed, viable wildlife populations of wildlife across the planning area; therefore none of 

them are expected to increase the likelihood of species listing under the ESA.

Monitoring, the systematic process of collecting information to evaluate effects of actions or changes in 

conditions or relationships (36 CFR 219.19), is a quality control process for implementation of the 

Tongass Forest Plan. It provides the public, the Forest Service, and other involved resource agencies 

with information on the progress and results of Forest Plan implementation. As such, monitoring, along 

with the evaluation of that monitoring, comprise an essential feedback mechanism within an adaptive 

management framework to keep the Forest Plan dynamic and responsive to changing conditions. The 

evaluation process also provides feedback that can trigger corrective action, adjustment of plans and 

budgets, or both, to facilitate feasible and meaningful action on the ground. 

The Forest Plan monitoring program is an important mechanism for confirming that the transition to 

young-growth management is achieving the desired effects. It allows the Forest Service to respond to 

new information and/or changing conditions, thereby working to ensure that there are no unintended 

consequences of the transition to a young-growth based timber program. The monitoring program is 

being modified concurrently with the proposed Forest Plan amendment to meet the requirements of the 

2012 Planning Rule (Forest Service Handbook 1909.12, chapter 30, section 32.3). The Forest Service is 

developing monitoring questions associated with biodiversity, wildlife, and streams and fish habitat 

(among other topics) which speak to the effects of young-growth management. Draft monitoring questions 

address the ability of young-growth harvest to improve habitat for wildlife and timber production, and the 

ability of riparian vegetation to support key riparian functions. Monitoring data will allow the Forest Service 

to evaluate and change silvicultural prescriptions and other practices as needed to ensure continued 

functioning of contributing elements of the conservation strategy across the planning area. 
Appendix D

Final EIS D-23 Old-growth Habitat Conservation Strategy

Table 9

Summary of Effects by Alternative and Comparison with 1997 Forest Plan

Alt 1 Alt 2 Alt 3 Alt 4 Alt 5

Projected acres of POG harvested 

under 1997 Forest Plan through 

2095

474,000 474,000 474,000 474,000 474,000

Actual acres of POG 

harvested since 1995 plus 

projected acres of harvest under 

2016 Forest Plan through 2095

100,517 70,274 73,233 80,262 80,144

Projected Percent of POG 

remaining in 2095 under 1997 

Forest Plan

84 84 84 84 84

Projected Percent of POG 

remaining in 2095 under 2016 

Forest Plan

90 91 91 91 91

Projected Road Miles/Road 

Density (mi/sq mi) on NFS Lands 

under 1997 Forest Plan in 2095

8,500 mi

0.32 mi/mi2

8,500 mi

0.32 mi/mi2

8,500 mi

0.32 mi/mi2

8,500 mi

0.32 mi/mi2

8,500 mi

0.32 mi/mi2

Projected Road Miles/Road 

Density (mi/sq mi) on NFS Lands 

under 2016 Forest Plan in 2095

6,036 mi

0.23 mi/mi2

6,148 mi

0.23 mi/mi2

6,113 mi

0.23 mi/mi2

5,964 mi

0.23 mi/ mi2

6,086 mi

0.23 mi/ mi2

Estimated Years to Fully 

Transition to Young-growth 

Management

32 years 12 years 13 years 16 years 16 years

Projected Young-growth Harvest 

in Old-Growth Habitat LUD (acres) 0 31,640 26,186 0 1,811

Projected Young-growth Harvest 

in Old-growth Habitat LUD as a % 

of Forest Land Acres in Oldgrowth Habitat LUD

0% 3.3% 2.8% 0% 0.2%

Projected Young-growth Harvest 

in Other Non-Dev. LUDs (acres) 0 12,868 12,857 0 0

Projected Young-growth Harvest 

in Other Non-Dev. LUDs as a % of 

Forest Land Acres in Other NonDev. LUDs

0% 0.8% 0.8% 0% 0%

Projected Young-growth harvest 

in Beach and Estuary Fringe (ac) 0 21,871 30,769 11,114 3,903

Projected Young-growth Harvest 

in Beach/Estuary Fringe as a % of 

Forest Land Acres in 

Beach/Estuary Fringe 

0% 2.4% 3.3% 1.2% 0.4%

Projected Young-growth harvest 

in RMAs outside of TTRA Buffers 

(acres)

0 26,030 0 0 882

Projected Young-growth Harvest

in RMAs as a % of Forest Land 

Acres in RMAs

0% 6.7% 0% 0% 0.3%
Appendix D

Old-growth Habitat Conservation Strategy D-24 Final EIS

References

ADF&G (Alaska Department of Fish and Wildlife). 2012. Status of Wolves in Southeast Alaska. October 

2012.

AFHA. 1995. Anadromous Fish Habitat Assessment. Report to Congress. USDA Forest Service, Pacific 

Northwest Research Station, Alaska Region. R10-MB-279.

D’Amore, D.V., N.S. Bonzey, J. Berkowitz, J. Ruegg, and S. Bridgham. 2011. Holocene soil-geomorphic 

surfaces influence the role of salmon-derived nutrients in the coastal temperate rainforest of 

Southeast Alaska. Geomorphology 126: 377-386. 

Fellman, J.B., E. Hood, R.T. Edwards, and D.V. D’Amore. 2008. Return of salmon-derived nutrients from 

the riparian zone to the stream during a storm in Southeastern Alaska. Ecosystems 11: 537-544.

Fellman, J.B., E.Hood, R.T. Edwards, and D.V. D’Amore. 2009. Changes in the concentration, 

biodegradability, and fluorescent properties of dissolved organic matter during stormflows in 

coastal temperate watersheds. Journal of Geophysical Research 114, GO 1021, doi: 10.1 

029/2008JG000790. 14 pp.

Flaherty, E.A., W.P. Smith, S. Pyare, and M. Ben-David. 2008. Experimental trials of the northern flying 

squirrel (Glaucomys sabrinus) traversing managed rainforest landscapes: perceptual range and 

fine-scale movements. Canadian Journal of Zoology 86:1050–1058.

Flaherty, E.A., M. Ben-David, and W.P. Smith. 2010. Diet and food availability implications for foraging 

and dispersal of Prince of Wales northern flying squirrels across managed landscapes. Journal 

of Mammalogy 91: 79-91.

Flynn, R.W., and T.V. Schumacher. 2009. Temporal changes in population dynamics of American marten. 

The Journal of Wildlife Management 73: 1269-1281.

Flynn, R.W., S.B. Lewis, L.R. Beier, G.W. Pendleton, A.P. Crupi, and D.P. Gregovich. 2009. Spatial use, 

habitat selection, and population ecology of brown bears along the proposed Juneau Access 

Improvements Corridor, Southeast Alaska. Final Wildlife Research Report, Alaska Department of 

Fish and Game, Juneau, Alaska.

Haufler, J., C. Mehl, and S. Yates. 2010. Climate change: anticipated effects on ecosystem services and 

potential actions by the Alaska Region, U.S. Forest Service. Ecosystem Management Research 

Institute, Seeley Lake, Montana.

Hayward, G.D., S. Colt, M. McTeague, T. Hollingsworth. eds. (n.d.). Climate change vulnerability 

assessment for the Chugach National Forest and the Kenai Peninsula. Manuscript in preparation.

Hood, E., J. Fellman, and R.T. Edwards. 2007. Salmon influences on dissolved organic matter in a 

coastal temperate brown-water stream: an application of fluorescence spectroscopy. Limnology 

and Oceanography 52: 1580-1587.

Hood, E., R. Edwards, D. D’Amore, and J. Fellman. 2008. Influence of salmon and wetland-derived 

nutrients on the watershed productivity in the Tongass National Forest. Presentation at the 2008 

USDA-CSREES National Water Conference, Sparks, Nevada.

Lamberti, G.A., Benbow, M.E., Bridgham, S.D., Campbell, E.Y., Chaloner, D.T., D'Amore, D.V., Edwards, 

R.T., Hudson, J.P., Levi, P.S., Merritt, R.W., Reisinger, A.J., Rueegg, J., Tank, J.L. and Tiegs, 

S.D. 2008. Aquatic-terrestrial coupling in the flux, uptake, and effects of Pacific salmon nutrients 

in Southeast Alaska watersheds. North American Benthological Society Annual Meeting. Salt 

Lake City, UT, USA.

Levi, P.S., Tank, J.L., Tiegs, S.D., Chaloner, D.T., and Lamberti, G.A. 2008. Coupled forest management 

and salmon disturbances may alter nutrient dynamics in southeast Alaskan streams. Ecological 

Society of America Meeting, Milwaukee, WI, USA.
Appendix D

Final EIS D-25 Old-growth Habitat Conservation Strategy

Nislow, K.H., C.O. Marks, and K.A. Lutz. 2010. Aquatic conservation planning at the landscape scale. 

Pages 99-119 in S.C. Trombulak and R.F. Baldwin, editors. Landscape-scale conservation 

planning. Springer, Netherlands.

Pauli, J.N., W.E. Moss, P.J. Manlick, E.D. Fountain, R. Kirby, S.M. Sultaire, P.L. Perrig, J.E. Mendoza, 

J.W. Pokallus, and T.H. Heaton. 2015. Examining the uncertain origin and management role of 

martens on Prince of Wales Island, Alaska. Conservation Biology DOI:10.1111/cobi.12491.

Person, D.K., and A.L. Russell. 2008. Correlates of mortality in an exploited wolf population. Journal of 

Wildlife Management 72:1540–1549.

Person, D.K., and A.L. Russell. 2009. Reproduction and den site selection by wolves in a disturbed 

landscape. Northwest Science 83:211–224.

Person, D.K., and B.D. Logan. 2012. A spatial analysis of wolf harvest and harvest risk on Prince of 

Wales and associated islands, southeast Alaska. Final Wildlife Research Report, 

ADF&G/DWC/WRR-2011-1. Alaska Department of Fish and Game, Division of Wildlife 

Conservation, Juneau, AK.

Pyare, S., W.P. Smith, and C.S. Shanley. 2010. Den use and selection by northern flying squirrels in 

fragmented landscapes. Journal of Mammalogy 91:886–896.

Rabe, D. 2009. Population status of Prince of Wales spruce grouse in Southeast Alaska. Final 

performance report. Alaska Department of Fish and Game, Juneau. September. 8 pp

Shanley, C.S., S. Pyare, and W. Smith. 2013. Response of an ecological indicator to landscape 

composition and structure: implications for functional units of temperate rainforest ecosystems. 

Ecological Indicators 24:68-74.

Shanley, C.S., S. Pyare, M.I. Goldstein, P.B. Alaback, D.M. Albert, C.M. Beier, T.J. Brinkman, R.T. 

Edwards, E. Hood, A. MacKinnon, MV. McPhee, T.M. Patterson, L.H. Suring, D.A. Tallmon, M.S. 

Wipfli. 2015. Climate change implications in the northern coastal temperate rainforest of North 

America. Climate Change 130: 155-170. Available online at: 

http://www.uas.alaska.edu/arts_sciences/naturalsciences/envs../faculty_staff/pubs/shanley_etal_

seak_climate_projections_climatic_change_2015.pdf

Schenk, T. 2011. Wildlife thinning-science and adaptive management on the Tongass National Forest. 

USDA Forest Service, Issue Paper. April 2011.

Schmiegelow, F.K.A., S.G. Cumming, S. Harrison, S. Leroux, K. Lisgo, R. Noss, and B. Olsen. 2006. 

Conservation beyond crisis management: a reverse-matrix model. BEACONs Project discussion 

paper No. 1. University of Alberta. Available online at: 

https://www.ualberta.ca/~fschmieg/Beacons/PDFs/BEACONS1.pdf

Schmiegelow, F. and K. Lisgo. 2014. Landscape conservation design: BEACONs and the NWB LCC. 

Presentation at the Northwest Boreal Landscape Conservation Cooperative steering committee 

meeting, July 15-17, 2014, Whitehorse, Yukon. Available online at: http://nwblcc.org/wpcontent/uploads/2014/08/4.-NWB-Fiona-S-BEACONs-Tuesday-AM.pdf

Smith, W. 2012. Flying squirrel demography varies between island communities and without red squirrels. 

Northwest Science 86: 27-38.

Smith, W. 2013. Spatially explicit analysis of contributions of a regional conservation strategy toward 

sustaining northern goshawk habitat. Wildlife Society Bulletin 37: 1-10.

Smith, W.P., D.K. Person, and S. Pyare. 2011. Source-sinks, metapopulations, and forest reserves: 

conserving northern flying squirrels in the temperate rainforests of southeast Alaska. Pages 399–

422 in J. Liu, V. Hull, A.T. Morzillo, and J.A. Wiens (eds). Sources, sinks, and sustainability. 

Cambridge University Press, Cambridge, U.K.
Appendix D

Old-growth Habitat Conservation Strategy D-26 Final EIS

Tiegs, S.D., Chaloner, D.T., Levi, P., Rueegg, J., Tank, J.L., and Lamberti, G.A. (2008). Timber Harvest 

Transforms Ecological Roles of Salmon in Southeast Alaska Rain Forest Streams. Ecological 

Applications 18(1):4-11.

USDA Forest Service (U.S. Department of Agriculture, Forest Service). 1997a. Tongass land and 

resource management plan revision: Tongass National Forest. R10-MB-338dd. Juneau, AK: 

Alaska Region.

USDA Forest Service. 1997b. Tongass land management plan revision: final environmental impact 

statement (FEIS). Part 1: Summary, chapter 1, 2, and 3. R10-MB-338b. Juneau, AK: Alaska 

Region. 

USDA Forest Service. 1997b. Tongass land and resource management plan revision: Final 

Environmental Impact Statement. Appendix N. R10-MB-338h. Juneau, AK: Alaska Region. 

USDA Forest Service. 2007. Interagency conservation strategy review: an assessment of new 

information since 1997. Proceedings of workshop held April 10-12 2006, Ketchikan, Alaska.

USDA Forest Service. 2008a. Tongass Land and Resource Management Plan. Forest Service, R10-MB603b. Juneau, AK: Alaska Region.

USDA Forest Service. 2008b. Tongass Land and Resource Management Plan, Final Environmental 

Impact Statement, Plan Amendment. Forest Service, R10-MB-603c. Juneau, AK: Alaska Region.

USDA Forest Service. 2008c. Tongass Land and Resource Management Plan, Plan Amendment, 

Record of Decision. Forest Service, R10-MB-603a. Juneau, AK: Alaska Region.

USDA Forest Service. 2013. Big Thorne Timber Sale Project Final Environmental Impact Statement. First 

Service, R10-MB-736c.

USFWS (U.S. Fish and Wildlife Service). 2010. Species assessment and listing priority assignment form: 

Falcipennis canadensis isleibi Prince of Wales spruce grouse. U.S. Fish and Wildlife Service, 

Region 7.

Weckworth, B.V., S.L. Talbot, and J.A. Cook. 2010. Phylogeography of wolves (Canos lupus) in the 

Pacific Northwest. Journal of Mammalogy 91:363–375.

Weckworth, B.V., N.G. Dawson, S.L. Talbot, M.J. Flamme, and J.A. Cook. 2011. Going coastal: shared 

evolutionary history between coastal British Columbia and southeast Alaska wolves (Canis 

lupus). PLoS ONE 6(5):1–8.

White, K.S., G.W. Pendleton, and E. Hood. 2009. Effects of snow on Sitka black-tailed deer browse 

availability and nutritional carrying capacity in southeastern Alaska. Journal of Wildlife 

Management 73:481–487.
APPENDIX E

INTERAGENCY OLD GROWTH

RESERVE REVIEW
1

Interagency Old Growth Reserve Review

Sealaska Land Conveyance

September 2015

Meeting date: Craig Ranger District, February 3-5, 2015

Attendees: Steve Brockmann (USFWS), Steve Bethune (ADF&G), Mark Minnillo (ADF&G);

USFS: Brian Logan, Marla Dillman, Ray Slayton, Sally Burch, Lucy Maldonado (Day 1 only), 

Molly Simonson (note taker).

INTRODUCTION 

The Sealaska Land Entitlement finalization of the Carl Levin and Howard P. ‘Buck’ McKeon 

National Defense Authorization Act for Fiscal Year 2015 conveyed 69,585 acres of Tongass 

National Forest lands to Sealaska Corporation to fulfill the commitment in the Alaska Native 

Claims Settlement Act. Included in these acres are areas that are designated as Old Growth 

Reserves (OGRs) in the 2008 Tongass Land and Resource Management Plan (Forest Plan). All 

of the OGRs reduced by the conveyance addressed here are on Prince of Wales Island and two 

smaller islands to the west. 

On February 3, 2015 an interagency review team (IRT) met to develop a biologically preferred 

option for OGRs that meets Forest Plan Appendix K criteria and to document why other 

proposals are not recommended. The IRT was comprised of biologists from the U.S. Fish and 

Wildlife Service (USFWS), the Alaska Department of Fish and Game (ADF&G), and the U. S. 

Forest Service (USFS) who met in Thorne Bay to review the small OGRs affected by the land 

conveyance. 

This meeting addressed how small OGRs have been affected by the Sealaska Land Entitlement

finalization. The IRT came up with an interagency recommendation (biologically preferred 

location IOGRs) for each small OGR affected and one medium OGR.

The 2008 Forest Plan uses Land Use Designations (LUD) to guide the management of NFS lands 

within the Tongass. Each designation provides for a unique combination of activities, practices 

and uses. LUD II areas are congressionally designated areas in a roadless state to retain the 

wildland character. Wildlife and fish habitat improvement and primitive recreational facility 

development may be permitted. Timber harvesting is limited to insect and disease control. Roads 

will not be built except to serve mining and other authorized activities and vital Forest 

transportation and utility system linkages. LUD IIs are also designated as large OGRs. Large 

OGRs have not been reviewed since 1997. Some of the LUD IIs changed as a result of the land 

conveyance. The 2008 Forest Plan defines LUD II as Congressionally designated areas that 

should be managed in a roadless state to retain the wildland character. Wildlife and fish habitat 

improvement and primitive recreational facility development may be permitted. Timber 

harvesting is limited to insect and disease control. Roads will not be built except to serve mining 

and other authorized activities and vital Forest transportation and utility system linkages. 

Our process was to look at large and medium OGRs and then move on to small OGRs. 

The land conveyance directly affected OGRs on POW, and neighboring islands) in VCUs 5450, 
2

5460, 5560, 5570, 5600, 5872, 5900, 5940, 6180, 6190, 6200, and 6850 (see map 1).

This document will discuss the effects to the VCUs listed above as well as OGRs in VCUs that 

were indirectly impacted by the land conveyance; most of these VCUs involve the medium 

OGR. These VCUs include 6160, 6170, 6750 and 6760. 

VCUs 5450, 5460 are on Kosciusko Island; 5560, 5570, 5600 and 5872 are on Tuxekan Island; 

while 5900 and 5940 (Election Creek); 6180, and 6190 were a medium OGR in the Old Thom’s 

Research Natural Area; 6200 (Dog Salmon) and 6850 (Nutkwa) are all Prince of Wales Island.

The 2015 Interagency review team proposal for the medium also affects VCUs 6160, 6170, 6750 

and 6760.
3 

Map 1

Conservation Strategy 
4

Small OGRs were analyzed extensively during the 2008 Forest Plan Amendment process (USFS 

2008), and many were modified. This review is discussed as the 2006 IRT. The Forest Plan 

allows line officers to further modify the size and location of OGRs under certain circumstances 

(Forest Plan Appendix K). Modifications of small OGRs require an interagency review to ensure 

that OGRs meet Forest Plan criteria. Alternative locations for OGRs “must provide comparable 

achievement of Old–growth Habitat LUD goals and objectives” (Forest Plan, p. 3-57 and 3-62).

Goals

• Maintain areas of old-growth forests and their associated natural ecological processes to 

provide habitat for old-growth associated resources.

• Manage early seral conifer stands to achieve old-growth forest characteristic structure 

and composition based upon site capability. Use old growth definitions as outlined in 

Ecological Definitions for Old-growth Forest Types in Southeast Alaska (R10-TP-28).

Objectives

• Provide old-growth forest habitats, in combination with other LUDs, to maintain viable 

populations of native and desired non-native fish and wildlife species and subspecies that 

may be closely associated with old-growth forests.

• Contribute to the habitat capability of fish and wildlife resources to support sustainable

human subsistence and recreational uses.

• Maintain components of flora and fauna biodiversity and ecological processes associated 

with old-growth forests.

• Allow existing natural or previously harvested early seral conifer stands to evolve 

naturally to old-growth forest habitats, or apply silvicultural treatments to accelerate 

forest succession to achieve old-growth forest structural features. Consider practices such 

as thinning, release and weeding, pruning, and fertilization to promote accelerated 

development of old-growth characteristics.

• To the extent feasible, limit roads, facilities, and permitted uses to those compatible with 

old-growth forest habitat management objectives.

• Significant modifications to OGRs (e.g. a land conveyance or substantial timber harvest) 

require consideration and review of factors such as connectivity, size, and shape of the 

reserve, as well as the basic assumptions behind the existing reserve location. 

Pursuant to Forest Plan Appendix K, OGR boundary changes require an interagency team of 

USDA Forest Service (USFS), U.S. Fish and Wildlife Service (USFWS), and Alaska Department 

of Fish and Game (ADF&G) biologists to jointly evaluate the location and habitat composition 

of the OGRs by reviewing such things as productive old growth (POG) blocks within a VCU. 

One goal of the Forest Plan is to maintain healthy forest ecosystems with a mix of habitats at 

different spatial scales capable of supporting the full range of naturally occurring flora, fauna, 

and ecological processes characteristic of Southeast Alaska. To accomplish this goal, an oldgrowth habitat conservation strategy was incorporated into the Forest Plan. This strategy consists 

of two components. The first is a forest-wide system of old-growth reserves (OGRs) comprised 

of lands classified by the Forest Plan as non-development land use designations (LUDs). These 

LUDs include, among others, Wilderness, Wilderness National Monument, Remote and SemiRemote Recreation, Wild Rivers, Municipal Watersheds, and Old-growth Habitat LUDs. The 

Old-growth Habitat LUD is further subdivided into small, medium, and large old-growth 
5

reserves. The second component of the old-growth strategy is the set of standards and guidelines 

for habitats that occur within the “matrix” or lands outside of the non-development LUDs. 

OGR Criteria 

The Forest Plan Appendix K and 2008 Forest Plan FEIS Appendix D describe the requirements 

for OGRs in detail. Primary OGR habitat criteria are summarized below. OGR calculations are 

based on the acres of National Forest Service lands within the VCU. 

• Small OGRs should encompass a contiguous landscape representing at least 16 percent of 

each VCU with at least 50 percent of that area in productive old growth (POG). The 

preferred biological objective is for each small OGR to contain at least 800 acres of POG. 

• OGRs must contain a minimum of 400 acres of POG. 

• Where VCU boundaries do not match watershed or ecological boundaries, up to 30 

percent of the OGR may be mapped in an adjacent VCU if the OGR objectives are met. 

• VCUs that are separated by saltwater channels, reserves may be separated, but attempt to 

retain 800 acres of productive old growth in each. 

• OGR boundaries should follow recognizable features that are identifiable on the ground 

such as streams, roads, distinctive ridges, watershed boundaries, or v-notches. 

• OGRs should be located so that spacing is maintained in the four cardinal directions. 

• Reserves should be more circular rather than linear to maximize the amount of interior 

forest habitat. 

• The amount of early seral habitat (young growth) and roads should be minimized within 

the OGRs. 

• Existing large blocks of contiguous high-volume old-growth forest should not be further 

fragmented by timber harvesting or road building. 

• Incorporate wider corridors. Designed corridors should be of sufficient width to minimize 

edge effect and provide interior forest conditions. 

• Do not differentially cut low altitude, high-volume old growth [represented by marten 

winter habitat: high-POG <800 feet elevation] 

• Site-specific factors in placing reserves should be considered to help meet multiple 

biodiversity or wildlife habitat objectives. Factors include, but are not limited to: 

1. The largest remaining blocks of contiguous old growth within a watershed. Oldgrowth forest that constitutes scattered fragments of unsuitable timberland generally 

did not contribute to meeting small reserve design. 

2. Rare features such as underrepresented forest plant associations or stands with some 

of the Forest’s highest volume timber stands (defined as high-POG and particularly 

SD67). 

3. Known or suspected goshawk nesting habitat (defined as high-POG <1000 feet 

elevation). 

4. Known or suspected marbled murrelet nesting habitat. [Represented by large tree 

SD67] 

5. Important deer winter range to maintain important deer habitat capability to meet 

public demand for use of the deer resource (defined as high-POG <800 feet elevation 
6

on south and west aspects for deep snow habitat and POG <1500 feet elevation for 

average winter habitat).

Other Forest Plan Direction 

Forest Plan Management Prescriptions for Old-growth Habitat (Forest Plan FEIS p. 3-62) 

• During project-level environmental analysis, for projects areas that include or are 

adjacent to mapped old-growth habitat reserves, the size, spacing, and habitat 

composition of mapped reserves may be further evaluated (See Appendix K for mapping 

criteria.) 

• Adjust reserves not meeting the minimum criteria to meet or exceed the minimum 

criteria. Reserve location, composition, and size may otherwise also be adjusted. 

• Alternative reserves must provide comparable achievement of the Old-growth Habitat 

LUD goals and objectives. Determination as to comparability must consider the criteria 

listed in Appendix K. 

• Adjustments to individual reserves are not expected to require a significant plan 

amendment. Adjustments Forest-wide shall be monitored yearly to assess whether a 

significant plan amendment is warranted on the basis of cumulative changes. 

Forest-wide Standards and Guidelines for Landscape Connectivity (Forest Plan p. 4-91):

Design projects to maintain landscape connectivity. The objective is to maintain corridors of oldgrowth forest among large and medium Old-growth Habitat reserves (Appendix K) and other 

Non-development LUDs at the landscape scale. Review forest connectivity within and between 

OGRs and non-development LUDs during environmental review of projects proposing timber 

harvest, road construction, or other significant vegetation alteration. Where existing corridors are 

insufficient or vulnerable to harvest, stands of POG should be provided as corridors or small 

reserves should be relocated.

HISTORY OF THE OGRS 

The following documents provide the history of OGRs:

Developmental and National Setting LUD’s and VPOP (February 1997)

Forest Plan (1997)

Prince of Wales Island Interagency OGR Review Report (2002)

Final Forest Plan (2008) OGR spreadsheet (09_092909_OGR_Tracking_Table.xls)

Individual NEPA documents that included OGRs analysis:

Central Prince of Wales (CPOW) EIS (1993) -VCU 5542

Polk Inlet EIS (1995) - VCUs 6180, 6190 and 6200

Control Lake EIS (1998) -VCUs 5940, 5950 and 5960

Cholmondeley EIS (1998) -VCUs 6160, 6170, 6750 and 6760

Kosciusko DEIS (2002) -VCUs 5450 and 5460

Tuxekan Timber Sale DEIS (update 2004) – VCUs 5560, 5570, 5600 and 5872

Staney Timber Sale (TEAMS) (2005) –VCU 5900

Big Thorne EIS (2013) -VCU 5950
7

Not covered under any previous NEPA (except Forest Plan) – 6850

ANALYSIS OF THE OGRS

Past reviews of the small OGRs include the 2002 Review of the OGRs on Prince of Wales Island 

(2002 POW review team) and a 2006 Tongass wide review of the OGRs, including those on 

Prince of Wales, for the 2008 Forest Plan amendment (2006 IRT). 

The goals of the 2015 IRT included:

• Review purpose, rational, and objectives used by previous interagency review teams for 

locating current OGRs;

• Identify biologically preferred OGR locations for OGRs located in VCUs 5450, 5460, 

5560, 5570, 5600, 5872, 5900, 5940, 6180, 6190, 6200, and 6850. 

ANALYSIS OF OGRS by VCU

Kosciusko Island 

Pre-conveyance: During the 2006 OGR review for the 2008 Forest Plan amendment the 

designated OGRs in VCUs 5450 and 5460 were combined. All the OGR in VCU 5460 were 

counted towards the OGR in VCU 5450. The acres designated as a Special Interest Area (SA) 

LUD in VCU 5460 function and count as OGR acres in VCU 5460. The required amount of 

acres for a small OGR is met in VCU 5460 by the designation of an SA in this VCU under the 

2008 Forest Plan. Both OGRs were modified to exclude units proposed in the Kosciusko Timber 

Sale. Acknowledge The IRT recommended that that Forest Road 1525225 which occurs within 

the OGR be closed. 

Post Conveyance: On Kosciusko Island the Defense Authorization Act for 2015 conveyed almost 

12,000 acres of National Forest land to the Sealaska Corporation. Nearly all of the acres were 

productive forest lands (11,161 acres) and the majority of these acres are young growth timber 

(7,328 acres). 

The land conveyance minimally affected the currently designated small OGR boundaries in VCU 

5450 and 5460. The conveyance removed a small portion of the OGR in VCU 5450 in the 

southwest corner and the OGR in VCU 5460 lost the small western finger. 

VCU 5450 -Survey Cove

In the 1997 TLMP there were two disconnected OGRs in this VCU that are mapped as small 

OGRs (see Figure 1). The western OGR is overlap from and applies to VCU 5450. 

Pre-conveyance: The 2002 POW review team relocated the 1997 TLMP small OGR to increase 

POG acres because the 1997 TLMP OGR was mostly muskeg. The 2002 POW review team 

proposal expanded the OGR to the south and northeast to pick up POG acres. Since there is not 

enough POG remaining in this VCU the 2002 POW review team expanded the OGR into 

adjacent VCU 5460. This OGR was linear, contained second growth, roads, and higher elevation 

stands. The OGR did not include preferred habitat but it did include the only remaining habitat. 

2006 IRT recommended adopting the 2002 POW review team OGR. The proposed 2006 IRT 

OGR in VCU 5450 overlaps into VCU 5460. 
8

The 2006 IDT noted that the 2006 IRT OGR (that was originally proposed by the 2002 POW 

review team) included units in the Kosciusko Timber Sale and modified the IOGR to exclude 

these units. A project level review was recommended to consider adding second growth habitat 

to make the OGR more circular.

Post Conveyance: The conveyance removed a small southwest portion of the OGR in VCU 

5450. The land conveyance resulted in the removal of 68 acres from the OGR in VCU 5450; 53 

of these acres were POG. The resulting OGR still meets minimum Forest Plan acre and POG 

acre requirements.

2015 IOGR Rationale/Notes: This VCU has been heavily impacted by past harvest. There are no 

large contiguous blocks of POG left in VCU 5450. In order to replace the acres of POG lost due 

to the land conveyance the 2015 IRT proposes adding acres from adjacent VCU 5460. The 

block of POG added from VCU 5460 is one of the largest remaining patches of contiguous old 

growth in that VCU. The 2015 IRT proposal also adds acres and POG acres to the OGR in VCU 

5450 from the adjacent VCU (5460) to try to compensate for the overall loss of POG in VCU 

5450. Adding the acres from VCU 5460 to the proposed 2015 biologically preferred OGR also 

helps to maintain connectivity through the central portion of south Kosciusko Island; this is 

especially important at the landscape scale when considering that this area is now surrounded by 

lands in other ownerships. The 2015 IRT proposal would add 1260 total acres and 904 acres of 

POG to the OGR. As a result of these additional acres the 2015 IRT OGR would exceeds both 

the minimum acre requirements and the POG acres requirements. The 2015 IRT felt this was 

necessary given the amount of past harvest in the area, the current lack of remaining POG and 

lack of connectivity in this portion of Kosciusko Island (see Figure 1). 
9

Comparison of Small OGR in VCU 5450 

Pre-conveyance Postconveyance2015 Biologically 

Preferred

General VCU Info./Forest Plan Appendix K Criteria

Total land all ownership (acres) 10,764

Non-NFS land (acres) 3,109 6,249 6,249

NFS land Total (acres) 7,655 4,515 4,515

16% of NFS land (Min. Req. OGR acres) 1,211 722 722

All Non-development LUD in VCU 1,993 1,917 1,994

Small OGR (total acres)1/ 1,454 1,386 2,6521/

8% of NFS land (Min. POG Req. acres) 605 361 361

OGR POG (total acres)2/ 867 814 1,718

All Non-development POG (acres) 1,267 1,220 1,468

Acreage requirements met? (Total/POG) Yes/Yes Yes/Yes Yes/Yes

Small OGR LUD Overlap into Adjacent VCU

VCU 5460

Total OGR Acres 266 260 1,448

OGR POG Acres 266 260 1,159

Small OGR LUD Overlap from Adjacent VCU

VCU NA NA NA

Total Acres

POG Acres

Appendix D General Design Criteria

Circular rather than linear to maximize interior 

habitat/minimize fragmentation effects 

Yes Yes Yes

Minimizes roads (total road miles) 3.9 3.9 4.8

Includes streams (Class I stream miles) 0.0 0.0 6.2

Minimizes early seral habitat (acres) 293 293 463

Includes largest remaining block of POG in VCU? No No Yes

Rare/Underrepresented features (large tree POG acres) 3/ 499 453 1,016

Deep snow deer/marten habitat (acres) 4/ 297 271 742

Goshawk and murrelet nesting habitat (acres) 5/ 703 656 1,273

Other Considerations

Maintains Connectivity No No Yes

Low elevation POG (acres)6/ 423 391 1,150

1/Small OGR includes all OG and other Non-Dev LUDs that apply to the VCU to meet Forest Plan Standard and Guidelines for

this reserve. This includes overlap into adjacent VCUs and excludes Non-Dev LUD in the VCU not associated with this reserve.

2/ 50% of OGR acres

3/ SD67 type

4/ High-volume POG ≤ 800 feet in elevation

5/ High-volume POG all elevations (indicative of optimal goshawk and marbled murrelet nesting habitat due to presence of large 

trees and snags, though both species may use all POG types; see Issue 3)

6/ All POG ≤ 800 feet in elevation (representative of low-elevation travel corridors important for many species)
10

VCU 5460 -Edna Bay

Pre Conveyance: In the 1997 TLMP there were two disconnected areas in this VCU that were 

both designated as small OGRs (see Figure 1). The western OGR was overlap from and applies 

to the OGR in VCU 5450. The eastern OGR counted towards the OGR in this VCU (5460). The 

acres in the western OGR that count towards the OGR in VCU 5450 are discussed above under 

that VCU.

Since eastern OGR was short total acres the 2006 IRT recommended expanding it to the north to 

create a more circular reserve and form a connection with the low elevation pass between Van 

Sant Creek and Trout Creek (in VCU 5430), where evidence of high deer use has been observed. 

This OGR includes the high vulnerability karst on west side of Van Sant Creek and a portion of 

the POG remaining at Van Sant Cove. The 2006 IRT recommended prioritizing second growth 

included in the OGR for thinning. 

The 2006 IRT IOGR included units proposed in the Kosciusko Timber Sale. The 2006 IRT 

responded that it was preferable that the IOGR maintain the travel corridor/pass located on the 

east side of the VCU. The modified the IOGR excluded the Kosciusko Timber Sale units but 

maintains the low elevation east-west travel corridor/pass between Van Sant Creek and Trout 

Creek (in VCU 5430). The 2006 team recommended that Forest Service Road 1525225 be 

closed. 

For the 2008 Forest Plan the eastern OGR designation was changed from small OGR to SA; the 

boundary of the OGR was not changed. The acres now designated as SA count and function as 

the OGR in this VCU. A portion of this SA overlaps into adjacent VCU 5430. The contiguous 

acres of this SA in VCU 5430 also count towards the OGR in VCU 5460. There is another noncontiguous SA in VCU 5430 that functions as the OGR for VCU 5430

Post conveyance: The land conveyance resulted in the loss of the western finger of the western 

OGR in this VCU; however these acres count towards the OGR in VCU 5450. The land 

conveyance also changed the area that was designated as SA to a LUD II designation. The 

boundaries of the SA/LUD II area were not changed (see Figure 1). 

2015 IOGR Rationale/Notes: For 2015 IRT comments on the affects to the western OGR see 

discussion under VCU 5450 above. 

Under the 2008 Forest Plan the SA in VCU 5460 functioned as the OGR in this VCU. As part of 

the defense bill the SA LUD in VCU 5460 was converted to a LUD II which the 2015 IRT 

believes meets the intent of and functions as an OGR in this VCU. The minimum acreage 

criteria and POG acres required for a small OGR are met by the LUD II area. Therefore no 

changes are recommended and no additional acres are required for this SA/LUD II/OGR. 

Acreage differences in this OGR/SA/LUD II shown in the comparison table between pre 

conveyance and post conveyance are due to GIS edits, no changes were made to the boundary

(see Figure 1).
11

Comparison of Small OGR in VCU 5460*

PreconveyancePostconveyance2015 Biologically 

Preferred

General VCU Info./Forest Plan Appendix K Criteria

Total land all ownership (acres) 14,655

Non-NFS land (acres) 4,055 5,326 5,326

NFS land Total (acres) 10,600 9,329 9,329

16% of NFS land (Min. Req. OGR acres) 1,697 1,493 1,493

All Non-development LUD in VCU 1,508 1,501 1,501

Small OGR (total acres)1/ 0 1, 656 1, 656

8% of NFS land (Min. POG Req. acres) 849 746 746

OGR POG (total acres)2/ 0 1,167 1,167

All Non-development POG (acres) 1,214 1,207 1,207

Acreage requirements met? (Total/POG) Yes/Yes Yes/Yes Yes/Yes

Small OGR LUD Overlap into Adjacent VCU

VCU 5430

Total OGR Acres 519 519 519

OGR POG Acres 305 305 305

Small OGR LUD Overlap from Adjacent VCU

VCU NA NA NA

Total Acres

POG Acres

Appendix D General Design Criteria

Circular rather than linear to maximize interior 

habitat/minimize fragmentation effects 

No No No

Minimizes roads (total road miles) 3.2 3.2 3.2

Includes streams (Class I stream miles) 0.6 0.6 0.6

Minimizes early seral habitat (acres) 360 360 360

Includes largest remaining block of POG in VCU? Yes Yes Yes

Rare/Underrepresented features (large tree POG acres) 3/ 935 935 935

Deep snow deer/marten habitat (acres) 4/ 494 494 494

Goshawk and murrelet nesting habitat (acres) 5/ 1,068 1,068 1,068

Other Considerations

Maintains Connectivity Yes Yes Yes

Low elevation POG (acres)6/ 561 561 561

1/Small OGR includes all OG and other Non-Dev LUDs that apply to the VCU to meet Forest Plan Standard and Guidelines for

this reserve. This includes overlap into adjacent VCUs and excludes Non-Dev LUD in the VCU not associated with this reserve.

2/ Should be approximately 50% of OGR acres

3/ SD67 type

4/ High-volume POG ≤ 800 feet in elevation

5/ High-volume POG all elevations (indicative of optimal goshawk and marbled murrelet nesting habitat due to presence of large 

trees and snags, though both species may use all POG types)

6/ All POG ≤ 800 feet in elevation (representative of low-elevation travel corridors important for many species)

*Acreage differences between pre and post conveyance due to GIS map edits and not boundary changes
12

Sealaska Land Conveyance effect to SA/OGR in VCU 5410 with ROW at Shipley Bay

There are no mapped OGR acres in this VCU; all acres are mapped as SA or LUD II acres. The

SA in this VCU is in two separate pieces. The northwestern piece functions as the OGR for VCU 

5430. This piece was originally contiguous with the large Mt Calder-Mt Holbrook LUD II; 

however due to the land conveyance Sealaska now has a road right of way (ROW) through here 

to potentially connect to the old LTF/MAF in Shipley Bay. As a result of the ROW the portion 

of the OGR/LUD II in VCU 5430 is now disconnected from the large Mt Calder –Mt Holbrook 

LUD II area (see Figure 1). 

These acres in the northwestern mapped SA/OGR in VCU 5430 are contiguous with the western 

OGR/SA acres in VCU 5410. Combining the northern SA/OGR in VCU 5430 (4,669 acres) 

with the western portion of SA/OGR in VCU 5410 (3,234 acres) for a total of 7,933 acres. The 

POG acres when these two areas are combined equal 6,008 acres. The small OGR requirements 

for this VCU are at least 2,522 acres with 1,261 acres of POG (without the reduction in required 

acres in the OGR due to the overall loss of Forest Service acres in the VCU). The Sealaska land 

conveyance resulted in a portion of the SA/OGR in this VCU being disconnected to the Mt 

Calder-Mt Holbrook LUD II area; however, despite loss of the connectivity between the 

OGR/LUD II in VCU 5430, the area still has adequate protected habitat to meet minimum small 

OGR requirements in this VCU. The 2015 IRT recommends no additional OGR designations in 

this VCU.
13

VCUs 5450 and 5460 and Right of Way in VCU 5410

Figure 1
14

Tuxekan Island

VCU 5560 -Northwest Tuxekan

Pre Conveyance: The 2006 IRT proposed to adopt the POW 2002 Review and Tuxekan Timber 

Sale Draft ROD proposal to relocate 1997 Forest Plan small OGR. This proposal added the 

largest remaining block of POG that includes south-facing slopes, high value deer winter range, 

and goshawk and murrelet nesting habitat. This proposal increased total acres in the OGR and

includes some young growth acres.

The 2008 Forest Plan Amendment reduced the size of the small OGR to meet minimum acre 

criteria but retained the largest remaining block of POG, south-facing slopes, high value deer 

winter range, and potential goshawk and murrelet nesting habitat. 

The OG LUD was added to this VCU because while the non-development LUD acres in this 

VCU meet the acre criteria for a small OGR these acres occur on a series of small islands and not 

on Tuxekan Island. 

Post Conveyance: Most of the land in this VCU is now in Sealaska ownership including the 

entire area that was designated as small OGR in this VCU. The remaining acres of nondevelopment LUD in this VCU are on small islands mostly to the north of Tuxekan Island. These 

acres of non-development meet the Forest Plan minimum acres requirements for a small OGR. 

2015 IOGR Rationale/Notes: Most of the remaining Forest Service acreage in VCU 5560 is on 

El Cap Island and other small, isolated, non-timbered islands. There is only one substantial block

of POG in Forest Service ownership left in this VCU on Tuxekan Island. The 2015 IRT

recommends that this block be included in the OGR. Most of the block of POG is within the

beach buffer and therefore low elevation POG. The 2015 IRT recommends that the OGR in this 

VCU connect with the OGR in VCU 5570 to maintain this block. The 2015 IOGR proposal in 

VCU 5560 is contiguous with the 2015 IOGR proposal in VCU 5570. These two OGRs provide 

some connectivity between Tuxekan Island and mainland POW via a saltwater channel (see 

Figure 2).
15

Comparison of Small OGR in VCU 5560

PreconveyancePostconveyance2015 Biologically 

Preferred

General VCU Info./Forest Plan Appendix K Criteria

Total land all ownership (acres) 6,789

Non-NFS land (acres) 843 4,359 4,359

NFS land Total (acres) 5,946 2,430 2,430

16% of NFS land (Min. Req. OGR acres) 951 374 374

All Non-development LUD in VCU 3,055 1,866 2,321

Small OGR (total acres)1/ 1,016 0 455

8% of NFS land (Min. POG Req. acres) 476 187 187

OGR POG (total acres)2/ 882 0 378

All-Non-development LUD POG (acres) 2,167 1,229 1,609

Acreage requirements met? (Total/POG) Yes/Yes No/No Yes/Yes

Small OGR LUD Overlap into Adjacent VCU

VCU NA NA NA

Total OGR Acres

OGR POG Acres

Small OGR LUD Overlap from Adjacent VCU

VCU NA NA NA

Total Acres

POG Acres

Appendix D General Design Criteria

Circular rather than linear to maximize interior 

habitat/minimize fragmentation effects 

Yes No Yes

Minimizes roads (total road miles) 1.6 0.0 0.0

Includes streams (Class I stream miles) 4.2 0 0.6

Minimizes early seral habitat (acres) 0 0 57

Includes largest remaining block of POG in VCU? Yes No Yes

Rare/Underrepresented features (large tree POG acres) 3/ 361 0 331

Deep snow deer/marten habitat (acres) 4/ 418 0 363

Goshawk and murrelet nesting habitat (acres) 5/ 418 0 363

Other Considerations

Maintains Connectivity Yes No Yes

Low elevation POG (acres)6/ 882 0 381

1/Small OGR includes all OG and other Non-Dev LUDs that apply to the VCU to meet Forest Plan Standard and Guidelines for

this reserve. This includes overlap into adjacent VCUs and excludes Non-Dev LUD in the VCU not associated with this

reserve.

2/ Should be approximately 50% of OGR acres

3/ SD67 type

4/ High-volume POG ≤ 800 feet in elevation

5/ High-volume POG all elevations (indicative of optimal goshawk and marbled murrelet nesting habitat due to presence of 

large trees and snags, though both species may use all POG types)

6/ All POG ≤ 800 feet in elevation (representative of low-elevation travel corridors important for many species)
16

VCU 5570 -Northeast Tuxekan

VCU 5570 is separated by a saltwater channel with a portion of the VCU on Tuxekan Island and 

part on Prince of Wales Island. 

Pre conveyance: The OGR in VCU 5570 overlaps into both VCU 5560 and VCU 5600. This 

overlap is not required to meet acre criteria but to follow recognizable features. The 2006 IRT

adopted the 2006 Tuxekan Timber Sale Draft ROD OGR that relocated the small OGR to 

increase POG, maintain low elevation habitat, deer winter range, murrelet nest, and potential 

goshawk nesting habitat. The 2006 IRT OGR was adopted in the 2008 Forest Plan.

Post Conveyance: The Sealaska land conveyance resulted in the loss of most the acres 

designated as small OGR in this VCU. The remaining acres of OGR are now isolated and 

surrounded by lands in other ownership. 

2015 IOGR Rationale/Notes: The 2015 IRT recommends replacing the acres remaining in the 

existing small OGR on Tuxekan with acres on the northern tip of the island adjacent to the 2015 

IRT proposed OGR in VCU 5560 (see Figure 2). The intent of these acres is to provide 

connectivity between the large LUD II area around Sarkar Lake in VCUs 5541 and 5542 (on 

POW mainland) and the IRT proposed small OGR in VCU 5560 (on Tuxekan). The connectivity 

factor is of higher importance than trying to exclude the second growth that occurs within the 

2015 IRT proposed OGR. The 2015 IRT recommends selecting an area, mostly beach buffer, 

which is across the saltwater channel on mainland POW. Most of these proposed acres on 

mainland POW are still in VCU 5570; however in order to provide compete connectivity to the 

large LUD II area acres in VCU 5542 were also included. These acres across the channel would 

extend from just south of Dargon Point north to Kahli Cove. Even though these two areas are 

separated by a saltwater channel they will contribute to the connectivity across to mainland 

POW. The saltwater channel is at the most about 1 mile across; however this channel is 

interspersed with many smaller islands which would facilitate dispersal. By selecting the acres 

on mainland POW connectivity is improved between Tuxekan Island and the large LUD II area 

around Sarkar Lake. This LUD II area is then connected to other OGRs and LUD II areas on 

POW. 
17

Comparison of Small OGR in VCU 5570

PreconveyancePostconveyance2015 Biologically 

Preferred

General VCU Info./Forest Plan Appendix K Criteria

Total land all ownership (acres) 8,520

Non-NFS land (acres) 1,487 3,812 3,812

NFS land Total (acres) 7,033 4,708 4,708

16% of NFS land (Min. Req. OGR acres) 1,128 738 738

All Non-development LUD in VCU 1,556 737 2,304

Small OGR (total acres)1/ 1,309 328 1,566

8% of NFS land (Min. POG Req. acres) 564 369 369

OGR POG (total acres)2/ 884 280 810

All Non-development LUD POG (acres) 4,097 576 1,328

Acreage requirements met? (Total/POG) Yes/Yes No/No Yes/Yes

Small OGR LUD Overlap into Adjacent VCU

VCU 5560

Total OGR Acres 103 0 0

OGR POG Acres 55 0 0

Small OGR LUD Overlap into Adjacent VCU

VCU 5600

Total Acres 93 0 0

POG Acres 62 0 0

Small OGR LUD Overlap into Adjacent VCU

VCU 5542

Total Acres 0 0 70

POG Acres 0 0 58

Appendix D General Design Criteria

Circular rather than linear to maximize interior 

habitat/minimize fragmentation effects 

Yes No Yes

Minimizes roads (total road miles) 3.4 0.4 4.4

Includes streams (Class I stream miles) 4.0 0.6 2.6

Minimizes early seral habitat (acres) 9 9 734

Includes largest remaining block of POG in VCU? Yes No Yes

Rare/Underrepresented features (large tree POG acres) 3/ 444 66 432

Deep snow deer/marten habitat (acres) 4/ 567 102 666

Goshawk and murrelet nesting habitat (acres) 5/ 567 102 666

Other Considerations

Maintains Connectivity Yes No Yes

Low elevation POG (acres)6/ 884 280 810

1/Small OGR includes all OG and other Non-Dev LUDs that apply to the VCU to meet Forest Plan Standard and Guidelines for

this reserve. This includes overlap into adjacent VCUs and excludes Non-Dev LUD in the VCU not associated with this reserve.

2/ Should be approximately 50% of OGR acres

3/ SD67 type

4/ High-volume POG ≤ 800 feet in elevation

5/ High-volume POG all elevations (indicative of optimal goshawk and marbled murrelet nesting habitat due to presence of large 

trees and snags, though both species may use all POG types)

6/ All POG ≤ 800 feet in elevation (representative of low-elevation travel corridors important for many species)
18

VCU 5600 -Southwest Tuxekan

Pre Conveyance: The 2006 IRT proposed to adopt the 2002 POW IRT and Tuxekan Timber Sale 

Draft ROD that modified the small OGR to increase acres to meet total and POG acre 

requirements; include both deer winter range and the largest contiguous block of POG, as well as

the low elevation pass between the east fork of Karheen Creek and the large lake in VCU 5800. 

This modified OGR also follows recognizable features and improves connectivity. The OGR is 

linear in shape because VCU is fragmented by past harvest. The OGR was designed to include 

remaining POG and maintain connectivity. 

Post Conveyance: Due to the Sealaska land conveyance there is very little Forest Service land 

remaining in this VCU. Conveyance reduces connectivity between OGRs in VCUs 5600 and 

5872, which were linear spanning Tuxekan Island.

2015 IOGR Rationale/Notes: The Sealaska land conveyance results in little National Forest 

Service (NFS) land remaining in this VCU. The 2015 IRT suggested OGR includes most of the 

remaining NFS land in the VCU and as a result exceeds the 16 percent of NFS land in the VCU 

requirement in the Forest Plan (see Figure 2). Biologically Preferred OGR enhances connectivity 

to the beach.
19

Comparison of OGR in VCU 5600

PreconveyancePostconveyance2015 Biologically 

Preferred

General VCU Info./Forest Plan Appendix K Criteria

Total land all ownership (acres) 6,026

Non-NFS land (acres) 2 5,264 5,264

NFS land Total (acres) 6,024 762 762

16% of NFS land (Min. Req. OGR acres) 964 122 122

All Non-development LUD in VCU 1,213 563 761

Small OGR (total acres)1/ 1,059 556 755

8% of NFS land (Min. POG Req. acres) 482 61 61

OGR POG (total acres)2/ 788 373 526

All Non-development LUD POG (acres) 861 373 526

Acreage requirements met? (Total/POG) Yes/Yes Yes/Yes Yes/Yes

Small OGR LUD Overlap into Adjacent VCU

VCU NA NA NA

Total OGR Acres

OGR POG Acres

Small OGR LUD Overlap from Adjacent VCU

VCU NA NA NA

Total Acres

POG Acres

Appendix D General Design Criteria

Circular rather than linear to maximize interior 

habitat/minimize fragmentation effects 

No No Yes

Minimizes roads (total road miles) 0.9 0.0 0.0

Includes streams (Class I stream miles) 5.2 3.8 4.8

Minimizes early seral habitat (acres) 0 0 21

Includes largest remaining block of POG in VCU? No No No

Rare/Underrepresented features (large tree POG acres) 3/ 382 95 116

Deep snow deer/marten habitat (acres) 4/ 474 165 299

Goshawk and murrelet nesting habitat (acres) 5/ 506 165 299

Other Considerations

Maintains Connectivity Yes No Yes

Low elevation POG (acres)6/ 756 373 526

1/Small OGR includes all OG and other Non-Dev LUDs that apply to the VCU to meet Forest Plan Standard and Guidelines for

this reserve. This includes overlap into adjacent VCUs and excludes Non-Dev LUD in the VCU not associated with this reserve.

2/ Should be approximately 50% of OGR acres

3/ SD67 type

4/ High-volume POG ≤ 800 feet in elevation

5/ High-volume POG all elevations (indicative of optimal goshawk and marbled murrelet nesting habitat due to presence of large 

trees and snags, though both species may use all POG types)

6/ All POG ≤ 800 feet in elevation (representative of low-elevation travel corridors important for many species)
20

VCU 5872 -Southeast Tuxekan

Pre Conveyance: The 2006 IRT recommended adopting the past interagency proposal and

Tuxekan Timber Sale Draft ROD that recommended relocating the small OGR to include the 

largest remaining block of POG and increase deer winter range. 

Post Conveyance: Due to the Sealaska land conveyance there is very little Forest Service land 

remaining in this VCU. The 2015 IRT suggested OGR includes most of the remaining NFS land 

in the VCU and as a result exceeds the 16 percent of NFS land in the VCU requirement in the 

Forest Plan.

2015 IOGR Rationale/Notes: The 2015 IRT recommend the 1997 TLMP OGR boundary with 

some modifications (see Figure 3). Nichen Cove on Tuxekan Island has human impacts and 

activities (log transfer facility and roads etc.). The 2015 IRT determined that it was less 

important to include the Nichen Cove area in the OGR as one criterion is to reduce road miles in 

an OGR. 

The conveyance eliminates connectivity with the small OGR in VCU 5600 (see Figure 2). The 

Biologically Preferred OGR adds connectivity to the beach.
21

Comparison of Small OGR in VCU 5872

Pre-conveyance Postconveyance2015 

Biologically 

Preferred

General VCU Info./Forest Plan Appendix K Criteria

Total land all ownership (acres) 3,310

Non-NFS land (acres) 0 2,087 2,087

NFS land Total (acres) 3,310 1,223 1,223

16% of NFS land (Min. Req. OGR acres) 530 196 196

All Non-development LUD in VCU 553 228 858

Small OGR (total acres)1/ 536 227 857

8% of NFS land (Min. POG Req. acres) 265 98 98

OGR POG (total acres)2/ 501 219 474

All Non-development LUD POG (acres) 501 219 474

Acreage requirements met? (Total/POG) Yes/Yes Yes/Yes Yes/Yes

Small OGR LUD Overlap into Adjacent VCU

VCU NA NA NA

Total OGR Acres

OGR POG Acres

Small OGR LUD Overlap from Adjacent VCU

VCU NA NA NA

Total Acres

POG Acres

Appendix D General Design Criteria

Circular rather than linear to maximize interior 

habitat/minimize fragmentation effects 

Yes No Yes

Minimizes roads (total road miles) 1.8 0.0 0.0

Includes streams (Class I stream miles) 0.7 0.5 3.5

Minimizes early seral habitat (acres) 1 1 5

Includes largest remaining block of POG in VCU? Yes No Yes

Rare/Underrepresented features (large tree POG acres) 3/ 293 32 36

Deep snow deer/marten habitat (acres) 4/ 295 36 51

Goshawk and murrelet nesting habitat (acres) 5/ 314 36 51

Other Considerations

Maintains Connectivity Yes No Yes

Low elevation POG (acres)6/ 482 219 474

1/Small OGR includes all OG and other Non-Dev LUDs that apply to the VCU to meet Forest Plan Standard and Guidelines for

this reserve. This includes overlap into adjacent VCUs and excludes Non-Dev LUD in the VCU not associated with this reserve.

2/ Should be approximately 50% of OGR acres

3/ SD67 type

4/ High-volume POG ≤ 800 feet in elevation

5/ High-volume POG all elevations (indicative of optimal goshawk and marbled murrelet nesting habitat due to presence of large 

trees and snags, though both species may use all POG types)

6/ All POG ≤ 800 feet in elevation (representative of low-elevation travel corridors important for many species)
22

VCU 5560, 5570, 5600 and 5872

Figure 2
23

VCU 5940 -Election Creek

Pre-Conveyance: During the 2006 review it was proposed to revert to the 1997 TLMP OGR to 

exclude contracted Timber Sale units. The 2006 IRT proposed to add an area east of the 1997 

TLMP OGR to maintain connectivity. 

A project level review was recommended because the 2006 IDT Forest Plan proposed OGR did

not maintain east/west connectivity. Although the proposed OGR does maintain the largest 

contiguous block of POG and north/south connectivity, it is important to also maintain east/west 

connectivity in the area because of the amount of past harvest that has occurred in this area.

Post Conveyance: The land conveyance resulted in the loss of the largest contiguous block of 

POG as well as connectivity between VCU 5940 and VCU 5900 (north/south connectivity). The 

connectivity between VCUs 5940 and 5900 provided connectivity between the OGR in VCU 

5940 and OGRs in VCUs to the north. 

2015 IOGR Rationale/Notes: Most of the existing small OGR in this VCU was conveyed to 

Sealaska. The 2015 IRT proposes that the small remaining portion of the original OGR along 

the western edge of the land conveyance be dropped. The 2015 IRT proposed the small portion 

along the eastern edge of the Sealaska land conveyance be kept and expanded to the east to the 

VCU line with VCU 5950 to connect with the current OGR that exists in VCU 5950 (see Figure 

3). This will provide the east/west connectivity mentioned in the 2006 review. This connectivity 

will help to compensate for the loss of the north/south connectivity lost due to the land 

conveyance.

The 2015 IRT proposed OGR in VCU 5940 is short both total and POG acres; however the IRT 

determined that this was acceptable due to the fact that the proposed OGR is adjacent to the IRT 

proposed OGR in VCU 5950 and the connectivity that the placement of the OGR here provides. 

The OGR in VCU 5950 connects to the large Honker OGR complex via roadless. The 2015 IRT 

OGR includes all remaining acres in this VCU east of the land conveyance; any additional acres 

in this VCU would be separated by Sealaska land.

The conveyance splits this small OGR. The Biologically Preferred alternative maintains 

connectivity to small OGRs in VCUs 5900 and 5950 (see Figure 3).
24

Comparison of Small OGR in VCU 5940

Pre-conveyance Postconveyance2015 Biologically 

Preferred

General VCU Info./Forest Plan Appendix K Criteria

Total land all ownership (acres) 33,334

Non-NFS land (acres) 15,737 17,587 17,587

NFS land Total (acres) 17,597 15,747 15,747

16% of NFS land (Min. Req. OGR acres) 2,816 2,520 2,520

All Non-development LUD in VCU 2,770 1,072 1,952

Small OGR (total acres)1/ 2,270 1,072 1,499

8% of NFS land (Min. POG Req. acres) 1,408 1,260 1,260

OGR POG (total acres)2/ 1,824 438 607

All Non-development LUD POG (acres) 1,824 438 805

Acreage requirements met? (Total/POG) No/Yes No/No No/No*

Small OGR LUD Overlap into Adjacent VCU

VCU NA NA NA

Total OGR Acres

OGR POG Acres

Small OGR LUD Overlap from Adjacent VCU

VCU NA NA NA

Total Acres

POG Acres

Appendix D General Design Criteria

Circular rather than linear to maximize interior 

habitat/minimize fragmentation effects 

Yes No No

Minimizes roads (total road miles) 3.9 1.2 1.2

Includes streams (Class I stream miles) 5.3 0.2 0.2

Minimizes early seral habitat (acres) 83 83 90

Includes largest remaining block of POG in VCU? Yes No No

Rare/Underrepresented features (large tree POG acres) 3/ 735 71 71

Deep snow deer/marten habitat (acres) 4/ 786 32 53

Goshawk and murrelet nesting habitat (acres) 5/ 1,344 243 203

Other Considerations

Maintains Connectivity NA No Yes

Low elevation POG (acres)6/ 945 65 125

1/Small OGR includes all OG and other Non-Dev LUDs that apply to the VCU to meet Forest Plan Standard and Guidelines for

this reserve. This includes overlap into adjacent VCUs and excludes Non-Dev LUD in the VCU not associated with this reserve.

2/ Should be approximately 50% of OGR acres

3/ SD67 type

4/ High-volume POG ≤ 800 feet in elevation

5/ High-volume POG all elevations (indicative of optimal goshawk and marbled murrelet nesting habitat due to presence of large 

trees and snags, though both species may use all POG types)

6/ All POG ≤ 800 feet in elevation (representative of low-elevation travel corridors important for many species)

*See discussion for this VCU and VCU 5950
25

VCU 5950 -Big Salt

The land conveyance did not impact the OGR in this VCU directly; however, the 2015 IRT 

proposes expanding the OGR in this VCU to the north and west (see Figure 3). The 2015 IRT 

also proposes an expansion of the current OGR to the southeast to include an area of contiguous

high volume POG (HPOG). This additional HPOG in VCU 5950 helps to compensate for loss of 

high volume POG in VCU 5940. This area of HPOG in VCU 5950 is currently mapped as 

roadless.

The existing 2008 Forest Plan OGR in VCU 5950 was modified under the Big Thorne EIS. The 

current proposed 2015 IRT expansions avoid Big Thorne units.

The east/west connectivity that this OGR modification helps to provide includes a connection 

with currently mapped roadless acres in VCU 5950 that then connects to the OGR in VCU 5960 

which is included as part of the large Honker OGR complex (OG LUD designated areas as well 

as other non-development LUDs). 
26

Comparison of Small OGR in VCU 5950

Pre-conveyance Postconveyance2015 Biologically 

Preferred

General VCU Info./Forest Plan Appendix K Criteria

Total land all ownership (acres) 21,465

Non-NFS land (acres) 3,741 3,741 3,741

NFS land Total (acres) 17,724 17,724 17,724

16% of NFS land (Min. Req. OGR acres) 2,836 2,836 2,836

All Non-development LUD in VCU 4,230 4,230 5,215

Small OGR (total acres)1/ 2,037 2,037 3,567

8% of NFS land (Min. POG Req. acres) 1,418 1,418 1,418

OGR POG (total acres)2/ 1,261 1,261 1,969

All Non-development LUD POG (acres) 2,161 2,161 2,694

Acreage requirements met? (Total/POG) No/No No/No Yes/Yes

Small OGR LUD Overlap into Adjacent VCU

VCU NA NA NA

Total OGR Acres

OGR POG Acres

Small OGR LUD Overlap from Adjacent VCU

VCU NA NA NA

Total Acres

POG Acres

Appendix D General Design Criteria

Circular rather than linear to maximize interior 

habitat/minimize fragmentation effects 

Yes Yes Yes

Minimizes roads (total road miles) 2.6 2.6 5.5

Includes streams (Class I stream miles) 2.9 2.9 6.3

Minimizes early seral habitat (acres) 256 256 295

Includes largest remaining block of POG in VCU? No No No

Rare/Underrepresented features (large tree POG acres) 3/ 477 477 755

Deep snow deer/marten habitat (acres) 4/ 488 488 786

Goshawk and murrelet nesting habitat (acres) 5/ 875 875 1,223

Other Considerations

Maintains Connectivity Yes Yes Yes

Low elevation POG (acres)6/ 755 755 1,100

1/Small OGR includes all OG and other Non-Dev LUDs that apply to the VCU to meet Forest Plan Standard and Guidelines for

this reserve. This includes overlap into adjacent VCUs and excludes Non-Dev LUD in the VCU not associated with this reserve.

2/ Should be approximately 50% of OGR acres

3/ SD67 type

4/ High-volume POG ≤ 800 feet in elevation

5/ High-volume POG all elevations (indicative of optimal goshawk and marbled murrelet nesting habitat due to presence of large 

trees and snags, though both species may use all POG types)

6/ All POG ≤ 800 feet in elevation (representative of low-elevation travel corridors important for many species)
27

VCU 5900 -North Election Creek

Pre Conveyance: This OGR is directly north of and contiguous with the OGR in 5940. As 

mapped the small OGR in VCU 5900 is 2,406 acres in size with 1,161 acres of POG (and 571 

acres of high volume POG). 

The 2002 POW review team modified 1997 TLMP small OGR to increase total acres. This 

proposal removed high-elevation areas from side slopes of middle fork of Staney Creek and adds 

low elevation stands along the north fork of Staney Creek, adds high value deer winter range and 

potential goshawk and murrelet nesting habitat. Addition of POG will aid in maintaining flying 

squirrel habitat. About 50 percent of POG is in riparian buffer. This OGR provides connectivity 

through the Staney Creek watershed to the Small OGR in VCU 5940. The 2006 Forest Plan 

adopted this proposal.

Pre Conveyance: The land conveyance reduced the OGR in this VCU by 83 acres. As a result of 

the land conveyance the OGR in this VCU does not meet the minimum acres and POG acres 

requirements for a small OGR in this VCU (see Figure 3). 

2015 Rationale/Notes: The 2015 IRT did not evaluate the OGR in this VCU. This OGR will still 

connected to the remaining OGR in VCU 5940 and so is connected through that OGR and the 

OGR in VCU 5950 to the Honker OGR. Via e-mails the OGR in this VCU was modified to 

improve the connectivity between this OGR and the OGR in VCU 5940. As a result of the land 

conveyance the remaining corridor connecting these two OGRs was less than 1,000 feet wide. 

With the proposed modification the corridor width now exceeds 1,000 feet in width. The 

modification results in the addition of about 395 total acres with about 189 of those acres being 

POG. The modification also added about 60 acres of young growth to the OGR. 
28

Comparison of Small OGR in VCU 5900

PreconveyancePost-conveyance 2015 Biologically 

Preferred

General VCU Info./Forest Plan Appendix K Criteria

Total land all ownership (acres) 13,795

Non-NFS land (acres) 0 168 168

NFS land Total (acres) 13,795 13,627 13,627

16% of NFS land (Min. Req. OGR ac) 2,207 2,180 2,180

All Non-development LUD in VCU 2,406 2,323 2,323

Small OGR (total acres)1/ 2,406 2,232 2,627

8% of NFS land (Min. POG Req. acres) 1,104 1,090 1,090

OGR POG (total acres)2/ 1,172 1,098 1,287

All Non-development LUD POG 1,172 1,098 1,287

Acreage requirements met? (Total/POG) Yes/Yes Yes/Yes Yes/Yes

Small OGR LUD Overlap into Adjacent VCU

VCU N/A

Total OGR Acres

OGR POG Acres

Small OGR LUD Overlap from Adjacent VCU

VCU N/A

Total Acres

POG Acres

Appendix D General Design Criteria

Circular rather than linear to maximize interior 

habitat/minimize fragmentation effects 

Yes Yes Yes

Minimizes roads (total road miles) 6.9 6.6 7.2

Includes streams (Class I stream miles) 12.5 11.7 11.7

Minimizes early seral habitat (acres) 435 435 +60

Includes largest remaining block of POG in VCU? No No No

Rare/Underrepresented features (large tree POG ac) 3/ 532 489 519

Deep snow deer/marten habitat (acres) 4/ 592 548 554

Goshawk and murrelet nesting habitat (acres) 5/ 615 571 648

Other Considerations

Maintains Connectivity Yes Yes Yes

Low elevation POG (acres)6/ 1,114 1,041 1,041

1/Small OGR includes all OG and other Non-Dev LUDs that apply to the VCU to meet Forest Plan Standard and Guidelines for

this reserve. This includes overlap into adjacent VCUs and excludes Non-Dev LUD in the VCU not associated with this reserve.

2/ Should be approximately 50% of OGR acres

3/ SD67 type

4/ High-volume POG ≤ 800 feet in elevation

5/ High-volume POG all elevations (indicative of optimal goshawk and marbled murrelet nesting habitat due to presence of large 

trees and snags, though both species may use all POG types)

6/ All POG ≤ 800 feet in elevation (representative of low-elevation travel corridors important for many species)
29

VCUs 5900, 5940 and 5950

Figure 3
30

VCU 6850 -Nutkwa

Pre Conveyance: The OGR in this VCU is contiguous with non-development LUDs in VCU 

compartments of this VCU; VCU 6851 and VCU 6852. 

The OGR maintains HPOG, deer winter range, and a low elevation corridor connecting Keeta 

Inlet to Nutkwa Lagoon. 

Post Conveyance: The land conveyed to Sealaska consisted of mostly high volume POG; 

however even with land conveyance the remaining OGR will still be contiguous with the SPOW 

wilderness as well as Nutkwa LUD II area. The remaining OGR maintains some low elevation 

connection between Keeta Inlet and Nutkwa Lagoon.

2015 Rationale/Notes: The 2015 IRT recommends moving the OGR to the south to include the 

largest remaining contiguous block of POG outside the existing OGR. This modified OGR also 

includes potential murrelet and goshawk nesting habitat, western facing slopes, and provides an 

elevational corridor from the alpine to the saltwater (see Figure 4).
31

Comparison of Small OGR in VCU 6850

PreconveyancePostconveyance2015 Biologically 

Preferred

General VCU Info./Forest Plan Appendix K Criteria

Total land all ownership (acres) 17,490

Non-NFS land (acres) 5,248 14,241 14,241

NFS land Total (acres) 12,242 3,249 3,249

16% of NFS land (Min. Req. OGR acres) 1,959 520 520

All Non-development LUD in VCU 2,221 1,001 1,985

Small OGR (total acres)1/ 2,058 914 984

8% of NFS land (Min. POG Req. acres) 980 260 260

OGR POG (total acres)2/ 1,458 453 555

All Non-development LUD POG 1,500 484 1,038

Acreage requirements met? (Total/POG) Yes/Yes Yes/Yes Yes/Yes

Small OGR LUD Overlap into Adjacent VCU

VCU 6870

Total OGR Acres 16 16 7

OGR POG Acres 3 3 0

Small OGR LUD Overlap from Adjacent VCU

VCU NA NA NA

Total Acres

POG Acres

Appendix D General Design Criteria

Circular rather than linear to maximize interior 

habitat/minimize fragmentation effects 

Yes No Yes

Minimizes roads (total road miles) 0.0 0.0 0.0

Includes streams (Class I stream miles) 1.0 0.0 0.0

Minimizes early seral habitat (acres) 0 0 0

Includes largest remaining block of POG in VCU? No No Yes

Rare/Underrepresented features (large tree POG acres) 3/ 468 16 120

Deep snow deer/marten habitat (acres) 4/ 501 11 90

Goshawk and murrelet nesting habitat (acres) 5/ 858 227 342

Other Considerations

Maintains Connectivity Yes No Yes

Low elevation POG (acres)6/ 745 16 1,119

1/Small OGR includes all OG and other Non-Dev LUDs that apply to the VCU to meet Forest Plan Standard and Guidelines for

this reserve. This includes overlap into adjacent VCUs and excludes Non-Dev LUD in the VCU not associated with this reserve.

2/ Should be approximately 50% of OGR acres

3/ SD67 type

4/ High-volume POG ≤ 800 feet in elevation

5/ High-volume POG all elevations (indicative of optimal goshawk and marbled murrelet nesting habitat due to presence of large 

trees and snags, though both species may use all POG types)

6/ All POG ≤ 800 feet in elevation (representative of low-elevation travel corridors important for many species)
32

VCU 6850

Figure 4
33

VCU 6200 -Dog Salmon

This small OGR was only minimally impacted by the land conveyance; however most of these 

acres were high volume POG. The OGR was adjusted to compensate for this loss. The 2015 IRT

recommendation includes the addition of a similarly sized piece of high volume POG just to the 

south of what was conveyed (see Figure 5).

Comparison of Small OGR in VCU 6200

PreconveyancePostconveyance2015 Biologically 

Preferred

General VCU Info./Forest Plan Appendix K Criteria

Total land all ownership (acres) 24,800

Non-NFS land (acres) 1,310 4,013 4,013

NFS land Total (acres) 23,490 20,787 20,787

16% of NFS land (Min. Req. OGR acres) 3,758 3,326 3,326

All Non-development LUD in VCU 3,874 3,710 3,943

Small OGR (total acres)1/ 3,827 3,707 3,940

8% of NFS land (Min. POG Req. acres) 1,879 1,663 1,663

OGR POG (total acres)2/ 1,907 1,836 1,919

All Non-development LUD POG (acres) 1,918 1,836 1,919

Acreage requirements met? (Total/POG) Yes/Yes Yes/Yes Yes/Yes

Small OGR LUD Overlap into Adjacent VCU

VCU NA NA NA

Total OGR Acres

OGR POG Acres

Small OGR LUD Overlap from Adjacent VCU

VCU NA NA NA

Total Acres

POG Acres

Appendix D General Design Criteria

Circular rather than linear to maximize interior 

habitat/minimize fragmentation effects 

Yes Yes Yes

Minimizes roads (total road miles) 13.7 13.1 13.1

Includes streams (Class I stream miles) 9.3 8.9 8.9

Minimizes early seral habitat (acres) 716 716 745

Includes largest remaining block of POG in VCU? No No No

Rare/Underrepresented features (large tree POG acres) 3/ 963 912 991

Deep snow deer/marten habitat (acres) 4/ 836 796 796

Goshawk and murrelet nesting habitat (acres) 5/ 1,357 1,306 1,387

Other Considerations

Maintains Connectivity Yes Yes Yes

Low elevation POG (acres)6/ 1,217 1,156 1,156

1/Small OGR includes all OG and other Non-Dev LUDs that apply to the VCU to meet Forest Plan Standard and Guidelines for

this reserve. This includes overlap into adjacent VCUs and excludes Non-Dev LUD in the VCU not associated with this reserve.

2/ Should be approximately 50% of OGR acres

3/ SD67 type

4/ High-volume POG ≤ 800 feet in elevation

5/ High-volume POG all elevations (indicative of optimal goshawk and marbled murrelet nesting habitat due to presence of large 

trees and snags, though both species may use all POG types)

6/ All POG ≤ 800 feet in elevation (representative of low-elevation travel corridors important for many species)
34

VCU 6200

Figure 5
35

Old Thom’s Medium

Pre-Conveyance: The medium OGR in this area consisted of acres designated as OGR in VCUs 

6180 and 6190 and the Old Thom’s Natural Research Area (RNA) in VCU 6180. Included in the 

RNA was a USGS Gauging Station. Medium OGRs are supposed to be approximately 10,000 

acres in size with a minimum of 5,000 acres of POG and a minimum of 2,500 acres of HPOG, 

and no farther than 8 miles from other medium or large OGRs, in the four cardinal directions

(1997 Forest Plan Appendix K). 

Post Conveyance: The Sealaska land conveyance affected the medium OGR in VCUs 6180 and 

6190. The resulting acres do not meet the criteria in the 1997 TLMP Appendix K for a medium 

OGR. The loss of the medium OGR violates the 8 mile proximity requirement for the medium 

OGRs. 

2015 IOGR Rationale/Notes: Options for remedying the loss of the medium in this area include 

establishing new medium OGR, and/or adjusting/expanding current existing ones to decrease 

distance between OGRs. The 2015 interagency group considered the intent of the Conservation 

Strategy at the larger landscape scale for this land area. Lands near Sunny Cove are particularly 

valuable for wildlife, and could be a small OGR; however, Sunny Cove by itself can’t replace or 

replicate the medium OGR that was lost. Sunny Cove is an intact watershed that may serve as a 

good replacement for the Old Thom’s RNA. The Sunny Cove small OGR in VCU 6750 is near 

the Cholmondeley medium OGR (VCUs 6170 and 6760) (see Figure 6). 

There was discussion as to whether to add the entire Cholmondeley medium to the remaining 

Old Thom’s medium, drop part of the existing Cholmondeley medium, or trade it out entirely 

(but that option doesn’t account for the loss of the Old Thom’s medium OGR).

The replacement of the medium in the Old Thom’s area needs to be considered at a landscape 

scale across many VCUs. The proposed replacement of the medium in this area impacts VCUs 

6160 (Monie Lake), 6170 (Clover Bay), 6180 (Old Thom’s), 6190 (Goose Bay), 6750 (Sunny 

Creek) and 6760 (Cholmondeley) (see Figure 6).

The discussion involved trying to connect what is left of the Old Thom’s medium OGR in VCU 

6190 to what was the proposed 2006 interagency medium OGR in VCUs 6160, 6170, 6750 and 

6760. The 2006 proposed medium OGR boundary would be modified in VCU 6750. The 2015 

IRT proposed enlarging the 2006 OGR in VCU 6750 to include acres to the north to connect to 

the southern boundary of VCU 6180. The 2015 IRT proposal is to build off the remaining 

medium OGR acres in VCU 6180 and increase the OGR to the south to connect to the proposed 

OGR in VCU 6750. A disconnected piece of remaining OGR in VCU 6190 south of Goose Bay 

would be expanded to include all reaming Forest Service acres in this area. VCU 6190 also 

includes acres across Polk Inlet. The piece south of Goose Bay was included to help minimize 

the distance between medium OGRs. It is a small isolated piece of OGR that does include low 

elevation POG habitat (see Figure 6).

The proposed new medium OGR has a total of 19,060 acres with 8,387 of POG and 4,121 acres 

of high volume POG. This new OGR is circular and includes only 0.7 miles of road, has 34 miles 

of Class I streams, only 229 acres of young growth, includes the largest block of POG, 1,184 of 

large tree POG (SD67), 2,697 acres of deep snow deer and marten habitat and 3,971 acres of 
36

potential goshawk and murrelet nesting habitat. This OGR maintains connectivity and includes 

5, 745 acres of low elevation POG.

VCU 6160 -Monie Lake

Pre Conveyance: Prior to the 2008 Forest Plan this VCU included both a medium and a small 

OGR. The location of the OGR was very controversial. It was recommended to consider this 

OGR for future review. The 1997 TLMP small OGR is linear along the beach fringe, contains 

few south facing slopes with POG, little habitat for goshawks or marbled murrelet and does not 

contain the largest contiguous blocks of POG in the watershed. 

The 2002 POW review proposed changing the TLMP small OGR to a medium OGR and relocating

the OGR to increase acres of POG and high volume POG and make the OGR more circular. The 

2002 proposal includes most of the largest blocks of contiguous POG, potential goshawk and 

murrelet nesting habitat and important deer winter range. The proposed medium OGR would occur 

along the shore of VCUs 6160, 6170, 6750 and 6760. The 2002 POW review added entire Monie 

Lake watershed from Lake to shoreline and includes large blocks of POG in this area. The proposed 

medium would eliminate the need for a small OGR in VCUs 6160 and 6750. 

The 2006 IRT biologically preferred OGR in this VCU changed the designation from a small 

OGR to a medium OGR. The OGR in this VCU would be combined with the OGRs in VCUs 

6170, 6750 and 6760 to form a medium OGR. 

Post Conveyance: The OGR in this VCU was not directly impacted by the land conveyance. 

2015 IRT: The 2015 IRT proposes that the medium OGR in this VCU be the same as the 

biologically preferred IOGR proposed for the 2008 Forest Plan (2006 IRT IOGR). The existing 

small OGR in VCU 6160 is expanded; as a result the small amount of existing medium OGR 

acreage goes away (see Figure 6).

VCU 6170 -Clover Bay

Pre Conveyance: The 2002 POW IRT relocated the TLMP OGR to increase acres of POG and 

high volume POG and to make more circular. The proposal included most of the largest blocks 

of contiguous POG, potential goshawk and murrelet nesting habitat and important deer winter 

range. The OGR in this VCU would be part of the medium OGR that also includes acres in 

VCUs 6160, 6170, 6750 and 6760. 

The 2006 IRT biologically preferred OGR in this VCU changed the designation from a small 

OGR to a medium OGR. The OGR in this VCU would be combined with the OGRs in VCUs 

6750 and 6760 to form a medium OGR.

Post Conveyance: The OGR in this VCU was not directly impacted by the land conveyance. 

2015 IRT: The 2015 IRT proposes that the medium OGR in this VCU be the same as the IOGR 

as proposed for the 2008 Forest Plan (2006 IRT IOGR) (see Figure 6).

VCU 6180 -Old Thom’s Research Natural Area

Pre Conveyance: The 2006 IRT modified the 1997 TLMP medium Old Thom Medium OGR by 

adding acres to south to increase both POG and high volume POG. The medium OGR maintains 

connectivity in area heavily fragmented by harvest and private lands.
37

Post Conveyance: Most of what was medium OGR/RNA in this VCU was lost due to the land 

conveyance. 

2015 Review: The 2015 IRT recommends including both the remaining OGR acres and the remaining 

RNA acres in the proposed medium. The southern boundary of this proposed modified medium OGR 

will be a Sealaska ROW. This ROW interrupts the connectivity of the medium OGR with other 

proposed OGR acres in this VCU. The interagency group felt that this ROW was narrow enough as to 

not pose a significant problem for most species. The 2015 IRT proposed additional acres south of the 

ROW provide connectivity to OGR acres in VCU 6750 (Sunny Cove). These acres also include low 

elevation habitat around the south end of McKenzie Inlet (see Figure 6). 

VCU 6190 -Goose Bay

Pre Conveyance: According to 2002 POW IRT the medium IOGR exceeded the minimum acre 

criteria for POG and high POG and it was mentioned to consider reducing OGR size to allow for 

future management activities. 

The 2006 review team recommended modifying the 1997 TLMP medium Old Thom’s OGR by 

adding acres to the south. This modification increased both POG and high POG acres. The 

added area includes both roads and second growth stands. 

The consensus of the 2006 review team was to not adopt the IOGR so as to maintain future 

harvest opportunities because while the IOGR is preferred biologically reverting to the 1997 

TLMP OGR still maintains the integrity of the OGR.

Post Conveyance: Most of what was medium OGR/RNA in this VCU was lost due to the land 

conveyance. 

2015 Review: The 2015 IRT recommends the creation of a new small OGR in this VCU. 

Alternatives for a small include the Goose Bay area which is currently mapped as part of the 

medium that was lost. The Goose Bay area is relatively intact, with the last portion of lowelevation POG in this VCU remaining on Forest Service land. 

VCU 6750 -Sunny Cove

Pre Conveyance: Prior to the 1997 TLMP, the entire Sunny Cove areas was proposed as a

Habitat Conservation Area (HCA). The 1997 TLMP excluded most of the south facing slopes on 

the north side of Sunny Creek. The 1997 TLMP OGR includes high elevation, low volume 

isolated patches of narrow strips of timber. 

In the 1997 TLMP this VCU contained a small OGR. The 2006 IRT changed the 1997 TLMP 

small OGR to a medium OGR and added acres to increase POG. The 2006 IRT proposal 

included most of the largest blocks of contiguous POG, potential goshawk and murrelet nesting 

habitat, important deer winter range and added a corridor that connects this OGR to the OGR in 

VCU 6170. The medium OGR would occur along the shore of VCUs 6160, 6170, 6750 and 

6760. This proposal dropped the 1997 TLMP small OGR in VCU 6750 and added an area north 

of Sunny Cove and along Sunny Creek to connect to OGR in VCU 6760. This medium OGR 

would include acres in VCUs 6160, 6170, 6750 and 6760. This proposal did not include changes 

to the OGR in VCU 6760 but did included changes to the OGR in VCU 6160 and VCU 6170. 
38

The proposed OGR includes HPOG and low elevation on both sides of Sunny Creek and higher 

elevation on south side of Sunny Creek. It also includes the large blocks of POG in this area. 

This option would eliminate the need for a small OGR in VCU 6750. The Polk Timber Sale EIS 

confirmed the value of wildlife habitat in this only unharvested drainage and avoided harvest in 

this area. This proposal does not include high value deer winter range north of Sunny Creek or 

goshawk use areas identified during field work for the timber sale (prey remains). 

The 2006 IRT recommended a review of this OGR especially if the Cholmondeley Timber Sale

is not completed. 

The 2006 IRT changed the small OGR in this VCU (6750) to a medium OGR. Past review 

document assumed OGR acres in VCU 6160 (Monie Lake) was part of the medium OGR. 

The location of the medium was very controversial. 

The 2006 Interagency Team preferred location was not implemented because there is a proposal 

for a timber sale with a supplemental ROD in this area. If the timber sale does not occur, then 

consider implementing the interagency OGR. Management recommended adoption of the 

Cholmondeley Timber Sale NEPA decision and Forest Plan Amendment OGR.

In the 2006 review the Forest Supervisor decided on the 1997 TLMP OGR. It was also 

recommended that potential future LTF/MAF sites be maintained in VCUs 6150 or 6160. 

Post Conveyance: The OGR in this VCU was not directly impacted by the land conveyance. 

2015 Review: The 2015 IRT proposes that the medium OGR in this VCU be reverted back to the 

IOGR for the 2008 Forest Plan (2006 IRT IOGR). The 2015 IRT proposed moving the current 

small OGR from the west side of Sunny Creek to the east side and changing the designation from 

a small OGR to being included as part of the proposed medium (see Figure 6). This proposal 

includes most of the largest blocks of contiguous POG, potential goshawk and murrelet nesting 

habitat, important deer winter range and adds a corridor that connects this OGR to the OGR in 

VCU 6170. The value of this area as an unharvest watershed has been recognized since the Polk 

Timber Sale EIS (1995).

VCU 6760 -Cholmondeley

Pre Conveyance: The 2006 IRT proposed modifying the 1997 TLMP medium OGR by adding

acres to the west to connect to Sunny Point and proposed OGR in VCU 6750. This proposal 

includes most of the largest blocks of contiguous POG, potential goshawk (prey remains were 

found) and murrelet nesting habitat and important deer winter range. 

Post Conveyance: The OGR in this VCU was not directly impacted by the land conveyance. 

2015 IRT: The 2015 IRT proposes that the medium OGR in this VCU be reverted back to the 

IOGR for the 2008 Forest Plan (2006 IRT IOGR) (Figure 6).
39

Medium OGR VCUS 6160, 6170, 6180, 6190, 6200, 6750 and 6760

Figure 6
40

Comparison of Medium OGRs in VCUs 6160, 6170, 6180, 6190, 6750, and 6760 

(Monie Lake and Old Thom Medium OGRs)

Pre-conveyance Postconveyance2015 

Biologically 

Preferred

General VCU Info./Forest Plan Appendix K Criteria

Total land ownership All VCUs (acres) 63,348

Non-NFS land (acres) 4,651 12,842 12,842

NFS land Total (acres) 58,697 50,801 50,801

Min. Req. OGR acres 10,000

Min. Req. POG acres 5,000

Min. Req. High-Volume POG acres 2,500

Old Thom Medium OGR (VCUs 6180/6190)

Total Medium OGR Acres 10,238 4,159 See Below

Total Medium OGR POG Acres 7,184 2,030

Total Medium OGR High-Volume POG Acres 4,293 652

Acreage requirements met? (Total/POG/HPOG) Yes/Yes/Yes No/No/No

Monie Lake Medium OGR (VCUs 6160, 6170, 6760)

Total Medium OGR Acres 15,527 15,527 See below

Total Medium OGR POG Acres 4,223 4,223

Total Medium OGR High-Volume POG Acres 1,429 1,429

Acreage requirements met? (Total/POG/HPOG) Yes/No/No Yes/No/No

New Cholmondeley Medium OGR (VCUs 6170, 6180, 6750, and 6760)

Total Medium OGR Acres See Above See Above 19,060

Total Medium OGR POG Acres 8,387

Total Medium OGR High-Volume POG Acres 4,121

Acreage requirements met? (Total/POG/HPOG) Yes/Yes/Yes

Contributing VCUS

VCU 6160

Total land ownership (acres) 6,207

Non-NFS land (acres) 0 0 0

NFS Land (acres) 6,207 6,207 6,207

Total Medium OGR (acres) 691 691 0

All Non-development LUD in VCU (acres) 1,954 1,954 4,091

Medium OGR POG (acres)2/ 16 16 0

Medium OGR High-volume POG (acres) 0 0 0

All Non-development LUD POG in VCU (acres) 620 620 1,822

All Non-development LUD High-volume POG in VCU (ac) 132 132 473

VCU 6170

Total land ownership (acres) 14,370

Non-NFS land (acres) 0 0 0

NFS Land (acres) 14,370 14,370 14,370

Total Medium OGR (acres) 10,786 10,786 5,721

All Non-development LUD in VCU (acres) 10,927 10,927 11,876

Medium OGR POG (acres)2/ 2,321 2,321 1,809

Medium OGR High-volume POG (acres) 827 827 591

All Non-development LUD POG in VCU (acres) 2,443 2,443 2,802

All Non-development LUD High-volume POG in VCU (ac) 942 942 1,016

VCU 6180

Total land ownership (acres) 18,234

Non-NFS land (acres) 1,075 6,573 6,573

NFS Land (acres) 17,159 11,661 11,661

Total Medium OGR (acres) 8,730 3,703 4,820

All Non-development LUD in VCU (acres) 8,854 3,755 6,068

Medium OGR POG (acres)2/ 6,009 1,715 2,408
41

Comparison of Medium OGRs in VCUs 6160, 6170, 6180, 6190, 6750, and 6760 

(Monie Lake and Old Thom Medium OGRs)

Pre-conveyance Postconveyance2015 

Biologically 

Preferred

Medium OGR High-volume POG (acres) 3,655 610 1,186

All Non-development LUD POG in VCU (acres) 6,033 1,739 2,924

All Non-development LUD High-volume POG in VCU (ac) 3,657 612 1,273

VCU 6190

Total land ownership (acres) 12,071

Non-NFS land (acres) 3,563 5,962 5,962

NFS Land (acres) 8,508 6,109 6,109

Total Medium OGR (acres) 1,543 492 0

All Non-development LUD in VCU (acres) 1,649 497 1,101

Medium OGR POG (acres)2/ 1,176 315 0

Medium OGR High-volume POG (acres) 638 41 0

All Non-development LUD POG in VCU (acres) 1,210 320 647

All Non-development LUD High-volume POG in VCU (ac) 655 44 69

VCU 6750

Total land ownership (acres) 6,887

Non-NFS land (acres) 11 11 11

NFS Land (acres) 6,876 6,876 6,876

Total Medium OGR (acres) 0 0 3,984

All Non-development LUD in VCU (acres) 2,522 2,522 6,024

Medium OGR POG (acres)2/ 0 0 2,187

Medium OGR High-volume POG (acres) 0 0 1,673

All Non-development LUD POG in VCU (acres) 968 968 2,774

All Non-development LUD High-volume POG in VCU (ac) 409 409 1,797

VCU 6760

Total land ownership (acres) 5,579

Non-NFS land (acres) 0 0 0

NFS Land (acres) 5,579 5,579 5,579

Total Medium OGR (acres) 4,014 4,014 4,534

All Non-development LUD in VCU (acres) 4,067 4,067 4,615

Medium OGR POG (acres)2/ 1,886 1,886 1,983

Medium OGR High-volume POG (acres) 601 601 671

All Non-development LUD POG in VCU (acres) 1,925 1,925 2,022

All Non-development LUD High-volume POG in VCU (ac) 614 614 682

Appendix D General Design Criteria and Other Considerations

Old Thom Medium OGR

Appendix D Design Criteria See Below

Circular rather than linear to maximize interior 

habitat/minimize fragmentation effects 

Yes No

Minimizes roads (total road miles) 0.0 0.0

Includes streams (Class I stream miles) 10.7 2.9

Minimizes early seral habitat (acres) 9 9

Includes largest remaining block of POG in VCU? Yes No

Rare/Underrepresented features (large tree POG acres) 3/ 3,229 456

Deep snow deer/marten habitat (acres) 4/ 2,982 123

Goshawk and murrelet nesting habitat (acres) 5/ 4,293 652

Other Considerations

Maintains Connectivity Yes No

Low elevation POG (acres)6/ 4,218 473

Monie Lake Medium OGR

Appendix D Design Criteria See Below
42

Comparison of Medium OGRs in VCUs 6160, 6170, 6180, 6190, 6750, and 6760 

(Monie Lake and Old Thom Medium OGRs)

Pre-conveyance Postconveyance2015 

Biologically 

Preferred

Circular rather than linear to maximize interior 

habitat/minimize fragmentation effects 

No No

Minimizes roads (total road miles) 0.0 0.0

Includes streams (Class I stream miles) 24.6 24.6

Minimizes early seral habitat (acres) 0 0

Includes largest remaining block of POG in VCU? No No

Rare/Underrepresented features (large tree POG acres) 3/ 378 378

Deep snow deer/marten habitat (acres) 4/ 1,196 1,196

Goshawk and murrelet nesting habitat (acres) 5/ 1,429 1,429

Other Considerations

Maintains Connectivity Yes Yes

Low elevation POG (acres)6/ 3,417 3,417

Proposed New Cholmondeley Medium OGR

Appendix D Design Criteria See Above See Above

Circular rather than linear to maximize interior 

habitat/minimize fragmentation effects 

Yes

Minimizes roads (total road miles) 0.7

Includes streams (Class I stream miles) 34.0

Minimizes early seral habitat (acres) 229

Includes largest remaining block of POG in VCU? Yes

Rare/Underrepresented features (large tree POG acres) 3/ 1,884

Deep snow deer/marten habitat (acres) 4/ 2,697

Goshawk and murrelet nesting habitat (acres) 5/ 3,971

Other Considerations

Maintains Connectivity Yes

Low elevation POG (acres)6/ 5,745

1/Medium OGR includes all OG and other Non-Dev LUDs that apply to the VCU to meet Forest Plan Standard and Guidelines for

this reserve. This includes overlap into adjacent VCUs and excludes Non-Dev LUD in the VCU not associated with this reserve.

2/ Should also include 2,500 acres of high-elevation POG

3/ SD67 type

4/ High-volume POG ≤ 800 feet in elevation

5/ High-volume POG all elevations (indicative of optimal goshawk and marbled murrelet nesting habitat due to presence of large 

trees and snags, though both species may use all POG types)

6/ All POG ≤ 800 feet in elevation (representative of low-elevation travel corridors important for many species)
43

Comparison of Small OGR in VCU 6160

Pre-conveyance Postconveyance2015 Biologically 

Preferred

General VCU Info./Forest Plan Appendix K Criteria

Total land all ownership (acres) 6,207

Non-NFS land (acres) 0 0

NFS land Total (acres) 6,207 6,207

16% of NFS land (Min. Req. OGR acres) 992 992

All Non-development LUD in VCU (acres) 1,954 4,091

Small OGR (acres)1/ 1,247 2,558

8% of NFS land (Min. POG Req. acres) 496 496

OGR POG (acres)2/ 597 1,441

All Non-development LUD POG in VCU (acres) 620 2,460

Acreage requirements met? (Total/POG) Yes/Yes Yes/Yes

Small OG LUD Overlap into Adjacent VCU

VCU # NA NA NA

Total OGR Acres

OGR POG Acres

Small OG LUD Overlap from Adjacent VCU

VCU # NA NA NA

Total Acres

POG Acres

Appendix D General Design Criteria

Circular rather than linear to maximize interior 

habitat/minimize fragmentation effects 

No Yes

Minimizes roads (total road miles) 0.0 0.0

Includes streams (Class I stream miles) 5.2 8.0

Minimizes early seral habitat (acres) 0 0

Includes largest remaining block of POG in VCU? No Yes

Rare/Underrepresented features (large tree POG acres) 3/ 38 270

Deep snow deer/marten habitat (acres) 4/ 132 325

Goshawk and murrelet nesting habitat (acres) 5/ 132 379

Other Considerations

Maintains Connectivity Yes Yes

Low elevation POG (acres)6/ 597 1,255

1/Small OGR includes all OG and other Non-Dev LUDs that apply to the VCU to meet Forest Plan Standard and Guidelines for

this reserve. This includes overlap into adjacent VCUs and excludes Non-Dev LUD in the VCU not associated with this reserve.

2/ Should be approximately 50% of OGR acres

3/ SD67 type

4/ High-volume POG ≤ 800 feet in elevation

5/ High-volume POG all elevations (indicative of optimal goshawk and marbled murrelet nesting habitat due to presence of large 

trees and snags, though both species may use all POG types)

6/ All POG ≤ 800 feet in elevation (representative of low-elevation travel corridors important for many species)
44
APPENDIX F

COMPARISON OF DIRECTION

BY ALTERNATIVE
Appendix F

Final EIS F-i Comparison of Direction by Alternative

Appendix F 

Comparison of Direction by Alternative 

CONTENTS

Introduction ................................................................................................................................................ F-1

Young-Growth Direction............................................................................................................................. F-1

Management Approaches for Young Growth......................................................................................... F-1

Management Approaches for Beach and Estuary Fringe...................................................................... F-2

Management Approach for Karst and Cave Resources ........................................................................ F-2

Management Approaches for Recreation and Tourism ......................................................................... F-2

Management Approaches for Riparian .................................................................................................. F-2

Management Approaches for Scenery .................................................................................................. F-3

Management Approaches for Soil and Water........................................................................................ F-3

Management Approaches for Timber .................................................................................................... F-3

Management Approaches for Wildlife.................................................................................................... F-3

Renewable Energy Direction...................................................................................................................... F-4

Management Approach for Renewable Energy..................................................................................... F-4

Transportation System Corridors Direction................................................................................................ F-4

Management Approach for Transportation System Corridors ............................................................... F-4

Forest-Wide Direction ................................................................................................................................ F-4

TABLES

Table F-1. Comparison of Young-Growth Direction by Alternative..........................................................F-5
Appendix F

Final EIS F-1 Comparison of Direction by Alternative

Appendix F

Comparison of Direction by Alternative

Introduction 

Chapter 5 of the Forest Plan contains the proposed direction for Alternative 5 (the Preferred Alternative). 

Direction in Chapter 5 applies to the entire plan area (forest-wide) or to specific LUDs as explained in 

Chapter 3. Management direction includes plan components and management approaches. This 

appendix shows how direction for the other alternatives compares to Alternative 5, whether direction is 

identical, or how it differs. This appendix follows the organization of Chapter 5 and presents the 

comparison in this order: Young Growth, Renewable Energy, Transportation System Corridors, and 

Forest-wide direction.

Young-Growth Direction

Table F-1, located at the end of this appendix, displays the proposed young-growth direction for 

Alternative 5 (the Preferred Alternative), which is the basis for the Forest Plan (see Forest Plan Chapter 

5). The table also shows how direction for the other alternatives compares to Alternative 5, whether 

direction is identical, or how it differs.

Management approaches for young growth for Alternative 5 are presented in the Forest Plan Chapter 5 

and are not repeated here. The following sections present how Alternatives 2 through 5 Management 

Approaches compare to those of Alternative 5. No management approaches would apply to Alternative 1, 

the No Action Alternative.

Management Approaches for Young Growth

Alternative 5: 

See Forest Plan Chapter 5.

Alternative 2-4: 

The intent is that responsible officials engage stakeholders (for example, conservation interests, timber 

operators, permitted user groups, and other interested parties) early and often to best design projects that 

meet ecological, social, and economic interests. Such inclusion would surface and resolve differences, 

and minimize and avoid social, environmental, and natural resource conflicts. At the earliest possible 

time, Interdisciplinary Teams (IDTs) would engage scientific and technical expertise, and knowledge of 

local resources to encourage creative thinking and enhance integration and coordination among 

jurisdictions. 

The intent is that during project planning, IDTs identify other resource opportunities in the project area, 

and integrate these opportunities into the project design. (See definition for Integrated Resource 

Management in Chapter 7.) When designing young-growth projects that would advance old-growth 

characteristics in the beach fringe, riparian management area (RMA), or old-growth reserve (OGR), IDTs

seek out stakeholders to encourage creative and innovative approaches for developing silvicultural 

treatments that imitate the natural scale and distribution of disturbance patterns on the Tongass (e.g., 

wind-thrown timber that creates gaps and patches; landslides that create corridors and gaps; mortality 

that naturally thins stand). The intent is that treatments in RMAs would address stream process group 

objectives. (Consult Appendix D, and Exhibit 2 in the Tongass Young Growth Management Strategy 

[USDA Forest Service 2014d].) 
Appendix F

Comparison of Direction by Alternative F-2 Final EIS

Where appropriate, line officers would use Stewardship Authority (FSH 2409.19, Chapter 60) and other 

authorities to help achieve land management goals while meeting regional and local community needs.

Management Approaches for Beach and Estuary Fringe

Alternative 5: 

See Forest Plan Chapter 5.

Alternative 2: 

The intent is that the IDT assesses the highly productive, sensitive, and valuable fish and wildlife habitat 

found in estuaries to determine how to protect these important resources. Forest Plan Appendix D 

provides guidance for delineating RMAs associated with estuarine stream process group. 

The intent is that the IDT consult and integrate permit holders, local users, and user groups in planning in 

the development of any management activity. 

When even-aged management of young growth occurs in the beach and estuary fringe, the intent is to 

maintain an approximate 1,000-foot-wide protected corridor adjacent and inland of the harvest unit to 

function as an alternate, low elevation, natural habitat corridor.

Alternative 3: 

Same as Alternative 5.

Alternative 4: 

Same as Alternative 5 with the addition of:

To maintain or improve habitat conditions and long-term ecological function, it is expected that the IDT 

would minimize the size of created openings in stands previously treated for wildlife and fish habitat 

purposes.

Management Approach for Karst and Cave Resources

Alternatives 2-4: 

Same as Alternative 5.

Management Approaches for Recreation and Tourism

Alternatives 2-4: 

Same as Alternative 5.

Management Approaches for Riparian

Alternative 2: 

Same as Alternative 5.
Appendix F

Final EIS F-3 Comparison of Direction by Alternative

Alternative 3: 

No management approaches.

Alternative 4: 

To maintain or improve habitat conditions and long-term ecological function, it is expected that the IDT 

would minimize the size of created openings in stands previously treated for wildlife and fish habitat 

purposes.

Management Approaches for Scenery

Alternatives 2-4: 

No management approaches.

Management Approaches for Soil and Water

Alternatives 2-4:

Same as Alternative 5.

Management Approaches for Timber

Alternatives 2-4:

Same as Alternative 5.

Management Approaches for Wildlife

Alternative 2:

It is expected that project IDT and the interagency review team of USDA Forest Service, U.S. Fish and 

Wildlife Service, and Alaska Department of Fish and Game biologists would jointly work to identify young 

growth for harvest within the Old-growth Habitat LUD that can be exchanged for old growth from adjacent 

landscapes, where a net gain of productive old growth habitat in the Old-growth Habitat LUD is possible 

while maintaining and enhancing landscape connectivity. (See Appendix K.) 

Alternative 3:

It is expected that project IDT and the interagency review team of USDA Forest Service, U.S. Fish and 

Wildlife Service, and Alaska Department of Fish and Game biologists would jointly work to identify young 

growth for harvest within the Old-growth Habitat LUD that can be exchanged for old growth from adjacent 

landscapes, where a net gain of productive old growth habitat in the Old-growth Habitat LUD is possible 

while maintaining and enhancing landscape connectivity. (See Appendix K.) 

When implementing young-growth timber harvest projects larger than 20 acres in VCUs that have had 

concentrated past timber harvest, it is intended that 30 percent of the young growth stand acres should 

be left. The purpose is to retain sufficient residual trees to diversify the structural characteristics of the 

stand and provide for future recruitment of snags. The VCUs where this is intended to apply are ones in 
Appendix F

Comparison of Direction by Alternative F-4 Final EIS

which 33 percent or more of the productive old growth has been harvested since 1954. (Consult Forest 

Plan Chapter 4 under Wildlife section (WILD1), IV. Legacy Forest Structure

Alternative 4: 

When implementing young-growth timber harvest projects larger than 20 acres in VCUs that have had 

concentrated past timber harvest, it is intended that 30 percent of the young growth stand acres should 

be left. The purpose is to retain sufficient residual trees to diversify the structural characteristics of the 

stand and provide for future recruitment of snags. The VCUs where this is intended to apply are ones in 

which 33 percent or more of the productive old growth has been harvested since 1954. (Consult Forest 

Plan Chapter 4 under Wildlife section (WILD1), IV. Legacy Forest Structure.) 

To maintain or improve habitat conditions and long-term ecological function, it is expected that the IDT 

would minimize the size of created openings in stands previously treated for wildlife and fish habitat 

purposes.

Renewable Energy Direction

All plan content for Renewable Energy presented in proposed Plan Chapter 5 apply to Alternatives 3 and 

4. They do not apply to Alternative 1, No Action. For Alternative 2, the plan components are identical to 

the preferred alternative except S-RE-SCENE-01. Under Alternative 2, the following standard would be 

applied:

S-RE-SCENE-01: Apply the Low Scenic Integrity Objective (SIO) to renewable energy sites. (Consult 

Forest Plan Chapter 4, Scenery Preparation: SCENE2 section.)

Management Approach for Renewable Energy

The management approaches for Renewable Energy presented in Chapter 5 apply to all action 

alternatives. (They do not apply to Alternative 1, No Action.)

Transportation System Corridors Direction

All plan components for Transportation System Corridors presented in Chapter 5 apply to all action 

alternatives. (They do not apply to Alternative 1, No Action.)

Management Approach for Transportation System Corridors

The management approaches for Transportation System Corridors presented in Chapter 5 apply to all 

action alternatives. (They do not apply to Alternative 1, No Action.)

Forest-Wide Direction

Chapter 5 of the Forest Plan includes Forest-wide plan Desired Conditions (Chapter 2), Multiple-use 

Goals and Objectives (Chapter 2), Standards and Guidelines (Chapter 4). The proposed direction 

presented for Alternative 5 (the Preferred Alternative) applies to all Action Alternatives.
Appendix F

Final EIS F-5 Comparison of Direction by Alternative

Table F-1 displays the proposed Young-Growth direction for Alternative 5 (the Preferred Alternative), for which the Forest Plan has been prepared 

(see Chapter 5). This table also shows how direction for the other alternatives compares to Alternative 5, whether direction is identical, or how it 

differs. The LUDs that a particular plan component would apply to are indicated using the following abbreviations: Old-growth habitat (OGH); 

Remote Recreation (RM); Recreation River (RR); Special Interest Area (SA); Semi-Remote Recreation (SM); Scenic River (SR); Scenic Viewshed 

(SV); Modified Landscape (ML); Timber Production (TM)

Table F-1. 

Comparison of Young-Growth Direction by Alternative

Alternative 5 Alternative 1 Alternative 2 Alternative 3 Alternative 4

Young Growth (YG)

Desired Condition (DC)

DC-YG-01: Young-growth forests 

produce desired resource values, 

products, services and conditions in ways 

that sustain the diversity and productivity 

of ecosystems. Lands suitable for timber 

production produce sawtimber and other 

wood products on an even-flow, long-term 

sustained yield basis; the timber yield 

contributes to the projected timber sale 

quantity (PTSQ).Timber and other 

ecosystem services from young-growth 

forest resources provide economical and 

sustainable opportunities that support 

Southeast Alaska communities. [OGH, 

SV, ML, TM]

Desired Conditions for 

young-growth timber are 

found in Chapter 4 of the 

approved 2008 Forest Plan 

under Timber and in the 

Tongass Young Growth 

Management Strategy 

Exhibit 1-Timber Approach 

(2014).

DC-YG-01 is identical to 

Alternative 5. [OGH, RM, 

RR, SA, SM, SR, SV, ML 

and TM LUDs only]

DC-YG-01 is identical to 

Alternative 5. [OGH, RM, 

RR, SA, SM, SR, SV, ML 

and TM LUDs only]

DC-YG-01 is identical to 

Alternative 5. [SV, ML and 

TM LUDs only]

DC-YG-02: Pre-commercial thinning 

treatment of young-growth timber stands 

approaching, or at, the stem-exclusion 

stage, increase stand growth and vigor 

(e.g., larger trees, small canopy gaps, 

diverse understory).Treatments occur 

where highest productivity, harvest 

operability and access is favorable.

[OGH, SV, ML, TM]

DC-YG-02 is identical to 

Alternative 5. [OGH, RM, 

RR, SA, SM, SR, SV, ML 

and TM LUDs only]

DC-YG-02 is identical to 

Alternative 5. [OGH, RM, 

RR, SA, SM, SR, SV, ML 

and TM LUDs only]

DC-YG-02 is identical to 

Alternative 5. [SV, ML and 

TM LUDs only]

DC-YG-03: Harvesting of young-growth 

stands provides opportunities to improve 

or maintain fish and wildlife habitat by 

accelerating old-growth characteristics. 

[OGH]

DC-YG-03 is identical to 

Alternative 5. [OGH, RM, 

RR, SA, SM, SR, SV, ML 

and TM LUDs only]

DC-YG-03 is identical to 

Alternative 5. [OGH, RM, 

RR, SA, SM, SR, SV, ML 

and TM LUDs only]

DC-YG-03 is identical to 

Alternative 5. [SV, ML and 

TM LUDs only]
Appendix F

Final EIS F-6 Comparison of Direction by Alternative

Table F-1. 

Comparison of Young-Growth Direction by Alternative

Alternative 5 Alternative 1 Alternative 2 Alternative 3 Alternative 4

DC-YG-04: Harvesting of young-growth 

stands in Riparian Management Areas 

(RMAs) and Beach Fringe provides 

opportunities to improve or maintain fish 

and wildlife habitat by accelerating oldgrowth characteristics. [OGH, SV, ML, 

TM]

DC-YG-04 is identical to 

Alternative 5. [OGH, RM, 

RR, SA, SM, SR, SV, ML 

and TM LUDs only]

DC-YG-04: Harvesting of 

young-growth stands in the 

Beach Fringe provides 

opportunities to improve or 

maintain fish and wildlife 

habitat by accelerating oldgrowth characteristics.

[OGH, RM, RR, SA, SM, 

SR, SV, ML and TM LUDs 

only]

DC-YG-04 is identical to 

Alternative 3. [SV, ML and 

TM LUDs only]

DC-YG-05: At the end of the planned 

rotation for young growth, stands are in a 

condition whereby regeneration harvests 

using even-aged, two-aged or unevenaged silvicultural systems are feasible 

and appropriate. [SV, ML, TM]

DC-YG-05 is identical to 

Alternative 5. [RM, RR, SA, 

SM, SR, SV, ML and TM 

LUDs only]

DC-YG-05 is identical to 

Alternative 5. [RM, RR, SA, 

SM, SR, SV, ML and TM 

LUDs only

DC-YG-05 is identical to 

Alternative 5. [SV, ML and 

TM LUDs only]

Suitability of Lands (SUIT)

SUIT-YG-01: Lands within Old-growth 

Habitat, Scenic Viewshed, Modified 

Landscape, and Timber Production LUDs 

are suitable for young-growth timber 

production, unless they do not meet the 

other suitability requirements (See 

Appendix A). Timber management within 

these LUDs is compatible with desired 

conditions for young-growth management.

[OGH, SV, ML, TM]

Suitability of lands for timber 

production are found in 

Appendix A of the current 

2008 Forest Plan.

SUIT-YG-01: Lands within 

Old-growth Habitat, 

Remote Recreation, 

Recreational River, Special 

Interest Area, Semi-remote 

Recreation, Scenic River, 

Scenic Viewshed, Modified 

Landscape, and Timber 

Production LUDs are 

suitable for young-growth 

timber production if they 

meet the other suitability 

requirements in 36 CFR 

219.11. [OGH, RM, RR, 

SA, SM, SR, SV, ML and 

TM LUDs only]

SUIT-YG-01 is identical 

to Alternative 2. [OGH, 

RM, RR, SA, SM, SR, SV, 

ML and TM LUDs only]

SUIT-YG-01: Lands within 

Scenic Viewshed, Modified 

Landscape, and Timber 

Production LUDs are suitable 

for young-growth timber 

production if they meet the 

other suitability requirements 

in 36 CFR 219.11. [SV, ML 

and TM LUDs only]

Objectives (O)

O-YG-01: During the 15 years after plan 

approval, the amount of young-growth 

offered would gradually increase to 

exceed 50 percent of the timber offered 

annually. [OGH, SV, ML, TM]

Objectives for young-growth 

timber are found in Chapter 

4 of the approved 2008 

Forest Plan under Timber 

and in the Tongass Young 

O-YG-01 is identical to 

Alternative 5. [OGH, RM, 

RR, SA, SM, SR, SV, ML 

and TM LUDs only]

O-YG-01 is identical to 

Alternative 5. [OGH, RM, 

RR, SA, SM, SR, SV, ML 

and TM LUDs only]

O-YG-01 is identical to 

Alternative 5. [SV, ML and 

TM LUDs only]
Appendix F

Final EIS F-7 Comparison of Direction by Alternative

Table F-1. 

Comparison of Young-Growth Direction by Alternative

Alternative 5 Alternative 1 Alternative 2 Alternative 3 Alternative 4

O-YG-02: During the 15 years after plan 

approval, offer increasing annual volumes 

of economically viable young-growth 

timber. Old-growth timber harvest would 

gradually be reduced to an average of 5

million board feet (MMBF) annually, to 

support local mills and investments in retooling, depending on markets and 

demand. [OGH, SV, ML, TM]

Growth Management 

Strategy Exhibit 1-Timber 

Approach (2014).

O-YG-02 is identical to 

Alternative 5. [OGH, RM, 

RR, SA, SM, SR, SV, ML 

and TM LUDs only]

O-YG-02 is identical to Altern 

5. [OGH, RM, RR, SA, SM, S 

ML and TM LUDs only]

O-YG-02 is identical to 

Alternative 5. [SV, ML and 

TM LUDs only]

O-YG-03: Annually, pre-commercially thin 

4,000 to 7,000 acres of young-growth 

stands. [OGH, SV, ML, TM]

O-YG-03 is identical to 

Alternative 5. [OGH, RM, 

RR, SA, SM, SR, SV, ML 

and TM LUDs only]

O-YG-03 is identical to 

Alternative 5. [OGH, RM, 

RR, SA, SM, SR, SV, ML 

and TM LUDs only]

O-YG-03 is identical to 

Alternative 5. [SV, ML and 

TM LUDs only]

Goals (G)

GL-YG-01: Provide a stable younggrowth timber supply that sustains longterm timber yields while maintaining or 

improving habitat conditions for wildlife 

and fish at the landscape level (see 

Proposed Forest Plan Appendix B). 

[OGH, SV, ML, TM]

Goals for young-growth 

timber are found in Chapter 

4 of the approved Forest 

Plan under Timber and the 

Tongass Young Growth 

Management Strategy 

Exhibit 1-Timber Approach 

(2014).

GL-YG-01: Provide a 

stable young-growth 

timber supply that sustains 

long-term timber yields 

without impairment of the 

productivity of the land, 

with consideration being 

given to ecological, social, 

and economic factors. See 

Tongass Young Growth 

Management Strategy 

(2014). [OGH, RM, RR, 

SA, SM, SR, SV, ML and 

TM LUDs only]

GL-YG-01 is identical to 

Alternative 2. [OGH, RM, 

RR, SA, SM, SR, SV, ML 

and TM LUDs only]

GL-YG-01 is identical to 

Alternative 2. [SV, ML and 

TM LUDs only]

GL-YG-02: Pre-commercially treat stands 

to reduce or eliminate stem exclusion, to 

decrease stand rotation time, and provide 

future silvicultural opportunities. [OGH, 

SV, ML, TM]

GL-YG-02 is identical to 

Alternative 5. [OGH, RM, 

RR, SA, SM, SR, SV, ML 

and TM LUDs only]

GL-YG-02 is identical to 

Alternative 5. [OGH, RM, 

RR, SA, SM, SR, SV, ML 

and TM LUDs only]

GL-YG-02 is identical to 

Alternative 5. [SV, ML and 

TM LUDs only]

GL-YG-03: Create opportunities in younggrowth management and the use of forest 

products in a manner that enhances the 

economic vitality of the region and the 

resilience of local communities. [OGH, 

SV, ML, TM]

GL-YG-03 is identical to 

Alternative 5. [OGH, RM, 

RR, SA, SM, SR, SV, ML 

and TM LUDs only]

GL-YG-03 is identical to 

Alternative 5. [OGH, RM, 

RR, SA, SM, SR, SV, ML 

and TM LUDs only]

GL-YG-03 is identical to 

Alternative 5. [SV, ML and 

TM LUDs only]
Appendix F

Final EIS F-8 Comparison of Direction by Alternative

Table F-1. 

Comparison of Young-Growth Direction by Alternative

Alternative 5 Alternative 1 Alternative 2 Alternative 3 Alternative 4

GL-YG-04: Harvest of young-growth 

timber supports a variety of mill sizes and 

operators across the forest, including 

small and micro sales that support 

economic opportunities. [OGH, SV, ML, 

TM]

GL-YG-04 is identical to 

Alternative 5. [OGH, RM, 

RR, SA, SM, SR, SV, ML 

and TM LUDs only]

GL-YG-04 is identical to 

Alternative 5. [OGH, RM, 

RR, SA, SM, SR, SV, ML 

and TM LUDs only]

GL-YG-04 is identical to 

Alternative 5. [SV, ML and 

TM LUDs only]

GL-YG-05: Make available a variety of 

potential forest products that support the 

development of an integrated industry 

based primarily upon young-growth 

timber harvest. [OGH, SV, ML, TM]

GL-YG-05 is identical to 

Alternative 5. [OGH, RM, 

RR, SA, SM, SR, SV, ML 

and TM LUDs only]

GL-YG-05 is identical to 

Alternative 5. [OGH, RM, 

RR, SA, SM, SR, SV, ML 

and TM LUDs only]

GL-YG-05 is identical to 

Alternative 5. [SV, ML and 

TM LUDs only]

Standard (S)

S-YG-01: When harvesting trees prior to 

the culmination of mean annual increment 

(CMAI) of growth under the authority 

granted by Public Law 113–291, Sec. 

3002, subsection (e)(4)(A), the limitation 

of subsection (e)(4)(B) shall be applied. 

[OGH, SV, ML, TM]

Standards for young-growth 

timber are found in Chapter 

4 of the approved Forest 

Plan under Timber and the 

Tongass Young Growth 

Management Strategy 

Exhibit 1-Timber Approach 

(2014).

S-YG-01 is identical to 

Alternative 5. [OGH, RM, 

RR, SA, SM, SR, SV, ML 

and TM LUDs only]

S-YG-01 is identical to 

Alternative 5. [OGH, RM, 

RR, SA, SM, SR, SV, ML 

and TM LUDs only]

S-YG-01 is identical to 

Alternative 5. [SV, ML and 

TM LUDs only]

Beach and Estuary Fringe (BEACH)

Desired Condition (DC)

DC-YG-BEACH-01: Active management 

of young-growth stands within the beach 

and estuary fringe supports a range of 

social, economic and ecological needs. 

These areas provide habitat and 

connectivity for wildlife and opportunities 

for accelerating old-growth characteristics

while also providing commercial timber 

byproducts. [OGH, SV, ML, TM]

Desired Condition of the 

beach and estuary fringe are 

found in Chapter 4 of the 

approved 2008 Forest Plan 

under Beach and Estuary 

Fringe.

DC-YG-BEACH-01 is 

identical to Alternative 5.

[OGH, RM, RR, SA, SM, 

SR, SV, ML and TM LUDs 

only]

DC-YG-BEACH-01 is 

identical to Alternative 5. 

[OGH, RM, RR, SA, SM, 

SR, SV, ML and TM LUDs 

only]

DC-YG-BEACH-01 is 

identical to Alternative 5. [SV, 

ML and TM LUDs only]
Appendix F

Final EIS F-9 Comparison of Direction by Alternative

Table F-1. 

Comparison of Young-Growth Direction by Alternative

Alternative 5 Alternative 1 Alternative 2 Alternative 3 Alternative 4

Objectives (O)

O-YG-BEACH-01: Offer about 3,500 

acres of young-growth in the beach and 

estuary fringe to provide commercial 

timber during the 15 years after Plan 

approval. [OGH, SV, ML, TM]

Objectives of the beach and 

estuary fringe are found in 

Chapter 4 of the approved 

2008 Forest Plan under the 

Beach and Estuary Fringe 

section.

O-YG-BEACH-01: Offer 

about 11,300 acres of 

young-growth in the beach 

and estuary fringe to 

provide commercial timber 

during the 15 years after 

Plan approval. [OGH, RM, 

RR, SA, SM, SR, SV, ML 

and TM LUDs only]

O-YG-BEACH-01: Offer 

about 8,000 acres of 

young-growth in the beach 

and estuary fringe to 

provide commercial timber 

during the 15 years after 

Plan approval. [OGH, RM, 

RR, SA, SM, SR, SV, ML 

and TM LUDs only]

O-YG-BEACH-01: Offer 

about 5,500 acres of younggrowth in the beach and 

estuary fringe to provide 

commercial timber during the 

15 years after Plan approval.

[SV, ML and TM LUDs only]

Suitability of Lands (SUIT)

SUIT-YG-BEACH-01: Young growth 

stands within the beach and estuary 

fringe are suitable for timber production; 

timber management within these stands 

is compatible with desired condition DCYG-BEACH-01. See SUIT-YG- 01 and 

Appendix A. [OGH, SV, ML, TM]

Lands within the beach and 

estuary fringe are not 

suitable for timber 

production. See DEIS 

Chapter 2 for Alternative 1 

Suitability.

SUIT-YG-BEACH-01 is 

identical to Alternative 5. 

See SUIT-YG -01 and 

DEIS Chapter 2 for 

Alternative 2 Suitability.

[OGH, RM, RR, SA, SM, 

SR, SV, ML and TM LUDs 

only]

SUIT-YG-BEACH-01 is 

identical to Alternative 5. 

See SUIT-YG- 01 and 

DEIS Chapter 2 for 

Alternative 3 Suitability.

[OGH, RM, RR, SA, SM, 

SR, SV, ML and TM LUDs 

only]

SUIT-YG-BEACH-01 is 

identical to Alternative 5. See 

SUIT-YG- 01 and DEIS 

Chapter 2 for Alternative 4 

Suitability. [SV, ML and TM

LUDs only]

Standards (S)

S-YG-BEACH-01: The maximum size of 

any created opening for commercial 

timber harvest in the beach fringe must 

not exceed 10 acres and a maximum 

removal of up to 35 percent of the acres 

of the original harvested stand is allowed. 

Commercial thinning is limited to 35 

percent of the stand’s basal area. A 

combination of the two treatments may be 

used, with no more than 35 percent of the 

total stand removed in either basal area 

and/or acres. TTRA and other 

administratively withdrawn areas do not 

count towards the stand’s total acreage.

[OGH, SV, ML, TM]

Standards and Guidelines 

for the beach and estuary 

fringe are found in Chapter 4 

of the approved 2008 Forest 

Plan under the Beach and 

Estuary Fringe section.

S-YG-BEACH-01: Even 

aged management is not 

allowed in young-growth 

stands within the beach 

and estuary fringe after 15 

years from plan approval. 

[OGH, RM, RR, SA, SM, 

SR, SV, ML and TM LUDs 

only]

S-YG-BEACH-01: Evenaged management of 

young-growth timber is not 

allowed for commercial 

timber harvest purposes. 

Commercial Thinning is 

allowed. [OGH, RM, RR, 

SA, SM, SR, SV, ML and 

TM LUDs only]

S-YG-BEACH-01 is identical 

to Alternative 3. [SV, ML and 

TM LUDs only]
Appendix F

Final EIS F-10 Comparison of Direction by Alternative

Table F-1. 

Comparison of Young-Growth Direction by Alternative

Alternative 5 Alternative 1 Alternative 2 Alternative 3 Alternative 4

S-YG-BEACH-02: Harvest of commercial 

timber within young-growth stands is 

limited to a one-time only entry and to the 

first 15 years unless best available 

scientific information shows that 

additional entries are: a) warranted, and 

b) meet the LUD objectives. [OGH, SV, 

ML, TM]

S-YG-BEACH-02 does not 

apply. See S-YG-BEACH01 above.

S-YG-BEACH-02 does not 

apply.

S-YG-BEACH-02 does not 

apply.

S-YG-BEACH-03: Commercial harvest 

within beach fringe and estuary is not 

allowed within a minimum 200-foot 

forested buffer beginning at mean high 

tide (that is, a no commercial harvest 

buffer). This does not preclude wildlife 

enhancement projects and providing

access to timber harvest units as long as 

process group objectives can be met in 

the RMA. [OGH, SV, ML, TM]

S-YG-BEACH-03 does not 

apply.

S-YG-BEACH-03 does not 

apply.

S-YG-BEACH-03 does not 

apply.

Facilities (FAC)

Standard (S)

S-YG-FAC-01: Authorize only those 

facilities (recreation and administrative) 

that are compatible with young-growth 

objectives O-YG-01 and O-YG-02. [OGH, 

SV, ML, TM]

Standards and Guidelines 

for facilities are found in 

Chapter 4 of approved 2008 

Forest Plan.

S-YG-FAC-01 is identical to 

Alternative 5

S-YG-FAC-01 is identical to 

Alternative 5

S-YG-FAC-01 is identical to 

Alternative 5

Karst and Cave Resources (KC)

Desired Condition (DC)

DC-YG-KC-01: The karst and cave 

ecosystems (or landscapes) maintain 

natural processes and the productivity, 

while providing for other land uses. [OGH, 

SV, ML, TM]

Desired Conditions for Karst 

and Cave Resources are 

found in Chapter 4, Karst 

and Cave Resources, and 

Appendix H of the approved 

2008 Forest Plan.

DC-YG-KC-01 is identical 

to Alternative 5

DC-YG-KC-01 is identical 

to Alternative 5

DC-YG-KC-01 is identical to 

Alternative 5
Appendix F

Final EIS F-11 Comparison of Direction by Alternative

Table F-1. 

Comparison of Young-Growth Direction by Alternative

Alternative 5 Alternative 1 Alternative 2 Alternative 3 Alternative 4

Standard (S)

S-YG-KC-01: Commercial timber harvest 

is not allowed on lands identified as high 

vulnerability karst lands. (Consult 

Appendix H.) [OGH, SV, ML, TM]

Standards and Guidelines 

for Karst and Cave 

Resources are found in 

Chapter 4, Karst and Cave 

Resources, and Appendix H 

of the approved 2008 Forest 

Plan.

S-YG-KC-01: Commercial 

thinning on high 

vulnerability karst is 

allowed on a case-by-case 

basis. (See young-growth 

management on karst in 

Appendix H) [OGH, RM, 

RR, SA, SM, SR, SV, ML 

and TM LUDs only]

S-YG-KC-01 is identical to 

Alternative 2. [OGH, RM, 

RR, SA, SM, SR, SV, ML 

and TM LUDs only]

S-YG-KC-01 is identical to 

Alternative 2. [SV, ML and 

TM LUDs only]

S-YG-KC-02: On lands identified as 

medium vulnerability karst (see Appendix 

H), patch clearcuts are allowed but may 

not exceed 10 acres with a maximum 

removal of 35 percent of the acres of the 

original harvested stand. [OGH, SV, ML, 

TM]

S-YG-KC-02: Even-age 

management is allowed on 

moderate vulnerability karst 

when karst management 

objectives (Appendix H) 

can be met. [OGH, RM, 

RR, SA, SM, SR, SV, ML 

and TM LUDs only]

S-YG-KC-021 is identical to 

Alternative 2. [OGH, RM, 

RR, SA, SM, SR, SV, ML 

and TM LUDs only]

S-YG-KC-02 is identical to 

Alternative 2. [SV, ML and 

TM LUDs only]

S-YG-KC-03: Even-aged management is 

allowed on lands identified as low 

vulnerability karst lands. (Consult 

Appendix H.) [OGH, SV, ML, TM]

S-YG-KC-03: Even-age 

management is allowed on 

low vulnerability karst when 

karst management 

objectives (Appendix H) 

can be met. [OGH, RM, 

RR, SA, SM, SR, SV, ML 

and TM LUDs only]

S-YG-KC-03 is identical to 

Alternative 2. [OGH, RM, 

RR, SA, SM, SR, SV, ML 

and TM LUDs only]

S-YG-KC-03 is identical to 

Alternative 2. [SV, ML and 

TM LUDs only]

Lands (LAND)

Standard (S)

S-YG-LAND-01: Authorize only those 

uses that are compatible with younggrowth objectives O-YG-01 and O-YG-02.

[OGH, SV, ML, TM]

Standards and Guidelines 

for Lands are found in 

Chapter 4 of the approved 

2008 Forest Plan.

S-YG-LAND-01 is identical 

to Alternative 5. [OGH, RM, 

RR, SA, SM, SR, SV, ML 

and TM LUDs only]

S-YG-LAND-01 is identical 

to Alternative 5. [OGH, RM, 

RR, SA, SM, SR, SV, ML 

and TM LUDs only]

S-YG-LAND-01 is identical to 

Alternative 5. [SV, ML and 

TM LUDs only]

Recreation and Tourism (REC)

Standard (S)

S-YG-REC-01: Authorize only those uses 

that are compatible with young-growth 

objectives O-YG-01 and O-YG-02. [OGH, 

SV, ML, TM]

Standards and Guidelines 

for Recreation and Tourism 

are found in Chapter 4 of the 

approved 2008 Forest Plan.

S-YG-REC-01 is identical 

to Alternative 5. [OGH, RM, 

RR, SA, SM, SR, SV, ML 

and TM LUDs only]

S-YG-REC-01 is identical 

to Alternative 5. [OGH, RM, 

RR, SA, SM, SR, SV, ML 

and TM LUDs only]

S-YG-REC-01 is identical to 

Alternative 5. [SV, ML and

TM LUDs only]
Appendix F

Final EIS F-12 Comparison of Direction by Alternative

Table F-1. 

Comparison of Young-Growth Direction by Alternative

Alternative 5 Alternative 1 Alternative 2 Alternative 3 Alternative 4

Riparian (RIP)

Desired Condition

DC-YG-RIP-01: Active management of 

young-growth stands that are suitable for 

timber production within riparian 

management areas (RMAs) supports a 

range of social, economic and ecological 

needs. These areas are managed to 

accelerate old-growth characteristics in 

order to improve riparian functions for 

soil, water, fish, wildlife and other 

resources (see Appendix D), while also 

providing a commercial timber byproduct. 

[OGH, SV, ML, TM]

Desired Conditions for 

riparian management areas 

are found in Chapter 4, 

Riparian, and Appendix D of 

the approved 2008 Forest 

Plan

DC-YG-RIP-01 is identical 

to Alternative 5. [OGH, RM, 

RR, SA, SM, SR, SV, ML 

and TM LUDs only]

DC-YG-RIP-01 is identical 

to Alternative 1.

DC-YG-RIP-01 is identical to 

Alternative 1.

Suitability of Lands (SUIT)

SUIT-YG-RIP-01: Young-growth stands 

within RMAs (excluding Tongass Timber 

Reform Act buffers) are suitable for timber 

production; timber management within 

these stands is compatible with desired 

condition DC-YG-RIP-01. See SUIT-YG01 and Appendix A for Alternative 5.

[OGH, SV, ML, TM]

Lands within Riparian 

Management Areas are not 

suitable for timber 

production. See DEIS 

Chapter 2 for Alternative 1.

SUIT-YG-RIP-01 is 

identical to Alternative 5. 

See SUIT-YG-TIM-01 and 

DEIS Chapter 2 for 

Alternative 2. [OGH, RM, 

RR, SA, SM, SR, SV, ML 

and TM LUDs only]

Lands within Riparian 

Management Areas are not 

suitable for timber 

production. See DEIS 

Chapter 2 for Alternative 3.

Lands within Riparian 

Management Areas are not 

suitable for timber production. 

See DEIS Chapter 2 for 

Alternative 4.

Objectives (O)

O-YG-RIP-01: During the 15 years after 

plan approval, treat about 900 acres of 

young-growth in RMAs to provide a 

commercial timber byproduct. [OGH, SV, 

ML, TM]

Objectives for riparian 

management areas are 

found in Chapter 4 of the 

approved Forest Plan under 

Riparian (RIP2).

O-YG-RIP-01: During the 

15 years after plan 

approval, treat about 1,600 

acres of young-growth in 

RMAs to provide a 

commercial timber 

byproduct. [OGH, RM, RR, 

SA, SM, SR, SV, ML and 

TM LUDs only]

Identical to Alternative 1. Identical to Alternative 1.
Appendix F

Final EIS F-13 Comparison of Direction by Alternative

Table F-1. 

Comparison of Young-Growth Direction by Alternative

Alternative 5 Alternative 1 Alternative 2 Alternative 3 Alternative 4

Standards (S)

S-YG-RIP-01: The maximum size of any 

created opening for commercial timber 

harvest in the RMA must not exceed 10 

acres and a maximum removal of up to 

35 percent of the acres of the original 

harvested stand is allowed. Commercial 

thinning is limited to 35 percent of the 

stand’s basal area. A combination of the 

two treatments may be used, with no 

more than 35 percent of the total stand 

removed in either basal area and/or 

acres. TTRA and other administratively 

withdrawn areas do not count toward the 

stand’s total acreage. [OGH, SV, ML, TM]

Standards and Guidelines 

for riparian management 

areas are found in Chapter 4 

of the approved 2008 Forest 

Plan under the Riparian 

section.

S-YG-RIP-01: Even-aged 

management is not allowed 

in RMAs. [OGH, RM, RR, 

SA, SM, SR, SV, ML and 

TM LUDs only]

Identical to Alternative 1. Identical to Alternative 1.

S-YG-RIP-02: Harvest of commercial 

timber within young-growth stands is 

limited to a one-time only entry and to the 

first 15 years unless best available 

scientific information shows that 

additional entries are: a) warranted, and 

b) meet the LUD objectives. [OGH, SV, 

ML, TM]

S-YG-RIP-02: Commercial 

thinning is allowed in RMAs 

with a maximum removal of 

33 percent of the stand.

[OGH, RM, RR, SA, SM, 

SR, SV, ML and TM LUDs 

only]

Scenery (SCENE)

Standards (S)

S-YG-SCENE-01: Apply the Very Low 

Scenery Integrity Objectives (SIO) for 

young-growth harvest. (Consult Forest 

Plan Chapter 4, Scenery Preparation: 

SCENE2 section.) For combined younggrowth and old-growth projects within the 

same viewshed, apply the Very Low SIO.

[SV, ML, TM]

Standards and Guidelines

for Scenery are found in 

Chapter 4 of the approved 

2008 Forest Plan under the 

Scenery section.

S-YG-SCENE-01 is 

identical to Alternative 5. 

[OGH, RM, RR, SA, SM, 

SR, SV, ML and TM LUDs 

only]

S-YG-SCENE-01: For 

young-growth harvests 

outside of Timber 

Production LUD, adopted 

Scenery Integrity 

Objectives for Each Land 

Use Designation shall be 

reduced by one level. 

(Consult Chapter 4 of the 

approved 2008 Forest Plan 

under the Scenery section 

There is no change to the 

SIOs for the Timber 

Production LUD. [OGH, 

RM, RR, SA, SM, SR, SV, 

ML and TM LUDs only]

Identical to Alternative 1.
Appendix F

Final EIS F-14 Comparison of Direction by Alternative

Table F-1. 

Comparison of Young-Growth Direction by Alternative

Alternative 5 Alternative 1 Alternative 2 Alternative 3 Alternative 4

Soil and Water (SW)

Desired Conditions (DC)

DC-YG-SW-01: Long-term soil quality 

and site productivity in the suitable land 

base is not impaired and is capable of 

supporting the regeneration, growth and 

successional pathways of naturally 

occurring plant communities. (Consult 

FSM 2554 Supplement No.: R-10 2500-

2006-1.) Soil surface erosion and mass 

wasting from management activities is 

minimized. [OGH, SV, ML, TM]

Desired Conditions for Soil 

and Water are found in 

Chapter 4 of the approved 

2008 Forest Plan under the 

Soil and Water section.

DC-YG-SW-01 is identical 

to Alternative 5. [OGH, RM, 

RR, SA, SM, SR, SV, ML 

and TM LUDs only]

DC-YG-SW-01 is identical 

to Alternative 5. [OGH, RM, 

RR, SA, SM, SR, SV, ML 

and TM LUDs only]

DC-YG-SW-01 is identical to 

Alternative 5. [SV, ML and 

TM LUDs only]

Guidelines (G)

G-YG-SW-01: During timber harvest or 

vegetation treatment operations, dense 

slash and woody debris accumulations 

are not allowed. [OGH, SV, ML, TM]

Standards for Soil and 

Water are found in Chapter 

4 of the approved 2008 

Forest Plan under the Soil 

and Water section.

G-YG-SW-01 is identical to 

Alternative 5. [OGH, RM, 

RR, SA, SM, SR, SV, ML 

and TM LUDs only]

GS-YG-SW-01 is identical 

to Alternative 5. [OGH, RM, 

RR, SA, SM, SR, SV, ML 

and TM LUDs only]

G-YG-SW-01 is identical to 

Alternative 5. [SV, ML and 

TM LUDs only]

G-YG-SW-02: Ground-based yarding 

should avoid creating ruts that are more 

than 12 inches deep. [OGH, SV, ML, TM]

Guidelines for Soil and 

Water are found in Chapter 

4 of the approved 2008 

Forest Plan under the Soil 

and Water section.

G-YG-SW-02 is identical to 

Alternative 5. [OGH, RM, 

RR, SA, SM, SR, SV, ML 

and TM LUDs only]

G-YG-SW-02 is identical to 

Alternative 5. [OGH, RM, 

RR, SA, SM, SR, SV, ML 

and TM LUDs only]

G-YG-SW-02 is identical to 

Alternative 5. [SV, ML and 

TM LUDs only]

Wildlife (WILD)

Desired Conditions (DC)

DC-YG-WILD-01: Active management of 

young-growth stands within the Oldgrowth Habitat LUD supports the 

integrated consideration of social, 

economic and ecological needs of 

regional and local communities. Younggrowth stands within the Old-growth 

Habitat LUD maintain habitat and 

connectivity for wildlife and are managed 

to accelerate development of old-growth 

characteristics while also providing 

commercial timber byproducts. [OGH]

Desired Conditions for 

wildlife management in 

young-growth timber are 

found in Chapter 4 of the 

approved Forest Plan under 

the Wildlife section.

DC-YG-WILD-01: Nondevelopment LUDs, 

maintain habitat and 

connectivity for wildlife at 

the landscape scale while 

also providing commercial 

timber byproducts. [OGH 

LUD only]

DC-YG-WILD-01 is 

identical to Alternative 2. 

[OGH, RM, RR, SA, SM, 

SR, SV, ML and TM LUDs 

only]

Identical to Alternative 1.
Appendix F

Final EIS F-15 Comparison of Direction by Alternative

Table F-1. 

Comparison of Young-Growth Direction by Alternative

Alternative 5 Alternative 1 Alternative 2 Alternative 3 Alternative 4

DC-YG-WILD-02: In the Old-Growth 

Habitat LUD, treated young-growth 

emulates the natural scale and 

distribution of disturbance patterns (for 

example, wind-thrown timber that creates 

gaps and patches; landslides that create 

corridors and gaps; and mortality that 

naturally thins stands). [OGH]

DC-YG-WILD-02 does not 

apply.

DC-YG-WILD-02 does not 

apply.

DC-YG-WILD-02 does not 

apply.

Objective (O)

O-YG-WILD-01: During the 15 years after 

plan approval, treat about 1,800 acres of 

young-growth in the Old-growth Habitat 

LUD to promote the development of oldgrowth characteristics while also 

providing commercial byproducts. [OGH]

Objectives for wildlife 

management in younggrowth timber are found in 

Chapter 4 of the approved 

2008 Forest Plan under the 

Wildlife section 

During the 15 years after 

plan approval, treat about 

3,200 acres of young 

growth in the Old-growth 

Habitat LUD to promote the 

development of old-growth 

characteristics while also 

providing commercial 

byproducts. [OGH LUD 

only]

During the 15 years after 

plan approval, treat about 

2,200 acres of young 

growth in the Old-growth 

Habitat LUD to promote the 

development of old-growth 

characteristics while also 

providing commercial 

byproducts. [OGH LUD 

only]

Identical to Alternative 1.

Standards (S)

S-YG-WILD-01: The maximum size of 

any created opening in the Old-growth 

Habitat LUD must not exceed 10 acres 

and a maximum removal of up to 35 

percent of the acres of the original 

harvested stand is allowed. Commercial 

thinning is limited to 35 percent of the 

stand’s original basal area. A combination 

of the two treatments may be used, with 

no more than 35 percent of the total stand 

removed in either basal area and/or 

acres. TTRA and other administratively 

withdrawn areas do not count towards the 

stand’s total acreage. [OGH]

Standards for wildlife 

management in younggrowth timber are found in 

Chapter 4 of the approved 

2008 Forest Plan under the 

Wildlife section.

S-YG-WILD-01: Allow 

management of young 

growth stands to produce 

commercial wood products 

in all LUDs suitable for 

timber production. [OGH, 

RM, RR, SA, SM, SR, SV, 

ML and TM LUDs only]

S-YG-WILD-01 is identical 

to Alternative 2. [OGH, RM, 

RR, SA, SM, SR, SV, ML 

and TM LUDs only]

Identical to Alternative 1.

S-YG-WILD-02: Commercial younggrowth harvest within the Old-Growth 

Habitat LUD is limited to a one-time only 

entry unless best available scientific 

information shows that additional entries 

are: a) warranted, and b) meet the LUD 

objectives. [OGH]

S-YG-WILD-02 does not 

apply.

S-YG-WILD-02 does not 

apply.

S-YG-WILD-02 does not 

apply.
Appendix F

Final EIS F-16 Comparison of Direction by Alternative

Table F-1. 

Comparison of Young-Growth Direction by Alternative

Alternative 5 Alternative 1 Alternative 2 Alternative 3 Alternative 4

Guideline (G)

G-YG-WILD-01: Road construction 

should be kept to the minimum necessary 

for the removal of young-growth timber 

within the Old-Growth Habitat LUD.

[OGH]

Guidelines for wildlife 

management in younggrowth timber are found in 

Chapter 4 of the approved 

2008 Forest Plan under the 

Wildlife section.

G-YG-WILD-01 is identical 

to Alternative 5. [OGH LUD 

only]

G-YG-WILD-01 is identical 

to Alternative 5. [OGH LUD 

only]

G-YG-WILD-01 does not 

apply.

Land Use Designations: Old-growth habitat (OGH); Remote Recreation (RM); Recreation River (RR); Special Interest Area (SA); Semi-Remote Recreation (SM); 

Scenic River (SR); Scenic Viewshed (SV); Modified Landscape (ML); Timber Production (TM).
APPENDIX G

TIMBER DEMAND AND SUPPLY
Appendix G

Final EIS G-i Timber Demand

Appendix G

Tongass National Forest

Timber Demand and Supply

CONTENTS

Summary................................................................................................................................................... G-1

Introduction ............................................................................................................................................... G-1

Demand Estimation................................................................................................................................... G-3

Using Derived Demand Estimates to Estimate Supply............................................................................. G-6

Development of Timber Sale Requirements to Meet Market Demand ..................................................... G-6

Conclusion ................................................................................................................................................ G-8

Acknowledgements ................................................................................................................................... G-8

Citations .................................................................................................................................................... G-8

LIST OF TABLES

Table G-1 Tongass National Forest Timber Sale Volume to Meet Derived Demand as Reported 

in Daniels et al. (in press)..................................................................................................... G-6
Appendix G

Final EIS G-1 Timber Demand

Appendix G

Tongass National Forest

Timber Demand and Supply

Susan Alexander, Ph.D., Program Manager

US Forest Service, Pacific Northwest Research Station

Nicole Grewe, Ph.D., Regional Economist

US Forest Service, Alaska Region

October 26, 2015

Summary

Since 1990, when the Tongass Timber Reform Act (Public Law 101-626) required the Tongass National 

Forest to take economics into account in planning timber sale programs, multiple demand studies have 

been published by the US Forest Service Pacific Northwest (PNW) Research Station assessing derived 

demand for Alaska forest products. Demand assessment information is incorporated into short-term 

timber sale planning through a supply model and into long-term planning through the Forest Plan 

process. Appendix G supports Forest Plan amendment environmental impact statement (EIS) text, 

provides additional information regarding Daniels et al. (in press) demand estimates, and outlines how 

Daniels et al. (in press) demand projections are incorporated into annual timber sale offer target 

calculations for the Tongass National Forest. 

Introduction

Section 101 of the 1990 Tongass Timber Reform Act (TTRA) states:

Subject to appropriations, other applicable law, and the requirements of the National 

Forest Management Act of 1976 (Public Law 94-588), except as provided in subsection 

(d) of this section, the Secretary shall, to the extent consistent with providing for the 

multiple use and sustained yield of all renewable forest resources, seek to provide a 

supply of timber from the Tongass National Forest which (1) meets the annual market 

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

for each planning cycle.

The 1997 Record of Decision for the Tongass Land and Resource Management Plan revision committed 

the US Forest Service to develop procedures to ensure annual timber sale offerings would be consistent 

with implementing TTRA’s “seek to meet” market demand language. Those procedures were completed 

in 2000 and have become known as the “Morse methodology”, in acknowledgement of the author, and 

are based on the following assumptions: 

• Forest products markets are volatile, especially in the short term. 

• Southeast Alaska timber purchasers have few alternative suppliers if they cannot obtain timber 

from the Tongass National Forest. Oversupplying this market has relatively few adverse 

economic effects; undersupplying it can have much greater negative economic consequences.

• It takes years to prepare national forest timber for sale, including completion of environmental 

impact statements.

• It is difficult to estimate Tongass National Forest timber demand, even a year or two in advance.

• To remain competitive, Alaska’s forest products industry must be able to respond to rapidly 

changing market conditions.
Appendix G

Final EIS G-2 Timber Demand

The Morse methodology establishes a system that strives to build and maintain sufficient volume of 

timber under contract (i.e., timber purchased but not yet harvested – the primary indicator of timber 

inventory available to the industry) 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 Morse 

methodology is self-correcting: if harvest levels drop below expectations, future timber sale offerings will 

also be reduced to levels needed to maintain the target level of volume under contract. Conversely, if 

harvest levels unexpectedly rise, future timber sale targets will also increase to ensure inventory of 

volume under contract is not exhausted. By dealing with uncertainty in a flexible science-based manner, 

the Morse methodology is an example of adaptive management. The US Forest Service intended for the 

Morse methodology to be the means by which the agency complies, year-to-year, with the annual 

demand portion of TTRA’s “seek to meet” requirement. Similarly, the agency intended to comply with the 

requirement to seek to meet demand “for each planning cycle” through a series of annual applications of 

the Morse methodology.

During the past 25 years, the PNW Research Station has published several studies in support of Tongass 

National Forest land management planning that estimate derived demand for Southeast Alaska timber

including Brooks and Haynes (1990, 1994, 1997), Brackley et al. (2006a), and Daniels et al. (in press). 

Procedures developed by Morse (2000) to estimate the timber offer target (supply) incorporate demand 

estimates from PNW studies as a spreadsheet input. PNW derived demand projections are trend 

projections. The Morse methodology relates these derived demand projections into an annual calculation 

of timber sale offer levels.

Procedures developed by Morse (2000) to estimate annual timber sale offering targets from the Tongass 

National Forest address the uncertainty associated with forecasting market conditions, considering the 

continuing transformation of the timber industry and the inability of the US Forest Service to respond 

quickly to market fluctuations due to the time it takes to prepare timber for sale. The basic approach is to 

allow the industry to accumulate an adequate volume under contract (i.e., a measure of inventory), then 

monitor industry behavior and adjust timber program levels to keep pace with harvest activity. Key 

economic indicators and stumpage market conditions are also monitored. Of noteworthy importance, the 

Morse methodology underwent rigorous technical and public review before it was implemented. Since 

the method was initially developed by Morse (2000), inputs to the model have been adjusted to reflect 

new understandings and information including share of raw material provided by the Tongass National 

Forest to local processors, amount of time between timber sale purchase and harvest, and sawmill 

capacity. In this way, the approach has allowed for adaptations to better reflect current conditions. 

An update of the timber demand assessment by Brackley et al. (2006a) was requested from the PNW 

Research Station to inform new efforts to amend the Tongass Land and Resource Management Plan. 

New timber demand projections were also needed to accommodate changes in forest policy regarding 

Tongass National Forest timber harvest, land ownership, shipping policy, and profile of foreign log 

demand. PNW Research Station published new demand projections (Daniels et al. in press), in support 

of forest plan amendment efforts, with three alternative future scenarios. Scenario 1 incorporates the 

young growth transition and resulting changing quality of timber from the Tongass over time. Scenario 2 

builds upon Scenario 1 by adding markets for wood energy products. Scenario 3 is motivated by 

uncertainty surrounding the domestic housing market and assumes a rebound in construction activity by 

only considering the pre-recession rate of growth in domestic lumber. New timber demand projections do 

not require significant change in the basic methodology for timber offer calculations in the procedure 

outlined by Morse (2000). 

During the 1990s, competition with production in other regions and market conditions led to the closure of 

Southeast Alaska’s two pulp mills and numerous other sawmill closures. From 2002 to 2006, the 

Tongass National Forest supplied approximately 65 percent of wood sawn by local sawmills (Kilborn et al. 

2004; Brackley et al. 2006b; sawmill survey data collected by Dan Parrent of US Forest Service and on 

file with the US Forest Service Alaska Region). This percentage has increased in recent years with the 

Tongass National Forest providing an estimated three-quarters (78%) of wood sawn by local sawmills in 

2013; nearly one-quarter (21%) of sawn wood originated from State of Alaska lands. State lands 

comprise a small percentage of Southeast Alaska forest lands and cannot indefinitely supply such a high 
Appendix G

Final EIS G-3 Timber Demand

proportion of timber needed by remaining sawmills. A very small proportion (< 1%) of sawn timber has 

come from private lands in recent years. On average, the ten remaining local sawmills in the study 

operated at approximately 15 percent of their estimated capacity in 2013 (sawmill survey data collected 

by Dan Parrent of US Forest Service and on file with the US Forest Service Alaska Region). 

The primary destination for Southeast Alaska sawn wood is other US states. Brackley and Haynes 

(2008) concluded many of the lumber and wood product markets Alaska sawmills compete in are higherend markets in which foreign and domestic prices have become fairly similar, through market arbitrage. 

Haynes at al. (2007) found that since 1994, the value of US forest product exports has been in gradual 

decline while the value of imports has steadily increased. Hansen (2006) further states US companies 

have historically jumped into the export market when the domestic market is down – and shifted back to 

the US market when the domestic market improves. Haynes et al. (2007) state US demand for forest 

products is varied and large, averaging 71 cubic feet per person per year. Furthermore, per capita 

consumption of wood products in the US has been relatively constant for 50 years. Since the national 

recession (2007 – 2009) and prolonged period of economic recovery, the US market has been slowly 

rebounding with housing starts and forest product prices again on the rise. Global population growth will 

also drive increases in wood products demand both domestically and internationally. 

In 2007, the US Forest Service in Alaska approved a new policy under which timber purchasers may ship 

to Lower 48 states unprocessed certain small-diameter and low-quality logs harvested from the Tongass

National Forest, up to 50 percent of the volume harvested on each sale. This interstate shipment policy 

places purchasers of Tongass National Forest timber in a similar position as their counterparts in the 

Lower 48, where there is no restriction on interstate shipments of timber harvested from National Forest 

System lands. Implementation of this policy has made Alaska forest products producers more 

competitive with their counterparts in the Lower 48 states. Of noteworthy importance, the emergence of 

the Tongass National Forest as an international supplier of softwood logs is a major development since 

the prior demand study (Brackley et al. 2006a) that Daniels et al. (in press) incorporated into new demand 

projections. 

On the supply side, the cost of preparing stumpage for sale and delivering it to sawmills has increased 

due to decreased size of sales, increased fuel costs, legal and procedural challenges to federal timber 

sales, and more constraints on harvest activity in the interest of resource protection. The uncertainty 

surrounding Tongass National Forest sale quantities has increased the risk faced by potential purchasers 

and investors in local processing capacity.

Demand Estimation

The method to project Alaska timber harvest and output followed by Daniels et al. (in press) is essentially 

the same as employed in previous estimates of Alaska timber demand by Brooks and Haynes (1990), 

Brooks and Haynes (1994), Brooks and Haynes (1997), and Brackley et al. (2006a). Derived demand is 

estimated by converting the volume of demand for Alaska forest products in all markets, foreign and 

domestic, to the timber volume required to produce those products. In the model, ratios are used to 

assign a portion of the total global demand to producing regions. Daniels et al. (in press) then estimate

Alaska forest products output, by product, required to meet projected demand and calculate the raw 

material requirements necessary to support this production, using explicit product recovery and 

conversion factors. The total raw material requirement (i.e., total derived demand for timber) is a 

combined projection of timber harvest from private ownership, national forest, and non-national forest 

public owners. Projected national forest timber demand is the quantity of timber required to satisfy 

projected derived demand given harvest by other owners, explicit assumptions about markets, and 

implicit assumptions about prices. The study analyzes past trends over a period of nearly 25 years (1990

to 2013), which forms the basis for a 15-year projection (2015 to 2030) incorporating three key 

parameters:

1. The level of forest product imports in Canada and Pacific Rim nations. Daniels et al. (in 

press) define the Pacific Rim as Japan, Korea, and China. Based on other research 

regarding these markets, Daniels et al. (in press) projects imports of sawn wood products 

and softwood logs will increase over the next 15 years.
Appendix G

Final EIS G-4 Timber Demand

2. The share of Canadian and Pacific Rim markets that will be supplied by US forest 

products producers will remain relatively constant.

3. The share of US exports to Pacific Rim and Canada that will come from Alaska. Daniels 

et al. (in press) examines three alternative assumptions regarding future trends of 

Alaska’s share of US exports to the Pacific Rim and Canada.

Daniels et al. (in press) assembled historic data describing relevant components of the Alaska forest 

products sector and calculated possible future wood needs by analyzing trends that influence harvests. 

They also used assessments of current markets from other analysts. Data from the historic period of 

1990 to 2013 were used as the basis for projecting the future (2015 to 2030) to avoid overemphasizing 

short-term cycles. Trends in imports and consumption (for example, sawn wood in the Pacific Rim) and

production trends represented by shipments (for example, lumber to all destinations) comprise the basic 

structure of the model. Demand for wood products is global in nature and the US is a net importer of 

timber. A sawmill in Alaska has the option to ship products to international export destinations, new 

markets in the Lower 48, or local Alaska purchasers. Price is the primary determinant of where products 

will be shipped. There are many high-value products (e.g., large timbers for architectural designed 

buildings and shop grades of lumber) that are shipped to the Lower 48 from Alaska. The vast majority of 

timber harvested in Alaska, however, is exported as softwood logs to Pacific Rim nations. 

The demand model calculates the quantity of national forest timber needed by sawmills and exporters as 

a residual necessary to balance the model. In other words, Daniels et al. (in press) estimated the 

roundwood equivalent of all material used to produce products from Alaska and subtracted estimated 

future volume harvested from other landowners to derive national forest roundwood needs (i.e., the 

“residual”). Of noteworthy importance, the results in Daniels et al. (in press) reflect standing timber 

volume necessary to meet product demand from federal, state, and private lands. 

Stumpage price projections in PNW Research Station demand studies are linked to price series used and 

projected in Resource Panning Act assessments (i.e., Haynes et al. 2007). Stumpage prices in Alaska 

are estimated as a function of Washington and Oregon prices. Alaska markets directly interact with 

producers and consumers in other US regions through this price relationship. Brackley and Haynes 

(2008) explain that “market arbitrage is used to understand parity among prices in spatially distinct 

markets where there is the opportunity for open exchange (trade). Market arbitrage is a powerful force

that keeps prices of different species, grades, and locations within some fixed proportion to each other. 

Abstracting from transportation and transactions costs, for example, prices of one species and grade will 

not exceed prices for other species of similar grade in the long run because of possibilities of 

substitution.” Tying price in Alaska to price in the Pacific Northwest is how market arbitrage is implicitly 

included in the demand assessment. The mix of products that enter end markets from Alaska are, on 

average, higher quality and more valuable than the average lumber markets in Washington, Oregon, and 

British Columbia (Brackley and Haynes 2008). The type of lumber products in the demand projections 

reflects this higher value by the type of markets they compete in. Although price is not explicit in the 

PNW Research Station demand studies, it is reflected through this mix of generally higher-value products 

that go into various end markets and by the assumption that Alaska price is a function of US price.

Southeast Alaska is one of the last places in western North America that produces products from slowgrown large old trees. Alaska’s old-growth trees, and some younger trees, have special high-quality 

strength and appearance characteristics. Wood products manufactured in Alaska are generally destined 

for high-end markets, such as window casings and door moldings. These markets are arbitraged 

throughout the Pacific Rim, meaning prices for these products are similar regardless of what market it 

enters – domestic or foreign. Brackley and Haynes (2008) illustrate how Alaska producers have shifted in 

and out of domestic markets. Daniels et al. (in press) accounted for this market arbitrage by assuming 

export products would be synonymous with products that could be sold in domestic or foreign markets 

based on price.

Data regarding domestic end markets for sawn wood production from Southeast Alaska have been 

available since about 2000, however, information on domestic end markets can be difficult to verify. A 

major unresolved challenge is determining how much of the product shipped to the Pacific Northwest is 
Appendix G

Final EIS G-5 Timber Demand

ultimately transshipped to another final destination. Transshipments are products that are shipped to 

foreign markets from a different customs district than the one in which they were manufactured. In the 

case of Southeast Alaska, lumber manufactured in Alaska is oftentimes shipped to foreign markets from 

the Seattle customs district, making it difficult to track many of the very recent end markets and 

subsequent demand for manufactured products from Alaska. Trade statistics for softwood log exports 

from Alaska are also confounded by transshipments. Other data used in the Daniels et al. (in press) 

analysis includes harvest of sawlogs and utility logs from all Southeast Alaska ownerships, production of 

lumber and other products from Southeast Alaska sawmills, log and lumber shipments out of Alaska to 

various destinations, Alaska market share of US forest products, and US market share in Canada and 

Pacific Rim nations. 

Daniels et al. (in press) developed a baseline demand model, projecting from 2015 to 2030, to construct 

three scenarios representing alternative futures for timber harvest – all incorporating a transition from 

predominantly old growth to young growth timber harvest. The baseline demand model assumes

projected trends in imports, consumption, and market share will remain constant. Additional assumptions 

include softwood log exports from all owners will continue at current five-year average, “other” production 

will remain constant, markets for utility logs and other low grade material will remain elusive, and the large 

majority of residues are sold. Alternative future scenarios reflect conditions related to changing timber 

quality, growing wood energy markets, and rebounding housing market demand. 

Scenario 1. The first scenario incorporates the young growth transition and resulting 

changing quality of timber from the Tongass National Forest over time. It includes a 

transition period of ten years of tapering levels of old growth harvest as the industry 

adjusts and more young growth becomes available. By 2025, old growth harvest will be 

limited to five million board feet annually for small and micro sales designed to provide 

raw material for small businesses and specialty products. Prior to 2025, scenario one 

reflects the baseline model. 

Scenario 2. The second scenario builds upon the first scenario by adding markets for 

wood energy products. It is US Forest Service policy to support the conversion from 

distillate fuel to wood-based energy in Southeast Alaska’s residential, commercial, and 

industrial sectors. Expanding markets for biomass energy will impact Tongass National 

Forest timber harvest by generating demand for two biomass sources – sawmill residues 

and low- and utility-grade logs. Scenario two includes derived demand estimates as the 

conversion is phased in over time. 

Scenario 3. The third scenario is motivated by uncertainty in the US housing market – a 

traditional driver of global lumber demand. Notably, scenario three assumes a higher 

trajectory for the market by considering only pre-recession (prior to 2007) domestic 

consumption growth rates. During recent years, US sawnwood consumption levels have

grown at levels nearly matching those of the pre-recession housing boom. The third 

scenario is based on the possibility that domestic sawnwood demand growth will continue 

at a pre-recession rate throughout the projection period. 

Daniels et al. (in press) indicate there are several challenges with developing timber demand projections. 

Most notable is the lack of published market data for Alaska forest products. Their analysis was based 

primarily on two data sources – one of which only collects data from a predetermined set of sawmills. 

The second data source is a full census survey of sawmills, but is only completed every five years. 

Furthermore, because Southeast Alaska forest products industry is relatively small, issues related to 

confidentiality and disclosure further hindered data collection and analysis. 
Appendix G

Final EIS G-6 Timber Demand

Using Derived Demand Estimates to Estimate Supply

Determining what demand estimates mean for timber sale offered from the Tongass National Forest 

involves taking the results from Daniels et al. (in press) and using them as input to a supply calculation

that seeks to meet annual market demand from the forest. Derived demand projections in Daniels et al. 

(in press) are one of the inputs to the timber offer calculation developed by Morse (2000). In the

development of the original model (Morse 2000), the derived demand input was total harvest volume, 

over time, from PNW Research Station projections developed by Brooks and Haynes (1997). Timber 

volume in the Daniels et al. (in press) demand projections, including scenarios one, two, and three, 

include export logs, lumber, residue, and “other” forest products (i.e., bowls, furniture, houselogs, 

molding, shakes, posts and poles, and siding). Table G-1 summarizes estimated sale volume 

represented by Daniels et al. (in press) in their projections.

Table G-1

Tongass National Forest Timber Sale Volume to Meet Derived Demand as 

Reported in Daniels et al. (in press)

Year

Projected Tongass National Forest Timber Harvest

(MMBF; includes logs, lumber, residue, and other)

Scenario 1

Young Growth

Transition

Scenario 2*

Wood Energy

Growth

Scenario 3*

Housing Market 

Recovery

2015 40.9 40.9 40.8

2016 41.6 41.6 41.6

2017 42.3 43.4 42.5

2018 43.1 46.3 43.3

2019 43.8 49.2 44.1

2020 44.5 52.1 45.0

2021 45.3 55.1 45.8

2022 46.0 58.0 46.7

2023 46.7 60.9 47.5

2024 47.5 63.8 48.4

2025 44.0 63.0 45.0

2026 44.5 65.7 45.6

2027 45.0 68.4 46.2

2028 45.5 71.0 46.8

2029 45.9 73.7 47.4

2030 46.4 76.4 47.9

* Scenario 2 and Scenario 3 include the transition to predominantly young growth timber harvest (Scenario 1). 

Demand numbers reported by Daniels et al. (in press) are projections of how much wood will be used to 

meet derived demand projections. Timber sales take years to process and can be held for several years 

by the purchaser in anticipation of future needs. Sales must be planned and timber made available in 

advance of projected needs. The derived demand projections do not include increased timber sale

volume in anticipation of increases in wood processing (i.e., increasing use of existing infrastructure, 

construction of new sawmills). Additional timber to supply existing infrastructure operating at higher 

capacity or the construction of new sawmills would need to be sold in preceding years to provide 

sufficient timber supply. 

Demand is an estimate, and translating that demand to on-the-ground sale numbers is also an estimate. 

The derived demand projections developed by Daniels et al. (in press) are used to estimate the market 

demand for the current Tongass National Forest planning cycle. They are also, as noted above, an 

important input to the model (Morse 2000) that the US Forest Service uses to compute the offer target or 

supply of timber from the Tongass National Forest in a given year. That procedure is outlined in the 

following section. 

Development of Timber Sale Requirements to Meet Market Demand

New demand projections in Daniels et al. (in press) required that the spreadsheet model outlined in 

Morse (2000) for estimating timber sale goals be slightly modified to reflect the three alternative future 
Appendix G

Final EIS G-7 Timber Demand

scenarios. Modification of the spreadsheet model allows continued implementation of Forest Service 

Sale Preparation Handbook direction (FSH 2409.18, R-10 Supplement 2409.18-2006-5; Ch. 11.4), which 

states that the procedure outlined in Morse (2000) will be followed in developing short-term offer targets.

The general approach of the timber sale offer model (Morse 2000) is to consider timber requirements of 

the region’s sawmills at different levels of operation and under different assumptions about market 

conditions and technical processing capacity. These assumptions provide a basis for estimating the 

volume of timber likely to be processed by the industry as a whole in any given year. The specific steps 

in the process are outlined below.

Volume of Timber Processed Locally. The first step in the calculations adjusts sawmill capacity estimates 

by the utilization rate assumed for each of the three scenarios, and by the percent of volume expected to 

come from the Tongass National Forest. This provides an estimate of the volume of logs from the 

Tongass National Forest likely to be processed into lumber by sawmills in Southeast Alaska under the 

different scenarios. These figures are then adjusted upward to account for species and grades of timber 

that are not processed into lumber locally. Given this set of assumptions, the timber supply expected to 

be consumed in a given fiscal year is then computed.

Inventory Requirements. The second stage provides an estimate of the volume of uncut timber inventory 

to carry under different demand scenarios. As described on pages 19-20 of Morse (2000), target 

inventory levels depend on the volume expected to be processed each year and the amount of time 

needed to replenish inventory. The relationship is summarized in Morse (2000; equation 2, page 20) and 

by the timber inventory requirements in the model itself. Because the volume of timber expected to be 

processed varies by scenario, timber inventory requirements also vary from one scenario to another.

Harvest Projections. The next step in the process is to incorporate the derived demand estimates 

developed by Daniels et al. (in press), adjusted as shown in Table G-1.

Range of Expected Timber Purchases. By subtracting the volume under contract at the beginning of the 

year from the required inventory, the projected inventory shortfall is calculated. The low range of 

expected timber purchases is replacement for the volume harvested; the high range is the volume 

harvested plus the inventory shortfall so that the inventory requirement is met at the end of the year.

Between fiscal years 1999 and 2008, annual US Department of the Interior and Related Agencies 

Appropriations Acts allocated specific funds to the Tongass National Forest for the purpose of preparing a

reliable timber supply. These “pipeline” funds were in addition to regular agency funding for forest 

management and timber sales. While “pipeline” funding varied by fiscal year, ranging from four to five 

million dollars, the objective remained the same – to establish a three-year timber supply to provide 

industry enough volume to maintain a viable inventory for financial integrity and to respond to market 

changes. While US Congress discontinued “pipeline” funding, the Tongass National Forest still strives to 

maintain a three-year timber supply. 

Three-Year Timber Supply. The annual timber supply needs from the Tongass National Forest is 

considered synonymous with the annual timber consumption (i.e., the amount that is expected to be 

harvested in a given year). To estimate the three-year timber supply, the annual consumption is 

multiplied by three years.

Timber Pipeline. The Tongass National Forest timber pipeline was established as a process to “ramp-up” 

to the three-year supply over a period of years. It takes approximately four years to get a project through 

the analysis and preparation process – to be ready to offer for sale. The additional average annual 

volume needed to meet the three-year timber supply in a given fiscal year is the three-year timber supply 

of timber inventory minus timber inventory requirement, spread evenly over a four-year period.

Total Timber Sale Requirement. By taking the median between the low and high range of the volume 

expected to be purchased, and combining it with the average annual pipeline volume, the total volume 

anticipated for purchase is estimated.

The measure of meeting TTRA’s “seek to meet” requirement while also developing a three-year timber 

supply is volume sold from the Tongass National Forest. To meet these objectives, a sufficient amount of 
Appendix G

Final EIS G-8 Timber Demand

volume must be offered to account for any fall-down between the volume offered and the volume sold. 

The final step in projecting the amount of volume to be purchased is to evaluate the anticipated volume 

that needs to be offered.

Timber Sale Fall-Down. Historically, there has been a difference between volume offered and volume 

sold from national forest timber sales. The reluctance of purchasers to buy timber sales tends to increase 

as markets decrease and/or logging costs increase. Mason et al. (2004) examined why some offerings in 

Southeast Alaska go unsold and concluded that the probability of a timber sale being successfully sold is

tied to downstream markets that are inherently difficult to predict rather than factors directly controlled by 

the US Forest Service.

Projected Offer Objectives. To project the amount of volume that needs to be offered for each of the 

alternative scenarios, the total timber sale projection is increased to account for fall-down and litigation to 

provide a rough estimate of the volume to be offered for each scenario to meet timber sale objectives.

Conclusion

Many challenges have confronted the Southeast Alaska forest products industry over the past two 

decades. Southeast Alaska’s two pulp mills and numerous sawmill facilities have closed. Remaining 

active sawmills operate at about 15 percent of their estimated capacity, on average. During 2013, the 

Tongass National Forest supplied approximately three-quarters of logs for local sawmills followed by onequarter from state land; less than one percent is from private lands. The destination for material sawn in 

Southeast Alaska is now primarily other US states (Kilborn et al. 2004; Brackley et al. 2006b; Backley and 

Crone 2009; Alexander and Parrent 2010, 2012). Demand for Southeast Alaska sawnwood products in 

export markets continues to be relatively low, while exports of softwood logs have remained strong. 

Hansen (2006) states US companies have historically jumped into the export market when the domestic 

market is down, and shifted back to the US market when the domestic market improves. In recent years, 

the US domestic market has been attractive with rising housing starts and forest product prices. 

On the supply side, the cost of preparing stumpage for sale and delivering it to sawmills in Alaska is 

generally higher than in Oregon and Washington, due to transportation and labor costs, decreased timber 

sale size, increased fuel costs, legal and procedural challenges to federal timber sales, and more 

constraints on harvest activity on federal lands in the interest of resource protection. The uncertainty 

surrounding Tongass National Forest sale quantities has increased the risk faced by potential purchasers 

and investors in local processing capacity.

In choosing the timber sale offer level, it is important to anticipate the consequences of decisions. In 

terms of short-term economic consequences, over-supplying the market is less damaging than undersupplying it. If more timber is offered than purchased in a given year, the unsold volume is still available 

for purchasing off-the-shelf or re-offered at a minimal investment. However, a significant shortfall in 

timber supply available for harvest can be financially devastating to the industry.

The purpose of this paper is to identify the extent to which economic analysis contributes to this decisionmaking process. In the final analysis, planning a timber sale program is an exercise in professional 

judgment and needs to consider more than economic factors. Realistic timeframes account for delays in 

timber sale preparation, administrative appeals, and/or litigation with sufficient contingent volume included

in the annual timber sale program. Budget and organizational constraints also limit the extent to which 

the US Forest Service can respond to economic cycles and associated fluctuations in timber demand. 

These are all important considerations in evaluating market demand for timber and setting timber 

offerings.

Acknowledgements

This paper was improved with information provided by multiple staff at the US Forest Service Alaska 

Region, Tongass National Forest, and PNW Research Station.
Appendix G

Final EIS G-9 Timber Demand

Citations

Alexander, S.J.; Parrent, D.J. 2010. Estimating sawmill processing capacity for Tongass timber: 2007 

and 2008 update. Res. Note PNW-RN-565. Portland, OR: U.S. Department of Agriculture, 

Forest Service, Pacific Northwest Research Station. 15 p.

Alexander, S.J.; Parrent, D.J. 2012. Estimating sawmill processing capacity for Tongass timber: 2009 

and 2010 update. Res. Note PNW-RN-568. Portland, OR: U.S. Department of Agriculture, 

Forest Service, Pacific Northwest Research Station. 15 p.

Brackley, A.M.; Crone, L.K. 2009. Estimating sawmill processing capacity for Tongass timber: 2005 and 

2006 update. Res. Note PNW-RN-561. Portland, OR: U.S. Department of Agriculture, Forest 

Service, Pacific Northwest Research Station. 15 p.

Brackley, A.M.; Rojas, T.D.; Haynes, R.W. 2006a. Timber products output and timber harvests in 

Alaska: projections for 2005-25. Gen. Tech. Rep. PNW-GTR-677. Portland, OR: U.S. 

Department of Agriculture, Forest Service, Pacific Northwest Research Station. 33 p.

Brackley, A.M.; Parrent, D.J.; Rojas, T.D. 2006b. Estimating sawmill processing capacity for Tongass 

timber: 2003 and 2004 update. Res. Note. PNW-RN-553. Portland, OR: U.S. Department of 

Agriculture, Forest Service, Pacific Northwest Research Station. 15 p.

Brackley, A.M.; Haynes, R.W. 2008. Timber products output and timber harvests in Alaska: an 

addendum. Res. Note PNW-RN-559. Portland, OR: U.S. Department of Agriculture, Forest 

Service, Pacific Northwest Research Station. 41 p.

Brooks, D.J.; Haynes, R.W. 1990. Timber products output and timber harvests in Alaska: projections for 

1989-2010. Gen. Tech. Rep. PNW-GTR-261. Portland, OR: U.S. Department of Agriculture, 

Forest Service, Pacific Northwest Research Station. 48 p.

Brooks, D.J.; Haynes, R.W. 1994. Timber products output and timber harvests in Alaska: projections for 

1992-2010. Gen. Tech. Rep. PNW-GTR-334. Portland, OR: U.S. Department of Agriculture, 

Forest Service, Pacific Northwest Research Station. 32 p.

Brooks, D.J.; Haynes, R.W. 1997. Timber products output and timber harvests in Alaska: projections for 

1997-2010. Gen. Tech. Rep. PNW-GTR-409. Portland, OR: U.S. Department of Agriculture, 

Forest Service, Pacific Northwest Research Station. 17 p.

Daniels, J; Paruskiewicz, M; Alexander, S. in press. Tongass National Forest Timber Demand, 

Projections for 2015 to 2030. Gen. Tech. Rep. PNW-GTR-xxx. Portland, OR: U.S. Department 

of Agriculture, Forest Service, Pacific Northwest Research Station. xx p. 

Hansen, Eric. 2006. Global forest products markets: impacts on western forests. Western Forester 

51(3): 1-2 and 22.

Haynes, R.W.; Brooks, D.J. 1990. An analysis of the timber situation in Alaska: 1970-2010. Gen. Tech. 

Rep. PNW-GTR-264. Portland, OR: U.S. Department of Agriculture, Forest Service, Pacific 

Northwest Research Station. 33 p.

Haynes, Richard W.; Adams, Darius M.; Alig, Ralph J.; Ince, Peter J.; Mills, John R.; Zhou, Xiaoping. 

2007. The 2005 RPA timber assessment update. Gen. Tech. Rep. PNW-GTR-699. Portland, 

OR: U.S. Department of Agriculture, Forest Service, Pacific Northwest Research Station. 212 p.

Kilborn, K.A.; Parrent, D.J.; Housley, R.D. 2004. Estimating sawmill processing capacity for Tongass 

timber. Res. Note. PNW-RN-545. Portland, OR: U.S. Department of Agriculture, Forest 

Service, Pacific Northwest Research Station. 12 p.

Mason, C.; Margolis, M.; Tsournos, P. 2004. SE Alaska timber: why do some offerings go unsold? 

Northwest Journal of Business and Economics XX(xx): 33-48. 
Appendix G

Final EIS G-10 Timber Demand

Morse, K.S. 2000. Responding to the Market Demand for Tongass Timber: using adaptive management 

to implement Sec. 101 of the 1990 Tongass Timber Reform Act. Manag. Bull. R10-MB-413. 

Juneau, AK: U.S. Department of Agriculture, Forest Service, Alaska Region. 43 p.

van Hess, Willem W.S.. 2003. Forest Resources of Southeast Alaska, 2000: Results of a Single-Phase 

Systematic Sample. Res. Paper PNW-RP-557. Portland, OR: U.S. Department of Agriculture,

Forest Service, Pacific Northwest Res. Station.
APPENDIX H

LIMITED EXPORT POLICY
Appendix H

Final EIS H-1 Alaska Limited Export

Appendix H

Alaska Limited Export

The concerns raised in public comment that log exports reduce the number of local jobs are not new and 

are not unique to the Tongass National Forest. Reviewers claim timber export employs fewer people than 

are required to process wood products domestically, or in this case, in Southeast Alaska. As a result then, 

fewer manufacturing facilities are built to process timber domestically, or within Southeast Alaska. 

Historically, those arguments have been effective in raising public concern and have resulted in 

legislation restricting exports since the 1930s. However, it has been long recognized that special 

circumstances exist in Alaska such that limited export allowance of forest products from the Tongass 

actually works to maintain local industry. Accordingly, the Forest Service allows, but appropriately limits,

the export of unprocessed timber from National Forests in Alaska under general authority of the Organic 

Administration Act,

1 National Forest Management Act (NFMA),2 and 36 Code of Federal Regulations 

(CFR) 223.201.

One of the primary goals of the Tongass National Forest timber program is to contribute to the local and 

regional economies of Southeast Alaska. In keeping with this long-standing goal, current law allows 

timber harvested from federal lands in Alaska to be shipped out of Alaska only if “the supply of timber for 

local use will not be endangered.”3 In 2007, the Forest Service Region 10 approved a Limited Export

Policy in an effort to boost appraised values and provide purchasers economical sale opportunities and 

additional processing options. In this case, such shipments actually increase the utilization of timber 

harvested on the Tongass because it allows local sawmills to make a profit when they purchase timber 

sales, keeping loggers, road construction crews, transporters and sawmill workers employed. These 

goals remain on the Tongass today, and will be especially important as the Tongass National Forest 

accelerates the transition to young-growth harvest. 

Background

For over 100 years, numerous laws, regulations, and policies have imposed varying degrees of export 

restrictions on timber harvested from Alaska federal lands. The common thread and purpose has always 

been to sustain the local timber industry. From the beginning, the 1897 Organic Administration Act

prohibited interstate export of national forest timber.

4 However, in departmental appropriations acts from

1917 to 1926, Congress granted the Secretary of Agriculture the discretionary authority to allow interstate 

exports.5 The 1926 Exportation of Timber Act permanently codified this Secretary’s authority to allow

interstate exports of National Forest System (NFS) timber if, “in the judgment of the [Secretary of 

Agriculture], the supply of timber for local use will not be endangered thereby.”6

 1 Organic Administration Act of 1897 (Organic Act), Act of June 4, 1897, ch. 2, 30 Stat. 11, 34-36 (codified as amended at 16 U.S.C. 

§§ 473-482, 551 (2000)). 2 National Forest Management Act of 1976, 16 U.S.C. §§ 1600, 1611-1614 (2000) (amending Forest and Rangeland Renewable 

Resources Planning Act of 1974, Pub. L No. 93-378, 88 Stat. 476). 3 16 U.S.C. § 616 (1960) (originally enacted in 1926). Further detail on implementing this requirement is provided by regulations 

found at 36 C.F.R. 223.201. 4 Organic Administration Act of June 4, 1897, Ch. 2, 30 Stat. 11, as amended; 16 U.S.C. §§ 473-475, 477-482, 551. The Act of May 

14, 1898 extended the homestead laws to Alaska, and authorized the sale of timber from public lands in Alaska for use only within 

the Territory. 

5 16 U.S.C. § 461 (1960). 6 16 U.S.C. § 616.. Local use, the primary qualifier for future regulating decisions, was later interpreted as “the supply of timber for 

local consumptive use rather than the supply of timber to meet the needs of local mills processing timber for non-local markets as 

well as local markets.” See Brief Summary of General Counsel’s Memorandum of July 10 in Reply to the Questions Submitted by 

Senator Morse of Oregon relative to the Secretary’s Authority to Sell Timber from the National Forests for Export. [Date unknown]. 

Washington, DC: U.S. Department of Agriculture, Office of the General Counsel: 4. This interpretation remains the primary authority 

regarding timber sales from National Forests in Alaska.
Appendix H

Alaska Limited Export H-2 Final EIS

In 1928, the Secretary exercised his discretion and permitted export from all States, except from the 

Territory of Alaska.7 The prohibition on the export of logs from Alaska originated in a 1928 memorandum 

from then Regional Forester W.B. Greeley who sought to promote development of Alaska’s pulp and 

paper industry by requiring primary manufacture of high-grade Sitka spruce and hemlock to bolster the 

value of lower-value material for the pulp and paper mills. The prohibition of raw log exports from Alaska 

did not appear in federal regulations until 1946, where discretionary authority was expressly granted to 

the Chief of the Forest Service to consent to export allowances for certain product considerations.8 Those 

regulations were again modified in 1974 to delegate exclusive approval authority to the Alaska regional 

forester.

9 The regulations, still in effect, recognize Alaska’s unique circumstances by allowing national 

forest lands timber purchasers, who cannot locate a buyer in their market area, to apply for an export 

exemption:10

36 CFR 223.201 Limitations on Unprocessed Timber Harvested in Alaska

Unprocessed timber from [NFS] lands in Alaska may not be exported from the U.S. or 

shipped to other States without prior approval of the Regional Forester. This requirement 

is necessary to ensure the development and continued existence of adequate wood 

processing capacity in Alaska for the sustained utilization of timber from the National 

Forests which are geographically isolated from other processing facilities. In determining 

whether consent will be given for the export of timber, consideration will be given to, 

among other things, whether such export will: a) permit more complete utilization on 

areas being logged primarily for local manufacture; b) prevent loss or serious 

deterioration of logs unsalable locally because of an unforeseen loss of market; c) permit 

the salvage of timber damaged by wind, insects, fire, or other catastrophe; d) bring into 

use a minor species of little importance to local industrial development; or e) provide 

material required to meet urgent and unusual needs of the Nation.

Several other special accommodations recognizing the circumstances in Alaska have been made.

11 For 

example, another disadvantage for Alaska is that the available old-growth is often defective, with over 50 

percent of some harvests unsuitable for sawing and therefore of limited market value. Because the local 

sawmills did not have the capacity to utilize the volume of chips produced from national forest timber, in 

1977 the Forest Service removed the export ban of chips, effectively expanding market opportunity for the 

sale of chips made from those defective logs.12 Similarly, export of salvage materials were expressly 

allowed to boost the local industry during the early 1980’s global recession that depressed timber 

prices.13

Another hurdle for the Alaska timber industry is that no timber sale on the Tongass National Forest may 

be advertised if the appraised value is deficit when using residual value appraisal and red cedar domestic 

processing. This restriction was first imposed by Section 318 of the Consolidated Appropriations 

Resolution, 2003 (Public Law 108-7), with identical language included in subsequent annual 

appropriations acts. 14 In 1969, yellow cedar was declared (by both Secretaries of Agriculture and Interior) 

 7 The Secretary has consistently interpreted 16 U.S.C. § 616 as authorizing the conditioning of export upon primary manufacture 

within the State of Alaska. See also 36 C.F.R. 221.25(g) (1970)). 8 Lane, Christine L. 1998. Log export and import restrictions of the U.S. Pacific Northwest and British Columbia: past and present. 

Gen. Tech. Rep. PNW-GTR-436. Portland, OR: U.S. Department of Agriculture, Forest Service, Pacific Northwest Research Station. 9 36 CFR 223.161 (1974) (current version at 36 CFR 223.201). 

10 36 CFR 223.201. 11 Lane, Christine L. 1998. Log export and import restrictions of the U.S. Pacific Northwest and British Columbia: past and present. 

Gen. Tech. Rep. PNW-GTR-436. Portland, OR: U.S. Department of Agriculture, Forest Service, Pacific Northwest Research 

Station.; i.e., substitution does not apply to Alaska (U.S. Department of Agriculture, Forest Service, Alaska Region. 1987. USDA 

Forest Service Manual; Alaska Region Supplement 275). 12 Lane, Christine L. 1998. Log export and import restrictions of the U.S. Pacific Northwest and British Columbia: past and present. 

Gen. Tech. Rep. PNW-GTR-436. Portland, OR: U.S. Department of Agriculture, Forest Service, Pacific Northwest Research Station. 

Federal Register. 1977. Vol. 42, No. 129. Wednesday, July 6.

13 Lane, Christine L. 1998. Log export and import restrictions of the U.S. Pacific Northwest and British Columbia: past and present. 

Gen. Tech. Rep. PNW-GTR-436. Portland, OR: U.S. Department of Agriculture, Forest Service, Pacific Northwest Research Station. 14 Most recently as part of the Carl Levin and Howard P. 'Buck' McKeon national Defense Authorization Act for Fiscal Year 2015, 

Public law No. 113-291, December 19, 2014, 128 Stat. 3729, section 3720(e)(4).
Appendix H

Final EIS H-3 Alaska Limited Export

surplus to Alaska domestic manufacturing needs and continues to be freely exportable to foreign markets.

Section 318 allowed red cedar to be shipped to the Lower 48 when local domestic markets do not exist.

Because, before 2007, the Alaska Region only approved out-of-state shipments on a case-by-case basis 

after the sale, the appraisals (developed before the sale) assumed that all timber except Alaska yellow 

cedar would be processed in Alaska. The list of export policy changes spanning 100 years is long, but 

the clear focus throughout this time has been on the need to ensure the development and continued 

existence of adequate wood processing capacity for the sustained utilization of timber.

Section 705(a) of the Alaska National Interest Lands Conservation Act (ANILCA), as amended by Section 

101 of the Tongass Timber Reform Act (TTRA), also guides the timber program on the Tongass. TTRA 

provides that the Secretary of Agriculture shall “...seek to provide a supply of timber from the Tongass 

National Forest which (1) meets the annual market demand for timber from such forest and (2) meets the 

market demand for timber from such forest for each planning cycle.” Although all national forests are 

required to estimate demand for timber during forest planning efforts, the “seek to meet” requirement is 

unique to the Tongass National Forest.

Alaska Region Limited Export Policy

In keeping with the regulations cited above, shipment outside Alaska of unprocessed timber from NFS

lands requires prior approval by the regional forester. Historically, such approvals were granted on a 

case-by-case basis at the request of the purchaser after the sale was awarded. The Forest Service began 

analyzing the benefits and potential impacts of easing the export restriction on the Tongass as early as 

1978.15 As timber prices fell dramatically in response to the so-called Great Recession of 2007 to 2009 

and prolonged period of economic recovery, the Forest Service recognized that because Alaska is far 

from most of its markets, it is the first to suffer in a recession and the last to benefit from economic 

recovery.

The wood products market crises made it difficult for the Forest Service to offer timber that would 

appraise positive, yet Section 318 prohibits the Forest Service from offering sales that do not. Timber 

values are lower in Alaska than elsewhere, largely due to higher operating and transportation costs in 

Alaska.16 Even if deficit sales could be offered, doing so would not be economically viable in the long run, 

since the purchasers would most likely lose money on them.

Non-federal lands adjacent to the Tongass National Forest have no log export restrictions so the Tongass 

National Forest has historically been the major supplier of timber to local sawmills. Unless the Tongass 

National Forest can offer a reliable supply of timber with a positive appraisal, the few remaining locallyowned sawmills in Southeast Alaska would find it very difficult to stay in business. Closure of the 

remaining sawmills, even on a temporary basis, would run counter to the objective of supporting local 

economies and wood processing capacity in Southeast Alaska.

Because Southeast sawmills do not have extensive supplies of timber available, even a short-term hiatus 

in offering sales from the Tongass National Forest could result in losses from which the sawmills, the rest 

of the timber industry in Southeast Alaska, and the entire Tongass timber program might never recover. 

Once a sawmill shuts down, re-opening becomes more difficult over time, as skilled employees find other 

jobs, equipment becomes obsolete or is sold, and capital becomes more difficult to obtain. Cessation of 

the program and the related private-sector activities would have very noticeable adverse consequences in 

several local economies across Southeast Alaska.

 15 Darr, David R. 1978. Potential Impact of Easing the Log Export Restriction on the Tongass National Forest. USDA Forest Service 

Resource Bulletin PNW-77. Portland, OR: U.S. Department of Agriculture, Forest Service, Pacific Northwest Forest and Range 

Experiment Station, available at http://www.fs.fed.us/pnw/pubs/pnw_rb077.pdf (citing the 1969 recommendation of the Public Land 

Law Review Commission to ease the export restriction to allow higher stumpage revenues). 16 Alaska Dept. of Labor. Alaska Economic Trends, at 11 (Dec. 2003), available at http://labor.alaska.gov/trends/dec03.pdf.
Appendix H

Alaska Limited Export H-4 Final EIS

The Forest Service recognized appraisals of proposed Tongass timber sales would rise if they assumed 

that a portion of the unprocessed Sitka spruce and hemlock logs were to be shipped to lower 48 markets,

such that timber sale appraisals would reflect beneficial pricing in markets outside of Alaska. That 

assumption would be possible if shipments were approved prior to the sales being appraised, instead of 

authorizing shipments only after the timber is sold. Allowing routine interstate shipment of a portion of 

unprocessed Sitka spruce and hemlock logs from Alaska provides Alaska operators the opportunity to 

capture some of the economic efficiency available from the vertical integration (i.e. consolidation) that 

exists in the lower 48. This approach would also lower some of the operating and transportation costs that 

are deducted from selling prices in the appraisal calculations. Between the higher prices and lower costs, 

limited interstate shipments significantly increase the likelihood that timber sales in parts of the Tongass 

would have a positive appraisal under poor market conditions. Such shipments would also increase the 

utilization of timber harvested on the Tongass.

Consequently, the Forest Service analyzed seven limited export scenarios it designed to establish a

programmatic approach that would best meet the following objectives:

1. Ensure that economic timber sales can continue to be offered from the Tongass National Forest.

2. Ensure the continuation of wood processing capacity in Alaska.

3. Minimize the amount of unprocessed logs being shipped outside of Alaska.

4. Maximize employment in the United States from timber harvest activities conducted on the Tongass.

It is important to recognize that, to some degree, these are competing objectives. For example, if the first 

objective were all that mattered, positive appraisals could be achieved by allowing all logs to be shipped 

out-of-state without any in-state processing. That approach would result in positive appraisals under most 

market conditions in most areas of the Tongass, so timber could continue to be offered for sale. It would 

not, however, support continuation of Alaska’s wood processing capacity or minimize the shipment of 

unprocessed logs out-of-state Likewise, if the third objective were all that mattered, it could be 

accomplished by not allowing any shipment of unprocessed logs outside of Alaska. As described above, 

however, that approach would soon prevent many Tongass sales from being offered, which would 

endanger the continuation of wood processing capability rather than ensure it. Without a reliable supply of 

timber from the Tongass, the remaining locally-owned sawmills would probably be forced to close.

Consistent with the results of that analysis, in 2007 the Alaska regional forester adopted the Limited 

Export Policy, intended to boost appraised timber values, provide economic sale opportunities for 

purchasers, and provide additional processing options for purchasers. The policy modified how timber 

sales were appraised and allowed timber purchasers options on shipping certain small diameter logs from 

national forest timber sales to the Lower 48 states. Designed to allow flexibility for timber purchasers, the 

Limited Export Policy was not, nor is today, something mandated by the Forest Service on a timber 

purchaser or automatically or immediately applied to all timber sales. Rather, the policy is applied by 

request of the timber purchaser after the contract offering is awarded or any time thereafter.

The Limited Export Policy established a programmatic limited approval for export so that total shipments 

of unprocessed logs outside of Alaska were limited to no more than 50 percent of the total volume of all 

species harvested on each sale. This included shipments of western red cedar to the Lower 48 and 

exports of Alaska yellow cedar to foreign markets. Requests to ship more than 50 percent of the total 

volume of a sale out of Alaska continued to be considered on a case-by-case basis.

Restrictions on the out-of-state shipment of unprocessed logs were put in place, among other things, to 

ensure the continuation of wood processing capability in Alaska. The programmatic limited approval of 

interstate shipments achieved that result by increasing the Forest Service’s ability to design sales with 

greater utilization and a positive appraisal.
Appendix H

Final EIS H-5 Alaska Limited Export

In recognizing that the Limited Export Policy is intended to support local manufacturing in down markets, 

the Limited Export Policy is reviewed on an annual basis to determine whether it should be adjusted or 

discontinued. Since 2007, the policy has continued, with modifications, which have provided additional 

options for purchasers while maintaining goals established by the Agency. Although improvements to 

markets have occurred since 2007, challenges continue for purchasers seeking domestic markets for 

Alaska timber. 

After a year of implementation, it became clear that the interstate shipment of unprocessed Sitka spruce 

and hemlock did not offset costs for fuel, barging/shipping, insurance, and manufacturing being 

experienced by Southeast Alaska’s timber industry. A corresponding decline in orders and values for 

wood chips in the Lower 48 states, coupled with 12 consecutive quarters of decline in the softwood 

lumber indices, threatened the viability of the timber industry, and dependent Southeast Alaska 

communities. Thus, in 2008 the regional forester responded to industry request by expanding the scope 

of the policy to also allow foreign export in 2008 for existing contracts if a premium was paid for certain 

species. The policy was again expanded in November 2009 to apply to all contracts and allowed export of 

unprocessed Sitka spruce and hemlock logs, up to 50 percent of the total sale sawtimber volume, to be 

shipped to the most advantageous markets. At that time, a foreign market appraisal was established for 

use on timber sales to reflect export values for Sitka spruce and hemlock.

In 2011, the policy was expanded to consider applications on settlement sales. Beginning in 2012, in a 

continuing effort to encourage and support domestic processing, the regional forester agreed to begin 

reviewing requests to allow increased export of Western hemlock and Sitka spruce from sales where an 

approved export permit was already in place. This increase in export has been approved on a case-bycase basis, in exchange for purchasers providing an equivalent amount of Alaska Yellow Cedar to small 

business operators who would process the timber locally. In 2014, the regional forester approved a rebate 

for young-growth Sitka spruce when timber had been appraised for export, but primary manufacture 

occurs in Alaska. 

The regional forester noted in the 2015 review that, while improvements occurred nationally over the past 

three years, challenges continue for purchasers seeking domestic markets for Alaska timber. As a result 

of this review, the Limited Export Policy remained in place for calendar year 2015. The current residual 

value appraisal allows a higher percentage of volume to be appraised for domestic processing, when 

indicated advertised values are very positive for a planned sale offering. Domestic processing is 

encouraged when a perceived opportunity exists. For example, sales with greater quantities of large 

diameter hemlock and Sitka spruce volume may be profitable for processing locally (i.e., > 20 inches for 

hemlock and > 18 inches for Sitka spruce). Hemlock and Sitka spruce volume approved for export that 

has not been appraised using the residual value appraisal have a premium fee requirement of $40/MBF 

for shipment of these species out of Alaska. The regional forester also continues to encourage and 

support domestic processing by considering requests on a case-by-case basis, to allow increased export 

in exchange for equivalent volume supplied directly to small local operators who would process the timber 

locally.

The Limited Export Policy was developed under existing authority, which up until 2007 had been 

exercised only on a case-by-case basis; the only difference is to grant such limited authority for interstate 

shipments of unprocessed Sitka spruce and hemlock logs on a programmatic basis applicable to all sales 

across the Tongass. The Forest Service undertook notice and comment rulemaking in adopting 

regulations allowing the limited export of forest products in Alaska, as well as in granting this authority to 

the Alaska regional forester. The Limited Export Policy represents the exercise of the regional forester’s 

express authority to provide “prior approval” for limited export allowances consistent with the regulation. 

The establishment of a programmatic policy was needed to ensure the continued existence of adequate 

wood processing capacity in Alaska. The policy also permits more complete utilization of small diameter 

and low grade logs which cannot be profitably processed in Alaska. By limiting export of unprocessed 

Sitka spruce and hemlock logs to no more than 50 percent of the total sale sawtimber volume, the policy
Appendix H

Alaska Limited Export H-6 Final EIS

ensures that the Tongass timber program will continue to be operated primarily for local manufacture. The 

2007 Limited Export Policy is reviewed on an annual basis and adjustments have been made reflecting 

the current needs of the industry based on that review. As the young-growth transition proceeds, 

additional policy changes may become necessary to align with market developments.

Effects Analysis

The authorization for limited interstate shipments of unprocessed Sitka spruce and hemlock logs may 

increase the amount of harvest on the Tongass above the amount that could occur without it. This is the 

case because with the positive appraisal requirement, many sales would not be offered if not appraised 

for export. However, in order to ensure that timber sale offerings are consistent the agency’s obligations 

under TTRA, timber sales must be offered so long as there is a demand for Tongass timber. The Limited 

Export Policy provides flexibility for the region to balance the economics of timber sales to meet both of

those statutory requirements. 

While it may be the case that more timber is cut than without the policy because sales would not appraise 

positive and could not be offered, this does not increase the amount of timber harvested beyond that 

analyzed and disclosed pursuant to the National Environmental Policy Act (NEPA), NFMA, and the 

Administrative Procedures Act. The policy itself has no environmental effects—implementation of the 

policy involves further Forest Service action, which is subject to NEPA analysis, including public notice 

and opportunity for comment. 

NEPA analysis of the effects of the Limited Export Policy has been conducted at both at the 

programmatic and site-specific levels since its adoption. While analysis at the forest plan level assists the 

agency in selecting among management alternatives, the forest plan itself also does not authorize the 

harvest of timber without further, site-specific NEPA review. Project-level NEPA analyses evaluate the 

effects of timber sales in light of the policy including potential effects on in-state employment and the 

financial efficiency of project alternatives. Project-level NEPA documents also describe how each specific 

timber sale meets the TTRA requirement to seek to meet market demand for Tongass timber while also 

providing for the multiple use and sustained yield management of the Forest’s renewable resources.

When it was adopted, the Limited Export Policy was also applied to projects already approved but not yet 

fully implemented. In each of those cases, an evaluation was completed to determine whether limited 

interstate shipments of unprocessed timber would meaningfully change the environmental effects of the 

project in a manner that was relevant to issues that were factors in the NEPA analysis and decision. Such 

determinations were and continue to be rare, because the environmental effects of timber harvest 

activities do not materially change as a function of where the timber is processed.

Timber sales are sold to purchasers with different business goals and ever-changing markets. Historically, 

the percentage of the volume harvested on the Tongass that has been shipped out-of-state has fluctuated 

so it is not possible to precisely predict what will be manufactured locally. Therefore, a range of 

employment and income figures is considered the most reasonable approach to display potential effects

of the policy on jobs and income. Most of the purchasers, since they are trying to make a profit, want to 

optimize the value of their products and use export as a means to do this. At the present time, some of 

the volume from larger sales is shipped out of state to optimize the return to the purchaser. Information on 

the amount of volume exported from 2001 to 2015 is located on the Tongass website 

(http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprd3845620.xlsx) and shows an annual range of 

2.7 MMBF to 19.5 MMBF. The highest volume reflects a 2005 salvage sale from the Yakutat Ranger 

District, the value of which the Forest Service wanted to ensure was captured before the wood decayed.

On average, export represented only 28.2 percent of what was harvested during that period. Thus, an 

average of 71.8 percent of the timber harvested on the Tongass National Forest over the last 15 years 

received primary manufacture in Alaska sawmills.
Appendix H

Final EIS H-7 Alaska Limited Export

Estimated employment is analyzed and presented as a range based on the existing Limited Export Policy. 

Direct employment and income estimates are presented as a range in the 2016 Forest Plan Amendment 

Final Environmental Impact Statement (FEIS) in Table 3.22-19. These estimates are for employment that 

would take place in Southeast Alaska. Although estimates of value for timber in the various alternatives 

are based on maximizing shipments of timber sold out of state (Table 3.22-17), purchasers have the 

choice to sell as much as they can to other markets as allowed under the Limited Export Policy, or 

process part or all of the material in local sawmills. Actual employment and income in Southeast Alaska 

would depend on choices made by purchasers; those choices may change as markets and prices shift. 

Under current market conditions, purchasers are likely to export as much as they can while processing 

enough material locally to keep manufacturing facilities open, and take advantage of opportunities to 

produce high-value sawn material in Southeast Alaska.

Transportation and other services include water transportation, independent trucking, stevedoring, 

scaling, and export marking and sort yard employment for export volume, and water transportation, 

scaling, and independent trucking for locally-sawn volume. Export employs more workers in 

transportation and other services per MMBF harvested than domestic production. This is reflected in the 

range of values presented in the FEIS.

When the Limited Export Policy was adopted in 2007, the Forest Service utilized the NEPA Economic 

Analysis Tool-RV (NEAT-R) model to analyze the policy potential effects on employment to aid the 

agency in selecting among various alternatives in its NEPA analysis. NEATR calculated jobs in two 

categories: logging and sawmill. Following adoption of the policy, sawmill jobs were presented as a 

range, representing 50 to 100 percent domestic processing. The job calculation for 50 percent export

assumed a 50 percent reduction in sawmill jobs, but did not consider that export supported transportationrelated, as well as logging jobs. In March 2011, the Forest Service implemented a new model, known as

the Financial Analysis Spreadsheet Tool-RV (FASTR), which addressed this shortcoming by estimating 

jobs in four categories: logging, sawmill, transportation related to domestic manufacturing, and 

transportation related to export. The model estimates jobs and associated income by utilizing annual 

trend-based employment information collected by the agency from 2007 to 2010. These annual sawmill 

surveys continue to inform the employment coefficients assigned to job categories in the FASTR model. 

As described in the Plan Amendment FEIS, the analysis presents a range for annualized sawmill jobs 

which reflects the range of export options that may be available to a timber sale purchaser. The 

employment and income analysis in the FEIS assumed a range from maximum possible shipment out of 

state (export of all Alaska yellow cedar plus hemlock and Sitka spruce export equal to 50 percent of total 

sale net sawlog volume), to no shipment of hemlock and Sitka spruce and export of 100 percent of Alaska 

yellow cedar (see Table 3.22-19 in the FEIS). It may overestimate the low range since the volume that 

can be shipped is limited to certain species and grades unless exemptions are approved by the current 

export policies. The analysis in the FEIS also presents employment and income estimates for this range.

The assumptions used with respect to the Limited Export Policy for the financial, employment, and 

income analyses are appropriate for programmatic analysis. Additional analyses will be conducted as part 

of the project-specific environmental analysis that will be prepared as part of future timber sale projects, 

as done since the Limited Export Policy was adopted. These analyses take into account the Limited 

Export Policy as well as any other potential restrictions on export or production in place at that time.

While the current policy allows case-by-case consideration for export in quantities beyond that which is 

programmatically approved by the regional forester, for the purposes of the programmatic analysis, it is 

reasonable to evaluate the upper limit as prescribed by the current version of the Limited Export Policy. If 

purchasers were allowed on a case-by-case basis to export a larger share of a particular sale in 

unprocessed form, there would be a commensurate reduction in sawmilling jobs and an increase in 

transportation-related jobs. This is explained in the Plan Amendment FEIS. In such cases, the agency 

undertakes analysis to determine the significance of the change. 
Appendix H

Alaska Limited Export H-8 Final EIS

The information presented in the Plan Amendment DEIS reflects the current industry and recent trends 

that are operating in Southeast Alaska. It is not intended to illustrate the full extent of the reduction in 

wood products employment that has occurred since it peaked at 3,543 jobs in 1990. At that time, there 

were two 50-year contracts that guaranteed a steady supply of timber. These long-term contracts 

involved supplying two pulp mills, which required a large workforce both to supply and operate the mills. A 

more complete explanation of the timber industry since 1990 is in the 2008 Forest Plan Amendment 

FEIS, p. 3-499 to 3-511.

Looking Forward

In 2010, the US Department of Agriculture announced a “Transition Framework” Policy aimed at 

diversifying the Southeast Alaska economy and shifting the timber industry to young-growth harvest and 

management. In 2013, Secretary Vilsack announced the Department’s goal “to effectuate this transition 

over the next 10 to 15 years, so that at the end of this period the vast majority of timber sold by the 

Tongass will be young-growth.” Since that time, the US Forest Service, USDA Rural Development, local

businesses, conservation groups, and others have been evaluating how the region can develop a locallybased, properly-scaled young-growth industry that provides greater economic security for local

communities, builds regional knowledge and skillsets, and restores critical forest habitat in the Tongass.

The agency has the authority to amend the forest plan to accelerate the transition to young-growth, which 

is one step in addressing sustainable forestry in Southeast Alaska. Additional steps in the Tongass 

Advisory Committee’s (TAC) detailed transition implementation recommendations provide guidance on 

elements for success in implementing the transition, and identify opportunities by which the agency, 

stakeholders, and greater community will share ownership of the transition strategy and embrace its 

successful implementation. The work done by the TAC offers the possibility of a regionally focused, 

collaborative path toward an innovative opportunity for a viable young-growth timber industry while 

honoring the suite of economic, ecological, social, and cultural values inherent in the forest. The TAC 

provided detailed recommendations for targeted investment, financial assistance, and financing 

mechanisms for stand inventory, research, infrastructure, and retooling. These investments are intended 

to help communities and businesses successfully transition to, and thrive within, a new young-growth 

economy.

A recent report by Government Accountability Office (http://gao.gov/products/GAO-16-456) outlines 

additional steps taken or planned by the Forest Service, including comparing potential market prices for 

young-growth timber or products to the cost to harvest, transport, and process the timber; refining of 

young-growth timber data; lengthening the duration of small sale contracts to provide small sawmill 

owners with flexibility; and expanding collaborative projects to support job creation through sustainable 

forest management and improve predictability of timber supply.

It is important to retain the expertise and infrastructure of the existing industry to allow businesses the 

opportunity to quickly retool. These businesses are fundamental to both the young-growth and restoration 

components of the future timber program, and to the economic vitality of the region. The Forest Service 

will continue to offer a supply of old-growth while increasing the supply of young-growth to provide the 

industry the opportunity to develop new markets, learn new skills, and acquire new equipment. This will 

include offering old-growth timber sales like the Big Thorne timber sale to provide “bridge timber, as well 

as continuation of the micro-sale programs and old-growth small sale program which target niche 

markets. In addition, young-growth timber sales may include old-growth to help boost appraisal values of 

young-growth sales until a reliable supply of economically viable young-growth may be established. It has 

been acknowledged since 2000, that the transition to young-growth in Southeast Alaska would be 

shortened and more abrupt because less unmanaged second growth, which has characteristics 
Appendix H

Final EIS H-9 Alaska Limited Export

intermediate between old-growth and young-growth, is available to ease the transition.17 This is why 

bridge timber is a critical factor to maintain a viable industry while the transition takes place. 

Successfully transitioning the Tongass timber sale program from one based on old-growth to younggrowth is dependent on a range of economic, social, and ecological factors, not all of which are under 

Forest Service control. Since the closure of the pulp mills, there is no local market for lower-grade 

materials that historically supplied the mills. Without the opportunity to export these products, utility and 

lower grade materials would be left in the woods. Allowing export of these materials which have no local 

market allows for more complete utilization of Tongass National Forest resources. Similarly, in the early 

years of the transition it may be the case that there is a very limited local market for young-growth logs. In

order to keep local operators in business, young-growth timber sale purchasers will have the option to 

export those logs which cannot be locally utilized, consistent with the Limited Export Policy. As the Forest 

Service builds the capability to provide a reliable supply of economically viable young-growth timber, local 

processing capability is expected to develop to utilize the material that has formerly been left in the woods 

or is currently being largely exported.

The agency’s long-range goal to ensure that Tongass timber is available primarily for local and domestic 

processing is a priority, in order to create more local economic benefits. Therefore, a glide path of 

increasing supply of young-growth gradually over time makes sense. Alternatively, young-growth might 

be entirely exported, a scenario that may not result in the same amount of local economic and community 

benefits. However, consistent with existing authority to allow export of forest products from public lands, 

export allowances may not endanger the supply of timber for local use. As shelf volume for young-growth

becomes available as the young-growth ages and the economics and market demand become more 

favorable, industry can re-tool. As the local demand for young-growth grows, the export of unprocessed 

young-growth logs should taper down so as to provide a supply of Tongass timber for local use. The 

transition is not expected to “generate jobs” but rather support existing jobs. Once the timber supply 

reaches a long-term stability above the needs of the current operators, other timber industry operators 

may move into Southeast Alaska. Currently, those purchasers that have been interested are discouraged 

by the lack of a stable timber supply.

The 2016 forest plan amendment FEIS was designed to analyze the feasibility of shifting from an oldgrowth forest management regime towards young-growth management on an accelerated timeline, so 

that within 10 to 15 years the vast majority of timber sales on the forest will be from young-growth forests.

How rapidly and effectively this is accomplished depends on local support from Alaska markets for younggrowth forest products. The ability to export some timber beyond Alaska may serve as a strategic option 

that can be used to help maintain workforce skills, industry expertise, and the physical infrastructure 

needed to develop a future young-growth industry. The Limited Export Policy will continue to be subject to 

review and modification on an annual basis, as noted above.

Although the Tongass young-growth resource is several years away from being able to support a regionwide industry, local harvesters, processors, builders and others are already building the skills, knowledge, 

infrastructure and demand needed to capture emerging opportunities. Still, transitioning to a younggrowth timber program is dependent on many factors outside the Forest Service’s control, including 

timber markets, industry changes, uncertainty in future supply, and litigation among others. Yet it is 

important to consider the different factors that could influence the duration and trajectory of switching to 

young-growth, such as changes in policy, the role of state and private timber lands and public-private 

partnerships. Given the high cost of operating in Alaska, it is important that this transition be planned in a 

way that allows wood processors a maximum of options, including current limited export options provided 

by the Limited Export Policy. 

 17 Duncan, Sally, based on science by Eini Lowell, Glenn Christensen, and Jim Stevens. Facing the Challenge of the Young, the 

Small, and the Dead: Alaska’s New Frontier. USDA Forest Service Pacific Northwest Research Station Science Findings, Issue 30, 

Dec. 2000, available at http://www.fs.fed.us/pnw/sciencef/scifind30.pdf.
Appendix H

Alaska Limited Export H-10 Final EIS

Conclusion

It is commonly claimed that allowing limited log exports reduces the number of local jobs, but this has not 

proven true for the Tongass National Forest. In practice, the current Limited Export Policy has allowed a 

steady supply of volume from the Tongass National Forest which supports the local industry. Eliminating 

the Limited Export Policy under current market conditions would result in a significant reduction in 

volume, value, and jobs. The purpose of all Forest Service export policy changes have focused on the 

development and continued existence of adequate wood processing capacity needed to meet national, 

regional, and forest management goals and objectives. The ultimate purpose of allowing export on a 

limited basis is to help achieve forest plan goals and objectives for which the effects have been analyzed 

during development of the Forest Plan as amended. The key goal is to accelerate the transition to younggrowth while seeking to provide a supply of timber that meets planning cycle and annual demand from the 

Tongass. The Limited Export Policy is even more vital to sustain the local industry during the transition to 

young-growth by allowing timber purchasers to export lower value logs while establishing a market for 

young-growth sawn products.
APPENDIX I 

DEIS COMMENTS AND RESPONSES
COMMENT SUMMARY and RESPONSES

2015 TONGASS AMENDMENT DRAFT EIS

June 2016
Appendix I

Appendix I

DEIS Comments and Responses

CONTENTS

A. INTRODUCTION...................................................................................................................................I-1

B. COMMENTS AND RESPONSES .........................................................................................................I-5

GENERAL COMMENTS (GEN) .................................................................................................................I-5

PURPOSE AND NEED (P&N)....................................................................................................................I-8

RANGE OF ALTERNATIVES (ALT)........................................................................................................I-17

PLANNING RULE (PLR)..........................................................................................................................I-24

TIMBER (TIM)...........................................................................................................................................I-33

CONSERVATION STRATEGY (CONS)...................................................................................................I-42

YOUNG GROWTH IN AUDUBON/TNC AND T77 WATERSHEDS (YGAT)...........................................I-56

BEST AVAILABLE OR RELEVANT SCIENCE (BAS)............................................................................I-58

AIR QUALITY (AIR)..................................................................................................................................I-59

GEOLOGY/SOILS AND PHYSICAL SETTING (SOIL) ...........................................................................I-61

STREAMS AND WATERSHEDS (S&W) .................................................................................................I-62

FISH (FISH) ............................................................................................................................................I-63

RIPARIAN (RIP) .......................................................................................................................................I-70

BOTANICAL RESOURCES (BOT)..........................................................................................................I-72

WILDLIFE (WILD).....................................................................................................................................I-75

DEER (DEER)...........................................................................................................................................I-81

WOLVES (WOLF).....................................................................................................................................I-84

GOSHAWK (GOSH).................................................................................................................................I-88

PRINCE OF WALES SPRUCE GROUSE (PGR).....................................................................................I-90

CROSSBILLS (CROSS)...........................................................................................................................I-91

NORTHERN FLYING SQUIRREL (NFSQ) ..............................................................................................I-92

KITTLITZ’S MURRELET (KMUR)............................................................................................................I-93

MARTEN (MART).....................................................................................................................................I-94

BLACK BEAR (BLABE)...........................................................................................................................I-96

Final EIS I-i DEIS Comments and Responses
Appendix I

BROWN BEAR (BROBE).........................................................................................................................I-97

BATS (BAT) ............................................................................................................................................I-98

AMPHIBIANS (AMPH) .............................................................................................................................I-99

SUBSISTENCE (SUB)............................................................................................................................I-100

KARST (KARS) ......................................................................................................................................I-101

ROAD DENSITY (RD) ............................................................................................................................I-104

TRANSPORTATION AND UTILITY SYSTEM LUD OVERLAY (TUS)..................................................I-107

RENEWABLE ENERGY (REN)..............................................................................................................I-115

MINERALS AND MINING (MIN) ............................................................................................................I-123

CARBON STORAGE AND GLOBAL WARMING (CARB) ...................................................................I-126

ECOSYSTEM SERVICES (ECOS).........................................................................................................I-139

ECONOMICS OF THE TIMBER INDUSTRY (ECON) ...........................................................................I-140

PUBLIC COSTS (PUBC)........................................................................................................................I-145

SOCIOECONOMICS (SOC) ...................................................................................................................I-147

MARKET DEMAND (MKD) ....................................................................................................................I-152

TIMBER EXPORT POLICY (TEXP) .......................................................................................................I-168

RECREATION AND TOURISM (R&T)...................................................................................................I-171

WILD AND SCENIC RIVERS (WSR) .....................................................................................................I-174

SCENERY (SCEN) .................................................................................................................................I-175

ROADLESS AREAS (RDLS) .................................................................................................................I-177

SPECIFIC COMMENTS ON THE FOREST PLAN AND DEIS (SPEC).................................................I-179

Attachment A Letters from Agencies, Elected Officials, and Tribal Governments

DEIS Comments and Responses I-ii Final EIS
Appendix I

Appendix H

Comments and Responses

A. Introduction

The Tongass Land and Resource Management Plan Amendment Draft Environmental Impact Statement 

(EIS) and the Draft Proposed Land and Resource Management Plan were completed and mailed out in 

November 2015 to organizations and individuals on the Tongass National Forest’s mailing list. On 

November 20, 2015, an NOA of the DEIS was published in the Federal Register (80 FR 72719), which 

started the 90-day public comment period. The document and supporting documents were also posted on 

the project web site (http://www.fs.usda.gov/goto/R10/Tongass/PlanAmend). 

This appendix presents a summary of the comments received during the public comment period and 

provides the Forest Service’s responses to these comments. In addition, Attachment A provides copies 

of the letters received from government agencies, elected officials, and tribal governments.

Public Meetings 

In January and February 2015, public open house were held in Juneau, Sitka, and Ketchikan to engage 

the public in the planning process and share information about the progress being made on the Proposed 

Forest Plan and DEIS. All of the open house materials were posted on the Forest Plan Amendment Web 

site.

In January and February 2016, the Forest Service hosted nine public open house meetings, each 

followed by a subsistence hearing. These public open house meetings were held in the following 

Southeast Alaska communities: Klawock, Ketchikan, Wrangell, Petersburg, Juneau, Sitka, Hoonah, 

Yakutat, and Kake. Participants had the opportunity to review the contents of the Proposed Forest Plan, 

including the five alternatives analyzed in the DEIS. Forest Service staff provided an overview, listened to 

public concerns, and was available to answer questions. The public was informed on how to submit 

comments, invited to submit written comments during the open house, and informed on the date 

comments must be received by. Although an ANILCA Section 810 evaluation and determination was not 

required for approval of a Forest Plan amendment (see Subsistence section in Chapter 3 of FEIS), 

subsistence hearings were held after each open house meeting, which gave the public an opportunity to 

provide oral testimony regarding concerns about the Proposed Forest Plan Amendment on subsistence 

uses.

Public Input

The Forest Service received more than 165,000 comments during the public comment period. These 

pieces of input, referred to here as “comment documents,” were provided in a number of different forms, 

including email, letter, fax, public testimony, and written comments. As part of the initial comment 

evaluation process, comment documents were initially divided into unique comment documents and form 

comment documents. Less than 1 percent of these documents received were classified as unique 

comment documents; with the rest being either form letters or non-substantive comments. Comments are 

considered substantive when they are within the scope of the proposal, are specific to the proposal, have 

a direct relationship to the proposal, and include supporting reasons for the responsible official to 

consider. 

Many of the comments received by the Forest Service during the public comment period were determined 

to be form letters. A document was considered to be a form letter when copies of the same or 

substantially similar document (letter, email, comment form, etc.) were submitted by five or more people. 

Form letters are typically generated by special interest organizations that encourage their members to 

Final EIS I-1 DEIS Comments and Responses
Appendix I

write letters, and provide a written template for them to use. In some cases members are encouraged to 

add their own personal message to the template. 

A total of 16 different form letter templates were identified. These templates are summarized below:

• Form letter template one requested that the Tongass “take bold action to protect the Tongass” 

and stated that “15 years for a transition is far was too long” to protect the sensitive resources 

found on the Tongass. It went on to say that the range of alternatives considered in the EIS was 

inadequate, and requested that the logging of old-growth be ended immediately.

• Form letter template two stated that “Alaskan’s want a Tongass Forest plan that works for all of 

us, not just the timber industry”, and that the Forest Service should shift their priorities to “meet 

the needs of the local small mills who are adding a tremendous amount of value to their 

produces”. The form letter went on to ask the Forest Service to enhance the salmon and tourism 

sectors of the economy.

• Form letter template three addressed the role the Tongass plays in global climate change, and 

stated that “old-growth is much more valuable for carbon storage than timber production”. 

• Form letter template four urged the Forest Service to ensure that the amendments to the Forest 

Plan protect high value fish watersheds and make the production of wild salmon, trout, and 

steelhead their highest management priority.

• Form letter template five requested that the clearcutting of old-growth be ended in 5 years instead 

of 15 years. It further stated that the 17 million that is annually generated by timber in the region 

is less than 1 percent of the combined 2 billion generated by fishing and tourism in the region, 

and that the Forest Service should focus on these resources instead of timber.

• Form letter template six stated that the draft plan is inconsistent with the current U.S. policies 

regarding climate change, and that the forest plan should focus on establishing an economic 

future for southeast Alaska that is based on restoration, recreation, fishing, and tourism instead of 

timber.

• Form letter template seven requested that the practice of “industrial-scale clearcutting” of oldgrowth be stopped as soon as possible.

• Form letter template eight requested that the Tongass transition away from harvesting old-growth 

sooner than 10 years, and that the Forest Service should “stop preparing more old-growth timber 

sales like the massive and highly ill-advised Big Thorne Project”.

• Form letter template nine requested that all proposed harvesting of old-growth be removed from 

the plan. The form letter also requested that the Tongass “stop cutting its budget for programs 

that support education, tourism, recreation, and public outreach”. 

• Form letter template ten requested that clearcutting be ended in 3 years not 15. It further 

requested that the Tongass manage and protect the forests instead of “selling them at wholesale 

rates to Asia”.

• Form letter template eleven stated that because the Prince of Wales wolves are no longer 

protected under the ESA, protecting the old-growth trees on the Tongass, which the wolves 

depend on, is critically important.

• Form letter template twelve requested that the Tongass end all “large-scale clearcutting of old 

growth as soon as possible”, and that the old-growth trees are far more valuable standing than 

they are cut down. Reasons to support this claim is that these trees provide habitat for wildlife, 

have benefits to carbon sequestration, have cultural values, and provide opportunities for tourism.

DEIS Comments and Responses I-2 Final EIS
Appendix I

• Form letter template thirteen requested that the Tongass adopt Alternative 5; remove salmon 

producing watersheds, priority conservation areas, and roadless areas from the timber pool; and 

make Fish Bay and old-growth reserve.

• Form letter template fourteen requested that forests in general be preserved globally to enhance 

carbon sequestration and protect wildlife habitats.

• Form letter template fifteen requested that instead of clearcutting the maturing forests found on 

the Tongass to “prop up a timber industry in economic transition”, the Forest Service should focus 

on the restoration of forests and watersheds.

• Form letter template sixteen requested that the Forest Service “not pass the Tongass Land 

Management Plan”, and stated that there is more than enough renewable timber in the U.S.

The large number of documents reflects the importance of the Tongass National Forest at a national 

level. It also reflects the membership and geographic reach of the organizations that prepared the 

original written templates.

The total number of form comment documents received in response to this Draft EIS (over 165,000) is 

more than double the comments received on the 2008 Forest Plan DEIS (82,407). 

Comment Document Evaluation

Each comment document was assigned a unique identifier (number) upon receipt and entered into a 

database. Documents were numbered in the order received by the comment management team. 

Summary demographic information for each response was entered into a database, including the name 

and address of the comment author (when provided), the type of comment author (individual, government 

agency, environmental organization, etc.), and the method of transmittal (online comment form, email, 

U.S. Mail, public hearing testimony, hard copy comment form). 

Members of the comment management team read each comment document and identified the comments 

within each document. Comments were identified for one copy of each form comment document. 

Comments were defined for the purposes of this initial identification phase as a coherent segment of text 

that stood alone as a suggestion, idea, request, or critique. Comments were delineated on a hard copy of 

the comment document and each comment was assigned a number. The comment number was entered 

into a database and assigned to a coding category. Up to three key words or terms that further 

characterized the comment, along with additional notes, were entered in separate fields in the database, 

as appropriate. The initial coding categories corresponded for the most part with the resource areas 

addressed in the Draft EIS. A copy of each coded comment document was scanned and saved as a 

unique PDF file. 

Comment Summaries and Responses 

The database allowed the comments to be sorted by coding category and key words. Resource 

specialists and members of the Forest Service interdisciplinary team reviewed all the comments and 

consolidated the individual comments into logical comment summaries, developed responses to the 

comment summary, and revised the analysis or text in the Final EIS, as appropriate. The comment 

summaries and responses are presented in Section B of this appendix. Some comment summaries 

represent a concern raised once; others represent a concern, opinion, or preference that was repeated in 

a number of different comments. 

Many of the comments consisted of statements of opinion or preference, and while they were considered, 

they did not require a written response. For substantive comments that require a response, comment 

summaries and responses are presented in Section B for a number of these types of comments, primarily 

to provide information to the public or clarify popular misconceptions. In some cases, comments prompted 

the Forest Service to review additional references that were submitted and some of these have been 

included in the EIS where they improved the analysis or discussion.

Final EIS I-3 DEIS Comments and Responses
Appendix I

In accordance with 40 Code of Federal Regulations (CFR) 1503.4, the Forest Service generally 

considered responding in five basic ways to the substantive public comments identified in the following 

sections.

Modifying alternatives. 

Developing and analyzing alternatives not given serious consideration in the Draft EIS.

Supplementing, improving, or modifying the analysis that the Draft EIS documented. 

Making factual corrections. 

Explaining why the comments do not need further Forest Service response.

Review of the public comments resulted in Alternative 5 being modified between the Draft and Final EIS 

to add a 100-foot no harvest buffer around anadromous lakes. Additionally, some wording that was 

deleted in the Proposed Forest Plan was restored (See Chapter 1, Changes between Proposed Forest 

Plan and Forest Plan.) After substantial consideration, it was decided that the range of alternatives was 

sufficient. The results of the public involvement and comment process did, however, lead to a number of 

improvements, clarifications, and updates between the Draft and Final EIS. These changes are identified 

where applicable in the following section (Section B).

The following section presents the comments and responses developed by the resource specialists and 

Forest Service managers that comprise the Interdisciplinary Team for this project. Copies of the 

comment documents received during the public comment period from government agencies, elected 

officials, and tribal governments are presented in Attachment A. All of the responses received are 

available for review in the project planning record. 

DEIS Comments and Responses I-4 Final EIS
Appendix I

B. Comments and Responses

General Comments (GEN)

COMMENT

GEN-1: The DEIS project planning record was incomplete. Scoping comments were missing and 

were not considered or responded to during the development of the DEIS. (NGO2-101)

RESPONSE

The planning record includes documents that support analytical conclusions made and alternatives 

considered throughout the planning process. It also includes all comments received during opportunities 

for public participation provided during the planning process (e.g., scoping, DEIS, and objections). The 

planning record also tiers to and incorporates by reference records from the 1997 Forest Plan Revision, 

2003 SEIS, and the 2008 Forest Plan amendment. All timely comments, including any attached 

references or exhibits, have been considered and are included as part of the planning record for this 

Tongass Forest Plan amendment process.

The May 27, 2014 Notice of Intent (NOI) (79 FR 30074) included instructions in the “Addresses” section 

about how to submit written comments. All comments, including any attached references and exhibits that 

were submitted during the scoping comment period (May 28 – June 26, 2014) were included in the USDA 

Forest Service Comment Analysis and Response Application (CARA) database and were considered by 

the interdisciplinary team (IDT) during the scoping process. The CARA database is used to collect all 

letters and comments for a particular project in an easily accessible and searchable centralized repository 

regardless of how they were received. If written comments were submitted via U.S. mail or facsimile, the 

Forest Service scanned these documents and uploaded them into the CARA database.

The process of scoping is an integral part of environmental analysis, and provides an “early and open 

process for determining the scope of issues to be addressed and for identifying the significant issues 

related to a proposed action.” (40 CFR 1501.7) The Forest Service Handbook (FSH 1909.15, Ch. 10, sec. 

11) also provides guidance for conducting scoping to include refining the proposed action, determining 

the responsible official and lead and cooperating agencies, identifying preliminary issues, and identifying 

interested and affected persons. The results of scoping are used to clarify public involvement methods, 

refine issues, select an interdisciplinary team (IDT), establish analysis criteria, and explore possible 

alternatives and their probable environmental effects.

In July and August 2014, the IDT conducted a content analysis on the scoping comments received, and 

included this analysis (excel spreadsheet) as record 769_02_000017 (planning record index # 817) in the

planning record. The planning record also included record 769_02_000024 (planning record index # 908), 

which was a link to the CARA database where the public could access all scoping comments. This link 

includes both scoping comments and DEIS comments.

The FEIS planning record has been updated to include all comments (in .pdf) received during a formal 

comment period to include scoping and DEIS comments. Subsistence testimony provided during the 

subsistence hearings for the DEIS was transcribed and are also included in the planning record.

COMMENT

GEN-2: The Forest Service should add information from Secretary’s Memorandum regarding the 

retention of existing industry and the need for old-growth timber until the transition is complete.

RESPONSE

Text was added to Chapter 1, Introduction, to clarify. Further, the Need statement in Chapter 1 makes it 

clear that the transition is intended to be implemented in a manner that preserves a viable timber industry. 

Chapter 2, Alternatives Considered in Detail, discloses that all alternatives were designed to correspond 

with current demand projections with old growth making up a decreasing percentage of the total. OldFinal EIS I-5 DEIS Comments and Responses
Appendix I

growth volume would continue to decrease until it reaches about 5 MMBF per year and it would remain at 

that level, to support limited small timber operators.

The Secretary’s Memorandum 1044-009 is included in the planning record, and has been made available 

on the Tongass Plan Amendment website http://www.fs.usda.gov/goto/R10/Tongass/PlanAmend

COMMENT

GEN-3: The effects of a larger harvest on the environment, commercial fishing, and tourism are 

unsupported by the record 

RESPONSE

You are correct that a larger harvest does not always mean greater environmental effects. It depends on 

the type of harvest, the location of harvest, and whether old growth or young growth is being harvested, 

among other factors. These are the types of questions that are the primary subjects analyzed in the 

FEIS. The FEIS record supports the document. Thank you for your comment.

COMMENT

GEN-4: An Executive Summary should be included in the FEIS.

RESPONSE

A plan amendment summary was provided as part of the proposed Forest Plan and Draft Environmental 

Impact Statement (DEIS) for the Tongass National Forest. This summary was made available on the CDROM, on the Tongass Plan Amendment website http://www.fs.usda.gov/goto/R10/Tongass/PlanAmend, 

and was made available at the public open house meetings / subsistence hearings in January 2016. A 

summary will also be included as part of the Final Environmental Impact Statement (FEIS) package.

COMMENT

GEN-5: Concerns were expressed that the amendment process is being rushed to comply with a 

directive from the Secretary of Agriculture and is unlikely to produce a viable, sustainable 

transition plan.

RESPONSE

See response to P&N-3 and P&N-4

If a need for change is determined by the responsible official an amendment may be considered. Plan 

amendments are intended to be an adaptive management tool to keep plans current, effective, and 

relevant between required plan revisions (every 15 years) (see FSH 1909.12 Chapter 20, Section 21.3).

COMMENT

GEN-6. The Forest Plan should provide sustainable management, maintain a viable timber 

industry with local processing, and encourage renewable energy development.

RESPONSE

We appreciate this input. The range of alternatives analyzed in detail support these and other goals to 

varying degrees. 

COMMENT

GEN-6: Protect Tongass old growth and/or stop clearcutting.

The Forest Service should protect the Tongass and stop industrial-scale logging, clearcutting, and highgrading old-growth, or stop resource extraction altogether. The Forest should be protected for its many 

values (e.g. habitat, streams, fisheries, species diversity, runoff and flood control, recreation, hunting and 

subsistence, commerce, its role in addressing air quality and climate change, the potential for 

DEIS Comments and Responses I-6 Final EIS
Appendix I

undiscovered value, and providing human health benefits) and to preserve the forest for future 

generations. Some recommended the entire forest be set aside as a national park or wilderness. 

RESPONSE

See responses to TIM-19, ALT-3, and ALT-11.

COMMENT

GEN-7: The Forest Service did not do enough public notification for this project and information 

was hard to find.

RESPONSE

Public notification and opportunities to participate and comment are described in Chapter 1.

COMMENT

GEN-8: Suggestions to recommend Wilderness or other special designation for specific areas 

including all of the areas proposed for protection by Trout Unlimited, Audubon Alaska, Southeast 

Alaska Conservation Council, and Tenakee Inlet by the Chichagof Conservation Council, among 

other areas. 

RESPONSE

Wilderness designations are outside of the scope of this plan amendment, as well as outside of 

the authority of the Forest Service.

Final EIS I-7 DEIS Comments and Responses
Appendix I

Purpose and Need (P&N)

COMMENT

P&N-1: The purpose and need section ignores some of the aspects outlined in the Secretary’s 

Memo, such as transitioning forest management on the Tongass to be more ecologically, socially, 

and economically sustainable. Commenters believe that the Secretary’s intent to transition away 

from old-growth harvesting in 10 to 15 years “so that after this timeframe the vast majority of 

timber sales on the forest will be from second-growth forests,” was meant to end old-growth 

logging on the Tongass. Commenters are concerned that the DEIS preferred alternative

(Alternative 5) increases rates of old-growth logging higher than the recent 10-year average for at 

least another 16 years.

RESPONSE

The Purpose and Need statement responds to the Secretary’s Memorandum 1044-009 that directs a 

“transition over the next 10 to 15 years, so that at the end of this period the vast majority of timber sold by 

the Tongass will be young growth.” The Secretary did not envision an end to old-growth logging, and this 

is made clear in the Memo under 1. PURPOSE AND BACKGROUND where it reads as follows:

“To ensure a smooth transition, the Forest Service will continue to offer a supply of old growth 

timber while increasing the supply of young growth to provide industry in Alaska the opportunity to 

develop new markets, learn new skills, and acquire new equipment. The continuation of limited 

sales of old growth timber is essential to maintain the existing industry until young growth can 

efficiently be processed. The Forest Service will also continue the Tongass National Forest’s 

micro-sale program and the old growth small sale program that targets niche markets, while 

developing a new integrated program of work focused on young growth, ecological restoration, 

and forest stewardship that protects and restores the Forest’s extraordinary fish and wildlife

habitat.”

The 2008 Forest Plan “planned” for a longer transition to young-growth management, and the ROD made 

it clear that there was an “expected increase in young-growth management over the next few planning 

cycles.” (USDA 2008a, p. 10). The Secretary’s memo directs the Tongass National Forest to “expedite” 

this transition. 

Basic tools used in the development of the alternatives include recent draft timber demand projections in 

Daniels et al. (USDA 2015). Alternatives 1 through 5 were designed to correspond with current demand 

projections and produce a projected timber sale quantity (PTSQ) of about 46 MMBF per year during the 

next 15 years, with old growth making up a decreasing percentage of the total. Old-growth volume would 

continue to decrease until it reaches about 5 MMBF per year and it would remain at that level, to support 

limited small timber operators. As more young growth becomes economic to harvest, the PTSQ would be 

allowed to increase. In no case, would the harvest level be allowed to exceed the sustained yield limit 

(SYL).

Also, see the recently finalized Tongass National Forest timber demand: projections for 2015 to 2030 

(Daniels et al 2016), available online at: http://www.treesearch.fs.fed.us/pubs/50909

COMMENT

P&N-2: Changes to the Forest Plan’s direction for transportation does not fulfill the Purpose and 

Need. The Purpose and Need section of the DEIS simply states that “[c]hanges to the Forest Plan 

are needed to make the development of renewable energy resources more permissible, including 

considering access and utility corridors to stimulate economic development in Southeast Alaska 

communities.” The new Transportation Systems Corridor direction in the Proposed Forest Plan is 

not related to or limited to renewable energy projects.

DEIS Comments and Responses I-8 Final EIS
Appendix I

RESPONSE

The responsible official has the discretion to determine whether and how to amend the plan (36 CFR 

219.13(a)). Based on comments received on the Five-Year Review of the Forest Plan, completed in 2013, 

the responsible official determined that there was a need “to make the development of renewable energy 

resources more permissible, including considering access and utility corridors to stimulate economic 

development in Southeast Alaska communities, and provide low carbon energy alternatives, thereby 

displacing the use of fossil fuel.” 

The responsible official has the authority to remove the existing Transportation and Utility System (TUS) 

Land Use Designation (LUD) overlay under the action alternatives in the DEIS under 36 CFR 219.13(a). 

The last sentence of 36 CFR 219.13(a) states that: “Except as provided by paragraph (c) of this section, a 

plan amendment is required to add, modify, or remove one or more plan components, or to change how 

or where one or more plan components apply to all or part of the plan area (including management areas 

or geographic areas).” (Emphasis added). The Department added the phrase “including management 

areas or geographic areas” to the final planning rule to clarify that an amendment is required for any 

change in how or whether plan components apply to those areas (77 FR 21238). That addition to the final 

rule and the provision that an amendment is necessary to remove plan components shows that the 

proposed amendment is legitimate. An amendment may remove all the plan components within a LUD 

and remove the LUD itself.

To meet the purpose and need, new direction (i.e., plan components and management approaches) was 

developed for renewable energy. To ensure future project decision-making was consistent with the 

amended plan, the responsible official decided to remove the TUS LUD and add to and modify the TUS 

LUD management prescription as plan components (see 36 CFR 219.7 (e)) in the amended plan. This 

new direction for renewable energy and transportation systems corridors is applied to the remaining 18 

LUDs.

The intent of the Forest Plan direction for transportation systems corridors is not to change the process 

the Forest Service will go through when developing future transportation systems. The purpose of the 

plan direction for transportation systems corridors is the same as the 2008 TUS LUD management 

prescription; to facilitate the availability of National Forest System land for the development of existing 

and future transportation systems such as those identified by the State of Alaska in the current version of 

the Southeast Alaska Transportation Plan (SATP) and applicable laws. (See Forest Plan Chapter 5.) The 

applicable transportation systems corridors direction in Chapter 5 is included for each LUD in Chapter 3 in 

a table that cross-references, by category, the plan content, found in Chapter 5.

COMMENT

P&N-3: The Department of Agriculture’s policy to expedite a transition away from old-growth 

timber harvesting and towards a forest industry that utilizes second growth – or young growth –

forests as expressed in the Secretary’s Memorandum (1044-009), is premature and would not 

restore a viable timber supply in Southeast Alaska.

RESPONSE

Under the direction of Thomas Vilsack, Secretary of Agriculture, the U.S. Department of Agriculture 

(USDA) administers the U.S. Forest Service. The Secretary of Agriculture is a member of the president's 

cabinet who takes the lead with USDA for the development of implementing policy on a variety of 

programs and services. The Secretary’s Memorandum (1044-009) Addressing Sustainable Forestry in 

Southeast Alaska was signed on July 2, 2013 and sets forth USDA policy for the Forest Service on the 

Tongass National Forest. Secretary Vilsack was quoted in a USDA Forest Service news release on July 

2, 2013:

"Today, I am outlining a series of actions by USDA and the Forest Service that will protect the 

old-growth forests of the Tongass while preserving forest jobs in southeast Alaska... I am asking 

the Forest Service to immediately begin planning for the transition to harvesting second growth 

timber while reducing old-growth harvesting over time."

Final EIS I-9 DEIS Comments and Responses
Appendix I

The actions outlined in the Secretary’s Memo that are carried forward in the amended plan are focused 

on conserving old-growth temperate rainforests of the Tongass, while ensuring a transition to secondgrowth forests so that current forest industry can continue to provide jobs and opportunities in Southeast 

Alaska. A transition timeframe of 10 to 15 years is intended to conserve old growth forests while allowing 

the forest industry time to adapt to this shift away from old-growth to young-growth forest management. 

Flexibility, like that provided by Congress in the National Defense Authorization Act for Fiscal Year 2015 

(Public Law 113-291, December 19, 2014, 128 Stat. 3729, section 3720(e)(4)) allows the harvest of trees 

prior to the culmination of mean annual increment of growth on lands identified as suitable for timber 

production to facilitate the transition from commercial timber harvest of old growth stands.

Alternatives 1 through 5 in the EIS were designed to correspond with current demand projections and 

produce a projected timber sale quantity (PTSQ) of about 46 MMBF per year during the next 15 years, 

with old growth making up a decreasing percentage of the total. As more young growth becomes 

economic to harvest, the PTSQ would be allowed to increase. In no case, would the harvest level be 

allowed to exceed the sustained yield limit (SYL).

See response to P&N-9.

COMMENT

P&N-4: The young-growth inventory and associated modeling used by the agency for the 

amended plan is not reliable to support the purpose and need.

RESPONSE

The 2008 Forest Plan Record of Decision (ROD) highlights the uncertainty about short- and long-term 

social, economic, and environmental risks and preparing to adjust promptly if conditions change. The 

responsible official noted in the 2008 ROD that there was an “...expected increase in young-growth

management over the next few planning cycles; and the increasing public interest in this conversion, 

which will ultimately reduce the need for old-growth timber resources...” (USDA 2008a, P. 10). 

With this in mind, the agency has made a concerted effort in the last decade to increase knowledge and 

information of the young-growth resource that is being used as the forest moves toward a forest 

management program that is focused on young-growth management. The agency has expended 

considerable effort and funds to acquire data and expertise to prepare for and define realistic 

expectations for a transition to young-growth forest management. In 2009, the Tongass acquired the 

Forest Projection and Planning System (FPS) software to serve as the Forest’s primary growth and yield 

model, which allows us to store, track and grow our stand inventory. This model is spatially explicit and is 

robust enough to handle forest wide analyses. This model has also allowed us to apply stand information 

that was collected in one stand to similar stands. As more data is collected on the ground, this model will 

become a more robust resource management tool. 

The Tongass is an annual contributor to the Forest Biometrics Research Institute (FBRI) which is a nonprofit public corporation dedicated to research, development, service and education organization in the 

field of forest inventory, forest growth and forest planning for sustainable and scientific forest 

management. This ensures that the regional species library used in the FPS growth and yield library 

remains certified and updated in a manner that is repeatable and scientifically based. In order to provide 

updated information to FBRI, the Tongass has funded the Pacific Northwest Research Station’s (PNW) 

Juneau Forestry Sciences Laboratory to remeasure their extensive network of permanent growth and 

yield plots. The permanent plots of the Cooperative Stand Density Study that were established 40 years 

ago provide long-term growth response of thinned and unthinned even-aged stands at over 50 locations 

throughout southeast Alaska. PNW is also monitoring permanent plots established in the 1920s. The 

long-term growth and yield record from the PNW permanent plots was used to create the southeast 

Alaskan variant of FPS in 2005 and more recently collected data were used in the 2015 recalibration of 

the Southeast Alaska information. 

DEIS Comments and Responses I-10 Final EIS
Appendix I

Some of the efforts that have been undertaken since 2005, more information is included in FEIS and the 

planning record:

• 2005 and 2011 - Two large scale young growth inventories of the Forest’s oldest young-growth 

stands.

1. 2009 - FPS growth and yield model software obtained to serve as the Forest’s primary growth 

and yield model to store, track and grow our stand inventory forward in time. 

2. 2010 - ongoing work with FBRI to establish the Tongass Inventory Database within the FPS 

growth and yield model, FBRI developed a forest wide site productivity based upon a stratified 

distribution of Forest Inventory Analysis (FIA) site measurements across the Forest. 

3. 2014 - Tongass, in conjunction with Sealaska, signed a cost share agreement with the Working 

Forest Group to hire an independent consultant to evaluate the FPS model who found the overall 

volume projections are within an acceptable range.

4. 2014 – a review of the young-growth forest management and conditions in GIS was conducted. 

5. 2015 - “Woodstock”, a forest management modeling system was used for long term strategic 

planning in order to define the long-term, non-declining, sustained yield from our land base. 

6. 2016 – Challenge cost share agreement with the State of Alaska to conduct the currently ongoing 

young growth inventory. See response to ECON-6.

COMMENT

P&N-5: The need expressed in the “purpose and need” section of the EIS is not warranted. Fuel 

prices have dropped precipitously over the last year or so, and there is no factual basis to support 

a pending climate change impact on the quality of life in the region.

RESPONSE

See responses to P&N-1 and P&N-3.

The Forest Service identified the need to make the development of renewable energy resources more 

permissible...thereby displacing the use of fossil fuel” is a valid one. A fall 2015 science update entitled 

Energy Anxiety, published by the USDA Forest Service Pacific Northwest Research Station states, 

“[r]ecently, crude oil prices have dropped considerably, but it is unclear what percentage of these cost 

savings will find its way to remote communities. The statewide average annual energy costs per 

household are frequently more than twice the national average. The price of heating oil, diesel fuel, and 

gasoline weighs heavily on Alaskans, particularly for isolated and economically struggling villages.” 

(USDA 2015k) The Climate and Air section in Chapter 3 of the FEIS includes a section on climate 

change, and the effects of climate change are disclosed. 

COMMENT

P&N-6: The purpose and need statement is arbitrarily narrow and results in a range of 

alternatives that limit the transition timeframe and timber volume. Some concerns expressed that 

this results in a transition that is too slow and focused on timber industry needs, while other 

express the opposite, that this results in a transition that is too fast with not enough timber 

volume. 

RESPONSE

See response to P&N-3. 

The Purpose and Need was based on a need for change. Chapter 1 of the FEIS includes a section 

entitled, Factors That Led to the Need for Change, which provides the context for the factors that led to a 

need for change. 

Final EIS I-11 DEIS Comments and Responses
Appendix I

The responsible official has the discretion to determine whether and how to amend the plan (36 CFR 

219.13(a)) and the Forest Service has flexibility in defining the purpose and need for action so long as it is 

not arbitrarily narrow. The Purpose and Need responds partly to the Secretary’s Memorandum that directs 

a “transition over the next 10 to 15 years, so that at the end of this period the vast majority of timber sold 

by the Tongass will be young growth.” Secretary Vilsack’s memorandum also guides that the transition 

should be implemented in a manner that preserves a viable timber industry that provides jobs and 

opportunities for Southeast Alaska residents. The Purpose and Need also responds to information 

generated during the Five-Year Review of the Forest Plan in 2013. The scope of the plan amendment is 

narrow because it is an amendment; not a revision, and the range of alternatives in the DEIS concentrate 

solely on the need for change as documented in the 5/27/14 NOI and the refined Purpose and Need 

statement in the DEIS. 

The Secretary’s Memo stated that “[the 10-15 year] timeframe will conserve old growth forests while 

allowing the forest industry time to adapt.” The Secretary did not envision an end to old-growth logging, 

and this is made clear where the Memo reads, “To ensure a smooth transition, the Forest Service will 

continue to offer a supply of old growth timber while increasing the supply of young growth to provide 

industry in Alaska the opportunity to develop new markets, learn new skills, and acquire new equipment. 

The continuation of limited sales of old growth timber is essential to maintain the existing industry until 

young growth can efficiently be processed.” In terms of “preserving a viable timber industry that provides 

jobs and opportunities for Southeast Alaska residents,” an effort to document current timber industry 

trends and to project future timber demand was undertaken. The Tongass National Forest requested the 

Pacific Northwest Research Station to update long-term Tongass National Forest timber demand

projections, 2015 – 2030. During the past 25 years, the U.S. Forest Service, Pacific Northwest (PNW) 

Research Station has published several studies in support of Tongass National Forest land management 

planning that estimate derived demand for Southeast Alaska timber including Brooks and Haynes (1990, 

1994, 1997), Brackley et al. (2006a), and Daniels et al. (2016). Daniels et al. (2016) is the fifth such 

analysis performed since 1990 to assist forest planners in meeting statutory requirements for estimating 

planning cycle demand for timber from the Tongass National Forest. The PNW Research Station’s timber 

demand projections are based on solid economic theory, peer-reviewed methodology, and rigorous and 

objective analysis. 

The intent of the Tongass Timber Reform Act (TTRA) was to maintain a timber industry in southeast 

Alaska while providing more resource protection, particularly forested buffers to fish-bearing streams in 

support of economic diversity. Providing old-growth ‘bridge’ timber during the transition is designed to 

fulfill the ‘seek to meet’ intent of TTRA. This will give industry the needed time to retool their mills or new 

industry to start up. Determining what demand estimates mean for timber sales offered from the Tongass 

National Forest involves taking the results from Daniels et al. (2015, 2016) and using them as input to a 

supply calculation that seeks to meet annual market demand from the forest. The derived demand 

projections developed by Daniels et al. were used to estimate the market demand for the current Tongass 

National Forest planning cycle, which is 46 MMBF per year. 

Alternatives were modeled to ensure that land allocations and output schedules for alternatives are 

realistic and meet Forest Plan direction in a cost-efficient manner. Results from the modeling process are 

only approximations of what to expect when any given alternative is implemented. The main purpose of 

modeling is to aid planners in estimating likely future consequences of management prescriptions. A 

choice between alternatives can be made even though the model may lack precision in describing 

specific attributes of a given alternative.

All action alternatives in the DEIS were developed to address the significant issues and meet the Purpose 

and Need. It is not always possible to provide all resource use opportunities in the amounts desired by 

everyone. The National Forest Management Act (NFMA) mandates the Forest Service to provide for 

multiple use and the sustained yield of the products and services obtained from the Forest. In an effort to 

help the Forest Service balance multiple use goals on the Tongass and continue to seek input from and 

work with stakeholders in the region towards this transition, the USDA established a Federal Advisory 

Committee under the Federal Advisory Committee Act to advise the Secretary and Chief on transitioning 

the Tongass to young-growth forest management. The committee, known as the Tongass Advisory 

DEIS Comments and Responses I-12 Final EIS
Appendix I

Committee (TAC), consisted of members from the timber industry, conservation community, Native 

interests, state and local governments and other interests.

In January 2015, the TAC recommended the Purpose and Need should consider an alternative that 

“[maximizes] the opportunities for social and economic returns from other economic sectors that depend 

on the Forest.” The Under Secretary responded to the TAC in writing in May 2015 stating the following:

“Let me be clear that USDA's top priority with the Transition Framework is maintaining resilient 

communities in Southeast Alaska... Including the language in the Purpose and Need as you 

suggest would broaden the scope of the Plan Amendment in a way that would require a corrected 

NOI, and an additional public comment period prior to the Draft Environmental Impact Statement 

(DEIS). We therefore propose recognizing the values that your suggested language addresses, 

without changing the purpose and need under NEPA. Meeting your interests this way, the 

agency could recognize the range of social and economic values supported by the Tongass, 

without needing to re-issue the NOI for a new round of public comment.”

The TAC recommendations were carried forward in the amended plan as Alternative 5 (preferred 

alternative), and this will enable the Forest to move out of old growth as quickly as possible and 

accelerate the transition while sustaining an economically viable timber industry. The agency has the 

authority to amend the forest plan, which is one step in addressing sustainable forestry in Southeast 

Alaska. Additional steps in the TAC’s detailed implementation recommendations provide guidance on 

elements for success in implementing the transition, and identify opportunities by which the agency, 

stakeholders, and greater community will share ownership of the transition strategy and embrace its 

successful implementation. The work done by the TAC offers the possibility of a regionally focused, 

collaborative path toward an innovative opportunity for a viable young-growth timber industry while 

honoring the suite of economic, ecological, social, and cultural values inherent in the Forest. The TAC 

provided detailed recommendations for targeted investment, financial assistance, and financing 

mechanisms for stand inventory, research, infrastructure, and retooling. These investments are intended 

to help communities and businesses successfully transition to, and thrive within, a new young-growth 

economy.

Plan amendments are intended to be an adaptive management tool to keep plans current, effective, and 

relevant between required plan revisions (every 15 years). Amendments help Responsible Officials adapt 

an existing plan to new information and changed conditions. Maintaining plans through amendment also 

may reduce the workload for subsequent plan revisions. Amendments may be broad or narrow in scope, 

depending on the need to change the plan. An assessment for a plan amendment is not required, but 

may be developed at the discretion of the Responsible Official (see FSH 1909.12, chapter 10, section 

15). Whether an amendment is proposed in response to changing conditions or in relation to a specific 

project, the Responsible Official should keep the scope and scale of the process, including public 

participation, commensurate with the scope of the plan amendment (CFR 219.13(b)(2)). 

The Forest Service has the authority to amend the forest plan, which is one step in addressing 

sustainable forestry in Southeast Alaska. Additional steps in the TAC’s detailed implementation 

recommendations provide guidance on elements for success in implementing the transition, and identify

opportunities by which the agency, stakeholders, and greater community will share ownership of the 

transition strategy and embrace its successful implementation. The work done by the TAC offers the 

possibility of a regionally focused, collaborative path toward an innovative opportunity for a viable younggrowth timber industry while honoring the suite of economic, ecological, social, and cultural values 

inherent in the Forest. The TAC provided detailed recommendations for targeted investment, financial 

assistance, and financing mechanisms for stand inventory, research, infrastructure, and retooling. These 

investments are intended to help communities and businesses successfully transition to, and thrive within, 

a new young-growth economy.

A recent report by Government Accountability Office (http://gao.gov/products/GAO-16-456) outlines 

additional steps taken or planned by the Forest Service, including comparing potential market prices for 

young-growth timber or products to the cost to harvest, transport, and process the timber; refining of 

young-growth timber data; lengthening the duration of small sale contracts to provide small-mill owners 

Final EIS I-13 DEIS Comments and Responses
Appendix I

with flexibility; and expanding collaborative projects to support job creation through sustainable forest 

management and improve predictability of timber supply. 

COMMENT

P&N-7: The Forest Service has abandoned prior commitments to Southeast Alaska communities, 

citing the July 2013 memo, signed by USDA Secretary Vilsack, to expedite the transition from oldgrowth to young-growth timber harvest while supporting a viable timber industry, retaining 

industry expertise and infrastructure, and ensuring young-growth harvest in tandem with 

continued old-growth harvest to maintain the industry during the transition. 

RESPONSE

Chapter 1 of the FEIS includes a section entitled, Factors That Led to the Need for Change, which 

provides the context for the factors that led to a need for change. One of the factors discussed in this 

section is about collaboration and the important relationships that were established that laid the 

groundwork for the “Transition Framework.” 

In a May 24, 2014 letter to the Tongass Futures Roundtable, signed by Alaska Regional Forester Beth 

Pendleton, the agency effectively announced the “Transition Framework”. The letter indicated the 

Agency’s belief that it is possible to “provide economic opportunity and jobs to local residents and to 

sustain a viable timber industry while at the same time transitioning from timber harvesting in roadless 

areas and old-growth forests to long-term stewardship contracts and young-growth management.” (USDA 

2014). The letter further outlines an approach to collecting input from Southeast residents and 

communities, a priority to support regional economic diversification, and a new vision for forest 

management. Since this time, the agency has invested significant resources in conducting public 

outreach, facilitating economic development, and amending the forest plan. As stated in the original letter 

announcing the “Transition Framework”, the agency maintained focus on the overarching goal of working 

with community members to create jobs in Southeast Alaska (USDA 2010). 

In an effort to document current timber industry trends and to project future timber demand, the Tongass 

National Forest requested the U.S. Forest Service, Pacific Northwest (PNW) Research Station update 

long-term Tongass National Forest timber demand projections, 2015 – 2030. During the past 25 years, 

the Pacific Northwest Research Station has published several studies in support of Tongass National 

Forest land management planning that estimate derived demand for Southeast Alaska timber including 

Brooks and Haynes (1990, 1994, 1997), Brackley et al. (2006a), and Daniels et al. (in press). Daniels et 

al. (in press) is the fifth such analysis performed since 1990 to assist forest planners in meeting statutory 

requirements for estimating planning cycle demand for timber from the Tongass National Forest. PNW 

Research Station’s timber demand projections are based on solid economic theory, peer-reviewed 

methodology, and rigorous and objective analysis. 

PNW Research Station scientists made two trips to Southeast Alaska with the specific purpose of 

collecting information and data from public and private sector stakeholders. Multiple meetings were 

conducted during summer and fall 2014 with the State of Alaska Department of Natural Resources, 

Alaska Mental Health Trust, Sealaska Corporation, Thuja Plicata, Western Gold Cedar Mill, Good Faith 

Lumber, and ALCAN Forest Products. Information provided by the aforementioned, among many other 

sources, where considered in the development of long-term timber demand projections.

Additionally, Management Approaches in Chapter 5 for the Forest Plan state the intent to “engage 

stakeholders (for example, conservation interests, timber operators, permitted user groups, and other 

interested parties) early and often to best design projects that meet ecological, social, and economic 

interests. Such inclusion would surface and resolve differences, and minimize and avoid social, 

environmental, and natural resource conflicts. At the earliest possible time, IDTs would engage scientific

and technical expertise, and knowledge of local resources to encourage creative thinking and enhance 

integration and coordination among jurisdictions.”

DEIS Comments and Responses I-14 Final EIS
Appendix I

COMMENT

P&N-8: The purpose and need statement is arbitrarily narrow, resulting in a range of alternatives

that is not broad enough to address ecological and social and economic sustainability. Concern 

was expressed about the ecological and socio-economic changes that have occurred in the 

region since the 1997 Forest Plan was revised. The forest plan should be revised since the 2012 

Planning Rule requires that “plans to be “revised at least every 15 years.” (36 CFR 219.7(a))

RESPONSE

See responses to P&N-6 and P&N-7.

The purpose and need does not support a plan revision. We are making changes to: 

1. Amend plan direction for timber harvesting to expedite the transition to young-growth forest 

management

2. Amend the plan direction to make the development of renewable energy resources more 

permissible, and 

3. Make miscellaneous technical adjustments to the plan. 

Because the 2008 plan amendment essentially completed the process of revising the Tongass Forest 

Plan that was initiated in 1987, the Forest Plan will not need to be revised again until 2023, unless 

changed conditions require it sooner. (USDA 2008a). No matter when the time starts to do a plan 

revision, the annual appropriations acts for the Department of the Interior, Environment, and Related 

Agencies have regularly permitted Forest Service land management plans to be more than 15 years old if 

USDA is acting in good faith to update the plans. The Chief’s schedule for plan revision is available 

online at http://www.fs.fed.us/emc/nfma/index.htm

COMMENT

P&N-9: The purpose and need is arbitrarily narrow because it is unreasonable to focus an entire 

Plan Amendment on satisfying the perceived needs of two timber exporters at the expense of 

social, economic and ecological sustainability.

RESPONSE

See responses to P&N-1, P&N-6, P&N-7 and ALT-1.

The need for change comes from a July 2013 memo from U. S. Department of Agriculture Secretary Tom 

Vilsack (Secretary’s Memorandum 1044-009) directing the Tongass to transition its forest management 

program to be more ecologically, socially, and economically sustainable, as well as information generated 

during the Five-Year Review of the Forest Plan in 2013.

COMMENT

P&N-10: Purpose and Need aims to support a marginal component of the regional economy 

instead of recreation, wildlife and fishing, which are the regional economic drivers. The Purpose 

and Need arbitrarily focuses on preserving a viable timber industry and fails to respond to 

changed conditions and circumstances in terms of multiple uses that are relevant to public land 

management in southeast Alaska. The amended plan does not meet the substantive requirement 

to provide for social, economic and ecological sustainability (36 CFR parts 219.8) and that 

substantial changes are needed to allow for a broader planning process. 

RESPONSE

See responses to P&N-6, P&N-9, ALT-1

Chapter 1 of the FEIS includes a section entitled, Factors That Led to the Need for Change, which 

provides the context for the factors that led to a need for change. The purpose and need responds to the 

Final EIS I-15 DEIS Comments and Responses
Appendix I

specific factors identified in the Secretary’s memo - primarily rapid reduction of old-growth harvest and 

maintenance of a viable timber industry. The purpose and need does not respond to changed conditions 

and circumstances in terms of other multiple uses because changes that have occurred and will occur in 

these areas are generally well within the range of changes anticipated by the 1997 Revision and the 2008 

Amendment. The Responsible Official determines how broad or narrow the scope of the amendment will 

be and thereby what provisions of the Rule apply; based on the narrow scope of this amendment, the 

sustainability provision at 36 CFR 219.8 was not invoked.

COMMENT

P&N-11: Consolidating the modifications made to the Forest Plan since its approval does not 

require an early transition to young-growth harvesting.

RESPONSE

Chapter 1 of the FEIS includes a section entitled, Factors That Led to the Need for Change, which 

provides the context for the factors that led to a need for change. 

It is not necessary to transition to young-growth harvesting to consolidate the modifications to the Forest 

Plan. However, this is a good opportunity to include the amendments made since the decision for the 

Forest Plan was signed in 2008, update the land status from the recent Sealaska land entitlement 

finalization in the Carl Levin and Howard P. ‘Buck’ McKeon National Defense Authorization Act for Fiscal 

Year 2015, and include new resource inventory and information. This is similar to what was done with the 

2008 amendment when there were changes to the Land Use Designations and other updates. This keeps 

the Forest Plan current as described in FSH 1909.12, chapter 20, section 21.3. 

DEIS Comments and Responses I-16 Final EIS
Appendix I

Range of Alternatives (ALT)

COMMENT

ALT-1: The development of the preferred alternative (Alternative 5) focused narrowly on the 

sustaining or increasing jobs that facilitate the timber industry transition. Options for sustaining 

or increasing jobs in other industry sectors should have been considered.

RESPONSE

See responses to P&N-6, P&N-7, and P&N-9.

In a September 30, 2013 memo entitled, Tongass Land and Resource Management Plan 5-Year Review 

Determination, the responsible official acknowledged the Secretary of Agriculture’s commitment to 

approve the establishment of an advisory committee under the Federal Advisory Committee Act (FACA)

as amended (5 U.S.C, App. 2), and he proposed establishment of such committee to provide stakeholder 

input on the transition (USDA 2013). In an effort to assist the Forest Service in balancing multiple use 

goals on the Tongass and ensuring input from and work with stakeholders in the region towards this 

transition, the USDA established an advisory committee to provide advice and recommendations to the 

Secretary and Chief on transitioning the Tongass on transitioning to young growth forest management. A 

charter was established under FACA for the advisory committee that outlined the objectives and scope of 

advice sought from the committee.

The advisory committee, known as the Tongass Advisory Committee (TAC), offers a regionally focused, 

collaborative path toward an innovative opportunity for a viable young-growth timber industry while 

honoring the suite of values – economic, ecological, social, and cultural – inherent in the Forest. Their 

recommendations related to modifications of the forest plan were carried forward in the amendment as 

Alternative 5 (preferred alternative), which enables the Forest to move out of old growth as quickly as 

possible and accelerate the transition while sustaining an economically viable timber industry.

The agency has the authority to amend the forest plan, which is one step in addressing sustainable 

forestry in Southeast Alaska as outlined in the Secretary’s Memo. Additional steps in the TAC’s detailed 

implementation recommendations provide guidance on elements for success in implementing the 

transition, and identify opportunities by which the agency, stakeholders, and greater community will share 

ownership of the transition strategy and embrace its successful implementation. The work done by the 

TAC offers the possibility of a regionally focused, collaborative path toward an innovative opportunity for a 

viable young growth-timber industry while honoring the suite of economic, ecological, social, and cultural 

values. The TAC provides detailed recommendations for targeted investment, financial assistance, and 

financing mechanisms for stand inventory, research, infrastructure, and retooling. These investments are 

intended to help communities and businesses successfully transition to, and thrive within, a new younggrowth economy.

COMMENT

ALT-2: The range of alternatives is arbitrarily narrow and a supplemental DEIS is warranted. 

Alternatives should have considered economic contributions of other industry sectors, such as 

the fishing and tourism industries that contribute to the region’s most important economic 

sectors.

RESPONSE

See responses to P&N-4, P&N-6, P&N-7 and P&N-9.

COMMENT

ALT-3: The agency failed to fulfill its obligations under NFMA with respect to wildlife and plant 

populations because it did not analyze a no old-growth logging alternative in the EIS. Dismissal of 

the no old-growth harvest alternative was improper and no rationale was given. All Old-growth 

should be unsuitable for timber production and the PTSQ for old-growth should be zero.

Final EIS I-17 DEIS Comments and Responses
Appendix I

RESPONSE

See response to PLR-2.

An alternative that immediately eliminates old-growth logging was analyzed during the 1997 Forest Plan 

Revision (Alternative 1). This analysis is an amendment to that revision and further consideration is not 

necessary. The rationale for not selecting that alternative is discussed on p. 16 in the record of decision

(ROD) of the 1997 Forest Plan Revision (USDA 1997a). 

In terms of meeting the purpose and need for the amended plan, an immediate end to old-growth logging 

would not allow industry to transition. Under the TTRA (Public Law 101-626), as amended, the Forest 

Service is obligated, subject to applicable law, to meet market demand annually and for the planning 

cycle. 

COMMENT

ALT-4: The Purpose and Need did not accurately reflect the Secretary’s intent to transition “no 

later than 10 to 15 years” and that the agency erred by eliminating from detailed analysis an 

alternative that proposes a five-year transition. The agency’s rationale for not analyzing this 

proposal in detail is flawed.

RESPONSE

The Secretary’s Memo stated that “[the 10-15 year] timeframe will conserve old growth forests while 

allowing the forest industry time to adapt.” In terms of “preserving a viable timber industry that provides 

jobs and opportunities for Southeast Alaska residents,” a report was completed by the US Forest Service 

Pacific Northwest (PNW) Research Station assessing derived demand for Alaska forest products. The 

derived demand projections developed by Daniels et al. were used to estimate the market demand for the

current Tongass National Forest planning cycle, which is 46 MMBF per year. The derived demand 

projections developed by Daniels et al. were used to estimate the market demand for the current Tongass 

National Forest planning cycle, which is 46 MMBF per year. Determining what demand estimates mean 

for timber sales offered from the Tongass National Forest involves taking the results from Daniels et al. 

(2015) and using them as input to a supply calculation that seeks to meet annual market demand from 

the forest. 

The Forest Service considered a Five-Year Transition Alternative in the DEIS and it was modeled and 

extensively analyzed; however, there were several reasons that this alternative did not meet the Purpose 

and Need and it was not carried forward for detailed analysis. 

The goal of the Five-Year transition proposal was to increase young-growth volume during this 5-year 

period to transition out of old growth logging more rapidly. Several “sideboards” were provided as part of 

this proposal to include the following: 1) total volume ≤35 MMBF per year after the transition (31.5 MMBF 

of young growth and 3.5 MMBF of old growth); 2) harvest only in Development LUDs; 3) old-growth 

harvest only in Timber Sale Program Adaptive Management Strategy Phase I lands and outside of 2001 

Roadless Areas; 4) young-growth harvest allowed only in Phase I lands outside of 2001 Roadless Areas; 

5) no harvest in beach and estuary fringe, RMAs, or in low, medium, or high vulnerability karst; and 6) 

apply CMAI flexibility - stands as young as 55 years of age (producing one-log/ tree).

When modeled, this proposal showed that it would provide for a more rapid transition compared to the 

other alternatives, but would not allow the Forest Service sufficient time to offer enough economic oldgrowth and young-growth volume during the next 10 or more years to maintain viable timber industry.

Rationale for not analyzing in detail is disclosed in Chapter 2 of the EIS.

COMMENT

ALT-5: The Forest Service should complete all old-growth timber sale planning and offerings 

within five years or sooner. 

DEIS Comments and Responses I-18 Final EIS
Appendix I

RESPONSE

The Secretary’s Memo stated that “[the 10-15 year] timeframe will conserve old growth forests while 

allowing the forest industry time to adapt.” The Secretary did not envision an end to old-growth logging, 

and this is made clear where the Memo reads, “To ensure a smooth transition, the Forest Service will 

continue to offer a supply of old growth timber while increasing the supply of young growth to provide 

industry in Alaska the opportunity to develop new markets, learn new skills, and acquire new equipment. 

The continuation of limited sales of old growth timber is essential to maintain the existing industry until 

young growth can efficiently be processed.”

Timber sale scheduling, as with any project scheduling, needs to be flexible to accommodate changes in 

policy, needs, timber appraisals, and funding. Intensive inventory work has been begun to identify the 

next old-growth ‘bridge’ timber projects but is at a stage where all of these projects cannot be identified. 

An effort is being made to include young-growth timber offerings along with old-growth timber to facilitate 

the transition. In order to have a successful transition to young-growth management, industry needs time 

to convert or retool to manufacture smaller logs and support with old-growth timber. 

The suggested estimate that all sales need to be planned and sold by 2018 is contrary to the process 

used to offer Forest Service timber. Sales are typically spread out over time to account for demand, 

market fluctuations, and availability of NEPA cleared timber. These will be sales of various sizes and 

would not require a 10-year contract. Old-growth is planned to be offered throughout the range of the 

transition years and beyond

COMMENT

ALT-6: The range of alternatives does not include restoration options that focus on restoring the 

forest to natural processes that preserve remaining old-growth and allow young-growth forests 

set aside for conservation purposes to mature naturally and eventually develop increased wildlife 

habitat value. Economic considerations could reallocate the old-growth timber budget toward 

restoration, supporting the fishing and tourism industries, as well as selective logging for highend specialty lumber operations. The Forest Service should prioritize spending to improve wildlife 

habitat, restore watersheds, and address the unmet needs of tourism, recreation, and commercial 

and sport fishing and hunting users. 

RESPONSE

The proposed amendment has a narrow scope, which is fundamentally different from a plan revision. The 

scope of the amendment is defined in the Purpose and Need. As such, this proposal is outside of the 

scope of the plan amendment. The responsible official has the discretion to determine whether and how 

to amend the plan (36 CFR 219.13(a)). Amending the Forest Plan responds to the July 2013 memo from 

the Secretary of Agriculture directing the Tongass National Forest to transition its forest management 

program to be more ecologically, socially, and economically sustainable. The Forest is also being 

responsive to comments from the Five-Year Review of the Forest Plan. All action alternatives in the DEIS 

were developed to address the significant issues and meet the Purpose and Need and are designed to 

protect and maintain natural processes. Setting aside young-growth forests for conservation purposes 

does not meet the Purpose and Need. 

The approved (2008) forest plan, and the ongoing program of the Tongass National Forest under that 

plan currently includes restoration actions particularly in young-growth stands, riparian areas and stream 

courses. Restoration activities would occur under all alternatives.

COMMENT

ALT-7: The range of alternatives should have included eliminating even-flow harvest. 

RESPONSE

Managing on a non-declining even-flow is a requirement established by the National Forest Management 

Act. (See Pub. L. 93-378, §13, as added Pub. L. 94-588, §11, Oct. 22, 1976, 90 Stat. 2957.) See 

Final EIS I-19 DEIS Comments and Responses
Appendix I

response to comment TIM-5. It is the goal of the Tongass to provide an even-flow of timber on a 

sustained-yield basis and in an economically efficient manner. The amount of timber offered each year is 

based on the objective of offering enough volume to meet the projected annual demand. That annual 

demand projection starts with installed mill capacity, and then looks to industry rate of capacity utilization 

under different market scenarios, the volume under contract, and a number of other factors, including 

anticipated harvest and the range of expected timber purchases.

An even-flow harvest scenario provides potential purchasers sufficient volume to maintain their 

operations, keep skilled workers and allow them to maintain/ increase their skills, ensure their employees 

steady employment, and allow the purchasers to secure the financial support as needed. Fluctuation in 

harvest already occurs with the markets, the amount of timber available and at which location due to 

mobilization and to some extent the weather. This is one of the reasons that 3 years of volume under 

contract is preferable to allow these fluctuations. 

COMMENT

ALT-8: Support for Alternative 5 because it transitions away from old-growth timber harvesting 

and protects some of the most important salmon producing watersheds and other biologically 

rich areas. Some expressed that it is a workable option that still provides some old-growth to local 

mills, but could be modified to exclude old-growth and/or clearcutting or to transition faster. 

Alternative 5 also opportunities for management of young growth that is in the stem exclusion 

phase.

RESPONSE

Thank you for your comment. The rate of transition is based on the availability of suitable young-growth 

that can be harvested economically. We agree that young-growth management will enhance forage 

availability and achieve the desired condition of stands faster in many locations. Alternative 5 also 

protects roadless areas, T77 watersheds and TNC/Audubon conservation priority areas from old-growth 

harvest.

See response to TIM-8 and YGAT-2.

COMMENT

ALT-9: The range of alternatives does not include an environmentally preferred alternative. There 

are many similarities between the action alternatives and that it is difficult to characterize which 

alternative is the environmentally preferable.

RESPONSE

The Forest Service has provided a reasonable range of alternatives that address the significant issues in 

different ways and varying degrees, and the analysis that has been completed is adequate to discuss 

preferences among alternatives based on relevant factors to identify an environmentally preferable 

alternative. 

The mere presence of timber harvest in young-growth or the amount of harvest does not preclude 

resulting benefits, such as commercial thinning in stands to encourage growth of the residual trees and 

promote understory. Each alternative differs in terms of suitability of lands (i.e., determination made 

regarding the appropriateness of various lands within a plan area for various uses or activities, based on 

the desired conditions applicable to those lands) and other plan components (goals; desired conditions; 

objectives; standards; guidelines) that provide direction and may apply forest-wide or to specific LUDs. 

The alternative or alternatives that are considered to be environmentally preferable will be identified in the 

record of decision.

See response to comments ALT-3, ALT-6, and ALT-11.

DEIS Comments and Responses I-20 Final EIS
Appendix I

COMMENT

ALT-10: Specific high-value suitable lands should be removed from the timber base, and 

managed primarily for restoration and for special management. On these lands, the Forest Service 

should not permit new roads, except for spur roads which extend less than one-quarter of a mile 

from an existing road. These areas should be identified for a microsale program designed in 

collaboration with local communities.

RESPONSE

See response to ALT-6 regarding restoration options in alternatives. 

The lands identified as suitable for timber production were determined by using a collaborative approach 

either by the Tongass Advisory Committee (Alternative 5) or by the Forest Service interdisciplinary team 

that includes a cooperative agency, the U.S. Fish and Wildlife Service (Alternatives 2, 3 and 4). 

Areas that are to be restored or enhanced are also determined through the interdisciplinary process 

including public involvement or collaboration. 

The lands proposed for special management (identified by commenters) will be managed in accordance 

with Forest Plan direction with various silvicultural prescriptions considered. Extensions of roads or new 

roads will be the minimum amount needed to access the timber and will consider the effects to various 

resources as well as the length. Areas for microsales are identified by potential purchasers and will reflect 

their needs.

Incidentally, for the microsale program, the potential purchasers identify the dead and down trees for 

harvest; not the Forest Service. That way, the purchaser is identifying trees that suit the needs of their 

operation.

COMMENT

ALT-11: The DEIS failed to analyze a reasonable range of alternatives by unreasonably rejecting

the conservation group alternative that would complete the transition within five years. This 

alternative was based on using the agency’s authority to follow industry practice by cutting trees 

well before they reached CMAI, minimizing environmental impacts and maximizing reliability by 

avoiding sensitive areas, and enhancing economic viability by focusing on stands near existing 

road infrastructure and off of steep slopes. The proposal took into account research and analysis 

undertaken by Mater, Ltd., based on Forest Service data, which concluded sufficient volume 

should be available close to currently open FS roads in the Southern Tongass, in the existing 

suitable land base, and avoiding sensitive lands, to conclude a transition to young growth within 5 

years. None of the specific reasons in the DEIS for not carrying forward this alternative for 

detailed analysis, or some version of it consistent with existing data and the basic request of the 

conservation groups, is well-founded or supported. 

RESPONSE

Although the Forest Service did commit to a quick transition in 2010 the Transition Framework (May 

2010), and initiated a process to transition the timber program on the Tongass National Forest to young 

growth management, many questions persisted about what the transition means, why we are doing it, 

how we plan to accomplish it, and how it fits in with other programs. In January 2013, a “Leader’s Intent” 

document was released by the R10 Regional Forester and the Tongass Forest Supervisor that explicitly 

outlined the vision and goals for the future young-growth timber program on the Tongass National Forest. 

While the document affirms that a future forest industry will be supported mainly by young growth harvest, 

it acknowledges that the transition to young growth will be gradual rather than abrupt to allow time for the 

young trees to mature and allow operators to adjust, adapt, and develop markets for new products 

(Leaders Intent, January 2013).

While it is pointed out that industry in other parts of the country has been able to transition more quickly 

than 10-15 years, the direction for the Tongass has been clear that industry will have at least 10-15 years 

Final EIS I-21 DEIS Comments and Responses
Appendix I

(see Leader’s Intent, January 2013) and USDA Secretary’s Memorandum 1044-009 (July 2013) to 

transition. This length of time is not only to allow for a re-tooling of industry, but will also allow for the 

current young-growth stands to mature to a point where there are significant acreages of an age and size 

that could be economically harvested. The Tongass has worked diligently to update forest inventories that 

have improved our understanding of the age, location, and amount of young growth across the Tongass, 

and helped clarify the challenges in establishing an economically viable young growth program due to the 

relatively young age of the available stands. While there is a long history of timber harvest on the forest, 

large acreages were not harvested until the startup of the pulp mills in the mid-1950s. This means that 

many of the oldest young-growth stands are still just barely 60 years old. This age is considered to be on 

the low end of stands that may have economical value. 

The comment is a misinterpretation of the reason why the Forest Service cannot move more quickly than 

10-15 years. In Chapter 2, the DEIS provided detailed rationale for not carrying forward alternatives that 

would complete the transition soon (specifically looking at immediate and 5-year timeframes). Based on 

current demand projections, neither of these alternatives would provide sufficient timber volume to 

maintain the current industry (Table 2-1) due to the lack of economically viable young-growth timber. The 

Tongass Young Growth Management Strategy (2016), exhibit 9, shows acres of harvest by suitability by 

age class. Young-growth acres that were harvested prior to 1960 are fairly limited, but after 1960, there is 

an increasing amount of young-growth acreage that will be available for harvest making the transition 

much more feasible in 10-15 years. 

Four scenarios were developed in response to USDA Secretary’s Memorandum 1044-009 (July 2013). 

The resulting paper, Scenario Analysis: Young Growth Management on the Tongass National Forest, was 

completed in August, 2013 but was authorized for internal use at the time. The report analyzed four 

scenarios related to the transition of the timber program on the Tongass National Forest away from a 

reliance on old growth forest stands toward a reliance primarily on the harvest of young growth forest 

stands, to evaluate ways to achieve such a transition within 10-15 years.

The report concluded that the only option that seems to have a realistic chance of achieving the 

Secretary's goals of implementing the transition to young growth management over the next 10-15 years 

while maintaining the current forest products industry was to make changes to the Tongass Forest Plan to 

allow young growth timber to be harvested in most areas where it currently is not allowed (for example, in 

the beach fringe and riparian management areas), except for roadless and congressionally designated 

areas. Specifically, the report concluded that:

“There appear to be three ways to transition the Tongass timber program to young growth: wait at least 

10 years for young growth stands to mature further before beginning the transition in earnest; provide 

additional funding for a sustained annual expenditure of several million dollars for a thinning program; or 

make changes to the Tongass Forest Plan to allow young growth timber to be harvested in most areas 

where it currently is not allowed, except for roadless and congressionally designated areas.

Only the last option, represented in this paper by Scenario 4, seems to have a realistic chance of 

achieving the Secretary's goals of implementing the transition over the next 10-15 years while maintaining 

the current forest products industry.

In addition to modifying the Forest Plan, transitioning under Scenario 4 requires the following: 

“Enactment of the Sealaska Lands bill, S.340 as currently drafted, including the limited exemption 

from current CMAI requirements.” (since completed); and

“Completion of the Alaska Mental Health Trust land exchange.”

See above discussion relating to the scenario’s analysis. The conclusion was that even with a removal of 

the requirement to meet Culmination of Mean Annual Increment (CMAI) prior to rotational harvest, the 

most aggressive scenario analyzed in the Scenario Analysis: Young Growth Management on the 

Tongass National Forest still requires a timeline of 10-15 years. 

In regards to ‘delayed regeneration’, in Ms. Mater’s report from November, 2015, it is stated that “Years to 

reach breast height is notably different based on stand age: 12 years for stands harvested 50-55 years 

DEIS Comments and Responses I-22 Final EIS
Appendix I

ago; 9 years for stands harvested 45-49 years ago; and just 3 years for stands harvested 40-45 years 

ago.” This is not consistent with findings from PNW growth and yield studies and we believe this 

statement is erroneous. The CSDS data show that the time required to reach breast height (4.5 feet) 

ranges from 6 to 11 years and typically it takes 7 to 9 years. Counting the annual rings in increment cores 

under field conditions is subject to considerable error. The age data for the CSDS study was obtained 

from prepared cores in the laboratory, with magnification used as necessary.

Although a GIS analysis of the entire forest may show enough acres of young-growth, it cannot reflect the 

great amount of variability in site productivity, growth rates, species composition and access to a mill 

and/or market across the entire forest, which spans a very large geographical area. These factors are 

incredibly important when considering and planning for a transition to young-growth. If the young-growth 

stands are not economically viable at age 55, then they cannot be harvested and therefore do not help 

contribute to the supply of volume in an immediate transition to young-growth. Many acres, particularly on 

the more remote districts that do not have mills or other processors like Sitka and Juneau Ranger 

Districts, will not meet the economic requirements. In accordance with Public Law 113-291, young-growth 

timber sales may not be offered unless they represent non-deficit sales. A transition to young growth 

cannot only be based upon modeled, available volumes. 

In order to provide updated information to FBRI for the Southeast Alaska library update, the Tongass has 

funded the Pacific Northwest Research Station’s (PNW) Juneau Forestry Sciences Laboratory to 

remeasure their extensive network of permanent growth and yield plots. The permanent plots of the 

Cooperative Stand Density Study (a.k.a. the Farr Plots) were established 40 years ago and provide us 

with the long-term growth response of thinned and unthinned even-aged stands at over 50 locations 

throughout southeast Alaska. PNW is also monitoring permanent plots established by R.F. Taylor in the 

1920s. The long-term growth and yield record from the PNW permanent plots was used to create the 

southeast Alaskan variant of FPS in 2005 and more recently collected data were used in the 2015 

recalibration of the Southeast Alaska library.

Final EIS I-23 DEIS Comments and Responses
Appendix I

Planning Rule (PLR)

COMMENT

PLR-1: The explanation in the DEIS of how the 2012 planning rule applies to the amendment is 

arbitrary and capricious because the “Forest Service is merely picking and choosing which 

provisions of each planning rule to apply.” 

The Forest Service should have complied with section 219.9 since a valid decision document 

cannot be written without explaining how the amendment complies with the 2012 planning rule’s 

substantive requirements. The Forest Service quotes section 219.14(a)(2) that says the decision 

document must include: “An explanation of how the plan components meet the sustainability 

requirements of § 219.8, the diversity requirements of § 219.9, the multiple-use requirements of § 

219.10, and the timber requirements of § 219.11.”

The 2012 planning rule requires plans to provide for social, economic, and ecological 

sustainability (36 CFR 219.8), and the preferred alternative is contrary to the provisions in the 2012 

planning rule on ecological integrity and ecosystem diversity (36 CFR §§ 219.8(a), 219.9(a)). 

The Forest Service is charged with sustaining wolf and wildlife populations at scales smaller than 

the entire forest. The 2012 planning rule requires plans to maintain and restore ecosystem 

function on the watershed level because of the following statement from 36 CFR 212.9(a)(1): “As 

required by § 219.8(a), the plan must include plan components, including standards or guidelines, 

to maintain or restore the ecological integrity of terrestrial and aquatic ecosystems and 

watersheds in the plan area, including plan components to maintain or restore their structure, 

function, composition, and connectivity.”

A plan revision is needed to remove the existing Transportation and Utility System overlay LUD 

under the action alternatives in the DEIS. Under the 2012 planning rule, the amendment process 

should not be used to add or remove a geographic or management area delineation from a Forest 

Plan. Instead, the amendment process envisions changing the way in which the Forest Plan 

components interact with a particular geographic or management area delineation. (36 CFR § 

219.13(a)).

RESPONSE

The Forest Service believes that the Agency has followed the requirements for a plan amendment 

process (36 CFR 219.13) and applied the rule appropriately. The Agency─

Began scoping for the plan amendment with a notice in the Federal Register on 

May 27, 2014, as required by 36 CFR 219.16 (79 FR 30074). 

Applied the best available scientific information in analyzing the effects of the proposal and the 

alternatives, as required by 36 CFR 219.3. 

Gave public notice and gave ample opportunities for public participation, as required by 36 CFR 

219.4. (See Forest Plan newsroom web page and DEIS p. 1-6.) 

Wrote the proposed direction in Chapter 5 of the proposed amended plan in the form required by 36 

CFR 219.7(e). 

Will give the public an opportunity to object to the proposed decision, as required by 36 CFR 219 

subpart B. 

Developed the proposed amendment to change substantive direction about timber harvest for 

purposes of timber production and for other multiple use purposes, including improving wildlife or fish 

habitat, so that it meets the 2012 Rule’s substantive requirements regarding timber harvest for timber 

production and other multiple-use purposes, as required by 36 CFR 219.11. 

DEIS Comments and Responses I-24 Final EIS
Appendix I

Integrated plan components for renewable energy direction and transportation systems corridors into 

the proposed plan amendment after consideration of the appropriate placement and sustainable 

management of infrastructure, as required by 36 CFR 219.10(a)(2) and (3). 

After careful consideration the Agency has concluded that the only practical way to interpret the 2012 

planning rule’s application to plan amendments is to focus on the proposed action—the responsible 

official’s proposed action will determine the scope and scale of the change to the plan. To have the 

scope of an amendment be determined by all the possible resource effects could have a cascading effect, 

necessitating a broadening of the responsible official’s proposed action, and a change to the plan with 

respect to any and every affected resource. 

The rule does not explicitly direct how changes to an “old rule” plan are to be made with “new rule” 

amendments, but it clearly does not change the fundamental principle that a line officer proposes and 

decides on an action. The rule provides that “[p]lan amendments may be broad or narrow, depending on 

the need for change,” and that “[t]he responsible official has the discretion to determine whether and how

to amend the plan.” (36 CFR 219.13(a)) (emphasis added). The rule reinforces the principle by providing 

that the rule “does not compel a change to any existing plan.” (36 CFR 219.17(c)). 

Furthermore, the rule continues to say at 36 CFR 219.17(c) that “None of the requirements of this part 

apply to projects or activities on units with plans developed or revised under a prior planning rule until the 

plan is revised under this part, except that projects or activities on such units must comply with the 

consistency requirement of § 219.15 with respect to any amendments that are developed and approved 

pursuant to this part.” This provision reflects the Agency’s intent that an amendment of an “old rule” plan 

will not require the entire plan to conform to the new rule’s substantive provisions (§§ 219.8 through 

219.11) and to be subject to the new rule’s consistency provisions (§ 219.15). 

The following words from the preamble for the planning rule show that the Department does not expect 

plan amendments to be comprehensive and meet all of the substantive provisions (36 CFR 219.8-219.11) 

of the planning rule: “[P]lans will be kept more current, effective, and relevant by the use of more frequent 

and efficient amendments, and administrative changes over the life of the plan, also reducing the amount 

of work needed for a full revision. Plan amendments incrementally change the plan as need arises. Plan 

amendments could range from project specific amendments or amendments of one plan component, to 

the amendment of multiple plan components.” (77 FR 21237 (April 9, 2012)). 

Because the responsible official has the discretion to determine whether and how to amend the plan, the 

responsible official has the discretion to determine the specific changes to propose and approve. Here, 

the forest supervisor has the duty to determine the purpose and need for the proposal. The purpose and 

need for the specific changes proposed to the Tongass plan do not support making extensive changes to 

conform the plan to §§219.8-219.10. 

The provision in 36 CFR 219.13(a), that the responsible official has the discretion to determine how to 

amend the plan, has been interpreted by some people to confer discretion regarding the amendment 

process, but not the scope and scale of the actual proposal. Such an interpretation, however, overlooks 

the fact that the rule already sets out a required process for plan amendment, at 36 CFR 219.13(b).

Section 219.17(c) clearly states that the rule does not compel any changes to any existing plan. 

Therefore, the responsible official, not the rule, determines the scope of any amendment. By choosing the 

scope and scale of the proposed plan amendment, the responsible official determines which of the new 

rule’s substantive provisions or parts thereof are applicable. 

The determination of which of the new rule’s substantive provisions are applicable, that the amendment 

meets them, and the finding that the amendment is not opposed to the Rule’s substantive provisions must 

be supported by rationale, as documented in the DEIS. 

In this case, the Tongass proposed plan amendment appropriately meets the applicable provisions of 36 

CFR 219.11 and 219.10(a)(2) and (a)(3) and will not be opposed to any of the other substantive 

provisions of the 2012 rule. 

Final EIS I-25 DEIS Comments and Responses
Appendix I

With respect to whether removing the existing Transportation and Utility System overlay LUD may be 

achieved through an amendment, the Rule provides an unequivocal affirmative answer. The last 

sentence of 36 CFR 219.13(a) states that: “Except as provided by paragraph (c) of this section [regarding 

administrative changes], a plan amendment is required to add, modify, or remove one or more plan 

components, or to change how or where one or more plan components apply to all or part of the plan 

area (including management areas or geographic areas).” (Emphasis added.) The Department added the 

phrase “including management areas or geographic areas” to the final planning rule to clarify that an 

amendment is required for any change in how or whether plan components apply to those areas (77 FR 

21238). An amendment may remove all the plan components within a LUD and remove the LUD itself. 

COMMENT

PLR-2: The proposed plan amendment does not meet requirements for viability, and does not 

meet the viability requirements of 1982 rule (section 219.19 of the 1982 rule). The proposed 

amendment would make substantive changes to the existing wildlife standards and guidelines 

thereby affecting the Tongass National Forest Old-growth Habitat Conservation Strategy. Those 

changes make the diversity requirements in 36 CFR 219.9 of the 2012 rule applicable. The Forest 

Service should therefore comply with 36 CFR 219.9.

RESPONSE

The Tongass Land and Resource Management Plan was developed using the 1982 rule. No obligations 

exist from the 1982 rule, as that rule no longer exists (36 CFR 219.17(c)). Implementing the viability 

requirement of the now superseded planning regulations, the Tongass Forest Plan contains a goal of 

providing an abundance and distribution of old-growth habitat to maintain viable populations of wildlife in 

the forest. The proposed amendment retains that goal in the Old-growth Habitat Conservation Strategy 

(hereafter ‘Conservation Strategy’) and the Wildlife Forest-Wide Standards and Guidelines, with plan 

direction to “Provide the abundance and distribution of habitat necessary to maintain viable populations of 

existing native and desirable non-native species well-distributed in the planning area (i.e., the Tongass 

National Forest).” (WILD1IIB, Proposed Forest Plan, p. 4-82).

Whether the diversity requirements of the 2012 rule applies to this amendment is determined by what the 

responsible official proposes. Here, the proposal is focused on accelerating the transition to young-growth 

timber harvest. The timber focus of the amendment therefore causes the 2012 rule’s timber provisions, at 

section 219.11, to apply. The proposed amendment would not change the plan’s Conservation Strategy

for wildlife, and so does not require the application of section 219.9. Even so, the Tongass Old-growth 

Habitat Conservation Strategy (“Conservation Strategy”) in the forest plan meets the intent of the 2012 

planning rule to provide the ecological conditions to both maintain the diversity of plant and animal 

communities and support the persistence of most native species in the plan area. The amended plan also 

provides the additional species-specific plan components to maintain viable populations. The amended 

plan, under any alternative proposed, will therefore be at least as protective as 36 CFR 219.9. 

At this time, the responsible official does not propose to redesign the Tongass Conservation Strategy in 

light of 36 CFR 219.9 for diversity of plant and animal communities. In particular, the regional forester is 

retaining and using the list of Alaska Region Sensitive Species (“sensitive species”) for the Tongass and 

is not designating species of conservation concern (SCC) at this time under 36 CFR 219.9. 

The proposed amendment includes plan components to improve habitat conditions in young growth 

stands and, as part of that direction, to mitigate effects on fish and wildlife, consistent with 36 CFR 

219.11(c) and 36 CFR 219.11(d)(3). This amendment triggers section 219.11(d)(3), which requires that 

timber harvest “would be carried out in a manner consistent with the protection of soil, watershed, fish, 

wildlife, recreation, and aesthetic resources.” Also, section 219.11(c) gives discretion to allow timber 

harvest for purposes other than timber production including improving fish and wildlife habitat. The 

amended plan therefore includes S&Gs to mitigate effects of harvest on fish and wildlife. 

The plan as amended will continue to fulfill our obligations under the NFMA to “provide for diversity of 

plant and animal communities based on the suitability and capability of the specific land area to meet 

overall multiple-use objectives.” (16 U.S.C. 1604(g)(3)(B)). The plan as amended would continue the 

DEIS Comments and Responses I-26 Final EIS
Appendix I

Tongass strategy to provide for the diversity of plant and animal communities, through management of 

both ecosystem conditions (the Conservation Strategy) and species-specific conditions (through S&G’s) 

as set forth in the 2012 planning rule at 36 CFR 219.9. This approach is sometimes characterized as the 

‘coarse-filter/fine-filter’ approach to conservation.

The coarse-filter/ fine-filter approach is a complementary ecosystem and species-specific approach to 

provide for the diversity of plant and animal communities and the long-term persistence of native species 

in the plan area. This approach is a well-developed concept in the scientific literature and has broad 

support from the scientific community. Indeed, this approach has been used on the Tongass since 1997.

The coarse filter focuses on ecological integrity, maintaining or restoring characteristics of the 

environment as expressed by features such as composition, structure, function, and connectivity of 

ecosystems, to maintain diversity and persistence of native species. Land management units with 

ecosystems exhibiting a high level of integrity or with plans that maintain and restore ecosystems are 

assumed to support the conservation of the vast majority of species. 

The fine filter, and associated plan components, complements the coarse filter by providing for additional 

specific habitat needs or other ecological conditions of at-risk species, when the responsible official 

determines those needs are not met through the coarse-filter. 

Implementing the viability requirement of the now superseded planning regulations, the 1997 Forest Plan 

developed a conservation framework for wildlife and integrated several elements into its Tongass 

Conservation Strategy. The proposed amended plan retains that framework, including a standard 

requiring the plan provide the abundance and distribution of habitat necessary to maintain viable 

populations of existing native and desirable non-native species well-distributed in the plan area. Below we 

explain the Tongass Conservation Strategy, the history of the Tongass Conservation Strategy, the 

proposed amendment, the effects of the proposed amendment on the Tongass Conservation Strategy, 

and the effects of the proposed amendment to species. 

The Tongass Conservation Strategy 

The Tongass National Forest Old-growth Habitat Conservation Strategy also uses the approach to 

conservation outlined at 219.9 in the 2012 Rule, the so-called coarse-filter/fine-filter approach to maintain 

ecological integrity while allowing multiple uses to occur. The Agency designed the Tongass 

Conservation Strategy to provide the spatial extent, distribution, and connectivity of old-growth forest 

ecosystems to support well-distributed, viable populations of old-growth associated species. Based on 

principles of conservation, a network of large, medium, and small sized old-growth reserves (OGRs) 

allocated to the Old-Growth Habitat Land Use Designation (LUD) plus all small islands less than 1,000 

acres remain intact. This largely undisturbed habitat is distributed across the Tongass National Forest. In 

addition to the broad, ecosystem-focused OGRs, additional conservation measures are provided through 

the standards and guidelines that apply to timber harvest in the matrix (DEIS, p. 3-186). 

The old-growth reserves retain ecosystem integrity by maintaining a functional and interconnected 

ecosystem. The standards and guidelines applicable to matrix lands ensure ecological conditions that 

support at-risk species and other old-growth associated species. The plan includes specific direction to 

provide ecological conditions for many species, including: bald eagle, brown bear, goshawk, heron, 

marbled murrelet, marten, mountain goat, river otter, deer, and wolf. 

At-risk species include federally listed species under the Endangered Species Act (ESA), and sensitive 

species. No federally listed fish species originate from Alaska streams. Some federally listed fish stocks 

occur in marine waters near the forest (DEIS, p. 2-110). No federally listed plants occur on the Tongass 

National Forest. The regional forester identified 16 plants which are known or suspected to occur on the 

Tongass as sensitive species (DEIS, p. 3-134). Some federally listed wildlife species occur in the marine 

waters: humpback whale, fin whale, sperm whale, and Steller sea lion (Western Alaskan distinct 

population segment) (DEIS, p. 3-210). 

The proposed amended plan adds standards to protect the Aleutian Tern and black oystercatcher, which 

were identified as sensitive species since the plan was last amended. Although several species were also 

Final EIS I-27 DEIS Comments and Responses
Appendix I

removed from the species list, the proposed amended plan retains standards and guidelines protecting 

those species. 

History of the Tongass Conservation Strategy 

The Tongass Old-Growth Conservation Strategy was designed through a collaborative effort by a broad 

range of scientists, Alaska Department of Fish and Game, and U.S. Fish and Wildlife Service, and 

underwent intensive peer review. The strategy was initially established as part of the 1997 plan revision 

process. The Tongass Conservation Strategy was developed to maintain a functional and interconnected 

old-growth forest ecosystem on the Tongass by retaining intact, largely undisturbed habitat. Outside of 

reserves, components of the old-growth ecosystem are maintained by standards and guidelines to protect 

important areas and provide old-growth forest habitat connectivity. A series of expert risk assessment 

panels prepared viability risk assessments based on this framework. Using the panels’ assessments, the 

Agency determined that there was a moderate to very high probability of maintaining sufficient habitat to 

maintain viable populations of wildlife species on the Tongass under the 1997 Plan. 

The Agency believes those probability estimates are very conservative because the panels of experts 

assumed timber harvest at 267 MMBF annually for 100 consecutive years, with no change in applicable 

S&Gs. (ROD 2008, p. 19) 

The Tongass Conservation Strategy was designed to take into account extensive timber harvest on nonNFS lands and relied little on non-NFS lands to maintain ecological integrity. (DEIS, p 3-202 to 203). The 

strategy maintains habitat for well-distributed, viable wildlife populations in the plan area (DEIS, Appendix 

D, p. D-16).

The 2008 Tongass amended plan added to the Tongass Conservation Strategy a forest-wide legacy 

forest structure standard, replacing the 1997 goshawk foraging and marten habitat S&Gs. This standard 

applies to watersheds with high levels of timber harvest. It requires the retention of forest structural 

components such as patches of large trees, downed logs, and snags (dead trees) after timber harvest. 

The 2008 amended plan enhanced the network of small OGRs by reconfiguring the network based on an 

interagency review to increase habitat protection and to reduce operational conflicts. In addition, the 2008 

amended plan increased the amount of land allocated to other non-development LUDs by 69,000 acres, 

effectively increasing the extent of the old-growth habitat reserves. 

In 2015, the National Defense Authorization Act for Fiscal Year 2015 conveyed 69,585 acres of NFS land 

to the Sealaska Native Corporation. To compensate for the loss of OGR lands, the Agency proposed 

boundary modifications that would result in a net increase of 6,171 acres of OGR and 7,148 acres of 

productive old growth (POG) forest included in the reserve system from existing (post-conveyance) levels. 

(DEIS, Appendix E). 

The Proposed Amendment

The proposed amendment accelerates the transition to young-growth timber harvest and makes the 

development of renewable energy more permissible. The proposed amendment maintains the integrity of 

the Tongass Conservation Strategy. To ensure the transition does not adversely affect wildlife, the 

proposed amendment includes standards and guidelines to improve wildlife habitat conditions and long–

term ecological function in young growth stands. (36 CFR 219.11(d)). In addition, the proposed 

amendment makes technical corrections to fix clerical errors, to conform the plan to changes of new 

statutory or regulatory requirements, and to add explanatory material about how the amendment will 

apply to projects on the ground. 

The proposed amendment accelerates the transition time from primarily old growth harvest to primarily 

young growth harvest from 32 years to 16 years resulting in a reduction in the extent of old-growth forest 

harvest. The proposed amendment would change the suitability of specific young-growth stands in beach 

and estuary fringe, old growth habitat LUD, and riparian areas from “not suitable for timber production” to 

“suitable for timber production.” (DEIS, Appendix D, Table 2, p. D-9). 

DEIS Comments and Responses I-28 Final EIS
Appendix I

By shifting away from old-growth harvest, the Agency would preserve undeveloped land in unroaded 

areas, contributing to unfragmented wildlife habitats. Young-growth timber harvest would occur within the 

previously harvested footprint and maximizes the use of existing roads to access young-growth stands. 

The proposed amendment identifies 11 percent of the productive forest land as suitable. However, the 

proposed amendment would only harvest 0.8 percent of the productive old growth (POG) after 100 years. 

Under the proposed amendment, the annual PTSQ would be 46 MMBF during the first decade and 56 

MMBF during the second decade (DEIS, p. 3-307). Therefore, more old-growth is retained under the 

proposed amendment than under the current plan. (DEIS, Appendix D, p. D-7). 

Alternatives 2, 3, and 4 would relax the S&Gs for “high vulnerability” karst areas. Alternatives 2, 3, and 5 

would relax the scenic integrity objectives to allow additional harvest. Given that these non-wildlife S&Gs 

are not part of the Conservation Strategy, relaxing these S&Gs will have no effect on the functioning of 

the Conservation Strategy. (DEIS, Appendix D, p. D-16).

Effects of the proposed amendment on the Tongass Conservation Strategy 

The Agency has disclosed the effects of the proposed amendment on plant and animal communities in 

the environmental impact statement. The Tongass Conservation Strategy, particularly the extent and 

distribution of old-growth habitat, has been found to be stronger than anticipated in the 1997 analysis. 

Past and projected harvest of old-growth forest are far lower than predicted in 1997. In addition, the 

Forest Plan designates Inventoried Roadless Areas, even if part of the land within the forest development 

LUD, as not suited for timber production, subject to the District Court of Alaska’s 2011 judgment 

reinstating the Roadless Rule on the Tongass (Organized Village of Kake v. USDA, 1:09-cv-00023 (May 

24, 2011)). Timber harvest in these roadless areas is prohibited (Appendix D, p D-6). The forest contains 

about 111,000 more acres of POG today, than was predicted in 1997 (DEIS, Appendix D, D-17). Today, 

92 percent of the original productive old growth that was inventoried in 1954 (5.4 million acres) still occurs 

on the Tongass. Under all alternatives, we estimate 91 percent will remain in 100 years. (DEIS, p. 3-195; 

DEIS Table 3.9-12). 

Within the Old-growth Habitat LUD and other non-development LUDS, young-growth forest stands do 

have ecological value. Under the action alternatives, openings created by even-aged timber harvest 

provide abundant forage for deer as sunlight reaches the forest floor enhancing the growth of forage 

(DEIS, p. 3-217). In addition, thinning of young-growth stands in the stem exclusion stage would also 

improve the forage for deer for 15 to 25 years (DEIS, p. 3-244). The Tongass Conservation Strategy, as 

designed in 1997, did not rely on the value of young-growth forest stands when assessing the risk to 

viability of old-growth associated at-risk species (DEIS, Appendix D, p. D-8). For this reason, and due to 

the spatial distribution and quantity of suitable young-growth harvest in the non-development LUDs, 

harvest of young-growth in these areas would pose a zero to very low risk, depending on the selected 

alternative, to the function and integrity of the Tongass Conservation Strategy that maintains old-growth 

associated species (e.g., marten, goshawks, flying squirrels). (DEIS, Appendix D, p. D-7 to D-10). 

Therefore, there would be no change to the functioning of this contributing element of the Conservation 

Strategy. (DEIS, Appendix D, p. D-8).

The beach and estuary fringe is a 1,000-ft wide corridor adjacent to saltwater shorelines; it consists of 

productive old growth, unproductive forest, young growth forests, and non-forest types. For all 

alternatives, due to the very local nature of effects, the beach and estuary fringe would continue to act as 

an ecological transition zone between interior forest and saltwater influences, maintain landscape 

connectivity, and provide benefits to the marine environment across the planning area, including sustain 

habitats for goshawks and bald eagles. (DEIS, Appendix D, p. D-11 to D-13). Therefore, there would be 

no measurable change to the functioning of this contributing element of the Conservation Strategy. (DEIS, 

Appendix D, p. D-13).

For all alternatives, the riparian areas would continue to maintain ecological functions of aquatic and 

terrestrial habitats, maintain water quality, and provide connectivity across the planning area for all the 

alternatives due to the local and short term nature of effects to the riparian areas. (DEIS, Appendix D, p. 

D-14). Therefore, there would be no measurable change to the functioning of this contributing element of 

the Conservation Strategy. (DEIS, Appendix D, p. D-14).

Final EIS I-29 DEIS Comments and Responses
Appendix I

Effects of the proposed amendment to species

Across the landscape of Federal and non-Federal lands within the boundary of the Tongass, ecological 

conditions (habitat) support viable populations of fish, plants, and wildlife. The likelihood of a wildlife 

population persisting over time has been suggested to be related to maintaining 20 to 50 percent of the 

habitat on the landscape (DEIS, p-3-261). Looking at all lands, all of the biogeographic provinces on the 

Tongass are projected to maintain at least 57 percent of the original (1954) POG after 100 years of Forest 

Plan implementation under the proposed amendment. (DEIS, p. 3-261). 

The Agency prepared a draft biological evaluation (BE) to analyze and document the effects of the 

proposed action on sensitive species. The review included consideration of the following sensitive 

species: Steller sea lion (Eastern Alaskan DPS), Queen Charlotte goshawk, Aleutian tern, black 

oystercatcher, and Kittlitz’s murrelet. The overall findings for all sensitive species was that the plan, as 

amended, may affect individuals but is not likely to result in a trend toward federal listing or loss of viability 

of the species. 

Allowing harvest in young-growth stands in the Old-growth Habitat LUD and other non-development 

LUDS, the beach and estuary fringe, and the riparian management areas may reduce the local function of 

these areas to for some species, and but opening up these areas for commercial harvest would also 

allow for commercial thinning to improve habitat quality in lower value stands. (DEIS, p. 3-237). 

All of the alternatives would maintain the integrity of the Conservation Strategy by maintaining the 

functioning of the system of old-growth reserves in the Old-growth Habitat LUD and other nondevelopment LUDS (DEIS, Appendix D, p. D-8). Also, the effects to the beach and estuary fringe would 

be short-term (10-15 years) after each entry and more localized in these areas (DEIS, Appendix D, p. D12. Also, because of the local nature of effects under all of the alternatives, riparian areas would continue 

to maintain aquatic and terrestrial habitats, maintain water quality, and provide landscape connectivity 

across the planning area (DEIS Appendix D, p. D-14). 

In addition, “all of the alternatives are expected to maintain a functional and interconnected old-growth 

ecosystem, capable of supporting well-distributed, viable wildlife populations across the planning area; 

therefore none of them are expected to increase the likelihood of species listing under the ESA.” (DEIS, 

Appendix D, p 18). 

The 2012 rule at 36 CFR 219.17(c) makes it clear that the responsible official determines the scope and 

content of any amendment and therefore determines which substantive provisions of the 2012 rule are 

applicable. This determination must be supported by rationale and informed by the best available 

scientific information and cannot be opposed to the applicable substantive provisions of the 2012 rule.

The proposed amendment meets the applicable substantive provisions of the 2012 rule, i.e., 36 CFR 

219.11. In addition, the amended plan will meet the intent, if not the letter, of other substantive provisions 

of the 2012 rule, such as the diversity provisions of 36 CFR 219.9. The amended plan would retain the 

underlying plan’s coarse/fine filter approach to maintain ecological integrity and provide ecological 

conditions for at-risk species. None of the proposed alternatives would reduce the ability of the

Conservation Strategy to maintain a functional and interconnected old-growth ecosystem across the 

planning area and the overall functioning of the Conservation Strategy in terms of its ability to maintain 

viable, well-distributed populations of wildlife across the planning area would not be affected. The 

amended plan will be consistent with the NFMA requirement to “provide for diversity of plant and animal 

communities based on the suitability and capability of the specific land area to meet overall multiple-use 

objectives” (16 U.S.C. 1604(g)(3)(B)). Therefore, no additional changes are needed to the amended plan 

to implement any other substantive provisions of the rule. (36 CFR 219.8 through 219.11).

COMMENT

PLR-3: Concerns were expressed about the approach that was taken to amend the 2008 Forest 

Plan saying it is confusing and will likely result in decisions that are inconsistent and lead to 

conflict. The priority of direction now includes both direction from both the 1982 and 2012 

planning rules. There is acknowledged variance among standards and guidelines between 

Chapters 3, 4 and 5 and inconsistent definition of terms. Using the blended planning rule 

DEIS Comments and Responses I-30 Final EIS
Appendix I

approach is confusing and would likely contribute to inconsistent and poorly understood decision 

making.

RESPONSE

Additional text has been added to Chapter 1 of the Forest Plan to clarify; see Priority of Direction.

COMMENT

PLR-4. The proposal implicates wildlife habitat and makes substantive changes to the existing 

wildlife standards and guidelines previously contained for the Forest Plan Conservation Strategy, 

and that these changes make the diversity requirements of the 2012 Planning Rule (36 CFR 219.9) 

applicable.

RESPONSE

See response to PLR-2.

COMMENT

PLR-5: The 2012 Planning Rule represents the best available scientific process for maintaining 

diversity of plant and animal communities, but the Forest Plan Amendment did not name species 

of conservation concern, nor employ an updated population viability analysis. The Forest Service 

must explain that the Forest Plan Amendment complies with NFMA’s diversity mandate, and this 

explanation must be added to the FEIS and record of decision (ROD). 

RESPONSE

See response to PLR-2.

COMMENT

PLR-6: The agency is required to identify species of conservation concern to comply with the 

2012 Planning Rule’s monitoring provisions. Not updating the monitoring plan as part of the 

Forest Plan Amendment represents a waste of government resources. 

RESPONSE

See response to PLR-2 regarding diversity requirements of 36 CFR 219.9.

The plan monitoring program has been modified to meet the requirements of 36 CFR 219.12 (c). The final 

planning directives, (Forest Service Handbook [FSH] 1909.12, ch. 30, sec. 32.3) provide guidance 

regarding identifying species of conservation concern (SCC) when transitioning to the plan monitoring 

program. Because SCC is a new category of species that did not exist before the 2012 Planning Rule, 

there is no requirement for SCC to be identified and monitored before a plan is revised under the rule. 

COMMENT

PLR-7: To comply with 36 CFR 219.14, the Forest Service cannot amend a forest plan under the 

2012 Planning Rule without first implementing the four substantive provisions (sections 219.8, 

219.9, 219.10 and 219.11). Nothing in section 219.14 or the preamble to the 2012 Planning Rule 

indicates that the Forest Service intended those explanations to be discretionary.

RESPONSE

See response to PLR-1 for planning rule applicability and PLR-2 regarding diversity requirements of 36 

CFR 219.9. Chapter 2 of the DEIS (p. 2-3) explains how the 2012 Planning Rule applies.

The proposed plan amendment adds provisions to and modifies provisions of the 2008 Forest Plan. As 

explained in Chapter 6 of the amended plan, the 2012 Planning Rule requirements for project consistency 

with plan components apply only to additions and modifications (36 CFR 219.15(d)).

Final EIS I-31 DEIS Comments and Responses
Appendix I

The Agency has reviewed the wording of both the 1982 planning rule and the 2012 planning rule dealing 

with the NFMA requirements of providing for diversity of plant and animal communities. The Agency has 

disclosed the effects to plant and animal communities in the EIS. 

The final planning directives, effective January 30, 2015, are now available. These directives are the key 

set of agency guidance documents that direct implementation of the 2012 planning rule. The Agency’s 

goal is to ensure an adaptive land management planning process that is inclusive, efficient, collaborative 

and science-based to promote healthy, resilient, diverse and productive National Forests and 

Grasslands. The final directives will support consistent approaches to achieving the broad goals of the 

2012 planning rule.

The 2012 planning rule was developed through the most collaborative rulemaking effort in Agency history. 

The complete planning rule, including the preamble and rule text, along with other informational materials, 

is listed in the News section below.

Please see the Collaboration and Public Involvement webpage for information on the collaborative efforts 

used during development of the rule. Links are also located in the left banner of this website providing 

information on the history of forest planning; the basics on what's involved in forest planning and why it's 

important; as well as answers to frequently answered questions (FAQs) about the rulemaking process.

Text has been added to Chapter 1 of the Forest Plan to clarify; see Priority of Direction. Additionally, 

management approaches have been added to Chapter Five to clarify the intent to consider all resources 

in Renewable Energy and TSC planning.

COMMENT

PLR-8: Changes made to the old-growth Conservation Strategy in the amendment are significant 

and trigger compliance with the viability requirements of 36 CFR 219.9 of the 2012 Planning Rule. 

The approach to modifying the Conservation Strategy without conducting a new viability analysis 

for each affected species violates NEPA and NFMA.

RESPONSE

See response to PLR-2.

COMMENT

PLR-9: Concerns were expressed regarding the proposed Amendment’s “Priority of Direction” in 

Chapter 1 of the Proposed Forest Plan. The problem with the Amendment’s priority of direction is 

that Chapter 5 plan components were developed under the 2012 Planning Rule without regard to 

wildlife viability or diversity. Chapter 5 direction now takes priority over all other plan direction, 

but wildlife diversity was not properly considered in developing those priority components. That 

represents an arbitrary and capricious agency decision, and it is inconsistent with NFMA and both 

2012 and 1982 Planning Rules.

RESPONSE

See response to PLR-1 and PLR-2.

Text has been added to Chapter 1 of the Forest Plan to clarify; see Priority of Direction. Additionally, 

management approaches have been added to Chapter Five to clarify the intent to consider all resources 

in Renewable Energy and TSC planning.

DEIS Comments and Responses I-32 Final EIS
Appendix I

Timber (TIM)

COMMENT

TIM-1: Use of the Sustained Yield Limit is incorrect. This limit includes logging on lands not 

suited for timber production. This violates the National Forest Management Act, the Multiple-Use 

Sustained-Yield Act, and implementing regulations. 

RESPONSE

Refer to Table 3.13-10 in the DEIS. This table shows the PTSQ as compared to the Sustained Yield Limit 

(SYL) which is the amount of timber, meeting applicable utilization standards, “which can be removed 

from [a] forest annually in perpetuity on a sustained-yield basis” (16 U.S.C. part 1611(a); 36 CFR 

219.11(d)(6)). It is the volume that could be produced in perpetuity on lands that may be suitable for 

timber production. Calculation of the limit includes volume from lands that may be deemed not suitable for 

timber production after further analysis during the planning process. The calculation of the SYL is not 

limited by land management plan desired condition, other plan components, or the planning unit's fiscal 

capability and organizational capacity. The SYL is not a target but is a limitation on harvest. Chapter 5 of 

the Forest Plan now includes the following forest-wide timber standard:

S-TIM-01: Not including salvage or sanitation harvest, the quantity of timber sold in a decade may not 

exceed the sustained yield limit of 2480 million board feet (MMBF).

The PTSQ of each of the alternatives is an indicator of possible future timber supply level that each 

alternative would produce. PTSQ is the estimated quantity of timber meeting applicable utilization 

standards that is expected to be sold during the plan period. The PTSQ is also based on the planning 

unit’s fiscal capability and organizational capacity. It should be noted in Table 3.13-10, that the 

percentage of the SYL that each PTSQ represents ranges from 36 to 54 percent, depending on the 

alternative, with the preferred alternative representing 38 percent of the SYL. These percentages are for 

decades 3 and later; for decades 1 and 2 the percentages range from 19 to 27 percent.

COMMENT

TIM-2: Young-growth harvest should increase at a rate equivalent to the decrease in old-growth 

harvest.

RESPONSE

Page 9 of the Tongass Advisory Committee’s Final Recommendations (Forest Plan, Appendix B) refers to 

replacing old-growth harvest with young growth on a one-to-one volumetric basis. This is addressed in 

the Forest Plan, Chapter 5 under the Forest-wide Multiple-use Goals and Objectives (Chapter 2) section 

where forest-wide timber objectives O-TIM-01 and 02 refer to offering a combination of old growth and 

young growth to meet demand. Forest-wide objective O-TIM-01 refers to the one-to-one exchange where 

it states ...”When young growth offered is less than 41 MMBF, provide old growth to make up the 

difference and achieve the annual market demand of 46 MMBF.”

COMMENT

TIM-3: The Forest Service should cease its practice of implementing project-specific plan 

amendments to facilitate timber sale planning at the expense of the Conservation Strategy.

RESPONSE

See response to PLR-1.

A plan amendment process relies on the Responsible Official’s identification of the need to change a 

plan. If a proposed project is not consistent with the plan, the Responsible Official has the option to start a 

plan amendment that, if approved, would accommodate the project. The final planning directives (FSH 

1909.12, chapter 20, section 21.31) provide guidance for project-specific plan amendments and 

administrative review.

Final EIS I-33 DEIS Comments and Responses
Appendix I

See Management Approaches for Wildlife in Forest Plan Chapter 5, Young Growth plan content. 

COMMENT

TIM-4: The Forest Service should release a full and detailed sale schedule for the transition and 

identify the caps that will not be exceeded during Transition Years.

RESPONSE

The Woodstock model analysis involved first maximizing young-growth harvest under a non-declining 

even flow and then adding old-growth volume to reach an annual average harvest of 46 MMBF and 

maximizing the net present value. The alternatives were designed to include the maximum amount of 

young growth that can be sold on a sustainable basis, but this amount is limited by the economics of 

young-growth harvest. Figures 3.22-12 to 3.22-16 in the Final EIS display the amount of young-growth 

and old growth projected to be sold during 5-year periods, based on modeling. However, these amounts 

would be affected by the actual annual demand, market fluctuations, NEPA-cleared volumes available, 

and other factors, so specific limits on old-growth harvest cannot be committed to in advance. The only 

commitment that can be made is that young-growth volume will replace old-growth volume over time as

rapidly as the economic availability of young-growth allows (see the response to Comment TIM-2).

FSH 1909.12, Section 22.34 states that the plan should not include a “to do” list of projects and expected 

dates. While a full and detailed schedule for the next 5 years is certainly desirable and every effort will be 

made to obtain it, it is not immediately able to be produced. An intense inventory of young growth is just 

now begun in collaboration with the State of Alaska to get information that will better enable the Forest 

Service to identify those areas of both young growth and old-growth that meet the criteria of feasible, 

economic offerings and meet all Forest Plan Direction. 

Two tables have been added to Forest Plan Appendix A. 1) Vegetation Management Practices (acres) 

Annual Average per Decade; and 2) Average volume outputs for the 1st and 2nd decades for Tongass 

National Forest planned timber sale program. 

In addition, the following forest-wide timber standard has been added to Chapter 5 of the Forest Plan: 

S-TIM-01 Not including salvage or sanitation harvest, the quantity of timber sold in a decade may 

not exceed the sustained yield limit of 2480 million board feet (MMBF).

COMMENT

TIM-5: The Forest Service should manage on an even-flow, long-term sustained yield basis.

RESPONSE

The Tongass is currently and will continue to manage on a non-declining even-flow as required by the 

National Forest Management Act. (See Pub. L. 93-378, §13, as added Pub. L. 94-588, §11, Oct. 22, 

1976, 90 Stat. 2957.) For the Forest Plan in 1997 and in 2008, the Allowable Sale Quantity was 

determined for suitable lands. It was determined that 267 MMBF/year could be harvested on the suitable 

lands on an even-flow, long-term sustained yield basis. The analysis in this EIS determines how much all 

lands that carry productive forest land could produce if these lands were not withdrawn from the suitable 

base due to legislated or administrative withdrawals. This is the sustained yield limit (SYL). Projected 

Wood Sale Quantity (PWSQ) is an estimate of the volume of all timber and other wood products that is 

expected to be sold during the plan period from expected harvests for any purpose (except salvage 

harvest or sanitation harvest) on all lands in the plan area. The PWSQ includes all woody material likely 

to be sold from these harvests whether or not the woody material meets the utilization standards. The 

Projected Timber Sale Quantity (PTSQ) is an estimate of the volume of timber that is expected to be sold. 

PWSQ and PTSQ must take into account the fiscal capability of the planning unit and be consistent with 

all plan components. The PWSQ and PTSQ have been determined in the proposed Forest Plan and 

includes both young-growth and old-growth yields.

DEIS Comments and Responses I-34 Final EIS
Appendix I

Two tables have been added to Forest Plan Appendix A. 1) Vegetation Management Practices (acres) 

Annual Average per Decade; and 2) Average volume outputs for the 1st and 2nd decades for Tongass 

National Forest planned timber sale program. 

In addition, the following forest-wide timber standard has been added to Chapter 5 of the Forest Plan: 

S-TIM-01 Not including salvage or sanitation harvest, the quantity of timber sold in a decade may not 

exceed the sustained yield limit of 2480 million board feet (MMBF).

COMMENT

TIM-6: The Forest Service should not allow old-growth clearcutting as part of a stewardship 

contract. Concerns were expressed in reference to the Big Thorne Stewardship Integrated 

Resource Timber Contract where this sale included thinning of young growth stands that 

provided stewardship credits for large old-growth clearcuts. This does not follow the original 

intent of stewardship contracts.

RESPONSE

Stewardship contracts are but one mechanism for funding resource enhancement projects. Stewardship 

was not used for years in the Alaska Region even though it was used elsewhere in the Forest Service for 

the very reason you mention. However, by not using the money generated from stewardship contracts, 

we were losing the opportunities to fund not only precommerical thinning, but also other projects such as 

trail restoration and stream enhancement. As we transition to young-growth, less and less old-growth 

forest will be harvested and eventually stewardship contracts may not be used for the remaining oldgrowth harvest.

COMMENT

TIM-7: Ecological concerns should be considered as a priority as part of “favorable logistical 

access” in Timber Sale planning.

RESPONSE

The first management approach for young-growth in Chapter 5 of the Forest Plan states: “The intent is 

that young-growth areas are generally treated in priority of most return and least environmental risk.” 

Favorable logistical access is an economic criteria and is considered along with “least environmental risk.” 

Additional management approaches for young growth provide the intent for integrated resource 

management when designing projects. For example, “The intent is that responsible officials engage 

stakeholders (for example, conservation interests, timber operators, permitted user groups, and other 

interested parties) early and often to best design projects that meet ecological, social, and economic 

interests. Such inclusion would surface and resolve differences, and minimize and avoid social, 

environmental, and natural resource conflicts.”

COMMENT

TIM-8: Trees are a renewable resource and removal of old-growth habitat is not an irreversible 

commitment.

RESPONSE

Irreversible includes loss of future options, primarily for non-renewable resources but also includes those 

that are only renewable over long periods of time. Under the current Forest Plan 100 year rotation, 

young-growth timber in development LUDs would be re-harvested before the stands develop old-growth 

characteristics (150+ years). Following complete removal of the overstory, it may take 300 years or more 

for a stands in Southeast Alaska and Northern coastal British Columbia to develop old-growth ecological 

characteristics (Orians and Schoen 2013). Therefore, clearcut timber harvest creates a permanent loss 

of old-growth habitat within development LUDs and a permanent reduction of habitat capability to support 

old-growth associated species. 

Final EIS I-35 DEIS Comments and Responses
Appendix I

COMMENT

TIM-9: A complete inventory and a better growth model are needed for young growth.

RESPONSE

The Tongass has conducted young growth inventories covering 60,000 acres and we are planning new 

inventories of all young growth stands over 55 years old and 15,000 acres in stands 40 to 55 years old. 

Additionally, The Forest Planning and Projection System (FPS) growth and yield model is well tested and 

calibrated with long-term growth and yield data from Pacific Northwest.

See response to P&N-4.

COMMENT

TIM-10: Agency fails to completely identify Tongass lands not suited for timber production. The 

Forest Service should remove all unsuitable lands from the development LUD Group in the FEIS 

to assure the public that the Projected Timber Sale Quantity is consistent with all plan 

components. Neither the public nor agency must await a Plan Revision before removing these 

unsuitable acres from the timber base. 

RESPONSE

The model implementation reduction factor (MIRF) is intended to capture those acreages that have been 

mapped as “suitable” but are actually not suitable due to unmapped streams or unstable slopes or other 

resource features that would preclude timber harvest. See the Forest Plan FEIS, Appendix B, pp. B-17, 

B-23 and B-24. MIRF does not influence how much is scheduled but rather helps identify how much is 

available for scheduling. We start out with the mapped suitable lands, which represents what is suitable 

based on GIS mapping. Then we apply the MIRF and reduce the acreage of the mapped suitable, 

producing an estimate of the actual suitable acreage. Finally, the scheduled suitable acreage is that 

acreage that was needed to meet the outputs over 100 years based on the Woodstock model. An 

explanation of how the scheduled acreage was determined has been added to the FEIS, Appendix B. 

The suitable acres not scheduled are not harvested because of economics or they were not needed to

achieve modeling objectives. The acres are still considered to be suitable and may be harvested in the 

next planning cycle if they still meet the criteria for suitable at the time.

During forest land and resource management planning, the Forest Service is required to identify lands 

suited and not suited for timber production (36 CFR 219.11). Suitability of Lands is considered a plan 

component in the 2012 Planning Rule, and modifying or removing suitable lands requires a plan 

amendment. The Forest Service followed the guidance in Forest Service Handbook (FSH 1909.12, 

chapter 60) to meet the requirements in 36 CFR 219.11. A review of the suitable lands was completed for 

Alternative 5 (preferred alternative) and it is displayed in Appendix A of the Forest Plan. This has been 

carried forth and unsuitable acres have been removed from the timber base. 

Proposed LUD changes common to the action alternatives are described in Chapter 2 of the FEIS. No 

other LUD changes are proposed to remove the lands not suited for timber production from the 

Development LUDs and incorporate these lands into the natural setting LUDs because that would require 

additional scoping.

COMMENT

TIM-11: The proposed Forest Plan objective O-TIM-01 violates the Tongass Timber Reform Act 

(TTRA) because it essentially makes the planning cycle demand projection of 46 MMBF into an 

annual timber target.

RESPONSE

As discussed in Appendix G to the Draft EIS, Section 101 of the 1990 Tongass Timber Reform Act

(TTRA) states: 

DEIS Comments and Responses I-36 Final EIS
Appendix I

Subject to appropriations, other applicable law, and the requirements of the National Forest 

Management Act of 1976 (Public Law 94-588), except as provided in subsection (d) of this 

section, the Secretary shall, to the extent consistent with providing for the multiple use and 

sustained yield of all renewable forest resources, seek to provide a supply of timber from the 

Tongass National Forest which (1) meets the annual market demand for timber from such forest 

and (2) meets the market demand from such forest for each planning cycle.

Starting in 1990, the PNW Research Station has developed a series of trend projections that estimate 

market demand for each planning cycle (Brooks and Haynes 1990, 1994, 1997; Brackley et al. 2006a, 

Daniels et al. 2016). These studies address the planning cycle demand portion of TTRA’s “seek to meet” 

requirement. The Forest Service developed the Morse methodology in 1990 as a means to comply, yearto-year, with the annual demand portion of the “seek to meet” requirement. This is discussed further in 

Appendix G to the Draft EIS.

The comment is concerned that a new Forest Plan objective for Timber (O-TIM-01) included in the Draft 

Forest Plan essentially makes the latest planning cycle projections (Daniels et al. 2016) equivalent to 

meeting annual market demand, with the level fixed at 46 MMBF each year. This is not the case. The 

Morse methodology will continue to be used to comply, year-to-year, with the annual demand portion of 

the “seek to meet” requirement. The Forest-wide multiple-use objectives O-TIM-01 and O-TIM-02 have 

been revised in the Final Forest Plan to make this clearer and avoid further confusion.

COMMENT

TIM-12: The legacy forest structure standard should be designed specifically for young-growth

harvest, and new Forest Plan components should consider the amount and distribution of 

residual old-growth and require retention of additional young-growth as necessary to meet the 

intent of the standard. The Forest Service should develop guidance on treatments that would 

accelerate succession of retained young-growth toward old-growth conditions. If retention of 

structure in young-growth stands would delay the transition to primarily young-growth harvest, 

additional alternatives that use a longer transition period should be developed and fully evaluated. 

RESPONSE

Alternatives 3 and 4 included the following management approach for wildlife (FEIS Appendix F):

“When implementing young-growth timber harvest projects larger than 20 acres in VCUs that have had

concentrated past timber harvest, it is intended that 30 percent of the young growth stand acres should 

be left. The purpose is to retain sufficient residual trees to diversify the structural characteristics of the 

stand and provide for future recruitment of snags. The VCUs where this is intended to apply are ones in 

which 33 percent or more of the productive old growth has been harvested since 1954. (Consult Forest 

Plan Chapter 4 under Wildlife section (WILD1), IV. Legacy Forest Structure.)”

Forest-wide wildlife standard for Legacy Forest Structure in Chapter 4 in the Forest Plan was clarified to 

make this more clear by adding the following clarification:

“The list of VCUs where Legacy Standards and Guidelines apply should be verified during project-specific 

planning and analysis based on the harvest standards above.”

Specific stand treatments are determined at the project level after site-specific analysis by an 

interdisciplinary team (IDT), and the IDT can recommend the use of legacy retention or similar measures 

to the responsible official through the harvest prescription or as project mitigation measures.

In responding to the USDA Secretary’s Memo (1044-009), the Forest Service identified the need (in 

Purpose and Need) to expedite the transition away from old-growth timber harvesting and towards a 

forest products industry that uses predominantly second-growth – or young-growth – forests. The goal is 

to “transition over the next 10 to 15 years, so that at the end of this period the vast majority of timber sold 

by the Tongass will be young growth.” A longer transition period does not meet Purpose and Need. Action 

alternatives are not “reasonable” if they do not respond to the purpose and need for the action. 

Final EIS I-37 DEIS Comments and Responses
Appendix I

Developing additional alternatives outside the range of alternatives analyzed in the DEIS would require a 

supplement. 

COMMENT

TIM-13: The Forest Plan authorization for clearcutting young-growth is arbitrary and does not 

include a justification for clearcutting. The DEIS never considers whether clearcutting should be 

the primary method for removing trees given that less destructive means of removing the trees 

are available. Clearcutting it is not the optimum method if there other ways to achieve 

regeneration goals, such as maintaining stands of Sitka spruce or Alaska yellow cedar within 

timber units, or through pre-commercial or commercial thinning.

RESPONSE

The silviculture prescriptions, such as clearcutting or thinning, are not decided at the Forest Plan level. 

Therefore, a justification for clearcutting is not required. Any clearcut prescriptions at the project level will 

have a justification at that time. The Forest Plan has the latitude for all prescriptions to be used (see 

Chapter 4 of the Forest Plan, Timber section, Silvicultural Examination and Prescription: TIM2) and 

further direction is provided in the Forest Service Handbooks.

The timber section in Chapter 3 of the FEIS, Table 3.13-8 displays the timber management practices as 

modeled. As explained in the text, this does “not limit the manager’s ability to use any regeneration 

method to best meet project goals and objectives.”

COMMENT

TIM-14: The Forest Service should take closer account of the TAC's detailed recommendation that 

if any suitable young-growth acres are removed from the timber base as a result of future review 

processes, an equal number of acres should be added to the young-growth base.

RESPONSE

Alternative 5 is based on the Final Tongass Advisory Committee (TAC) Final Recommendations (Forest 

Plan, Appendix B). Under Alternative 5, areas identified as not suited for timber production are partially 

based on the Land Use Designation (LUD). On Page 4 of the TAC recommendations, Overarching 

Principles (4) states “Co-intent occurs on all suitable and non-suitable acres, and with proper S&Gs can 

work to meet multiple uses associated with the Forest.” However, on page 6, under Recommendations for 

Land Use Designations and Standards and Guidelines, the TAC recommended that “the USFS does not 

seek young growth volume or change S&Gs...” in specific non-development LUDs and areas (e.g., 

Remote Recreation LUD, roadless areas, high vulnerability karst, steep slopes).

The only Forest Plan LUDs not included in this list that address forested land as not suited for timber 

production are the Research Natural Areas LUD and Experimental Forest LUD. Research Natural Areas 

are unmodified environments where natural processes prevail and therefore do not lend themselves to 

timber production and young-growth harvest would be incompatible. Experimental Forests are to be 

managed for the purpose for which they were established. Young-growth harvest has occurred in the 

Maybeso Experimental Forest for research needs rather than for timber production goals. 

The TAC did recommend to “Fully utilize currently allowed prescriptions in beach buffer, Old Growth 

Reserves, and Riparian Management Areas (RMAs) (outside of TTRA) that improve fish and wildlife 

habitat and create a commercial by-product.” Further, young growth volume produced from these 

treatments should be counted toward the Projected Timber Sale Quantity (PTSQ) (Page 7 for Final TAC

Recommendations). These were included in Alternative 5 (DEIS, p. 2-34). 

To represent a more complete application of young-growth harvest on lands suited for timber production, 

Alternatives 2 and 3 would allow harvest in both development and non-development LUDs, except for 

Congressionally designated and administratively withdrawn areas and islands < 1,000 acres. In addition, 

Alternative 2 also considered the portions of inventoried roadless areas (IRAs) that were roaded before 

the 2001 Roadless Rule and during the 2001 Roadless Rule exemption period for the Tongass to be 

DEIS Comments and Responses I-38 Final EIS
Appendix I

suitable for young-growth and old-growth harvest, after rulemaking to modify 36 CFR 294.13(b)(4). 

Alternative 3 assumed 2001 Roadless Rule changes would occur, and considered lands in 2001 

Roadless Rule IRAs to be suitable for timber production after rulemaking to modify 36 CFR 294.13(b)(4). 

Therefore, these two alternatives expand the suitable young-growth timber base as part of the range of 

alternatives considered in the DEIS. 

COMMENT

TIM-15: The Forest Service should take closer account of the TAC's detailed recommendations, 

including additional federal aid, new policies for planning and overseeing sales, and new 

oversight panels.

RESPONSE

These recommendations, while important, are not part of the analysis for the impacts of the Forest Plan 

amendment on various resources. Rather, they are items that will come into play during the 

implementation of the amended Plan, if adopted. These items are more dependent on outside influences 

rather than things that can be developed for a Forest Plan. While the timber demand calculation does 

come into play in providing a reliable supply of timber, there is no way to guarantee this supply primarily 

due to the fact that most of our timber harvest projects are litigated and the decision to implement them is 

often dictated by the courts.

COMMENT 

TIM-16: One entry into the beach and estuary fringe will not advance the stand to late seral stage, 

especially if a 200-foot strip is left along the shoreline. 

RESPONSE

The young-growth plan components and management direction for Beach and Estuary Fringe (BEACH) 

in Chapter 5 of the Forest Plan are based on the Tongass Advisory Committee recommendations

(Alternative 5).

The integrity of the Conservation Strategy was included as an issue for the proposed Forest Plan 

Amendment; one part of that concern was the effect harvest within contributing elements of the 

Conservation Strategy (such as the beach fringe, RMAs, and Old-growth Habitat LUD) could have on 

wildlife species that depend on these areas for part or all of their life cycle. Limited young-growth harvest 

is allowed in these areas under the 2008 Forest Plan but because the volume from any trees cut or 

removed does not count as commercial timber volume, these treatments are often prohibitively expensive 

and therefore not utilized or result in heavy slash accumulation that reduces the effectiveness of the 

treatment as a habitat improvement. The proposed changes to the Forest Plan under Alternative 5 would 

make it easier to include these stands along with nearby young growth in traditional development LUDs 

and allow for more flexibility in choosing a harvest prescription that will benefit the stand. 

The plan amendment is designed to produce a transition to young-growth management over the next 10-

15 years (life of the plan). Under Alternative 5, we do not foresee a need to enter the young-growth 

stands in the beach, RMA, and Old-growth Habitat LUD more than once during that timeframe. Under the 

proposed Forest Plan, there are young growth standards that constrain re-entry in these areas unless 

there is scientific justification to do so. (See S-YG-BEACH-02, S-YG-RIP-02, and S-YG-WILD-02 in 

Chapter 5.) Habitat improvement projects could also be conducted in the future to meet LUD objectives 

(current process). 

Alternative 5 does not prevent treating all young-growth acres in the beach, RMA, and Old-growth Habitat 

LUD, but does set standards for those treatments and establishes desired conditions. All young-growth 

acres could be treated with commercial thinning (up to 35 percent removal) or up to 35 percent of the 

stand acres could be harvested if an even-aged prescription is used. Site specific analysis at the project 

level will compare the existing stand characteristics to the desired conditions and determine if and how 

the stand should be treated to achieve the desired conditions; some acres may already be moving toward 

old-growth conditions naturally while others may be in a dense, stem exclusion phase requiring treatment. 

Final EIS I-39 DEIS Comments and Responses
Appendix I

A buffer immediately adjacent to the shoreline would contribute to future structural complexity of the 

stand. It would provide a minimal wind buffer, some snow interception, provide for wildlife movement, or 

the trees/root systems could be used as denning sites for marten or river otter. The trees may be large 

enough, or approaching the size needed, to be used as perching or roosting trees for eagles. Likely 

these trees are beginning to produce cones and can serve as a seed source for the adjacent harvest.

COMMENT

TIM-17: The Forest Service should modify its use of the term “young-growth.” Suggestions 

included defining it to include 130-150 year old trees or, conversely, that this is too old and an age 

of 40 to 80 years is more appropriate.

RESPONSE

Young growth stands that would be harvested under the proposed amendment are typically a minimum of 

65-75 years old (DEIS page 3-310), and have not yet reached the understory reinitiation stage which 

occurs at around 150 years of age in Southeast Alaska (Alaback 1984). See Forest Plan Chapter 7, 

Glossary. On the Tongass, a forest younger than 150 years old is considered young-growth forest.

COMMENT

TIM-18: Why was the TAC only given 10‐15 years to make the transition happen? The transition in 

such a short time is destined to fail. 

RESPONSE

Please see Response to P&N-1. The timeframe of 10 to 15 years came from the Secretary’s 

Memorandum 1044-009 that directed a “transition over the next 10 to 15 years, so that at the end of this 

period the vast majority of timber sold by the Tongass will be young growth.” This was used as a goal for 

the design of the TAC alternative and the action alternatives analyzed in the FEIS. As can be seen, in 

Chapter 2 of the DEIS, two of the alternatives fully achieved this goal and three alternatives, including the 

TAC alternative, required more than 15 years to fully transition.

COMMENT

TIM-19: The DEIS and Forest Plan failed to consider plan components that reduce the scale and

size of old-growth clearcuts. The DEIS identifies NFMA requirements to limit clearcutting, and 

national directives to limit clearcutting except when essential to meet Forest Plan objectives, but 

then it arbitrarily picks out timber economic objectives from the Forest Plan to the exclusion of 

multiple use objectives. [DEIS at 3-299-300].

RESPONSE

The purpose and need and the resulting scope of this amendment does not include limiting the size of 

old-growth clear cuts. Currently, most old-growth clear cuts on the Tongass are less than the maximum 

allowed under NFMA. The DEIS section referred to in the comment simply describes the options that are 

available for timber management. As the transition occurs, old-growth timber harvest will be reduced, thus 

also reducing clearcutting of old-growth stands. See forest-wide timber objective O-TIM-01 in Chapter 5.

COMMENT

TIM-20: The Forest Plan failed to develop measures to respond to Alaska Yellow Cedar Decline.

Harvest of healthy Alaska Yellow Cedar should be limited with the goal of maintaining healthy 

stands.

RESPONSE

While there is much of uncertainty on the effects of continuing climate change on Alaska yellow-cedar 

(AYC) populations and regeneration, the Forest has ensured long-term survival by allocating much of the 

Alaska yellow-cedar’s range on the Tongass to non-Development LUDs, while also practicing active 

forest management like thinning and planting to encourage future establishment and survival of future 

DEIS Comments and Responses I-40 Final EIS
Appendix I

AYC trees. All of these practices are already part of the Forest Plan, TIM-2, and will continue to be 

practiced.

A report, A Climate Adaptation Strategy for Conservation and Management of Yellow-Cedar in Alaska, 

PNW-GTR-917, January 2016 (Hennon et al., 2016) acknowledges that the health of yellow-cedar varies 

throughout its extensive range, with nearly 600,000 acres of declining trees mapped. Within these areas, 

up to 70 percent of the Alaska yellow-cedar are dead and/or dying from climate caused cedar decline. 

Although it is declining in some areas, in northern areas of Southeast, the tree appears healthy and the 

projections for its survival is optimistic. Hennon et al., 2016 acknowledges that while yellow-cedar may be 

declining at a fast rate in some areas, the species is unlikely to become extinct according to models that 

have projected survival to the year 2080. 

According to Hennon et al., 2016, active forest management offers the most direct opportunity for 

adapting to climate change and responding to yellow-cedar decline (page 189). Forest management 

practices can increase the abundance of yellow-cedar in habitats that are expected to be favorable into 

the future, and other approaches can be used to restore some ecosystem functions in decline-affected 

forests. The Tongass has used precommercial thinning and tree planting to favor Alaska yellow-cedar in 

areas where they can be expected to thrive in the future. 

The Tongass has planted over 1000 acres of Alaska yellow-cedar since 2012, selecting recently 

harvested areas that are north facing, higher elevation and contain well-drained soils in an effort to reestablish cedar seedlings in areas that will be best suited for survival in a changing climate. While deer 

predation can cause mortality in young AYC trees in some areas, the Tongass has worked in conjunction 

with the U.S. Forest Service, Pacific Northwest (PNW) Research Station, Sealaska, and Oregon State 

University to conduct studies to determine successful methods to ensure seedling survival. The Forest 

also precommercially thins between 5,000 to 7,000 acres of young conifer stands a year. Since 

approximately 1990, Alaska yellow-cedar has been the preferred species in nearly all contracts, allowing 

growing space free from competition from the faster growing Sitka spruce and western hemlock. On the 

other hand, past practices favored Sitka spruce. Therefore older young growth stands are predominately 

spruce and hemlock with a very low cedar component.

The Center for Biological Diversity petitioned for listing Alaska yellow-cedar for endangered status under 

ESA in July 2014. The U.S. Fish and Wildlife Service ruled in April 2015 that the petition warranted further 

research, but a final ruling has not been issued.

COMMENT

TIM-21: The Forest Service should stop harvesting old-growth and mature young-growth 

immediately or within 5-years. Currently planned old-growth timber sales should be stopped. 

RESPONSE

Refer to ALT-3 and ALT-4.

Final EIS I-41 DEIS Comments and Responses
Appendix I

Conservation Strategy (CONS)

COMMENT

CONS-1: The changes proposed in the Forest Plan, such as implementing silvicultural treatments 

on a programmatic scale without any scientific support for its assumptions and conclusions, 

adversely affect the long-standing wildlife Conservation Strategy. The DEIS does not disclose or 

analyze the broad scope of these changes, or consider the significant uncertainties and unknown 

risks associated with plan components for commercial thinning and patch clearcuts in protected 

areas. The Forest Service also ignores relevant science that has developed since the 2008 Forest 

Plan was adopted, including science that questions many of the assumptions of the Conservation 

Strategy itself. All of these considerations are exacerbated by the fact that the Proposed Forest 

Plan dramatically changes the agency’s approach to resolving conflict between plan provisions. 

Under the Proposed Forest Plan, Chapter 5 would prevail over the rest of the plan in the event of 

conflict or discrepancies between directions. the consequences of this dramatic change in 

management is not addressed in the DEIS.

RESPONSE

The Tongass Conservation Strategy was designed to maintain viable and well distributed populations of 

old-growth associated species. Most of the proposed changes in this amendment pertain to younggrowth; old-growth harvest remains unsuitable in conservation areas such as non-development LUDs, 

beach and estuary fringe, and riparian management areas. Completely changing the Conservation 

Strategy to a different approach would be outside the scope of this amendment. 

This amendment considers effects of allowing young-growth harvest and renewable energy siting in 

contributing elements of the Conservation Strategy (beach, RMA, and Old-growth Habitat LUD).

DEIS Appendix D contains a review of possible effects to Conservation Strategy changes that are 

proposed, such as young-growth harvest in the beach fringe. Forest-wide, suitable acres of young growth 

in the beach fringe, RMA, and Old-growth Habitat LUD are about 2 percent, 4 percent, and 3 percent of 

the total acres in that component, respectively. Projects must still maintain landscape connectivity per 

WILD1.VI.A (Chapter 4) and several Young Growth plan components inChapter 5 set constraints and 

expectations on young growth harvest: 

DC-YG-01 references sustaining diversity and productivity of ecosystems; 

DC-YG-03 and DC-YG-04 reference maintaining or improving fish and wildlife habitat by accelerating 

old-growth conditions; 

GL-YG-01 provides a constraint for maintaining or improving habitat conditions at the landscape level; 

DC-YG-BEACH-01 states that the beach and estuary fringe provide habitat and connectivity for 

wildlife and opportunities for accelerating old-growth characteristics; 

S-YG-BEACH-01 and 02, S-YG-RIP-01 and 02, and S-YG-WILD-01 and 02 set constraints for 

maximum limits on opening sizes and allow for only one entry per stand in the beach fringe, RMAs, 

and Old-Growth Habitat LUD; 

S-YG-BEACH-03 provides a constraint for a minimum 200-foot-wide forested no commercial harvest 

corridor; 

DC-YG-RIP-01 states that RMAs are managed to accelerate old-growth characteristics in order to 

improve riparian functions for soil, water, fish, wildlife, and other resources; and 

DC-YG-WILD-02 states that in the Old-Growth Habitat LUD young growth stand treatments emulate 

the natural scale and distribution of disturbance patterns. 

In addition several management approaches in Chapter 5 explain the intent of implementation for these 

plan components. 

DEIS Comments and Responses I-42 Final EIS
Appendix I

For renewable energy sites, DC-RE-02 states that renewable energy resources are developed in a 

manner that would maintain and protect NFS lands and resources; a management approach for 

renewable energy was added to the Forest Plan that explains the intent that renewable energy plan 

components do not change the need to ensure that resource protection measures are incorporated during 

project-level planning, construction, and operation of renewable energy sites.

The Forest is not changing its approach to resolving conflict between provisions of the Plan. Under the 

2008 Forest Plan, Chapter 3 direction (LUD-specific standards and guidelines) prevailed over Ch. 4 

(Forest-wide standards and guidelines) just as it does under this Forest Plan; this amendment simply 

adds that Chapter 5 direction, which is new, prevails over Chapter 3 only in the event of conflicting 

direction. Standards and guidelines in Chapters 3 and 4 still apply except in a few instances where 

Chapter 5 provides a specific plan component such as suitability for young-growth harvest that would be 

relevant to a particular project. In Chapter 1 of the Forest Plan, under the Priority of Direction section, t 

content was added to make clear that when applying Chapter 5 direction, all laws, regulations, and policy 

pertaining to management of National Forest resources will be followed, such as Clean Water Act, 

Endangered Species Act, and approved best management practices to avoid, minimize, or mitigate 

environmental impacts.

Silviculture prescriptions, such as clearcutting or thinning, are not decided at the Forest Plan level; a 

model was run to allow resource specialists to analyze potential effects but this does not limit the options 

available to be implemented at the project level after site-specific analysis. See also TIM-13 response 

regarding silvicultural prescriptions

COMMENT

CONS-2: The Proposed Forest Plan disregards the original Tongass Conservation Strategy, 

which was set up to protect apex predators. The Proposed Forest Plan pushes back the original 

sideboards of the Conservation Strategy. This is most dramatically evident on Prince of Wales 

Island, where 94 percent of the contiguous large-tree old-growth stands have been eliminated 

since 1954 (Albert and Schoen 2013). As a result, we can expect significant declines in Sitka 

black-tailed deer populations. The preferred alternative in the Proposed Forest Plan will erode the 

original Tongass Conservation Strategy, increase risks to the Archipelago wolf, and is contrary to 

the provisions in the 2012 planning rule on ecological integrity and ecosystem diversity (36 CFR. 

219.8(a), 219.9(a)) 

RESPONSE

See responses to CONS-1, PLR-2, WOLF-3, and WOLF-5, and EIS Appendix D.

Overall, the Conservation Strategy is functioning under conditions that are much better than anticipated at 

the time of its development. Actual and projected old-growth harvest levels under the current Forest Plan 

(Alternative 1) are far below levels predicted under the 1997 Forest Plan, which formed the context within 

which the [original] Conservation Strategy was intended to function. This has occurred largely because of 

economics and a significant decline in the timber industry due to various factors (Appendix D, FEIS). 

This Forest Plan reduces the amount of old-growth harvest in about 10-15 years, while increasing the 

amount of young-growth harvested. During this transition timeframe, harvest of old-growth will occur in 

the same land use designations as the 2008 Forest Plan (Timber Management, Modified Landscape, and 

Scenic Viewshed) and is within the effects considered and disclosed in the 1997 and 2008 Forest Plan 

Conservation Strategy analyses. The Forest Plan also allows for young-growth harvest in portions of the 

contributing elements of the Conservation Strategy (e.g., beach and estuary fringe, RMAs, and nondevelopment LUDs). Proposed modifications to contributing elements of the Conservation Strategy under 

the action alternatives have the potential to result in localized reductions in the functioning of these 

elements. That is, young-growth harvest may locally alter forest structure and reduce connectivity, but the 

beach and estuary fringe and RMAs would continue to function as intended across the planning area by 

serving as ecological transition zones, maintaining freshwater and marine aquatic and terrestrial habitat, 

and providing landscape connectivity (Appendix D, FEIS). The Forest Plan includes several plan 

components that ensure that young-growth projects would maintain habitat and connectivity for wildlife

Final EIS I-43 DEIS Comments and Responses
Appendix I

and opportunities for accelerating development of old-growth characteristics. (See Forest Plan Chapter 5 

young growth direction.) The young growth direction also includes management approaches that describe 

the principal strategies and program priorities the Responsible Official intends to employ to carry out 

projects and activities developed under the Plan. Management approaches are intended to assist the IDT 

to design projects that would maintain or move the forest toward desired conditions. (See Chapter 6, 

Project Consistency Requirements.)

The Forest Plan is a programmatic document that sets guidance for activities Forest-wide. Including 

specific components for one location, for example Prince of Wales Island, are generally not included in 

programmatic direction. 

The 94 percent (Albert and Schoen 2013) large-tree reduction since 1954 pertains to high-volume stands 

which are defined differently by Albert and Schoen (2013) than large-tree for the Forest Service analysis. 

Further, this reduction is true of the existing condition, not a result of this plan amendment. 

In addition, the numbers calculated for the Forest Plan amendment do not match those of Albert and 

Schoen (2013) for either large tree or high volume: page 3-204 of the DEIS shows original acres of highvolume in the North Central Prince of Wales biogeographic province on all lands (NFS and non-NFS) to 

be 479,014 acres with 54 percent remaining and page 3-205 shows large-tree POG in that province to be 

235,402 acres with 50 percent remaining while Albert and Schoen indicate 77,536 hectares (about 

191,514 acres) of original high-volume with 6 percent remaining. 

COMMENT

CONS-3: Alternative 5 is not an acceptable alternative because it compromises the integrity of the 

Conservation Strategy. The Forest Service has concluded that the “beach fringe was a very key 

feature of the overall Tongass Conservation Strategy.” Beach and riparian buffers are essential to 

maintaining viable populations of old-growth dependent wildlife and marine-associated species.

The Forest Service should not relax protections for the areas by allowing young-growth harvest in 

them. The Forest Service has not properly accounted for the major impacts that would result from 

relaxing protections for these areas.

RESPONSE

Beach fringe and riparian management areas provide landscape connectivity functions and old-growth 

habitat for numerous species. These areas are not suited for old-growth timber production as in the 1997 

and 2008 Forest Plans. In some cases, young growth in these areas is not functioning to its potential as 

forested habitat; the desired condition for such stands is to accelerate development of old-growth 

characteristics, maintain habitat and connectivity, and emulate the natural scale and distribution of 

disturbance. Several species-specific standards and guidelines also remain in place, such as nest and 

den buffers and protection of waterfowl and shorebird habitat. Each project decision must say how the 

project is consistent with plan components, including desired conditions.

Forest-wide, suitable acres of the maximum amount of young growth that would be harvested in beach 

fringe, RMA, and OG LUD under any alternative comprise a very small component of the forest land 

within each of these plan components. Forest-wide maximum young-growth harvest would affect 

approximately 2.4 percent, 3.3 percent, 1.2 percent, and 0.4 of the forest land within the beach and 

estuary fringe under Alternatives 2, 3, 4, and 5, respectively. Likewise, Forest-wide maximum younggrowth harvest would affect approximately 6.7 percent and less than 1 percent of the forest land within 

RMAs, outside of TTRA buffers, under Alternatives 2 and 5, respectively. Finally, under Alternatives 2, 3, 

and 5 the maximum amount of young-growth harvest in the Old-growth Habitat LUD would comprise 

approximately 3.3 percent, 2.8 percent, and 0.2 percent of the forest land (young-growth, POG, and 

unproductive forest) within the Old-growth Habitat LUD Forest-wide, respectively, and less than 1 percent 

of the forest land within other non-development LUDs (Alternatives 2 and 3 only). are about 2 percent, 4 

percent, and 3 percent of the total acres in that component, respectively. Therefore, proposed 

modifications to contributing elements of the Conservation Strategy (e.g., beach and estuary fringe, 

RMAs, and non-development LUDs) under Alternatives 2, 3, 4, and 5 have the potential to result in 

localized, temporary reductions in the functioning of these elements (see response to CONS-1 and 

DEIS Comments and Responses I-44 Final EIS
Appendix I

CONS-2). That is, young-growth harvest may locally alter forest structure and reduce connectivity, but the 

beach and estuary fringe and RMAs would continue to function as intended across the planning area by 

serving as ecological transition zones, maintaining freshwater and marine aquatic and terrestrial habitat, 

and providing landscape connectivity. Additionally, as noted above, the transition to young-growth 

management would result in a significant reduction in the amount of projected old-growth harvest. 

Therefore, none of the alternatives would reduce the ability of the Conservation Strategy to maintain a 

functional and interconnected old-growth ecosystem across the planning area. When this is considered in 

conjunction with the plan components that are in place for young growth harvest in these areas (see 

CONS-1), any effects are anticipated to be localized and temporary. 

Overall, the Conservation Strategy is functioning under conditions that are much better than anticipated at 

the time of its development. Actual and projected old-growth harvest levels under the current Forest Plan 

(Alternative 1) are far below levels predicted under the 1997 Forest Plan, which formed the context within 

which the Conservation Strategy was intended to function. Under the 1997 Forest Plan, it was projected 

that 84 percent of the original (1954) POG forest would remain in 100 years. Under the Proposed Forest 

Plan (Alternative 5) and the action alternatives, 91 percent of the original POG forest is anticipated to 

remain. This equates to approximately 400,000 acres of additional old-growth than were assumed during 

the development of the Conservation Strategy. These additional POG acres may function as additional 

reserves, enhance existing reserves, or increase the effectiveness of the matrix when located around 

harvest units. Moreover, with the Roadless Rule in effect, inventoried roadless areas (approximately 

2,148,000 acres of development LUDs in roadless areas containing about 828,000 acres of POG) make 

an additional contribution to the maintenance of ecological function on the Tongass National Forest but 

do so outside of the elements of the Conservation Strategy. As such, the substantially greater presence 

of old-growth forest on the landscape across the planning area would outweigh the localize effects of 

young-growth harvest proposed in the Old-growth Habitat LUD, the beach and estuary fringe, and RMAs 

that would result under the action alternatives.

The Forest Service analyzed and disclosed the potential environmental consequences of young-growth 

harvest to contributing elements of the Conservation Strategy (e.g., beach and estuary fringe, RMAs, and 

non-development LUDs) under Alternatives 2, 3, 4, and 5 in the FEIS (See FEIS Chapter 3, Biodiversity 

section, Effects to the Old-Growth Forest Ecosystem). Appendix D of the FEIS also includes a section 

about the Integrity of the Conservation Strategy and discusses the ability of each alternative to maintain 

the integrity of the Conservation Strategy.

The proposed amendment retains the goal of providing an abundance and distribution of old-growth 

habitat to maintain viable populations of wildlife in the forest in its Wildlife Forest-Wide Standards and 

Guidelines, with plan direction to “Provide the abundance and distribution of habitat necessary to maintain 

viable populations of existing native and desirable non-native species well-distributed in the planning area 

(i.e., the Tongass National Forest).” (WILD1IIB, Proposed Forest Plan, p. 4-82).

See responses to PLR-2 and FEIS Appendix D.

COMMENT

CONS-4: The DEIS and Forest Plan lack detail on the harvest prescriptions for harvest in the 

beach fringe, Riparian Management Areas, and non-development LUDs. For example, the number 

of units, gaps between them, and the number of units in the specific area need to be explored and 

direction developed appropriately. We appreciate that the overarching LUD management goal and 

future desired conditions would define what is technically allowable and feasible in these 

areas, but there are few details as to how this will happen. The Forest Service should take steps 

towards figuring out how this is accomplished through pre-project planning with stakeholders 

and a clear process for reviewing projects to figure out how the goals were accomplished and 

what lessons were learned to ensure that these carry over to future projects. The Forest Service 

should also include direction in the Forest Plan to invest in scientific research to assess and 

monitor ecological conditions in the beach fringe, Riparian Management Areas, and nondevelopment LUDs with the intention of strengthening management approaches and treatments.

Final EIS I-45 DEIS Comments and Responses
Appendix I

RESPONSE

The Forest Plan includes plan components related to harvest of young growth in beach and estuary 

fringe, RMAs, and the Old-Growth Habitat LUD. The desired conditions, goals, objectives, standards, 

and guidelines work together, to provide overall direction and set sideboards for the project managers 

and resource specialists who will be implementing the Forest Plan. Management approaches add 

additional guidance by stating the intent of the plan components. Appendix D Table 2 contains a 

modeled estimate of harvest types by alternative for the beach, RMA, and Old-Growth Habitat LUD; 

specific stand prescriptions will be determined for each project based on site-specific information and are 

not included in the Forest Plan (see TIM-13). Appendix B contains a compatibility matrix for what harvest 

can be done in each LUD under each alternative: see Tables B-2.1 through B-2.5.

The plan monitoring program was revised to meet the 2012 Planning Rule requirements at 36 CFR 

219.12 and is now a separate document, but part of the Forest Plan 

(http://www.fs.usda.gov/goto/Tongass/Monitoring). This document outlines what monitoring the Tongass 

plans to conduct. Monitoring must be within the technical and financial capabilities of the Forest. In 

addition to Forest-wide monitoring outlines in the plan monitoring program, project-level monitoring can 

also be done if recommended by the interdisciplinary team that evaluates the project and approved by the 

Responsible Official (decision-maker). 

The Forest Plan is not the appropriate document to determine where money will be invested. Funding for 

Forest Service work comes through a variety of sources but is primarily allocated annually through 

Congress; this allocation is specific to a particular resource and cannot be used for other purposes. In 

addition, the National Forest System does not conduct independent research, although it can recommend 

projects and coordinate with its research branch, universities, and other interested partners. For 

example, there is currently ongoing research on a Tongass-Wide Young Growth Study to look at different 

treatment options in young growth and a cost share agreement with the State of Alaska for young growth 

inventory work.

See response to SPEC-42.

COMMENT

CONS-5: The amendment calls for the harvest of young-growth in beach buffers and key old 

growth habitat, however there is no mention of prioritizing certain places. The Forest Service 

should prioritize young-growth treatments to improve degraded habitats and improve deer 

numbers, especially in areas close to towns and villages to ensure subsistence opportunities are 

equal across the Tongass.

RESPONSE

The Forest Plan is a programmatic document that sets guidance for activities Forest-wide. Chapter 2 of 

the Forest Plan provides a forest-wide subsistence objective to “evaluate and consider the needs of 

subsistence users in making project land management decisions.” 

Young-growth direction in Chapter 5 of the Forest Plan includes plan components and management 

approaches that are specific to young-growth management. The following management approach for 

young growth would allow for the consideration of other opportunities in the project area:

“The intent is that during project planning, IDTs identify other resource opportunities in the 

project area, and if approved by the responsible official, integrate these opportunities into the 

project design. (See definition for Integrated Resource Management in Chapter 7.) When 

designing young-growth projects that would advance old-growth characteristics in the beach 

fringe, RMA, or old-growth reserve (OGR), IDTs seek out stakeholders to encourage creative 

and innovative approaches for developing silvicultural treatments that imitate the natural scale 

and distribution of disturbance patterns on the Tongass (e.g., wind-thrown timber that creates 

gaps and patches; landslides that create corridors and gaps; mortality that naturally thins 

stand).”

DEIS Comments and Responses I-46 Final EIS
Appendix I

The Tongass Young Growth Strategy does outline some broad priorities and general options for young 

growth treatments across the Tongass. This type of priority setting is usually completed at the district or 

island level rather than at the Forest Plan level so that site-specific needs and information can be 

incorporated into the project, such as treatments that benefit local subsistence use patterns and winter 

habitat conditions.

See response to SUB-1. 

COMMENT

CONS-6: The 1997 Forest Plan intended that early seral stands in non-development LUDs would 

be managed so that they develop into old-growth, but the Proposed Forest Plan dismisses these 

early seral stands as unimportant to the Conservation Strategy. Under Alternative 5, the Tongass 

Advisory Committee (TAC) recommended significant changes to the Tongass Conservation 

Strategy. Specifically, the preferred alternative calls for logging of young-growth stands in OGRs, 

Beach/Estuary Fringe Buffers, and Riparian Management Areas. This violates the intent of the 

original VPOP Strategy, and also stands at odds with the scientific underpinnings of the 

Conservation Strategy. Harvesting young-growth forest and building roads in buffers and 

reserves will seriously harm the Conservation Strategy. The DEIS states that “Continued 

inventories and monitoring of established nest protection buffers will help to inform future 

decisions,” but there are no specifics on how this monitoring will be accomplished and what 

measures will be used to gauge continued success of the goshawk in heavily managed timber 

production areas. The Forest Service should leave intact beach- and estuarine-fringe forests, 

Riparian Management Areas, and OGRs. Allowing new clearcuts, of whatever size, in OGRs, beach 

buffers and Riparian Management Areas will reduce populations of goshawks and other forestdwelling birds. These areas were set aside as reserves because they were considered critical to 

the long-term viability of many wildlife species across the forest.

RESPONSE

See also PLR-2, CONS-1, CONS-7, GOSH-2

Chapter 3 of the FEIS (Biodiversity section) states that “of the approximately 506,000 acres of younggrowth forest on the Tongass National Forest, about 76 percent of young growth is older and in the stem 

exclusion stage. This type of stand condition has very low species diversity.” The stem exclusion phase 

has little to no forage species important to deer and some small mammals, is often too dense to be used 

as foraging habitat for goshawks, and may not yet have large enough trees to be used for eagles to nest. 

These stands may be just reaching cone-bearing age so may also not be important for red squirrels. 

Treatment of these stands may open the canopy to allow more light to reach the forest floor which may 

assist in forage production; treatment can also be aimed at improving to tree spacing to increase growth. 

Each stand will be evaluated for treatment options by an interdisciplinary team of resource specialists. 

For example, a project evaluation can include consideration of existing and desired habitat conditions, 

adjacent landscape and habitat types, reserve connectivity, known wildlife usage in and near the project, 

insect and disease conditions, access and operability, and LUD. Young growth treatments in beach 

fringe, RMAs, and Old-Growth Habitat LUD should accelerate the stand toward old growth characteristics 

(desired conditions). Ten acre openings is the maximum allowed; it is not required to be that size. 

Openings may be less depending on stand size (cannot be over 35 percent of the stand) and the ability to 

achieve desired conditions. Management of young-growth stands through release, pre-commercial, and 

commercial thinning has the potential to increase biodiversity by concentrating growth in fewer, larger 

trees that, if allowed to grow over time, promote conditions that accelerate natural succession in order to 

achieve old-growth stand characteristics at a faster rate than would occur without treatment (Caouette et 

al. 2000; Carey 2003). 

Alternative 3 and 4 consider allowing only commercial thinning in the beach fringe rather than a maximum 

10 acre opening. Alternatives 3 and 4 also considered applying legacy standards and guidelines to 

young growth harvest. These are available options for the Responsible Official to choose for the 

decision.

Final EIS I-47 DEIS Comments and Responses
Appendix I

The beach fringe and Old-Growth Habitat LUD discouraged road construction but it was allowed under 

some circumstances in the 2008 Forest Plan, as it would be under the proposed amendment. This 

amendment recognizes that some road construction or reconstruction may be required to access young 

growth for the transition; it includes a guideline (G-YG-WILD-01) to keep road construction to the 

minimum necessary in the Old-Growth Habitat LUD and a standard (S-TSC-WILD-01) to design and 

construct transportation system corridors to maintain wildlife habitat corridors between OGRs, RMAs, and 

beach fringe. 

The intent of the Conservation Strategy was focused on the viability of old-growth associated/ dependent 

species and at that time no young growth management was foreseen in the life of the plan. Therefore, the 

intent was focused on old-growth and only precommercial treatments were envisioned for young-growth. 

Multiple criteria are considered during the design of old-growth reserves (see Appendix K), not just 

whether or not the reserve contains young growth or roads; Appendix K still allows for project-level review 

of reserves under this amendment. (See Young-growth Management Approach for Wildlife in Chapter 5 

of the Forest Plan).

The created openings of up to 10-acres in the Old-growth Habitat LUD, beach buffers and RMAs was to 

provide more economical offerings to allow a more rapid transition to young-growth management. The 

TAC recommendation was to allow these openings to emulate the natural scale and distribution of 

disturbance patterns on the Tongass (e.g., wind-thrown timber that creates gaps and patches, landslides 

that create corridors and gaps, mortality that naturally thins stand, etc.) that correspond with silvicultural 

treatments. (See Young Growth Management Approaches in Chapter 5 of the Forest Plan.) While most 

natural disturbance results in openings are smaller than 10 acres, wind events and landslides have 

created this type of landscape. This type of management is limited to the first 15 years after plan 

approval and may result in up to 6,803 acres harvested across the Tongass within Old-growth Habitat 

LUD, beach buffers and RMA outside the TTRA buffer (FEIS Appendix D, Table 2). The 10-acre opening 

is a maximum and may be used in conjunction with thinning up to 35 percent of the stand. The shape 

and size of the clearcut could be designed to conform and blend with the landscape to minimize effects 

wildlife habitat. Forest Plan Standards (S-YG-BEACH-02, S-YG-RIP-02, S-YG-WILD-02) constrain younggrowth harvest in these areas to a one-time only entry and to the first 15 years unless best available 

scientific information shows that additional entries are: a) warranted, and b) meet the LUD objectives. 

Every project and activity must be consistent with the applicable plan components, including the desired 

conditions. (36 CFR 219.15(d))

COMMENT

CONS-7: Concentrating logging on small isolated portions of the Tongass exacerbates an already 

troubling situation and compromises the Conservation Strategy. These areas are of critical 

importance to several old-growth dependent species. According to the DEIS, the vast majority of 

the stands in the Tongass result in negative stumpage value and the isolated areas that reflect 

positive stumpage values are located in a very concentrated portion of the Tongass. The DEIS 

never discloses the average stumpage values across the Tongass or the location of the only 

stands that appraise positively. The analysis also does not appear in the planning record.

RESPONSE

In order to transition to primarily young growth harvest, it is necessary to enter the same areas that oldgrowth harvest has occurred in the past because that is where the young growth and associated 

infrastructure are located. Many of the oldest young growth stands that will be ready for commercial 

harvest over the next 15 years have received no intermediate treatments, are in a stem exclusion phase, 

and were logged prior to current standards and guidelines so may occur in more sensitive areas than 

would be allowed under the 2008 Forest Plan direction. Most of the younger young growth stands (those 

less than 25 years) have received some precommercial thinning treatment; important deer forage may 

persist for longer in these areas and the trees may grow faster, delaying the onset of stem exclusion. 

Young growth could also receive additional intermediate treatments. 

Some areas of the Forest are important to both wildlife and timber harvest, such as Prince of Wales 

Island. Viability analyses that occurred leading up to the 1997 Forest Plan acknowledged that there could 

DEIS Comments and Responses I-48 Final EIS
Appendix I

be gaps in distribution of some species but that overall viability could be maintained across the Forest. It 

is possible that Prince of Wales is a location where some species are not contiguous across the entire 

island (i.e., gaps exist). The Conservation Strategy protects a series of large, medium, and small oldgrowth habitat reserves (including non-development LUDs) as well as standards and guidelines for matrix 

management. Although the amendment would include harvest of young growth in some Conservation 

Strategy elements such as beach fringe, Riparian Management Areas, and Old-Growth Habitat LUDs, the 

range of alternatives includes varying levels of protection of these areas through new young growth plan 

direction, but no old growth harvest would be allowed in these areas under any alternative.

The suitable land base where timber harvest can occur has continually decreased over the years. The 

latest reductions in this suitable land base are within the Inventoried Roadless Areas. The Preferred 

Alternative (Alternative 5) also proposes no old-growth harvest outside the Phase 1 lands as identified by 

the decision on the 2008 Forest Plan Amendment (ROD pp. 64 to 66) or within T77 watersheds and The 

Nature Conservancy /Audubon Priority Conservation Priority Areas (See Forest Plan Appendix A). 

By restricting this land base, the timber harvest becomes more concentrated into small areas. It is also 

true that the economics of timber harvest tend to concentrate harvest. The Forest Service is required to 

issue only positive sales, but specific locations of these are not known until project-level analyses are 

conducted. However, on the other hand, more and larger areas will not have any old-growth timber 

harvest and will maintain the old-growth characteristics and contribute to maintaining the integrity of the 

Tongass Conservation Strategy. This is a trade-off for resources that should provide both habitat for oldgrowth associated and dependent species and a timber base for commercial timber harvest. 

In order to transition in 10-15 years as outlined in the Secretary’s Memo and brought forward in the 

Purpose and Need, all young-growth lands were considered. Since the age of the young-growth stands is 

a limiting factor, the oldest stands of young growth are being considered for harvest to facilitate the 

transition. If the oldest young-growth stands are not included in the earliest phase of the transition, it is 

highly unlikely the Forest Service could meet the Purpose and Need of the amendment. Therefore, oldgrowth timber harvest would continue for a longer time period. If young-growth harvest is not allowed in 

the most areas, opportunities to improve habitat conditions for wildlife and fish and stand function in 

places that would potentially benefit from restoration work and advancement of seral stages toward oldgrowth conditions, would be lost.

An updated productive old-growth analysis including a high volume productive old-growth and a large tree 

productive old-growth analysis has been provided in the Forest Plan Amendment FEIS (Chapter 3, 

Biodiversity section).

An updated financial analysis is provided in the Forest Plan Amendment FEIS (Chapter 3, Economics 

section) and includes the net revenues or stumpage values (see Table 3.22-16). Viewed over 15-year 

and 100-year planning horizons, all five alternatives would result in positive net revenues (stumpage 

values). Alternatives 1, 4, and 5 also would result in positive net revenues over the 25-year planning 

period; Alternatives 2 and 3 would result in negative net revenues for the 25-year period. FEIS Appendix 

B describes and documents the analytical processes and models used for the 2016 Forest Plan 

Amendment FEIS. 

COMMENT

CONS-8: Forest Service must examine the adverse effects of second-growth logging on the 

overall Conservation Strategy because not all second-growth stands have the same ecological 

value.

RESPONSE

Not all young-growth stands have the same habitat value. Young-growth stands that have reached the 

stem exclusion stage may not be fully functioning in terms of habitat value; these stands could benefit 

from treatment such as those proposed during this amendment. 

FEIS Appendix D describes the effects to the Conservation Strategy of logging young growth in beach 

buffers, RMAs, and Old-Growth Habitat LUDs. Chapter 5 of the Forest Plan contains several plan 

Final EIS I-49 DEIS Comments and Responses
Appendix I

components related to young growth management in these contributing elements to the Conservation 

Strategy, including desired conditions to accelerate old-growth characteristics in those stands. Each 

project implemented under the Forest Plan will evaluate site-specific conditions and resource concerns to 

determine whether, how, and when to log young-growth stands. Part of that analysis by the 

interdisciplinary team should include looking at where on the landscape stands proposed for harvest 

occur, the current condition of those stands, and the harvest prescription to advance those stands toward 

the desired condition. Landscape connectivity would also be reviewed (See WILD1.VI.A, page 4-86 of 

the Forest Plan.) Every project and activity must be consistent with the applicable plan components (36 

CFR 219.15(d)). 

See response to PLR-2 and FEIS Appendix D.

COMMENT

CONS-9: Changes to the Tongass Conservation Strategy and transportation management in the 

Proposed Forest Plan are significant enough to require a plan revision. The NFMA requires land 

management plans to be revised at least every 15 years, or sooner if physical conditions or 

demands on the land and resources have changed sufficiently to affect overall goals or uses for 

the entire unit.

RESPONSE

Effects to the Tongass Conservation Strategy from proposed changes to the Forest Plan have been 

evaluated and discussed in Appendix D of the Forest plan Amendment FEIS concluding that the integrity 

of the Conservation Strategy is maintained under all alternatives. This Strategy was designed to provide 

habitat for old-growth associated and dependent species. Since the proposed action alternatives target a 

more rapid transition to young growth harvest, there would be a corresponding lower amount harvest of 

old-growth harvest to meet demand . As noted under CONS-3, the Conservation Strategy is functioning 

under conditions that are much better than anticipated at the time of its development in 1997. Actual and 

projected old-growth harvest levels under the current Forest Plan (Alternative 1) are far below levels 

predicted under the 1997 Forest Plan, which formed the context within which the Conservation Strategy

was intended to function 

Some young-growth harvest is proposed in the beach buffer, Riparian Management Areas and the Oldgrowth Habitat LUD. However, constraints are in place to limit the size of the openings and the level of 

thinning. See young growth direction in Chapter 5 of the Forest Plan and response to CONS-1. Forest 

Plan Standards (S-YG-BEACH-02, S-YG-RIP-02, S-YG-WILD-02) constrain young-growth harvest in 

these areas to a one-time only entry and to the first 15 years unless best available scientific information 

shows that additional entries are: a) warranted, and b) meet the LUD objectives. Every project and activity 

must be consistent with the applicable plan components, including the desired conditions. (36 CFR 

219.15(d)). The desired conditions in these areas is to mantain connectivity for wildlife and to accelerate 

old-growth conditions.

See response to PLR-1 and CONS-3.

COMMENT

CONS-10: The Forest Service should clarify old-growth habitat reserve modification procedures 

for small OGRs to require comparable conservation value (see Appendix D of the 2008 Plan) and 

modify Chapter 3, Old-Growth LUD, WILD1 to read “”Alternative reserves must provide 

comparable achievement of the Old- growth Habitat LUD goals and objectives within each VCU.

RESPONSE

The responsible official has the discretion to determine whether and how to amend the plan. See 36 CFR 

219.13.a and FSH 1909.12, Chapter 20, Section 21.3. For this amendment, the scope is focuses on 

making changes primarily to facilitate a transition to primarily young growth harvest in about a 15 year 

timeframe and on making separate renewable energy and transportation systems corridors plan 

components (to replace the TUS overlay). Modifying criteria for small OGRs, which are part of the 

DEIS Comments and Responses I-50 Final EIS
Appendix I

Conservation Strategy, is outside of the scope of this focused amendment. Many of the 

recommendations from the 5-year review were not incorporated into this amendment.

OGR modification procedures are outlined in Appendix K of the forest plan (now with clarifications for 

young-growth harvest in the Old-growth Habitat LUD). At the project level, proposed OGR modifications 

would be required to provide comparable achievement of Old-growth Habitat LUD goals and objectives 

compared to the original OGRs.

Plan components are considered together and interact to form the overall direction; every project decision 

must describe how the project is consistent with plan components, including meeting the desired 

condition of the LUD. 

COMMENT

CONS-11: Large forest openings and extensive timber thinning without appropriate slash 

treatments can interfere with animal movements and increase vulnerability of some species to 

predation, harvest by humans, and/or exposure to deep snow and severe weather. The selected 

alternative should limit young-growth treatments to actions that maintain or improve wildlife 

habitat in beach and estuary fringe forest. These actions should include: openings that are limited 

to two acres or less in order to maintain hunting habitat for goshawks and provide thermal cover 

for deer; slash that is treated to allow unconstrained movement of deer, bears, wolves, and other 

species; and openings in the beach fringe that maintain a corridor of mature or old forest that is 

no less than 660 feet wide to maintain effective thermal cover (Concannon 1995).

RESPONSE

See CONS-3, CONS-4, CONS-6, CONS-12, and SPEC-6. 

Plan components are considered together and interact to form the overall direction; every project decision 

must describe how the project is consistent with plan components, including meeting the desired 

condition. For beach and estuary fringe, those desired conditions include providing habitat and 

connectivity and accelerating the development of old-growth characteristics (DC-YG-BEACH-01). 

Management approaches are used to guide project implementation of the Forest Plan components 

(desired conditions, objectives, standards, guidelines, suitability of lands, and goals if stated); they relate 

to the desired conditions and describe the principal strategies and program priorities the Responsible 

Official intends to use to carry out projects. The Forest Plan includes an intent statement for young growth 

harvest prescriptions and opening sizes in the beach and estuary fringe to consider spatial and temporal 

conditions of the adjacent landscape, and intends for treatments to facilitate a more rapid recovery of late 

successional forest characteristics. (See management approaches for beach and estuary fringe in 

Chapter 5 of the Forest Plan.)

The recommendation from the Tongass Advisory Committee represented in Alternative 5 is that any 

created opening size must not exceed 10 acres or to thin the stand in no more than 35 percent of the 

stand’s basal area. Site-specific openings determined at the project level will vary in size and shape. 

Alternatives 3 and 4 considered only commercial thinning in the beach fringe rather than a maximum 10 

acre opening. Alternatives 3 and 4 also considered applying legacy standards and guidelines to young 

growth harvest (see Appendix F of the FEIS). These are available options for the Responsible Official to 

choose for the decision. No old-growth harvest is planned under any alternative in the beach and estuary 

fringe, Riparian Management Area, or Old-Growth Habitat LUD.

Recent studies of slash treatment, such as Module IV of the Tongass-wide Young Growth Study and 

observation of commercial thinning of ongoing commercial young-growth sales and older young-growth 

treatments, will be used to determine which slash method is included in the silvicultural prescription to 

meet resource objectives. Specific harvest prescriptions and slash treatment will be determined at the 

project level to consider site specific conditions (see TIM2, WILD2). Silvicultural prescriptions are 

determined at the project level (see TIM2). The recommended slash treatment may depend on the 

silvicultural prescription used, the density of the existing stand, utilization specifications, and the location 

Final EIS I-51 DEIS Comments and Responses
Appendix I

of the treated stand on the landscape. Landscape connectivity will also be evaluated at the project level 

(WILD1.VI).

COMMENT

CONS-12: Young-growth treatments in the Old-growth Habitat LUD should be designed to 

accelerate development of old-growth characteristics without compromising landscape 

connectivity and animal movement.

RESPONSE

See responses to TIM-13, CONS-1, and SPEC-6.

The Old-Growth Habitat LUD does play an important role in the Conservation Strategy. In some 

instances, young-growth stands within the boundary of this LUD are not fully functioning for wildlife 

needs. Individual stand treatments will be determined at the project level. Plan components are 

considered together and interact to form the overall direction; every project decision must describe how 

the project is consistent with plan components, including meeting the desired condition. For Old-Growth 

Habitat LUD, those desired conditions include maintaining habitat and connectivity and accelerating the 

development of old-growth characteristics (DC-YG-WILD-01) and treating young-growth to emulate the 

natural scale and distribution of disturbance patterns (DC-YG-WILD-02). 

Management approaches are used to guide project implementation of the Forest Plan components 

(desired conditions, objectives, standards, guidelines, suitability of lands, and goals if stated); they relate 

to the desired conditions and describe the principal strategies and program priorities the Responsible 

Official intends to use to carry out projects. The Forest Plan includes an intent statement for Old-Growth 

Habitat LUD harvest prescriptions and opening sizes to consider spatial and temporal conditions of the 

adjacent landscape; intends for treatments to facilitate a more rapid recovery of late successional forest 

characteristics; and allows for an Old-Growth Habitat LUD to be modified to exclude young-growth 

proposed for harvest if a net gain in old-growth can be achieved and Forest Plan Appendix K criteria can 

be met (see management prescriptions).

COMMENT

CONS-13: The Forest Service’s refusal to undertake a comprehensive review of the Conservation 

Strategy—its scientific underpinnings, its overall validity, and its species-specific validity - along 

with the 2016 amendments, is arbitrary, capricious, and contrary to NEPA, NFMA, and the 1982 

Rule.

RESPONSE

See responses to PLR-1, and PLR-2, CONS-1, and Appendix D of the FEIS.

COMMENT

CONS-14: The Forest Service must re-evaluate the integrity of the Conservation Strategy to bring 

the plan into compliance with the 1982 Rule.

RESPONSE

See response to PLR-1, PLR-2, CONS-1, and Appendix D in the FEIS.

COMMENT

CONS-15: The changes proposed by the 2016 Forest Plan Amendments cannot be reconciled with 

the Conservation Strategy, and therefore are inconsistent with the 1982 rule.

RESPONSE

See responses to PLR-1, PLR-2, and CONS-1 and Appendix D in the FEIS.

DEIS Comments and Responses I-52 Final EIS
Appendix I

COMMENT

CONS-16: The analysis of impacts to the Conservation Strategy was deferred to project-level 

decisions, and this approach is not reasonable for three reasons: 1) the agency has a duty at the 

programmatic stage of analysis, where it is required analyze the cumulative effects of localized 

impacts across a broader landscape; 2) there is precedent for the agency manipulating the 

elements of the Conservation Strategy to effectuate timber harvest goals, at the expense of other 

resources considerations; and 3) there is a significant risk that this approach will lead to 

significant impacts escaping meaningful review when tiering and site-specific projects will not be 

given the full level of environmental review required by NEPA.

RESPONSE

See also PLR-2 and Appendix D.

The proposed Forest Plan does not change the old growth Conservation Strategy, although effects to 

elements of the Conservation Strategy may occur (see Appendix D). The FEIS and Appendix D analyzed 

possible impacts to the Conservation Strategy of the proposed Forest Plan and concluded that the 

integrity of the Conservation Strategy is maintained. Estimated young growth harvest within the beach 

and estuary fringe over 100 years would range from only 0.4 percent of the total forested beach and 

estuary fringe acres for the preferred alternative (Alternative 5) to 3.3 percent for Alternative 3. For RMAs, 

the preferred alternative would harvest an estimated 0.3 percent of the total forested habitat in RMAs over 

100 years, while the other alternatives would harvest between 0 and 6.7 percent. Estimated young 

growth harvest within the Old-growth Habitat LUD for the preferred alternative is 0.2 percent of the total 

forest land area within the Old-growth Habitat LUD, while the other alternatives would harvest an

estimated 0 to 3.3 percent over 100 years. At the project level, the interagency review process outlined in 

Appendix K can be used to modify an Old-growth Habitat LUD with proposed young-growth harvest so 

this number could be lower once the site-specific project review and decision are implemented. 

The Forest Plan is programmatic and provides overall direction for projects implemented under the plan. 

The FEIS and Appendix D did not defer the effects analysis of the Conservation Strategy to the project 

level but acknowledged that additional site specific analysis occurs at the project level. The sideboards 

set in the Forest Plan by lands suited for timber production, standards and guidelines, and other plan 

components and content were used to evaluate the expected outcomes at the Forest Plan level, but 

because individual projects and activities are not yet proposed, site specific information is not available 

for the programmatic review. Thus, additional analysis occurs at the project level to include any localized 

resource effects and to ensure the project implements the relevant Forest Plan requirements, such as the 

landscape connectivity standard and guideline (WILD1.VI.A). The DEIS looked at the Conservation 

Strategy from overall integrity of the strategy; cumulative effects during project analysis look at past, 

present, and reasonably foreseeable projects in the analysis area to further ensure the Conservation 

Strategy is maintained during project implementation.

The FEIS version of Appendix D has been expanded and an evaluation of the integrity of the 

Conservation Strategy under the no action and action alternatives is presented. The conclusion is that 

the integrity of the Strategy would be maintained under any of the alternatives. We believe the 

documentation for this conclusion is clearly presented.

COMMENT

CONS-17: Some old-growth reserves (OGRs) were included in the conveyance of the nearly 

70,000 acres of NFS land in the Tongass to Sealaska under the National Defense Authorization Act 

for Fiscal Year 2015 (Public Law 113-291). These circumstances require a re-evaluation of the 

entire network of OGRs on northern Kuiu Island and on Prince of Wales Island and its adjacent 

islands because the function of some other OGRs and matrix lands may be affected by nearby 

transfer lands that can be expected to logged more intensively than anticipated under the prior 

federal ownership. This re-evaluation is necessary to ensure the integrity of the Conservation 

Strategy as a whole in those areas.

Final EIS I-53 DEIS Comments and Responses
Appendix I

RESPONSE

FEIS Appendix E explains the modifications made to the small OGRs on Prince of Wales Island. These 

modifications were done by interagency biologists from US Fish and Wildlife Service, State of Alaska 

Department of Fish and Game and US Forest Service and represent the biologically preferred alternative. 

No OGRs were affected on Kuiu Island or elsewhere. No effort was made during these modifications to 

avoid higher productive forested lands to allow for more intensive management. The evaluation of these 

modifications followed the Forest Plan, Appendix K direction. Both the Appendix K criteria and the 

Appendix D criteria plus an evaluation of low elevation Productive Old-growth (POG) were used in 

evaluation. Also the small OGRs were examined to see if they still provided connectivity as the previous 

design did. As currently done at the project level, the old-growth matrix lands as they relate to connectivity 

will be further examined at the project level to disclose the effects. 

The tables in the FEIS Appendix E evaluate the pre-conveyance, post-conveyance and the interagency’ s 

biologically preferred OGR designs using the Forest Plan Appendix K and FEIS appendix D criteria. In 

some cases, the post-conveyance design still meets the OGR design criteria and the biologically 

preferred design is identical. No other designs were proposed to balance other resource considerations 

(Forest Plan Appendix K, p. K-2.)

This approach does not preclude that further analysis may occur during project-level analysis. One of the

TAC’s recommendations was to “The USFS should prioritize utilizing OGR modification processes to 

capture ...additional young growth acres within OGRs, putting particular emphasis on adjacent 

landscapes, where a net gain of productive old growth habitat is possible, while maintaining and 

enhancing landscape connectivity.” 

Public Law 113-291 also amended ANILCA, Section 508, to include 152,000 acres of LUD II 

Conservation Areas. These areas primarily focused on protecting old-growth forest. A LUD II is a 

Congressionally-designated land allocation and the Land Use Designation cannot be changed except by 

an act of Congress. More than 31,000 of these areas were previously allocated to Development LUDs 

and now contribute to the Conservation Strategy. 

COMMENT

CONS-18: There should be a provision and standards and guidelines prescribing that, during the 

OGR modification process, there should be no net loss of protected POG across the Forest.

RESPONSE

The Forest Plan includes a young-growth management approach for wildlife for adjusting OGRs if younggrowth harvest is proposed within the current boundaries. The intent is that an “exchange” of young 

growth and old growth could be made – where the boundary of the reserve is adjusted to remove young 

growth and add an equivalent acreage of productive old growth. The objective of this direction would be 

to achieve a net increase in productive old growth acres, whenever possible. When applied at the project 

level, this would lead to an increase of productive old growth in the reserve network. 

COMMENT

CONS-19: Forest Service should use science review process to assess the new and modified 

OGRs before issuing the FEIS. If the review of the modified OGRs indicates they are unlikely to 

meet the reserve system intent, especially in heavily-logged areas, and more old-growth logging 

occurs on nearby USFS land, the opportunity to create a more effective system in those areas 

may be lost.

RESPONSE

The reserve system has to be only on NFS lands where the USFS has jurisdiction for management of 

those lands. The interagency team has recommended modifications to the reserves to best meet the 

criteria for such reserves on remaining NFS lands adjacent to the transferred lands. The interagency 

recommendations for the modified reserves are included in all action alternatives. Project level reviews of 

old growth reserves can also occur if the interdisciplinary resource team identifies a concern about the 

DEIS Comments and Responses I-54 Final EIS
Appendix I

location or functionality of a reserve within the project area. In addition, if young growth harvest is 

proposed within Old-Growth Habitat LUD, an interagency team can recommend modifying the boundary 

to exclude young growth if additional old growth can be included for a net increase of old growth within 

the reserve.

Appendix K of the Forest Plan provides the procedures for modifying old-growth habitat reserves. These 

procedures were followed; they do not include a Science Review. 

COMMENT

CONS-20: Alternative 5 should be rejected because it increases the number of watersheds that 

would exceed a road density greater than 1 mile / square mile by 20 percent.

RESPONSE

The Watershed Condition Framework (USDA Forest Service 2011) concluded that a watershed with a 

road density of less than 1 mile / square mile is considered “properly functioning.” Table 3.4-5 in the 

DEIS indicates that currently 9.6 percent of 6th field subwatersheds exceed 1 mile / square mile road 

density and Alternative 5 would take that to 11.0 percent after 100 years of implementation on NFS lands. 

This would leave 89 percent of the watersheds on the Tongass National Forest with less than 1 mile / 

square mile of road after 100 years of assumed maximum harvest and road building allowed under the 

Forest Plan. Across all NFS lands on the Tongass, this is an average of 0.23 mile / square mile road 

density. When all ownerships are considered (Table 3.4-13 in the DEIS), 19.8 percent of watersheds 

would exceed 1 mile / square mile after 100 years of full implementation under Alternative 5, which leaves 

over 80 percent of the watersheds in Southeast Alaska in a properly functioning condition, and an overall 

average of 0.45 miles / square mile. 

COMMENT

CONS-21. The EIS should include the most recent inventory of global temperate rainforest and 

evaluate the importance of the Tongass’ intactness (DellaSalla et al 2011). 

RESPONSE

This reference has been added in the FEIS.

COMMENT

CONS-22. The EIS should include an old-growth analysis by watershed.

RESPONSE 

See FEIS Chapter 3, Biodiversity section. In Chapter 3, Tables 3.9-12 through 3.9-14 present the 

estimated percent of original productive old-growth (POG), original high-volume POG, and original largetree POG remaining after 100 years by biogeographic province and alternative. In addition, Table 3.9-15 

presents the number and acreage of intact large watersheds under existing condition and after 100 years 

by biogeographic province and alternative. These tables demonstrate the percentage of old growth in 

these various categories that will be preserved. Tongass old growth is defined as stands with trees at 

least 250 years of age. Also see FEIS Appendix D.

Final EIS I-55 DEIS Comments and Responses
Appendix I

Young Growth in Audubon/TNC and T77 Watersheds (YGAT)

COMMENT

YGAT-1: The Forest Plan lacks substantive requirement to reduce or mitigate potential impacts 

from young-growth timber sales in these watersheds.

RESPONSE

The Forest Service may apply project-specific mitigation to reduce effects to fish and wildlife habitat, or 

elect to apply the ‘no net loss” concept outlined in the TAC overarching principals. These measures are 

determined based on the specific conditions of planned and proposed sales following project-specific 

analysis by an interdisciplinary team. For all land-disturbing activities, BMPs from the National Core BMP 

Technical Guide FS-990a are applied to maintain the chemical, physical, and biological integrity of the 

Nation’s waters. Applicable BMPs are also found in the Alaska Region Soil and Water Conservation 

Handbook, FSH 2509.22. Plan components from Chapters 3, 4, and 5 also apply.

COMMENT

YGAT-2: The Forest Service should recognize the exceptional fish and wildlife values of the T77 

watersheds and TNC/Audubon conservation priority areas. Some recommend that they be remove 

from the suitable timber base altogether. The Forest Service should preserve these watersheds 

and make production of wild salmon, trout and steelhead their highest management priority. 

RESPONSE

The Forest Service recognizes the exceptional fish and wildlife values of the T77 watersheds. These 

watersheds, along with watersheds in LUD II status are considered the pillar of commercial, sport, and 

subsistence wild salmon harvest in the region and provide a large contribution to the southeast Alaska 

economy. Alternative 5 identified old-growth stands within the T77 watersheds as not suitable for timber 

production, except for small sales after the transition is complete. If young-growth harvest is not allowed 

to be harvested in these watersheds, opportunities to improve habitat conditions for wildlife and fish and 

stand function in places that would potentially benefit from restoration work and advancement of seral 

stages toward old-growth conditions, would be lost. 

Further, in order to transition in 10-15 years as outlined in the Secretary’s Memo and brought forward in 

the Purpose and Need, all young-growth lands were considered. Since the age of the young-growth 

stands is a limiting factor, the oldest stands of young growth are being considered for harvest to facilitate 

the transition. If the oldest young-growth stands are not included in the earliest phase of the transition, it 

is highly unlikely we could meet the Purpose and Need of the amendment. Under Alternative 5, the lands 

inside T77 watersheds and TNC/Audubon conservation priority areas, include almost 17,000 acres of 

suitable young-growth that would be at least 60 years old by the end of the 15-year transition period. The 

Tongass Advisory Committee recognized this need to facilitate the transition, and recommended that 

these areas be identified as suitable for young-growth timber production.

COMMENT

YGAT-3: Should have a more Rigorous Scientific Review of Projects likely to be implemented in 

certain High-value Watersheds.

RESPONSE

Language in Chapter 5 of the forest plan has been edited to better reflect the intent of the TAC 

recommendations for the “high-value fish watersheds”. Alternative 5 now includes Management 

Approach language explaining the agency’s intent to conduct an internal scientific review with 

stakeholders to determine likely impact to fish and wildlife habitat from proposed young-growth timber 

projects that intersect with the “high-value fish watersheds” identified in Appendix B of the Final TAC 

DEIS Comments and Responses I-56 Final EIS
Appendix I

Recommendations (Forest Plan Appendix B). Project-specific analysis by an interdisciplinary team will 

determine if additional mitigation measures are needed. 

See response to comment SPEC-39.

COMMENT

YGAT-4: Forest Service should clarify that all old-growth stands in the T77 watersheds and 

TNC/Audubon conservation priority areas will be protected and removed from the suitable timber 

base as recommended by TAC.

RESPONSE

Forest Plan Appendix B has been updated to reflect the Final Tongass Advisory Committee (TAC)

recommendations. We believe that the term used on p. 13 of the final TAC recommendations –

TNC/Audubon conservation priority areas – means the same as what is stated in the text on page 38 of 

the TAC recommendations - TNC/Audubon Core Conservation Areas. Unfortunately, these terms are a 

bit confusing but they both together comprise the Conservation Priority Watersheds. During the drafting of 

the Proposed Forest Plan, the TAC provided the Forest Service a map (project record 769_05_000771), 

and the legend term on that map - Conservation Priority Watersheds - includes two categories: Core 

Areas of Biological Value and High Value Watersheds (dark green and light green, respectively). This is 

what was used to identify the TNC/Audubon conservation priority areas in the analysis. 

Proposed LUD changes common to the action alternatives are described in Chapter 2 of the FEIS. No 

other LUD changes have been made to incorporate lands not suited for timber production into the natural 

setting LUDs. Old-growth harvest from T77 watersheds and TNC/Audubon conservation priority areas is 

excluded under Alternative 5. (See FEIS Chapter 2, Alternative 5 description and Forest Plan Appendix 

A.) This was not clear in the DEIS and the suitability map did not show that all of these areas had been 

removed. The map for Alternative 5 in the FEIS clearly shows that they have been removed from the oldgrowth suitable base.

COMMENT

YGAT-5: The Forest Service should set up a phased approach for young-growth logging and 

create two phases, similar to the approach used in the 2008 Plan. Doing so would ensure that 

TNC/Audubon conservation priority areas could be set aside into Phase 2 for young-growth 

harvesting, while all other young-growth lands would be in Phase 1. 

RESPONSE

In order to meet the timeline for the young growth transition as outlined in the Undersecretary’s memo, all 

young growth lands were considered. Since the age of the young growth stands is a limiting factor, the 

oldest stands of young growth are being considered for harvest to facilitate the transition. If the oldest 

young growth stands are not included in the earliest phase of the transition, it is highly unlikely we could 

meet the purpose and need of the amendment.

Forest Plan Appendix B has been updated to reflect the Final Tongass Advisory Committee (TAC) 

recommendations regarding. TNC/Audubon conservation priority areas are discussed in Chapter 2 of the 

FEIS under Alternative 5, and also in Forest Plan Appendix A.

COMMENT

YGAT-6: The Forest Service should not preclude any timber harvest in the T77 watersheds. There 

are already too many restrictions affecting communities.

RESPONSE

Alternatives 1 through 4 considered this option.

Final EIS I-57 DEIS Comments and Responses
Appendix I

Best Available or Relevant Science (BAS)

COMMENT

BAS-1: The Forest Service should comply with NFMA’s regulatory requirements to base its 

decision on the best available science.

RESPONSE

The interdisciplinary team has used the best available scientific information to amend the plan and to 

modify the plan monitoring program to meet the requirements of the 2012 Planning Rule (36 CFR 

219.12(c)). The responsible official will document how the best available scientific information was used 

to inform the plan decision. The record of decision (ROD) for the plan amendment will include 

documentation of how the best available scientific information was used to inform planning, the plan 

components, and other plan content, including the plan monitoring program. Further, numerous 

refinements and updates were made to the EIS between the DEIS and FEIS (e.g., climate change 

assessment, Conservation Strategy assessment).

In regards to the Tongass Old-growth Habitat Conservation Strategy, recent advancements in the fields of 

conservation science and landscape ecology and new knowledge of individual species’ biological needs 

are discussed throughout the Wildlife and Biodiversity sections of the EIS, as well as in Appendix D. 

Many of these topics, including the importance of strong connections between aquatic and terrestrial 

ecosystems and upstream and downstream linkages within stream and river systems, the contribution of 

matrix lands to conservation, and the range of ecological functions provided by young-growth stands were 

identified during the original development of the Conservation Strategy for the 1997 Forest Plan and 

considered again during the Interagency Forest Plan Conservation Strategy Review (USDA Forest 

Service 2007) conducted for the 2008 Forest Plan Amendment. Appendix D of the EIS touches on some 

of the new science related these topic areas relevant to conservation planning on the Tongass National 

Forest. Information from these studies, other relevant studies and other best available science would be 

used to review the Conservation Strategy design if in the future, data from various sources suggest that 

the Conservation Strategy is no longer functioning as originally intended. However the results of the 

analysis in Appendix D indicate the Conservation Strategy currently functions as intended and is 

expected to function regardless of which alternative is selected.

COMMENT

BAS-2: The DEIS Fails to Include or Address Relevant Science.

RESPONSE

See response to BAS-1.

DEIS Comments and Responses I-58 Final EIS
Appendix I

Air Quality (AIR)

COMMENT

AIR-1: The DEIS should evaluate health risks associated with increased utilization of biomass for 

energy and heat stating that NEPA requires the Forest Service to consider the health effects of 

federal actions. [40 C.F.R. § 1508.8]. The reason for this request was due to a citation presented 

stating that “[b]urning biomass could lead to significant increases in emissions of nitrogen 

oxides, particulate matter and sulfur dioxide and have severe impacts on the health of children, 

older adults, and people with lung diseases.” [Exh. 50 at 5 (Vick 2011)]. Despite federal 

directives, the DEIS never addressed the issue of air pollution caused by wood combustion and 

concludes that the analysis of air quality effects in the DEIS is conclusory, misleading and fails to 

consider the adverse health impacts caused by wood combustion. The USFS should explain the 

linkage between Juneau’s past exceedance in National Ambient Air Quality Standards (NAAQS) to 

wood combustion. And to address why the USFS concludes that the greatest risk to air quality in 

the region arises from cruise ship emissions in Wilderness. Additionally, scoping comments 

requested that the DEIS review public safety concerns with biomass combustion facilities and 

disclose the risk of explosions to the public.

RESPONSE

Comments suggest that disclosure of the risks to human health caused by pollutants, in particular those 

created by the combustion of wood projects (biomass burning or other wood burning in wood stoves) be 

presented more clearly. Comments also suggest the specific causes attributed to the 1990’s exceedance 

of National Ambient Air Quality Standards in the city of Juneau be disclosed. Comments also suggest that 

the analysis in the DEIS inadequately evaluates the effects of air pollution on Tongass resources, in 

particular human health and provide some citations for us to review and consider in our analysis.

This amendment is not focused on biomass. Some portion of the harvested timber may be used in 

energy production as biomass but the amount and timing of such use is uncertain. Therefore, the 

consequences of harvesting as biomass is not a focus of the analysis. Discussion of biomass and its 

production of particulate and other air pollutants are identified in the FEIS Chapter 3 Air section.

Biomass boiler facilities in schools, hospitals, health clinics and office buildings, proposed in any plan by 

the USDA Forest Service would be required to undergo project-level NEPA analysis, which indeed would 

evaluate the risks to human health as a possible consequence of these types of actions. The Forest Plan 

Amendment, however, is not a focused project plan on biomass facilities or any other specific renewable 

energy proposal. The Plan Amendment provides for opportunities for any proponent of renewable energy, 

including the development of biomass facilities, to consider such actions through additional project-level 

NEPA. 

With regard to the causation of exceeded the NAAQS which occurred in the Juneau area during 1990-97, 

the EIS indicates that the sources of pollutants are probably local and anthropogenic (Dillman et al. 2007) 

(see page 3-19). The exact sources of these air pollutants is uncertain since the Forest Service has no 

jurisdiction for monitoring on non-NFS lands. The EPA through ADEC issues air permits to industrial 

sources that demonstrate compliance with the Alaska Ambient Air Quality Standards, which are identical 

to the National Ambient Air Quality Standards (NAAQS). The primary standards were developed to 

protect public human health and the secondary standards to protect public welfare. Linking pollutants to 

specific sources would be speculative on our part; however possible sources for particulates are 

described in Dillman et al. (2007). Because we currently do not have an abundance of biomass boiler 

facilities on the Tongass N.F. they currently are considered to provide low levels of particulate into the 

atmosphere and are not currently contributing to levels of air pollution that would trigger exceeding 

NAAQS. The discussion in Chapter 3.1 concerning air pollution sources discusses cruise ship emissions 

in Wilderness as one of the greatest contributors to particulate into the atmosphere which currently has 

the greatest risk to air quality in the region. When and if biomass facilities or other additional uses of 

biomass are proposed on National Forest System Lands, the sources and its affects will be properly 

analyzed through project-specific NEPA.

Final EIS I-59 DEIS Comments and Responses
Appendix I

The Forest Service does acknowledging that an increase in wood burning could adversely impact air 

quality, but has not quantitatively analyzed those impacts. Because this amendment does not propose 

any specific biomass or wood-burning energy development, we have no specific parameters to evaluate 

for any of the alternatives. EPA and ADEC have regulatory responsibility, under the Clean Air Act, for air 

quality related to these kinds of sources. The enforcement of the applicable regulations by these 

agencies is anticipated to keep any potential adverse effects within the standards for air quality; therefore 

we conclude that no significant indirect effects from the uses of the Tongass National Forest should 

occur.

DEIS Comments and Responses I-60 Final EIS
Appendix I

Geology/Soils and Physical Setting (SOIL)

COMMENT

SOIL-1: The EIS incorrectly describes the history of Glaciation of Tongass.

RESPONSE

This section of the EIS was intended to tell the reader that the long history of glaciation shaped the 

landscape of Southeast Alaska. We agree that the data presented in this paragraph misses an important 

point, namely that by about 13,500 years ago much of southeast Alaska was ice free (Geology section, 

page 3-25 in the DEIS). This particular paragraph of the introduction has been in the Forest plan EIS 

since 1997 and was not updated for the amendment. The statement was not an “effort to halt responsible 

development and utilization of the forest”. A sentence has been added to this paragraph in the FEIS to 

clarify that by about 13,500 years ago much of Southeast Alaska was ice free.

Final EIS I-61 DEIS Comments and Responses
Appendix I

Streams and Watersheds (S&W)

COMMENT

S&W-1: Stream surveys are inadequate and critical information concerning the stream miles by 

class in the whole forest is not presented. These gaps—and the failure to acknowledge or analyze 

them— have the result that the DEIS understates the likely effects of logging and roadbuilding on 

aquatic habitat.

RESPONSE

The DEIS (and FEIS) discloses that streams may be missing from the corporate layer at the forest level. 

During project planning, field surveys are conducted to add and correct streams to support effects 

analysis and ensure stream protection during project implementation according to Forest Plan standards 

and guidelines. Field efforts place high priority on areas with high probability of unmapped fish streams. 

Standard field procedures are followed (USDA Forest Service 2015c).

During project planning, field surveys are conducted to add and correct streams to support effects 

analysis and ensure stream protection during project implementation according to Forest Plan standards 

and guidelines. Field efforts place high priority on areas with high probability of unmapped fish streams. 

Standard field procedures are followed (USDA Forest Service 2015c). Decisions at the project level will 

consider the additional streams and effects. Text was added to the water section to clarify the meaning of 

the percent water bodies in watersheds within 300 feet of roads and the footnote on Table 3.4-1 has been 

revised to state that additional unmapped streams are present, as opposed to unmappable.

COMMENT

S&W-2: The DEIS presents a misleading picture of current watershed condition in areas impacted 

by logging.

RESPONSE

Text additions were added in the FEIS to clarify status of watersheds and the source of that information. 

Additional details for each watershed are available in the project record and on an interactive map 

available to the public at http://apps.fs.fed.us/nfs/nrm/wcatt/WCFMapviewer/ 

Effects to specific watersheds proposed to be harvested in the future, including young-growth harvest in 

RMAs outside of TTRA buffers, would be evaluated during project-specific analysis.

COMMENT

S&W-3: Standards and Guidelines for stream surveys are not implemented before decisions on 

road building and harvest are made, especially for small headwater streams.

RESPONSE

See response to S&W-1.

Annual BMP monitoring results summarized in the annual Forest Plan Monitoring and Evaluation reports 

include additional detail on the implementation of forest plan standards and guidelines for stream 

protections. These are available in the record.

COMMENT

S&W-4: The DEIS does not properly assess sedimentation effects of log landings.

RESPONSE

Landings in the Tongass system are generally part of the road systems, which was assessed to their 

effect to water quality sediment as well as fish in both water and the fish sections. Text was modified to 

include reference to landings when discussing effects of roads.

DEIS Comments and Responses I-62 Final EIS
Appendix I

Fish (FISH)

COMMENT

FISH-1: Logging, particularly old-growth, adversely affects salmon species. Additionally, the 

TTRA buffer does not prevent harvest in Riparian Management Areas (RMAs) of class III and IV 

streams, including patch cuts in Alternative 5, which may affect sediment, flow and nutrient in 

downstream fish bearing streams.

RESPONSE

Alternatives 1, 3 and 4 would generally prevent harvest in RMAs, including Class III streams. 

Alternatives 2 and 5 require that treatments in RMA must achieve stream process group objectives 

(Appendix D). In these alternatives, some harvest in the form of thinning in young-growth RMA is 

proposed outside of TTRA buffers along Class I, II and III streams. A watershed analysis, as described in 

Forest Plan Appendix C, would be needed for implementing any alternative that proposed to enter the 

RMA. BMPs for all alternatives combined with the Fish and Riparian Standards and Guidelines also 

apply. In addition, under Alternative 5, a 100-foot no harvest buffer has been applied around anadromous 

lakes

COMMENT

FISH-2: Logging results in elevated stream temperatures that are detrimental to fish and 

conditions may worsen in the project area considering future climatic change caused stream 

temperature increases.

RESPONSE

The Forest Service believes that the current and Final Proposed Forest Plan Standards and Guidelines 

(refer to Chapter 4, Chapter 5, and Appendix D) minimize riparian harvest in order to maintain streamside shade. Chapter 3 Water and Fish sections disclose and discuss likely effects of past and planned 

riparian harvest on stream temperatures. The Forest Service does not see a need for additional 

restrictions at the Forest Plan level. Analysis conducted under the NEPA process would evaluate sitespecific resource impacts and cumulative effects from individual timber sales or other extractive activities, 

and adjustments would be made as needed to ensure protection of these resources. 

Additional information regarding temperature effects on small streams has been added. See Chapter 3 

Water.

COMMENT

FISH-3: Logging increases stream flow, which is detrimental to fish.

RESPONSE

Stream flow effects will be extremely difficult to ultimately resolve given a number of limitations including 

disentangling the effects of multiple vegetation and road management treatments (including young-growth 

harvest) that overlap in both time and space, along with potential effects attributable to climate change 

(Grant et al. 2008). The EIS acknowledges uncertainty with respect to the effects of timber harvest and 

roads on stream flows. 

COMMENT

FISH-4: Logging increases sediment input in streams including from increased landslides and 

may be a greater issue for Alternative 5, which would allow harvest to the banks of some class III 

and all class IV streams. 

RESPONSE

The preferred alternative would allow harvest to the banks of Class III streams in existing young-growth 

stands for the first 15 years following signing of the ROD. All alternatives allow harvest to the banks of 

Final EIS I-63 DEIS Comments and Responses
Appendix I

Class IV streams. For steep slopes (>72%) and Class IV streams a slope stability analysis is required 

(page 4-61 and 5-11) and this requirement will minimize the number of management induced landslides 

and sediment to stream courses. 

The standards, guidelines and management approaches in Chapter 5 describe how project level 

interdisciplinary teams are to consult Appendix D for objectives for riparian areas (including lakes and 

Ponds and Class III streams) and to protect those resources while providing a commercial young-growth 

product. All BMPs designed to keep sediment out streams and lakes still apply. Annual BMP monitoring 

conducted in 2014 concluded that prescribed BMPs were mostly or fully implemented during timber 

harvest, road, and facilities activities and have been effective in limiting or preventing sediment transport 

to streams (USDA Forest Service 2015)1. Timber harvest within riparian areas will still need to move the 

stand toward old-growth conditions to meet the objectives of the RMA. 

The data presented in Table 3.3.5 in the DEIS was based on an assumption that a similar rate of 

landslide occurrence would occur as a result of young-growth harvest as occurred as a result of oldgrowth harvests. The estimate is based on the best available science at this time and the DEIS (pages 3-

43 and 44) discusses the factors that contribute to the uncertainty. The draft forest plan still requires a 

slope stability analysis for timber harvest on slopes over 72%, although the on-site analysis of slope 

stability is not required for young-growth stands. The DEIS page 3-43 and 44 explains why this is a 

reasonable approach and why harvest on slopes over 72 percent will likely become less of an issue (page 

3-43). The Forest Service has no data regarding landslide frequencies as a result of young-growth 

harvest in southeast Alaska. Text in the Chapter 3 Water was modified for clarification.

COMMENT

FISH-5: Logging in riparian areas including outside of the TTRA 100-foot buffers reduces large 

woody debris to streams, affecting fish habitat.

RESPONSE

Most of the large woody debris recruited to stream channels would occur from the TTRA buffer. However, 

some reduction in woody debris in stream channels could occur in RMAs outside of the TTRA buffer 

depending on alterative. Riparian Management objectives would be maintained as proposed under 

Alternatives 1, 3, and 4. Alternatives 2 and 5 require that management in young growth riparian areas 

accelerate old-growth characteristics to improve riparian function, but would allow some harvest in younggrowth outside of TTRA buffers (refer to Water section). Alternative 2 allows only for commercial thinning 

of up to 33 percent of stand basal area over more than 36,000 RMA acres. This Alternative would likely 

have additional adverse effects to fish habitat not common to the other alternatives and could result in a 

loss of large woody debris to portions of floodplain and alluvial fan channel types. While Alternative 5 

allows up to 10 acre openings and commercial thinning totaling no more than 35 percent of the total stand 

acres, it is estimated to be about 900 acres of total harvested RMA area and will only occur in the first 15 

years of the finalization of the Plan Amendment. With these restrictions, the overall areas affected would 

be small relative to the total RMA acres in the Tongass. A watershed analysis (as described in Forest 

Plan Appendix C) would be needed for implementing any alternative that proposed to enter the RMA. 

COMMENT

FISH-6: Logging adversely affects food for salmon by allowing harvest along class III and IV 

streams.

RESPONSE

It is understood that much of the food supply in fish streams originates from Class III streams and a 

significant portion of that food source is terrestrial, entering from riparian vegetation. Alternatives 1, 3 and 

4 would generally prevent harvest in RMAs, including Class III streams. Alternatives 2 and 5 require that 

treatments in RMA must achieve stream process group objectives (Appendix D). In these alternatives, 

1 USDA Forest Service. 2015. Annual Monitoring and Evaluation Report for Fiscal Year 2014. R10-MB-770. Ketchikan, Alaska. 

Available online at: http://www.fs.usda.gov/detail/tongass/landmanagement/planning/?cid=stelprd3856205

DEIS Comments and Responses I-64 Final EIS

 
Appendix I

some harvest in the form of thinning in young-growth RMA is proposed outside of TTRA buffers along 

Class I, II and III streams. A watershed analysis, as described in Forest Plan Appendix C, would be 

needed for implementing any alternative that proposed to enter the RMA. BMPs for all alternatives 

combined with the Fish and Riparian Standards and Guidelines also apply. As is noted in the Fish 

Section of the EIS, while changes to riparian vegetation on fishless streams will alter the composition of 

the food sources transported downstream, the overall effect on downstream fish streams over the long 

term is not clear, as actions near these small streams may have additional effects on stream production 

(Wipfi and Gregovich 2002). 

COMMENT

FISH-7: Forest Service must retain or improve existing protections in both riparian and shoreline 

areas to protect salmon.

RESPONSE

The proposed plan components and BMPs would adequately protect fish and water resources on the 

Tongass National Forest and additional restrictions at the Forest Plan level are not necessary. Analysis 

conducted under the NEPA process would evaluate site-specific resource impacts and cumulative effects 

from individual timber sales or other extractive activities, and adjustments would be made as needed to 

ensure protection of these resources. The amount and location of land available for timber harvest varies 

by Alternative. Plan components protect watershed resources and watershed analysis will be conducted 

where conditions indicate the need. 

COMMENT

FISH-8: Road construction in riparian areas increases stream temperature. 

RESPONSE

The EIS Water and Fish sections discussion acknowledges and addresses the effects of roads and 

harvest on water quality, stream flow, and watershed condition. The EIS acknowledges that risks to 

aquatic resources would increase with more harvest and associated road construction and would vary by 

alternative (refer to the Fish and Water sections including additional text to the water section addressing 

potential temperature effects of roads). Site-specific evaluations, and if needed based on standard and 

guidelines, watershed analysis would be conducted for all timber harvest proposals to evaluate if specific 

adverse effects would occur and identify how best to modify the actions to minimize these specific effects. 

COMMENT

FISH-9: Roads increase stream flow and peak flow timing, impacting stream channels and 

degrading fish habitat. The Forest Service should adopt a plan that involves fewer newly 

constructed road miles.

RESPONSE

The DEIS discusses and analyzes the effects of harvest and roads on streamflow on pages 3-64 through 

3-68. The cumulative effects of roads and timber harvest on streamflow are discussed on pages 3-77 

through 3-80.

COMMENT

FISH-10: Roads increase sediment entering streams and adequate stream buffers would reduce 

this sediment input. 

RESPONSE

The EIS acknowledges the risks of roads to streams and the need to control sediment delivery to water 

bodies. Standards and guidelines for road construction have been developed to keep these risks at low 

levels with measures such as avoiding steep, unstable slopes, taking roads out of use after harvest is 

complete, including removal or stormproofing culverts. Recent monitoring demonstrates that the 

Final EIS I-65 DEIS Comments and Responses
Appendix I

maintenance program practices are effective in minimizing sediment transport from roads (USDA Forest 

Service 2015). Potential sediment effects are evaluated on a site-specific basis during the NEPA 

evaluation of timber sales and other projects, and as needed adjustments will be made to reduce the risks 

and ultimately the effects of roads to streams and control sediment delivery to water bodies. 

COMMENT

FISH-11: Habitat access and fish passage at road crossings of streams must be considered and 

adequately monitored.

RESPONSE

Providing for fish passage at stream and road intersections to ensure fish migration is an important 

consideration when constructing, reconstructing, or storing forest roads. Standards and Guidelines direct 

specialists to avoid location of roads near fish-bearing streams and to seek locations that avoid fish 

streams, crossing streams when other locations are not feasible and fish habitat can be protected. All fish 

stream crossing installations in all action alternatives will be designed to meet fish passage standards. 

The Tongass National Forest strives to incorporate an adaptive management process to achieve the 

desired management goals and objectives for the fish passage at road crossings program. The adaptive 

management approach includes a continuous process of using, or developing, state-of-the-art 

assessment and restoration techniques followed by monitoring and adjustment of the techniques 

accordingly. 

The Forest Service plans to continue to monitor all new and recent culvert installations in fish streams. A 

subsample of culverts installed from 1998 to present in fish streams are monitored annually. Only nonbottomless culvert installations are evaluated since they are more problematic for fish passage than 

bridges and bottomless culverts which routinely do not impede fish passage. 

Furthermore, the transition to young growth will be managed at a pace that allows operators to adjust, 

adapt, and develop markets for new products. The duration and scale at which old growth harvest will be 

needed is unclear. Factors such as the role of State and private land in contributing wood supply to a 

viable industry; the availability of suitable young growth that is mature and economic to harvest; export 

and domestic processing policies; and fluctuations in domestic and world markets for forest products must 

be considered but are unpredictable, and will influence the timeframe for transition. 

COMMENT

FISH 12: The Forest Service must consider options that would lessen road-building and protect 

salmon from its serious, varied harms.

RESPONSE

In the DEIS- Transportation, affected environment page 3-273 there is a description of the intent of the 

road construction to provide access to NFS lands. As mentioned in the environmental consequence 

section, page 3-275 the Forest will implement the Best Management Practices to protect water quality. 

The potential effects to the resources such as plants and fish are discussed in the subject resource 

sections. Relative to concerns associated with invasive plants, in the Plants, Environment & Effects 

section on page 3- 156 there is a discussion about the potential effects from road construction. This 

section mentions that the potential effect on risk of increased invasive plants as inferred from the amount 

of anticipated soil disturbance associated with alternative 5 would be intermediate relative to the other 

alternatives. There is a discussion in the cumulative effects section relative to invasive plants on pages 

3-159- 3-160. In the end of this section the intent of the application of mitigation through the standards 

and guidelines as well as ongoing invasive control measures will contribute to minimize the cumulative 

effects of road building. The environmental effects relative to water are addressed in the section starting 

on page 3-49 and specific description relative to roads and road construction starts on 3-65. This section 

examines the miles of projected road construction relative to road densities as well as projected 

construction and reconstruction in beach/ estuary areas and riparian management areas. In the summary 

of this section on page 3-77, the analysis concluded that alternative 5 would have little overall effect to 

water quality in comparison to the current condition. The discussion of the cumulative effects of water 

DEIS Comments and Responses I-66 Final EIS
Appendix I

associated with roads starts on page 3-77. In this section, the Forest states that the application of the 

Best Management Practices will moderate the effect of the proposed action. In reference to details about 

the cumulative increase of estimated road miles is included on page 3-79. The environmental effects to 

fish are addressed starting on page 3-97 and a description of the fish and aquatic resources as well as 

streams and watersheds follows. Mention of roads and associated impacts is included on page 3-104, 

culvert replacements and removals at road crossings on page 3-109. Specific discussion of fish passage 

across roads is included on page 3-114- 3-115 and details associated with the number of stream 

crossings by alternative is displayed. Detailed description of alternative 5 and the potential impact on 

riparian management areas is included on page 3-123. 

COMMENT

FISH 13: Inappropriately designed or located hydroelectric projects harm salmon.

RESPONSE

The analysis presented in this EIS is programmatic and provides overall Forest-wide direction. Project 

specific analyses are conducted for specific projects, such as hydropower developments. Project-level 

analyses quantify all the impacts—beneficial and adverse—of a proposed project. Potential impacts may 

include impacts to fish. Analysis conducted under the NEPA process would evaluate site specific 

resource effects and cumulative impacts from hydropower developments, and adjustments would be 

made as needed to ensure protection of resources.

Additional information has been added to the Fish section of the FEIS under the Renewable Energy 

Development subsection. 

Chapter 5 of the Forest Plan includes the following renewable energy standard for fish:

“Assure that renewable energy projects continue the productivity of existing fish populations and habitat.”

COMMENT

FISH 14: The Forest Service should consult with the National Marine Fisheries Service on 

Essential Fish Habitat.

RESPONSE

The reasons for not consulting with NMFS regarding EFH is provided on page 3-125 in the DEIS. The 

EFH assessment and NFMS consultation will occur at the project scale for projects that affect essential 

fish habitat.

COMMENT

FISH-15: Climate change poses a serious threat to salmon that could be exacerbated by proposed 

actions in the Draft Forest Plan. 

RESPONSE

The Forest Service has modified the Fish section discussion on climate change. We believe the current 

discussion of effects of climate change on fish resources and their habitat is adequately addressed in this 

section as revised. 

COMMENT

FISH 16: Forest Service should measure the economic contributions of salmon produced on the 

Tongass.

RESPONSE

This request is beyond the scope of this Forest Plan Amendment. 

Final EIS I-67 DEIS Comments and Responses
Appendix I

COMMENT

FISH-17: One commenter noted that the DEIS overstates log transfer and log storage facilities 

effects on marine habitat, while another indicated that LTF facilities assessment was incomplete 

inaccurate and did not consider the current and future effects of these facilities on the marine fish 

and habitat conditions. It was also noted that the considered actions should be addressed in an 

Essential Fish Habitat (EFH) assessment.

RESPONSE

Explanation of need and potential number of LTFs is included in the Transportation Section of the FEIS. 

The effects of LTFs on marine fish, shellfish and habitat conditions was modified, expanded and 

presented in the Fish Section of the FEIS. The analysis includes further descriptions of mitigation and 

monitoring actions, state law requirements, and Forest Service limitations in place to protect marine 

resources from LTF and log storage sites and notes that future development of a substantial number of 

new LTF facilities is unlikely considering projected future harvest. The reasons for not developing and 

EFH analysis at this planning level is presented in the Fish section. 

COMMENT

FISH-18: The Forest Plan should address road long-term road maintenance obligations under the 

CWA exemption for construction and maintenance of forest roads. It is not enough to only

consider the initial construction of a road, and treat BMP violations that emerge later as merely 

part of an existing condition that are unrelated to any project decision.

RESPONSE

The DEIS/FEIS adequately discloses the effects of roads on fish passage and BMP compliance. The 

Forest Service plans to continue to address past culvert problems as funding is available. Determining 

funding levels is outside the scope of this Forest Plan Amendment EIS. Current standards and guidelines 

and Forest Service Handbook direction for culvert installation have requirements to ensure fish passage 

is provided when fish are present at the crossing areas. All road construction and reconditioning will be 

completed in conformance with Forest Plan Standards and Guidelines and best management practices 

(BMPs). Recent monitoring demonstrates that the current maintenance program practices are effective in 

minimizing sediment transport from roads (USDA Forest Service 2015)

As is stated in the DEIS (and FEIS) the Forest Service considers fish passage to be an important priority 

and has an ongoing program to eliminate or replace culverts that do not provide passage. Information on 

the status of the current culvert inventory relative to fish passage can be found in the Fish section of the 

Draft and Final EIS. The number of potential stream crossings identified in the EIS provides a relative 

approximation of the potential number of culverts by alternative (Table 3.6-4 on DEIS page 114-115); an 

exact number of future culverts cannot be determined prior to site-specific analyses. The exact number of 

culverts would be determined at a project level and the potential effects would be addressed as part of 

the project-specific NEPA analysis at that time. The Forest has a substantial database that identifies the 

status of nearly all existing fish stream – road crossings and includes detailed fish passage information 

(available in the project record). 

COMMENT

FISH-19: The analysis of the effects from road crossings, both new and reconstructed, on fish 

passage and associated stream sediment is deficient in the DEIS.

RESPONSE

Additional information and clarification has been added to the Fish section of the Final EIS discussing 

risks to streams and fish habitat from road reconstruction including stream crossings. The Forest Service 

agrees that providing for fish passage at stream and road intersections to ensure fish migration is an 

important consideration when constructing, reconstructing, or storing forest roads. Current standards and 

guidelines direct specialists to avoid location of roads near fish-bearing streams and to seek locations that 

DEIS Comments and Responses I-68 Final EIS
Appendix I

avoid fish streams, crossing streams when other locations are not feasible and fish habitat can be 

protected. All fish stream crossing installations in all action alternatives will be designed to meet fish 

passage standards (refer to references cited 

in https://www.researchgate.net/publication/265814797_Road_Surface_Erosion_Part_1_Summary_of_Eff

ects_Processes_and_Assessment_Procedures for further information).

COMMENT

FISH-20: The DEIS fails to recognize that damage to fish habitat means loss of fish production 

and harm to the fishing industry.

RESPONSE

See response to FISH-1. Effects to fish populations from future actions cannot be directly quantified given 

the number of outside variables, such as ocean conditions and population fluctuations. However, past, 

present and future actions are discussed by quantifying factors known to have increased risk to fish 

habitat. All of the proposed alternatives have a substantial number of measures that would be 

implemented during timber harvest to protect fish habitat, many of which were not in place during most of 

the past timber harvest. 

COMMENT

FISH-21: The DEIS does not clearly present effects to fish populations and watershed conditions. 

RESPONSE

The DEIS/FEIS adequately discloses and discusses the effect of each alternative, including relative to 

road-related parameters, in the Water and Fish sections of Chapter 3. These and other site-specific 

variables would be evaluated more precisely during project-level planning.

COMMENT

FISH-22: Fishing, largely commercial, has devastated populations of the wild salmon and 

steelhead in our rivers throughout Southeast Alaska.

RESPONSE

The FEIS provides baseline information on commercial fish harvest, including past harvest in Chapter 3 

Fish. In Chapter 3 Wildlife, the FEIS acknowledges that the amount of human activity in the marine 

environment associated with Forest management activities is only a fraction of the total amount of human 

activity occurring in the marine environment. Some of the other activities include commercial fishing, sport 

fishing, hunting, subsistence, tourism, and mariculture. Assessing the overall effects of past commercial 

fishing on wild populations throughout Southeast Alaska is outside of the scope of this amendment.

Final EIS I-69 DEIS Comments and Responses
Appendix I

Riparian (RIP)

COMMENT

RIP-1: No-cut buffers should apply to all anadromous water bodies, including lakes, ponds, and 

wetlands.

RESPONSE

All alternatives provide old growth no-harvest buffers along Class I, II, and III streams. TTRA directs that 

no commercial timber harvest is allowed within a minimum of 100 feet horizontal distance either side of 

Class I streams and Class II streams that flow directly into a Class I stream. RMAs outside of TTRA are 

protected in accordance with the intent of the Anadromous Fish Habitat Assessment (1995), through 

application of the direction contained in Riparian Management Area Standards and Guidelines (Appendix 

D) and through application of BMPs. Riparian buffers vary in width, depending on site-specific conditions, 

including stream class, channel type, and the risk of windthrow. The areas identified in the comment are 

generally included in the riparian buffers. 

In reference to young-growth outside of TTRA buffers, Alternatives 1, 3 and 4 would generally prevent 

harvest in RMAs. Alternatives 2 and 5 allow only for commercial thinning in RMA’s with maximum removal 

varying from 33 percent (Alternative 2) to 35 percent with created openings (< 10 acres) allowable. 

Commercial thinning in Alternative 2 would occur over a majority of all the available young-growth RMA 

areas. Alternative 5 commercial thinning is limited in area based on model assessment. Forest Plan 

Standard S-YG-RIP-02 constrains young-growth harvest in these areas to a one-time only entry and to 

the first 15 years unless best available scientific information shows that additional entries are: a) 

warranted, and b) meet the LUD objectives. However, the harvest prescription is less restrictive. Under 

all alternatives, any commercial harvest in RMAs (excluding TTRA buffers) must be compatible with 

direction contained in Riparian Management Area Standards and Guidelines (Appendix D). A watershed 

analysis would be required for implementing any alternative that proposed to enter RMA. BMPs 

combined with the Fish and Riparian Standards and Guidelines would also apply. Every project and 

activity must be consistent with the applicable plan components, including the desired conditions. (36 

CFR 219.15(d))

In addition, under Alternative 5, a 100-foot no harvest buffer has been applied around anadromous lakes.

COMMENT

RIP-2: The language of TTRA mandates buffers of "at least" 100 feet and the effect of an RMA 

would seem to be widening that buffer.

RESPONSE

Forest Plan Appendix D provides a detailed description of the standards and guidelines applicable in 

Riparian Management Areas, including the requirements of TTRA.

COMMENT

RIP-3: The proposed action is concentrating timber production in the most valuable areas. 

Targeting riparian areas for timber harvest will use and develop legacy roads and landings that 

should be allowed to continue their natural path to restoration, especially in floodplains and on 

alluvial fans. Harvesting in riparian areas will affect LWD recruitment, sediment delivery, and 

hydrologic connectivity.

RESPONSE

See response to FISH-5 and FISH-10. The DEIS/FEIS discloses these effects, which must also be 

considered at the project level. Under all alternatives, any commercial harvest in RMAs must be 

compatible with direction contained in Riparian Management Area Standards and Guidelines (Forest Plan 

Appendix D). A watershed analysis (Forest Plan Appendix C) would be required for implementing any 

DEIS Comments and Responses I-70 Final EIS
Appendix I

alternative that proposed to enter RMA. BMPs combined with the Fish and Riparian Standards and 

Guidelines would also apply. 

The DEIS acknowledges that existing legacy roads would be reconstructed. However, it is unlikely that 

many of the original valley bottom (floodplain and alluvial fan) legacy roads would be used to access 

timber because of the risk to productive fish habitat and cost of reconstruction. This would be evaluated at 

the project-scale.

Final EIS I-71 DEIS Comments and Responses
Appendix I

Botanical Resources (BOT)

COMMENT

BOT-1: Sensitive Plants: The USFS should provide more detail in the Forest Plan Amendment 

regarding the largest population of one sensitive plant, lesser round-leaved orchid, and the recent 

monitoring results indicating a decline in known sightings within the Big Thorne Project area on 

Prince of Wales Island. The USFS should also address climate change as a threat to the species. 

The FEIS should more specifically address these concerns and the body of literature related to 

this sensitive plant. 

RESPONSE

Forest Service policy requires that a review of programs and activities be conducted to determine their 

potential effect on threatened and endangered species, species proposed for listing, and Regional 

Forester-designated sensitive species (FSM 2670.31-2670.32). The Forest Service has prepared a 

Biological Evaluation (see FSM 2670.3) for Plants for the Forest Plan Amendment (see Forest Plan 

Amendment Planning Record) that presents the analysis and determination of effects for the Forest 

Service sensitive species, including the lesser-round leaved orchid. Preparation of a Biological Evaluation 

(BE) as part of the National Environmental Policy Act (NEPA) process ensures that sensitive species 

receive full consideration in the decision-making process. 

Sensitive plants are those plants identified by the Regional Forester for which population viability is a 

concern on National Forest System (NFS) lands within the region. A viability concern is identified by 

either a significant existing or predicted downward trend in population numbers or density, or a significant 

existing or predicted downward trend in habitat capability that would reduce a species’ existing range in 

the planning area. For forest planning purposes, a planning area is one or more identified National 

Forest(s) (FSM 2605). 

The analysis area for the Plan Amendment Plant BE is the Tongass National Forest (i.e., the plan area), 

which includes all biological populations existing in whole or in part of the plan area. Because population 

viability is evaluated at a Forest-level, we considered all known occurrences of the lesser round-leaved 

orchid throughout the plan area, which includes a larger land base than the analysis conducted for the Big 

Thorne Timber Sale (i.e., Big Thorne project area).

Recent population mapping of all occurrences of the lesser round-leaved orchid by the Alaska Natural 

Heritage Program conducted in 2015 using national mapping standards and definitions of populations2 

resulted in 61 distinct populations. Of the total area occupied by the 61 known populations, 44 percent is 

located within non-development LUDs and 56 percent is located within development LUDs (USDA Forest 

Service 2015). 

We acknowledge that approximately 50 percent of the known occurrences of lesser round-leaved orchids 

occur on Prince of Wales Island. Therefore, half of the known occurrences exist elsewhere on the 

Tongass. The largest occurrences are concentrated in east-central Prince of Wales Island near Thorne 

Bay, AK. Other concentrations are on western Revillagigedo Island, Gravina Island, and southern Etolin 

Island. The northern limit of known occurrences on the Tongass is on Wrangell Island. (USDA Forest 

Service 2015).

A recent pilot monitoring of population trend for this species on Prince of Wales Island suggests a 

potential decrease in population density of 57 percent in a two-year monitoring period (USDA Forest 

Servie 2015). The severity of the potential downward trend emphasizes the need for continued 

monitoring of lesser round-leaved orchid to understand whether the short-term pattern observed suggests 

a possible concern about the long-term persistence of this species on this portion of the Tongass. Factors 

related to a potential downward trend are uncertain and may include a this species’ inherent dormancy 

(and therefore cryptic nature); mycorrhizal associations of the plant and soil; herbivory; changes in soil 

2 Populations are defined differently than occurrences. Rare and sensitive plant occurrences documented in the 

Tongass National Forest database do not always correspond to the definition of a population.

DEIS Comments and Responses I-72 Final EIS

 
Appendix I

moisture regime over the long term as a result of long-term climatic variation; management impacts, such 

as changes in light and soil regimes as a result of timber harvest and road construction, among other 

factors. Furthermore, the monitoring sample size was small, resulting in high variation among the sample 

plots. A larger number of sample plots would be needed to reduce this variation. Thus, we have a limited 

ability to make robust conclusions regarding trends indicated by the monitoring results. Because 

monitoring is focused on a small sample of known locations, which are limited to only a portion of the 

Forest over a two-year monitoring period, inferences regarding downward trends may only apply to 

populations on the portion of Prince of Wales Island where monitoring has occurred. Current monitoring, 

does not sample populations across the full range of this species in the plan area and; therefore, should 

not be used to make accurate inferences as to this species’ viability status across the Tongass.

Substantial timber harvest and road construction has occurred within development LUDs within the range 

of this species on the Tongass. The Old-growth Conservation Strategy provides for large reserves of oldgrowth habitat, in particular within the non-development LUDs; resulting in conserving at least 40 percent

of the known populations of lesser-round leaved orchid and their habitat across the Forest.

Key threats to this species and its habitat in the development LUDs continue to be impacts from timber 

harvest and road construction. These threats were analyzed in Chapter 3 of the DEIS (pages 3-142 

through 3-159) and in the Draft Plant BE (see Forest Plan Amendment Planning Record). Several largescale harvests of mostly mature to old-growth timber are currently being planned within the range of this 

species. If implemented, these projects could impact a substantial amount of habitat and known 

occurrences. However, Forest-wide standards and guidelines in the approved Forest Plan (USDA 2008b, 

page 4-41) have been implemented in current and on-going project NEPA analysis and have provided 

protection of many lesser round-leaved orchids occurrences by buffering and avoiding known 

occurrences during timber layout for several timber sale areas; illustrating a concerted effort to avoid and 

minimize impacts to known occurrences from timber harvest and road construction. Continued 

implementation of the standards and guidelines are fully anticipated for the life of the Plan Amendment 

and therefore, impacts will be minimized.

Predicted increase in average temperatures in southeast Alaska due to climate change could theoretically 

expand the range of the lesser round-leaved orchid and other sensitive plants northward on the Tongass. 

Recent collaboration with the Alaska Natural Heritage Program will provide the Tongass with better 

information on future climate change scenarios associated with several sensitive plants (work in 

progress). Until we receive this work on species assessments and the associated climate change 

scenarios, the future expansions or contractions in sensitive plant ranges within the Planning Area is 

uncertain. Unlike the research and findings related to the effects of yellow-cedar due to climate change 

(Hennon et. al. 2016), no specific work has been done on any of the sensitive plants in Region 10 related 

to climate change impacts on their distribution and extent. 

Fragmentation of habitat due to past and potential future management activities could inhibit the ability of 

lesser round-leaved orchid and its habitat to adapt or migrate. As the level of old-growth harvest 

decreases under this Forest Plan’s transition period, fragmentation will become less of a concern. The 

lesser round-leaved orchid is also subject to browsing or grazing by a number of herbivores, but the 

effects of herbivory on the Tongass populations is currently not known. Collection or trampling by 

recreationists is likely to be a minor threat, since the flowers are small and the plant can be difficult to see 

in its shady forest habitat. Additionally, the rarity of this species across its range may be at least partially 

due to the rarity of its pollinators.

We recently evaluated the lesser-round leaved orchid in light of the Tongass old-growth Conservation 

Strategy and our most recent information on the numbers of occurrences within the plan area (USDA-FS 

2015). We concluded that with 44 percent of their population areas occurring within non-development 

LUDs, combined with the on-going and active implementation of 2008 Forest Plan direction in this Forest 

Plan for avoiding and minimizing impacts to this species, that current science evidence does not indicate 

a substantial concern for the capability of lesser round-leaved orchid to persist over the long-term in the 

Tongass plan area (USDA Forest Service 2015). 

Furthermore, in our evaluation of the direct, indirect, and cumulative effects as required through the BE

process, we considered timber harvest and road construction – the two management actions identified in 

Final EIS I-73 DEIS Comments and Responses
Appendix I

this Plan Amendment NEPA analysis as most impacting - and conclude that the consequence of adverse 

effects on currently unknown and known occurrences in the Tongass would be low because 

approximately 40 percent of the known occurrences are not currently threatened by proposed 

management activities. In addition, Forest-wide standards and guidelines under all alternatives would 

consider protection to minimize impacts to known occurrences of this species and new occurrences of

this species located during project surveys. Because, at the most, approximately 17 known occurrences 

are expected to be within old-growth harvest units, and another 29 known occurrences are expected to be 

within young-growth harvest units, out of the 291 distinct occurrences on the Tongass, there would be a 

relatively low level of risk to this species’ viability. Because of this plant’s abundance outside the Tongass 

no alternative would result in a trend toward federal listing (see the Biological Evaluation for Plants in the 

planning record, USDA 2016)

COMMENT

BOT-2: The DEIS needs to provide more detail about Forest Service plans to treat invasive plants 

– particularly the use of herbicides.

RESPONSE

Currently the Forest uses over 30 specific mitigation measures for invasive plant prevention and control 

for all management actions, ranging from timber sale programs, transportation planning and maintenance 

programs, renewable energy development, recreation and wilderness management and other special 

uses. Mitigation measures are identified in a draft guidance document that is currently undergoing 

revision (Krosse, P. March 2014). This document follows specific guidance for prevention and control 

measures as described in FSM 2900 (Invasive Species Management – November 2011). Additional 

directives associated with integrated pest management include FSM 2070 (Native Plant Material Policy) 

and FSM 2150 (Pesticide Use Management and Coordination Policy), the latter of which is particular to 

the use of herbicides. The draft guidance document provides 38 specific best management practices 

(BMPs) associated with invasive plants along with several exhibits which provide more information and 

direction on process and methods for applying these mitigation measures.

Due to the draft status of this document, it is premature to include it in the FEIS. However, the full intent 

of implementing mitigation measures associated with invasive plant management is comprehensively 

delineated in FSM 2900, which is incorporated by reference in the FEIS.

DEIS Comments and Responses I-74 Final EIS
Appendix I

Wildlife (WILD)

COMMENT

WILD-1: The Forest Service has not provided its assessment of wildlife viability or disclosed its 

reasoning and conclusions in the DEIS as it relates to well-distributed, viable populations.

RESPONSE

See response to PLR-2.

A thorough viability analysis was conducted during the 1997 Forest Plan revision. The Tongass 

Conservation Strategy was designed to provide enough old-growth habitat strategically placed across the 

Tongass National Forest to provide for viable and well distributed populations under old-growth logging 

for 100 years; old-growth associated species were emphasized because that habitat is what was targeted 

for harvest at the time. The basic Conservation Strategy of old-growth habitat reserves is still in place 

under this proposed amendment; no old-growth harvest is proposed in areas important to the 

Conservation Strategy such as old growth reserves, beach and estuary buffers, and riparian management 

areas. 

Young-growth harvest in conservation areas (Old-Growth Habitat LUD, RMA, beach) is limited by plan 

components established in Chapter 5 and include: maximum opening size, maximum percent of each 

stand that could be harvested, a one-time entry per stand, and desired conditions to accelerate oldgrowth characteristics. If young growth harvest is proposed within Old-Growth Habitat LUD, an 

interagency biologist team will review the possibility of modifying the boundaries to exclude that younggrowth in exchange for increasing the old-growth protected within the reserve boundary.

One purpose and need of this amendment is to transition to primarily young-growth harvest in about 15 

years. Although old-growth harvest will still occur under the amended Forest Plan, it will be at levels 

lower than those analyzed under the 1997 Forest Plan and will be for a shorter duration (10-15 years) 

than previously evaluated (100 years). There will be a phased approach to the transition - the maximum 

old-growth harvest (for 10 years or so) and maximum young-growth harvest (beyond 15 years) will not be 

taking place at the same time. . In addition, the level of old growth harvest that occurred since 1997 has 

been less than the maximum anticipated in the mid-1990s viability analysis.

Standards and Guidelines in Chapter 4 also remain in place, such as designing projects to maintain 

landscape connectivity; nest buffers for goshawks, marbled murrelets, and herons and raptors; and den 

buffers for wolves.

COMMENT

WILD-2: The Forest Service should make a concerted effort to maintain remaining wildlife 

corridors and leave strips in heavily fragmented developed areas.

RESPONSE

One Forest-wide Goal stated in Chapter 2 of the Forest Plan is “Maintain the abundance and distribution 

of habitats, especially old-growth forests, to sustain viable populations in the planning area” and this is 

considered during project planning. In addition, Forest-wide Standard and Guideline WILD1.VI pertains 

to Landscape Connectivity: projects are to be designed to maintain landscape connectivity between large 

and medium Old-Growth Habitat reserves and other forested non-development LUDs, and young-growth 

treatments that accelerate old-growth characteristics should be considered in beach fringe, riparian 

buffers, and other lands not suitable for timber production.

In order to transition in 10-15 years as outlined in the Secretary’s Memo and brought forward in the 

Purpose and Need, all young-growth lands were considered. Since the age of the young-growth stands is 

a limiting factor, the oldest stands of young growth are being considered for harvest to facilitate the 

transition. Many of the older young growth stands were harvested prior to having the current standards 

and guidelines and other restrictions in place; these older young growth stands that will have restrictions 

Final EIS I-75 DEIS Comments and Responses
Appendix I

or limitations on harvest under the proposed Forest Plan that will contribute to protection of habitat. For 

example, some of the oldest young-growth stands may have unmapped streams that will require stream 

buffers. Some areas may occur on soils that would have harvest deferred on them under the current 

forest plan. These areas are expected to add structure and habitat in patches and/or corridors in many of 

the older young growth stands.

All alternatives provide old growth no-harvest buffers along Class I, II, and III streams. TTRA directs that 

no commercial timber harvest is allowed within a minimum of 100 feet horizontal distance either side of 

Class I streams and Class II streams that flow directly into a Class I stream.

See response to CONS-11.

COMMENT

WILD-3: Specific attention should be made to improve habitat conditions in ecologically 

important areas and emphasize timber production in intensive rotational forestry areas near mills 

and roads.

RESPONSE

“Include a young-growth management program to maintain, prolong, and/or improve understory forage 

production, and to improve habitat distribution, including future old-growth characteristics in young-growth 

timber stands for wildlife on lands both suitable and not suitable for timber production” is a Forest-wide 

Objective from Chapter 2 of the Forest Plan and is considered during project planning. At the Forest Plan 

level, land use designations are used to designate general areas where development such as timber 

harvest can occur. Site-specific information regarding economics (for example, logistics and proximity to 

infrastructure) and resource considerations (for example, ecological importance) are evaluated by an 

interdisciplinary team during project planning. Specific stand treatment objectives are also completed at 

the project level. 

The Tongass uses intermediate silvicultural treatments to meet a variety of objectives in our young-growth 

stands. Precommercial thinning is the most predominant management tool prescribed to improve tree 

growth and stand vigor, as well as allow for more light to reach the understory, allowing a more robust 

and persistent understory including forage. Follow up treatments can be planned for young growth where 

the objective is other than long-term rotational harvest. Some of these treatments may include creation of 

canopy gaps, pruning and/or slash reduction. In areas of timber intensive objectives, precommercial 

thinning can improve the understory and stand health for the benefit of wildlife and other resources during 

the decades the stand is growing prior to reaching economical or ecological maturity.

COMMENT

WILD-4: The LRMP suitability determinations failed to respond to multiple use values in heavily 

logged biogeographic provinces on the central and southern end of the Tongass where high 

volume and large tree POG already have substantial cumulative impacts.

RESPONSE

The DEIS acknowledged that parts of the Forest have been logged more intensively than others, 

including Prince of Wales Island. The DEIS, page 3-202, states: “As development continues through 

timber harvest and associated activities such as roadbuilding, and community expansion, particularly in 

areas where extensive development as already occurred (i.e., Prince of Wales Island), maintaining 

connectivity and roadless refugia will become increasingly important, particularly for wide-ranging species 

whose distribution depends on some level of connectivity across the landscape.” In addition, Tables 3.9-

16, 3.9-17, and 3.9-18 show cumulative impacts by biogeographic province for total POG, high-volume 

POG, and large-tree POG for all ownerships across Southeast Alaska, clearly showing some 

biogeographic provinces with higher percentage harvest than others.

In order to expedite transition away from harvesting old growth, all young-growth lands were considered. 

Since the age of the young-growth stands is a limiting factor for commercial harvest, the oldest stands of 

DEIS Comments and Responses I-76 Final EIS
Appendix I

young growth are being considered for harvest to facilitate the transition, and it is necessary to harvest 

older young-growth stands in these areas of the Forest in order to meet the stated Purpose and Need of 

the amendment. This harvest also provides an opportunity to improve habitat conditions for wildlife and 

fish and improve stand function in places that could benefit from restoration; the opportunity to advance 

these stands toward old-growth conditions would be lost if young growth was not considered in previously 

harvested areas. 

Old growth timber harvest will be limited to the Timber Management, Modified Landscape, and Scenic 

Viewshed LUD as is allowed under the 1997 and 2008 Forest Plans. Changes to these LUDs as suitable 

for old growth harvest are not proposed as part of this amendment. Legacy standards and guidelines 

apply to old-growth harvest in heavily harvested VCUs. To complete the transition to primarily young 

growth harvest, it is inherently necessary to do that young growth harvest in areas with previous old 

growth harvest. Roadless area direction also limits timber harvest to areas that have roads, which 

generally means past timber harvest.

Also see WILD-6

COMMENT

WILD-5: All alternatives would result in federal lands remaining at the stem exclusion phase 

which is not consistent with the need to provide long-term understory forage production.

RESPONSE

The EIS acknowledges that the management of young-growth stands for commercial timber harvest will 

reset the stand development process when even-aged harvest is used, transitioning older young-growth 

stands currently in the stem exclusion stage back to stand initiation. Young growth stands that would be 

harvested under the proposed amendment are typically a minimum of 65-75 years old (DEIS page 3-

310), and have not yet reached the understory reinitiation stage which occurs at around 150 years of age 

in Southeast Alaska (Alaback 1984); Alaback also found that forests with open, patchy canopies tend to 

produce the most understory vegetation while those even-aged forests in the 30 – 150 year produced the 

least understory vegetation. 

Over time, active management of these stands for commercial timber harvest (repeated entries) would 

delay the development of old-growth. Alternative 5 addresses this by including a one-time entry for 

young-growth harvest in the beach fringe, RMAs, and Old-Growth Habitat LUD during the first 15 years 

after Plan approval (S-YG-BEACH-02, S-YG-RIP-02, and S-YG-WILD-02) and a desired condition to 

accelerate old-growth conditions in these areas (DC-YG-BEACH-01, DC-YG-RIP-01, and DC-YG-WILD01). Ultimately, all of the action alternatives would result in the maintenance of more old-growth forest 

across the landscape than originally assumed during the development of the 1997 Tongass Conservation 

Strategy.

COMMENT

WILD-6: Cumulative effects of non-federal logging heightens the need to downscale federal 

second growth logging. This is especially apparent in areas such as Kosciusko Island, which was 

acknowledged by the Forest Service in other analysis, and likely in POW and southern Revilla due 

to the scale of foreseeable Sealaska and Alaska Mental Health Trust logging, other smaller scale 

areas.

RESPONSE

The Draft EIS presents the cumulative effects of old-growth timber harvest under each alternative in 

Section 3.9 – Biodiversity (Table 3.9-16). As noted in the comment, the EIS describes assumptions made 

about future harvest on non-NFS lands. However, the EIS analysis assumed that these harvested lands 

never return to old-growth condition (i.e., they are conservatively assumed to make no contribution over 

time to the old-growth land base once harvested). This assumption also is conservatively used for 

existing young-growth on non-NFS and NFS lands.

Final EIS I-77 DEIS Comments and Responses
Appendix I

The cumulative effects discussion notes that the future cumulative reduction in POG would result in 

increased fragmentation and loss of connectivity. It further notes, that edge effects such as shifts in 

species composition may reduce natural biodiversity over time by favoring some species over others and 

that these effects would be lessened by the action alternatives which propose a transition to younggrowth harvest. Based on the analysis included in Table 3.9-16, additional discussion has been added to 

the Final EIS identifying where on the Tongass, these effects are most likely to occur (i.e., those areas 

that have experienced the most past harvest). However, more detailed, location-specific analyses of 

cumulative effects, such as in the Kosciusko Vegetation Management and Watershed Improvement EA 

referenced by the commenter, necessarily occur at the project-level where proposed harvest units can be 

identified and effects can be evaluated in the context of the surrounding landscape (i.e., the presence and 

proximity of non-NFS lands, future land exchanges, and other factors in relation to proposed harvest units 

or other activities on NFS lands). Any future proposed project on the Tongass would undergo its own 

NEPA analysis and must demonstrate consistency with the Landscape Connectivity standard and 

guideline. Moreover, it is possible at the project level to adjust the location of proposed actions to 

minimize cumulative impacts. For these reasons, the cumulative effects analysis in this EIS adequately 

addresses timber harvest on non-NFS lands and therefore does not warrant republication of the Draft 

EIS.

Also see WILD-4.

COMMENT 

WILD-7: The Forest Service needs to provide more information on how young-growth 

management will benefit wildlife and explain what is meant by “maintain” and “improve.” 

RESPONSE

The 2012 Planning Rule (36 CFR 219.19) defines maintain for ecological conditions: “To keep in 

existence or continuance of the desired ecological condition in terms of its desired composition, structure, 

and processes.” It also says this may be done by active or passive management or both depending on 

the circumstances. Although “improve” is not defined in the Planning Rule, the general definition would 

simply mean to make better, which in this case would be to move the habitat toward the Forest Plan 

desired conditions, or toward the habitat conditions needed to support a particular species if that is the 

objective of a specific project. Habitat preferences are discussed in the FEIS for selected species 

(Wildlife section) and in general terms of old-growth (Biodiversity section). It should be noted that the 

wildlife components of the Forest Plan remain under the 1982 Planning Rule, and specific updates to 

meet 2012 Planning Rule requirements are not proposed under this Forest Plan Amendment.

The transition to young-growth harvest proposed in the action alternatives would have a beneficial effect 

to wildlife species associated with old-growth forest by reducing the amount of old-growth timber harvest 

that would occur over the planning horizon. As described in Appendix D, about 400,000 additional acres 

of old growth will occur on the Tongass after 100 years of implementation under one of the current 

transition alternatives compared with the amount of old growth projected to be existing in 100 years under 

the 1997 Forest Plan. When developed for the 1997 Forest Plan, the Conservation Strategy was based 

on this assumed harvest level. This factor alone provides a tremendous benefit for those wildlife species 

that use old-growth habitat. Similarly, the overall level of road construction would be reduced 

substantially from the level assumed under the 1997 Forest Plan. Over 2,000 fewer miles of road would 

be developed over 100 years, which is expected to have substantial benefits for species affected by road 

density (e.g., wolf, marten). Finally, direct benefits of young-growth management will result by moving 

stem exclusion stage stands back to the stand initiation stage; this will be especially beneficial in locations 

with very high densities of stem exclusion stage forest. The EIS also notes in a number of locations the 

potential benefits of precommercial and commercial thinning and other silvicultural treatments. 

COMMENT 

WILD-8: The DEIS inappropriately grouped golden-crowned kinglet with early seral species.

DEIS Comments and Responses I-78 Final EIS
Appendix I

RESPONSE

The EIS affected environment of Section 3.10 – Wildlife correctly describes the golden-crowned kinglet as 

being associated with old-growth interior forest conditions. The effects analysis correctly identifies this 

species as one that primarily nests in POG forest, and therefore could be affected by old-growth timber 

harvest. The statement identifying this species as being associated with early seral habitat has been 

corrected. 

COMMENT

WILD-9: The amount of old-growth logging proposed likely violates the Endangered Species Act.

RESPONSE

The Tongass does not have any threatened or endangered species under ESA that use old-growth 

forests. 

WILD-10. The Forest Service should evaluate the cumulative effects of logging on all lands, 

including State managed lands, on wildlife and habitat connectivity.

RESPONSE

Cumulative effects to wildlife considered in Chapter 3 Wildlife, including evaluating deer habitat capability 

from all land ownerships. When combined with other management activities occurring on non-NFS lands, 

all alternatives would produce additional impacts associated with continued old-growth harvest to species 

for which this forest type is optimal habitat, such as goshawks, marten, mountain goats, red squirrel, redbreasted sapsucker, hairy woodpecker, brown creeper, and bat species. However, these declines in 

habitat (and associated effects such as fragmentation) would be lessened to some extent through the 

transition to young-growth harvest on NFS lands under Alternatives 2, 3, 4, and 5. 

COMMENT

WILD-11: Commercial thinning is not beneficial to wildlife or their habitats. Second growth 

stands should be allowed to return to old growth stands in order to protect wildlife.

RESPONSE

Additional text has been added to the Final EIS to acknowledge that although research has shown that 

the removal of commercial-sized trees can promote tree growth and understory vegetation development, 

there remains some uncertainty about the effectiveness of young-growth treatments in benefiting wildlife

COMMENT

WILD-12: Logging in beach fringe, riparian areas, and old-growth reserves should be prohibited, 

or at least deferred for 15 years to protect sensitive avian species. Literature related to the effects 

of timber managed on avian species is limited in the EIS, and additional references should be 

added. Furthermore, the Marbled Murrelet (Brachyramphus marmoratus) should be considered in 

the forest planning.

RESPONSE

The potential adverse effects to wildlife associated with young-growth harvest in the beach and estuary 

fringe, RMAs, and the Old-growth Habitat LUD are discussed in the Wildlife section and more broadly, in 

the context of the Forest Plan conservation strategy, in Appendix D of the EIS. The EIS analysis includes 

alternatives which do not include harvest within the beach and estuary fringe, RMAs, and/or the Oldgrowth Habitat LUD.

The marbled murrelet was one of the species selected for detailed evaluation during the development 

1997 Forest Plan conservation strategy. For the 1997 Forest Plan, a series of panel assessments were 

conducted for a select group of species, including the marbled murrelet (Smith 1996), to evaluate the 

likelihood that various plan alternatives would maintain an abundance and distribution of habitat sufficient 

Final EIS I-79 DEIS Comments and Responses
Appendix I

to support viable and well-distributed populations across the planning area over the planning horizon. The 

panel assessment process was designed to provide the context for, and guide the development of, the 

Forest Plan Conservation Strategy. The results of the panel assessments are included in Appendix N to 

the 1997 Forest Plan FEIS (USDA Forest Service 1997b) and summarized (and supplemented with new 

information) in Appendix D of the 2008 Forest Plan FEIS (USDA Forest Service 2008b). A more detailed 

discussion of the marbled murrelet has been added to the Final EIS including an additional discussion of 

viability, drawing from the findings of the 1997 panel assessments has been added to the Final EIS. 

Specific Forest Plan components for this species are not proposed under this focused Forest Plan 

Amendment. 

COMMENT

WILD-13: The EIS underplays the importance that deadwood (both standing and on the ground) 

has to wildlife. Furthermore, the EIS should consider the effects that forest management would 

have on all endemic avian subspecies in Southeast Alaska that may be restricted to a limited area 

(e.g., Swainson’s Thrush and Song Sparrow), as well as Marbled Murrelet. In addition to 

protecting the 100 acres surrounding goshawk nests, the EIS should adopt guidelines for 

conservation within the projected goshawk foraging territory.

RESPONSE

The ecological values of young-growth stands are discussed in the Wildlife Section of the EIS and in 

Appendix D. The marbled murrelet was one of the species selected for detailed evaluation during the 

development 1997 Forest Plan conservation strategy. Additional discussion of this species has been 

added to the Final EIS. As noted in the comment, many species rely on habitats within the beach and 

estuary fringe. Effects of young-growth harvest on a subset of wildlife species, representative of others 

with similar habitat characteristics, is included in the Wildlife section including a discussion of endemic 

species. At the project level, additional endemic species could be addressed in detail taking into account 

site-specific landscape characteristics and species of greatest conservation need. These would include 

additional endemic species limited to certain portions of the Alexander Archipelago. Regarding goshawks, 

no additional changes in goshawk standards and guidelines are proposed under this Forest Plan 

Amendment. The DEIS statement about monitoring is in reference to the Tongass Monitoring and 

Evaluation Program; although the program is concurrently undergoing review, no changes are proposed 

under this Forest Plan Amendment.

See response to WILD-12

COMMENT

WILD-14: The productivity of thinned forests can diminish after 20-30 years following thinning 

treatment. The longevity of treatments should be considered when modeling the benefits of these 

treatments on deer habitat, as multiple treatments over time may be necessary to maintain 

adequate wildlife habitat.

RESPONSE

The interagency deer model does not have the capability of taking into account different types of younggrowth treatments. Therefore, it is conservative in that it does not account for the benefits of younggrowth management over time, including methods such as pruning that might extend the longevity of 

young-growth treatments. However, these benefits are described qualitatively in the discussion in the 

Wildlife section under Deer. A statement has been added to the final EIS disclosing that the forage in 

clearcuts is of lower nutritional quality than that of old-growth forest.

DEIS Comments and Responses I-80 Final EIS
Appendix I

Deer (DEER)

COMMENT

DEER-1: Forest Service should avoid projects that are likely to reduce deer populations in areas 

where deer density is already below Forest Service standards.

RESPONSE

An interdisciplinary team of resource specialists reviews possible effects of the project during project 

specific analysis, including changes in deer habitat. That analysis includes site-specific and landscape 

factors at an appropriate scale for each species. Each project implemented under the amended plan 

must document in the project decision how the project is consistent with the applicable plan components, 

including standards and guidelines. 

No changes are proposed to Chapter 4 standards and guidelines for deer density. WILD1.XIV.A.2 is a 

guideline to ensure consideration and evaluation of deer habitat needs during project planning, not a bare 

minimum deer density requirement for all agency actions. Use of the words “where possible” and 

“generally considered” convey that this is not an absolute requirement: “Provide, where possible, 

sufficient deer habitat capability to first maintain sustainable wolf populations, and then to consider 

meeting estimated human harvest demand. This is generally considered to equate to the habitat 

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

provinces where deer are the primary prey of wolves.” In addition, it goes on to say the biologist should 

consider additional local factors rather than relying solely on model outputs. Many places on the forest 

may not meet this number naturally and there are places where deer are not the primary prey item. This 

standard and guideline, while important, is only one part of a comprehensive strategy for maintaining 

population viability. 

COMMENT

DEER-2: Deer model results were not presented by WAA, denying the public a clear view of the 

Plan’s impact. Table 3.10-10 is mislabeled with a title saying that the data in the table is by WAA, 

when in fact it is by province. 

RESPONSE

This information was summarized in the FEIS and is available by WAA in the project record. The title of 

Table 3.10-10 has been corrected.

COMMENT

DEER-3: The DEIS should present deer model results for all lands; not just for NFS lands only. 

This practice of limiting the analysis of such impacts to only federal lands conceals impacts 

because the indirect effect of the alternatives acts on the environment as a whole regardless of 

land ownership, even if the direct effect is just on the federal land. (NGO2-061)

RESPONSE

The Tongass National Forest is the largest land owner in Southeast Alaska. Non-National Forest (NFS) 

ownerships lands are not governed by the same management direction as the Tongass National Forest 

(Forest Plan standards and guidelines, for example). In addition, the Forest Service does not maintain 

habitat data for all of the non-NFS lands in Southeast Alaska to be able to enter accurate data into the 

model. For these reasons, a zero value is assigned to all non-National Forest ownerships to provide a 

worst-case analysis. In addition, non-NFS lands are not within the jurisdiction of the Forest Service to 

determine what activities will take place or when / where those activities will occur (if any). Therefore, 

results are presented for NFS land only. Although reasonably foreseeable activities on other lands can 

be generalized (DEIS page 3-260 and Appendix C) to include probable timber harvest, road building, 

residential development, mining, recreation and tourism, specific size and timing of such activities over 

the planned 100 year harvest rotation are not known. As an example, although an Alaska Mental Health 

Final EIS I-81 DEIS Comments and Responses
Appendix I

Trust land exchange is proposed, various alternatives are being considered and a selected alternative is 

years away; therefore a site specific analysis under a separate NEPA is considered to evaluate effects of 

all alternatives of that proposal.

Table 3.10-15 in the FEIS shows deer density across all ownerships. The habitat capability outputs are 

still based on NFS land only but the density calculation is now shown for both NFS and all lands.

COMMENT

DEER-4: The DEIS violates NEPA by presenting deer model results as percent change, which is 

poor quality, misleading information because it conceals both the state of the environment and 

the impacts upon it. Deer model results should show an alternative with an immediate end to oldgrowth logging and a 250 year output.

RESPONSE

The deer model is used as a relative comparison tool between alternatives and at the Forest scale 

represents a general trend across the planning area. Percent change is used since these are modeled 

results, not actual deer known to inhabit the forest. Differences among deer habitat capability (theoretical 

deer numbers) do occur in the alternatives but the differences are small, as displayed in Table 3.10-10 in 

the DEIS. 

The Forest Plan amendment is proposing changes primarily to young growth harvest; stands that would 

be proposed for harvest are assumed by the deer model to currently be in the stem exclusion phase 

because they are all over 25 years old. The deer model does not assign differing values to varying 

harvest levels (thinning versus clearcutting) so the model assumes that harvest of a stand will reduce the 

winter value to zero or nearly zero. In this case, some alternatives propose clearcutting while others 

propose more thinning of young growth stands. Therefore modelled differences between alternatives, 

especially when looking forest-wide or by biogeographic province, seem slight. 

Programmatic planning at the forest level also includes evaluation of all lands suitable for harvest so the 

modeled habitat capability includes more harvest than is likely to occur once field reconnaissance and 

resource analysis are completed at the project level. At the project level, a site specific analysis can 

refine the projected effects of the project, including the specific stands proposed for harvest and what 

harvest prescriptions would be used, information on project area wildlife use and habitat conditions, and 

juxtaposition of those stands to each other as well as to known travel corridors.

The reason for the slight increase in the short-term is the harvest of stem exclusion phase stands which 

have minimal to no value in the model; the stand initiation phase these stands would be in for about the 

first 25 years post-harvest are modeled to have varying levels of forage value depending on other 

components of the model such as aspect and average snow levels. The deer model is used as a 

comparison tool between alternatives and represents a general trend. A 100-year rotation length is 

modeled, so both the 25 year post harvest (stand initiation) and 100-year post harvest (stem exclusion) 

phases are presented for comparison for each alternative considered in detail. The Forest Plan is 

intended to provide direction for 10-15 years but the model assumes the same direction (standards and 

guidelines) and maximum harvest rates for the full 100 years. In addition, all non-NFS lands are 

considered by the model to have zero winter habitat value for deer, providing a conservative estimate of 

habitat capability. A 250-year column would represent a return to old-growth conditions and is not 

necessary to present in the table as it would be similar to the original habitat capability.

All alternatives that were considered in detail were analyzed using the deer model. In depth resource 

analysis, such as calculating habitat capability, is not done for alternatives considered but eliminated from 

detailed study. Chapter 2 of the FEIS, provides the reasons for eliminating alternatives, which includes an 

alternative for the immediate end to old-growth logging and another for transition within 5 years. 

COMMENT

DEER-5: Managing forage and habitat for the Sitka Black-tailed deer would have a positive effect 

on the Wolf. The Forest Service should specify an objective for improvement in winter habitat 

DEIS Comments and Responses I-82 Final EIS
Appendix I

conditions for Sitka black-tailed deer within young-growth stands on Prince of Wales Island, 

sufficient to offset the ongoing effects of forest succession into stem exclusion. The objective 

should include precommercial thinning along with other treatments.

RESPONSE

Alexander Archipelago Wolves eat a variety of prey, with Sitka black-tailed deer a primary species 

especially in areas where other ungulate prey is not available, such as on Prince of Wales Island. 

Managing for a sustainable deer population in these areas would benefit wolves, although predator-prey 

relationships have a number of other factors besides just the population level. In some cases, deer 

forage species may be increased when a young growth stand is treated (harvested) but generalizing that

large clearcuts will maintain deer populations is overstating the role of one aspect of a complex 

population dynamic. 

Deer are considered and analyzed at the project level so that site-specific factors can be considered, 

such as local winter habitat capability (a critical season for deer survival), levels of subsistence use in the 

project area, and how different habitat types are spatially arranged. An interdisciplinary resource team 

works together to propose projects and analyze potential effects of the project; determining the type of 

harvest (for example, clearcut or commercial thinning) that will best contribute toward achieving desired 

conditions is part of that process. 

The Forest Service is actively conducting precommercial thinning on young-growth lands. Over 200,000 

acres have been precommercially thinned on the Tongass since 1979. In recent years, precommercial 

thinning has averaged approximately 5,600 acres per year.

COMMENT 

DEER-6. The Forest Service should approve actions with the least impact on Sitka Black-tailed 

Deer habitat. Support was expressed for the actions or alternatives with the least impact on Sitka 

black-tailed deer habitat.

RESPONSE

We appreciate the input provided. 

Final EIS I-83 DEIS Comments and Responses
Appendix I

Wolves (WOLF)

COMMENT

WOLF-1: Prince of Wales Wolves are in serious decline and continued logging will hasten the 

decline. The Forest Service must address the decline in deer winter habitat and wolves on the 

Prince of Wales Archipelago in the FEIS. Additionally, the Forest Service must explain whether 

and how the Proposed Forest Plan fulfills the agency’s obligations under NFMA to ensure the 

viability of the wolf. 

RESPONSE

See responses to WOLF-2 and DEER-5.

COMMENT

WOLF-2: The Draft Forest Plan directly violates the agency’s obligation under NFMA to adopt a 

Forest Plan that ensures the wolf remains viable in the Tongass. The Forest Service does not 

disclose how much of the Tongass is not expected to meet deer habitat capability of 18 deer / 

square mile.

RESPONSE

Table 3.10-14 of the Draft EIS summarizes the percentage of WAAs across the Tongass that would meet 

the 18 deer per square mile (modeled deer density based on the interagency deer model) Wolf Standard 

and Guideline after implementation of the alternatives. Changes in modeled deer habitat capability by 

biogeographic province are presented in Table 3.10-10 under Deer, but additional information relating this 

to the wolf standard and guideline has been added to the FEIS in the Wolf section. 

Additional information has also been added to the FEIS summarizing the findings of the recent U.S. Fish 

and Wildlife wolf status assessment (USFWS 2015), which notes that even with continued decline of 

wolves in GMU 2, viability of the species is anticipated to be maintained in Southeast Alaska. The 

integrity of the Tongass Conservation Strategy would be maintained by all alternatives (see FEIS 

Appendix D), and therefore no change is necessary to maintain a well-distributed and viable wolf 

population (see Forest-wide Standard and Guideline WILD1IIB).

See responses to PLR-2 and DEER-1.

COMMENT

WOLF-3: The FEIS must disclose and explain the agency’s assessment of the relevant science 

and explain its conclusions for a viable well distributed wolf population in light of the recent 

USFWS Wolf Findings. The Forest Service should strengthen the plan provisions governing 

wolves.

RESPONSE

The FEIS has incorporated additional information related to the recent status assessment for the 

Alexander Archipelago Wolf (USFWS 2015). 

Per Forest Plan WILD1.XIV.A.1, an interagency Wolf Technical Committee has been established and is 

reviewing information pertinent to wolf management. One objective is to develop recommendations for 

wolf and associated deer habitat management for Prince of Wales Island; findings and recommendations 

from their work is not yet available. 

Strengthening the plan provisions governing wolves is outside of the scope of this narrow amendment. No 

changes to WILD1.XIV (wolf standards and guidelines) are proposed.

See also response to WOLF-2.

DEIS Comments and Responses I-84 Final EIS
Appendix I

COMMENT

WOLF-4: The Forest Service needs to update DEIS based on USFWS Findings on the wolf.

RESPONSE

The FEIS has incorporated additional information related to the recent status assessment for the 

Alexander Archipelago Wolf.

COMMENT

WOLF-5: On Prince of Wales the Forest Service should develop a Wolf Habitat Management 

Program, reduce road densities, and avoid reducing deer habitat capabilities. 

RESPONSE

Human harvest of wolves is outside the scope of the amendment. Harvest and bag limits are set by the 

Federal Subsistence Board and the State of Alaska Board of Game. Chapter 4 standard and guideline 

WILD1.XIV.A.1.c states that in areas where wolf mortality concerns have been identified and road access 

is a significant contributing factor that road densities of 0.7 to 1.0 mile per square mile may be necessary 

but the decision to close specific roads is made at the district, island, or project level through Access 

Travel Management plans and is based on an evaluation of all affected resources.

See responses to WOLF-2 and WOLF-3.

COMMENT

WOLF-6: The design of very large OGRs in 1997 under the Conservation Strategy was arbitrary 

and insufficient for sustainability or viability of wolf populations.

RESPONSE

The Conservation Strategy was implemented in 1997 as an overall conservation framework for wildlife. It 

provides for the diversity of plant and animal communities as required by NFMA. Redesigning the very 

large Old Growth Habitat reserves, one component of the Conservation Strategy, is outside the scope of 

this focused amendment. All alternatives maintain the integrity of the Conservation Strategy. Potential 

effects are discussed in Appendix D. 

See also PLR-2.

COMMENT

WOLF-7: The Conservation Strategy was not revisited after the deer model was corrected.

RESPONSE

See PLR-2 regarding Conservation Strategy design.

The deer habitat suitability model is one tool used by resource managers to evaluate effects. It is used to 

compare the relative differences between alternatives. The model is periodically reviewed and updated to 

reflect current habitat relationships and modeling techniques. The design of the Conservation Strategy

did not rely solely on deer habitat capability; the panel of experts considered many other factors in 

establishing the conservation framework to maintain viable and well distributed wildlife populations across 

the Tongass. Redesigning the Conservation Strategy is not part of this focused amendment. 

COMMENT

WOLF-8: The 2008 and Proposed Forest Plans’ wolf guidelines are unenforceable, violating NFMA 

by not ensuring viability.

Final EIS I-85 DEIS Comments and Responses
Appendix I

RESPONSE

See responses to PLR-2, DEER-1, WOLF-2, and WOLF-3.

COMMENT

WOLF-9: The cumulative impacts of the alternatives to wolves and hunters were not disclosed in 

the DEIS.

RESPONSE

See responses to DEER-1, DEER-2, and DEER-3.

COMMENT

WOLF-10: The road density analysis for wolves was calculated using all lands when it should 

have included only roads below 1200 feet. High road density is a concern and should be reduced 

to be within the Forest Plan standard and guidelines.

RESPONSE

Road density below 1200 feet elevation has been added to the FEIS. 

Appendix N of the 1997 Forest Plan FEIS explains the road density standard and guideline that is in the 

Forest Plan: 

The Forest Plan contains a forest-wide standard and guideline that outlines a cooperative 

interagency analysis to identify regions where wolf mortality is apparently excessive. In such 

areas we would attempt to determine if the mortality is unsustainable and identify the probable 

causal factors of the excessive mortality. If road access and specific roads are identified as 

contributing to excessive mortality, then road closures or access management recommendations 

can be made and actions taken. In addition, seasons, harvest methods and bag limits need to be 

considered as population management tools by the ADF&G and Federal Subsistence Board as a 

cooperative approach to managing wolf mortality at a sustainable level. The Forest Plan, a 

programmatic forest plan, does not prescribe a rigid open road density limit. The Wolf 

Assessment Panel recommended not using a specific road density “rule of thumb.” This was 

contrary to Kirchhoff (1993) and Pletscher (1994) who recommended a road density limit of no 

more than one mile of open road/square mile. Appendix 13 lists WAA’s that currently exceed the 

0.7 mile road density identified in the Wolf Assessment and the miles of existing road that would 

have to be closed to reduce road densities to within these identified limits. Establishing a rigid 

road density level, and arbitrarily closing roads to meet this density, provides no management 

assurance that wolf conservation objectives would be achieved, and may unnecessarily limit 

overall public use of an established road system that may otherwise have no specific adverse 

impact on wolf mortality. Management recommendations for road and access management, if 

necessary, would result from the site-specific analysis discussed above that would identify a 

problem requiring a local and cooperative management resolution. Open road densities above or 

indeed below these referenced densities may be appropriate to effectively manage road-access 

related wolf mortality. This approach is taken by the Forest Plan.

Per Forest Plan WILD1.XIV.A.1, an interagency Wolf Technical Committee has been established and is 

reviewing information pertinent to wolf management on Prince of Wales Island.

COMMENT

WOLF-11: The DEIS does not consider flaws in the recent Archipelago Wolf ESA listing decision.

RESPONSE

The USFWS is the agency responsible for implementing the Endangered Species Act nationally, along 

with National Marine Fisheries Service for marine species. The FEIS reviewed and incorporated 

DEIS Comments and Responses I-86 Final EIS
Appendix I

information from the recent USFWS status assessment (2015) and listing decision (2016) and believes it 

to be the best available science. 

COMMENT

WOLF-12: The Forest Plan should refer to wolves as grey or timber wolves, not Alexander 

Archipelago wolves. 

RESPONSE

The FEIS has been updated to reflect the recent USFWS determination. No changes were made to the 

Forest Plan use of Alexander Archipelago wolf terminology, since this is the subspecies common name.

Final EIS I-87 DEIS Comments and Responses
Appendix I

Goshawk (GOSH)

COMMENT

GOSH-1. The Queen Charlotte Goshawk is a sensitive species and the Forest Service must 

maintain viable populations and habitat distributed across the range to avoid extirpation and/or 

federal listing. The DEIS does not provide a meaningful analysis for goshawks that includes 

continued old-growth logging in addition to young growth harvest in the beach fringe, RMAs, and 

Old-Growth Habitat LUD; cumulative effects of NFS and non-NFS lands including the Sealaska 

conveyance and old-growth harvest since 2008; or at a site specific scale for high-risk VCUs. The 

DEIS should have responded to concerns about the adequacy of the Conservation Strategy, 

considered alternative nest management strategies, and manage young growth to return it to old 

growth conditions.

RESPONSE

A review of the potential effects to the Conservation Strategy from the amendment is presented in 

Appendix D, as well as discussion on habitat for species intermixed in DEIS Chapter 3 analysis of 

Biodiversity and Wildlife. All alternatives include a proposal to adopt the interagency recommended OldGrowth Habitat reserve modifications that were necessary as a result of the Sealaska land conveyance 

on Prince of Wales and surrounding islands. See also the PLR-2 response regarding the Conservation 

Strategy.

The 1982 Planning Rule (in effect at the time of the 1997 and 2008 Forest Plans) directed that “fish and 

wildlife habitat shall be managed to maintain viable populations of existing native and desired non-native 

vertebrate species in the planning area.” The 1997 Forest Plan developed a conservation framework for 

wildlife that employed this now superseded regulation; this proposed amendment carries forward that 

Conservation Strategy and contains a goal of providing an abundance and distribution of habitats to 

sustain viable populations in the planning area (Tongass National Forest).

The goshawk is a Region 10 sensitive species. Goshawks are analyzed in the Biological Evaluation, 

available in the planning record. The DEIS provides a summary of that analysis on pages 3-211 to 3-212 

and 3-240 to 3-241 in the DEIS. The finding for goshawk is “may impact individuals but would not result in 

loss of viability of this species or a trend toward federal listing.” This finding took into account habitat 

needs and proposed management activities, and Forest Plan direction for goshawks. In 2007, the 

USFWS confirmed the Queen Charlotte goshawk Southeast Alaska Distinct Population Segment to not 

be warranted for listing under the Endangered Species Act. 

In addition, the 1997 and 2008 Forest Plan FEIS’s provide additional information on goshawk. These 

analyses included assumptions that old growth would be harvested at the maximum allowable rate under 

Forest Plan direction for 100 years and still found that goshawk populations would remain viable in the 

planning area; old growth harvest has been far less than that anticipated in those analyses. In the longterm this proposed amendment would further reduce old-growth harvest, although there is a necessary 

transition time until a primarily young growth harvest industry is anticipated; this is about 16 years under 

the preferred alternative. There is potential for short term localized disturbance to individual goshawks in 

beach fringe, RMAs, and Old Growth Habitat LUDs, which is taken into account in the BE finding for this 

species. 

Tables 3.9-12and 3.9-13 display Forest-wide (range of the goshawk) by biogeographic province total 

POG and high-volume POG; about 91 percent total POG and about 83 percent high-volume POG are 

expected to remain on the Forest under the preferred alternative (Alternative 5). These provide a good 

estimate of goshawk preferred habitat for analysis at the programmatic (Forest Plan) level. A smaller 

scale taking into account site specific information is done at the project level.

The young growth proposed for harvest in the beach fringe, RMAs, and Old-Growth Habitat LUD should 

accelerate those stands toward old-growth conditions (desired conditions DC-YG-BEACH-01, DC-YGRIP-01, and DC-YG-WILD-01). Forest-wide, suitable acres of young growth in beach fringe, RMA, and 

OG LUD are about 2 percent, 4 percent, and 3 percent of the total acres in that component, respectively. 

DEIS Comments and Responses I-88 Final EIS
Appendix I

Standards in these areas allow for a one time entry with a maximum of 10 acre openings and a maximum 

of 35 percent of the acres or basal area to be removed; these are the upper limits and it is unknown how 

often these maximums would meet the stated desired conditions. Project decisions will have to disclose 

how they meet plan components, including desired conditions. In addition, within Old Growth Habitat 

LUD, young growth treatments should emulate the natural scale and distribution of disturbance patterns 

(DC-YG-WILD-02). The Old-Growth Habitat LUD could also be modified using Appendix K process and 

criteria to eliminate young growth and gain old-growth within the reserve boundary if the interagency team 

thought this exchange beneficial (management approach). 

Existing nest buffer standards and guidelines remain in the Forest Plan, with the clarification that if there 

is not 100 acres of POG available, then the largest diameter young growth may be substituted. See the 

GOSH-2 response. 

Existing Forest Legacy standard and guideline also remains. This standard and guideline was 

implemented in the 2008 Forest Plan in place of a species-specific goshawk standard and guideline; this 

was to provide a more comprehensive approach (versus species-specific) and applies to high-risk VCUs 

across the Forest instead of just on Prince Of Wales Island. The proposed Forest Plan amendment 

clarified the existing standard and guidelines to apply to any VCU found during project level review to 

have POG harvest over 33 percent, not just those listed in the Forest Plan. Alternatives 3 and 4 also 

considered having it apply to young growth harvest in addition to old-growth harvest; this option is 

available to the responsible official to choose as part of the decision. 

COMMENT

GOSH-2: Comment recommends updating standards for management of goshawk nesting habitat 

to not remove nest buffers after two years of inactivity and to incorporate post-fledging areas.

RESPONSE

Buffers for known nests remain intact; the buffers that may be removed after two years of inactivity are for 

probable nest stands where no nest was located / confirmed. A clarification was made to the Forest-wide 

Standards and Guidelines for Northern Goshawk (including the Queen Charlotte goshawk subspecies) 

(WILD4, II. Sensitive Species, A.1.c. Nesting Habitat) to clarify that if productive old-growth alone is not 

sufficient to maintain an area of not less than 100 acres around a nest, the largest diameter young-growth 

forest will be used. Addition of new standards and guidelines for goshawk, such as addition to 

management of post-fledging areas, were not included as part of this focused amendment.

COMMENT

GOSH-3. The 2008 Forest Plan FEIS (Appendix C, page C-3) concluded that the Sealaska 

conveyance would require a plan revision based on the changes and inability to make up lost 

lands in the reserve system; it is arbitrary for the agency to reverse its previous position without 

an adequate explanation. 

RESPONSE

Although Appendix C of the 2008 Forest Plan FEIS indicated that the proposed Sealaska conveyance 

would require a plan revision (C-3), it also indicated this was still only proposed legislation that it was not 

possible to identify the types of Tongass lands and resources that would likely be affected by the proposal 

and “Consequently, the discussion of forest management implications for the potential conveyances is 

necessarily quite general” (C-2). The 2008 Record of Decision clarified this to state that “If at a later date 

one or both of these proposals become law, an analysis of the effects will be necessary to determine if a 

revision or amendment of the Forest Plan is warranted” (page 54). Thus, this amendment includes a 

review of the Old-Growth Habitat LUD affected by the conveyance, and proposes to adopt the 

interagency location for these reserves under all action alternatives (see Appendix E of the FEIS).

Final EIS I-89 DEIS Comments and Responses
Appendix I

Prince of Wales Spruce Grouse (PGR)

COMMENT

PGR-1: The DEIS does not disclose the Proposed Forest Plan’s risks to the spruce grouse. The 

Forest Service must explain and the FEIS must disclose whether and how the Forest Plan will 

ensure the continued viability of Prince of Wales spruce grouse. 

RESPONSE

Alternatives are ranked in relative order (comparison) of the amount of POG they harvest (DEIS page 3-

260) and thus the amount of fragmentation and potential risk to Prince of Wales Spruce Grouse. A shortterm benefit from increased forage availability may occur under all alternatives. 

Spruce Grouse is not a Management Indicator Species or a Region 10 sensitive species nor is it a 

species listed as threatened, endangered, proposed, or candidate under the Endangered Species Act. 

The population is large enough to support harvest (hunting). The current regulations issued from ADF&G 

have a harvest season of August 1 – May 15 with a bag limit of 5 grouse / day. The effects analysis 

acknowledges the species’ susceptibility to overharvest (DEIS page 3-233). A discussion of potential 

effects to spruce grouse in relation to timber harvest and road development is included in the FEIS. Road 

closures are managed at the district / island level through the Access and Travel Management Plans.

This species is also known to use young growth forest about 15-30 years in age. Proposed young-growth 

harvest under the Forest Plan amendment is for commercial harvest and would be in stands older than 

those used by spruce grouse. 

See response to PLR-2.

DEIS Comments and Responses I-90 Final EIS
Appendix I

Crossbills (CROSS)

COMMENT

CROSS-1: The DEIS does not adequately address effects to red crossbills or recognize them as a 

“species of greatest conservation need.” 

RESPONSE

A general analysis of migratory birds was included in the DEIS, including birds that use 

hemlock/spruce/cedar forest as their primary habitat; individual species were not analyzed. 

Red crossbill is included in the most recent Alaska Comprehensive Wildlife Conservation Strategy as a 

species in two species groups: a) landbirds with long-term declines and b) landbirds sensitive to forest 

management (ADF&G 2006, Appendix 3). Within the “landbirds with long-term declines” group, species of 

particular concern included the Olive-sided flycatcher, Blackpoll warbler, and Rusty blackbird; the red 

crossbill was identified as a species with “widespread declines but not in Alaska,” approximately 5 percent 

of the global population estimated in Alaska, and a slightly increasing abundance trend across the state 

(ADF&G 2006, Appendix 4). The State of Alaska is in the process of updating the strategy; the recent 

Alaska Wildlife Action Plan review draft (ADF&G 2015) does not include the red crossbill on the list of 

“Species of Greatest Conservation Need.” In addition, the 2010 Audubon Alaska “Watchlist” does not 

include the red crossbill on its list of Alaska species vulnerable or declining and warranting conservation 

attention. 

Final EIS I-91 DEIS Comments and Responses
Appendix I

Northern Flying Squirrel (NFSQ)

COMMENT

NFSQ-1: The Forest Service has not considered available information or cumulative effects on 

Northern Flying Squirrel.

RESPONSE

The DEIS acknowledges that flying squirrels have limited dispersal capability and that abundance may be 

reduced through forestry practices that reduce the structure or age of residual stands or create openings 

too wide (page 3-259). Some additional discussion has been added to the FEIS regarding cumulative 

effects to flying squirrel and flying squirrel viability.

The 1982 Planning Rule (in effect at the time of the 1997 and 2008 Forest Plans) directed that “fish and 

wildlife habitat shall be managed to maintain viable populations of existing native and desired non-native 

vertebrate species in the planning area.” The 1997 Forest Plan developed a conservation framework for 

wildlife that employed this now superseded regulation; this proposed amendment carries forward that 

Conservation Strategy and contains a goal of providing an abundance and distribution of habitats to 

sustain viable populations in the planning area (Tongass National Forest). NFMA requires forest plans to 

“provide for the diversity of plant and animal communities based on the suitability and capability of the 

specific land area.” This is achieved through implementation of the Conservation Strategy and Forest 

Plan direction.

DEIS Comments and Responses I-92 Final EIS
Appendix I

Kittlitz’s Murrelet (KMUR)

COMMENT

KMUR-1: The DEIS does not consider effects of climate change on Kittlitz’s Murrelet.

RESPONSE

The Biological Evaluation (BE) concludes that the proposed amendment may affect individuals but is not 

likely to cause a trend toward listing for this species (located in planning record). Page 25 of the BE 

acknowledges that disturbance or displacement of foraging Kittlitz’s murrelets could slightly impact 

foraging success or energy reserves (indirect effects of associated marine traffic near young growth or 

renewable energy site management). 

Cumulative effects for TES species are considered in the BE on pages 29-31, including a paragraph on 

general climate change. Climate change could affect the Kittlitz’s murrelet if saltwater glaciers melt and 

change preferred foraging habitat or if preferred nesting habitat (unvegetated scree slopes, cliffs, rock 

ledges) are affected such as by vegetation encroachment; quantifiable information is not available on 

what those effects might be and any such effects would be distant in the future and unrelated to the 

Forest Plan amendment. 

Final EIS I-93 DEIS Comments and Responses
Appendix I

Marten (MART)

COMMENT

MART-1: Forest Service needs to address the status of the Pacific marten and explain how the 

Draft Forest Plan affects its viability in the Tongass.

RESPONSE

See response to PLR-2.

The DEIS acknowledges there are two lineages of marten in Southeast Alaska (page 3-220). The FEIS 

adds language regarding taxonomic uncertainty of the marten and the recent information suggesting two 

distinct species (Dawson and Cook 2012). Additional discussion has been added to the FEIS.

COMMENT

MART-2: The DEIS fails to meaningfully examine the impacts associated with the Draft Forest 

Plan’s proposal to log in OGRs, beach fringe, and riparian buffers on marten.

RESPONSE

Marten are strongly associated with old growth (late successional) forest and riparian areas including the 

breach fringe. Only young growth harvest would be authorized in the beach fringe, riparian areas, and 

Old-Growth Habitat LUD under the amendment; old growth harvest would remain not suited for timber 

production in these areas. Young growth harvest in these areas would be aimed to accelerate old growth 

conditions in these areas under the preferred alternative (desired conditions), which should benefit 

marten. Alternatives 3 and 4 consider implementing legacy standards in young growth harvest; all 

alternatives would evaluate landscape connectivity among reserves during project analysis.

All alternatives provide old growth no-harvest buffers along Class I, II, and III streams. TTRA directs that 

no commercial timber harvest is allowed within a minimum of 100 feet horizontal distance either side of 

Class I streams and Class II streams that flow directly into a Class I stream. Alternative 5 allows up to 10 

acre openings and commercial thinning totaling no more than 35 percent of the total stand acres in beach 

fringe, RMA, and Old-Growth Habitat LUD, and will only occur in the first 15 years of the finalization of the 

Plan Amendment; it is estimated to be about 3,500 acres of beach fringe, 900 acres of total harvested 

RMA area, and 1,800 acres of Old-Growth Habitat LUD. With these restrictions, the overall areas 

affected would be small relative to the total beach, RMA, and Old-Growth Habitat LUD acres in the 

Tongass.

COMMENT

MART-3: The DEIS misses important recent information (Goldstein et al. 20133) that marten use 

young growth and did not evaluate viability.

RESPONSE

See response to PLR-2.

Additional information on marten use of young growth habitat and marten viability has been updated in 

the FEIS. 

The marten effects analysis in the DEIS focuses on old-growth (POG) timber harvest because 1) the 

strong association of marten with structural complexity typically found in old-growth forest, 2) the 

importance of low elevation high volume POG to marten in winter, and 3) preference for landscapes with 

forest interior habitat conditions. However, DEIS page 3-250 acknowledges that both old-growth and 

young-growth harvest would reduce the vertical and horizontal structural complexity needed by marten. 

3 Goldstein, M.I., L.H. Suring, C.D. Vojta, M.M. Rowland, and C. McCarthy. 2013. Developing a Habitat Monitoring Program: Three

Examples from National Forest Planning. in USDA Forest Service. 2013. A Technical Guide for Monitoring Wildlife Habitat. GTRWO-89.

DEIS Comments and Responses I-94 Final EIS

 
Appendix I

In addition, road density is displayed in Table 3.10-12 for NFS lands and for all ownerships. Under the 

preferred alternative about 12 percent of the WAAs on the Forest would exceed 1 mile per square mile 

road density for all roads, with less than 3 percent of WAAs exceeding that when open roads on NFS 

lands are considered. 

Alternatives 3 and 4 considered applying legacy forest structure during young growth harvest in those 

high risk VCUs listed in WILD1.IV; this demonstrates consideration of science indicating marten’s use of 

young growth. This option is available for the responsible official to choose as part of the decision.

The 1982 Planning Rule (in effect at the time of the 1997 and 2008 Forest Plans) directed that “fish and 

wildlife habitat shall be managed to maintain viable populations of existing native and desired non-native 

vertebrate species in the planning area.” The 1997 Forest Plan developed a conservation framework for 

wildlife that employed this now superseded regulation; this proposed amendment carries forward that 

Conservation Strategy and contains a goal of providing an abundance and distribution of habitats to 

sustain viable populations in the planning area (Tongass National Forest). 

Final EIS I-95 DEIS Comments and Responses
Appendix I

Black Bear (BLABE)

COMMENT

BLABE-1: The DEIS’s cursory analysis of black bears does not rise to the level of a hard look 

required by NEPA and the Forest Service should employ the 2012 Planning Rule.

RESPONSE

Black bears need old growth forest for denning but during the spring and summer seasons use a variety 

of habitats, including young clearcuts. Anadromous (Class I) streams are important to bears in the late 

summer as they build fat reserves for hibernation; these are protected from harvest under the proposed 

amendment. Inventoried Roadless Areas will also provide areas of undisturbed habitat for black bears 

beyond what was anticipated during the 1997 Forest Plan viability analyses. Large and medium reserves 

are also not scheduled for harvest; small reserves may have up to 35 percent of the young growth 

harvested but the reserve may be modified at the project level to exclude the proposed harvest and 

replace it with old growth if the interagency team proposes such modification. The black bear population 

in much of southeast Alaska appears stable (ADFG 20154). 

All alternatives provide old growth no-harvest buffers along Class I, II, and III streams. TTRA directs that 

no commercial timber harvest is allowed within a minimum of 100 feet horizontal distance either side of 

Class I streams and Class II streams that flow directly into a Class I stream. While Alternative 5 allows up 

to 10 acre openings and commercial thinning totaling no more than 35 percent of the total stand acres, it 

is estimated to be about 900 acres of total harvested RMA area and will only occur in the first 15 years of 

the finalization of the Plan Amendment. With these restrictions, the overall areas affected would be small 

relative to the total RMA acres in the Tongass.

See also PLR-2.

4 ADF&G. 2015. Black Bear Management Report. Individual Game Management Unit (GMU) reports for GMUs 1A, 1B, 1C, 1D, 2, 3, 

and 5 were accessed at http://www.adfg.alaska.gov/index.cfm?adfg=wildliferesearch.smr20145

DEIS Comments and Responses I-96 Final EIS

 
Appendix I

Brown Bear (BROBE)

COMMENT

BROBE-1: The DEIS needs to analyze Brown Bear effects more fully and use the 2012 Planning 

Rule.

RESPONSE

Brown bears do need large areas of undisturbed habitat. Additional undisturbed habitat beyond the 1997 

and 2008 analyses will be maintained in Inventoried Roadless Areas in the future; no young growth or old 

growth harvest will take place in these areas under the selected alternative. Young growth harvest that 

would be available for harvest in the Old Growth Habitat LUD is primarily located in small reserves near 

current development LUDs, not in the medium and large reserves that are more important for brown 

bears. Much of the prime brown bear habitat on the Forest is located in areas protected by the Forest 

Plan – Wilderness, LUD II, and other non-development LUDs on the mainland, Admiralty and Baranof 

Islands, and portions of Chichagof Island. Prince of Wales Island contains a large portion of the young 

growth that would be harvested under the amended Forest Plan; no brown bears persist on this island 

which further reduces risk to the species.

All alternatives provide old growth no-harvest buffers along Class I, II, and III streams. TTRA directs that 

no commercial timber harvest is allowed within a minimum of 100 feet horizontal distance either side of 

Class I streams and Class II streams that flow directly into a Class I stream. While Alternative 5 allows up 

to 10 acre openings and commercial thinning totaling no more than 35 percent of the total stand acres, it 

is estimated to be about 900 acres of total harvested RMA area and will only occur in the first 15 years of 

the finalization of the Plan Amendment. With these restrictions, the overall areas affected would be small 

relative to the total RMA acres in the Tongass.

See also PLR-1 and PLR-2.

Final EIS I-97 DEIS Comments and Responses
Appendix I

Bats (BAT)

COMMENT

BAT-1: The DEIS fails to consider or disclose impacts on Keen’s Myotis and other bat species. 

RESPONSE

Seven species of bats are known to occur in Alaska; all but the little brown bat is restricted to Southeast 

Alaska (http://www.adfg.alaska.gov/index.cfm?adfg=citizenscience.batsinak). Bats occur in low 

densities in Alaska, and distribution, abundance, and behavior are poorly understood; ADF&G has 

ongoing research and monitoring efforts to learn more about the bats in Alaska 

(http://www.adfg.alaska.gov/index.cfm?adfg=citizenscience.bats). Timber harvest may be a threat to little 

brown bats, but activity was rare in young growth forest 

(http://www.adfg.alaska.gov/index.cfm?adfg=littlebrownbat.main). Across North America, large 

scale wind energy developments and White-Nose Syndrome (a fungal infection) are causing high 

mortality of bats. White-Nose Syndrome has not been documented in Alaska; the nearest known location 

is a recent confirmed infection in Washington state 

(http://www.usgs.gov/newsroom/article.asp?ID=4496#.Vww6GnL2ZMw ). The Draft Forest Plan is 

not proposing to harvest old-growth in riparian management areas (RMAs) but may have limited younggrowth harvest in these RMAs; bat activity in young growth is low. 

DEIS Comments and Responses I-98 Final EIS
Appendix I

Amphibians (AMPH)

COMMENT

AMPH-1: The Forest Service must include an analysis of potential impacts on amphibians from 

logging and roads.

RESPONSE

A discussion of amphibians has been added to the Final EIS. This includes a discussion of those species 

potentially present on the Tongass, as well as potential effects associated with old-growth and younggrowth timber harvest such as fragmentation, road mortality, exposure to contaminants along roads, and 

cumulative effects associated with climate change.

Possible effects to riparian areas, which could influence amphibians survival and production, are also 

disclosed in the FEIS in the Water, Wetlands, and Fish sections.

COMMENT

AMPH-2: Amphibians are especially susceptible to air pollution. 

Because amphibians’ skin is permeable, they are especially susceptible to the harmful effects of air 

pollution. Atmospheric contaminants such as acidic compounds may also be deposited in aquatic 

ecosystems where amphibians live. In Southeast Alaska, air pollution from local or global sources may 

be contributing to a decline in amphibians’ numbers.

The DEIS predicts that “direct effects on air quality from forest management activities would be temporary 

and limited in nature” and may include emissions from industrial processing sites and firewood burning. It 

also notes that, cumulatively, air pollution from wood processing could “increase somewhat if more wood 

is burned to produce energy.” The Forest Service should consider the potential consequences of 

worsened air quality for amphibians in the FEIS, in light of their sensitivity to this kind of pollution.

RESPONSE

None of the alternatives are expected to result in long-term adverse impacts to air quality or compliance 

with air quality standards. All air quality effects associated with equipment usage, wood processing, etc. 

would be temporary and localized, and would occur infrequently over the planning horizon. Therefore, no 

effects to amphibians are anticipated in association with reduced air quality.

Final EIS I-99 DEIS Comments and Responses
Appendix I

Subsistence (SUB)

COMMENT

SUB-1: The Forest Service must engage communities to identify and prioritize restoration areas 

that will enhance local subsistence opportunities.

RESPONSE

Prioritizing restoration treatments is done at a scale smaller (districts and project level) than the Forest 

Plan. During every EIS the Forest Service holds subsistence hearings as required by ANILCA section 

810 in addition to public scoping and comment periods. These provide opportunities for communities, 

tribal members, subsistence users, and others to speak specifically to project effects to subsistence use. 

COMMENT

SUB-2: The treatment of subsistence deer hunting in the DEIS is arbitrary and masks local 

impacts to abundance and distribution of subsistence resources.

RESPONSE

At the programmatic level (Forest Plan), the DEIS conclusion of a significant possibility of a significant 

restriction on subsistence uses, particularly for deer, acknowledges that cumulatively across the Forest 

there could be areas where subsistence uses may be impacted. Each project that uses an EIS must hold 

a subsistence hearing to determine whether the project would have a significant possibility of a significant 

restriction on subsistence uses. This allows for site specific information to be used in the analysis such 

as what subsistence resources occur in the project area and may be affected, what levels of use occur in 

the project area by subsistence and non-subsistence users, and for subsistence users of the project area 

to tell managers what impacts the project may have on them. Subsistence uses would be given 

preference over non-subsistence uses if any restrictions are determined necessary. The Forest Plan 

determined an overall possible risk while project-level subsistence evaluations better identify specific 

impacts to abundance and distribution, access to resources, and competition with non-rural users.

COMMENT

SUB-3: The Forest Service should conduct a more thorough ANILCA Section 810 Analysis.

RESPONSE

Each project that requires an EIS must hold a subsistence hearing (ANILCA 810(b)) to determine whether 

the project would have a significant possibility of a significant restriction on subsistence uses. Individual 

projects are not proposed at the programmatic level; the Forest Plan subsistence analysis acknowledges 

that cumulatively across the Forest there could be areas where subsistence uses may be impacted 

(makes a finding that a significant possibility of a significant restriction on subsistence uses, particularly 

for deer, may occur when the Forest Plan is fully implemented). Subsistence hearings were held across 

the Forest during the comment period. Site specific information such as what subsistence resources 

occur in the project area and may be affected, what levels of use occur in the project area by subsistence 

and non-subsistence users, and for subsistence users of the project area to tell managers what impacts 

the project may have on them would be incorporated in to ANILCA 810 analysis at the project level.

COMMENT

SUB-4: The Forest Service should include greater protections for subsistence uses and hunting in 

the Plan, especially in areas already highly impacted by past practices.

Changes to subsistence standards and guidelines (Chapters 3 and 4 of the Plan) are outside the scope of 

this focused plan amendment. 

DEIS Comments and Responses I-100 Final EIS
Appendix I

Karst (KARS)

COMMENT

KARS-1: The DEIS does not adequately disclose the effects of changes to the degree and 

methods of logging permitted in karst lands. Some suggest that forest management activities 

should not take place in and around sensitive karst landscapes.

RESPONSE

The DEIS does not allow for any less restrictive methods of timber management on karst lands than from 

those in the 2008 Forest Plan. The 2008 Forest Plan, Appendix H, V. Young-Growth Management on 

Karst, Page H-8 states that; “Commercial thinning is appropriate on low to moderate vulnerability karst 

lands when the karst management objectives can be met. Generally, no thinning shall be permitted on 

lands determined to be of high vulnerability such as within 100 feet of a cave entrance, a karst feature 

accepting surface flow, or of the edge of a sinking or losing stream within 0.25 mile upstream of their 

swallow hole or loss point. On a case-by-case basis, other karst features will be assessed as to their 

susceptibility to surface disturbing activities, the proposed harvest method, and the thinning prescription. 

The area surrounding these features is still considered high vulnerability and should be mapped as such; 

however, thinning of this sensitive area might be considered permissible. All features not fully protected 

would be buffered from their center to just outside the lip of the sink allowing for thinning within the area 

that would normally be a non-harvest buffer. It is probable that a zone equal to one tree height be left 

untreated to ensure that no material will be placed in these features. All thinned timber will be directionally 

felled from the untreated area surrounding the karst feature and split yarded from the area. Any material 

landing on the slope break of the feature or within the feature will be hand removed. No yarding across or 

through the untreated area surrounding the feature will be allowed. Directional falling and split yarding 

away from the karst depressions and features should provide adequate protection for water quality and 

karst features. It is believed that the benefit of hydrologic recovery of the areas adjacent to these features 

outweighs the risk of harvest. Again this should be assessed on a case-by-case basis.” 

The same process for assessing the vulnerability of karst lands and determining appropriate timber 

management methods exist in the DEIS. Even-aged management on low vulnerability karst and limited 

clear-cutting in medium vulnerability karst has always been allowed, although more restrictive guidelines 

than normally employed on non-karst lands may be needed on medium vulnerability karst. Alternatives 1 

through 4 would be managed in similar fashion so long as karst management objectives could be met. 

Under Alternative 5, created openings are limited to 10 acres with a maximum removal of 35 percent of 

the original stand. Project-specific karst evaluations would still be required and effects would be avoided 

or minimized through project and site specific management prescriptions, such as requiring partial 

suspension yarding or limiting the size of openings moderate changes to precipitation throughfall.

The Tongass is not opening up all high vulnerability karst areas to timber management. There would be 

no additional harvest in any areas mapped as high vulnerability karst under Alternatives 1 and 5. 

Alternatives 2, 3, and 4 each allow for commercial thinning on high vulnerability karst on a case-by-case 

basis when the karst management objectives can be met (Draft DEIS, p. 3-33, paragraph 1). Alternatives 

2, 3, and 4 each allow for commercial thinning on high vulnerability karst lands but does not guarantee it. 

Based on our experience, we believe that carefully planned and implemented commercial thinning of 

young growth stands on high vulnerability karts can be neutral or even beneficial to the karsts, where 

appropriate.

We believe the activities discussed above could be implemented with careful planning. We also recognize 

the shortage of monitoring on the effects to karst from second growth management and acknowledge 

there is some uncertainty. However, at the project-scale, karst resources will continue to be evaluated 

and effects from harvests on medium and high vulnerability karst lands will be addressed through projectspecific prescriptions. 

Low vulnerability karst lands are not sensitive to management activities due to the depth of overlying 

material (e.g. glacial till) and low hydrologic conductivity. There would be no change to management 

practices on these lands between any alternatives. 

Final EIS I-101 DEIS Comments and Responses
Appendix I

Text has been added to the Karst section of Chapter 3.

COMMENT

KARS-2: The Forest Plan should clarify how young-growth stands in Geologic Special Interest 

Areas can be managed (See Timber Resource Planning TIM4) and the Kruzof Geological special 

interest area should be designated as a National Monument with no harvest.

RESPONSE

Many of the Geologic Special Interest Areas created for their intensity of karst development contain areas 

of past harvest. We recognize the sensitivity of these areas to disturbance, timber management, and 

road construction. However, we believe that careful commercial thinning of some of the young-growth 

stands in these areas should be considered when karst and cave resource values are not compromised. 

Preliminary data (Prussian, 2011) does support the concept that commercial thinning of the older younggrowth stands on karst, returning the stand to closer-to-pre-harvest tree spacing, hastens the hydrologic 

recovery of the site. Reducing the canopy cover could restore the ‘health’ of young growth forests on 

karst lands by increasing the volume of throughfall, flushing sedimentation out of diffuse and discrete 

karst openings, and reconnecting surface to subsurface flow pathways. The management of older younggrowth stands can also hasten the return to more natural stand characteristics and conditions.

Thinning of heavily stocked young-growth stands can increase tree growth, improve stand stability and 

health of the trees, and increase the amount of light and rainfall that reaches the understory. These may 

benefit areas of karst that were previously harvested. Some treatments may be prescribed on karst areas 

where it is determined, through site specific analysis, that it could benefit the resource and not 

compromise or damage the karst resource.

Designation of the National Monuments are outside of the scope of this amendment and the authority of 

the Responsible Official.

COMMENT

KARS-3: The Forest Plan should address active management of young growth stands in Karst 

formations and how harvest should be accomplished to minimize any negative impacts while 

generating volume.

RESPONSE

The young-growth plan components in Chapter 5 ensure that karst ecosystems “maintain natural 

processes and productivity, while providing for other land uses.” (See desired condition DC-YG-KC-01 in 

Chapter 5.) Alternatives 2, 3 and 4 include young-growth standard S-YG-KC-01 that allows commercial 

thinning on high vulnerability karst on a case-by-case basis (DEIS, Appendix F). The management 

approach for karst and cave resources in Chapter 5 also provides direction to evaluate karst vulnerability.

COMMENT

KARS-4: Alternative 3 should prohibit commercial timber harvest on High Vulnerability Karst.

RESPONSE

The range of alternatives analyzed in detail included support these and other goals to varying degrees. 

Table 2-17 in Chapter 2 shows that Alternatives 1 and 5 (preferred alternative) do not allow commercial 

timber harvest on high vulnerability karst while Alternatives 2, 3, and 4 allow commercial thinning. 

See response to KARS-1.

COMMENT

KARST-5: High-vulnerability karstlands should be fully protected from timber harvest. The 

prescriptions available for medium-vulnerability karstlands should be limited.

DEIS Comments and Responses I-102 Final EIS
Appendix I

RESPONSE

Among the five alternatives, some allow no entry into high-vulnerability karst and some allow commercial 

thinning only. No specific additional restrictions are added for moderate vulnerability karst; however, 

many of the existing Forest-wide standards and guidelines are specific to moderate vulnerability 

karstlands.

Final EIS I-103 DEIS Comments and Responses
Appendix I

Road Density (RD)

COMMENT

The Forest Service needs to actively reduce road densities, stop wolf harvest, and end old-growth 

clearcutting to save wolves.

RESPONSE

Wolf harvest bag limits are not within the scope of the Forest Plan amendment. The Federal Subsistence 

Board works with the State of Alaska Board of Game to set seasons and bag limits for subsistence and 

sport harvest.

Specific harvest prescriptions, such as even-aged management, are determined at the project level, not 

the programmatic Forest Plan level, after a review of each stand’s goals, needs, and resource concerns. 

See also TIM-13.

Young growth harvest within the Old-Growth Habitat LUD could require roads to be constructed but that 

would depend on site-specific conditions such as existing access and the harvest prescription for the 

stand. When young-growth harvest is proposed within an Old-Growth Habitat LUD, an interagency 

biologist team would review the location and design of the reserve and could recommend a modification 

to the LUD boundaries to exclude the young-growth stand to be harvested if adjacent old-growth could be 

added and if it would better meet the criteria in Forest Plan Appendix K. 

Road density is evaluated as part of project planning; site specific resource concerns are identified and 

evaluated during that process. Access Travel Management plans and road maintenance objectives are 

generally reviewed during each project as well. Often, road closures for existing roads are prioritized 

based on funding, resource concerns, and access needs for resource management activities; closed 

roads (ML1) may or may not be physically barricaded but are not open for public use.

COMMENT

RD-2: Forest Service has not Fulfilled Road Density Goals in the 2008 Plan for wolf populations 

and does not identify where several WAAs exceed 0.7 mile per square mile.

RESPONSE

Table 3.10-4 in the DEIS displays road density for all roads and for open roads, both on NFS lands only 

and for all land ownerships. Average road density across all Wildlife Analysis Areas (WAAs) is provided in

the FEIS. WILD1.XIV.A.1(c) includes a total road density of 0.7 to 1.0 miles per square mile in areas 

where wolf mortality concerns have been identified and road access was determined to be a significant 

contributing factor; not all WAAs are required to have road densities less than 0.7 miles per square mile. 

Resource concerns, such as road density, are evaluated at the project level; decisions under the 

amended Forest Plan are required to say how they meet the plan components which include standards 

and desired conditions. See also RD-1.

An interagency Wolf Technical Committee has been established and is currently working on wolf 

management concerns on Prince of Wales Island. Findings and recommendations of that committee are 

not yet available.

COMMENT

RD-3: The Plan Amendment should bring greater clarity to the road density issue by defining the 

various terms for Tongass road closures. The Plan Amendment does not presently define “open 

road,” “closed road,” and “decommissioned road.” (See Plan Amendment Glossary for lack of 

definitions for these terms; although “open road mileage” is defined, “open road” is not).

DEIS Comments and Responses I-104 Final EIS
Appendix I

RESPONSE

Maintenance Level 1 (ML1) roads are considered closed (Transportation section DEIS page 3-273); open 

roads are roads in ML 2-5. Closed roads may or may not be physically blocked but use is illegal on roads 

designated as ML 1 status; these roads do not show up on the Motor Vehicle Use Maps available to the 

public. The Table 3.10-4 in the DEIS displays road density for all roads and for open roads, both on NFS 

lands only and for all land ownerships. In the FEIS, this table has been expanded to include a break 

down by Wildlife Analysis Area (WAA). Pages 3-224 to 225 in the DEIS include information on wolf 

harvest and the role of road access in that harvest, and acknowledges possible consequences of such 

harvest vulnerability. The Forest Plan Glossary has been updated to clarify that roads in ML 2-5 are 

considered when calculating open road density. 

COMMENT

RD-4: The Forest Service should add a standard and guideline in its Transportation System 

Corridors direction to maintain Tongass WAAs at a threshold of 0.7 mi/mi2. WAAs that presently 

exceed the 0.7 mi/mi2 threshold should have no net gain in roads (new road additions should be 

countered by road closures/decommissioning). WAAs that exceed 1.0 mi/mi2 should receive 

priority efforts to reduce road densities.

RESPONSE

Standards and Guidelines are included under the primary resource that is driving that particular standard. 

In this case, the suggested standard and guideline are primarily a wildlife concern not a transportation 

concern. WILD1.XIV.A.1(c) on page 4-88 includes a similar road density (total road density of 0.7 to 1.0 

miles per square mile) in areas where wolf mortality concerns have been identified and road access was 

determined to be a significant contributing factor. An interagency Wolf Technical Committee has been 

established and is currently working on issues related to wolf management concerns on Prince of Wales 

Island.

Access Travel Management plans are completed at the island, district, or project levels to allow for more 

localized analysis of road densities in relation to resource concerns and which roads are needed to 

access areas for resource management (or those that are not needed which can be closed). In addition, 

road closures are prioritized based on financial constraints in addition to resource concerns.

COMMENT

RD-5: We are concerned that the cumulative effects on transportation arising from the interlinkage of logging road systems, is not disclosed or considered in the EIS. Important choices are 

being made without benefit of good information.

RESPONSE

The DEIS/FEIS adequately discloses the effects of roads. In the affected environment sections the 

cumulative effects of all existing roads, including open, closed, and decommissioned roads, are 

addressed. In the effects sections, the assessments include the estimated future roads on NFS lands 

and on non-NFS lands over a 100-year period.

COMMENT

RD-6: The extent of sediment delivery from roads that results from construction, reconstruction, 

and storage of logging roads is not well addressed. Increased use of roads also has the effect of 

increasing sediment delivery to streams. Many studies show increased logging traffic elevates 

sediment delivery to streams. 

The DEIS seems to suggest the agency is using the road storage strategy as a back-door way to 

avoid complying with the Clean Water Act, rather than as a considered transportation strategy. 

Where a road truly is justified, the best public interest seems to be met by just building and 

properly maintaining that road. The second-growth transition provides an opportunity to focus 

Final EIS I-105 DEIS Comments and Responses
Appendix I

logging in fewer areas, which means fewer roads should be need to access them, and so a 

straight-forward road management strategy becomes increasingly more affordable and desirable. 

RESPONSE

The DEIS recognizes that roads are a major source of resource effects. The Water and Fish sections 

provide extensive analysis and quantification of road effects on streams and fish, including sediment 

effects. The analysis addresses existing roads, stored roads, decommissioned roads, reconstructed 

roads, and new roads.

Road storage is a management tool to reduce long-term costs, by minimizing road maintenance costs, 

and reducing effects on streams and fish. If a road is important for recreation or other purposes, it is 

managed differently. Storage, which results in road closure, also helps address potential effects on 

wolves, by reducing access. Most roads accessing young-growth stands will not be needed, after 

harvest, for many decades.

DEIS Comments and Responses I-106 Final EIS
Appendix I

Transportation and Utility System LUD Overlay (TUS)

COMMENT

TUS-1: The amended plan should reinstate the Transportation and Utility Systems LUD overlay 

and the “windows” and “avoidance” language because it discouraged road building in Wilderness 

LUDs and some non-development LUDs, and required transportation projects to first consider 

feasible alternatives. The Forest Service should either reinstate the overlay, or add new direction 

for completing a transportation avoidance analysis in the same LUDs where the overlay applied in 

the 2008 Forest Plan.

RESPONSE

The intent of the Forest Plan direction for transportation systems corridors is not to change the process 

the Forest Service will go through when developing future transportation systems. The purpose of the 

plan direction for transportation systems corridors is the same as the 2008 TUS LUD management 

prescription; to facilitate the availability of National Forest System land for the development of existing 

and future transportation systems such as those identified by the State of Alaska in the current version of 

the Southeast Alaska Transportation Plan (SATP) and applicable laws. (See Forest Plan Chapter 5.) The 

applicable Transportation Systems Corridors direction in Chapter 5 is included for each LUD in Chapter 3 

in a table that cross-references, by category, the plan content, found in Chapter 5. 

When developing future transportation systems, the project must be designed to be consistent with the 

applicable plan direction. For example, Forest-wide desired condition DC-02: 

Transportation systems support community resilience, resource management, and provide 

for current and future land management needs, subject to applicable laws. Transportation 

systems avoid, minimize, or mitigate adverse effects to natural and cultural resources.

The decision document (Decision Memo, Decision Notice, Record of Decision) for a transportation activity 

or project must describe how the project or activity is consistent with DC-02 and other applicable plan 

direction, and this process is described in the Project Consistency Requirements section in Chapter 6 of 

the Forest Plan. 

The Forest Service will continue projects and activities under the direction in Chapters 2, 3 and 4. The 

Chapter 5 plan direction for Transportation Systems Corridors will take precedence only in the event of 

conflicting direction. (See Priority of Direction section in Chapter 1 in Forest Plan.) If there is no direction 

in Chapter 5 on a specific forest resource, then Chapter 3 direction takes precedence for that resource. 

The following language was added to the Forest Plan in Chapter 1, Priority of Direction:

Chapter 5 assumes all laws, regulations, and policy pertaining to management of National Forest 

resources will be followed. Ground-disturbing projects will use the approved best management 

practices (BMPs) (National Core BMP Technical Guide FS-990a and Alaska Region Soil and 

Water Conservation Handbook, FSH 2509.22) to avoid, minimize, or mitigate environmental 

impacts.

COMMENT

TUS-2: Removal of Transportation and Utility System LUD should not be done under an 

amendment. A change of this nature should be done through the Forest Plan revision process 

described in 36 CFR 219.7 rather than the amendment process set forth in 36 CFR 219.13.

RESPONSE 

The Notice of Intent (NOI) that was published on May 27, 2014 in the Federal Register (79 FR 30074) 

stated under the “Purpose and Need for Action” that [the Forest Service] will also evaluate other changes 

suggested in the 5-year review. Concerns were consistently expressed during the Five-Year Review of 

the 2008 Forest Plan regarding the impact of high fossil fuel prices; the adverse effect of high energy 

costs on economic diversification and sustainable economic development; and increasing climate change 

Final EIS I-107 DEIS Comments and Responses
Appendix I

on the quality of life in Southeast Alaska. Concerns were also expressed that the 2008 Plan’s direction 

regarding transportation and utility systems, including the Transportation and Utility System (TUS) overlay 

Land Use Designation (LUD), were overly complex, confusing, and difficult to implement, creating an 

impediment to development of hydropower, other types of renewable energy, and transmission lines 

needed to connect communities to sources of electric power. Based on this review, the responsible 

official determined to propose changes to the Forest Plan to make the development of renewable energy 

resources more permissible -- including allowing greater project-level consideration of transportation and 

utility corridors and removing the TUS overlay LUD -- to facilitate renewable energy development in 

Southeast Alaska communities, provide low-carbon energy alternatives, and reduce the use of fossil 

fuels.

Removing the existing Transportation and Utility System LUD through a plan amendment is permissible. 

The last sentence of 36 CFR 219.13(a) states that: “Except as provided by paragraph (c) of this section 

[regarding administrative changes], a plan amendment is required to add, modify, or remove one or more 

plan components, or to change how or where one or more plan components apply to all or part of the plan 

area (including management areas or geographic areas).” (Emphasis added.) The Department added the 

phrase “including management areas or geographic areas” to the final planning rule to clarify that an 

amendment is required for any change in how or whether plan components apply to those areas (77 FR 

21238). An amendment may remove all the plan components within a LUD and remove the LUD itself. 

See responses to P&N-2 and PLR-1.

COMMENT

TUS-3: The Forest Service should clarify that the transportation systems corridors direction in 

Chapter 5 of the Forest Plan applies to major roads only and not to all roads, such as those 

defined in Chapter 7 (Glossary) under the term “Forest transportation system. This clarification is 

needed because removal of the Transportation and Utility Systems LUD leaves a gap in that major 

public roads would otherwise receive special consideration under the 2008 Forest Plan. The 

Forest Service should clarify in both the FEIS and the Forest Plan that any new transportation 

direction applies only to major roads.

RESPONSE

The management prescription goal in the 2008 Transportation and Utility Systems LUD, and the purpose 

of the plan direction for transportation systems corridors in Chapter 5 is to facilitate the availability of 

National Forest System land for the development of major roads; existing and future transportation 

systems such as those identified by the State of Alaska in the current version of the Southeast Alaska 

Transportation Plan (SATP) and applicable laws. (See page 5-13 of the Proposed Forest Plan Chapter 5 

for this description.) The transportation systems corridors direction in Chapter 5, including Forest-wide 

plan components DC-02, DC-03 and DC-04, was written with this purpose in mind. 

The transportation systems corridor direction is not intended to address the forest transportation system, 

which is defined in the glossary in Chapter 7 as “[t]he system of National Forest System (NFS) roads, 

trails, and airfields on NFS lands (36 CFR 212.1).” The Transportation section in Chapter 3 of the FEIS 

describes both major roads and forest transportation systems. (See subsections for Regional 

Transportation System and National Forest System Roads.) Forest-wide transportation standards and 

guidelines were included in the Proposed Forest Plan on pages 4-74 through 4-80. The Proposed Forest 

Plan also included standards and guidelines that describe Transportation Planning in TRAN 3, and the 

maintenance levels in TRAN 6 & TRAN 7. The first part of the following standard and guideline TRAN4 I. 

D. was removed in the Proposed Forest Plan:

D. Cooperate with the Alaska Department of Transportation and Public Facilities and the Federal 

Highway Administration in the administration of the Forest Highway Program. Provide 

nominations of routes to be upgraded and encourage their transfer to state jurisdiction, in order to 

provide safe facilities and adequate maintenance between communities linked by the Forest 

Transportation System. (Consult FSM 7700.) (emphasis added)

DEIS Comments and Responses I-108 Final EIS
Appendix I

This standard and guideline has been added back into the Forest Plan and was clarified. It now reads as 

follows:

D. Cooperate with the Alaska Department of Transportation and Public Facilities and the Federal 

Highway Administration in the administration of the Federal Highway Programs. Provide 

nominations of routes to be upgraded and encourage their transfer to state jurisdiction, in order 

to provide safe facilities and adequate maintenance between communities linked by the Forest 

Transportation System. (Consult FSM 7700.) (emphasis added)

A discussion about the Southeast Alaska Transportation Plan (SATP) was included in Chapter 3 of the 

DEIS in the Transportation section on pages 3-271 to 3-273. The 2004 SATP was incorporated into the 

2008 Forest Plan and direction was provided for it in the Transportation and Utility LUD. A draft SAPT 

was published in June 2014 (ADOT&PF 2014), and the DEIS provided a description of the intent of the 

road construction to provide access to NFS lands. Because the Proposed Forest Plan removed the 

Transportation and Utility Systems LUD, the SATP was incorporated into the Proposed Forest Plan and 

direction for it was provided in the transportation systems corridors direction in Chapter 5. 

The Transportation environmental consequences section in Chapter 3 of the DEIS disclosed the following 

on p. 3-277: 

“Proposed new plan components for Transportation Systems Corridors (TSC) would replace the 

direction currently found in the Transportation and Utility System LUD. TSC plan components 

apply only to major road systems such as state and federal highways, railroads, and those 

identified by the State of Alaska in the current version of the SATP and applicable laws (for 

example, Section 4407 of Public Law 109-59, Title XI of the Alaska National Interest Lands 

Conservation Act, Public Law 96-487)... When planning future transportation projects, these plan 

components would apply. Prior to this, all other applicable Forest Plan LUD direction would remain 

in effect.” (emphasis added)

COMMENT

TUS-4: The Proposed Forest Plan does not clearly indicate how the transportation systems 

corridors direction for major roads in Chapter 5 is to be applied with other LUD restrictions 

governing roads. Removal of the “avoidance area” and “window” designations in the Proposed 

Forest Plan makes it easier to build projects, eliminating a protective barrier to siting major roads 

on the majority of the Tongass. The DEIS does not disclose this change, or analyze its significant 

environmental effects or compliance with NFMA. Therefore, the Forest Service should make it 

explicit that major roads are subject to Chapter 3 road restrictions for individual LUDs in the 

Proposed Forest Plan.

RESPONSE

In the introduction to Chapter 5 of the Proposed Forest Plan, an explanation was provided stating that “[a] 

plan amendment is required to add, modify, or remove existing plan direction, or to change how or where 

one or more plan components apply to all or part of the plan area (including Land Use Designations) (36 

CFR 219.13(a)).” On page 5-3 of the Proposed Forest Plan under the section entitled “Changes Made in 

the 2008 Forest Plan” the Forest Service disclosed the following:

The Transportation and Utility System overlay LUD was removed, as well as all associated 

direction (i.e., “window” and “avoidance area”) in the LUD Standards and Guidelines 

pertaining to application of this overlay LUD. No other LUDs were removed. Other LUD 

boundaries were modified to reflect changes since 2008.

Removal of the TUS overlay LUD was also disclosed in Chapter 2 of the DEIS on p. 2-10 under the 

section entitled, “Proposed LUD Changes Common to the Action Alternatives.” 

The management prescription in the 2008 Transportation and Utility Systems LUD, and the purpose of 

the plan direction for transportation systems corridors in Chapter 5 is to facilitate the availability of 

Final EIS I-109 DEIS Comments and Responses
Appendix I

National Forest System land for the development of major roads; existing and future transportation 

systems such as those identified by the State of Alaska in the current version of the Southeast Alaska 

Transportation Plan (SATP) and applicable laws. (See page 5-13 of the Proposed Forest Plan Chapter 5 

for this description.) The transportation systems corridors direction in Chapter 5, including Forest-wide 

plan components DC-02, DC-03 and DC-04, was written with this purpose in mind. 

The Introduction to Chapter 3 of the Proposed Forest Plan explained how the plan direction for 

transportation systems corridors in Chapter 5, is applied to the LUDs by the table that cross-references 

the applicable direction that applies to the LUD. 

When developing future transportation systems corridors, the project must be designed to be consistent 

with the applicable plan direction. For example, development of a major road must be consistent with 

forest-wide desired condition DC-02: 

Transportation systems support community resilience, resource management, and provide for 

current and future land management needs, subject to applicable laws. Transportation systems 

avoid, minimize, or mitigate adverse effects to natural and cultural resources.

The Forest Service will continue projects and activities under the direction in Chapters 2, 3 and 4. The 

Chapter 5 plan direction for transportation systems corridors will take precedence only in the event of 

conflicting direction. (See Priority of Direction section in Chapter 1 in Forest Plan.) If there is no direction 

in Chapter 5 on a specific forest resource, then Chapter 3 direction takes precedence for that resource. 

See responses to PLR-1 and TUS-1 regarding NFMA compliance. 

COMMENT

TUS-5: The Forest Service must make the Chapter 5 plan direction for transportation systems 

corridors clearer, since the direction in Chapter 5 will have priority over all other plan direction in 

Chapters 3 and 4 if a conflict or discrepancy in directions occur. The Forest Service must 

thoroughly explain what will constitute a conflict in this context, describe the extent of potential 

conflicts, and provide examples of the circumstances under which Chapter 5 direction would or 

would not have priority over direction in Chapters 3 and 4. The Old Growth Habitat LUD direction 

in Chapter 3 precludes roads unless there is no feasible alternative, but Chapter 5 transportation 

systems corridors direction applies to the Old Growth Habitat LUD, which allows the Forest 

Service to build a major road for which there may be a feasible alternative. The Forest Service has 

failed to disclose its obligations under NEPA and NFMA with respect to the transportation 

changes.

RESPONSE

The Forest Service Handbook ([FSH] 1909.12, chapter 20, section 22.2) indicates that if a plan has 

direction that overlaps, the plan must clearly explain which direction has priority. The explanation 

regarding priority is located in Chapter 1 of the Forest Plan, in the Priority of Plan Direction section, as 

well as in the introduction section in Chapter 5.

Until the Forest Service implements this new direction on a site-specific transportation project, providing 

examples of conflicts of direction, or describing the extent of potential conflicts is not warranted at a 

programmatic level. When developing future transportation systems, the project must be designed to be 

consistent with the applicable plan direction in Chapter 5. For example, wildlife standard S-TCS-WILD-01, 

and forest-wide desired condition DC-02. 

S-TSC-WILD-01: Design and construct transportation systems to maintain wildlife habitat 

corridors between old-growth reserves (OGRs), riparian management areas (RMAs), and 

beach and estuary fringe.

DC-02: Transportation systems support community resilience, resource management, and 

provide for current and future land management needs, subject to applicable laws. 

DEIS Comments and Responses I-110 Final EIS
Appendix I

Transportation systems avoid, minimize, or mitigate adverse effects to natural and cultural 

resources.

The decision document (Decision Memo, Decision Notice, Record of Decision) for the project or activity 

must describe how the project or activity is consistent with S-TSC-WILD-01, DC-02, and other applicable 

plan direction, and this process is described in the Project Consistency Requirements section in Chapter 

6 of the Forest Plan. 

On p. 3-277 of the DEIS in the Transportation environmental consequences section, the Forest Service 

disclosed that under the action alternatives:

“With this amendment, the existing transportation and utility LUD and avoidance areas 

would be removed from the Forest Plan. TSC plan components, e.g., standards and 

guidelines to the Forest Plan, would take precedence over other forest-wide and LUDspecific standards and guidelines (subject to applicable laws) where TSC are proposed 

or exist.”

See response to PLR-1 and TUS-2 regarding NFMA compliance. 

COMMENT

TUS-6: Removal of the Transportation and Utility System LUD in the action alternatives violates 

the 2012 Planning Rule and requirements of the National Environmental Policy Act (NEPA) 

because specific geographic management areas were removed from the Forest Plan. Removal of 

the LUD does not fulfill the stated purpose of the proposed plan amendments, and removal was 

not disclosed as a secondary purpose for the plan amendment. These geographic corridors 

connecting the communities located within the boundaries of the Tongass National Forest are 

intended to be developed and operated as transportation and utility systems in accordance with 

the State of Alaska’s Southeast Alaska Transportation Plan (SATP). Neither the published notice 

of intent nor the DEIS purpose and need statement disclose the intent to eliminate the TUS LUD. 

The NEPA requires the significant federal action be disclosed and fully analyzed prior to 

implementation.

RESPONSE

See responses to P&N-2, TUS-2 and TUS-3. See response to PLR-1 and TUS-2 regarding NFMA 

compliance. 

COMMENT

TUS-7: The Forest Service’s conclusion in the DEIS, that there is considerable uncertainty about 

the future development of Southeast Alaska’s road system, is unsupported. This conclusion was 

used to create transportation systems corridor objective O-TSC-01 in Chapter 5 of the Proposed 

Forest Plan. Development and delivery of transportation projects in the established transportation 

and utility corridors is accomplished, in part, by the stability and predictability of the 

geographically designated Transportation and Utility System (TUS) LUD. This objective (O-TSC01) is extremely limited and contradictory to the many upcoming and reasonably foreseeable 

highway projects. With nearly 200 miles of state highway construction recently completed and 

planned for the near future - and congressionally granted easements underlying hundreds of 

miles of the TUS LUD - this objective does not reflect the planned development in the TUS LUD. 

RESPONSE

The Southeast Alaska Transportation Plan (SATP) states the following on page 2:

“Alaska may see a decrease in funding in the future. The federal highway trust fund is no 

longer sufficient to cover surface transportation needs and must be supplemented by the 

federal general fund, or restructured. State funding which pays for all operating and some 

capital expenses is expected to decrease as state revenues decline, primarily due to oil 

Final EIS I-111 DEIS Comments and Responses
Appendix I

production declines and price fluctuations. Consequently, the Department must plan for the 

possibility of reduced financial resources. The SATP recommendations need to account for 

this year to year uncertainty and plan for periods of reduced funding.” (ADOT&PF 2014)

The recent work completed on the roads that were improved through Western Federal Lands funding 

were relocation and reconstruction of existing roads on Prince of Wales Island. Easements have been 

given for some sections of the roads on Prince of Wales Island as well as on some roads on other islands 

to the State of Alaska. These road sections are included in the roads illustrated on Map 21 Prince of 

Wales Corridors from the Southeast Alaska Transportation Plan, an approved component of the Alaska 

Statewide Transportation Plan, August 14, 2004. Many of the sections of road illustrated on this map 

have not been constructed and some sections will not be constructed but were alternative roads. Several 

maps are included in the Southeast Transportation Plan show roads that will be difficult to construct and 

expensive to construct considering the terrain, landslides, cultural resources, aquatic resources, stream 

crossings as well as ferry transportation required to connect some waterways. 

Updates to the potential routes and forecasted costs are included in the Southeast Alaska Transportation 

Plan 2014 Draft. The Forest Plan present and reasonably foreseeable actions and projects (DEIS 

Appendix C) were developed to be consistent with the Southeast Transportation Plan that provides set of 

proposed road and utility corridors the State of Alaska is pursuing to meet future transportation and 

energy needs of Southeast Alaska. The Forest Plan objectives are written to be “...concise, measurable, 

and time-specific...based on reasonably foreseeable budgets.” (FSH 1909.12 Ch. 20, sec. 22.12). 

Objective O-TSC-01 was written to be achievable and realistic given the fiscal and time constraints as 

well as anticipated litigation. 

COMMENT

TUS-8: The Forest Plan direction for renewable energy and transportation systems corridors 

direction in Chapter 5 may prove workable for the Forest Service, but the Section 4407 easements 

and the SATP corridors in the existing TUS LUD must be recognized in the Forest Plan for the 

multiple-agency and multiple-year planning required to connect the communities of Southeast 

Alaska. It is unclear how removing the Transportation and Utility System (TUS) LUD will better 

facilitate the availability of NFS land for the development of existing and future transportation 

systems, since the State currently holds easements over the vast majority of the TUS LUD. 

Removal of the of the TUS LUD will likely have the effect of making NFS land less available, create 

future use conflicts, and deter development of existing and future transportation systems. The 

depiction of the corridors on the TUS LUD maps in the 2008 plan was informative and consistent 

with the management direction in the plan concerning the priority of TUS development in those 

corridors. The State, regulatory agencies, and the public require the disclosure and predictable 

management of the transportation and utility corridors in the TUS LUD.

RESPONSE

Chapter 3 of the DEIS Transportation section (pages 3-271 to 3-273) included a discussion about the 

Final Southeast Alaska Transportation Plan (SATP), and described the intent of the road construction to 

provide access to NFS lands. Pages 3-274 and 3-275 of the DEIS provided a discussion about the TUS 

LUD under the 2008 Forest Plan. On p. 3-277 of the DEIS in the Transportation environmental 

consequences section, the Forest Service disclosed that under the action alternatives:

“Under Alternatives 2, 3, 4, and 5, the existing TUS LUD would be removed from the Forest 

Plan. Proposed new plan components for Transportation Systems Corridors (TSC) would 

replace the direction currently found in the Transportation and Utility System LUD. TSC plan 

components apply only to major road systems such as state and federal highways, railroads, 

and those identified by the State of Alaska in the current version of the SATP and applicable 

laws (for example, Section 4407 of Public Law 109-59, Title XI of the Alaska National Interest 

Lands Conservation Act, Public Law 96-487).”

The Proposed Forest Plan LUD map for Alternative 1 included the TUS LUD, while the LUD map 

representing Alternatives 2-5 did not include the Section 4407 of Public Law 109-59 easements and the 

DEIS Comments and Responses I-112 Final EIS
Appendix I

SATP corridors. FEIS maps have been corrected to include the Section 4407 easements and the SATP 

corridors.

The management prescription goal in the 2008 Transportation and Utility Systems LUD, and the purpose 

of the plan direction for transportation systems corridors in Chapter 5 is to facilitate the availability of 

National Forest System land for the development of major roads; existing and future transportation 

systems such as those identified by the State of Alaska in the current version of the SATP and applicable 

laws. (See page 5-13 of the Proposed Forest Plan Chapter 5 for this description.) The transportation 

systems corridors direction in Chapter 5, including Forest-wide plan components DC-02, DC-03 and DC04, was written with this purpose in mind. 

COMMENT

TUS-9: There is no management advantage by replacing TUS LUD with transportation systems 

corridors direction in Chapter 5. Without the TUS LUD, the specific property and development 

rights granted by Congress are not recognized. The TUS LUD provides predictability and 

transparency, and minimizes potential conflicts with underlying LUD goals and associated 

management prescriptions should transportation development occur. The TUS LUD represents “a 

‘window’ through the underlying LUD through which roads and/or utilities can be built. To provide 

the predictability and transparency necessary for the continued development of the infrastructure 

connecting the communities of Southeast Alaska, the Forest Service should preserve the TUS 

LUD.

RESPONSE

The Proposed Forest Plan transportation systems corridors direction in Chapter 5 was developed to 

replace the TUS LUD direction. The TUS LUD direction in the 2008 Forest Plan took precedence over 

underlying LUDs regardless of whether the underlying LUD was a TUS “Avoidance LUD.” Similarly, the 

applicable transportation systems corridors direction in Chapter 5 takes precedence over other forestwide and LUD-specific standards and guidelines where transportation systems corridors exist or are 

proposed. The Introduction to Chapter 3 of the Proposed Forest Plan explained how the plan direction for 

transportation systems corridors in Chapter 5 is applied to the LUDs and is represented in the table that 

cross-references the applicable direction that applies to the LUD. 

The Proposed Forest Plan LUD map for Alternative 1 included the TUS LUD, while the LUD map 

representing Alternatives 2-5 did not include the Section 4407 of Public Law 109-59 easements and the 

SATP corridors. FEIS maps have been corrected to include the Section 4407 easements and the SATP 

corridors.

The management prescription goal in the 2008 Transportation and Utility Systems LUD, and the purpose 

of the plan direction for transportation systems corridors in Chapter 5 is to facilitate the availability of 

National Forest System land for the development of major roads; existing and future transportation 

systems such as those identified by the State of Alaska in the current version of the SATP and applicable 

laws. (See page 5-13 of the Proposed Forest Plan Chapter 5 for this description.) The transportation 

systems corridors direction in Chapter 5, including Forest-wide plan components DC-02, DC-03 and DC04, was written with this purpose in mind. 

See response to TUS-8. Regarding the removal of the Transportation and Utility Systems LUD and 

adding new direction, see responses to P&N-2, PLR-1, and TUS-2.

COMMENT

TUS-10. The practice of road decommissioning is expensive, wasteful, unnecessary, and reduces 

ancillary community benefits. Roads support tourism by providing access for a wide variety of 

activities, including hunting, fishing, hiking, birding, wildlife viewing, photography, recreational 

vehicle use, boating/kayaking, and more.

Final EIS I-113 DEIS Comments and Responses
Appendix I

RESPONSE

Future transportation needs are considered using the travel analysis process. See Forest Service Travel 

Planning Handbook FSM 7709.55. Some travel management issues (such as response to visitor demand, 

open road density, and other wildlife issues) should be considered at a broad scale, while other issues 

(such as potential conflicts among uses on a particular trail and mitigation measures for a particular 

stream crossing) are best evaluated at a reduced scale. Travel analysis is often the point where broadscale issues can be identified. Site-specific issues are addressed at the project level.

DEIS Comments and Responses I-114 Final EIS
Appendix I

Renewable Energy (REN)

COMMENT

REN-1: The Forest Service is commended for emphasizing renewable energy in the Proposed 

Forest Plan, but encouraging renewable energy at the expense of essential environmental 

protections takes this policy too far. The Forest Service has not explained why it is necessary to 

locate renewable energy sites in what are currently “avoidance” areas, particularly in highly 

sensitive areas like beach and estuary fringe. The Proposed Forest Plan removes the “avoidance” 

area language that constrained hydroelectric projects in certain areas of the Forest unless an 

alternative location was not feasible. The renewable energy direction in Chapter 5 of the Proposed 

Forest Plan now has priority over other plan direction and overrides legally required 

environmental protection measures. The Proposed Forest Plan is inconsistent in describing the 

priority of direction that will apply, saying both that “[c]onsistent with the 2008 Forest Plan, 

renewable energy projects need to be consistent with the standards and guidelines for the 

respective LUDs affected by energy development” and that “should there be a conflict in 

direction, the proposed plan components in Chapter 5 would take priority over forest-wide and 

LUD-specific standards and guidelines (subject to applicable laws).” Neither the DEIS nor 

Proposed Forest Plan justifies the priority of direction with respect to renewable energy.

RESPONSE

Protection of forest resources is a priority when considering renewable energy development on National 

Forest System (NFS) lands. The Notice of Intent (NOI) that was published on May 27, 2014 in the Federal 

Register (79 FR 30074) stated under the “Purpose and Need for Action” that [the Forest Service] will also 

evaluate other changes suggested in the 5-year review.” Concerns were consistently expressed during 

the Five-Year Review of the 2008 Forest Plan regarding the impact of high fossil fuel prices; the adverse 

effect of high energy costs on economic diversification and sustainable economic development; and 

increasing climate change on the quality of life in Southeast Alaska. Concerns were also expressed that 

the 2008 Plan’s direction regarding transportation and utility systems, including the Transportation and 

Utility System (TUS) overlay Land Use Designation (LUD), were overly complex, confusing, and difficult to 

implement, creating an impediment to development of hydropower, other types of renewable energy, and 

transmission lines needed to connect communities to sources of electric power. Based on this review, 

the responsible official determined to propose changes to the Forest Plan to make the development of 

renewable energy resources more permissible -- including allowing greater project-level consideration of 

transportation and utility corridors and removing the TUS overlay LUD -- to stimulate renewable energy 

development in Southeast Alaska communities, provide low-carbon energy alternatives, and reduce the 

use of fossil fuels. The “window” and “avoidance” direction in the LUD management prescriptions was 

also removed because it was associated with application of the TUS LUD which was removed in the 

Proposed Forest Plan. 

Chapter 5 of the Forest Plan includes renewable energy direction that was developed to replace the 

renewable energy direction in the TUS LUD. Like the TUS LUD direction in the 2008 Forest Plan, the 

renewable energy direction in Chapter 5 gets applied to a specific geographic location on the Forest 

(LUD). For example, guideline G-RE-FAC-01 and G-RE-FAC-02 in Chapter 5 of the Forest Plan include 

the following direction:

G-RE-FAC-01: Utility lines should follow existing or planned transportation systems corridors, including 

those identified in the Logging Systems and Transportation Analysis (LSTA) and Public Law 109-59.

G-RE-FAC-02: An alternative route can be considered if it reduces or minimizes resource impacts.

Each LUD in Chapter 3 of the Forest Plan provides a table indicating the renewable energy plan 

components that apply. 

Not all NFS lands may be suitable for renewable energy. Chapter 5 includes the following suitability of 

lands plan component to identify the suitability of renewable energy in a particular area at the project level 

with site-specific analysis:

Final EIS I-115 DEIS Comments and Responses
Appendix I

SUIT-RE-01: All NFS lands may be suitable for renewable energy sites on a case-by-case basis in 

consideration of the LUD, ecological and social values, and benefit to Southeast Alaska communities. 

The interdisciplinary team (IDT) assigned to a renewable energy project will determine if the proposed 

renewable energy development is suitable based on the factors in SUIT-RE-01. The management 

approach for renewable energy further clarifies the intent of SUIT-RE-01 that “Identifying renewable 

energy sites as suitable is not a commitment but only an indication that the use might be appropriate.”

Identifying suitability will help determine if future renewable energy projects and activities are consistent 

with the following desired conditions:

DC-RE-01: Renewable energy resources (subject to applicable law) contribute to the economic well-being 

of Southeast Alaska communities.

DC-RE-02: Renewable energy resources are developed in a manner that would maintain and protect 

National Forest System (NFS) lands and resources. 

Protection of resources remains a priority and consistency with the Forest Plan and monitoring of results 

will continue. The Forest Service developed the set of plan components including the suitability of lands 

to integrate social, economic, cultural, and ecological considerations. When developing future renewable 

energy projects, the project or activity must be designed to be consistent with the applicable plan direction 

in Chapter 5. (Consult Chapter 6 of the Forest Plan regarding Project Consistency Requirements.)

The Proposed Forest Plan is not changing the process the Agency will go through when a proponent 

desires to develop a renewable energy project. The Forest Service will continue land administration 

activities under the direction in Chapters 2, 3 and 4. The Chapter 5 plan components take precedence 

only in the event of conflicting direction. The Forest Service Handbook (FSH) 1909.12, Chapter 20, 

Section 22.2 guides that if a plan has direction that overlaps, the plan must clearly explain which direction 

has priority. The Forest Service explained in the Proposed Forest Plan which direction has priority. (See 

Priority of Direction section in Chapter 1 on p. 1-4, Introduction section in Chapter 5 on p. 5-1, and in the 

introduction to Renewable Energy Direction section on p. 5-12.)

A Management Approach was added to the Forest Plan in Chapter 5 that reads as follows: 

“The addition of the renewable energy plan components do not change the need to ensure that resource 

protection measures are incorporated throughout project-level planning, construction, and operation of 

renewable energy sites.” 

The following sentence was added to Forest Plan, Chapter 1, Priority of Direction:

“Chapter 5 assumes all laws, regulations, and policy pertaining to management of National Forest 

resources will be followed. Ground-disturbing projects will use the approved best management practices 

(BMPs) (National Core BMP Technical Guide FS-990a and Alaska Region Soil and Water Conservation 

Handbook, FSH 2509.22) to avoid, minimize, or mitigate environmental impacts.”

COMMENT

REN-2: The Forest Service is right to encourage most kinds of renewable energy, but the 

definition of “renewable energy” in the Proposed Forest Plan is too broad because it extends to 

all renewable energy technologies regardless of their environmental effects. For example, poorly 

designed and located hydropower projects can adversely affect salmon, which are critical to the 

Southeast Alaskan way of life. The Forest Service should adopt a definition that focuses on 

beneficial technologies. The current definition does not differentiate between energy resources 

whose use will force climate change, such as biomass, and those whose use is essentially 

climate-neutral or even climate beneficial, such as wave action. The current definition does not 

exclude resources that replenish too slowly to matter for purposes of human civilization. Based 

on the current definition, old-growth forests that may take hundreds or thousands of years to 

replenish, but can ever truly be replenished, are classified as “renewable energy.”

DEIS Comments and Responses I-116 Final EIS
Appendix I

RESPONSE

The definition of renewable energy in the Proposed Forest Plan is consistent with the Forest Service 

Strategic Energy Framework, approved by the Chief in January, 2011. Environmental consequences 

associated with the utilization of various renewable energies are disclosed in a project-level 

environmental analysis (the reviewer’s example of the potential for hydropower to adversely impact 

aquatic resources is one), but those do not change the fundamental definition of renewable energy. It is 

not the role of this plan to redefine a commonly agreed-upon term. The Forest believes it is appropriate to 

maintain the definition in the Forest Plan.

COMMENT

REN-3: If “renewable energy” was defined to focus on beneficial technologies, it would not 

include biomass. Biomass technology’s effect on climate change, its potential demands on forest 

resources, its harmful emissions, and the fact that Tongass biofuels are not competitive in the 

market, makes it a mistake for the Forest Service encourage this as a type of renewable energy. 

The DEIS mentions a Forest Service goal of converting 30 percent of fuel oil heating to biomass. 

This goal does not exist as a plan component in the Proposed Forest Plan. To avoid confusion, 

the Forest Service should remove references to this goal from the FEIS for the reasons stated. 

The Forest Service has not considered the environmental effects of promoting biomass energy as 

NEPA requires. The Forest Service has not considered these issues, despite the fact that they are 

integral to understanding the environmental effects of the Proposed Forest Plan’s new renewable 

energy direction. The Forest Service must consider all of these issues before it adopts forest plan 

components that promote biomass energy, such as those in the Proposed Forest Plan. 

RESPONSE

A programmatic analysis of the Proposed Forest Plan’s new renewable energy direction was provided on 

pages 3-289 to 3-290 in the DEIS. As stated on page 3-289 of the Renewable Energy section in Chapter 

3 of the DEIS, the new renewable energy direction in Chapter 5 of the Proposed Forest Plan could affect 

other resources, and these effects are discussed in each respective resource section in the FEIS. The 

Forest Plan does not specifically authorize biomass projects. Rather, the Forest Plan provides overall 

strategic direction for management of the Tongass and encourages development of renewable energy 

without compelling specified Agency actions or guaranteeing specific results. Timber sales can currently 

support biomass energy products under the 2008 Plan. Several examples of current biomass projects 

were provided in the DEIS on page 3-286, and the Forest Service acknowledged that “successfully 

launched projects provide useful learning opportunities as case studies, but future projects will need to 

continue analyze overall cost savings based on choosing the right technology for the local biomass fuel 

supply (USDA Forest Service 2015k).”

The Forest Service’s “goal to support a transition of 30 percent of the heating oil use in Southeast Alaska 

to biomass over the next decade (Deering 2014)” as stated in the DEIS on page 3-459, was used by the 

U.S. Forest Service, Pacific Northwest (PNW) Research Station in a baseline model that was used to 

construct three management scenarios representing alternative futures for timber harvest in southeast 

Alaska (Daniels et al., 2016). The Forest Plan includes the following forest-wide goal in Chapter 5:

G-RE-01: The Forest would proactively contribute to sustainable production of renewable energy and 

energy transmission and distribution across the Forest, on all lands and LUDs, after consideration of 

other resources and community benefits.

The Forest Service’s role does not include performing human health risk assessments of the deployment 

and usage of materials derived from the National Forests. That role is appropriately held by regulatory 

agencies such as the EPA and ADEC. As such the Forest Service is not in a position to quantify the 

extent of “substantial risk to human health.” 

Final EIS I-117 DEIS Comments and Responses
Appendix I

Site-specific locations and mitigation measures for proposed renewable energy projects would be 

determined by project-level planning and environmental analysis at the time a specific project is 

proposed. Issues related to these proposed projects would be disclosed at that time.

See response to REN-1 regarding application of new renewable energy direction in Chapter 5.

COMMENT

REN-4: There is support for providing Southeast Alaskans with clean, affordable and reliable 

energy, particularly in small communities like Kake, which depend on isolated electric systems 

that run on high cost diesel. Development of community-based renewable energy solutions is the 

most effective approach. The Forest Service should invest agency resources to help small, dieseldependent communities transition to renewable energy. Examples include partnering with these 

communities to assist with public meetings, consensus building, site surveys, feasibility 

determination and project selection, and providing advice and resources to help these 

communities identify and implement energy efficiency and demand side management measures. 

Projects 5 MW or less, with minimal environmental impacts may qualify for a FERC exemption 

from licensing. 

RESPONSE

Since 2010, USDA agencies, led by the Forest Service and Rural Development, have been directed to 

develop a strategy known as the Transition Framework to help Southeast Alaska communities transition 

to a more diversified economy. Renewable energy, forest restoration, young-growth management, and 

tourism are a few of the components of the transition strategy. This is discussed in Chapter 1 of the FEIS.

The Forest Plan plays a role in supporting the Transition Framework to help move Southeast Alaska 

communities to a more diversified economy and provides desired conditions/objectives to benefit

communities powered by diesel. See response to REN-1 regarding application of new renewable energy 

direction in Chapter 5 of the Forest Plan.

COMMENT

REN-5: Sensitive habitats should be avoided when renewable energy facilities or transportation 

and utility corridors are proposed, studied, and ultimately developed. The Proposed Forest Plan’s 

plan components should require siting roads and other infrastructure outside of OGRs, beach 

fringe, designated wildlife corridors, and other sensitive areas unless an analysis demonstrates 

that there are no practical alternatives. The action alternatives evaluated in the DEIS do not appear 

to require this analysis, which leads to the presumption that construction of roads and renewable 

energy facilities are allowed wherever they may be proposed, irrespective of habitat values. This 

proposed approach could undermine the integrity of the Conservation Strategy, which was 

designed to protect important habitat in specific locations from human impacts.

RESPONSE

The Forest Plan does not specifically authorize renewable energy projects. Rather, the Forest Plan 

provides overall strategic direction for management of the Tongass and encourages development of 

renewable energy without compelling specified Agency actions or guaranteeing specific results. The 

analysis presented in the Forest Plan FEIS is programmatic. Project level analyses are conducted for sitespecific projects, such as renewable energy sites. Project level analyses quantify all the impacts—

beneficial and adverse—of a proposed project. Potential impacts may include impacts to wildlife, 

wetlands, particular sectors of the economy, and other resources or uses.

Analysis conducted under the NEPA process would evaluate site-specific resource impacts and 

cumulative effects from renewable energy site development, and adjustments could be made as needed 

to ensure protection of these resources.

DEIS Comments and Responses I-118 Final EIS
Appendix I

Renewable Energy desired condition DC-RE-02 in Chapter 5 of the Forest Plan requires that the Forest 

Service develop renewable energy resources “...in a manner that would maintain and protect National 

Forest System (NFS) lands and resources.”

Protection of resources remains a priority and consistency with the Forest Plan and monitoring of results 

will continue. The Forest Service developed the set of plan components including the suitability of lands 

(SUIT-RE-01) to integrate social, economic, cultural, and ecological considerations. When developing 

future renewable energy projects, the project or activity must be designed to be consistent with the 

applicable plan direction in Chapter 5. (Consult Chapter 6 of the Forest Plan regarding Project 

Consistency Requirements.) See response to REN-1 regarding application of new renewable energy 

direction in Chapter 5.

COMMENT

REN-6: Proposed Renewable Energy direction is moving in the right direction, but lacks clear, 

enforceable direction necessary to promote renewable energy development. Suggested changes 

to Chapter 5 include:

• Change wording in the introduction so that “preliminary stage” is not confused with the 

industry term “preliminary permit.”

• Adding clear guidance to SUIT-RE-01 about how consideration to LUD, ecological and 

social values, and benefits to Southeast Alaska communities will be applied. 

• Change O-RE-01(1) to include all communities in Southeast Alaska.

• Change wording in O-RE-01(2) to make it clear that "renewable energy capacity" is 

intended to be broadly interpreted to include increases in capacity, efficiency, and storage 

in support of Priority 1. 

• Add a Management Approach to Facilities (FAC) to acknowledge that some renewable 

energy facilities may not have previously defined corridors. This is especially true for 

renewable sites not contemplated when corridors were originally established (e.g., wind, 

tidal, biomass).

• Change G-RE-FAC-01 to acknowledge that existing and planned transportation system 

corridors should be used when present.

• Change G-RE-FAC-02 to acknowledge that viable and beneficial alternative routes outside 

of established corridors may not be "linear".

• Revise scenery design management approach to not be unreasonable or render a project 

infeasible.

• Modify SUIT-RE-TRAN-01 and S-RE-TRAN-01 to provide clear interpretation on lands 

pertaining to renewable energy development within an Inventoried Roadless Area.

• Specify a thirty (30) day timeline for review and issuance of special use permits for 

exploratory and study activities.

• Specify authorized decision-making authorities for each subsection of the Renewable 

Energy Direction in such a way that helps streamline renewable energy permitting and 

development.

• Ensuring that renewable energy developers are able to construct roads, including in 

roadless areas.

Final EIS I-119 DEIS Comments and Responses
Appendix I

RESPONSE

The majority of the above suggestions have been incorporated into the Forest Plan as appropriate. The 

Forest Plan provides guidance in how LUDs and other resource values are to be addressed. The word 

“rural” was maintained primarily due to the fact that most of these communities are those that are 

currently not interconnected or have established renewable energy capabilities available. Specifying 

timelines for permitting response is outside the scope of the amendment. Agency policy provides for 

notification whether a proposal for a special use permit will receive further consideration (FSH 2709.11, 

chapter 10, section 10.3), and other agencies that may have authority over certain proposed energy 

projects, such as the Federal Energy Regulatory Commission, will establish timelines as appropriate. 

The Forest Service developed the set of plan components including suitability of lands (SUIT-RE-01) to 

integrate social, economic, cultural, and ecological considerations. When developing future renewable 

energy projects, the project or activity must be designed to be consistent with the applicable plan 

components in Chapter 5. (Consult Chapter 6 of the Forest Plan regarding Project Consistency 

Requirements.)

Road development would be considered based on the siting of the project and the objectives of the LUD it 

is located in, in consideration of all applicable plan components.

COMMENT

REN-7: The renewable energy direction in the Proposed Forest Plan is vague, unenforceable, 

subject to broad interpretation, and fails to deliver the type of clear and consistent approach and 

understandable criteria that is required by renewable energy developers to undertake renewable 

energy development activities. The new direction will also require many assumptions and a great 

deal of discretion, which does not make renewable energy development more permissible. The 

renewable energy direction in the Proposed Forest Plan is not consistent with national energy 

policy and national energy security policy. Additionally, Public Law 106 -511 enacted on 

November 13, 2000 establishing the Southeast Alaska Intertie System is not referenced, explained, 

or identified. There is no discussion about how these laws could assist in the development of an 

enforceable renewable energy resource plan that would reduce air emissions, including 

greenhouse gases, from mining operations. A renewable energy resource plan or LUD should 

have been included in the Proposed Forest Plan to recognize pre-existing power site 

classifications and other potential renewable energy resources on the Tongass such as 

hydropower, geothermal, wind, tidal, or other renewable energy sites.

RESPONSE

The Forest Service is committed to playing a significant and long-term role in resolving challenges to our 

energy resources, on which our environment and quality of life depend. The Forest Service Strategic 

Energy Framework, approved by the Chief in January, 2011, sets direction and proactive goals for the 

Agency to significantly and sustainably contribute toward resolving U.S. energy resource challenges, by 

fostering sustainable management and use of forest and grassland energy resources. Challenges include 

the need to balance the social, environmental, and economic variables influencing and influenced by 

energy supply.

We acknowledge that a renewable energy plan for the Tongass may be valuable; however, this amended 

forest plan provides overall strategic direction for management of the Tongass and encourages 

development of renewable energy without compelling specified Agency actions or guaranteeing specific 

results.

The plan amendment proposed to remove the “avoidance areas” as the initial impediment for locating 

renewable energy projects. We understand that this alone does not provide certainty to project 

developers as they weigh the risks and economics of a project. However, whether a specific renewable 

energy plan exists will not reduce the need for the Forest to balance the social, environmental, and 

economic variables for those communities within southeast Alaska. 

Response to comments related to mining are referenced under MIN-1 through MIN-8.

DEIS Comments and Responses I-120 Final EIS
Appendix I

COMMENT

REN-8: Renewable Energy projects should not be prioritized based on market destination or endline user as proposed in the renewable energy direction in Chapter 5 of the Proposed Forest Plan. 

The use of the term “export” to describe sale of renewable energy to markets outside of Alaska is 

inappropriate. Selling energy across state boundaries, and even across the Canadian border 

pursuant to North American Free Trade Act, is a well-established and commercially reasonable 

activity typical of the utility sector. Even if power is not sold locally, renewable energy projects in 

the Tongass create rural “green jobs,” local expenditures, and local tax revenue in southeast 

Alaska, all of which are meaningful benefits, which the Forest Service should recognize. The 

Forest Service should ensure timely and adequate staff participation in all renewable energy 

development proposed on National Forest System lands, in accordance with FERC’s permitting 

and licensing processes, and treat all developers equally without prioritizing projects based their 

intended market or user.

RESPONSE

The Forest Service acknowledges in the desired conditions of the Renewable Energy Direction that 

renewable energy projects contribute to the economic well-being of Southeast Alaska communities. To 

ensure Southeast Alaska has the benefit of sustainable economic development, the plan components 

provide for a priority consideration of renewable energy projects based on whether the projects lead to a 

decrease in the number of Southeast Alaska rural communities powered by diesel generators, an 

increase in energy capacity, efficiency, or storage at existing projects, or an export of renewable energy 

resources without power benefitting Southeast Alaska communities. This prioritization is consistent with 

the goals of the Transition Framework and the Secretary’s Memorandum, and is reflected in the 

recommendations of the Tongass Advisory Committee. That group noted that relief to communities is 

ensured where the Forest Plan provides for increased access to new renewable energy and hydropower 

resources within the Tongass, thereby allowing communities to enjoy more affordable energy for current 

purposes and future growth, while also supporting the growth and prosperity of a new young growth 

manufacturing industry through more affordable renewable energy. 

The Forest Service also acknowledges that adequate staff participation in all renewable energy 

development projects proposed on the Tongass is desirable; however, in the 2011 Forest Service 

Strategic Energy Framework, the agency identified the need to increase the Agency’s institutional 

capacity with the specialized skills necessary to assess the effects of existing and new technologies that 

affect America’s forests. The Tongass has similar challenges regarding capacity and specialized skills. 

Applying priority considerations to renewable energy projects also gives the Tongass an opportunity to 

respond to proposals more effectively given limited agency resources.

COMMENT

REN-9: The Proposed Forest Plan does not make it clearer and easier for roads and utility 

systems to be built to facilitate less expensive construction of renewable energy projects, or give 

greater assurance of speedy approval for roads or transmission facilities through roadless areas. 

These amendments would also aid economic development of mineral deposits in the forest. 

Transportation and utility access was guaranteed through most of the Tongass National Forest by 

Title XI of ANILCA, which set up a process guaranteeing access through conservation system 

units after the agency ruled that IRAs are covered under that definition. Although the existing 

alternatives propose to provide more "flexibility" on a "case-by-case" basis for roads and utilities, 

the language does not provide sufficient certainty of approval to encourage developers to 

advance costly reconnaissance studies of potential projects that could be impacted by 2001 

Roadless Rule regulations. In order to prevent needless costs and development uncertainties, the 

Forest Service should determine how to handle future requests for renewable energy 

developments in 2001 roadless areas. 

Final EIS I-121 DEIS Comments and Responses
Appendix I

RESPONSE

Not all NFS lands may be suitable for renewable energy. Chapter 5 includes the following suitability of 

lands plan component to identify the suitability of renewable energy in a particular area at the project level 

with site-specific analysis:

SUIT-RE-01: All NFS lands may be suitable for renewable energy sites on a case-by-case basis in 

consideration of the LUD, ecological and social values, and benefit to Southeast Alaska communities. 

See response to REN-1 regarding application of new renewable energy direction in Chapter 5. The new 

plan components are set to ‘encourage renewable energy production’ (Proposed Forest Plan, Page 5-

12).

The Forest Service acknowledges that these new components will make it ‘easier for roads and utility 

systems to be built’; 36 CFR 219.13 (a) allows for such LUD changes. See response to TUS-2. There is 

no authority for the responsible official to modify federal law enacted by Congress or be inconsistent with 

higher-level direction through forest planning (See Forest Plan Priority of Direction in Chapter 1). 

Conservation system units on the Tongass National Forest are statutorily designated areas; roadless 

areas on the Tongass National Forest are administratively established, designated by the Secretary of 

Agriculture in accordance with the 2001 Roadless Rule. The Priority of Direction as explained on page 1-

4 of the Proposed Forest Plan provides that higher-level direction (federal law and regulations) take 

precedence over the Forest Plan direction. The clear intent of the Proposed Forest Plan is to encourage 

renewable energy production within the laws and regulations. Changes to the 2001 Roadless Rule are 

outside of the scope of this amendment. 

COMMENT

REN-10. The Forest Plan should incorporate the September 29, 2006 Memorandum of 

Understanding (MOU) between U.S. Department of Agriculture, Forest Service, Alaska Region, and 

the State of Alaska Department of Natural Resources and Alaska Department of Transportation 

and Public Facilities (FS Agreement No. 06MU-11100100-151; State of Alaska Agreement No. ADL 

107516), which specifically identified rights of way for transmission corridors and log transfer 

facilities illustrated in Safe, Accountable, Flexible, Efficient Transportation Equity Act 

(SAFETEALU). The Forest Service must also consider the impacts of these reciprocal easements 

in the EIS.

RESPONSE

The FEIS acknowledges Public Law 109-59, as amended, and the rights-of-way and easements identified 

in Safe, Accountable, Flexible, Efficient Transportation Equity Act (SAFETEALU) Map 92337 under 

existing conditions in Chapter 3 under Land Uses, Ownership, and Adjustments and the Transportation 

sections. The MOU and easements for transportation and utility corridors are described and analyzed in 

the Transportation section in Chapter 3 of the FEIS. 

Renewable energy guideline G-RE-FAC-01 in the proposed Forest Plan has been revised in the Forest 

Plan to include the easements as follows:

G-RE-FAC-01: Utility lines should follow existing or planned transportation systems corridors, including 

those identified in the Logging Systems and Transportation Analysis (LSTA) and Public Law 109-59.

DEIS Comments and Responses I-122 Final EIS
Appendix I

Minerals and Mining (MIN)

COMMENT

MIN-1: The proposed TLMP Amendment should discuss the adverse impacts to the mining sector 

from re-imposition of the Roadless Rule on the Tongass. 

RESPONSE

The 1872 Mining Law gives a statutory right of reasonable and necessary access related to the 

exploration and development of mineral properties, and the 2001 Roadless Area Conservation Rule 

(Roadless Rule) recognizes this right. This statutory right is subject to reasonable regulation for the 

protection of surface resources. If the inventoried roadless area is open to mineral entry, locatable 

mineral mining, including certain activities ancillary to the mining such as access roads for exploration 

and development, may be approved. 

The Roadless Rule anticipates a number of other permissible activities, including exploration and 

development of leasable minerals, such as oil and gas or geothermal resources, hydropower projects, 

forest restoration projects, and certain special uses that do not involve road construction or 

reconstruction. The Forest Service will work with the project proponent to determine the permissible 

activities during NEPA analysis of a proposed project.

COMMENT

MIN-2: The TLMP Amendment should include mining in the multiple use strategy and include 

enforceable mechanisms to promote mineral and strategic mineral development, including a 

Mineral and Strategic Mineral LUD; interpreting “reasonable access” for mining operations within 

the Tongass to mean road access for mineral and leasable mineral development; including clear 

guidelines allowing for cutting trees in association with mining exploration and development 

access on the Tongass; and including an alternative that would allow access to future mineral 

leases (including geothermal leases) on the Tongass, even if such alternative(s) would require a 

modification to the Roadless Rule.

RESPONSE

As stated above, the 1872 Mining Law gives a statutory right of reasonable and necessary access related 

to the exploration and development of mineral properties, and the Roadless Rule recognizes this right. 

This statutory right is subject to reasonable regulation for the protection of surface resources. If the 

inventoried roadless area is open to mineral entry, locatable mineral mining, including certain activities 

ancillary to the mining such as access roads for exploration and development, may be approved. It is 

important to note that “reasonable access” does not have a strict interpretation, and in many cases road 

access is not the most reasonable alternative or the most cost efficient. If a mineral exploration or 

development project is proposed within an inventoried roadless areas, the Forest Service will work with 

the project proponent to determine the permissible activities, including reasonable access, during NEPA 

analysis of the proposed project.

Exploration and development of leasable minerals, such as oil and gas or geothermal resources, are not 

prohibited under the Roadless Rule. 

COMMENT

MIN-3: Thirty day turnaround for issuance of Special Use Permits to those holding mining claims.

RESPONSE

Specifying timelines for permitting response is outside the scope of the amendment. There is no 

regulatory basis to provide mining claimants priority or special treatment when it comes to the processing 

of Special Use Permits. Agency policy provides for notification whether a proposal for a Special Use 

Permit will receive further consideration (FSH 2709.11, sec 10.3).

Final EIS I-123 DEIS Comments and Responses
Appendix I

COMMENT

MIN-4: The Forest Service should allow roads through roadless areas to guarantee more 

affordable access to mineral developments. Any plan update should be modified to guarantee 

more affordable access to mineral developments.

RESPONSE

The Roadless Rule allows for the construction of roads in IRA’s consistent with the level of locatable 

mineral exploration or development. Reasonable access in some of the more remote locations on the 

Tongass has frequently been interpreted in the past as helicopter or water access. The Bokan Mountain 

and Niblack Projects mentioned did not propose road access for their projects, likely due to the costs of 

construction and maintenance, as well as reclamation bonding for said access relative to the lesser costs 

of helicopter and boat access. Economics are only one of many variables considered in determining 

reasonable access. 

Project-level decisions, such as access roads to specific mining projects, are beyond the scope of the 

Forest Plan (and thus the currently proposed amendment). 

COMMENT

MIN-5. The impacts to mining from the President’s November 3, 2015 Memorandum directing 

agencies to avoid and minimize harmful effects to natural resources caused by land- or waterdisturbing activities, and to ensure that any remaining harmful effects are effectively addressed 

are impossible for the public to predict and must be disclosed in the EIS.

RESPONSE

Nationally, the Forest Service is developing a brief regulation that establishes clear goals for the use of 

mitigation on National Forest System lands and a set of directives in the Forest Service Manual and 

Handbook that clarify methods, tools, and their appropriate use to accomplish this. The regulation and 

guidance are in development. When draft regulation is developed, it will include an opportunity to provide 

specific input. When final, it will be provided to the Tongass and be implemented. Currently, the Final 

Directives are anticipated in late 2017. Additional information is available at: 

http://www.fs.fed.us/emc/nepa/FSMitigationPolicy.htm

COMMENT

MIN-6. Minerals management activities should be equally facilitated on any and all lands, not just 

what someone perceives as highest potential areas. See MG1.A (Forest Plan Chapter 3, Minerals). 

RESPONSE

Changes to the Minerals overlay LUD standards and guidelines are outside of the focused scope of this 

Forest Plan amendment. Forest-wide Minerals and Geology Standards and Guidelines are provided in 

Chapter 4 of the Plan, where MG2.II provides direction to "encourage" exploration, development, and 

extraction of mineral on all lands open to mineral entry.

COMMENT

MIN-7. Forest Plan Chapter 3, Minerals, TRAN A, should not require reasonable access to mineral 

resources to be consistent with other resource values. 

RESPONSE

Changes to the Minerals overlay LUD standards and guidelines are outside of the focused scope of this 

Forest Plan amendment. Ensuring other resources are protected during the planning, approval, and 

operation of roads for mineral exploration and development is consistent with the Mineral LUD goals, 

objectives, and desired conditions and locatable mineral regulations at 36 CFR 228, Subpart A.

DEIS Comments and Responses I-124 Final EIS
Appendix I

COMMENT

MIN-8. The Forest Plan should acknowledge acceptance of other agency requirements and ability 

to jointly bond mineral projects.

RESPONSE

Changes to the Minerals overlay LUD standards and guidelines are outside of the focused scope of this 

Forest Plan amendment. 36 CFR 228.8(h) authorizes the Forest Service to accept certifications and 

other approvals issued by State or other Federal agencies with similar or parallel requirements. Further, 

Forest Service Manual 2817.24 provides that "All reasonable effort should be made, through agreements 

with States which require bonds for reclamation disturbances in National Forests, to avoid double 

bonding."

Wherever possible the Forest Service works cooperatively with states to avoid duplication or double 

bonding; however, The Forest Service should not waive its bond requirements in lieu of a state bond 

involving an instrument that is not acceptable to the Forest Service.

Final EIS I-125 DEIS Comments and Responses
Appendix I

Carbon Storage and Global Warming (CARB)

COMMENT

CARB-1 and CARB-2: The Plan Amendment should better discuss and analyze the critical role of 

the TNF in global carbon sequestration and storage and the importance to the climate-change 

mitigation contributions of forests in general, and of the Tongass in particular. In particular the 

Forest Service should consider a no-harvest scenario as a mitigation measure to prevent a carbon 

flux deficit from federal forests in southeast Alaska. The FS did not consider the full body of 

science showing how each alternative will likely result in an increased concentration of CO2 in the 

atmosphere in the near and long term.

RESPONSE: 

Regarding the scope of the plan amendment, see response to PLR-1.

The suggestion that the Tongass “consider an alternative that would mitigate climate change by lowering 

CO2 emissions and maximizing carbon storage” is beyond the scope of the amendment and would not 

meet the purpose and need of this action. That notice indicated that the purpose of the amendment was: 

“as needed to accomplish the transition to young growth management over the next 10 to 15 years while 

retaining the expertise and infrastructure of a viable timber industry in Southeast Alaska, as outlined by 

the Secretary in Memorandum 1044–009.”

The analysis in the Forest Plan has been modified to acknowledge the substantial role the Tongass plays 

in carbon storage and the importance to climate change mitigation. Additional text has been added in 

Chapter 3.1 of the Final EIS (pages 3-13, 3-21, 3-23, 3-26). In response, we revised the evaluation of 

GHG storage and the comparison among alternatives in relative contribution to atmospheric GHG’s to 

clarify the potential differences among alternatives in carbon sequestration and storage (pages 3-13-14). 

The analysis qualitatively discloses that carbon storage on the Tongass will remain substantial under 

each alternative (while disclosing the relatively small differences among alternatives). However, based 

on the scope of this amendment outlined in the ‘Notice of Intent To Prepare An Environmental Impact 

Statement’ published on 27 May, 2014, the purpose of the amendment is to: “accomplish the transition to 

young growth management over the next 10 to 15 years while retaining the expertise and infrastructure of 

a viable timber industry in Southeast Alaska, as outlined by the Secretary in Memorandum 1044–009.” 

Comments suggests that the Tongass examine the contribution of the Tongass “in general” to climate 

change mitigation by discussing the role of undisturbed forest. As an amendment, rather than revision, 

the scope of options being considered does not include the potential for no timber harvest and therefore 

the consequences of such an alternative are not considered.

The Secretary’s memo makes clear that the Department of Agriculture is committed to not only 

maintaining Southeast Alaska’s exceptional natural resources in perpetuity but is equally committed to 

doing its part to ensure that communities within and adjacent to the Tongass National Forest are 

economically vibrant. The proposed action for the Amendment is intended to bring these two goals hand 

in hand. To do so, there will be costs and in the case of carbon storage we acknowledge that in order to 

bring to fruition the multiple-use objectives of this document as well as the overall mission of the Forest 

Service, the Tongass will incur a short- and mid-term net loss of total carbon storage through GHG 

emissions as a result of timber harvest on the Tongass. 

COMMENT

CARB-3: The direct and indirect effects conclusion in the DEIS mistakenly describes the 

estimation of the effects of the Plan Amendment on carbon storage as “complex”. There is 

disagreement with the DEIS’ conclusion of no significant effect, claiming this conclusion is 

arbitrary.

RESPONSE: 

Additional discussion and citations regarding the direct and indirect effects of logging under the 

Amendment have been added to the text in Chapter 3.1 of the Final EIS. 

DEIS Comments and Responses I-126 Final EIS
Appendix I

COMMENT

CARB-4: The DEIS was insufficient in identifying a relevant time frame in its climate change 

analysis and should establish quantifiable criteria for measuring carbon emissions and lost 

carbon storage according the Revised DRAFT CEQ.

RESPONSE

Additional discussion and citations regarding the differential ability of old-growth forest to sequester 

carbon dioxide and store carbon as well as a more explicit discussion about relevant timescale have been 

added to the text in Chapter 3.1 of the Final EIS. The Tongass National Forest currently sequesters large 

quantities of carbon (referred to it as the combined outcome of carbon “storage” and carbon “emissions”). 

Timber harvesting and forest management can affect a forest’s ability to store carbon as well as emit 

carbon as carbon dioxide and other greenhouse gasses. The climate change discussion in Chapter 3’s 

Affected Environment provide added discussion of the dynamics of carbon storage and loss due to 

proposed actions identified in this amendment. In summary, harvesting old growth creates a net release 

of CO2 into the atmosphere – particularly in short- and mid-term. There is uncertainty regarding longterm CO2 release particularly because of the importance of how the wood is used (durable or nondurable 

products), the regrowth of young forests, and market dynamics related to substitution. 

The revised Chapter 3 also more clearly discloses uncertainty of GHGs contributions in the short- and 

long-term that result from timber harvest (both old-growth and young-growth) for each action alternative. 

The EIS does not present a quantitative analysis of carbon emissions, nor is there a requirement to do so 

(see response to CARB-23). Given the level of uncertainty in parameters related to the net contribution of 

GHGs, an attempt to quantify the evaluation would not provide clarity but instead result in a false sense of 

certainty. We qualitatively evaluate differences among the alternatives. The qualitative analysis provides 

the necessary level of information to evaluate the relative differences in carbon losses and gains for each 

alternative, thus providing the information for the deciding official on the relative contribution of GHGs 

from the proposed actions (USDA-Forest Service 2009).

COMMENT

CARB-5 and 6: The Forest Service’s assumptions that carbon storage in wood products and 

thinning can offset emissions are incorrect. Also incorrect is the statement that “thinning 

activities may lead to a net gain or a net release of carbon...depending on how the thinning is 

conducted.” 

RESPONSE

Additional discussion and revisions in text have been added to Chapter 3.1 of the Final EIS regarding the 

effects of total carbon storage as a result of logging (both old-growth and young-growth forests) for each 

alternative. Additional discussion and citations regarding likely effects the social costs of carbon 

emissions as a result of proposed actions for each alternative have been added to the text in Chapter 3 of 

the Final EIS). 

COMMENT

CARB-7, CARB-23 and CARB-24: The Forest Service should adopt the conservation alternative 

(e.g. no harvest alternative), provided by the Conservation Consortium, to comport with CEQ 

guidelines, the Paris climate agreement, and efforts to reduce climate damages from CO2 

pollution. The FEIS should also include a cost-benefit analysis of avoiding damages to the 

environment cause by climate change “so as to level the economic playing field” in compliance 

with Executive Order 12866. A carbon life-cycle analysis should be presented to illustrate the 

outcome of the alternatives as well as an evaluation of the social cost of carbon emissions based 

on Executive Order 12866 and using the Interagency Working Group guidelines on carbon 

costing. (A GEOS Institute Analysis)

Final EIS I-127 DEIS Comments and Responses
Appendix I

RESPONSE

See CARB-23 and CARB-24.

COMMENT

CARB-8: The DEIS arbitrarily and incorrectly characterizes the role of the public lands in 

southeast Alaska as insignificant by comparing global forest carbon sequestration to carbon 

storage in marine ecosystems. Further, this approach, which compares global storage in forests 

to global carbon storage in oceans (and, indeed, the atmosphere itself), fails to provide a 

cumulative effects analysis at a meaningful scale.

RESPONSE

Additional documentation and evaluation of cumulative effects of climate change have been added to the 

text in Chapter 3.1 of the Final EIS. See Response to CARB-4 for a fuller discussion of the effects 

analysis using a more meaningful time scale.

This section is made of 2 parts: 1) the effect of the project Amendment on climate change; and 2) the 

effects of climate change on the project Amendment. The first part of this section addresses the 

cumulative effects of GHG emissions and other contributors to climate change; while the second part 

addresses cumulative effects of the project on carbon sequestration (carbon storage and emissions). 

This section highlights the conclusion that higher levels of harvest (e.g., the total available harvest under 

each of the alternatives) would only occur if additional manufacturing facilities and markets are 

developed, as well as other factors such as funding and staff levels. In addition, we added a brief 

discussion that addresses the different time scales these effects could have on carbon sequestration as 

discussed in Environmental Consequences section). The net contribution to atmospheric CO2 is lower 

given longer time scales due to regeneration, particularly if wood products include ‘storage’ products, if 

biomass substitutes for local fossil fuel use, and if market substitution (also called market leakage) is 

relatively high (e.g. Jonsson et al. 2012).

The global contribution of carbon storage that the Tongass provides is acknowledged in the Secretary of 

Agricultures memo to the US Forest Service in providing the scope and need for action to this Plan 

amendment. We have added language in Chapter 3.1 to further demonstrate our understanding of the 

forest’s global importance in storing carbon. The Secretary’s memo makes clear that the Department of 

Agriculture is committed to not only maintaining Southeast Alaska’s exceptional natural resources in 

perpetuity but is equally committed to doing its part to ensure that communities within and adjacent to the 

Tongass National Forest are economically vibrant. The proposed action for the Amendment is intended 

to bring these two goals together. We acknowledge that in order to address the multiple-use objectives of 

this document we will incur a net loss of total carbon storage through GHG emissions as a result of timber 

harvest on the Tongass. No timber harvest, would not meet the purpose and need of the amendment and 

is outside the scope of the document. 

COMMENT

CARB-9 and CARB-4: The DEIS’s analysis is inaccurate because it ignores the differential ability 

of old-growth forest to sequester carbon dioxide and store carbon within the timeframe relevant to 

climate change mitigation. The Forest Service should evaluate timescale in light of scientific 

literature which suggests that “large-scale changes” in land use must occur within 10 to 15 years. 

RESPONSE

Additional discussion and citations regarding the differential ability of old-growth forests to sequester 

carbon dioxide and store carbon as well as a more explicit discussion about relevant timescale have been 

added to the text in the Climate and Air section of the Final EIS. The Tongass National Forest currently 

sequesters large quantities of carbon (referred to as carbon “storage”). Timber harvesting and forest 

management can affect the timing (e.g., short- term mid-term) and net amount of carbon stored in forests. 

The climate change discussion in Chapter 3’s Climate and Air section provides added discussion of the 

DEIS Comments and Responses I-128 Final EIS
Appendix I

dynamics of carbon storage and loss due to proposed actions identified in this amendment. In summary, 

harvesting old growth creates a net release of CO2 into the atmosphere – particularly in short- and midterm. There is uncertainty regarding long-term CO2 release particularly because of the importance of the 

use of the wood, the regrowth of young forests, and market dynamics related to substitution (sometimes 

called market leakage – e.g. Jonsson et al. 2012). 

As discussed in previous responses to comments (see CARB-4) a quantification of carbon flux due to the 

many pathways created naturally or by management actions proposed in this amendment is unnecessary 

to make an informed decision regarding the proposed action because a qualitative analysis provides the 

necessary level of information to evaluate the relative differences in carbon losses and gains for each 

alternative, thus providing the information for the deciding official on the relative contribution of GHGs 

from the proposed actions (USDA-Forest Service 2009). However, this amendment proposes to 

discontinue old-growth timber harvest after 15 years, and as such, we can expect a net decrease in 

carbon emissions from current levels through time.

COMMENT

CARB-10, CARB-1 and CARB-23: The DEIS’s figure for the overall size of the carbon cycle is 

incorrect and should be corrected in the FEIS. A quantitative evaluation of the emissions savings 

or losses attributable to the Plan is insufficient, incorrect and misleading.

RESPONSE

We revised the EIS to more clearly describe the potential of the Tongass action and contributions to 

atmospheric greenhouse gasses. See responses to CARB-1 and 23 for additional details pertaining to 

these comments.

COMMENT

CARB-11: Forest Service Should Leverage Taxpayer Dollars to Help Local Communities 

Transition from Old-growth Logging, while also Contributing to Carbon Storage.

RESPONSE

The Tongass National Forest appreciates the support for the intent of the amendment – to help local 

communities transition from old-growth logging while continuing to contribute to carbon storage. Each of 

the action alternatives seek to help local communities transition to forest management based largely on 

harvest of young-growth forest and reduces harvest of old-growth forest over a 15 year transition period. 

Funding for these actions comes from the Federal budget process through the Department of Agriculture. 

The intent of this Plan Amendment is to provide opportunities for the development of project-level plans 

that implement the transition of predominantly old-growth logging to harvest of young-growth forests. An 

outcome of this transition is the contribution of increase carbon storage from its current condition on the 

National Forest.

COMMENT

CARB-12: The DEIS did not include all relevant literature in the analysis of carbon and suggest 

the agency explain how the various alternatives, including the selected alternative, affect the 

amount of stored carbon on the Tongass.

RESPONSE

We appreciate the additional references mentioned and have considered them in our analysis and 

conclusions regarding effects of each alternative on climate change. We revised the EIS to more clearly 

describe the potential of each alternative to contribution to atmospheric greenhouse gasses and the 

relative amount of stored carbon on the Tongass for each alternative and have cited the literature that 

supports our findings.

Final EIS I-129 DEIS Comments and Responses
Appendix I

COMMENT

CARB-13: The FEIS should provide more detail, including stronger literature citations, regarding 

the recognition that rising temperature accelerates decomposition particularly in instances of oldgrowth logging and regarding changes in decomposition rates.

RESPONSE

We revised the evaluation of GHG storage and the comparison among alternatives in relative contribution 

to atmospheric GHG’s. As noted in our analysis we emphasize the dynamics of soil organic matter 

decomposition are complicated due to the many different factors involved in the process and cite the most 

recent study that identifies a lack of consensus in the science community on the temperature sensitivity of 

soil carbon decomposition to changes in regional temperature (Davidson and Janssens 2006). Many 

factors, including the relative mix of soil organic matter along a continuum of decomposability, and an 

array of environmental constraints (abiotic and biotic conditions) obscure the intrinsic temperature 

sensitivity of soil organics to decomposition (Davidson and Janssens 2006) suggesting a clear evaluation 

of the outcome of warming climate on decomposition on the Tongass is not feasible. Depending on 

environmental features such as changes in soil moisture, changes in water table, changes in 

predominance of decomposition-resistant soil carbon, the rate of soil carbon movement into streams, 

lakes, and marine environments, and other factors outlined in the most comprehensive recent review by 

Davidson and Janssen (2006), the net direction (increase or decrease) in GHG contribution to the 

atmosphere as a result of decomposition of soil carbon is uncertain. However, the ultimate response is 

one of increased decomposition with increasing temperature (D’Amore, pers. comm. 2016).

COMMENT

CARB-14: The DEIS does not adequately describe the difference in resilience to climate change 

between old-growth and young forests. The FEIS should evaluate how each alternative will vary in 

its preservation of old-growth and how that may have bearing on overall forest resilience for 

future net carbon flux.

RESPONSE

We appreciate the input suggesting improvements in evaluation of the relative value of old-growth vs. 

young-growth forest for carbon storage particularly in light of the general understanding that old-growth 

(or primary forest) may be more resilient to climate change. In response, we revised the evaluation of 

GHG storage and the comparison among alternatives in relative contribution to atmospheric GHG’s. We 

note however, that our analysis discloses that evaluation of the relative stability of biomes and the climate 

niche of dominant tree species on neighboring Chugach National Forest suggests that the temperate 

coastal rainforest of Alaska is particularly resilient to expected changes in climate in the region over the 

next 30 to 50 years (see Hayward et al. n.d.5: Chapter 6). Consequently, there is no direct evidence to 

suggest that that regenerating rainforest on the Tongass will be less resilient and therefore, that it will 

have reduced capacity for carbon storage under future climate conditions than it displays currently.

COMMENT

CARB-15: Rain and gale force winds are expected to increase in Southeast Alaska due to 

changes in climate. As such the agency should adopt mitigation policies, including standards and 

guidelines, in anticipation of rising winds and rain during this Plan Amendment related to soil and 

slope suitability, riparian area (RAW buffers) and other buffers around sensitive and important 

areas such as beach fringe.

RESPONSE

The current minimum size requirement for beach buffers (1,000 foot width from shoreline) and riparian 

management buffers (minimum of 100 feet on either side of Class I and II streams), will continue to be 

5 G. D. Hayward, S. Colt, M. McTeague, T. Hollingsworth. eds. (n.d.). Climate change vulnerability assessment for the Chugach 

National Forest and the Kenai Peninsula. Manuscript in preparation.

DEIS Comments and Responses I-130 Final EIS

 
Appendix I

implemented for the 2016 amendment. While some young-growth timber harvest is proposed within these 

buffers under alternatives 2, 3, 4 and 5, the new standards identified in the amendment allow for only 

partial harvest of these areas (e.g. maximum size of 10 acres and up to 35% removal of the stand) and in 

the case of Alternative 2, not to exceed the 15 year transition. Furthermore, the forest plan standards and 

guidelines for Reasonable Assurance of Windfirmness (RAW) buffers and steep slopes are flexible in that 

the application of RAW buffers and soil conservation measures depends on the specific conditions 

encountered at each site. This flexibility allows the application of the RAW buffers and steep slope soil 

conservation practices to be tailored to site specific conditions and anticipated increases in precipitation 

resulting from a changing climate. The anticipated changes in climate may require a more conservative 

approach in areas already at risk for windthrow or loss of slope stability. The FEIS Climate and Air section 

of Chapter 3 discusses the risks and effects associated with anticipated climate change on the forest. 

Monitoring of windthrow within stream buffers is ongoing on the forest and data from that monitoring is 

considered when designing projects and determining the need for, or design of RAW buffers. This 

monitoring began on the Tongass in 2000 and has continued yearly, for a total of 15 years of monitoring 

results (see annual Forest Plan Monitoring and Evaluation Reports 

at http://www.fs.usda.gov/main/tongass/landmanagement/planning). The proposed management within 

buffers under the amendment (size openings and percent harvest) have not yet been implemented, nor 

undergone monitoring to provide the Forest Service information on the effectiveness of the overall buffers 

when managed in this way. Through future monitoring the Tongass will evaluate effectiveness. Until new 

information is available the Tongass will use the standards, guidelines and management approaches 

identified in 2016. 

COMMENT

CARB-16: The Forest Service should undertake a climate change resiliency assessment across 

the Tongass and an analysis to discover which watersheds will be most resilient to future climatic 

change. Additionally, the agency should invest in research to understand how climate change will 

affect stream flows, stream temperatures, and salmon populations/spawning success/ fish 

production. 

RESPONSE

The Forest Service appreciates the suggestion to assess the climate change resiliency of the Tongass. 

The Tongass National Forest, in line with national policy has been collaborating with partners since 2012 

improving understanding of the potential consequences of climate change for ecosystems and resources 

in southeast Alaska. The recently published assessment (EcoAdapt 20146) is an example of this effort. 

Similarly, the USFS was the lead agency, collaborating with a wide array of partners, for a recent 

workshop examining water resources and anadromous fisheries in response to climate change [Climate 

Change in Southeast Alaska – Informing Sustainable Management of Water Resources and Anadromous 

Fisheries. April 12-15, 2016]. These accomplishments demonstrate that the Tongass recognizes the 

value of climate assessments and is actively incorporating climate science into its work. These efforts 

specifically focused on salmon and their fisheries. Regarding the suggestion that the Tongass “invest in 

research to understand how climate change will affect stream flows, stream temperatures, and salmon 

populations/spawning success/ fish production.” Based on law and policy the National Forest System 

does not conduct research (cite law/policy) but is involved in cooperative and, administrative studies 

modeling hydrologic changes and consequences for salmon as well as several other climate change 

research studies in progress with the Forest Science Laboratory of the Pacific Northwest (PNW) 

Research Station.

COMMENT

CARB-17: Cited literature related to climate change in the Plan Amendment contains “hypothetical 

as well as irrelevant” information. The Plan Amendment’s purpose and need to transitioning from 

and old-growth dominated harvest strategy to harvesting young growth trees is premature. 

6 EcoAdapt. 2014. A Climate change vulnerability assessment for aquatic resources in the Tongass National Forest. EcoAdapt, 

Bainbridge Island,WA

Final EIS I-131 DEIS Comments and Responses

 
Appendix I

Furthermore, the amount of timber proposed for harvest over the transition period and its effects 

on total carbon storage is inconsequential at a global scale. The Amendment should clarify the 

carbon flux discussion, including the ultimate destiny of carbon storage and emissions after 

harvest.

RESPONSE

Best available science (e.g., IPCC 2014, Melillo et al. 2014, Millennium Ecosystem Assessment. 20057) 

and broad science consensus indicates that the preponderance of evidence supports the contention that 

climate change is occurring and that human production of greenhouse gases is a major contributor. 

National policy as indicated by the 2012 Planning Rule (36 CFR 219) directs the Forest Service to 

disclose the consequences of its actions in relation to climate change. Regarding the relationship of 

forest condition on the Tongass and carbon storage, analysis of field data (Barrett et al. 2014) provides 

evidence regarding the status of carbon storage on the Tongass. The agency agrees that carbon in wood 

products is stored for variable periods of time, and potentially for long periods in structural lumber and 

other durable products (http://www.fs.fed.us/ecosystemservices/carbon.shtml). Revisions made in 

Chapter 3 of the FEIS (Climate and Air section) further clarify the status of carbon storage on the 

Tongass, to the extent that can be resolved with current scientific understanding.

COMMENT

CARB-18: The agency should improve the FEIS’ discussion related to increased carbon emissions 

which would occur with additional biomass fuel development, including disclosure of the 

environmental effects caused by biomass fuel combustion for air quality and human health. 

Further, a more specific discussion should be added to the FEIS related to substituting biomass 

fuels for fossil fuels and compare these two energy systems in terms of total CO2 emissions. 

Finally, the Amendment should prepare a “no- harvest” alternative to evaluate a more ambitious 

climate change mitigation strategy.

RESPONSE

This comment is outside the scope of this amendment. The Forest Service’s role does not include 

performing human health risk assessments of the deployment and usage of materials derived from the 

National Forests. That role is appropriately held by regulatory agencies such as the EPA and ADEC. As 

such, the Agency is not in a position to quantify the extent of “substantial risk to human health”. 

Further the Forest isn’t distinguishing between renewable energies, of which biomass is one type, nor is it 

authorizing specifically biomass. However, timber sales can and are currently being used to support 

biomass energy products. The Forest believes it is appropriate to maintain the goal as stated in the EIS; 

no change made. Also, see response to CARB-1 and CARB-2 for more discussion the “no harvest” 

alternative to mitigate for climate change.

COMMENT

CARB-19: The agency should remove biomass from its list of renewable energies and add more 

content about wood biomass combustion and the carbon cycle. More discussion on the effects of 

carbon emissions as a result of biomass fuel development on air quality should be included in the 

FEIS.

7 IPCC. 2014. Summary for policymakers. In: Field, C.B.; Barros, V.R.; Dokken, D.J.; Mach, K.J.; Mastrandrea, M.D.; Bilir, T.E.; 

Chatterjee, M.; Ebi, K.L.; Estrada, Y.O.; Genova, R.C.; Girma, B.; Kissel, E.S.; Levy, A.N.; MacCracken, S.; Mastrandrea; P.R.; 

White, L.L. eds. Climate Change 2014: Impacts, Adaptation, and Vulnerability. Part A: Global and Sectoral Aspects. Contribution of 

Working Group II to the Fifth Assessment Report of the Intergovernmental Panel on Climate Change. Cambridge University Press, 

Cambridge, United Kingdom and New York, NY, USA: 1-32.

Melillo, J.M.; Richmond, T.C.; Yohe, G.W., eds. 2014. Climate Change Impacts in the United States: The Third National Climate 

Assessment. U.S. Global Change Research Program. 841 p.

Millennium Ecosystem Assessment. 2005. Ecosystems and Human Well-being: Synthesis. Island Press, Washington, DC.

DEIS Comments and Responses I-132 Final EIS

 
Appendix I

RESPONSE

This is outside the scope of this amendment. The Forest Service’s role does not include determining 

what type of renewable energy (e.g., zero-emitting vs. “dirty” energies) or performing human health risk 

assessments of the deployment and usage of materials derived from the National Forests. That role is 

appropriately held by regulatory agencies such as the EPA and ADEC. The Forest is not authorizing 

specifically biomass; however, sales can and are currently used to support biomass energy products. 

The Forest believes it is appropriate to maintain the goal as stated in the EIS and reiterates that it is not 

distinguishing between renewable energies. If the Forest were to begin to see numerous proposals for 

biomass utilization at a large scale, additional NEPA would then account for this. 

Please refer to AIR-1 response for more information on the effects of increase carbon emissions on air 

quality. 

COMMENT

CARB-20: DEIS failed to analyze lost opportunities for zero-emitting renewable energies caused 

by biomass facility subsidies.

RESPONSE

The amendment does not explicitly favor one form of renewable energy over another, nor is it focused on 

biomass. As the commenter notes, there have been a number of conversion to biomass fuel projects. 

The Forest is not authorizing specifically biomass; however, sales can and are currently used to support 

biomass energy products. The Forest believes it is appropriate to maintain the goal as stated in the EIS 

and reiterates that it is not distinguishing between renewable energies. The EIS clearly states that 

successfully launched conversion projects provide useful learning opportunities as case studies, but 

future projects will need to continue to analyze the cost/benefit savings based on choosing the right 

technology for the local biomass fuel supply. Each project will need to weigh the cost of converting to 

biomass with the cost of other readily available energy sources. 

Please refer to AIR-1 response for more information on the effects of increase carbon emissions on air 

quality and GHGs.

COMMENT

CARB-021 and CARB-8: The Forest Service failed to adequately consider the cumulative effects 

of programmatic alternatives and climate change, as recommended by various climate change 

experts, also supported in agency documents, such as the Alaska Region’s Climate Change 

Assessment (2010).

RESPONSE

Additional documentation and evaluation of cumulative effects of climate change have been added to the 

text in Chapter 3.1 of the Final EIS. 

This section is made of 2 parts: 1) the effect of the project Amendment on climate change; and 2) the 

effects of climate change on the project Amendment. The first part of this section addresses the 

cumulative effects of GHG emissions and other contributors to climate change; while the second part 

addresses cumulative effects of the project on carbon sequestration (carbon storage and emissions). 

This section highlights the conclusion that higher levels of harvest (e.g., the total available harvest under 

each of the alternatives) would only occur if additional manufacturing facilities and markets are 

developed, as well as other factors such as funding and staff levels. In addition, we added a brief 

discussion that addresses the different time scales these effects could have on carbon sequestration as 

discussed in Environmental Consequences section. The net contribution to atmospheric CO2 is lower 

given longer time scales due to regeneration, particularly if wood products include ‘storage’ products, if 

Final EIS I-133 DEIS Comments and Responses
Appendix I

biomass substitutes for local fossil fuel use, and if market substitution (also called market leakage)is 

relatively high (e.g. Jonsson et al. 20128).

COMMENT

CARB-022 and CARB-23: The climate change analysis in the DEIS is insufficient and lacks usage 

of the most recent science specific to southeast Alaska. Furthermore, in addition to the Secretary 

of Agriculture’s direction on the purpose and need for the Forest Plan Amendment, that purpose 

and need should also include changes in forest management and health as a consequence of a 

changing climate. Additional references, including EPA data 

(www3.epa.gov/climatechange/impacts/alaska.html) and the 2014 National Climate Assessment 

(http://nca2014.globalchange.gov/report/regions/alaska#intro-section) should be used in the FEIS 

as well as include a quantification of GHG emissions from the proposed action and “appropriate” 

quantitative or qualitative analytical methods. 

RESPONSE

See CARB-23 response for specific address of quantification of GHGs.

COMMENT

CARB-23: Disclosure of the magnitude of carbon emissions, carbon storage, and ultimately 

carbon sequestration should be presented more clearly in light of the literature and that the 

disclosure should also more clearly present the importance of carbon stores on the Tongass 

National Forest. The analysis in the DEIS downplays the emissions of carbon that result from 

timber harvest. A carbon life-cycle analysis should be presented to illustrate the outcome of the 

alternatives. An evaluation of the social cost of carbon emissions based on Executive Order 

12866 and using the Interagency Working Group guidelines on carbon costing should be 

conducted.

THE DEIS had several shortcomings in disclosure of the relationship between ongoing climate 

change and the resilience of the temperate coastal rainforest and the potential role of the Tongass 

as a climate refuge for biodiversity associated with coastal rainforests. In particular, the analysis 

did not sufficiently examine the potential impact of harvesting old-growth (and young-growth 

forest in old-growth reserves) or harvest of beach buffers on the resilience of the forest in 

response to changing climate. The DEIS did not reference a communication On January 2015, 

from the Federal Forest Carbon Coalition to Secretary Vilsack, Beth Pendleton, and Forrest Cole 

asking that management of the Tongass National Forest align with the Administrations climate 

direction.

RESPONSE- A. Forest Carbon 

We appreciate input suggesting a more clear disclosure of carbon emissions, storage and ultimately 

carbon sequestration on the Tongass National Forest. The FEIS more clearly illustrates the role of the 

Tongass National Forest in carbon sequestration and discloses the relative differences among 

alternatives in carbon storage and sequestration at multiple temporal scales. 

A quantitative carbon life-cycle analysis has not been conducted and is not included in the analysis. CEQ 

recommends that agencies determine the appropriate level of action for NEPA review at which to more 

rigorously evaluate the effects of GHG emissions and climate change – whether broad programmatic, 

landscape scale, or at a project/site specific levels of NEPA (79 FR 77824 Dec. 24, 2014). CEQ further 

indicates that agencies continue to have substantial discretion in how they tailor their NEPA process (79 

FR 77824 Dec. 24, 2014) and that agencies should apply the philosophy of ‘proportionality’ and ‘rule of 

reason’ to determine the extent to which a particular analysis or approach to evaluation is useful to the 

8 Jonsson, R., W. Mbongo, A. Felton, and M. Boman. 2012. Leakage implications for European timber markets from reducing 

deforestation in developing countries. Forests 3:736-744.

DEIS Comments and Responses I-134 Final EIS

 
Appendix I

public and to the decision-making process for distinguishing between alternatives (79 FR 77824 Dec. 24, 

2014). 

We determined that a qualitative analysis comparing the relative contribution of alternatives to carbon 

emissions or storage was most appropriate for understanding tradeoffs. Therefore we do not present a 

quantitative carbon life-cycle analysis. We contend that project-level analysis is the appropriate stage of 

planning for a more rigorous evaluation of carbon in this case because of the substantial reduction in 

uncertainty at the project-level regarding the estimates for parameters of a carbon life-cycle analysis (e.g. 

sources and extent of emissions during harvest, environmental conditions related to carbon loss and 

carbon capture during forest regeneration, and potential use of the wood). Furthermore, the narrow 

scope of this action as an amendment to the Forest Plan precluded the option to explore action 

alternatives specifically designed to promote carbon sequestration. Thus, the principles of proportionality 

and the ‘rule of reason’ suggest that a quantitative carbon life-cycle analysis, particularly an analysis with 

high uncertainty, would not contribute toward evaluation and decision making. It is important to 

emphasize the high uncertainty in estimates of short- medium- and long-term carbon emissions, storage,

and sequestration (or in a carbon life-cycle analysis) for any alternative (explained further below). Given 

the high uncertainty in the carbon life-cycle analysis compared to the relatively small differences among 

alternatives in carbon sequestration (particularly in the medium- and long-term), the results of the analysis 

would not inform the decision.

The high uncertainty in a carbon life-cycle analysis associated with this amendment results from the 

substantial range of potential values for most of the parameters in the carbon life-cycle analysis and 

therefore the array of final results. Adequate quantitative analysis must present the many estimates of 

carbon associated with the different parameter estimates resulting from different assumptions related to 

uncertainty. For example, following timber harvest a substantial quantity of organic material remains on 

site and decomposes over time. The decomposition rates and extent of decomposition depend on a 

broad array of factors and therefore different carbon life-cycle estimates result from differing assumptions 

regarding decomposition. A recent study identifies the lack of consensus in the science community on 

the temperature sensitivity of soil carbon decomposition to changes in regional temperature (Davidson 

and Janssens 2006). Many factors, including the relative mix of soil organic matter along a continuum of 

decomposability, and an array of environmental constraints (abiotic and biotic conditions) obscure the 

rate of soil organic decomposition (Davidson and Janssens 2006). This suggests that a clear evaluation 

of the rate and extent of soil carbon decomposition on the Tongass has high uncertainty and a variety of 

estimates are reasonable. A qualitative evaluation, however, leads to conclusions that substantially 

reduce uncertainty – soil carbon decomposition will increase with increasing temperature (expected with 

climate change) (D’Amore, pers. comm. 2016), and those amendment alternatives which harvest more 

extensive areas will have higher rates of carbon emissions in the short- and medium-term. 

High uncertainty confounding quantitative analysis also occurs because of the range of reasonable 

estimates for other features (in addition to soil carbon). Uncertainty in rates of forest regrowth after oldgrowth and young-growth harvest on the Tongass, amounts of wood material remaining following harvest, 

transportation methods and distances for logs and wood products, use of the wood, market dynamics 

related to substitution (sometimes called market leakage – e.g. Jonsson et al. 2012)), and product 

substitution all confound a quantitative carbon life-cycle analysis (see McKinley et al 2011 for a broad 

overview of the complexity of carbon life-cycle analysis). A quantitative analysis would be both 

misleading in its rigor and perceived precision (if the substantial uncertainties where not taken into 

account) or confusing (if the range of uncertainty in important parameters was taken into account and the 

full range of resulting estimates displayed).

We have not provided a rigorous evaluation of the differences among alternatives in the social costs that 

may result from carbon emissions and resulting short- medium- or long-term contributions to GHGs. 

Given the high uncertainty in carbon emissions, and particularly the relatively small differences among 

alternatives in carbon emissions, an evaluation of social costs would be highly speculative and contrary to 

CEQ guidance (79 FR 77817 Dec. 24, 2014)

Although an estimate of carbon emissions can be calculated (as illustrated by one commenter), the 

uncertainty in any estimate must be disclosed and the relative merit in considering that estimate 

Final EIS I-135 DEIS Comments and Responses
Appendix I

evaluated based on the degree of uncertainty. As described earlier, evaluation of carbon emissions, 

particularly over the mid- and long-term, is highly uncertain and that uncertainty far exceeds the potential 

differences among alternatives in carbon storage.

RESPONSE - B. Climate Change 

We appreciate the input regarding the reduced probability of fire, the role of the temperate coastal 

rainforest potentially serving as a climate refugia and the resilience of the temperate coastal rainforest. 

The revised EIS includes these concepts. We carefully considered the input from the letter from the 

Federal Forest Coalition on January 2015, and concluded that the resilience of the temperate coastal 

rainforest in SE Alaska is maintained through the system of reserves and other non-development LUDs 

and therefore the broad region of SE Alaska will continue to serve a strong role as a climate change 

refugia. Under all of the amendment alternatives The Tongass National Forest will continue to maintain 

large intact areas, larger than those evaluated under the 1997 plan, and therefore, as outlined in the EIS, 

will continue to play a strong role in supporting biodiversity as a climate refugia and a region with resilient 

forests.

Regarding the contention that the preferred alternative, or any alternative, does not align with Executive 

Branch guidance because management will not conserve carbon sinks by protecting them in perpetuity. 

CEQ guidance (79 FR Dec. 24, 2014) and Executive Order 13653 do not require such. 

COMMENT

CARB-24 and CARB-7: The agency should adopt the conservation alternative (e.g. no harvest 

alternative), provided by the Conservation Consortium, to comport with CEQ guidelines, the Paris 

climate agreement, and efforts to reduce climate damages from CO2 pollution. The FEIS should 

also include a cost-benefit analysis of avoiding damages to the environment cause by climate 

change “so as to level the economic playing field” in compliance with Executive Order 12866. 

RESPONSE

In response to comments regarding the importance of the Tongass Rainforest as Alaska’s first line of 

climate change defense and the importance to the Paris Climate change agreement, we revised the FEIS 

to clarify the role the Tongass plays in global carbon sequestration. The analysis acknowledges the 

substantial role the Tongass plays in carbon storage and the role it will continue to play under each of the 

alternatives. The analysis qualitatively discloses that carbon storage on the Tongass will remain 

substantial under each alternative (while disclosing the relatively small differences among alternatives). 

Further, there is no present legal mandate to stop or limit timber sales based on the Paris Climate 

Change Agreement. Refer to CARB-23 for a more robust explanation of the global role of the temperate 

rainforest in carbon sequestration and the subsequent analysis we conducted. Additional discussion 

regarding the role of the Tongass in global carbon sequestration has been added to the text in Chapter 3 

of the Final EIS.

Based on the scope of this amendment outlined in the ‘Notice of Intent To Prepare An Environmental 

Impact Statement’ published on 27 May, 2014, the purpose of the amendment is to: “accomplish the 

transition to young growth management over the next 10 to 15 years while retaining the expertise and 

infrastructure of a viable timber industry in Southeast Alaska, as outlined by the Secretary in 

Memorandum 1044–009.” Commenters suggest that only a no-logging scenario maintains carbon stores 

through time and while that may be true, an alternative designed to meet this scenario is outside the 

scope of the EIS. As an amendment, rather than revision, the scope of options being considered does 

not include the potential for no timber harvest and therefore the consequences of such an alternative are 

not considered.

The global contribution of carbon storage that the Tongass provides is acknowledged in the Secretary of 

Agricultures memo to the US Forest Service in providing the scope and need for action to this Plan 

amendment. The Secretary’s memo makes clear that the Department of Agriculture is committed to not 

only maintaining southeast Alaska’s exceptional natural resources in perpetuity but is equally committed 

to doing its part to ensure that communities within and adjacent to the Tongass National Forest are 

economically vibrant. The proposed action for the Amendment is intended to bring these two goals hand 

DEIS Comments and Responses I-136 Final EIS
Appendix I

in hand. To do so, there will be costs and in the case of carbon storage we acknowledge that in order to 

bring to fruition the multiple-use objectives of this plan as well as the overall mission of the Forest Service, 

the Tongass will incur a short- and mid-term net loss of total carbon storage through GHG emissions as a 

result of timber harvest on the Tongass. 

Regarding CEQ guidelines, the Paris climate agreement, and efforts to reduce climate damages from 

CO2 pollution, the agency (USDA) has not yet provided final guidance or policy directed at their 

implementation. Therefore, there is no present legal mandate to stop or limit timber sales based on the 

Paris Climate Change Agreements, nor to follow proposed draft CEQ guidance regarding NEPA. To 

date, guidance from the agency includes an analysis of climate for project NEPA (2009) and for Plan 

Revisions (2010). The CEQ cited by commenters is currently in DRAFT form and has therefore not been 

fully vetted as established policy. While the Revised DRAFT CEQ directs agencies to adopt projects with 

low emission using a reference point of 25,000 metric tons of CO2 (e) on an annual basis, the CEQ 

further indicates that agencies continue to have substantial discretion in how they tailor their NEPA 

process (79 FR 77824 Dec. 24, 2014) and that agencies should apply the philosophy of ‘proportionality’ 

and ‘rule of reason’ to determine the extent to which a particular analysis or approach to evaluation is 

useful to the public and to the decision-making process for distinguishing between alternatives (79 FR 

77824 Dec. 24, 2014). For this EIS, a quantitative carbon life-cycle analysis has not been conducted and 

is not included in the analysis. CEQ recommends that agencies determine the appropriate level of action 

for NEPA review at which to more rigorously evaluate the effects of GHG emissions and climate change –

whether broad programmatic, landscape scale, or at a project/site specific levels of NEPA (79 FR 77824 

Dec. 24, 2014). 

We determined that a qualitative analysis comparing the relative contribution of alternatives to carbon 

emissions or storage was most appropriate for understanding tradeoffs. Therefore we do not present a 

quantitative carbon life-cycle analysis as proposed in the revised DRAFT CEQ. We contend that projectlevel analysis is the appropriate stage of planning for a more rigorous evaluation of carbon in this case 

because of the substantial reduction in uncertainty at the project-level regarding the estimates for 

parameters of a carbon life-cycle analysis (e.g. sources and extent of emissions during harvest, 

environmental conditions related to carbon loss and carbon capture during forest regeneration, and 

potential use of the wood). Furthermore, the narrow scope of this action as an amendment to the Forest 

Plan precluded the option to explore action alternatives specifically designed to promote carbon 

sequestration. Thus, the principles of proportionality and the ‘rule of reason’ suggest that a quantitative 

carbon life-cycle analysis, particularly an analysis with high uncertainty, would not contribute toward 

evaluation and decision making. It is important to emphasize the high uncertainty in estimates of shortmedium- and long-term carbon emissions, storage, and sequestration (or in a carbon life-cycle analysis) 

for any alternative (explained further below). Given the high uncertainty in the carbon life-cycle analysis 

compared to the relatively small differences among alternatives in carbon sequestration (particularly in 

the medium- and long-term), the results of the analysis would not inform the decision.

As well, the commenter suggests that the agencies’ preferred alternative is generally inconsistent with the 

COP climate agreements (Article 4 on greenhouse sinks) to conserve forests as a sink for atmospheric 

carbon and is well above the CEQ emissions reference. However, the Revised DRAFT CEQ does not 

establish regulatory requirements or compel agencies to prohibit or curtail GHG emissions. In 

conformance with NEPA’s basic principles, it does not mandate particular results or insist that agencies 

select the alternative with the least GHG emissions and climate change effects. 

The commenter also suggests that “in any cost-benefit analysis, it is imperative to incorporate the benefits 

(or cost savings) of avoiding damages to the environment, or, in this case, the climate, so as to level the 

economic playing field (although many ecosystem services critical to properly functioning forests are 

difficult to quantify)”. We have not provided a rigorous evaluation of the differences among alternatives in 

the social costs that may result from carbon emissions and resulting short- medium- or long-term 

contributions to GHGs. Given the high uncertainty in carbon emissions, and particularly the relatively 

small differences among alternatives in carbon emissions, an evaluation of social costs would be highly 

speculative and contrary to CEQ guidance (79 FR 77817 Dec. 24, 2014) 

Final EIS I-137 DEIS Comments and Responses
Appendix I

COMMENT

CARB-25: Forest Service should provide specific forest-wide goals, objectives and desired 

conditions for the Tongass National Forest in meeting challenges of climate change.

RESPONSE

Climate change is addressed in the Forest Plan in a number of ways. In the Implementation chapter, for 

example, “Our role in addressing climate change” is listed as one of five Tongass-wide high priority 

actions developed each year to guide project implementation. More importantly, climate change is 

incorporated extensively throughout the new Tongass National Forest Monitoring Program, released in 

May 2016.

DEIS Comments and Responses I-138 Final EIS
Appendix I

Ecosystem Services (ECOS)

COMMENT

ECOS-1: Forest Service should define performance metrics for salmon production and the 

economic contribution that salmon produced by the Tongass. Additionally provide the amount of 

renewable energy supplied by the Tongass. Both of these should be measured as part of the 

Ecosystem Services that the Tongass provides. 

RESPONSE

This request is beyond the scope of this Forest Plan Amendment. It is noted that a national effort is 

underway to define a new and improved suite of performance metrics. 

Final EIS I-139 DEIS Comments and Responses
Appendix I

Economics of the Timber Industry (ECON)

COMMENT

ECON-1: The EIS discussion of small log manufacturing should be updated to explain that the 

manufacturing of young growth spruce and hemlock trees will not be financially feasible until the 

trees are at least 90 years old or until there are sufficient acres of 60-year old and older trees 

available to enable the amortization of a modern small log sawmill. The proposed alternatives 

would provide less than 10 percent of the volume necessary to supply a single local small log mill 

and the trees are too small to be profitably sawn in the existing sawmills. Most of the logs cut 

from these trees will be exported in unprocessed form and will not support local manufacturing 

jobs. The Forest Service should continue with the current Forest Plan and allow the young 

growth stands to grow for another 30 years at which time the trees will be larger and more 

valuable, and the volume will have doubled.

RESPONSE

Table 3.13-4 in the Timber section of the FEIS displays the acres of harvested even-aged young-growth 

forest by age class and LUD group. This section of the FEIS also describes young growth management 

on the Tongass and provides an overview of the direction provided in the Secretary of Agriculture’s 

Memorandum 1044-009. Among other things, the Secretary directs the Forest Service to “(s)eek 

opportunities to supply sufficient old-growth “bridge timber” while the industry re-tools for processing 

young growth”. All of the alternatives evaluated in the Draft EIS include old-growth “bridge timber” and 

provide for a PTSQ that is a mix of old-growth and young-growth timber in the short-run, with old growth 

decreasing as a share of this total volume (46 MMBF) over time as more young growth becomes 

economic to harvest. 

The results of the financial analysis prepared for the FEIS indicated that, viewed over 25-year and 100-

year planning horizons, all five alternatives resulted in positive net revenues (Table 3.22-16, p. 3-482). 

Positive values for the 5-year increments that comprise years 1 to 25 were in most cases due to the oldgrowth component of projected harvest, which generated net positive revenue for all alternatives and 5-

year increments over the 25-year planning horizon. In contrast, in most cases net revenues generated by 

the young-growth component were negative (Figure 3.22-18, p. 3-483). 

As discussed in the FEIS, this programmatic analysis suggests that individual timber sales offered under 

any of the alternatives in the first 25 years of the planning period will likely need to include a mix of old 

growth and young growth to appraise positive as required by Public Law 112-74, House Report 2055-257, 

Section 414. However, over time, the young-growth component also generates positive revenues under 

all alternatives, which is reflected in the discounted net revenues presented for the 100 year planning 

horizon in Table 3.22-16. 

The financial analysis has been revised in the FEIS to more clearly explain what is included in this 

analysis. The estimates presented in the FEIS have also been updated in the FEIS. More detailed 

discussion of the modeling approach and the assumptions and values used to develop these estimates is 

provided in FEIS Appendix B Modeling and Analysis, which has also been updated. The results of the 

Woodstock modeling are used for the purposes of analysis in the FEIS and represent the best information 

available at this time. The timber demand study (Daniels et al. 2016) used to estimate the PTSQ of 46 

MMBF are long-term projections that represent estimated demand for the planning cycle, also used in the 

FEIS for the purposes of analysis. The Forest Service will continue to evaluate annual market demand 

using the Morse methodology and may adjust the mix of old-growth and young-growth timber made 

available for sale on a year-to-year basis, as needed to meet demand and the Secretary’s direction to 

speed the transition toward a young-growth timber industry.

The suggestion in the comment that the Forest Service continue to manage the Tongass under the 2008 

Forest Plan and offer primarily old-growth timber sales for the next 30 years, while allowing young-growth 

stands to increase in age and size, does not meet the purpose and need of the proposed Forest Plan 

amendment.

DEIS Comments and Responses I-140 Final EIS
Appendix I

COMMENT

ECON-2: Young growth timber is typically used for low value construction lumber. In order to 

compensate for the low value, new small log mills tend to rely on high volume processing and 

proximity to both their timber supply and markets. A young growth facility in Southeast Alaska 

would be at a competitive advantage due to the relative high cost and uncertainty of the timber 

supply and distance to markets. Viking Lumber has indicated they could process up to 8 to 10 

MMBF of small logs over a period of several years, provided they are able to maintain full 

operations of their old-growth saw mill.

RESPONSE

As discussed in response to ECON-1, all of the alternatives evaluated in the Draft EIS include old-growth 

“bridge timber” and provide for a PTSQ that is a mix of old-growth and young-growth timber in the shortrun, with old growth decreasing as a share of this total volume (46 MMBF) over time as more young 

growth becomes economic to harvest. As indicated in the comment and discussed in the FEIS, Viking 

Lumber’s current small log line processes approximately 8 MMBF of logs annually, running one shift per 

day, 40 hours per week. 

The exact transition trajectory cannot be predicted. Our EIS predictions are best on the best information 

we have available. If it turns out that young growth does not sell as fast as expected due to markets and 

economics, then a greater proportion of old growth could temporarily be included in the sale to make up 

for the deficit. While this continues, existing young-growth stands will be growing and the shelf volume for 

young growth will continue to grow.

COMMENT

ECON-3: The Daniels et al. (2016) study assumes that “existing mills will make any machinery 

upgrades necessary for the young growth transition, but rates of utilization may fluctuate”. This 

is a poor assumption. The projected supply of young-growth timber is too small to support the 

investment necessary to construct a small log sawmill, which will cost more than $100 million. 

Small log mills in Arkansas, Florida, and another proposed for Washington State have respective 

annual capacities of 387 MMBF, 700 MMBF, and 200 MMBF. 

RESPONSE

The assumption cited in the comment from Daniels et al. pertains to their Scenario 1, which is 

summarized in the Draft EIS (starting on p. 3-458) and discussed in detail in Daniels et al. (2016). 

Despite this assumption Daniels et al.’s Scenario 1 projects that timber demand would decrease relative 

to the baseline projections following the young-growth transition in 2025, as the transition would in effect 

result in a reduction in Pacific Rim demand for lumber processed in Southeast Alaska. 

The annual capacities of the small log mills cited in the comment are larger than those identified in the 

Draft EIS. The Beck Group (2009), for example, identified sawmills in the coastal regions of Oregon and 

Washington that currently process western hemlock for framing lumber production, using comparable 

equipment configurations as Viking Lumber to process logs of comparable size and quality. They found 

that these generally comparable sawmills processed on average 23 MMBF of logs per year, based on 

operating a single shift per day (Beck Group 2009). Another example of the type of facility that could be 

developed to process young-growth timber in Southeast Alaska, the Vaagen Brothers mill in Colville in 

eastern Washington, produced a total of 273 MMBF of lumber in 2014, of which 135 to 140 MMBF was 

also sawn at the Colville mill.

COMMENT

ECON-4: The timber industry in Southeast Alaska has lost its economy of scale and much of the 

related infrastructure required to support a competitive industry. In the face of this decline, the 

remaining mills have been able to remain competitive by selling high value products that cannot 

be produced from young-growth timber.

Final EIS I-141 DEIS Comments and Responses
Appendix I

RESPONSE

As discussed in response to ECON-1, all of the alternatives evaluated in the Draft EIS include old-growth 

“bridge timber” and provide for a PTSQ that is a mix of old-growth and young-growth timber in the shortrun, with old growth decreasing as a share of this total volume (46 MMBF) over time as more young 

growth becomes economic to harvest. Old-growth volume would continue to decrease until it reaches 5 

MMBF per year, at which point it would be stabilized at 5 MMBF per year to support a small sale and 

micro sale industry, and would remain at that level for the remainder of the planning period. 

COMMENT

ECON-5: As currently scheduled, the Forest Plan will be amended before the Forest Service has 

completed the necessary studies to confirm the volume of young-growth timber available for 

harvest, the cost of harvesting young growth stands that are small and widely scattered, or 

confirm that it will be financially viable for a young-growth industry to develop and find markets 

for its products based on that volume. In the absence of this and other information that proves 

that a transition to young-growth can happen sooner than the industry’s expectation of 30 years, 

it is inappropriate for the plan amendment to be proposed.

RESPONSE

As discussed in response to ECON-1, all of the alternatives evaluated in the FEIS include old-growth 

“bridge timber” and provide for a PTSQ that is a mix of old-growth and young-growth timber in the shortrun, with old growth decreasing as a share of this total volume (46 MMBF) over time as more young 

growth becomes economic to harvest. 

The Woodstock modeling analysis conducted in support of the Forest Plan amendment indicated that 

initially, older young growth stands can be harvested economically when combined with old-growth. The 

Woodstock model tracks the growth of young-growth stands over time and does not select stands for 

harvest until it is economical. This analysis is discussed in detail in the revised Appendix B to the FEIS. 

In general, the results of the financial analysis prepared for the FEIS indicated that, in most cases, net 

revenues generated by the young-growth component in 5-year increments for the first 25 years following 

implementation would be negative. However, over time, the young-growth sale component would also be 

expected to generate positive revenues. The Forest Service will continue to evaluate annual market 

demand using the Morse methodology and may adjust the mix of old-growth and young-growth timber 

made available for sale on a year-to-year basis, as needed to meet demand and the Secretary’s direction 

to speed the transition toward a young-growth timber industry.

Our analysis indicates that initially, older young growth stands can be harvested economically when 

combined with old-growth. The Woodstock model used tracked the age and growth of young-growth 

stands and did not select stands for harvest until they reached 65 to 75 years of age, depending on site 

class. These ages were based on discussions with industry who confirmed that minimum age required 

that two logs per tree could be obtained from the majority of trees in a stand and an evaluation of stand 

tables to determine what ages this occurred. 

See response P&N-4 (Young growth Inventory)

COMMENT

ECON-6: Appendix B of the Draft EIS implies that new class/site index data was estimated and 

used to model wood availability, but no new field surveys were conducted to verify the accuracy 

of this site index information. Until these site index data are verified, it is impossible for the 

Forest Service and others to have faith in the accuracy of the estimates presented in the Draft EIS. 

The Forest Service, acting on the TAC recommendations, proposed in July 2015 to fund up to $4 

million of studies to update the inventory of young-growth by location and to develop better data 

on the growth rates of young-growth trees. This study is unlikely to be completed prior to 

finalization of the new Forest Plan and is unlikely to produce the quality data necessary to 

forecast the forest-wide availability of young-growth timber. 

DEIS Comments and Responses I-142 Final EIS
Appendix I

RESPONSE

The Challenge Cost-Share agreement between the State of Alaska and the US Forest Service, which 

began in 2016, will inventory approximately 50,000 acres of young-growth timber to provide knowledge 

about the conditions and feasibility of the older young-growth timber stands. This inventory will also note

logging systems needed to access these stands. This agreement has been already been funded. The 

transition timeline for the action alternatives proposed in the amendment is designed to accelerate this 

data collection on young-growth harvest by providing more opportunities to harvest the older young 

growth sooner than the 2008 Forest Plan direction allows. The Forest Service will continue to evaluate 

annual market demand using the Morse methodology and may adjust the mix of old-growth and younggrowth timber made available for sale on a year-to-year basis, as needed to meet demand and the 

Secretary’s direction to speed the transition toward a young-growth timber industry.

COMMENT

ECON-7: The financial analysis presented in the Draft EIS significantly overstates the likely value 

of the proposed timber volume to a purchaser. The Forest Service has only been able to achieve 

similar returns on about one-quarter of the old-growth timber sale volume planned each year, with 

three-quarters of planned timber sale volume never offered because it was not economic to 

harvest under the 2008 Forest Plan. The Draft EIS analysis anticipates a fourfold increase in 

returns, even though the Forest Service proposes to sell increasing volumes of lower value, 

young-growth timber. 

RESPONSE

The financial analysis in the Draft EIS has been revised to more clearly explain what is included in this 

analysis. The estimates presented in the Draft EIS have also been updated. More detailed discussion of 

the modeling approach and the assumptions and values used to develop these estimates is provided in 

Appendix B to the EIS, which has also been updated.

The numbers reported in the financial analysis are derived from the Woodstock modeling conducted in 

support of the proposed Forest Plan amendment. As discussed in the Draft EIS (p. 3-481):

Positive values for the 5-year increments that comprise years 1 to 25 are in most cases due to 

the old-growth component of projected harvest. The old-growth component generates net positive 

revenue for all alternatives and 5-year increments over the 25-year planning horizon (Figure 3.22-

17). In contrast, in most cases net revenues generated by the young-growth component are 

negative (Figure 3.22-18). 

This programmatic analysis suggests that individual timber sales offered under any of the 

alternatives in the first 25 years of the planning period will likely need to include a mix of old 

growth and young growth to appraise positive as required by Public Law 112-74, House Report 

2055-257, Section 414.

COMMENT

ECON-8: The financial analysis presented in the Draft EIS indicates that all plan alternatives have 

a positive net present value. In the absence of information on the cost of young-growth harvest 

and the potential products that will be manufactured from young-growth timber and associated 

costs and profits, it is impossible to accept that these estimates, which are based on conditions in 

the Lower 48 states, are potentially accurate. These estimates also fail to account for reductions 

in the value of productive old-growth when sale areas decrease in size and production costs rise.

RESPONSE

The costs and revenues associated with the young growth harvesting and manufacture were developed 

by a private consultant based on young growth in as similar as possible conditions in the Lower 48 states 

and adjusted for Southeast Alaska conditions. The Alaska region cost collection process will, over time, 

provide more refined costs and revenues to be used in the appraisal process. The Forest Service will 

Final EIS I-143 DEIS Comments and Responses
Appendix I

continue to evaluate annual market demand using the Morse methodology and may adjust the mix of oldgrowth and young-growth timber made available for sale on a year-to-year basis, as needed to meet 

demand and the Secretary’s direction to speed the transition toward a young-growth timber industry.

COMMENT

ECON-9: The Draft EIS cites the Nature Conservancy’s 2009 Beck report but fails to report that the 

Beck Group found that a small log manufacturing operation would be uneconomic unless the 

Forest Service subsidized the associated logging costs. In addition, the Alaska Forest 

Association reportedly identified several errors in the Beck Group analysis, which resulted in the 

costs to establish and operate a small log mill being significantly understated.

RESPONSE

The Draft EIS cites the referenced study prepared for the Nature Conservancy by the Beck Group (2009) 

in a number of ways, including the Beck Group’s evaluation of the small log line at the Viking saw mill and 

their general characterization of the other mills currently operating on Prince of Wales Island. The Draft 

EIS also cites the Beck Group’s (2009) finding that sawmills in the coastal regions of Oregon and 

Washington that currently process western hemlock for framing lumber production, using comparable 

equipment configurations as Viking Lumber, processed on average 23 MMBF of logs per year, based on 

operating a single shift per day. The Draft EIS does not use the findings of the Beck Group report to 

illustrate or support the economic feasibility of a young growth mill.

COMMENT

ECON-10: Processing logs and producing finished products represents a substantial component 

of a logs value. How will continued large-scale log export support the development of a 

sustainable and vibrant pool of small-scale, local wood processors?

RESPONSE

The purpose and need for the Forest Plan amendment responds to the July 2, 2013 memorandum from 

USDA Secretary Tom Vilsack which specifically directs the US Forest Service to expedite the transition 

from old-growth to young-growth timber harvest while maintaining a viable timber industry that provides 

jobs and opportunities for Southeast Alaska residents. Among other things, the Secretary directs the 

Forest Service to “(s)eek opportunities to supply sufficient old-growth “bridge timber” while the industry retools for processing young growth” (Draft EIS, p. 3-297). All of the alternatives evaluated in the Draft EIS 

include old-growth “bridge timber” and provide for a PTSQ that is a mix of old-growth and young-growth 

timber in the short-run, with old growth decreasing as a share of this total volume (46 MMBF) over time as 

more young growth becomes economic to harvest. 

The limited timber export policy and the young-growth transition are discussed in response to TEXP-3. 

As indicated in this response, the Forest Plan amendment is designed to analyze the feasibility of shifting 

from an old-growth forest management regime towards young growth management. How rapidly and 

effectively this is accomplished depends on local support from Alaska markets for young-growth forest 

products. The ability to export some timber beyond Alaska may serve as a strategic option that can be 

used to help maintain workforce skills, industry expertise, and the physical infrastructure needed to 

develop a future young-growth industry. The limited shipment policy will continue to be subject to review 

and modification on an annual basis, as noted above.

DEIS Comments and Responses I-144 Final EIS
Appendix I

Public Costs (PUBC)

COMMENT

PUBC-1: The Draft EIS does not present the estimated costs and revenues to the U.S. Treasury 

associated with the proposed alternatives. Instead the Draft EIS presents estimated values to the 

purchaser (selling value minus costs for logging, transportation, manufacturing, profit, and risk), 

which are misleadingly identified as net revenues. The Final EIS must present actual past and 

expected future costs and revenues to the U.S. Treasury for the Tongass timber program.

RESPONSE

The financial analysis section in the Draft EIS has been revised to more clearly explain what is included in 

the analysis, with additional information provided in Appendix B Modeling and Analysis, which has also 

been revised. In addition, the revised financial analysis includes estimated Forest Service administrative 

costs per MBF and provides an estimate of net agency revenues (timber sale revenues minus timber 

variable costs). 

Evaluating the past and expected future costs and revenues associated with the overall Tongass timber 

sale program is outside the scope of this Forest Plan amendment. Information on Tongass program 

administrative costs and revenues is, however, readily available to the public in the annual State of the 

Tongass National Forest report prepared by the Forest Service. The most recent version available online 

is for Fiscal Year (FY) 2013 (USDA Forest 2014). More recent information is available upon request. 

COMMENT

PUBC-2: The net revenues presented in the Draft EIS represent the estimated values to the 

purchaser (selling value minus costs for logging, transportation, manufacturing, profit, and risk), 

and should, therefore, reflect the prices purchasers should be paying for Tongass timber. Data 

from the Draft EIS analysis indicates that the Forest Service is estimating pond log values of $351 

per thousand board feet (MBF), which substantially exceeds the actual 5-year average from 2011 

to 2015 of $57 per MBF. Neither the Draft EIS nor the planning record provide the assumptions 

used to develop these estimates, displaying only the final model outcomes. The Final EIS needs 

to more fully explain these estimates.

RESPONSE

As noted in response to PUBC-1, the financial analysis in the Draft EIS has been revised to more clearly 

explain what is included in this analysis. The estimates presented in the Draft EIS have also been 

updated. More detailed discussion of the modeling approach and the assumptions and values used to 

develop these estimates is provided in Appendix B Modeling and Analysis to the EIS, which has also 

been updated.

COMMENT

PUBC-3: The Draft EIS improperly excluded a detailed public investment analysis that disclosed 

the full cost of the Tongass timber program, including logging road costs, agency timber program 

administrative costs, the costs of timber program-related restoration projects, and NEPA costs. 

The Draft EIS also failed to estimate the costs, monetary and otherwise, on other forest values and 

users, including carbon storage, recreation and tourism, fisheries, and ecosystem services. 

NEPA requires that the agency provide at least a broad, informal cost benefit analysis of the 

proposed action, and CEQ regulations require that this analysis include discussion of the 

relationship between the analysis and any analysis of unquantified environmental impacts, values 

and amenities.

RESPONSE

As noted in response to PUBC-1, a detailed public investment analysis of the Tongass timber program is 

outside the scope of this Forest Plan amendment. Information on Tongass program administrative costs 

Final EIS I-145 DEIS Comments and Responses
Appendix I

and revenues is, however, readily available in the annual State of the Tongass National Forest report 

prepared by the Forest Service. In addition, the financial analysis section in the Draft EIS has been 

revised to include an estimate of net agency revenues (timber sale revenues minus timber variable costs) 

by alternative.

The Draft and Final EIS documents were prepared under the 2012 planning rule, which “does not include 

requirements to demonstrate that plans will maximize net public benefits or require valuation of economic 

efficiency or require present net value analysis as the 1982 rule did” (Federal Register [FR], Vol. 77, No. 

68, 21187). The preamble to the Final 2012 planning rule and record of decision (FR, Vol. 77, No. 68, 

21188), further notes that the: 

“Forest Service Handbook (FSH 1909.15.section 22.32) as well as NEPA regulations (40 CFR 

1502.23) state that for purposes of complying with the [NEPA], the weighing of the merits and 

drawbacks of the various alternatives need not be displayed in a monetary cost-benefit analysis 

and should not be when there are important qualitative considerations.”

The handbook and NEPA regulations do, however, state that an EIS should indicate those considerations 

that are likely to be relevant and important to a decision, which may “include a variety of quantified or 

qualitative descriptions of costs and benefits that are linked to significant issue determinations for a 

particular forest plan” (FR, Vol. 77, No. 68, 21188). The Draft and Final EIS documents provide a 

detailed and extensive assessment of the effects of the alternatives on non-timber forest values and user 

groups. As discussed in the Draft EIS with respect to ecosystem services (p. 3-487): 

The effects of the alternatives on these types of services including the sections of the EIS that 

address watersheds, fisheries, soils, wildlife and subsistence use, heritage resources, and timber 

and vegetation, among others. Monetary values are not assigned to these services, but this does 

not lessen their importance in the decision making process.

In addition, as referenced in the Draft EIS (p. 3-487), ecosystem services are discussed at the forest 

planning level for the Tongass National Forest in the 2008 Forest Plan EIS (USDA Forest Service 2008b, 

p. 3-544 to 3-556).

COMMENT

PUBC-4: The Forest Plan amendment goes to great lengths to support about 200 timber jobs 

rather than allocating the associated funds to the fishing and tourism industries that support 

thousands of jobs. The Forest Service should take a “hard look” at this allocation and recognize 

the monetary and societal value of other forest uses, as well as seek ways to improve protections 

for fish and wildlife habitat and enhance visitor services. 

RESPONSE

The management alternatives presented in the EIS are all designed to support sustainable levels of 

tourism and fishing. The Economic and Social Environment analysis presented in the EIS discusses the 

monetary and societal value of other forest uses at some length, including recreation and tourism, 

commercial fishing, mining, and the economic value of natural amenities and quality of life. The 

Economic and Social Environment section also addresses the potential impacts to these resources, as 

well as other non-value uses including passive use values and ecosystem services. 

Under the current Forest Plan, Forest Service programs currently emphasize protection for fish and 

wildlife habitat and seek ways to enhance visitor services. These protections will remain in place in the 

proposed Forest Plan amendment, and the Forest Service will continue to work with other regional groups 

to develop visitor services, as appropriate. 

Many factors affect the availability of public sector funds for multiple program areas. Consideration of 

funding strategies and resource allocation is outside the scope of this forest plan amendment and EIS. 

DEIS Comments and Responses I-146 Final EIS
Appendix I

Socioeconomics (SOC)

COMMENT

SOC-1: The Draft EIS acknowledges that the Tongass timber sale program causes significant 

adverse effects to the environment, but makes no attempt to evaluate the economic costs of these 

impacts, and disregards the extensive literature that discloses the economic value of non-timber 

forest uses, including hunting and wildlife viewing. 

RESPONSE

The Draft EIS discusses the contribution of the timber and other natural resource-based industries to the 

regional economy in the Economic and Social Environment section. In addition to timber, this section 

provides a detailed discussion of the recreation and tourism, commercial fishing and seafood processing, 

and mining and mineral development sectors, and also addresses the importance of quality of life and 

natural amenities in attracting and retaining residents and businesses. Further, the Communities 

subsection of the Draft EIS provides detailed information on employment and economic conditions by 

community. Potential impacts to the regional economy are also assessed in the Economic and Social 

Environment section, including potential impacts to the timber, recreation and tourism, and commercial 

fishing and seafood processing sectors, as well as quality of life and natural amenities.

COMMENT

SOC-2: Contrary to federal policy, the Draft EIS makes no attempt to address the social costs of 

carbon dioxide released as a result of timber harvest. Federal agencies, including USDA and the 

Forest Service, have calculated the social costs of carbon from other federal land management 

actions.

RESPONSE

Additional discussion regarding the social costs of carbon has been added to the Climate Change section 

in the Final EIS.

COMMENT

SOC-3: The Draft EIS (pg. 3-441) appears to suggest that harvesting old-growth timber has 

negative impacts on tourism. This is a false assumption. Continued timber harvest and road 

development will enhance tourism.

RESPONSE

The text from the Draft EIS quoted in the original text of the above comment is part of a general 

introductory paragraph that addresses three different types of broad value: recreation and tourism; 

ecosystem values; and non-use values. The paragraph does not address the relationship between timber 

harvest and tourism. Potential impacts to recreation and tourism are evaluated in the Recreation and 

Tourism section of the Draft EIS, and the associated economic impacts are addressed in the Social and 

Economic Environment section. 

COMMENT

SOC-4: The Draft EIS fails to show how the proposed alternatives will meet the goal of providing 

jobs for Southeast Alaska residents because the timber industry accounts for only a small share 

of regional employment. The Draft EIS fails to consider the impact of the limited export policy on 

the number of saw mill jobs supported per MMBF harvested, the share of logging jobs held by 

non-residents, or the potential for young growth logging to employ fewer workers due to 

increased mechanization, making it impossible to evaluate whether the proposed timber harvest

levels will meet the goal of providing jobs for Southeast Alaska residents.

Final EIS I-147 DEIS Comments and Responses
Appendix I

RESPONSE

Concerns regarding the scope of the Purpose and Need are addressed in detail in the Purpose and Need

section of this comment response document (see, for example, P&N-10). The purpose and need for the 

amendment responds to the July 2, 2013 memorandum from USDA Secretary Tom Vilsack which 

specifically directed the US Forest Service to expedite the transition from old-growth to young-growth 

timber harvest while maintaining a viable timber industry that provides jobs and opportunities for 

Southeast Alaska residents. 

Diversity of employment opportunities is important for any economy especially in small towns. The 

Communities section of the Draft EIS inventories estimated employment, by industry sector, for each 

community. Some small towns, such as Thorne Bay, are more focused on timber employment than 

others such as Skagway, where the economy is more based on tourism. In addition, transitioning to 

young growth timber management may disperse these jobs across the region. The oldest young growth 

is in the northern part of the Tongass National Forest, which may create possible niche markets in that 

subregion. 

Concerns related to the limited timber export policy are addressed in detail in the Timber Export 

subsection of this comment response document. The comment notes that the sawmill jobs per MMBF 

harvested on the Tongass have declined since 2008 when the limited timber export policy was initiated, 

dropping from an average of 2.2 jobs/MMBF (2002 to 2007) to an average of 1.5 jobs/MMBF (2009 to 

2014). This does not, however, capture the entire picture, as exporting unprocessed timber supports a 

different range of jobs than domestic processing with more of an emphasis on transportation and 

stevedoring than sawmilling. This is reflected in the estimated timber industry employment and income 

estimates presented by alternative in Table 3.22-18 in the Draft EIS (p. 3-484). As noted in footnote 5 to 

this table, export employs more workers in transportation and other services per MMBF harvested than 

domestic production. Transportation and other services for export volume include water transportation, 

independent trucking, stevedoring, scaling, and export marking and sort yard employment for export 

volume. Transportation and other services for locally sawn volume include water transportation, scaling, 

and independent trucking. 

Local sawmilling and transportation-related employment estimates presented in Table 3.22-18 are based 

on a range, from maximum possible shipment out of state (export of all Alaska yellow cedar plus hemlock 

and Sitka spruce export equal to 50 percent of total sale net sawlog volume), to no shipment of hemlock 

and Sitka spruce and export of 100 percent Alaska yellow cedar (see Table 3.22-18, footnote 4). 

Non-resident employment in Southeast Alaska is discussed in the Economic and Social Environment 

section of the Draft EIS and summarized in Figure 3.22-2. Alaska currently employs a significant quantity 

of seasonal workers in resource-dependent industries because of the nature of this employment and the 

weather conditions. Nonresident workers as a share of direct employment in resource-dependent 

industries in Southeast Alaska range from 39.5 percent in the leisure and hospitality sector to 71.3 

percent in the manufacturing sector (which mainly consists of employment in the seafood processing 

sector) (Figure 3.22-2). Many workers leave in the winter either because employment ends (i.e., tourist 

season ends) – or, they prefer to spend their wages somewhere where the cost of living is lower than 

Alaska. These are seasonal workers that do not become year-around residents. 

Transitioning to young-growth timber harvest may result in a different range of types of employment than 

the current mix. Mechanical harvesters, for example, were they to be employed, require different 

maintenance, repair services, and transportation than conventional harvesting. 

COMMENT

SOC-5: The Draft EIS fails to appreciate the full economic impact of commercial fishing. The exvessel value reported in the Draft EIS fails to account for the economic impact of in-state 

processing and the various goods and services provided to the fish harvesting and processing 

industries. The Draft EIS also fails to accurately identify the number of jobs provided by 

commercial and sport fishing. The economic value of commercial and sport fishing should be 

balanced against the value of logging. 

DEIS Comments and Responses I-148 Final EIS
Appendix I

RESPONSE

The text cited in this comment is from the introduction to the Fish section of the Draft EIS. The economic 

impacts associated with commercial fishing are described in more detail in the Economic and Social 

Environment section in Chapter 3 of the Draft EIS. A note referring the reader to the Economic and 

Social Environment section has been added to the introduction to the Fish section to avoid confusion. 

Direct employment in natural resource industries is, for example, compared in Table 3.22-3 and Figure 

3.22-1, and a detailed discussion of the commercial fishing sector is provided in the subsection entitled 

Commercial Fishing and Seafood Processing (starting on p. 3-465 of the Draft EIS). 

COMMENT

SOC-6: The Draft EIS indicates that the proposed alternatives would likely have negative effects 

on subsistence, but provides no information on the role that subsistence plays in communities or 

the socioeconomic importance of these potential adverse effects. There is a wealth of information 

on the topic, much of which has been developed by or with the cooperation of the Forest Service. 

Much of this information is available through the ADF&G, Division of Subsistence.

RESPONSE

The Draft EIS includes a substantial amount of information regarding subsistence activities including 

detailed analysis for each community within the region (see pp. 3-501 through 3-656). The Forest 

Service is aware that ADF&G has expertise in and publishes data and information on subsistence 

resources and activities. ADF&G subsistence data and information, including some developed by the 

Forest Service, is provided, cited, and discussed at length throughout the Draft EIS. In addition to 

publicly available data, ADF&G also provided the more detailed data used for the community-level 

analyses (pp. 3-501 through 3-656).

COMMENT

SOC-7: The Draft EIS indicates that the proposed alternatives would likely have negative effects 

on hunting, fishing, and wildlife-viewing, but provides no information about the economic 

importance of these activities. The Draft EIS should have cited the results of a report prepared for 

ADF&G that assessed the economic importance of wildlife in 2011 (ECONorthwest 2014).

RESPONSE

The economic importance of hunting, fishing, and wildlife-viewing is discussed in the Economic and 

Social Environment section of the Draft EIS starting on page 3-463 under Recreation and Tourism. 

Additional information from the report cited in the comment has been added to this section in the Final 

EIS. 

COMMENT

SOC-8: The Draft EIS fails to assess the importance of resource-related amenities, such as access 

to fish, wildlife, and scenic unlogged forests, to the quality of life for local residents and the role 

these resources play in attracting and retaining residents and businesses. While these issues are 

discussed in the Draft EIS, the Draft EIS analysis is deficient because it does not include survey 

results from a report prepared for ADF&G that found that quality of life issues are important to 

many Southeast Alaska residents (ECONorthwest 2014). In addition, the Draft EIS fails to 

consider the impact of the alternatives on quality of life issues.

RESPONSE

The Draft EIS discusses the importance of resource-related amenities, such as access to fish, wildlife, 

and scenic unlogged forests, to the quality of life for local residents and the role these resources play in 

attracting and retaining residents and businesses in the Economic and Social Environment section of the 

Draft EIS starting on page 3-468 under Natural Amenities and Quality of Life. Potential impacts to quality 

of life issues are discussed in the Environmental Consequences part of the Economic and Social 

Environment section of the Draft EIS starting on page 3-486 under Natural Amenities and Quality of Life. 

Final EIS I-149 DEIS Comments and Responses
Appendix I

Additional information from the report cited in the comment has been added to this section in the Final 

EIS.

COMMENT

SOC-9: The Draft EIS would have presented a more complete portrait of the potential 

socioeconomic impacts of the alternatives if it had provided information about the net economic 

benefits local residents and visitors derive from wildlife, fish, scenery, and other resources. 

Specifically, the Draft EIS should have included information from a report prepared for ADF&G 

that assessed the economic importance of wildlife in 2011 (ECONorthwest 2014). In addition, the 

Draft EIS does not address the potential impacts of the alternatives on ecosystem services.

RESPONSE

The report referenced in the comment provides estimates of the “net economic benefits” of hunting and 

wildlife viewing for residents and visitors in Alaska in 2011. Net economic benefits as presented in this 

report include the amount residents and visitors spent on these activities plus a hypothetical amount they 

would have been willing-to-pay above the amount they actually did pay. In addition, the estimates also 

included the estimated amount survey respondents would theoretically be willing-to-pay to visit an area 

managed to ensure they would see a specific species and the amount they would be willing-to-pay into a 

wildlife conservation fund. The resulting estimates are, of course, considerable and provide an indication 

of the importance of wildlife to residents and visitors to Alaska. These types of non-use values (i.e., 

values that individuals assign to a resource independent of their use of that resource) are discussed 

further in the 2008 Forest Plan EIS (USDA Forest Service 2008b, p. 3-551 to 3-552). 

The Draft EIS provides an overview of ecosystem services and references the detailed discussion in the 

2008 Forest Plan EIS (USDA Forest Service 2008b, pp. 3-544 to 3-556). The discussion in the current 

Forest Plan EIS is located in the Economic and Social Environment section of the Draft EIS on page 3-

487 under Ecosystem Services. The author of the above comment notes that there are many good 

introductions to the values of services derived from forest ecosystems and provides a list of references for 

the Forest Service to consider. Many of these references are included in the discussion in the 2008 

Forest Plan EIS, which is incorporated in the current EIS, as noted above. 

COMMENT

SOC-10: The Draft EIS does not assess the economic impacts and costs to businesses and 

communities in the event that the young-growth transition is not successful and existing timber 

operations go out of business. If Viking Lumber were to go out of business, for example, AP&T 

would experience a significant reduction in energy demand on Prince of Wales Island. This could 

potentially lead to a so-called “death spiral” whereby a drop in sales leads to an increase in rates 

to cover fixed costs, which in turn leads to further sales reductions.

RESPONSE

The purpose and need for the amendment responds to the July 2, 2013 memorandum from USDA 

Secretary Vilsack which directed the US Forest Service to expedite the transition from old-growth to 

young-growth timber harvest while maintaining a viable timber industry that provides jobs and 

opportunities for Southeast Alaska residents. All of the alternatives, including No Action, are designed to 

expedite this transition. The amended Forest Plan under all alternatives would provide an annual 

average of 46 MMBF during the transition period and it is up to the industry to respond to the 

transition. The transition time frame provides opportunity for the existing industry to adjust or retool for a 

predominantly young-growth supply from the Tongass, as well as time for new operations to develop, if 

appropriate.

COMMENT

DEIS Comments and Responses I-150 Final EIS
Appendix I

SOC-11: The Final EIS should identify the number of jobs that would be created for industry 

maintaining and decommissioning existing forest roads. Unlike the Draft EIS alternatives, this 

type of emphasis would create long-term, sustainable employment for timber industry workers. 

RESPONSE

The Draft and Final EIS documents include five alternatives designed to meet the Purpose and Need for 

the Forest Plan amendment, as directed by the Secretary of Agriculture. This is explained further in the 

Purpose and Need section of the Draft EIS, starting at page 1-4. An alternative that does not include 

timber harvest would not meet the Purpose and Need. Information related to road maintenance and 

proposed decommissioning on the Tongass National Forest is available in the Access Travel 

Management Plans prepared for each Ranger District. These plans are available at the District offices.

Final EIS I-151 DEIS Comments and Responses
Appendix I

Market Demand (MKD)

COMMENT

MKD-1a: The PNW Research Station demand study overestimates the likely actual demand for 

timber. All three scenarios evaluated in the study ignore the long-term decline in market demand 

and anticipate increasing demand over the next 15 years. These scenarios rely on misleading 

assumptions about the U.S. share of global timber markets, the portion of this share accounted 

for by federal harvest in Southeast Alaska, and in particular the assumption that the Tongass will 

retain the same share it currently has of rising global demand. The Forest Service should 

recognize that this approach has failed to accurately predict demand in the past, and consider a 

scenario that involves a continued decline in demand.

RESPONSE

During the past 25 years, the U.S. Forest Service, Pacific Northwest (PNW) Research Station has 

published several studies in support of Tongass National Forest land management planning that estimate 

derived demand for Southeast Alaska timber including Brooks and Haynes (1990, 1994, 1997), Brackley

et al. (2006a), and Daniels et al. (2016). Daniels et al. (2016) is the fifth such analysis performed since 

1990 to assist forest planners in meeting statutory requirements for estimating planning cycle demand for 

timber from the Tongass National Forest. 

Projections of Alaska timber products outputs, the derived demand for logs, lumber, residues, and niche 

projects, and timber harvest by owner are developed using trend-based projections. “Derived demand”, 

in PNW Research Station studies, is defined as the volume of national forest harvest needed to meet 

projected consumption of Alaska forest products, over time, given the harvest levels of other owners and 

based on assumptions about product markets. Similar to prior studies, Daniels et al. (2016) estimate 

demand for Tongass National Forest timber using a materials balance approach based on forecasted 

trends in product markets. Projected harvest from the Tongass National Forest is calculated as the 

volume of timber required to meet the shortfall between projected demand and harvest from other 

ownerships, primarily Native Corporation and State of Alaska lands. Alternatively stated, derived demand 

for Tongass National Forest timber is computed as the residual – the quantity of national forest timber 

required to balance the market. 

Demand for Tongass National Forest timber depends on final markets supplied by Alaska forest products. 

The PNW Research Station identified all markets receiving Alaska wood products including utility logs, 

softwood lumber, mill residue, and other niche products. Additional information was gathered regarding 

production, shipments, and relative scale of markets served. This information was combined with 

projections of total wood product consumption (for domestic markets) or imports in destination regions to 

arrive at the share of the market supplied by Southeast timber production. Historic market data was 

collected and assessed for each product market including softwood log exports, domestic log market, 

utility logs, lumber, and other products. 

The PNW Research Station then developed a baseline model based on the assumption that the industry 

in southeast Alaska production would remain at post-2008 recession levels for the next 15 years, despite 

indications at the time the study was completed (summer 2015) that U.S. sawnwood consumption had 

reached levels approaching those seen during the pre-recession housing boom (Daniels et al. 2016). 

The baseline model was subsequently used to evaluate three scenarios representing different potential 

futures for timber harvest in Southeast Alaska. The first scenario (Scenario 1) assumed that the transition 

to young growth would occur by 2025, with old-growth harvest constrained to 5 MMBF for small sales and 

micro-sales from that point onward. As modeled, this scenario resulted in a reduction in Pacific Rim 

demand for dimensional lumber from Southeast Alaska that would in turn cause a decline in harvest from 

the Tongass relative to the baseline rate. The second scenario built upon the transition modeled in 

Scenario 1 by adding an expansion of bioenergy markets. Scenario 3 also built on the transition modeled 

in Scenario 1, but assumed increased demand for lumber from the Lower 48 States, by considering only 

the pre-recession rate of growth in domestic lumber consumption, as opposed to the more conservative 

growth rates used in the baseline model (Daniels et al. 2016). In other words, the PNW Research Station 

study assesses a range of potential demand scenarios that build upon a baseline model that employs 

DEIS Comments and Responses I-152 Final EIS
Appendix I

conservative assumptions regarding the development of future markets. The likelihood that baseline 

demand will drop below post-recession levels is considered very low.

Observed declines in timber harvest should not supplant the use economic theory and peer-reviewed 

methodology to project demand for Tongass National Forest timber in an objective and scientific manner. 

There are many extenuating circumstances, unrelated to market demand for forest products, that impact 

actual timber harvest including administrative appeals and delays, litigation, agency budget, and other 

administrative challenges.

COMMENT

MKD-1b: The Proposed Forest Plan and all of the alternatives (including no action) evaluated in 

the DEIS are based on an inflated estimate that market demand for timber will average 46 MMBF 

per year for the next fifteen years, regardless of the allocation between old-growth and secondgrowth. This results in the DEIS overstated the number of jobs supported and the overall 

economic benefits of logging. The Forest Service should revise this estimate downward and vary 

projected timber outputs by alternative.

RESPONSE

Concerns that the PNW Research Station demand study overestimates potential timber demand are 

discussed in response to MKD-1, above. 

As discussed in Chapter 2 of the Draft EIS, the Proposed Action and range of alternatives developed for 

the Draft EIS were designed to maximize or emphasize the percentage of harvest volume coming from 

young growth as early as possible, while minimizing any potential effects on the old-growth Conservation 

Strategy and other resources. Alternatives 1 through 5 in the EIS were designed to produce a PTSQ of 

about 46 MMBF per year during the next 15 years, with old growth making up a decreasing percentage of 

the total. Old-growth volume would continue to decrease until it reaches about 5 MMBF per year and it 

would remain at that level, to support limited small timber operators. As more young growth becomes 

economic to harvest, the PTSQ would be allowed to increase. 

In past Forest Plan revisions and amendments, varying demand scenarios were used to develop 

alternatives, including scenarios that allowed for growth and expansion of the current industry. In this 

amendment, the purpose and need requires the transition to a predominantly young-growth based 

industry and the reduction of old-growth harvest. The alternatives evaluated in the EIS differ in their 

approach to meeting this purpose and need, rather than varying the volume expected to be made 

available for harvest. Each alternative evaluated in detail in the EIS differs in terms of suitability of lands 

(i.e., determination made regarding the appropriateness of various lands within a plan area for various 

uses or activities, based on the desired conditions applicable to those lands) and other plan components 

(goals; desired conditions; objectives; standards; guidelines) that dictate direction and may apply forestwide or to specific LUDs. These variations among alternatives affect the ability of each alternative to 

meet the purpose and need of the proposed amendment, and the speed at which the transition to younggrowth could potentially occur.

The Forest Service will continue to evaluate annual market demand using the Morse methodology and 

may adjust the total volume, as well as the mix of old-growth and young-growth timber, made available for 

sale on a year-to-year basis, as needed to meet demand and the Secretary’s direction to speed the 

transition toward a young-growth timber industry.

COMMENT

MKD-1c: The Draft EIS does not discuss current export market information compiled by the PNW 

Research Station and ignores the substantial weakening of export markets and the competitive 

disadvantage of Alaska and Pacific Northwest raw log exporters. Recent PNW Research Station 

press releases indicate that both the value and volume of log exports from Alaska and the West 

Coast are declining and at a much greater rate than other timber exporting regions.

Final EIS I-153 DEIS Comments and Responses
Appendix I

RESPONSE

The Draft EIS provides an overview of the modeling approach used by the PNW Research Station to 

estimate market demand for timber (see pp. 3-455 to 3-460). More detailed information regarding the 

methodology and data sources used for the PNW Research Station study is provided in Daniels et al. 

(2016). These projections are based on longitudinal trend information available at the time the demand 

study was completed (summer 2015) and do not include data from the more recent PNW Research 

Station press releases and publications cited in the comment. The demand projections developed by 

Daniels et al. are based on long-term trends and represent long-term, planning cycle demand. Short-term 

fluctuations in demand are represented in the Morse methodology, which informs the amount of timber 

offered in a year.

COMMENT

MKD-2: The project record indicates that the DEIS inflates the volume of old-growth – 5 MMBF per 

year – needed to sustain small timber operators. An email exchange between the Regional 

Economist and the lead author of the PNW Research Station’s demand study indicates that the 

volume used by small operators “is probably somewhere between 1.4 MMBF and 3.0 MMBF.” This 

inflated estimate will result in future levels of old-growth logging that are higher than needed to 

support small operators.

RESPONSE

Data compiled from publicly available reports posted on the Alaska Region Forest Management and 

Accomplishment Reports web page indicates that from 2005 through 2014, small operators had an 

annual average of 11 MMBF of uncut timber under contract, ranging from an annual low of 6 MMBF in 

2014 to a high of 17 MMBF in 2008 and 2009 (see the first table below). The same data source indicates 

that small operators harvested an annual average of 7 MMBF over the same time period, ranging from an 

annual low of 4 MMBF in 2006 to a high of 11 MMBF in 2011 (see the second table below). These data 

indicate that the annual estimate of 5 MMBF of old growth volume needed to sustain small timber 

operators is lower than the annual average volume harvested over the past 10 years. These numbers 

suggest that based on current and past volumes under contract and harvest levels, 5 MMBF is not an 

overstatement of the volume likely to be required by small operators.

See: http://www.fs.usda.gov/detail/r10/landmanagement/resourcemanagement/?cid=fsbdev2_038785

DEIS Comments and Responses I-154 Final EIS
Appendix I

Source: USDA Forest Service 20169

COMMENT

MKD-3: The Proposed Forest Plan explicitly adopts, for the first time, a fixed PTSQ. This new 

provision must comply with the 2012 planning rule, which requires that a Forest Plan provides for 

economic sustainability. The EIS must analyze whether the new PTSQ and the associated plan 

objective (O-TIM-01) comply with the economic sustainability requirement of the 2012 planning 

rules.

RESPONSE

Timber objectives O-TIM-01 and O-TIM-02 have been revised in the Final EIS. This is discussed further 

in response to Comment TIM-11. These revisions clarify that O-TIM-01 is not intended to be a fixed 

target. 

COMMENT

9 USDA Forest Service. 2016. Timber Volume Under Contract, various years. Available online at: 

http://www.fs.usda.gov/detail/r10/landmanagement/resourcemanagement/?cid=fsbdev2_038785

Final EIS I-155 DEIS Comments and Responses

 
Appendix I

MKD-4: Each year the Forest Service uses the Morse methodology to estimate the volume of 

timber it needs to offer for sale to maintain adequate inventory for purchasers. This methodology 

uses the PNW Research Station demand projections as part of this calculation, which tends to 

overstate the volume required, and will continue to do so in the future if the latest PNW Research 

Station projections (Daniels et al. 2016) are used. The Forest Service must monitor demand on an 

annual basis or develop different estimates that project lower demand than Daniels et al.

RESPONSE

Specific concerns regarding the PNW Research Station demand projections are discussed in response to 

MKD-1a and elsewhere in this comment response document. As discussed in response to comments 

regarding the economics of the timber industry (see, for example, ECON-1, -5, -6, and -8), the Forest 

Service will continue to evaluate annual market demand using the Morse methodology, as needed to 

meet demand and the Secretary’s direction to speed the transition toward a young-growth timber industry. 

Revisions to the Morse methodology are outside the scope of this Forest Plan amendment.

COMMENT

MKD-5: The Draft Forest Plan sets a goal of maintaining a three-year supply of timber under 

contract based on “annual timber consumption (i.e., the amount that is expected to be logged in a 

given year).” If the annual amount expected to be logged is based on the PNW Research Station 

forecasts, it will likely be too high, and the over-estimate will then be tripled in an attempt to 

maintain a three-year supply, causing the Forest Service to waste public resources on the 

preparation of unnecessary timber sales. 

RESPONSE

Specific concerns regarding the PNW Research Station demand projections are discussed in response to 

MKD-1a and elsewhere in this comment response document. The goal of maintaining a three-year timber 

supply is to allow flexibility for forest products businesses to plan their operations and to allow flexibility in 

the timing of selling final products. In order to accomplish this goal, there needs to be more timber under 

contract than actual timber harvest. Annual projected harvest is based on the Morse Methodology. The 

2008 Forest Plan revision used the Morse Methodology consistently as has the annual market demand 

calculations. This is explained in the Big Thorne FEIS, Appendix A and other project EISs. These 

sections have been revised, over time, to clarify this concept for the public. The Forest Service will 

continue to evaluate annual market demand using the Morse methodology, as needed to meet demand 

and the Secretary’s direction to speed the transition toward a young-growth timber industry. Revisions to 

the Morse methodology are outside the scope of this Forest Plan amendment.

COMMENT

MKD-6: The Morse methodology used by the Forest Service to estimate annual market demand is 

based in part on mill capacity, which it defines as “the amount of net sawlog volume that could be 

utilized by the sawmill, as currently configured, during a standard 250 day per year, two shifts per 

day annual operating schedule – and, not limited by availability of workforce, raw materials, or 

market conditions.” The Draft EIS shows that utilization of active mill capacity has been 

significantly lower than this amount in recent years. Viking Lumber, for example, has a listed 

capacity of 80 MMBF, but has milled one-fifth of this amount.

RESPONSE

The Forest Service will continue to evaluate annual market demand using the Morse methodology, as 

needed to meet demand and the Secretary’s direction to speed the transition toward a young-growth 

timber industry. Revisions to the Morse methodology are outside the scope of this Forest Plan 

amendment. It may also be noted that observed declines in timber harvest and utilization rates do not 

necessarily equate to a reduction in demand. There are many extenuating circumstances, unrelated to 

market demand for forest products, that impact actual timber harvest including administrative appeals and 

delays, litigation, agency budget, and other administrative challenges. 

COMMENT

DEIS Comments and Responses I-156 Final EIS
Appendix I

MKD-7: The Draft Forest Plan has raised the “volume-under-contract goal” revising it from 2 to 3 

years supply to 3 years supply without explanation or related analysis. The proposed change 

should be deleted or the Forest Service should explain why the change is necessary.

RESPONSE

Language in the Draft Forest Plan was updated to “(p)rovide about 3 years supply of volume under 

contract to local mills and then establish NEPA-cleared volume to maintain flexibility and stability in the 

sale program” (p. 2-5). This objective is identified in the 2008 Forest Plan as “2 to 3 years supply of 

volume.” This objective was revised in response to public concern and comments received during timber 

harvest project environmental analysis document reviews, which questioned whether the amount should 

be 2 or 3 years supply – or somewhere in between (2.5 years). In order to make the objective clearer, 

one number was used instead of the prior range. The higher number (3 years) was selected because it is 

more representative of our practices and provides more flexibility with a higher volume under contract to 

mitigate the impact of potential delays in offering timber volume. Factors causing potential delays in 

offering timber volume include policy changes or injunctions during litigation which preclude either 

harvesting or offering certain projects. Harvest levels also fluctuate with changing markets and the 

amount of timber available, and also vary due to mobilization and weather-related impacts. In short, three 

years of volume under contract is not a change from our current practices and is preferable to help 

address market fluctuations and other changes in conditions. 

COMMENT

MKD-8: The PNW Research Station demand estimates do not comply with the requirements of 

TTRA because the analysis accounts for round log exports, which were limited from the Tongass 

in 1990 when TTRA was enacted. It was never the intent of Congress that the mills in Southeast 

Alaska would have to compete against the round log export market. 

RESPONSE

As discussed in the Draft EIS, for the past 25 years, the Forest Service has commissioned the PNW 

Research Station to prepare a number of long-term projections of demand for Tongass timber over time, 

including Brooks and Haynes (1990, 1994, 1997) and Brackley et al. (2006a, 2006b). The PNW 

Research Station has prepared a similar analysis in support of the current proposed amendment of the 

Forest Plan (Daniels et al. 2016). Using methods adapted from the previous PNW Research Station 

analyses, Daniels et al. estimate demand for Tongass timber using a materials balance approach based 

on projected trends in product markets. The analysis projects future demand for timber (“derived 

demand”) based on the overall end-market demand in foreign and domestic markets and the portion of 

that demand Alaska is likely to fill (based on historic trends). 

The 2015 PNW Research Station study identified five primary timber products harvested from Southeast 

Alaskan forests -- softwood sawlogs, utility logs, softwood lumber, mill residue, and other products – and 

projected the associated demand by product. The analysis accounts for the demand for unprocessed 

logs and assumes that logs from the Tongass would continue to be exported. The limited export policy 

has affected the amount of logs available for local processing in recent years by allowing timber sales that 

would otherwise have been uneconomic to appraise positively and be made available for purchase. Part 

of the resulting sale may then be exported while the remaining volume is processed locally. Assuming 

that this practice would remain in place – by using recent trends to estimate future demand – reflects the 

current environment within which the Southeast Alaska timber industry operates. Viewed from a 

modeling perspective, the mills in Southeast Alaska are not competing with the round wood log export 

market. Timber export policy is discussed further in the Timber Export Policy section of this response to 

comments document. 

COMMENT

Final EIS I-157 DEIS Comments and Responses
Appendix I

MKD-9: The PNW Research Station study (Daniels et al. 2016) overestimates the volume of private 

timber that will be available for local processing, with volumes projected to increase from existing 

harvest levels (about 61 MMBF) to about 80 MMBF over the next 15 years. The study also 

overstates the volumes expected to be offered on state lands and assumes they will be offered on 

an annual basis. These overestimates result in the NFS volume being reduced to just 46 MMBF 

per year. Based on this low volume and the Forest Service’s record of consistently 

underperforming on their timber sale volume, purchasers cannot risk investing in their 

businesses to stay competitive.

RESPONSE

The PNW Research Station long-term timber demand projections (Daniels et al. 2016) are based on 

economic theory, peer-reviewed methodology, and scientific and objective analyses conducted by timber 

economists and forest researchers. The PNW Research Station study projected future demand for timber 

(“derived demand”) based on the overall end-market demand in foreign and domestic product markets 

and the portion of that demand Alaska is likely to fill (based on historic trends). The baseline demand 

projections developed by the PNW Research Station were developed in three stages: 1) historic 

estimates of Alaska forest products output by product and destination were gathered and projected from 

2015 to 2030; 2) the raw material requirements necessary to support this projected output were estimated 

by product type; and 3) the timber harvest equivalent was calculated and allocated by owner, including 

Native Corporation and State lands (Daniels et al. 2016). Based on historic trends, Daniels et al. 

assumed that Native Corporation harvest would be exported as unprocessed round wood, with none of 

this timber expected to be available for local processing. .For State harvest, Daniels et al. assumed that 

70 percent of State logs would be exported as unprocessed round wood, with the remaining 30 percent 

processed in Southeast Alaska. 

The PNW Research Station study developed projections for State and Native Corporation harvest as part 

of the baseline and three scenarios constructed as part of their study. State and Native Corporation 

harvest varied by scenario based on the underlying assumptions. Assuming that 30 percent of State 

harvest would be available for local processing results in an annual average of 6.2 MMBF (Baseline and 

Scenario 1) to 7.8 MMBF (Scenario 2) available from 2015 to 2030, equivalent to about 13 percent to 17 

percent of the PTSQ. As discussed above, the Forest Service will continue to evaluate annual market 

demand using the Morse methodology or a similar process and may adjust the total volume, as well as 

the mix of old-growth and young-growth timber, made available for sale on a year-to-year basis, as 

needed to meet demand and the Secretary’s direction to speed the transition toward a young-growth 

timber industry.

COMMENT

MKD-10: The PNW Research Station study’s (Daniels et al. 2016) Scenario 2 assumes increased 

demand for wood-based energy products. The economics of wood-based energy products in 

Southeast Alaska are marginal even with extensive subsidies and Daniels et al.’s projected utility 

log harvest for this scenario overstates the utility log share of total harvest. Utility logs at most 

average about 15 percent to 17 percent of total harvest. Timber supply constraints effectively 

limit wood-based energy to sawmill residuals, most of which are already being effectively used. 

RESPONSE

The PNW Research Station’s timber demand projections are based on economic theory, peer-reviewed 

methodology, and scientific and objective analyses conducted by timber economists and research 

scientists. “Derived demand”, as defined by the PNW Research Station scientists, is the volume of 

national forest harvest needed to meet projected consumption of Alaska forest products, over time, given 

the harvest levels of other owners and based on assumptions about product markets. In addition to 

projecting baseline timber demand, scientists also developed three scenarios that represent a range of 

possible future market conditions. Scenario 2, the “wood energy” scenario, accommodates the US Forest 

Service’s 30 percent conversion goal from distillate fuels to wood-based energy products for Southeast 

Alaska’s residential, commercial, and industrial sectors. Scenario 2 and the other scenarios evaluated in 

DEIS Comments and Responses I-158 Final EIS
Appendix I

the demand study represent different futures and are an attempt to project the future based on past 

observations and potential future conditions that may or may not come to fruition.

COMMENT

MKD-11: The PNW Research Station demand study (Daniels et al. 2016) does not estimate the cost 

of accessing, transporting, and harvesting young-growth timber, and contains no Alaska-specific 

estimates of the cost of producing timber from young-growth timber. The absence of this 

analysis undermines the credibility of the study’s estimates of young-growth demand.

RESPONSE

Daniels et al. (2016) is the fifth scientific analysis performed since 1990 to assist forest planners in 

meeting statutory requirements for estimating planning cycle demand for timber from the Tongass 

National Forest. “Derived demand”, as defined by PNW Research Station scientists, is the volume of 

national forest harvest needed to meet projected consumption of Alaska forest products, over time, given 

the harvest levels of other owners and based on assumptions about product markets. The methodology 

used to develop these estimates is summarized in the Draft EIS and described in detail in the timber 

demand study (Daniels et al. 2016). This approach to estimating demand is not based on the type of cost 

data identified in the comment and, as a result, the PNW Research Station demand study did not develop 

these types of estimates.

The results of the PNW Research Station demand study are used in the Draft EIS to develop the PTSQ 

and compare the alternatives. As discussed in Chapter 2 of the Draft EIS, the Proposed Action and 

range of alternatives developed for the Draft EIS were designed to maximize or emphasize the 

percentage of harvest volume coming from young growth as early as possible, while minimizing any 

potential effects on the old-growth Conservation Strategy and other resources. 

Although not part of the PNW Research Station demand study, the costs of accessing, transporting, and 

harvesting young-growth timber were estimated as part of the Woodstock modeling analysis prepared in 

support of the EIS analysis, and are included in the financial analysis of the alternatives. This is 

explained further in Appendix B to the Final EIS, which has been updated, as have the results of the 

financial analysis presented in the Final EIS.

COMMENT

MKD-12: The timber demand analysis prepared by the PNW Research Station was rushed and 

prepared without seeking input from the State of Alaska or the Southeast Alaska timber industry. 

RESPONSE

Input was solicited from the State of Alaska and the Southeast Alaska timber industry as part of the 

timber demand analysis prepared by the PNW Research Station. Multiple meetings were conducted with 

the State of Alaska and the Southeast Alaska timber industry during the summer and fall of 2014. The 

following table lists the visits Dr. Jean Daniels, the lead author of the PNW Research Station demand 

analysis, made to speak with staff from the state and timber industry about the demand study, along with 

dates and locations, as well as anyone else who attended these meetings. This concern is also 

addressed in response to Comment P&N-9 in the Purpose and Need section of this response to 

comments volume.

Trip Date Met with: Where Also in 

attendance:

Ketchikan, 

AK, Summer, 

2014

June 20, 2014 Owen Graham Tongass NF SO Su Alexander

June 20, 2014 Clarence 

Clark

AK DNR, White Cliff Building

Ketchikan, 

AK, Fall, 

2014

September 15, 

2014

Jim Tuttle Sealaska Corp office Clarence Clark

Final EIS I-159 DEIS Comments and Responses
Appendix I

September 15, 

2014

Paul 

Slenkamp

Alaska Mental Health Trust, 

White Cliff Building

Clarence Clark

September 15, 

2014

Eric Nichols Alcan Ward Cove export yard Clarence Clark

POW Island, 

Fall, 2014

September 16, 

2014

Ernie Eads Thuja Plicata Mill Clarence Clark

September 16, 

2014

Jim Harrison Western Gold Cedar Mill Clarence Clark

September 16, 

2014

Hans Kohn Good Faith Lumber Mill Clarence Clark

COMMENT

MKD-13: The PNW Research Station demand analysis was prepared because the Forest Service 

is planning to reduce the supply of old-growth timber in response to the Secretary’s 

Memorandum. This restriction does not reduce demand, it limits supply. Supply is also limited 

due to the high costs of harvesting federal timber sales that are a result of the Forest Plan 

standards and guidelines. Daniels et al. (2016) indicate that existing mills are operating well 

below capacity, but do not explain that this is due to the constrained timber supply, not a lack of 

demand. Viking managers have, for example, repeatedly told the Forest Service that they would 

like to purchase more timber sales. Providing sufficient old-growth timber is the best approach to 

sustaining a viable timber industry and meeting the intent of TTRA’s market demand provision. 

RESPONSE

The Tongass National Forest has been directed, per the Secretary’s Memorandum 1044-009: “To 

conserve the Tongass National Forest under the principles of the Multiple-Use Sustained- Yield Act of 

1960, Tongass Timber Reform Act and other relevant statutes, we must speed the transition away from 

old-growth timber harvesting and towards a forest industry that utilizes second growth – or young growth 

– forests. Moreover, we must do this in a way that preserves a viable timber industry that provides jobs 

and opportunities for residents of Southeast Alaska.” This memorandum does not direct the Tongass 

National Forest to artificially limit timber supply, rather it directed the forest to expedite the transition from 

old-growth harvest to young-growth harvest while maintaining a viable timber industry. 

The PNW Research Station has projected long-term timber demand, in support of forest planning efforts, 

for over two decades. The most recent report (Daniels et al. 2016) identifies a number of reasons for 

undertaking a new timber demand analysis. These include “evolving USDA policy limiting old-growth 

harvesting and encouraging the harvest of younger second-growth forest stands”, the recent transfer of 

some NFS lands to the Sealaska Corporation, “the entry of Tongass sawlogs into international export 

markets, rising fuel costs, and efforts to promote biomass energy products and technology for space 

heating and electricity generation” (Daniels et al. 2016, p.1). 

The USDA recognizes the importance of maintaining the existing infrastructure and providing old growth 

timber to “bridge” the transition to young growth and allow a market to develop for these products. The 

USDA also recognizes it is important to retain the expertise and infrastructure of the existing industry so 

businesses can re-tool. Since the Forest Service is also governed by the Multiple Use Sustained Yield 

Act, there are standards and guidelines in place for the protection of other resources. Efforts are made to 

reduce the costs of timber harvest and provide economic timber sales but costs are higher in Southeast 

Alaska than other parts of the country due to the high costs of supplies, difficult terrain and high 

transportation costs. 

COMMENT

DEIS Comments and Responses I-160 Final EIS
Appendix I

MKD-14: The PNW Research Station demand study states that the entry of Tongass sawlogs into 

international export markets invalidates prior demand assumptions. Tongass cedar sawlogs have 

been sold into international export markets for many decades, as have hemlock and spruce 

sawlogs on occasion. The current, temporary log export policy does not lower the demand for 

timber from the Tongass.

RESPONSE

Daniels et al. (2016, p. 1) identify a number of events that they believe “invalidate many of the 

assumptions for the last timber demand analysis.” These include “evolving USDA policy limiting oldgrowth harvesting and encouraging the harvest of younger second-growth forest stands”, the recent 

transfer of some NFS lands to the Sealaska Corporation, “the entry of Tongass sawlogs into international 

export markets, rising fuel costs, and efforts to promote biomass energy products and technology for 

space heating and electricity generation” (Daniels et al. 2016, p.1). In other words, increased log exports 

is just one of a number of changes from the last demand study. Daniels et al. do not state that increased 

log exports have reduced demand for timber from the Tongass.

Prior Pacific Northwest Research Station demand studies were conducted when Japan was the primary 

market for export logs from Alaska and before the Tongass National Forest began exporting to US 

domestic and other international markets. The relatively recent developments identified by Daniels et al. 

have changed the competitive position of Alaskan exports compared to Washington and Oregon. 

Furthermore, overall timber demand depends on markets for sawn wood and exports for softwood logs. 

COMMENT

MKD-15: The proposed PTSQ in the Draft EIS and Forest Plan (46 MMBF) does not provide 

sufficient timber volume to meet the most recent annual market demand estimates prepared by 

the Forest Service. These estimates developed for FY2014 using the Morse Methodology indicate 

that annual demand for that FY was 142 MMBF. As a result, the proposed PTSQ fails to meet the 

requirements of TTRA Section 101 to seek to meet annual demand from the Forest. The Draft EIS 

does not explain why the new estimates are almost 100 MMBF lower than the 2014 annual 

estimate.

RESPONSE

Estimated annual demand for FY 2014 was developed using the Morse methodology, which uses 

information from a number of sources, including the long-term timber demand projections. These 

projections will be updated as part of the Forest Plan amendment process, which will affect estimated 

annual demand in future years. The proposed PTSQ is discussed further in the Purpose and Need 

section of this response to comments document.

COMMENT

MKD-16: The Tongass Timber Reform Act, sec. 101 requires the Forest Service to “seek to meet” 

timber demand, and, therefore, the use of an unpublished draft of timber demand projection is 

unacceptable in the Draft EIS. Further, the Draft EIS refers to the same study inconsistently as 

Daniels (2015), Daniels et al. (2015), and Daniels et al. (in press). In addition, the Draft Forest Plan 

itself makes no direct mention of the Daniels et al. study.

RESPONSE

The Draft PNW Research Station study was available for public review before the Draft EIS was 

published. While the associated technical paper was cited as “Draft” or “In press” in the Draft EIS, the 

projections themselves were finalized prior to completion of the Draft EIS analyses. The report has 

subsequently been published and is consistently cited throughout the Final EIS as Daniels et al. (2016). 

The full reference is as follows:

Daniels, Jean M.; Paruszkiewicz, Michael D.; Alexander, Susan J. 2016. Tongass National Forest 

timber demand: projections for 2015 to 2030. Gen. Tech. Rep. PNW-GTR-934. Portland, OR: 

U.S. Department of Agriculture, Forest Service, Pacific Northwest Research Station. 53 p.

Final EIS I-161 DEIS Comments and Responses
Appendix I

The Draft Forest Plan indirectly references the findings of the PNW Research Station demand study in 

the new Forest-wide timber objectives added as part of Chapter 5. These objectives have been revised 

in the Final Forest Plan. The Daniels et al. study is not directly referenced in the Draft Forest Plan. 

Similarly, the demand study conducted in support of the 2008 Forest Plan (Brackley et al. 2006) is not 

directly referenced in the 2008 Forest Plan.

COMMENT

MKD-17: The current Draft EIS understates market demand and establishes a PTSQ that is the 

volume the Forest Service wishes to add, rather than what the industry needs to continue 

operating. An unrealistic assessment of market demand may be considered a fatal flaw for a 

Forest Plan EIS. “The USFS’ inflated assessment of market demand was successfully challenged 

in Natural Resource Defense Council v. USFS, 421 F.3d 797, 811-12 (9th Cir. 2005).” The same 

flaw exists for this plan, with market demand deflated to the point of being misleading.

RESPONSE

The market demand estimates used in the Draft EIS are PNW Research Station projections developed by 

Daniels et al. (2016). These demand projections are based on economic theory, peer-reviewed 

methodology, and scientific and objective analyses conducted by PNW Research Station scientists. The 

methodology used to develop these projections is summarized in the Draft EIS and discussed in detail in 

Daniels et al. (2016). Specific concerns regarding the accuracy of the latest PNW Research Station 

projections are discussed elsewhere in this comment response document.

It may also be noted that the challenge to the market demand assessment cited in the comment related to 

an error in interpretation of the 1997 market demand calculations, not an “inflated” or “unrealistic” 

assessment. As explained by the court in the opinion for Natural Resource Defense Council v. USFS, 

421 F.3d 797, 811-12 (9th Cir. 2005):

“The Forest Service misinterpreted the 1997 Brooks and Haynes market demand projection 

within the published ROD and EIS. The Forest Service incorrectly thought that the projection 

numbers refer only to “sawlogs suitable for producing lumber,” when they actually refer to “total 

National Forest harvest, including both net sawlog and utility volume.” Because of the Forest 

Service’s error, the ROD and EIS project an average market demand for Tongass timber nearly 

double that which Brooks and Haynes projected. The projected demand scenarios used by the 

ROD and EIS are 130 MMBF/year (low), 212 MMBF/year (medium), and 296 MMBF/year (high).”

This was one of the issues analyzed and updated by the Brackley et al. (2006) demand calculations for 

the 2008 Forest Plan Amendment FEIS, Appendix G.

COMMENT

MKD-18: Explain why the Draft EIS uses 25- and 100-year timeframes for comparison purposes. 

The lifespan of a Forest Plan is 15 years and Forest Service handbook direction requires that a 

Forest Plan must show volumes for PWSQ (Projected Wood Sale Quantity) and PTSQ (Projected 

Timber Sale Quantity) for two decades. Based on this requirement, analysis and comparison of 

alternatives should be based on a 20-year period. Projecting that a Forest Plan and PTSQ will not 

change over 25- and 100-year periods is misleading to the public.

RESPONSE

The use of 25- and 100-year frameworks is consistent with past Forest Plan EIS analyses and also allows 

an evaluation of the long-term implications of the alternatives with respect to the proposed young-growth 

transition. As modeled, the volumes available under the four action alternatives (Alternatives 2 through 5) 

would support a transition to young-growth by Year 25. In addition, in many cases, analysis results are 

presented in the Draft EIS by decade. 

Concerns related to the treatment of the PWSQ and PTSQ in the Forest Plan are discussed elsewhere in 

this comment response document, see for example TIM-5. The Draft EIS does not assume that the 

PTSQ would remain unchanged following completion of the young-growth transition. As discussed in the 

DEIS Comments and Responses I-162 Final EIS
Appendix I

Draft EIS, once the transition occurs (with the share of total harvest comprised of old-growth stabilized at 

5 MMBF), the amount of timber offered for sale would be allowed to increase above 46 MMBF as more 

young growth becomes economic to harvest. 

COMMENT

MKD-19: The annual PTSQ of 46 MMBF is based on the baseline projections developed by the 

PNW Research Station, rather than Scenario 1, which assumes the young-growth transition would 

occur by 2025, with a subsequent decline in projected demand (see Table 2-1 in the Draft EIS). 

Using the baseline projection overstates potential demand, and compounds multiple other issues 

with the PNW Research Station projections. 

RESPONSE

The Draft EIS compares the alternatives with three demand scenarios developed from the initial baseline 

projections. Using the baseline projections to estimate the PTSQ is consistent with this approach. It 

should also be noted that the annual average difference between the baseline and the Scenario 1 

estimates developed by the PNW Research Station is 1.8 MMBF. The use of the baseline model 

projection is discussed further below in response to MKD-20.

COMMENT

MKD-20: The PNW Research Station demand projections are for a 15-year period. These 

projections should be for 20 years to allow development of the PWSQ and PTSQ. In addition, the 

PTSQ established in the Draft Forest Plan (46 MMBF) is less than the derived demand for the three 

scenarios developed by Daniels et al. (2016). The PTSQ should at least be equal to the largest 

derived demand volume for the first two decades of the plan.

RESPONSE

The Daniels et al. (2016) study of long-term timber demand projections is based on economic theory, 

peer-reviewed methodology, and scientific and objective analyses conducted by timber economists and 

forest researchers. Daniels et al. avoids recommending any one scenario as a “most likely” projection 

because of the relatively high degree of uncertainty surrounding developments in Southeast Alaska. The 

baseline model, however, utilizes historical datasets necessary to represent Southeast Alaska timber 

markets and assumes the timber industry in Southeast Alaska will remain at post-2008 recession levels 

for the next 15 years. As such, the baseline annual average of 46 MMBF timber demand from the 

Tongass represents a conservative and rational estimate. In addition, the 46 MMBF projection is not only 

represented in the baseline model, but it is also represented in all three scenarios at different points in 

time, and these scenarios represent alternative futures for timber harvest in Southeast Alaska. 

It should also be noted that the PNW Research Station projections estimate planning cycle demand. The 

Forest Service will continue to evaluate annual market demand using the Morse methodology and may 

adjust the mix of old-growth and young-growth timber made available for sale on a year-to-year basis, as 

needed to meet demand and the Secretary’s direction to speed the transition toward a young-growth 

timber industry.

COMMENT

MKD-21: The Draft EIS needs to clearly define the terms “viable timber industry” and “existing 

industry.” These terms need to be defined for the Forest Service to be able to: a) develop a Forest 

Plan that “preserves” or “retains” the timber industry, and b) assess positive or negative changes 

in the timber industry as a result of implementing the transition.

RESPONSE

The term “existing industry” refers to the industry as it currently exists, as described in the Draft EIS (pp. 

3-448 through 3-454). The phrase “viable timber industry” as used in the Draft EIS refers to a timber 

industry that meets a dictionary definition of “viable”: i.e., Viable (adj) -- Capable of working successfully; 

feasible (Oxford Dictionary). The form that this industry will take is expected to evolve over time as the 

transition towards predominantly young-growth harvest occurs. In the short-run, in the absence of 

sufficient young-growth volume to meet average annual demand, the Forest Service will offer a mix of 

Final EIS I-163 DEIS Comments and Responses
Appendix I

old-growth and young-growth volume. Over time, the old-growth share will decrease as more younggrowth timber becomes available to harvest. This is expected to be a period of transition that will allow 

the opportunity for existing operations to retool and/or new operations to develop in response to changing 

supply conditions. Small operators will continue to have the opportunity to process old-growth timber with 

an annual average of 5 MMBF of old-growth volume expected to be made available through and following 

the young-growth transition. 

COMMENT

MKD-22: The Forest Plan amendment is based on a circular argument: the alternatives are all 

designed to meet a PTSQ that has clearly been limited in response to the Secretary’s policy 

decision to accelerate a transition to young-growth harvesting. The Forest Service should adopt a 

No Action alternative that allows annual old-growth harvests of up to 167 MMBF in accordance 

with the 2008 Forest Plan, while also allowing the Forest Service to offer more young-growth sales 

to help begin a young-growth transition. 

RESPONSE

As discussed in response to MKD-13 (above), the PNW Research Station has projected long-term timber 

demand, in support of forest planning efforts, for over two decades. The most recent report (Daniels et 

al., 2016), which is the fifth such analysis performed since 1990, identifies a number of reasons for 

undertaking a new timber demand analysis. These include “evolving USDA policy limiting old-growth 

harvesting and encouraging the harvest of younger second-growth forest stands”, the recent transfer of 

some NFS lands to the Sealaska Corporation, “the entry of Tongass sawlogs into international export 

markets, rising fuel costs, and efforts to promote biomass energy products and technology for space 

heating and electricity generation” (Daniels et al. 2016, p.1). 

The projections developed by Daniels et al. are based on economic theory, peer-reviewed methodology,

and scientific and objective analyses, and use a “derived demand” approach. The analysis projects future 

demand for timber (“derived demand”) based on the overall end-market demand in foreign and domestic 

markets and the portion of that demand Alaska is likely to fill (based on historic trends). Baseline demand 

projections Tongass timber were developed in three stages: 1) historic estimates of Alaska forest 

products output by product and destination were gathered and projected from 2015 to 2030; 2) the raw 

material requirements necessary to support this projected output were estimated by product type; and 3) 

the timber harvest equivalent was calculated and allocated by owner (Daniels et al. 2016). These 

baseline projections were used in the Draft EIS to develop the PTSQ. As this brief summary suggests, 

the baseline estimates developed by Daniels et al. were not constrained or otherwise affected by the 

Secretary’s policy decision to speed up the transition to young-growth harvesting. The methodology 

employed to develop these projections is discussed in more detail in Daniels et al. (2016).

As discussed in Chapter 2 of the Draft EIS, the No Action Alternative represents current management 

direction (2008 Forest Plan) and includes the application of the Roadless Area Conservation Rule (2001 

Roadless Rule). Under this alternative, timber harvest would follow the existing timber sale program 

adaptive management strategy in all phases outside of inventoried roadless areas. Timber management 

would be restricted to the development LUDs and no commercial harvest would be allowed in beach and 

estuary fringe or RMAs. In other words, the No Action alternative continues to follow 2008 Forest Plan 

management direction, but the upper harvest limit has been adjusted downward from an allowable sale 

quantity of 167 MMBF to a PTSQ of 46 MMBF in recognition of changed market and other conditions, as 

summarized above in the first paragraph of this response. 

COMMENT

MKD-23: The Draft EIS fails to describe the uncertainties and risks associated with its Preferred 

Alternative. The Draft EIS fails to identify the share of projected harvest that would be exported as 

logs versus processed locally, and also fails to identify the final destination of these logs and 

wood products. The Draft EIS also fails to describe the uncertainties and risks involved in its 

demand projections, specifically the potential consequences should projected demand fail to 

materialize. This does a disservice to business owners and others who may make decisions 

based on these projections. 

DEIS Comments and Responses I-164 Final EIS
Appendix I

RESPONSE

As discussed in the Timber Export Policy section of this response to comments document, the Draft EIS 

makes several assumptions regarding the limited export policy, including the following: 

• The financial analysis prepared for the Draft EIS (which has been updated for the Final EIS) 

assumed that all western redcedar would be processed domestically and that all Alaska yellowcedar would be sent to markets outside of Alaska, with Western hemlock and Sitka spruce 

volumes and other species assumed for the purpose of this analysis to be divided equally 

between domestic production and export in accordance with the current limited export shipment 

policy (Draft EIS, p. 3-481).

• The timber-related employment and income estimates presented in Table 3.22-18 in the Draft EIS 

were based on a range, from maximum possible shipment out of state (export of all Alaska yellow 

cedar plus hemlock and Sitka spruce export equal to 50 percent of total sale net sawlog volume), 

to no shipment of hemlock and Sitka spruce and export of 100 percent of Alaska yellow cedar. 

(Draft EIS, p. 3-484).

The assumptions used to develop the PNW Research Station demand projections are discussed in detail 

in Daniels et al. (2016). The demand study looked at export figures over the last 5 years and used these 

numbers to estimate softwood sawlog exports. These trend-based projections therefore reflect export 

trends in light of the export policy as well as the case-by-case export allowances beyond that 

programmatic approval.

The 2015 PNW Research Station study identified five primary timber products harvested from Southeast 

Alaskan forests: softwood sawlogs, utility logs, softwood lumber, mill residue, and other products. The 

projected allocation of Tongass timber by market is shown in Table 3.22-8 of the Draft EIS (pp. 3-456 to 

3-457) and discussed in detail in Daniels et al. (2016).

The Draft EIS discusses factors affecting the projected demand and other factors that affect the timber 

sale program in the Timber section of Chapter 3 (pp. 3-310 to 3-311). Daniels et al. (2016, p. 45) provide 

the following discussion regarding sensitivity:

“Our approach to incorporating and displaying uncertainty has two components. The first is the 

design and analysis of the three management scenarios. The second is a sensitivity analysis in 

which we examined the effects of changes in individual elements of the projections. The 

sensitivity analysis showed model results to be most sensitive to changes in Pacific Rim log 

export markets. This highlights the importance of competitiveness relative to producers in the

Pacific Northwest and other global log suppliers. Our model showed that the young-growth 

transition is most likely to affect lumber production; maintaining Pacific Rim log export markets in 

the face of changing raw material quality and the high costs of harvesting and transporting 

material are central issues facing the competitiveness of the Alaska forest sector.” 

A reference to this discussion has been added to the section that summarizes the PNW Research Station 

demand projections in the Final EIS.

COMMENT

MKD-24: The PNW Research Station projections are not based on price, and therefore, are not 

really demand projections at all. Instead of considering price, the demand study assumes that the 

quantity produced will be determined by other factors that are subject to the Forest Service’s 

decision-making authority. As a result, the “Forest Service is more or less saying that the 

demand for TNF timber will be however much it wants to log, based on its interpretation of 

‘multiple policies and objectives.”

RESPONSE

The PNW Research Station demand projections are not based on price as explained in Daniels et al. 

(2016, pp. 21-22):

Final EIS I-165 DEIS Comments and Responses
Appendix I

Projected harvest from the Tongass National Forest is calculated as the volume of timber 

required to meet the shortfall between projected demand and harvest from other ownerships, 

primarily Native Corporation and State of Alaska lands. In other words, derived demand for 

Tongass timber is computed as a residual—the quantity of national forest timber necessary to 

balance the market. ... Historical trends and assumptions about the share of harvest by other 

ownerships were used to project the share of future harvest to be met by the Tongass. The 

method is based on quantity, rather than price, because timber harvests from public lands are 

generally planned based on multiple policies and objectives, rather than on prices alone.

The methodology and data used to develop the PNW Research Station projections is further described in 

detail in Daniels et al. (2016). As stated in the above quote and explained in Daniels et al. (2016) and the 

Draft EIS, the demand estimates are based on historical trends and assumptions about the share of 

harvest, and are influenced by factors outside the Forest Service’s decision-making authority. 

The Forest Service disagrees with the characterization in the comment that the “Forest Service is more or 

less saying that the demand for TNF timber will be however much it wants to log, based on its 

interpretation of ‘multiple policies and objectives.’” The demand projections prepared by Daniels et al. 

and reported in the Draft EIS are based on economic theory, peer-reviewed methodology, and scientific 

and objective analyses conducted by PNW Research Station scientists.

COMMENT

MKD-25: The EIS should account for the impact of deficit timber sales and log export restrictions 

on the expected demand for wood products from young-growth logs and describe how these 

factors would cause the socioeconomic impacts of the alternatives to differ from those described 

in the Draft EIS. 

RESPONSE

The demand projections developed in support of this EIS are discussed in the Draft and Final EIS 

documents and Daniels et al. (2016). Concerns regarding these projections are discussed elsewhere in 

this comment response document, see, for example, the response to MKD-1a. Daniels et al.’s (2016) 

approach to uncertainty is discussed in response to MKD-23.

The Draft EIS presents projected levels of annual employment and income by alternative in Table 3.22-

18. These estimates are based on the maximum annual average harvest that could occur over the first 

decade following implementation (Years 1 to 10). All five alternatives are based on an annual PTSQ of 

46 MMBF, with the proportion of the total that is made up of young growth increasing over time, and the 

share made up of old growth decreasing. The estimates presented in Table 3.22-18 are based on a 

range that accounts for variations in export restrictions and behavior. The estimates range from 

maximum possible shipment out of state (export of all Alaska yellow cedar plus hemlock and Sitka spruce 

export equal to 50 percent of total sale net sawlog volume), to no shipment of hemlock and Sitka spruce 

and export of 100 percent of Alaska yellow cedar.

Further, the Draft EIS analysis recognizes that the numbers presented in Table 3.22-18 are estimates 

based on average jobs per MMBF ratios that were developed using harvest and employment data from 

2007 to 2010. As discussed in the Draft EIS, actual employment and income in Southeast Alaska will 

depend on choices made by purchasers, and these choices may change as markets and prices shift. 

Actual employment and income will also vary as timber offerings are packaged to include some or all of 

the units, and individual sales targeted for different sized operators are developed. 

COMMENT

MKD-26: The Forest Service must discard the Draft EIS and prepare a revised Draft EIS based on a 

new range of demand projections that employ a different methodology to those prepared by the 

PNW Research Station and more explicitly incorporate risk and uncertainty. The revised Draft EIS 

must describe risk and uncertainties and develop alternatives that explicitly address them by 

responding to a new range of demand projections, rather than the PTSQ used in the current DEIS. 

DEIS Comments and Responses I-166 Final EIS
Appendix I

RESPONSE

Specific concerns regarding the PNW Research Station demand projections are discussed in response to 

MKD-1a and elsewhere in this comment response document. The Forest Service disagrees with the 

assertions that the Draft EIS must be discarded and that a different methodology must be employed to 

estimate market demand. Concerns regarding the use of a range of demand projections and potentially 

varying levels of demand by alternative are discussed in response to MKD-1b.

COMMENT

MKD-27: The baseline projections developed by the PNW Research Station and presented in the 

Draft EIS Table 3.22-9 indicate that Native Corporation and State lands will account for a large 

share of timber harvest in Southeast Alaska over the next 15 years. The Draft EIS and supporting 

analyses do not consider whether this projected supply of non-federal timber would reduce the 

demand for federal timber or meet the Forest Service’s objective to meet timber demand and 

support logging and export jobs. 

RESPONSE

As discussed in the FEIS and in response to Comment MKD-1a (above), the projections developed by 

the PNW Research Station (Daniels et al. 2016) are based on “derived demand.” “Derived demand” in 

PNW Research Station studies is defined as the volume of national forest harvest needed to meet 

projected consumption of Alaska forest products, over time, given the harvest levels of other owners and 

based on assumptions about product markets. Demand for Tongass National Forest timber is estimated 

using a materials balance approach based on forecasted trends in product markets. Projected harvest 

from the Tongass National Forest is calculated as the volume of timber required to meet the shortfall 

between projected demand and harvest from other ownerships, primarily Native Corporation and State of 

Alaska lands. In other words, derived demand for Tongass National Forest timber is computed as the 

residual – the quantity of national forest timber required to balance the market – and the projected supply 

of non-federal timber is part of the analysis used to determine the demand for federal timber.

Timber harvest on Native Corporation and State lands would support logging and export-related 

transportation jobs over the planning period, and in the case of State lands may also support mill jobs. 

These potential jobs would be in addition to those identified in Table 3.22-18 in the Draft EIS. The jobs 

presented in Table 3.22-18 are limited to those that would be supported by federal harvest only. Nonfederal harvest would help support a viable timber industry by providing logging and export-related 

transportation employment, but would not supply sufficient old-growth “bridge timber” to allow the local 

saw mill industry to re-tool for processing young-growth.

Final EIS I-167 DEIS Comments and Responses
Appendix I

Timber Export Policy (TEXP)

COMMENT

TEXP-1: The Draft EIS fails to consider alternatives in which the limited export policy is not 

continued unchanged and indefinitely, premising its analysis on the “assum[ption]” that “Western 

hemlock and Sitka spruce volumes . . . [will] be divided equally between domestic production and 

export in accordance with the current limited export shipment policy.” This assumption – that the 

limited export policy will continue unchanged in its current form – has a strong effect on the 

projected timber sale quantity. To comply with NEPA and meet the project purpose and need, the 

EIS must evaluate alternatives that do not involve continuation of the limited export policy in its 

current form.

RESPONSE

Initially established in 2007, the Limited Export Policy is intended to boost appraised timber values, 

provide economic sale opportunities for purchasers, and provide additional processing options for 

purchasers. As discussed in the Draft EIS (pp. 3-453 to 3-454), the policy has continued since 2007 with 

modifications that have provided additional opportunities for purchasers. The policy modifies how timber 

sales are appraised and allowed timber purchasers options on shipping certain small diameter logs from 

national forest timber sales to outside Alaska. Designed to allow flexibility for timber purchasers, the 

limited export policy is not something mandated by the US Forest Service on a timber purchaser or 

automatically or immediately applied to all timber sales. Rather, the policy is applied by request of the 

timber purchaser after the contract offering is awarded or any time thereafter. Further, the policy is 

subject to review and modification on an annual basis. 

The text from the Draft EIS cited in the above comment pertains to the financial analysis developed as 

part of the Woodstock modeling process. The financial analysis presented in the Draft EIS has been 

revised for the Final EIS and continues to assume for the purposes of analysis that the current limited 

export shipment policy remains in place. A detailed discussion of the methodology and assumptions 

used to develop this analysis is presented in Appendix B to the Final EIS. 

The methodology employed to develop the PNW Research Station’s timber demand estimates is 

summarized in the Economic and Social Environment section of the Draft EIS and described in detail in 

the PNW Research Station demand study (Daniels et al. 2016). The demand study looked at export 

figures over the last 5 years (during which the limited export policy has been in place) and used these 

numbers to estimate softwood sawlog exports. 

The employment and income analysis in the Draft EIS assumed a range from maximum possible 

shipment out of state (export of all Alaska yellow cedar plus hemlock and Sitka spruce export equal to 50 

percent of total sale net sawlog volume), to no shipment of hemlock and Sitka spruce and export of 100 

percent of Alaska yellow cedar (see Table 3.22-18 in the Draft EIS). The analysis in the Final EIS also 

presents employment and income estimates for this range.

The assumptions used with respect to the limited export policy for the financial and employment and 

income analyses are appropriate for this programmatic analysis. Financial efficiency analyses will be 

conducted as part of the project-specific environmental analysis that will be prepared as part of future 

timber sale projects. These analyses will take into account the limited export policy and/or other potential 

restrictions on export or production in place at that time. Project-specific analyses will also consider the 

employment and income implications of the export restrictions in place or expected to be in place at that 

time. The Limited Export Policy is discussed further in Appendix H.

COMMENT

TEXP-2: The Draft EIS does not analyze the full extent or impact of the export policy or how it 

increases the environmental impacts of federal logging. It states that the Forest Service allows 

the export of up to 50% of the western hemlock and spruce sawlog volume, and notes that Alcan 

must sell logs that cannot be exported to a processing facility in the state. Actual data show the 

Forest Service routinely waives these requirements, and allows Viking and Alcan to ship 

increasing proportions of timber out of the region as unprocessed logs. As a result, the EIS 

DEIS Comments and Responses I-168 Final EIS
Appendix I

should disclose that exports often exceed the prescribed limits and consider the additional 

implications for local employment.

RESPONSE

The timber industry employment and income estimates presented by alternative in Table 3.22-18 are 

based on a range, from a maximum possible shipment out of state (export of all Alaska yellow cedar plus 

hemlock and Sitka spruce export equal to 50 percent of total sale net sawlog volume), to no shipment of 

hemlock and Sitka spruce and export of 100 percent of Alaska yellow cedar. As noted in the comment

and explained in the Limited Export Policy subsection of the Draft EIS, the Forest Service has allowed 

timber purchasers to exceed the maximum possible shipment on a case-by-case basis; and this could 

potentially happen again in the future. However, for the purposes of this programmatic analysis, it is 

reasonable to evaluate the upper limit as prescribed by the current version of the Limited Export Policy. If 

purchasers were allowed on a case-by-case basis to export a larger share of a particular sale in 

unprocessed form, there would be a commensurate reduction in sawmilling jobs and an increase in 

transportation-related jobs. A note explaining this possibility has been added to the Environmental 

Consequences part of the Economic and Social Environment section in the Final EIS. 

As noted in response to TEXP-1, financial efficiency analyses that will compare the export policy in place 

at the time and domestic processing will be conducted as part of the project-specific environmental 

analysis prepared as part of future timber sale projects. Project-specific analyses will also consider the 

employment and income impacts of the current timber export policy. The Limited Export Policy is 

discussed further in Appendix H.

COMMENT

TEXP-3: The young-growth transition must end the practice of allowing the export of taxpayersubsidized Tongass timber to compete with logs sold by private landowners on the export market. 

RESPONSE

As discussed in response to TEXP-1, a limited shipment policy was instituted on the Tongass National 

Forest during 2007. The policy modified how timber sales are appraised and allowed timber purchasers 

options on shipping certain small diameter logs from national forest timber sales to outside Alaska. This 

policy is subject to review and modification on an annual basis. 

The Forest Plan amendment is designed to analyze the feasibility of shifting from an old-growth forest 

management regime towards young growth management. How rapidly and effectively this is 

accomplished depends on local support from Alaska markets for young-growth forest products. The 

ability to export some timber beyond Alaska may serve as a strategic option that can be used to help 

maintain workforce skills, industry expertise, and the physical infrastructure needed to develop a future 

young-growth industry. The limited shipment policy will continue to be subject to review and modification 

on an annual basis, as noted above. The Limited Export Policy is discussed further in Appendix H.

COMMENT

TEXP-4: The Draft EIS does not evaluate the costs and benefits of the Limited Export Policy at all 

ecological, social, and economic scales.

RESPONSE

As discussed in response to TEXP-1, a limited shipment policy was instituted on the Tongass National 

Forest during 2007. The policy modified how timber sales are appraised and allowed timber purchasers 

options on shipping certain small diameter logs from national forest timber sales to outside Alaska. The 

limited shipment policy will continue to be subject to review and modification on an annual basis, as noted 

above. Changes to this policy are outside the scope of this Forest Plan EIS.

As noted in response to TEXP-1, financial efficiency analyses will be conducted as part of the projectspecific environmental analysis that will prepared as part of future timber sale projects. These analyses 

will take into account the limited export policy and/or other potential restrictions on export or production in 

place at that time. Project-specific analyses will also consider the employment and income implications of 

Final EIS I-169 DEIS Comments and Responses
Appendix I

the export restrictions in place or expected to be in place at that time. The Limited Export Policy is 

discussed further in Appendix H.

DEIS Comments and Responses I-170 Final EIS
Appendix I

Recreation and Tourism (R&T)

COMMENT

R&T-1: Tourism management is an important part of the region’s economy and integral to the 

Purpose and Need and to addressing the Secretary’s direction to make Forest management more 

ecologically, socially and economically sustainable and to consider diverse economies. The 

Forest Service should measure the jobs and economic contributions that recreation programs 

support in Southeast Alaskan communities. Tourism associations and businesses must be 

engaged as partners early in planning processes to build buy-in for projects. While tourism 

provides thousands of jobs and significant economic opportunity, the US Forest Service 

continues to decrease budgets for recreation, heritage, and wilderness programs. 

RESPONSE

The Draft EIS acknowledges the economic importance of tourism to the region as a whole, as well as at 

the borough and community level (see the Economic and Social Environment section of the Draft EIS). 

The amended Forest Plan responds to the July 2013 memo from the Secretary of Agriculture directing the 

Tongass National Forest to transition its forest management program to be more ecologically, socially, 

and economically sustainable, while also being responsive to comments from the Five-Year Review of the 

Forest Plan. This is explained further in the Purpose and Need section of the Draft EIS, starting at page 

1-4. See also the response to P&N-7. 

The US Forest Service recognizes the importance of supporting regional economic diversification – and 

the relationship between public land management and creating economic opportunities for Southeast 

communities. The draft Tongass National Forest Plan Monitoring Program directs the Forest Service to 

assess whether the forest plan is providing “a diversity of opportunities for resource uses that contribute 

to local and regional economies of Southeast Alaska.” The draft monitoring program further recommends 

studying employment trends for three primary industries – forest products, recreation and tourism, and 

seafood – on a biennial basis. This draft monitoring objective acknowledges the importance of the forest 

plan supporting a wide range of natural-resource employment opportunities across Southeast Alaska. 

Recreation and tourism management direction continues to be provided in the Forest-wide Standards and 

Guidelines for Recreation and Tourism (Forest Plan, Chapter 4), as well as the management prescriptions 

for each LUD (Forest Plan, Chapter 3). The Forest Service will continue to work with the timber industry 

and other government agencies, as indicated in the Forest Plan (see, for example, the Forest-wide 

Standards and Guidelines for Recreation and Tourism, including those that specifically address Tourism 

[p. 4-41]). 

Many factors affect the availability of public sector funds for multiple program areas. Consideration of 

funding strategies and resource allocation is outside the scope of this forest plan amendment and EIS. 

COMMENT

R&T-2: The DEIS inadequately considers saturation at recreation sites, impacts to recreation 

opportunities and places and the benefits from expanding recreation. The Plan’s suggestion that 

permit access be restricted in recreation places where demand exceeds supply is troubling as 

tourism businesses seek sustainable ways to grow. The Forest Service should consider 

prioritizing areas for recreation to address demand for recreation places exceeding supply, and 

recognize the significant undeveloped potential for tourism opportunities in small communities.

RESPONSE

The DIES acknowledged that demand appears to exceed supply in some recreation places, including 

bear-viewing areas and helicopter use in the immediate vicinity of urban areas (p. 3-347) and that 

management practices for specific areas will continue to be evaluated on a project-by-project basis and in 

accordance with the applicable Forest Plan standards and guidelines under all alternatives. Limiting 

access via permit is provided as an example of the type of management practice that would be evaluated 

in this way. The text is not intended to imply that the Forest Service plans to limit permit access as part of 

Final EIS I-171 DEIS Comments and Responses
Appendix I

this Forest Plan amendment. Forest Plan recreation and tourism management direction will continue to 

be provided in the Forest-wide Standards and Guidelines for Recreation and Tourism (Forest Plan, 

Chapter 4), as well as the management prescriptions for each LUD (Forest Plan, Chapter 3).

Expansion of recreation places is outside of the scope of the narrow scope of this amendment; however, 

the proposed changes do not preclude the consideration of recreation expansion in the future.

COMMENT

R&T-3: The US Forest Service has been directed, by Secretary Vilsack, to support communities 

and jobs while also making management more ecologically, socially, and economically 

sustainable. Tongass National Forest habitat supports wild salmon and the region supports a 

robust visitor industry. Despite a growing visitor industry, the US Forest Service continues to cut 

recreation program budgets that support the tourism industry, which is a socially, economically, 

and ecologically sustainable industry.

RESPONSE

In a memorandum dated July 2, 2013, USDA Secretary Tom Vilsack directed the US Forest Service to 

expedite the transition from old-growth to young-growth timber harvest while maintaining a viable timber 

industry that provides jobs and opportunities for Southeast Alaska residents. Secretarial Memorandum 

1044-99, Addressing Sustainable Forestry in Southeast Alaska, affirms the USDA’s intent and priority to 

transition the Tongass National Forest to a more ecologically, socially, and economically sustainable 

forest management, over the next 10 to 15 years, while maintaining a viable timber industry. The Draft 

EIS, as prepared by the US Forest Service, describes and analyzes proposed changes to the forest plan 

to accomplish the transition to young-growth management as provided by Secretarial Memorandum 

1044-99. While the memorandum encouraged a multifaceted approach to transitioning the Tongass 

National Forest, the primary focus is on transitioning the timber harvest program from predominantly oldgrowth to young-growth timber harvest while maintaining the timber industry. 

As noted in response to R&T-1, the US Forest Service recognizes the importance of supporting regional 

economic diversification – and the relationship between public land management and creating economic 

opportunities for Southeast communities. The draft Tongass National Forest Plan Monitoring Program

directs the Forest Service to assess whether the forest plan is providing “a diversity of opportunities for 

resource uses that contribute to local and regional economies of Southeast Alaska.” The draft monitoring 

program further recommends studying employment trends for three primary industries – forest products, 

recreation and tourism, and seafood – on a biennial basis. This draft monitoring objective acknowledges 

the importance of the forest plan supporting a wide range of natural-resource employment opportunities 

across Southeast Alaska. 

Many factors affect the availability of public sector funds for multiple program areas. Consideration of 

funding strategies and resource allocation is outside the scope of forest plan amendment. 

COMMENT

R&T-4: Recreation has long been subsidized by the timber industry through the construction of 

roads, docks, and other infrastructure. The Forest Service should identify the cost of providing 

recreation opportunities on the Tongass and use this information to assess recreation user fees 

in the form of charges per person for facility maintenance. 

RESPONSE

The Multiple Use - Sustained Yield Act of 1960 (or MUSYA) (Public Law 86-517) authorizes and directs 

the Secretary of Agriculture to develop and administer the renewable resources of timber, range, water, 

recreation and wildlife on the national forests for multiple use and sustained yield of the products and 

services. Roads and other infrastructure developed as part of the Forest Service’s timber program are 

used for multiple uses including recreation and tourism. 

DEIS Comments and Responses I-172 Final EIS
Appendix I

The Forest Plan and Draft EIS do not identify the costs of administering recreation or other programs. 

This information is, however, readily available to the public in the annual State of the Tongass National 

Forest report prepared by the Forest Service. The most recent version available online is for Fiscal Year 

(FY) 2013 (USDA Forest 2014). More recent information is available upon request. In FY 2013, the total 

budget for the Tongass National Forest was $64.1 million, including: $6.8 million (11 percent) allocated to 

Recreation, Heritage, and Wilderness Management; $11.4 million (18 percent) allocated to Forest 

Management; and $12.5 million (20 percent) allocated to Capital Improvements, Infrastructure 

Maintenance, and Trail Building and Maintenance.

Recreation Fees (Outfitter/Guides & Collection Support, Recreation Sites & Collection Support, and 

National Pass Sales & Collection Support) accounted for 61 percent ($3.2 million) of the total revenues 

received by the Tongass National Forest, with Recreation Service Receipts accounting for an additional 2 

percent ($0.1 million). Changes to existing user recreation fee structures are outside the scope of the 

proposed Forest Plan amendment. 

COMMENT

R&T-5: How much is spent annually on personnel required to administer recreation on the 

Tongass National Forest? How much is spent maintaining roads and other infrastructure for 

recreation? How much of the existing NFS road system is unsupported by timber or recreation 

maintenance funds and expected to be decommissioned? The Forest Plan should require 

recreation users to pay for road maintenance in areas that are not presently being harvested. The 

Forest Plan should address “more systematic timber harvest” that will generate a steady stream 

of funds to maintain the existing road system and allow for expansion for future young growth 

harvest. 

RESPONSE

As noted in response to Comment R&T-4, the state of the Tongass National Forest finances is reported 

each fiscal year and readily available to the public in the annual State of the Tongass National Forest 

report prepared by the Forest Service. The most recent version of this report available online is for FY 

2013 (USDA Forest 2014). More recent information is available upon request. In FY 2013, the total 

budget for the Tongass National Forest was $64.1 million, including: $6.8 million (11 percent) allocated to 

Recreation, Heritage, and Wilderness Management; $11.4 million (18 percent) allocated to Forest 

Management; and $12.5 million (20 percent) allocated to Capital Improvements, Infrastructure 

Maintenance, and Trail Building and Maintenance. Information related to road maintenance and 

proposed decommissioning on the Tongass National Forest is available in the Access Travel 

Management Plans prepared for each Ranger District. These plans are available at the District offices. 

As noted in response to Comment R&T-4, changes to existing recreation fee structures are outside the 

scope of the proposed Forest Plan amendment. In general, Congress appropriates funding for federal 

agencies and specifies how they may spend it. For the most part, increasing allowable harvest levels in 

the short-term would not necessarily generate additional funds for road maintenance. Increasing 

allowable harvest levels would also not be consistent with the Secretary’s Memorandum 1044-009, which 

directs the Tongass National Forest to transition away from old-growth timber harvesting and towards a 

forest industry that utilizes second growth – or young growth – forests. 

COMMENT

REC-5. Suggestions for specific recreation areas and trails.

RESPONSE

Modification or creation of specific recreation areas, trails, and related facilities is outside of the scope of 

this focused plan amendment. These types of changes are generally best determined at the local 

planning unit.

Final EIS I-173 DEIS Comments and Responses
Appendix I

Wild and Scenic Rivers (WSR)

COMMENT

WSR-1: There are currently no federal Wild and Scenic River designation in the Tongass and yet 

the Forest Service Management Plan specifies LUDS to protect these characteristic of 32 rivers 

that were previously recommended by the Forest Service for inclusion on this list. We do not 

support continued protection of these rivers under the current Wild, Scenic and Recreational LUD 

designations.

RESPONSE:

Changes to the Wild, Scenic and Recreational River LUDs is outside the narrow scope of this 

amendment. 

DEIS Comments and Responses I-174 Final EIS
Appendix I

Scenery (SCEN)

COMMENT

SCEN-1: The Forest Service should cease planning on components with lowered scenic integrity 

objectives.

We strongly object to the proposal to reduce scenic integrity objectives in Alternatives 2, 3, and 5. The 

NFMA directs that the forest planning process include a review of the esthetic impacts of clearcutting, and 

ensure that clearcuts do not conflict with esthetic resources or recreation. [16 U.S.C. § 1604(g)(3)(F)]. 

NEPA’s policy purposes similarly include a goal of assuring “esthetically .. pleasing surroundings.” [42 

U.S.C. § 4331(b)(4)]. The proposed LRMP would create a patchwork of 10 acre clearcuts in the beach 

fringe and allow removal of up to 35% of a stand. [LRMP at 5-8]. The result would be a visual landscape 

that “appears heavily altered.” [DEIS at 3-352].

The beach fringe clearcuts do not meet NFMA’s standards. The DEIS recognizes that “Southeast Alaska 

possesses a remarkable and unique combination of features” that attract visitors and that “[m]ost visitors 

who travel long distances to see Alaska expect to find it in a wild and “unspoiled state.” [FEIS at 3-321]. It 

further explains that:

Demand for scenic quality can best be represented by the increase in tourist related travel to the 

Tongass, as well as a heightened awareness and sensitivity to scenic resource values. These facts 

result in a strong indirect connection between scenic resource values and the economy of southeast 

Alaska. For example, Southeast Alaska’s Inside Passage is advertised by the Division of Tourism, cruise 

ship operators, and the Southeast Alaska Tourism Council. Their marketing strategy focuses on the 

scenery of the Tongass National Forest as a major attraction. The visitors to Southeast Alaska would 

therefore, arrive with expectations and an image of the environment and scenery awaiting them. If current 

trends continue, demand for viewing scenic landscapes will increase. [Id. at 3-354].

Further, “[t]he ability to market Alaska tourism is dependent on meeting customer expectations of seeing 

and experiencing vast, untamed land and its wildlife.” [FEIS]. Given these findings, it is arbitrary to 

degrade these valuable scenic landscapes in order to remove low value timber that can be obtained 

elsewhere. The discussion in the DEIS is not adequate to disclose the effects of this major change. It 

carries over the analysis from the 2008 TLMP FEIS and changes the numbers and the alternatives and 

uses the exact same locations as points of reference. It does not link the reduced scenery with areas 

identified as Visual Priority Routes – a process that took extensive professional work. If the Forest 

Service continues to proceed with this change, we believe that Tongass National Forest landscape 

architects should prepare the analysis and a resource report. A distant contractor punching in numbers 

into a previous analysis does not show the public the true visual impacts.

We would prefer, however, that the Forest Service eliminate this component of the LRMP. The proposed 

LRMP’s scenery goal has two parts. It first provides that the Forest Service is to “[P]rovide Forest visitors 

with visually appealing scenery, with emphasis on areas seen from the Alaska Marine Highway, tour ship 

and small boat routes, state highways, major Forest roads, and population recreation places.” [LRMP at 

2-4]. But then, it provides that the Forest Service should “[r]ecognize that there will be areas where these 

landscapes are altered by management activities, particularly young-growth timber harvest, and the 

activity may visually dominate the characteristic landscape.” [Id.]. We recommend that you delete this 

second sentence, and the entire Beach Fringe component of the Proposed Plan.[LRMP at 5-8].

The Beach Fringe logging component is also inconsistent with the proposed LRMP goal for recreation to 

“[p]rovide a range of recreation opportunities consistent with public demand, emphasizing locally popular 

recreation places and those important to the tourism industry.” [LRMP at 2-4]. The DEIS describes 

recreation generally, and recognizes that it largely involves marine transportation to bays and along water 

ways. [DEIS at 3-326-335]. It describes generally some activities that have a low tolerance for other 

groups, or incompatible activities occurring in close proximity. [Id.] But it never consider the extent to 

which logging in particular is an incompatible activity that may discourage not only shoreline recreation, 

but even one of the most critical pieces of the tourism business – the returning customer.

Final EIS I-175 DEIS Comments and Responses
Appendix I

RESPONSE

The alternatives show a range of SIOs for analysis. This range was developed in order that a range of 

young-growth harvests could be evaluated, especially during the early years with the idea that lower SIOs 

could help speed up the transition. Any young growth harvest will still require a NEPA analysis at the 

project level, so impacts to scenery will still be analyzed and disclosed on a project-by-project basis. 

Public involvement will also be a part of any future project.

Any clearcuts implemented in the suitable land base, including beach fringe, would meet NFMA 

requirements.

The analysis is linked to the analysis conducted for the 2008 TLMP FEIS so the reader can compare and 

contrast the visual effects represented in the 2016 alternatives with the visual effects of the 2008 

alternatives. This consistency allows the reader to understand how management is changing over time. 

The analysis does involve all the VPRs on the Forest; Distance Zones and SIOs are both related to 

VPRs. This is a programmatic EIS; individual VPRs will be analyzed when projects are proposed in 

project-level NEPA analyses.

The Tongass Landscape Architects recommended the change to the Scenery goal (referenced as LRMP 

2-4) by adding “particularly young-growth timber harvest” to reflect the emphasis that has been given to

young-growth harvest by Leadership.

COMMENT

SCEN-2. Scenic Integrity Objectives are prejudicial and inconsistent with many local values going 

back generations. 

RESPONSE

Changes to the definitions of scenic integrity objectives, are outside of the narrow scope of this Forest 

Plan amendment. In this amendment, changes are made only to where SIOs are applied, reducing the 

level of scenic integrity in areas of renewable energy and young growth harvest to Low and Very Low. 

Scenic integrity terminology (High, Moderate, etc.) is not prejudicial, and refers to the level of the integrity, 

or intactness, of the landscape. It does not refer to a priority or value of the scenery. Scenic Integrity 

levels are defined within Agricultural Handbook Number 701, “Landscape Aesthetics: A Handbook for 

Scenery Management”, which is required to be used on all U.S. Forest Service lands and is not specific to 

the Tongass National Forest. Constituent analysis is a part of the Scenery Management system, with 

constituents not only being the local population of an area, but the entire American public.

COMMENT

SCENE-3. Suggestions for changes to Visual Priority Routes in Appendix F.

RESPONSE

Changes to Visual Priority Routes is outside the scope of this focused plan amendment.

DEIS Comments and Responses I-176 Final EIS
Appendix I

Roadless Areas (RDLS)

COMMENT

RDLS-1: Forest Service Should Change the Amendment’s Appendix A to Permanently Exclude 

Roadless Areas from Lands Suitable for Timber Production.

It appears that the Draft Forest Plan is intended to keep Inventoried Roadless Areas off limits to logging in 

its own right, regardless of the fate of the Roadless Area Conservation Rule in two pending court actions 

or in any future amendments to or litigation over that rule. Commenters appreciate this important 

amendment and strongly urge the Forest Service to adopt a final plan amendment that protects roadless 

areas from logging. The Forest Service should clarify this intent in Appendix A of the Proposed Forest 

Plan, the suitable lands analysis. That analysis identifies Inventoried Roadless Areas as not suitable for 

timber production on legal grounds in “Step 1,” since logging on those lands is prohibited by the Roadless 

Rule. 22 This is correct, but it should be made clear that even if the Roadless Rule were struck down by a 

court, or amended by USDA, the intent of this forest plan amendment is to preclude logging in roadless 

areas, as stated in the DEIS. Therefore, the “Step 2” analysis should specify that Inventoried Roadless 

Areas would be deemed not suited for timber production even if they lost their protection under Step 1.

RESPONSE

The intent behind the suitability analysis for this Forest Plan amendment is to identify lands that are 

suitable for timber production. As the 2001 Roadless Area Conservation Rule (Roadless Rule) generally 

prohibits commercial timber harvest in Inventoried Roadless Areas (IRAs), the IRAs on the Tongass 

National Forest are considered not suited for timber production. The designation of these lands as 

unsuitable in Step 1 meets the intent of FSH 1909.12, Section 61.1.1. 

FSH 1909.12, Section 61.2 provides guidance on determining, from those lands identified as tentatively 

suitable in Step 1, the lands that are suitable for timber production based on all the multiple-use 

objectives for the forest. As the lands within the IRAs on the Tongass National Forest are no longer 

considered tentatively suitable for timber production, there is no need to review their suitability under Step 

2 of this process. 

COMMENT

RDLS-2: Support for Updated Roadless Inventory and Rulemaking to Remove “Roaded Roadless” 

from the Inventory.

We had hoped the agency would use this amendment process to support additional rulemaking and 

update the 2001 roadless area inventory. Such an update would have removed the so-called “roaded 

roadless” from the inventory, areas that were roaded before the 2001 Roadless Rule or during the eight 

years the Tongass was exempted from the 2001 Roadless Rule. A rule change would also conserve 

roughly 500,000 acres of roadless wildlands under the 2001 Roadless Rule excluded from the Tongass 

roadless inventory used for developing the 2001 Roadless Rule because of assumed logging 

development that never occurred. Such action would conserve remaining intact old-growth habitat,

maintain existing carbon stocks, and increase carbon stored. 

RESPONSE

Alternative 2 considered harvest within “roaded roadless” subject to rule making.

This amendment to the Tongass Forest Plan is using the IRA boundaries identified in a set of maps 

associated with the Final EIS for the Forest Service Roadless Area Conservation Rule, Volume 2, dated 

November 2000. These maps identify 9.2 million acres in IRAs on the Tongass, and correspond closely 

with the 1996 roadless area inventory that was prepared for the 1997 Forest Plan Revision (USDA Forest 

Service 1997c). 

COMMENT

RDLS-3: Application of 2001 Roadless Rule Requires Clarification.

Final EIS I-177 DEIS Comments and Responses
Appendix I

Chapter 1 of the DEIS states that “the Tongass has been subject to the Roadless Rule since 2011 and 

remains so today.” DEIS at 1-4. The framework for Alternative 5 states “this alternative would allow oldgrowth harvest only within Phase 1 of the timber sale program adaptive management strategy." Since the 

Phase 1 portion of the timber base included some Inventoried Roadless Areas, please clarify that this 

statement only applies to the developed portion of the Phase I base.

RESPONSE

In Chapter 2 of the FEIS, the Framework and Expected Outcomes section for Alternative 5 clarifies that, 

“(a)s in Alternatives 1 and 4, the 2001 Roadless Rule would apply and no old-growth or young-growth 

harvest would occur in roadless areas.” Thus, it is clear that no harvest is allowed in those Inventoried 

Roadless Areas identified in the maps associated with the Final EIS for the Forest Service Roadless Area 

Conservation Rule, Volume 2, dated November 2000. Table 2-14 in Chapter 2 of the FEIS also shows 

that no harvest is allowed in Inventoried Roadless Areas in Alternative 5.

COMMENT

RDLS-4: Inventoried Roadless Areas Need to be Maintained.

We support the preferred alternative’s adherence to the Roadless Area Conservation Rule given that 

inventoried roadless areas provide unique ecosystem, wildlife, and climate benefits to the national forest 

systems18. Alternatives 3 and 4 would violate the roadless rule and should be dismissed on those 

grounds alone. The idea that this administration might undo landmark protections like this is genuinely 

unacceptable.

RESPONSE

We believe Alternative 3 is reasonable. The State of Alaska’s challenge to application of the 2001 

Roadless Area Conservation Rule (Roadless Rule) in Alaska is pending in the District of Columbia District 

Court. Alternative 3 would allow young-growth and old-growth harvest in 2001 Roadless Rule IRAs. If this 

alternative were selected, harvest in IRAs would be deferred until agency rulemaking modified 36 CFR 

294(b)(4)(2001). 2001 IRAs are removed from lands suitable for timber production in Alternative 4.

However, three of the alternatives analyzed in detail (Alternatives 1, 4, and 5) allow no harvest in roadless 

areas.

COMMENT

RDLS-5: Decisions regarding resource development within Inventoried Roadless Areas should be 

delegated to the local Forest or District. 

The May 2009 Decision by Secretary of Agriculture, Tom Vilsack, to arrogate to himself all decisions 

regarding resource development in IRAs in the Tongass National Forest (now delegated to the Chief of 

the Forest Service), added national politics to decision making on such issues as issuance of a Special 

Use Permit; a decision that had previously been made by the Tongass Forest Supervisor and District 

Rangers. The Secretary’s control of what had been local decision making on the Tongass has drastically 

altered the assumptions upon which the Forest Plan was promulgated in January 2008. For example, 

even were the

Tongass still exempt from the 2001 Roadless Rule, the Washington Office of the Forest Service could 

refuse to allow a project that is in an IRA to go forward for political reasons. The Chief of the Forest 

Service should re-delegate to the Forest Supervisor and District Rangers on the Tongass the authority to 

make permitting decisions within IRAs.

RESPONSE

This recommendation is outside to the decision authority of the Forest Supervisor, the Responsible 

Official for this decision.

DEIS Comments and Responses I-178 Final EIS
Appendix I

Specific Comments on the Forest Plan and DEIS (SPEC)

COMMENT

SPEC-1: Forest Service Should Reinstate the Deleted Beach and Estuary Management Standards 

and Guidelines.

RESPONSE

The amended plan includes changes specific to young-growth forest management. The beach and 

estuary fringe standards and guidelines (BEACH 2, III. Management, 6 and 7) in Chapter 4 were removed 

as part of this amendment because the standards and guidelines were changed as a result of updating 

the suitability of lands as it pertains to lands suitable for young-growth timber production. Under 

Alternatives 2, 3 and 5, young-growth stands within the beach and estuary fringe are identified as suitable 

for timber production. The applicable standards and guidelines were deleted from Chapter 4 and rewritten 

and replaced by forest-wide standard (S-BEACH-01) in Chapter 5 to reflect that lands in the beach and 

estuary fringe are not suitable for old-growth timber production.

COMMENT

SPEC-2: The Forest Service should reinstate the deleted karst resources standards and 

guidelines in Chapter 4 of the Forest Plan.

RESPONSE

The amended plan includes changes to young-growth forest management. The karst standards and 

guidelines (KC1, IV. Young Growth Management on Karst) in Chapter 4 were removed, rewritten, and 

added to the young-growth direction in Chapter 5.

COMMENT

SPEC-3: The Forest Service should reinstate the timber sale preparation standards and 

guidelines in Chapter 4 of the Forest Plan.

RESPONSE

Some language that is covered in Forest Service directives (e.g., Forest Service Manual, Forest Service 

Handbook) and direction used at project level planning was deleted from the DEIS version of the Forest 

Plan. We added content at the beginning of Chapters 3, 4 and 5 of the Forest Plan to state that the 

chapter assumes all laws, regulations, and policy pertaining to management of National Forest resources 

will be followed. We added much of this language back in for the FEIS version of the Forest Plan.

COMMENT

SPEC-4: The Forest Service should reinstate the road and bridge reconstruction – location and 

design, standards and guidelines in Chapter 4 of the Forest Plan. 

RESPONSE

In the Transportation section in Chapter 3 of the DEIS (affected environment), a description was provided 

regarding the intent of the road construction to provide access to NFS lands. In these introductory 

paragraphs, the road maintenance level system is also described. In Chapter 4 of the Forest Plan in the 

Transportation section, the standards and guidelines provide direction for Transportation Planning in 

TRAN 3, Road and Bridge reconstruction in TRAN5, and the maintenance levels in TRAN 6 and TRAN 7. 

The aspects of location are not relative since the roads exist; however, some of the mechanisms for 

reconstruction relative to slope stability and reconstruction of stream crossing features as well as bridge 

abutments could be included.

Final EIS I-179 DEIS Comments and Responses
Appendix I

COMMENT

SPEC-5: The young growth desired condition DC-YG-04 in Chapter 5 of the Forest Plan should be 

rewritten. Accelerating old-growth characteristics in Riparian Management Areas (RMAs) and the 

beach fringe through young-growth harvest has not been scientifically demonstrated. Ten-acre 

clearcuts are not similar to natural disturbance patterns and would: 1) set back decades of 

progress toward mature, uneven-aged stand structure; 2) further fragment the older young growth 

that now exists; and 3) compromise the integrity of the old growth Conservation Strategy. 

RESPONSE

To meet the purpose and need, the forest identified the oldest young-growth stands as lands suitable for 

timber production to begin the transition away from old-growth harvest. Some of the oldest young-growth 

stands are located in RMAs and the beach fringe, where past harvest occurred, but where the current 

Forest Plan prohibited commercial harvest. The alternatives analyzed in the FEIS include various levels 

of young-growth harvest in these areas as well as a range of potential treatment types. Additionally, 

young-growth direction (i.e., plan components and management approaches) for the beach and estuary 

fringe are applied so as to minimize impacts to these areas while also allowing some of the oldest trees to 

be harvested in support of the transition. All project-level decisions implementing the 2016 Forest Plan 

must be consistent with the plan components. 

Effects to the old-growth forest ecosystem are disclosed in the FEIS in the Biodiversity section in Chapter 

3, and Appendix D for the FEIS specifically discusses effects to the old-growth Conservation Strategy.

See response to FISH-5. 

COMMENT 

SPEC-6: The Forest Service should change young growth suitability SUIT-YG-01 in Chapter 5 of 

the Forest Plan. The Old-growth Habitat LUD should not be identified as suitable for young-growth 

timber production because it lacks scientific justification.

RESPONSE

As stated in Chapter 2 of the FEIS (How the 2012 Planning Rule Applies), the responsible official has 

determined that for this amendment only a part of the substantive provisions of 36 CFR 219.11 apply for 

this amendment. Using the provisions of 36 CFR 219.11(a), specific young-growth stands are identified 

as suitable for timber production. Such stands include young growth in the beach and estuary fringe, 

riparian management areas, and in the Old-Growth Habitat LUD.

COMMENT

SPEC-7: The Forest Service young-growth objective O-YG-01 in Chapter 5 of the Forest Plan 

should be changed to end old-growth clearcutting in no more than five years.

RESPONSE

See responses to P&N-1 and ALT-4. Young-growth objective O-YG-01 in the Forest Plan was written to 

be a concise, measurable, and time-specific statement of a desired rate of progress toward a desired 

condition or conditions. That is to effectuate this transition, over the next 10 to 15 years, preserving a 

viable timber industry and allowing the forest industry time to adapt so that at the end of this period the 

vast majority of timber sold by the Tongass (i.e., gradually increase to exceed 50 percent of the timber 

offered annually) will be young growth. 

COMMENT

SPEC-8: The young-growth objective O-YG-02 in Chapter 5 of the Forest Plan should be re-written 

to end to old-growth clearcutting before the end of the amended plan's lifespan, and preferably 

within five years, as one milestone within the overall 15 year transition. 

DEIS Comments and Responses I-180 Final EIS
Appendix I

RESPONSE

See responses to P&N-1, ALT-4, ALT-5, ALT-11, and SPEC-7.

COMMENT

SPEC-9: Forest Service should make the following changes to plan components for Wildlife in 

Chapter 5 of the Forest Plan.

9a The young-growth desired condition for wildlife DC-YG-WILD-01 in Chapter 5 of the Forest Plan 

should be changed to exclude active management of young-growth stands within the Old-growth 

Habitat LUD. The Old-growth Habitat LUD was set aside for ecological reasons and infringing 

onto those areas is not consistent with meeting social and economic needs. This LUD is a crucial 

component of the old-growth Conservation Strategy, and entering this LUD for young-growth 

timber production erodes the effectiveness of the Conservation Strategy and places undue risk on 

particular wildlife populations.

RESPONSE

See responses to CONS-1, PLR-1, PLR-2 and SPEC-6.

The Old-Growth Habitat LUD does play an important role in the overall Conservation Strategy. The OldGrowth Habitat LUD remains not suited for old growth timber production as in the 2008 Forest Plan. In 

some instances, young growth is within the boundary of this LUD and may not be fully functioning for 

wildlife needs. DC-YG-WILD-01 allows for young growth management within this LUD as long as habitat 

and connectivity is maintained and the treatment can move the stand toward old-growth characteristics. 

The Forest Plan also allows for an Old-Growth Habitat LUD to be modified to exclude young growth 

proposed for harvest if a net gain in old growth can be achieved through the boundary modification and 

Appendix K criteria can be met (see management prescriptions).

COMMENT

9b. The young-growth desired condition for wildlife DC-YG-WILD-02 in Chapter 5 of the Forest 

Plan should be rewritten. Ten-acre clearcuts do not emulate the natural scale and distribution of 

disturbance patterns, and there is no science to support this. The Forest Service should consider 

restoration treatment methods that would increase habitat value in second-growth forests, such 

as removing 1-3 trees in widely spaced gaps. 

RESPONSE

See response to SPEC-6.

Desired conditions describe specific social, economic, and/or ecological characteristics of the plan area, 

or a portion of the plan area, toward which management of the land and resources should be directed. 

Desired condition DC-YG-WILD-02 ensures that young-growth treatments in the Old-growth Habitat LUD 

do not foreclose the opportunity to maintain or achieve natural scale and distribution of disturbance 

patterns over the long term. Young-growth standard S-YG-WILD-01 constrains the maximum size of 

openings to not exceed 10 acres. Specific harvest prescriptions will be determined at the project level 

after site-specific analysis by an interdisciplinary team of resource specialists. Project decisions must 

describe how the project is consistent with plan components, including meeting the desired conditions 

(see DC-YG-WILD-01 and DC-YG-WILD-02) if young-growth harvest is taking place in an Old-Growth 

Habitat LUD. 

COMMENT

9c. Young-growth objective for wildlife O-YG-WILD-01 and young-growth standards for wildlife SYG-WILD-01 and S-YG-WILD-02 in Chapter 5 of the Forest Plan should be removed because the 

Old-growth Habitat LUD should not be entered for young-growth harvest. 

Final EIS I-181 DEIS Comments and Responses
Appendix I

RESPONSE

See response to SPEC-6. 

Objectives are measurable and time-specific statements to indicate the desired rate of progress toward 

desired conditions. Objective O-YG-WILD-01 estimates the number of acres to be treated over a 15 year 

time period to promote the development of old-growth characteristics within the LUD, and ensures that 

young-growth treatments in the Old-growth Habitat LUD do not foreclose the opportunity to maintain or 

achieve the development of old-growth characteristics over the long-term. 

Standards are mandatory constraints on project and activity decision-making, established to help achieve 

or maintain the desired condition or conditions, to avoid or mitigate undesirable effects, or to meet 

applicable legal requirements. This standard provides the constraints on commercial young-growth 

harvest to help achieve or maintain old-growth characteristics within the Old-growth Habitat LUD.

Standard S-YG-WILD-01 does not require the Old-Growth Habitat LUD to be entered nor does it require 

10 acre openings. Rather, it constrains the maximum opening size and percent of stand removal. Every 

project analysis will use an interdisciplinary approach to review site-specific conditions and determine the 

harvest prescription that will best meet the desired conditions. Similarly, Standard S-YG-WILD-02 does 

not require the Old-Growth Habitat LUD to be entered. If a project proposes commercial young-growth 

harvest in this LUD, this standard provides a constraint for a one-time entry within the first 15 years of 

Plan approval, unless there is a compelling need to do so based on the best available science and to 

meet the LUD objectives. (Consult Chapter 3 Old-Growth Habitat LUD objectives.) In addition, an OldGrowth Habitat LUD with proposed young-growth harvest may be modified using Appendix K criteria, 

using an interagency review process, to exclude the proposed young-growth and include a net gain of 

old-growth from the adjacent landscape. (See Wildlife Management Approaches.) 

COMMENT

9d. The young-growth goal for wildlife G-YG-WILD-01 in Chapter 5 of the Forest Plan should be rewritten to state that no new roads should be built in the Old-growth Habitat LUD.

RESPONSE

The management prescription for the Old-growth Habitat LUD includes standards and guidelines for 

transportation (see Old-growth Habitat LUD Transportation Operations: TRAN in Chapter 3). Since the 

Old-growth Habitat LUD has been identified as suitable for young-growth timber production in the 

amended plan (see response to SPEC-6), goal G-YG-WILD-01 was written to ensure that roads used to 

access young-growth were kept to a minimum. Projects or activities must be consistent with this goal, as 

well as all other applicable plan components, such as DC-YG-WILD-01. 

COMMENT

SPEC-10. Forest Service should make the following change to the plan component for 

Transportation Systems Corridors Direction in Chapter 5 of the Forest Plan.

The Transportation Systems Corridors objective O-TSC-01 should focus on improvements to 

existing travel corridors rather than new roads in areas with high road density. This is particularly 

an issue in areas on Prince of Wales Island where wolf mortality has increased in proportion to 

road density. 

RESPONSE

Objectives are measurable and time-specific statements to indicate the desired rate of progress toward 

desired conditions. Objective O-TSC-01 is tied to Forest Desired Condition DC-03 in Chapter 5 of the 

Forest Plan.

The purpose of transportation systems corridors is to facilitate the availability of National Forest System 

lands for the development of existing and future transportation systems corridors such as those identified 

by the State of Alaska’s Southeast Alaska Transportation Plan and applicable laws (for example, Section 

DEIS Comments and Responses I-182 Final EIS
Appendix I

4407 of P.L. 109-59, Title XI of the Alaska National Interest Lands Conservation Act, P.L. 96-487). These 

transportation system corridors are not part of the forest transportation system (see Chapter 7 glossary), 

such as roads that are used for timber harvest. 

At the project level, an interdisciplinary team of resource specialists analyzes the site-specific resource 

concerns such as road density and provides that information to the public and the responsible official 

(decision-maker) to determine the best course of action, which may include relevant mitigation measures.

COMMENT

SPEC-11: Forest Service should add a standard and goal for Transportation Systems Corridors 

direction in Chapter 5 of the Forest Plan.

11a. The Forest Service should aim for no net gain in roads and add a standard for wildlife to the 

Transportation Systems Corridors direction in Chapter 5 of the Forest Plan to maintain road 

densities within Wildlife Analysis Areas (WAAs) at less than 0.7 mi/mi2. If a new road goes into a 

particular WAA, the Service should close or decommission the equivalent road mileage within the 

same WAA. 

RESPONSE

The Transportation Systems Corridors direction in Chapter 5 of the Forest Plan does not address the 

forest transportation system (see definition in Chapter 7 glossary). Chapter 4 of the Forest Plan includes 

Transportation standards and guidelines (see Transportation Improvement Planning: TRAN3; Road 

Maintenance: TRAN6; and Road Decommissioning: TRAN7), but there are no WAA road density 

thresholds. 

The Transportation section in Chapter 3 of the FEIS (affected environment) describes the intent of the 

road construction to provide access to NFS lands. There is a discussion of road density and WAAs 

included in the Wildlife section in Chapter 3 of the FEIS (environmental consequences) and Table 3.10-12 

compares by alternative the estimated average road density and percent of WAAs in road density 

categories on National Forest System lands and all lands combined, and a measurable increase is not 

anticipated. 

Road closures are determined through an access travel management plan and project level planning 

efforts.

Standards and Guidelines are included under the primary resource that is driving that particular standard. 

In this case, the suggested standard and guideline are primarily a wildlife concern not a transportation 

concern. WILD1.XIV.A.1(c) on page 4-88 includes a similar road density in areas where wolf mortality 

concerns have been identified and road access was determined to be a significant contributing factor. An 

interagency Wolf Technical Committee has been established and is currently working on issues related to 

wolf management concerns. 

COMMENT

11b. A goal for wildlife should be added to Transportation Systems Corridors direction in Chapter 

5 of the Forest Plan to maintain the ability for wildlife to withstand illegal hunting pressure and 

should depend on limiting WAAs to road densities of less than 0.7 mi/mi2. In WAAs that already 

exceed the 0.7 mi/mi2 threshold, the Forest Service should actively close and decommission 

roads in order to alleviate the hunting access pressure in those areas, paying special attention to 

GMU 2.

RESPONSE

This request is outside of the scope of this focused amendment. Road management decisions are best 

made at the local planning unit in response to specific conditions. This type of change is best considered 

during a revision. It is notable, however, that road densities are expected to grow at a much lower rate 

than were predicted by the 1997 Forest Plan, under which the Conservation Strategy and species viability 

Final EIS I-183 DEIS Comments and Responses
Appendix I

were evaluated. The same is true of the level of old growth remaining after 100 years, being 

substantially greater under the current amendment alternatives than under the 1997 Forest Plan.

COMMENT

SPEC-12: Regarding the forest wide timber objectives O-TIM-01 and O-TIM-02 in Chapter 5 of the 

Forest Plan, the Forest Service should articulate a schedule for decreasing old-growth timber to 

ensure an end to old-growth clearcut logging before the end of the Plan, and preferably within 5 

years of the Plan's implementation. Any post-transition harvest of old growth should be 

accomplished by single or small group tree selection rather than clearcutting. The overall forest 

transition may require moving away from even-flow timber harvest, allowing greater flexibility in 

annual harvest quotas.

RESPONSE

The Forest Plan is a broad plan that defines the appropriate uses in the Forest, sets overarching goals 

and objectives for the land use designations on the forest. The Forest Plan also sets forth desired 

conditions that describe specific social, economic, and/or ecological characteristics of the plan area, or a 

portion of the plan area, toward which management of the land and resources should be directed. 

Specific prescriptions are developed at the stand level that are designed to meet forest plan goals and 

objectives, to move the stand towards a desired condition while considering the stand’s current condition. 

Developing specific prescriptions at a Forest Plan level may not allow for flexibility at the stand level to 

account for the unique conditions that can be found at the stand level.

See response to Alt-4 and SPEC-7.

COMMENT

SPEC-13: The beach and estuary fringe, RMAs, and the Old-Growth Habitat LUD should be 

changed to not suitable for timber production in Appendix A of the Forest Plan. 

RESPONSE

See response to SPEC-6.

Appendix A represents Alternative 5 (preferred alternative) and reflects final TAC recommendations 

(Forest Plan Appendix B). The TAC recommendations included commercial young-growth harvest in 

these areas. Appendix A in the Forest Plan has been updated and identifies lands as not suitable for oldgrowth timber production in the beach and estuary fringe, RMAs, and Old-Growth Habitat LUD, but 

suitable for young-growth timber production in these areas.

COMMENT

SPEC-14: The Forest Service should clarify the language in the forest plan regarding the status of 

lands in development LUDs that are not suitable for timber production, as well as other areas, 

such as The Nature Conservancy/Audubon priority conservation areas that are not suitable for 

timber production. 

RESPONSE

Appendix A of the Forest Plan has been updated to reflect the preferred alternative and clarifications have 

been made.

COMMENT

SPEC-15: Incorrect potential entitlement for 5 new urban Native corporation – total acres is 

115,000, not 184,320. 

DEIS Comments and Responses I-184 Final EIS
Appendix I

RESPONSE

The potential entitlement is 115,200 acres and the correction will be made. The text of the Senate Bill 

S.872 introduced on 3/26/2015 reads as follows:

“SEC. 43. URBAN CORPORATIONS FOR HAINES, KETCHIKAN, PETERSBURG, TENAKEE, AND 

WRANGELL.

“(a) OFFER OF COMPENSATION.—

“(1) IN GENERAL.—On incorporation of the Urban Corporations for Haines, Ketchikan, Petersburg, 

Tenakee, and Wrangell, the Secretary, in consultation and coordination with the Secretary of Commerce, 

and in consultation with representatives of each such Urban Corporation and the Regional Corporation for 

Southeast Alaska, shall offer as compensation, pursuant to this Act, 1 township of land (23,040 acres) to 

each of the Urban Corporations for Haines, Ketchikan, Petersburg, Tenakee, and Wrangell, in 

accordance with this subsection.”

COMMENT

SPEC-16: As the dominant strategy for managing young-growth forests within old-growth habitat 

reserves, the Forest Service should develop an “old-growth restoration” management 

prescription that has been scientifically well vetted with a panel of experts. 

RESPONSE

The Forest Plan is a broad plan that defines the appropriate uses in the Forest, sets overarching goals 

and objectives for the land use designations on the forest. The Forest Plan also sets forth desired 

conditions for each of the Specific prescriptions are developed at the stand level that are designed to 

meet forest plan goals and objectives, to move the stand towards a desired condition while considering 

the stand’s current condition. Developing specific prescriptions at a Forest Plan level may not allow for 

flexibility at the stand level to account for the unique conditions that can be found at the stand level.

The Forest has implemented several scientifically rigorous studies that are designed to quantify how 

various prescriptions can meet specific objectives that are designed to improve wildlife habitat and move 

a stand towards old-growth conditions. The Tongass-wide Young-Growth Study (TWYGS) was begun in 

2001. TWYGS is helping increase the knowledge of thinning and response of tree and plant vegetation. 

The plan is expected to continue for 20-30 years, if funding and support continue. The results of TWYGS 

should increase our knowledge of effects of thinning, inter-planting alder, pruning, girdling, and slash 

treatment for various objectives, including wildlife habitat improvement, and timber production. 

The Prince of Wales Commercial Thinning Study was awarded as an integrated resources service 

contract at the end of FY2008. This study looks at 5 different commercial thinning prescriptions that offer 

a range of potential treatments that could be used on the Tongass. The 5 different prescriptions were 

implemented at three replicates: near Harris River, in the Maybeso Experimental Forest, and near 

Naukati. The objectives of the study are to assess how mechanized equipment operates, how the 

different prescriptions hold up to SE Alaska’s weather, and what the understory response is after 

treatment. Long-term monitoring is helping to understand how a treated stand moves towards achieving 

old-growth structure.

COMMENT

SPEC-17: Young-growth harvest in RMAs (in or outside TTRA buffers) should only be allowed for 

habitat enhancement (e.g., to accelerate stand development toward old-growth conditions). One of 

the key processes and characteristics of old growth that is critical for the riparian zone is the 

creation of coarse woody debris inputs to streams which create diverse and structurally important 

habitats for aquatic invertebrates and fish. Using wide spaces in thinning treatments can more 

quickly grow large trees, which would provide these critical structures.

Final EIS I-185 DEIS Comments and Responses
Appendix I

RESPONSE

In order to meet the timeline for the young growth transition as outlined in the undersecretary’s memo, all 

young growth lands were considered. Since the age of the young growth stands is a limiting factor, the 

oldest stands of young growth are being considered for harvest to facilitate the transition. If the oldest 

young growth stands are not included in the earliest phase of the transition, it is highly unlikely we could 

meet the purpose and need of the amendment. Therefore, old growth timber harvest would continue for a 

longer time period. 

Most of the large woody debris recruited to stream channels would occur from the TTRA buffer. However, 

some reduction in woody debris in stream channels could occur in RMAs outside of the TTRA buffer 

depending on alterative. Riparian Management objectives would be maintained as proposed under 

Alternatives 1, 3, and 4. Alternatives 2 and 5 require that management in young growth riparian areas 

accelerate old-growth characteristics to improve riparian function, but would allow some harvest in younggrowth outside of TTRA buffers (refer to Water section). Alternative 2 allows only for commercial thinning 

of up to 33 percent of stand basal area over more than 36,000 RMA acres. This Alternative would likely 

have additional adverse effects to fish habitat not common to the other alternatives and could result in a 

loss of large woody debris to portions of floodplain and alluvial fan channel types. While Alternative 5 

allows up to 10 acre open area cuts and commercial thinning totaling no more than 35 percent of the total 

stand acres, it is restricted to less than 900 acres of total harvested RMA area and will only occur in the 

first 15 years of the finalization of the Plan Amendment. With these restrictions, the overall areas affected 

would be small relative to the total available in the Tongass. A watershed analysis (as described in 

Forest Plan Appendix C) would be needed for implementing any alternative that proposed to enter the 

RMA. Per Plan Chapter 5 Management Approaches for Riparian, it is expected that the first priority for 

wood removed from RMAs will be to support local stream restoration needs. 

COMMENT

SPEC-18: Specific Comments on Economic and Social Environment section of DEIS.

Nowhere in the Economic and Social Environment section on wood products is there any 

discussion on the cost to harvest and produce a manufactured product, either lumber or biomass 

(see lumber price graph). Please provide this missing information. Based on information on page 

3-481 revenue estimates were made in the document. Based on this information when combining 

estimated yearly revenue for all timber sale within an alternative, as shown in text figures, results 

in some years projected into the future with negative revenue. Negative revenue would violate 

federal laws for federal timber sales. The estimated revenue values used for timber sales also 

does not include subsidies that the Forest Service contributes through sale preparation, support 

and administration and therefore estimates of positive review from the proposed options of timber 

sales are incorrect. 

Using the discounted net revenue number for Alternative 5 from Table 3.22-16, the USFS is saying

it will average a positive return of ~$98/MBF ($112.9 million divided by (46MM(annual volume)

*25years)) over a 25-year period after subtracting its administrative cost.

RESPONSE

The statement on p. 3-481 in Chapter 3 of the DEIS under Financial Analysis has been corrected in the 

FEIS to refer to the costs used by the R10 Appraisal program instead of Forest Service administrative 

costs. The Forest Service administrative costs are not relevant to a programmatic EIS such as the Forest 

Plan Amendment since there is no actual volume (MMBF) realized through the NEPA process. Instead 

these costs are disclosed in project timber harvest EISs. 

The correct costs used to determine the information on including the estimated logging costs associated 

with old growth harvest and young growth and estimated road and other transportation costs, are now 

disclosed in detail in Chapter 3 of the FEIS in the Economic and Social Environment section (affected 

environment) under “R10 Appraisal Costs.” 

DEIS Comments and Responses I-186 Final EIS
Appendix I

The FEIS also discusses the fact that these estimates represent only a snapshot in time, and that they 

may change at the time of sale and are useful primarily for comparing alternatives. The R10 Appraisal 

was used as a tool for financial analysis and alternative comparison at the programmatic EIS level; it does 

not yield a timber sale appraisal. When actual timber sales are sold from a project after environmental 

analysis, the appraisal is based on the current appraisal bulletin, cost information, and a profit and risk 

allowance to determine stumpage values at the time of offering.

COMMENT

SPEC-19: When economics are relevant and important to a decision, economic information must 

be included in an EIS.

According to 40 CFR 1502.23, when economics are relevant and important to a decision, 

economic information must be included in an EIS.

The DEIS documents do not detail the PLV used by the USFS. What is the PLV number for YG?

What is the PLV for OG? Nothing in the documents tells the reviewer how the USFS determined the

PLV and cost of future harvest 25 and 100 years out. Did the USFS use a set percentage increase

over time? Please provide this missing information.

In Appendix B (pg. B-13) when they performed the modeling exercise they used only the five southern 

districts on the Tongass for the first 15 years. By not considering/using the entire Tongass they

misrepresent the actual cost of harvesting timber from the forest. See TWFG paper, Analysis of Old 

Growth Inventory and Land Base Available for Operations within the Tongass National Forest, 2014.

In that document the cost of transportation from the northern part of the Tongass to the Viking mill in 

Klawock drives most volume available for harvest into negative value territory.

Based on the Woodstock model (see attached TWFG sheet) for Alternative 5 and the statement on 

pg. 2-32 of the DEIS, by year 16 the volume of OG harvest will be reduced to 5MMBF per year or a

total of 25MMBF for the period years 16-20. The Woodstock model shows the 25MMBF of OG 

producing a net return of $360.9/MBF. Refer to the net returns for Saddle Lakes and Big Thorne; the

USFS has not produced an OG timber sale that generates a net return after administrative cost of

$360.99.

Corrections or Revisions Needed

Page 3-450, DEIS: Table 3.22-5 shows the average timber harvest for State lands is 25.7 MMBF for 

the last 13 years; the average for the last seven years is a much lower 12.3 MMBF. The last seven 

years is a better indication of future volume based on the fact that Alaska Mental Health Trust and 

the University are not bound to manage on a sustained-yield basis.

RESPONSE

A cost-benefit analysis has not been displayed as a strict quantitative monetary analysis due to the many 

other considerations that must be given to other resources that have no dollar value assigned as 40 CFR 

1502.23 recommends “For purposes of complying with the Act, the weighing of the merits and drawbacks 

of the various alternatives need not be displayed in a monetary cost-benefit analysis and should not be 

when there are important qualitative considerations” (emphasis added). An analysis of the effects for 

each resource has been included with the ‘costs’ and ‘benefits’ explained either quantitatively or 

qualitatively. A summary of the effects by Alternative and the comparison of alternatives for each of the 

significant issues is in Chapter 2. In addition, a discussion of the Tongass Old-growth Conservation 

Strategy is displayed in the Forest Plan Amendment DEIS, Appendix D.

The pond log values are located on the RV spreadsheets. While this information is not included in the 

FEIS which is the summary of the analysis done for this amendment, they are located in the planning 

record.

Final EIS I-187 DEIS Comments and Responses
Appendix I

The southern five districts were used instead of the entire Tongass National Forest due to their proximity 

to the majority of the existing mills. Timber harvest projects could occur on the northern part of the 

Tongass but would probably need to be 100% exported such as the Yakutat sale in the mid-2000s. 

The analysis that you mention for Big Thorne and Saddle Lakes EISs were run using FASTR and used 

the volume for the entire alternative and much of this volume is of lower grades than is found in small 

sales and microsales which target larger, higher value trees destined for higher end value-added 

manufactured for products.

COMMENT

SPEC-20: Correction on open roads in non-NFS lands needed in Appendix C.

Page C-4, DEIS: Table C-1 breaks down past road construction and states that 3,379 miles out of 3,660 

miles of roads constructed on non-national forest land remain open. Based upon the Division of Forestry’s 

best estimate, instead of 92% remaining open, the total still open is more likely in the range of 1500-2000 

miles, or about 50%.

RESPONSE

As suggested, the proportion of all roads in open vs. closed status is not readily available for non-NFS 

lands. The Forest Service based the DEIS estimate on available GIS information, and has decided to use 

the State’s estimate of 50 percent for the FEIS. The numbers in Appendix C have been updated where 

information was available.

COMMENT

SPEC-21: Specific Wildlife-related Comments on DEIS.

Page 2-7, Wildlife, DEIS: Please consider managing habitat to provide for sustainable wildlife populations 

rather than viable populations.

RESPONSE

Forest Plan Chapter 2 includes the following forest-wide goal for wildlife:

“Maintain the abundance and distribution of habitats, especially old-growth forests, to sustain viable 

populations in the planning area.”

See response to PLR-2.

COMMENT

Pages 2-14 through 2-20, Alternative 2, DEIS: Please provide a clearer description of how harvest 

in the beach buffer occurs. Include discussion of the anticipated effects on MIS when the 1,000 ft 

beach buffer is removed for harvest and road construction. Please expand the discussion of how 

leaving an adjacent inland stand of POG or young growth serves the purpose of the beach buffer. 

It would be helpful to focus this discussion on biogeographic provinces 13 and 14. See our 

similar comments for Appendix D on page 4.

RESPONSE

Chapter 2 of the FEIS describes the alternatives in detail, including tables and figures. The alternative 

description states whether young growth may be harvested in the beach and estuary fringe, how it can be 

harvested (e.g., clearcutting, commercial thinning), where it can be harvested, and how much younggrowth volume the alternative yields. In terms of describing how harvest in the beach and estuary fringe 

would occur, the Forest Plan provides the actual management prescription; not the FEIS. Each Land Use 

Designation (LUD) has a management prescription. Each management prescription includes the following 

elements: 1) Land Use Designation Standards and Guidelines; 2) Forest-wide Standards and Guidelines 

(Chapter 4); and 3) Plan Content Developed Under the 2012 Planning Rule (Chapter 5). Chapter 5 

DEIS Comments and Responses I-188 Final EIS
Appendix I

includes plan components and management approaches for young-growth harvest in the beach and 

estuary fringe that provides direction for an IDT when designing and implementing a project.

The Forest Plan Amendment does not propose to remove the 1,000-foot beach buffer. Rather, as under 

Alternative 5, a minimum 200-foot-wide forested buffer along the shoreline adjacent to young-growth 

harvest units is required, which would continue to protect forest in the beach and estuary fringe for 

connectivity and habitat while the harvested stand matures. (See Chapter 5 young-growth standard SYG-BEACH-03.) Thus, the functioning of the beach and estuary fringe may be reduced in places due to 

the reduced buffer, but effects would be short-term and more localized. (See FEIS Appendix D, Beach 

and Estuary Fringe section.)

The FEIS provides a programmatic analysis that addresses the Forest Plan. A programmatic analysis of a 

Forest Plan includes a set of policies and maps of possible future activities and uses, the specifics of 

which are not yet known. Any future development, if and when it does take place, would result in effects. 

It is reasonable, therefore, to foresee that on-the-ground impacts would occur if the Forest Service 

harvests young-growth in the beach and estuary fringe. An analysis of each alternative and discussion 

about the anticipated effects from harvesting young growth in the beach and associated road construction 

is included under each resource section in FEIS Chapter 3 including Biodiversity and Wildlife. Because 

the FEIS is analyzing an amendment to the 2008 Forest Plan developed under the 1982 Planning Rule, 

these species are analyzed even though the 2012 Planning Rule does not use MIS for evaluating effects. 

Most of these species are associated with POG forests of Southeast Alaska either directly or rely on prey 

species associated with these habitats.

The Forest Plan provides young-growth direction for the beach and estuary fringe. The FEIS in the 

Chapter 3 Biodiversity and Wildlife sections describe and analyze young-growth harvest in the beach and 

estuary fringe. FEIS Appendix D also provides a similar analysis, and also includes several tables that 

facilitate understanding the anticipated effects. Table 6 summarizes distribution of young-growth harvest 

acres (over 100 years) within the beach and estuary fringe by Biogeographic Province and Alternative. 

Due to the localized nature of anticipated effects, under all of the alternatives the beach and estuary 

fringe would continue to act as a transition zone between interior forest and saltwater influences, maintain 

landscape connectivity, and provide benefits to the marine environment across the planning area. 

Therefore, it would be expected that there may be localized reductions in the ability of the beach and 

estuary fringe to function as intended under the Conservation Strategy under each of the alternatives but 

Forest-wide effects would not measurably reduce the functioning of this contributing element of the 

Conservation Strategy. 

COMMENT

Page 3-223, DEIS: Please update this section to reflect the Fish and Wildlife Service decision 

announced on January 5, 2016 that the Alexander Archipelago wolf does not warrant protection as 

an endangered or threatened species under the Endangered Species Act.

RESPONSE

Chapter 3 of the FEIS, Wildlife Section (Alexander Archipelago Wolf) has been updated to include a 

discussion regarding the USFWS publishing a 12-Month Finding that listing of the subspecies was not 

warranted.

COMMENT

Page 4-100, DEIS: We recommend eliminating the distinction between peregrine falcon 

subspecies given recent studies about the subspecies status along parts of coastal Alaska.

Final EIS I-189 DEIS Comments and Responses
Appendix I

RESPONSE

Changes to Chapters 3 and 4 of the Forest Plan were minimized during this amendment. Direction related 

to the purpose and need of this narrow amendment (young growth, renewable energy, transportation 

systems corridors) was modified as appropriate. The suggested change is not necessary to accomplish 

the narrow focus of this amendment. 

COMMENT

SPEC-22: Specific Wildlife-related Comments on the Proposed Plan.

Page 2-8, Wildlife, Proposed Plan: Replace the term sport with hunting.

RESPONSE

The Forest Service restored some wording deleted in the Proposed Forest Plan. Public comments 

expressed concerns about the “breadth” or expansiveness of these changes, giving the appearance of a 

broad-based amendment. (See P&N-8, PLR-3) Although these changes are administrative, for clarity 

sake, the changes have been restored to the original language. Therefore, the suggestion to change 

terms in Chapter 2 was not included.

COMMENT

Page 3-10, Desired Condition, paragraph 1, Proposed Plan: Define appropriate research, how the 

determination is made, and what role the State plays in the process.

RESPONSE

In Chapter 3, LUD-specific standards and guidelines provide direction for implementation of projects. It is 

not the location to give specifics on operating procedures such as how special use requests for research 

are determined. Research may be proposed and conducted by a variety of partners and agencies, which 

may include the State of Alaska, universities, non-profits, and others. Forest Plan guidance is not 

intended to list the role of partners and cooperators for each activity that could be authorized.

COMMENT

Page 3-45, Proposed Plan: Consider adding a land use designation (LUD) standard and guideline 

under the wildlife habitat improvement heading that addresses non-native wildlife management 

following a natural disturbance or disease.

RESPONSE

Changes to Chapters 3 and 4 of the Forest Plan were minimized during this amendment. Direction related 

to the purpose and need of this narrow amendment (young growth, renewable energy, transportation 

systems corridors) was modified as appropriate. Therefore, the suggestion to add a new standard and 

guideline to the Research Natural Area LUD is not included as it is beyond the scope of the amendment.

COMMENT

Page 3-57, Desired Condition, Proposed Plan: Clarify how a population of a species is defined as 

a subspecies. Consider revising the definition on page 7-42 and consult the ADF&G draft Wildlife 

Action Plan for more information on subspecies (2015).

RESPONSE

LUD specific standards and guidelines is not an appropriate place to define / clarify terminology.

COMMENT

Page 3-138, Wildlife, Proposed Plan: Please clarify the author and standing of the Tongass Young 

Growth Management Strategy referenced here. The document could be strengthened by adding 

DEIS Comments and Responses I-190 Final EIS
Appendix I

more information regarding the effects of the strategy to wildlife. The version available through 

the references (Page 6-49, DEIS) does not contain Exhibit 3.

RESPONSE

The Tongass Young Growth Strategy is included in the Planning Record. The Forest Plan now indicates 

the Tongass Young Growth Management Strategy is an unpublished US Forest Service document.

COMMENT

Page 4-96, Proposed Plan: We recommend adding standards and guidelines for protection of the 

Pacific marten Martes caurina, which is endemic to Admiralty and Kuiu Islands. Macdonald and 

Cook (2007) and Dawson (2008) are good resources.

RESPONSE

The FEIS acknowledges both American and Pacific marten and discusses that the existing Forest Plan 

guidance on marten (WILD1. XVIII) is intended to apply to all marten across the Tongass National Forest. 

Accordingly, no additional standards and guidelines specific to Pacific marten were added to the Forest 

Plan.

COMMENT

Page 4-99, Proposed Plan: Please replace goshawk nest stand with nest site. The monitoring 

protocol could be strengthened by ensuring the assumptions of nest identification and the 

probability of detection is valid. ADF&G biologists are interested in helping USFS biologists 

develop the monitoring program. We are concerned about the efficacy and statistical validity of 

the current goshawk monitoring program.

RESPONSE

Most of the goshawk standard and guideline (WILD4.II) refers to nest site. The one instance where it 

says “nest stand” is intended to mean the minimum 100 acre nest buffer area, which is appropriately 

referred to as a “stand.”

COMMENT

Page 5-8, Management Approaches, Proposed Plan: This section would benefit from clear goals 

and objectives related to monitoring the effects of young-growth harvest on MIS. See our similar 

comments for Appendix D on page 4.

RESPONSE

Monitoring is outlined in the Tongass Plan Monitoring Program (USFS 2016). The monitoring plan is no 

longer included within the Forest Plan (was Chapter 6 in the 2008 Forest Plan), but is now a separate 

document. Management approaches in Chapter 5 of the Forest Plan, describe the intent or expectations 

of the responsible official in terms of the applicable plan components, such as a desired condition or 

standard for the affected resource.

COMMENT

SPEC-23: Specific Wildlife-related Comments on Appendix D of the DEIS.

Page D-3: This section summarizes the scope of analysis and acknowledges new science. As in the 

DEIS, the analysis does not adequately describe how young-growth harvest affects wildlife species. 

Similarly, the DEIS and the section on the contribution of matrix lands lacks adequate analysis and should 

be strengthened with references from land management focused research conducted on the Tongass.

RESPONSE

The purpose of this section was not to describe how young-growth harvest affects wildlife, but rather to 

highlight new science related to the contribution of young-growth stands to conservation. This section 

Final EIS I-191 DEIS Comments and Responses
Appendix I

specifically notes that transition to young-growth management under this Forest Plan amendment has the 

potential to both positively and negatively affect the condition and quality of matrix lands, and thus their 

contribution to the Conservation Strategy. The subsequent discussion in Appendix D describes the 

potential adverse effects to wildlife associated with young-growth harvest, including:

• Young-growth harvest within the Old-growth Habitat LUD and other non-development LUDs has 

the potential to increase habitat fragmentation and reduce the ecological contribution of younggrowth stands to the reserve system by setting back the trajectory toward late seral forest 

condition by delaying the development of old-growth stand characteristics such as snags, downed 

logs, and diverse tree canopy layers required by some POG-associated species (e.g., marten, 

goshawks, flying squirrels);

• Young-growth harvest in the beach and estuary fringe has the potential to locally decrease buffer 

width and reduce its effectiveness in facilitating the movement of organisms across the landscape 

and providing habitat for wildlife species that are negatively affected by edge; and

• Young-growth harvest in the RMA has the potential to locally decrease buffer width and reduce its 

effectiveness in facilitating the movement of organisms across the landscape and reduce the 

function of riparian areas.

COMMENT

Page D-4, paragraph 2, DEIS: Stating young growth serves as dispersal corridors between oldgrowth stands is a generalization, as young-growth stands can be barriers rather than corridors 

for some old-growth associated species. Please revise.

RESPONSE

The purpose of this section was to note the growing recognition, which was acknowledged during the 

development of the 1997 Forest Plan, of the ecological function that young-growth stands and matrix 

lands in general play in conservation. A statement has been added to Appendix D noting that younggrowth stands can act as barriers. Throughout Appendix D, the adverse effects of young-growth harvest 

are discussed (see response to SPEC-23).

COMMENT

Page D-5, paragraph 3: The USFS states that on a forest-wide basis, over 90% of the existing POG 

will be protected from harvest. Given the context, this statement implies that forest management 

will have little effect on old-growth associated species because 90% of their habitat will remain 

intact. However, populations of many old-growth associated species are confined to islands or 

biogeographic regions where a much higher proportion of POG has been or will be harvested. We 

recommend that relative to wildlife, such habitat summaries be presented at a scale that is 

meaningful to the species or populations being discussed.

RESPONSE

For all analyses related to old-growth retention and proposed young-growth harvest in non-development 

LUDs, RMAs, or the beach and estuary fringe results included in the Wildlife and Biodiversity sections of 

the EIS and in Appendix D, which addresses the Forest Plan Conservation Strategy specifically, results 

are presented Forest-wide and by biogeographic province. The breakdown by biogeographic province is 

intended to provide context for the spatial distribution across the Forest of potential effects given that 

some portions of the Tongass have been more affected by past timber harvest than others. Where 

appropriate, a discussion of particular areas of the Tongass where effects to wildlife species are more 

likely to occur is included in the species-specific discussions and in the cumulative effects discussion in 

the Wildlife section of the EIS. 

DEIS Comments and Responses I-192 Final EIS
Appendix I

COMMENT

Page D-5, paragraph 4: To help the reader get a better sense of the scale of changes resulting 

from GIS mapping updates, please add text and a table describing how the changes affected the 

wildlife habitat analysis. For example, provide the number of polygons/acres in a given bioregion 

found to be >150 years old and corrected to size class 4, resulting in increased POG acreage in a 

bioregion.

RESPONSE

Mapping updates occur on an ongoing basis for various reasons. Mapping updates that have happened 

periodically since 2008 have been incorporated consistently in the description of existing conditions and 

in the evaluation of each alternative. Additional updates were made between the DEIS and FEIS to 

provide the best available information. See Chapter 1 of the FEIS for a discussion of changes between 

the DEIS Updates. GIS data used in the FEIS is available in the project record.

COMMENT

Page D-12: Please provide a clearer description of how harvest in the beach buffer occurs under 

Alternative 2. Include discussion of the anticipated effects on MIS when the 1,000 ft beach buffer 

is removed for harvest and road construction. Please expand the discussion of how leaving an 

adjacent inland stand of POG or young growth serves the purpose of the beach buffer. It would be 

helpful to focus this discussion on biogeographic provinces 13 and 14, which have the highest 

level of this type of harvest under Alternative 2. See our similar comments for the DEIS on page 3.

RESPONSE

Page D-15 of Appendix D describes harvest proposed under Alternative 2 within the beach and estuary 

fringe. The most intensive young-growth harvest in the beach and estuary fringe would occur under 

Alternative 2 which would allow clearcutting to the shoreline during the first 15 years after plan approval 

and commercial thinning thereafter (see Table 2 in Appendix D which describes the harvest prescriptions 

proposed within the beach and estuary fringe by alternative). A statement has been added to the above 

referenced paragraph that conveys that by shifting the beach and estuary fringe inland, the level of 

connectivity between watersheds would be maintained but the ability of the beach and estuary fringe to 

serve as a transitional zone between interior forest and marine influence would be locally reduced.

COMMENT

Page D-17, paragraph 4: Please clarify the statement that individual islands function as 

metapopulations for some species.

RESPONSE

This statement has been clarified to state that this relates to species that do not typically disperse 

between islands.

COMMENT

Page D-18, paragraph 7: This section would benefit from clear goals and objectives related to 

monitoring the effects of young-growth harvest on MIS. See our similar comments for the DEIS on 

page 3. ADF&G is available to help develop the monitoring questions.

RESPONSE

Modifications to monitoring questions, and revision of the Monitoring and Evaluation program are outside 

of the scope of this EIS. In a separate process, the Tongass recently published a draft Plan Monitoring 

Plan on March 9, 2016 for a 30-day comment period. The new Plan Monitoring Plan was adopted on May 

9, 2016. The final monitoring plan is posted at http://www.fs.usda.gov/goto/R10/Tongass/Monitoring. 

Final EIS I-193 DEIS Comments and Responses
Appendix I

Future administrative changes may be necessary after completion of the ongoing Forest Plan 

Amendment. In addition, the Tongass is deferring action on two requirements: focal species and species 

of conservation concern. The requirement to monitor the status of focal species to assess ecological 

conditions is in 36 CFR 219.12(a)(5)(iii) and the requirement to monitor the status of ecological conditions 

to maintain viable populations of species of conservation concern is location at 36 CFR 219.12(a)(5)(iv). 

Once these species and their associated ecological conditions have been identified, relevant monitoring 

questions will be added or modified as necessary. The public would be notified of any substantial 

administrative changes and would have the opportunity to comment at that time.

COMMENT

SPEC-24: Specific Fish-related Comments on the DEIS (SOA-016)

Page 3-31, DEIS: Include discussion and citation of literature regarding how increased harvest in 

the riparian management area (RMA) in moderate vulnerability karst landscapes could impact 

diffuse recharge and stream water quality.

RESPONSE

The 2008 Amended Forest Plan, Appendix H, V. Young-Growth Management on Karst, Page H-8 states 

that; “Commercial thinning is appropriate on low to moderate vulnerability karst lands when the karst 

management objectives can be met.” Preliminary data (Prussian, 2011) does support the concept that by 

commercial thinning of the older young-growth stands on karst, returning the stand to closer-to-preharvest tree spacing, thus hastening the hydrologic recovery of the site. Reducing the canopy cover 

could restore the ‘health’ of young growth forests on karst lands by increasing the volume of throughfall, 

flushing sedimentation out of diffuse and discrete karst openings, and reconnecting surface to subsurface 

flow pathways. With increased recharge, karst springs should contribute more to the aquatic 

systems. Wissmar et al. 1997 and Bryant et al. 1998 documented a higher productivity in karst influenced 

streams than in other streams. The karst landscape influences productivity of its aquatic habitats in 

several ways. The geochemistry associated with karst development contributes to productivity of aquatic 

environments through its carbonate buffering capacity and carbon input dissolved from the limestone 

bedrock (Wissmar et al. 1997). This action has significant downstream effects on the aquatic food chain 

and biotic community. Preliminary studies suggest that aquatic habitats associated with karst landscapes 

may be 8 to 10 times more productive than adjacent, nonkarst-dominated aquatic habitats (Bryant et al, 

1998). The karst-dominated aquatic habitats support a higher biodiversity than the noncarbonate-based 

systems, have higher growth rates for smolts and resident fish, reflect less variable water temperatures 

and flow regimes, and contain unique habitat affecting species distribution, abundance, and adaptations 

(Bryant et al, 1998, Baichtal and Swanston, 1996). 

COMMENT

Page 3-103, DEIS: Include discussion and citation of literature regarding potential changes to 

windfirmness due to thinning in the RMA.

RESPONSE

Windthrow risk will be evaluated when prescribing thinning and openings treatments in RMA to minimize 

accelerated windthrow. In order to protect the RMA, a Reasonable Assurance of Windfirmness (RAW) 

zone adjacent to the RMA buffer will be established in situations where multiple high risk factors are 

present. The RAW buffer guidance document (Landwehr 2007) and Harris 1989 are used to provide 

guidance when establishing these buffers during planning and final layout. RAW buffers have and 

continue to be monitored to help determine stability of current practices. Although the monitoring does 

not yet include young growth, the overall information is relevant as conditions that influence stability are 

determined through the monitoring process. Monitoring information provided in this section of Chapter 3 

is specific to old growth. We have not been monitoring windfirmness of young growth RMA buffers to 

date. Additional text, including the paragraph below, has been added to Fish section 3.6.

DEIS Comments and Responses I-194 Final EIS
Appendix I

COMMENT

Page 3-103, DEIS: Include discussion and citation of literature regarding how a reduction of the 

RMA width could affect wood recruitment where average tree heights exceed 100 ft.

RESPONSE

See response for FISH-5. Wood recruitment should not be impacted from thinning as that would be 

counter to the objectives for RMA. A watershed analysis (as described in Forest Plan Appendix C) would 

be needed for implementing any alternative that proposed to enter the RMA. Additional information was 

added to the requested section discussing effect of tree height on LWD addition.

COMMENT

Page 3-118, paragraph 5, DEIS: Consider strengthening the discussion by citing recent research 

on rainbow trout and steelhead Onchorhynchus mykiss (Kendall et al. 2015, Pearse et al. 2009, 

Sloat and Reeves 2014a, Sloat and Reeves 2014b).

RESPONSE

The suggested references have been added to the FEIS in the Fish section in Chapter 3.

COMMENT

Page 3-123, DEIS: Please clarify the circumstances where substantially more RMA group selection 

could occur, and how many acres would be acceptable under this alternative given the standards 

and management approaches in the riparian section of Chapter 5.

RESPONSE

It would be a rare circumstance that 10-acre openings in RMA would meet the desired future condition for 

the RMA outside of the TTRA buffer. In most cases, we would envision less than that. The young growth 

standard for riparian S-YG-RIP-01 allows up to 10 acre openings and up to 35 percent of the acres of the 

original harvested stand. The management approach for riparian also states that the intent is that younggrowth treatments in the RMA must meet the objectives of RMA process groups as defined in Appendix 

D. Young-growth treatments in the RMA must be consistent with the all of the applicable plan 

components. Some text changes were made to the Fish section 3.6 to clarify this. 

COMMENT

Page 3-126, paragraph 2, DEIS: Consider removing the statement:

Some negative effects, or more appropriately, increased risk, to the natural range of variation in 

stream processes and fish habitat would likely occur by management activities over the long 

term for all alternatives. The extent of harvest activity and associated road development are 

likely to result in decreases of some fish populations in managed watersheds.

This is speculative and contradictory to the statement in the first two sentences of the third paragraph 

page 3-126. The presence of risk should not be confused or used interchangeably with negative effects, 

in the absence of supportive research. We recommend removing the association between risk and 

negative effects to fish habitat from the DEIS. The concept that risk is both normal and being fully 

mitigated in the Tongass should be added to the DEIS with discussion of Dr. Doug Martin’s body of 

research, cited elsewhere in the DEIS.

RESPONSE

This statement has been removed from the FEIS.

Final EIS I-195 DEIS Comments and Responses
Appendix I

COMMENT

Page D-19, Table 8 DEIS: Consider adding a row in the table showing projected young-growth 

acreage suitable for harvest in development LUDs following proposed changes to the scenic 

integrity standards and guidelines and the application of the rules surrounding harvest prior to 

the culmination of mean annual increment. This would provide perspective when evaluating the 

necessity to conduct harvest in environmentally sensitive areas by showing the relative gains in 

available timber from all components of each alternative.

RESPONSE

The relaxed SIOs do not affect the total amount of young-growth that is harvested. They only affect where 

it is harvested and may also result in larger harvest units in some areas. For example, a higher SIO might 

force unit openings to be less than 10 or 20 ac but relaxing the SIO may allow them to be 40 or more 

acres; however, the maximum total acres of young-growth harvested would not change. Therefore, no 

changes were made to DEIS Table 8 (Table 9 in the Final EIS).COMMENT

Page D-12, paragraph 3, DEIS: Improve clarity by beginning the first sentence with of the action 

alternatives.

RESPONSE

The statement has been revised.

COMMENT

Page D-12, paragraph 3, DEIS: Consider revising the statement in the last sentence about effects 

being short-term and localized, which contradicts the statement on page D-11, paragraph 4.

RESPONSE

The statement has been revised.

COMMENT

Page 3-98, Table 3.6-2, DEIS: Suggest changing the title to commonly targeted sport, subsistence, 

and commercial fish. The existing title is misleading since sport fishing for steelhead in the region 

is primarily catch-and-release. 

RESPONSE

The title has been revised.

COMMENT

3-104, paragraph 1, DEIS: Specify the harvest type discussed in the second sentence.

RESPONSE

The harvest type has been revised. Text was added to clarify that cited evaluation was related to 

watershed level timber harvest rate.

COMMENT

Page 3-108, paragraph 2, DEIS: Angler days (Table 1), recorded in ADF&G’s statewide harvest 

survey data, better represent fishing effort trends than license sales. The data is available 

at: http://www.adfg.alaska.gov/sf/sportfishingsurvey/index.cfm?ADFG=region.home.

Table 1.–Angler days by water type 

among Southeast Alaska 

communities,

 1996–2014

DEIS Comments and Responses I-196 Final EIS
Appendix I

Year Freshwater Saltwater Total

1996 72,459 297,960 370,419

1997 93,478 346,320 439,798

1998 75,445 295,302 370,747

1999 99,054 435,610 534,664

2000 106,355 435,052 541,407

2001 98,093 409,148 507,241

2002 101,563 367,739 469,302

2003 107,755 369,437 477,192

2004 104,166 443,083 547,249

2005 102,200 465,584 567,784

2006 104,834 412,001 516,835

2007 104,431 435,859 540,290

2008 100,094 409,503 509,597

2009 96,343 403,738 500,081

2010 87,279 356,572 443,851

2011 95,332 352,276 447,608

2012 91,009 387,998 479,007

2013 83,871 462,179 546,050

2014 95 068 469 242 564 310 RESPONSE

Information from the total angler effort was added to the text 

COMMENT

Page 3-328, Table 3.15-7, footnote 6, DEIS: Please include the data source for the ADF&G ratings.

RESPONSE

As discussed in the Draft EIS (p. 3-327), the data presented in Table 3.15-7 are from the 1997 Forest 

Plan EIS:

The Forest Service developed this rating system in response to public comments received on the 

1990 DEIS. Recreation places may be important for one, several, or none of the identified 

categories. Important recreation places by category are summarized in Table 3.15-7 and discussed 

Final EIS I-197 DEIS Comments and Responses
Appendix I

further in the Recreation and Tourism section of the 1997 Forest Plan Revision FEIS (USDA Forest 

Service 1997a, pp. 3-109, 3-111). 

These same pages are the source of the information presented in Table 3.15-7, including the ADF&G 

ratings.

COMMENT

Page 3-343, Fishing, DEIS: Please provide a citation for the statement 13 percent of inventoried 

recreation places acres are currently important for fishing.

RESPONSE

This is a reference to the data in Table 3.15-7. The text has been revised in the Final EIS and now refers 

the reader back to that table. As noted in response to the above comment, the recreation place rating 

system was developed as part of the 1997 Forest Plan Revision EIS.

COMMENT 

SPEC-25: Specific Fish-related Comments on the Proposed Plan.

Page 5-8, S-YG-BEACH-03, Proposed Plan: In some locations, such as estuaries, the forest edge 

could be greater than 200 feet from mean high tide and it is not clear whether or not this buffer 

includes non-forest acreage. If the standard is intended to include non-forested acreage, please 

include in the FEIS an evaluation of compatibility with the proposed desired conditions of the 

beach and estuary fringe in Chapter 5 and the forest side standards and guidelines in Chapter 4. If 

the standard is intended to include forested acreage only, we suggest modifying the first sentence 

of the standard to Commercial harvest in the beach fringe is not allowed within a minimum 200-

foot buffer beginning at the forested edge above the mean high tide line.

RESPONSE

S-YG-BEACH-03 now reads: “Commercial harvest within the beach and estuary fringe is not allowed 

within a minimum 200-foot forested buffer beginning at mean high tide (that is, a no commercial harvest 

buffer). This does not preclude wildlife enhancement projects and providing access to timber harvest 

units as long as process group objectives can be met in the RMA.

The management approach for beach and estuary fringe explains that Forest Plan Appendix D provides 

guidance for delineating RMAs associated with estuarine stream process group. Estuarine RMAs extend 

1,000 feet from the landward extent of salt tolerant vegetation, regardless of vegetation type.

COMMENT

Page 5-9, Proposed Plan: A 10-acre opening in the RMA outside of the Tongass Timber Reform 

Act buffer appears contradictory with desired condition DC-YG-RIP-01, the fish and riparian 

standards and guidelines of Chapter 4, and Appendix D. Given the desired condition in DC-YGRIP-01 is to improve functions for soil, water, fish, wildlife, and other resources, while also 

providing a commercial byproduct, please explain where a 10-acre opening would improve 

conditions and be approved at the project level, especially if there is no requirement to thin the 

RMA following harvest. If the assumption in Alternative 5 is that timber can be harvested in such a 

matter from the RMA, the FEIS should describe instances when a 10-acre opening in the RMA 

could be implemented so that decision makers understand whether or not this wood source is a 

reliable element of the alternative.

RESPONSE

It would be a rare circumstance that 10 acre openings in a RMA would meet the desired future condition 

for the RMA outside of the TTRA buffer. The Alternative 5 standard S-YG-RIP-01 allows up to 10 acre 

openings and up to 35 percent of the acres of the original harvested stand, and the management 

approach for riparian states that it is expected that young-growth treatments in the RMA achieve stream 

DEIS Comments and Responses I-198 Final EIS
Appendix I

process group objectives as defined in Appendix D of the Forest Plan. Young-growth treatments in the 

RMA must be consistent with the all of the applicable plan components. 

COMMENT

Page 5-9, Proposed Plan: Alternatives 2 and 5 allow removing up to 35% basal area of a stand in 

the RMA. Consider adding a standard in the Chapter 5 riparian section to clarify how the 35% 

removal can be distributed across the stand and if harvest can be focused in the RMA.

RESPONSE

Alternative 2 allows for commercial thinning of up to 33 percent of stand basal area. Alternative 5 allows 

up to 10 acre patch cuts and commercial thinning totaling no more than 35 percent of the total stand 

acres. A combination of the two treatments may be used, with no more than 35 percent of the total stand 

removed, as long as the treatment facilitates a more rapid recovery of the late successional forest 

characteristics.

COMMENT

Page 4-10, Section III, Proposed Plan: Add a reference for the 2015 Fish Stream Identification and 

Stream Classification on the Tongass National Forest document and its associated field guide, 

which include results of recent working groups and field verification studies.

RESPONSE

The suggested reference was added.

COMMENT

Page 5-7, paragraph 5, Proposed Plan: Consider including prioritization of stewardship fund use 

on the district where they were generated, a process made easier by Public Law 108-148-DEC.

RESPONSE

The young-growth management approach that discusses using the stewardship authority, where 

appropriate is based on final recommendations from the Tongass Advisory Committee, which did not 

address prioritizing the use of stewardship funds. Therefore, this suggestion is not included. 

COMMENT 

SPEC-26: Specific Subsistence-related Comments on the DEIS.

Pages 3-97 through 3-101, DEIS: This section includes a general characterization of the magnitude 

of sport and commercial fish harvests from Conrad and Gray (2014). The FEIS should include 

similar information for subsistence harvest presented in Conrad and Gray (2014). 

RESPONSE

Additional information has been added to Chapter 3 of the FEIS in the Fish section. 

COMMENT

Page 3-390, first paragraph under abundance and distribution, DEIS: The ADF&G (2014) citation is 

inaccurate. Please cite the 1987 Tongass resource use cooperative survey (TRUCS), which 

provides the only survey data for Tenakee Springs and Skagway.

RESPONSE

This has been re-worded in the FEIS.

Final EIS I-199 DEIS Comments and Responses
Appendix I

COMMENT

Pages 3-533 through 3-635, DEIS: In the subsistence sections of the Elfin Cove, Gustavus, Meyer’s 

Chuck, Metlakatla, Pelican, Port Alexander, Skagway, and Tenakee Springs individual community 

assessments, the 1987 ADF&G harvest data are referenced as distinct from the TRUCS data 

presented in Kruse and Frazier (1988), but the information in both references is from the same 

study. Citations in these sections presenting the data from both publications should be 

reconciled.

RESPONSE

The subsistence discussions for each community draw upon several sources of information including 

Kruse and Frazier (1988) and the latest information available in the ADF&G Community Subsistence 

Information System, cited in the EIS as ADF&G (2014). In some cases, as indicated in the comment, the 

most current information in the ADF&G database is from 1987 and was originally reported in Kruse and 

Frazier (1988). The references to ADF&G (2014) for the above communities have been deleted to avoid 

duplication.

COMMENT

Page 3-508, third paragraph, DEIS: Prince of Wales communities are listed as using a combination 

of hydroelectric and diesel-generated power while the individual community summaries indicate 

power is generated by diesel only. Please clarify.

RESPONSE

The FEIS has been updated to state that Coffman Cove is served by diesel generation. The other six 

POW communities identified (Craig, Hollis, Hydaburg, Kasaan, Klawock, and Thorne Bay) are served by 

hydroelectric generation, with diesel generation used as a back-up. The source of information for the 

clarification is Black & Veatch. 2012. Southeast Alaska Integrated Resource Plan. Volume 2 – Technical 

Report. Prepared for the Alaska Energy Authority. 

COMMENT

Pages 3-513 through 3-654, DEIS: Please include a citation for the source of information presented 

in the community use area maps for all communities. If maps are based on the 1987 TRUCS 

harvest data, please include an analysis of how uses may have changed in the last 30 years.

RESPONSE

The community use areas used in the analysis were originally developed as part of the 1997 Forest Plan 

revision EIS. The community analysis and the use of these maps is discussed further at the beginning of 

the Communities section in the subsection entitled Community Assessments. Updated subsistence 

information is provided for each community based on the most current information available from ADF&G 

and potential effects to deer are assessed at the WAA level using detailed unpublished information 

provided by ADF&G. The WAAs analyzed for each community were identified based on the data 

provided by ADF&G for 2004 through 2013, the most recent available at the time of preparation. 

COMMENT

Pages 3-542 through 3-43 and 3-560 through 3-561, DEIS: The Haines and Hyder individual 

community assessments focus on potential impacts to local resident deer harvests, however, 

moose are more important for these residents, unlike most other southeast communities. Please 

modify the assessments to include the importance of moose in these communities.

DEIS Comments and Responses I-200 Final EIS
Appendix I

RESPONSE

Chapter 3 of the DEIS on page 3-509 (subregional overview), states that deer is the only subsistence 

resource that is potentially significantly affected by the alternatives and that the subsistence analysis 

therefore uses deer as a key indicator for potential community impacts.

The FEIS has been updated to acknowledge that moose are more important than deer for Haines 

residents and that moose are not expected to be adversely impacted by any alternative.

Chapter 3 of the DEIS on page 3-560, acknowledges that bear and moose make up most of the land 

mammal subsistence for Hyder residents. The FEIS has been updated to include goat as well. These 

species are not expected to be adversely impacted by any alternative.

COMMENT

Pages 3-568, 3-599, and 3-653, DEIS: The Kake, Pelican, and Yakutat individual community 

assessments specify several subsistence use areas as most important or very important. Please 

provide a definition for these subjective terms, or eliminate them.

RESPONSE

The cited text has been revised and the words “most” and “very” have been removed as suggested.

COMMENT

Page 3-550, DEIS: Update this section to include recent completion of the Gartina Falls 

Hydroelectric facility in Hoonah.

RESPONSE

This project has been updated in Chapter 3 of the FEIS in the Renewable Energy section. Gartina Falls 

Hydroelectric (P-14066) began operating on August 5, 2015 and the 425kw project provides about a third 

of Hoonah’s energy needs. This information was also updated in the Communities section. 

COMMENT

Page 3-604, DEIS: In the Petersburg Subsistence section, replace land mammals (mostly deer) 

with deer, to be consistent with information for other communities regarding the TRUCS data.

RESPONSE

The words, “land mammals (mostly deer)” has been replaced with “deer.”

COMMENT

Page 3-612, first paragraph: Replace Pelican with Port Alexander.

RESPONSE

Change has been made in the FEIS.

COMMENT

SPEC-27: Specific Plan Comments for Chapters 1 and 2 of the Forest Plan.

Chapter 1 Introduction

Proposed Plan page 1-5 second to last paragraph states: “The communities of Southeast Alaska depend 

on the Tongass National Forest in various ways, including employment in wood products, commercial 

fishing and fish processing, recreation, tourism, and mining, and mineral development.” The paragraph 

also goes on to explain the importance of subsistence resources; however, overlooked is the importance 

of public access to the forest by all modes including maintenance of forest roads. We recommend 

Final EIS I-201 DEIS Comments and Responses
Appendix I

including in the introduction a sentence describing the importance and role of public access and 

transportation infrastructure.

RESPONSE

The following introductory sentence has been added:

National Forest System roads are a vital component of the State of Alaska’s Southeast Transportation 

Plan to provide for mobility residents, goods and services that facilitates the economic development and 

sustainability of southeast Alaska. These roads provide access for sustainable resource management as 

well as recreation opportunities, subsistence use, and community connectivity throughout the islands of 

the Alexander Archipelago. 

COMMENT

Chapter 2 Goals and Objectives

No mention is made under Forest Desired Conditions of transportation utility system goals and 

objectives.

Recommend the inclusion statements of desired conditions for development and maintenance of regional 

and area transportation - utility systems:

Provision and maintenance of air and marine access points and associated infrastructure by the 

Forest Service, including a system of forest trails and road to facilitate access to forest areas 

managed for timber harvest and various multi-uses including recreation, subsistence and 

administration of the forest.

A State of Alaska maintained multi-modal regional transportation system of airports, marine docks 

and floats, and road system supporting access to and through the National Forest providing efficient 

and essential transportation between communities within the forest and between the forest and the 

rest of the world in support of the area economy.

Under Forest-wide Multiple-use Goals and Objectives recommend the addition of the above as goals 

under a category referred to as “Access.” Similar access objectives should be listed under and in support 

of the following categories:

Local and Regional Economies

Minerals and Geology

Recreation and Tourism

Renewable Energy

Subsistence and

Timber

Recommend redefining “Transportation” as a category supporting the following Goal:

Development and operation of transportation and utility infrastructure within the “Transportation Utility 

System” corridors linking the communities of Southeast Alaska as provided by Section 4407 of P.L. 

109-59, as amended by P.L. 114-94, and as allowable under ANILCA Title XI.

RESPONSE

Changes to Chapters 2, 3, and 4 of the Forest Plan were minimized during this amendment. Direction 

related to the purpose and need of the amendment (young growth, renewable energy, transportation 

systems corridors) was provided. Therefore, the suggestion to change terms in Chapter 2 was not 

included.

DEIS Comments and Responses I-202 Final EIS
Appendix I

COMMENT

SPEC-28: Specific Comments for Chapter 3 Management Prescriptions.

Do not replace the overlay Transportation Utility System (TUS) overlay Land Use Designations 

(LUD) as described in the 2008 Forest Plan. Retention of the TUS LUD is needed to physically 

locate TUS corridors established by law, replete with goals and management prescriptions having 

precedence over the underlying LUDs.

RESPONSE

See response to TUS-1.

COMMENT

LUD Management Prescriptions:

ADD TUS LUD overlay LEVEL ONE precedence to other LUDs in the following categories:

SPECIAL INTEREST AREA LUD under TRANSPORTATION, Transportation Operations,

TRAN, add:

B. Coordinate interpretation of the unique values of the Special Interest Area with management of 

transportation infrastructure in TUS LUD corridors and the rights-of-way of other publicly- owned 

roadways.

REMOTE RECREATION LUD under TRANSPORTATION, Transportation Operations, TRAN, 

add:

A. (revise) New roads are not permitted, except within a TUS LUD and to access authorized mineral 

operations (or as excepted under Lands).

MUNICIPAL WATERSHED LUD under TRANSPORTATION, Transportation Operations, 

TRAN, add:

A. (revise last sentence) New road construction is generally inconsistent with Old-growth Habitat LUD 

objectives, but new roads may be constructed if within a TUS LUD. Forest roads may occur in this area 

with due consideration for protection of the watershed.

OLD-GROWTH HABITAT LUD under TRANSPORTATION, Transportation Operations, TRAN, 

add:

A. (revise) New road construction is generally inconsistent with Old-growth Habitat LUD objectives, but 

new roads may be constructed if within a TUS LUD, or if a forest road with no feasible alternative.

B. Add: 4. Roads under the jurisdiction of the Alaska Department of Transportation and Public Facilities 

shall be managed in accordance with the State of Alaska’s best management practices.

SEMI-REMOTE RECREATION LUD under TRANSPORTATION, Transportation

Operations, TRAN, add:

A. (revise) Where Semi-Primitive Motorized recreation opportunities are emphasized, existing low 

standard roads are generally managed for use by high clearance or OHVs, snowmobiles, or motorcycles 

subject to an approved Access and Travel Management Plan. Generally, new roads are not constructed 

in this area, except within a TUS LUD and to link existing roads or provide access to adjacent LUDs.

Add : 4. Roads under the jurisdiction of the Alaska Department of Transportation and Public Facilities 

shall be managed in accordance with the State of Alaska’s best management practices.

Final EIS I-203 DEIS Comments and Responses
Appendix I

LUD II Page 3-68 under Objectives add bullet: Roads and utility lines are allowed within a TUS

LUD.

Page 3-72 under Transportation Operations: TRAN: add 3. Roads and utility lines allowed within a TUS 

LUD. Roads under the jurisdiction of the Alaska Department of Transportation and Public Facilities shall 

be managed in accordance with the State of Alaska’s best management practices.

WILD RIVER LUD page 3-74 add under Objectives: Permit road and utility lines allowed within 

a TUS LUD.

Under TRANSPORTATION, Transportation Operations, TRAN, add:

Page 3-80 (add) D. Roads and utility lines allowed within a TUS LUD. Roads under the jurisdiction of the 

Alaska Department of Transportation and Public Facilities shall be managed in accordance with the State 

of Alaska’s best management practices.

SCENIC RIVER LUD page 3-87 TRANSPORTATION, Transportation Operations: TRAN Add: 5. Roads 

and utility lines allowed within a TUS LUD. Roads under the jurisdiction of the Alaska Department of 

Transportation and Public Facilities shall be managed in accordance with the State of Alaska’s best 

management practices.

RECREATIONAL RIVER LUD page 3-87 TRANSPORTATION, Transportation Operations: TRAN

Page 3-94 add: 3. Roads and utility lines allowed under a TUS LUD. Roads under the jurisdiction of the 

Alaska Department of Transportation and Public Facilities shall be managed in accordance with the State 

of Alaska’s best management practices.

EXPERIMENTAL FOREST LUD page 3-100 TRANSPORTATION, Transportation

Operations: TRAN

Add: C. Roads and utility lines allowed within a TUS LUD. Roads under the jurisdiction of the Alaska 

Department of Transportation and Public Facilities shall be managed in accordance with the State of 

Alaska’s best management practices.

SCENIC VIEWSHED LUD

Add under Objectives page 3-101: Roads and utility lines are allowed under a TUS LUD.

TRANSPORTATION, Transportation operations: TRAN, page 3-108

Add: 6. Roads and utility lines allowed within a TUS LUD. Roads under the jurisdiction of the Alaska 

Department of Transportation and Public Facilities shall be managed in accordance with the State of 

Alaska’s best management practices.

MODIFIED LANDSCAPE LUD page 3-109 add under Objectives: Roads and utility lines allowed within a 

TUS LUD.

Under TRANSPORTATION, Transportation Operations, TRAN, add:

Page 3-115 (add) 6. Roads and utility lines allowed within a TUS LUD. Roads under the jurisdiction of 

the Alaska Department of Transportation and Public Facilities shall be managed in accordance with the 

State of Alaska’s best management practices.

TIMBER PRODUCTION LUD page 3-116 add under Objectives: Roads and utility lines allowed within a 

TUS LUD.

Under TRANSPORTATION, Transportation Operations, TRAN, add:

DEIS Comments and Responses I-204 Final EIS
Appendix I

Page 3-122 (add) 5. Roads and utility lines allowed within a TUS LUD. Roads under the jurisdiction of 

the Alaska Department of Transportation and Public Facilities shall be managed in accordance with the 

State of Alaska’s best management practices.

MINERALS LUD page 3-123 add under Objectives: Roads and utility lines allowed within a TUS LUD.

Under TRANSPORTATION, Transportation Operations, TRAN, add:

Page 3-128 (add) E. Roads and utility lines allowed within a TUS LUD. Roads under the jurisdiction of 

the Alaska Department of Transportation and Public Facilities shall be managed in accordance with the 

State of Alaska’s best management practices.

RESPONSE

See response to TUS-1 and TUS-2. All of the suggested changes assume the Transportation and Utilities 

System (TUS) overlay LUD is not removed. Under the Forest Plan, the TUS overlay LUD was removed, 

as well as all associated direction (i.e., “window” and “avoidance area”) in the LUD Standards and 

Guidelines pertaining to application of this overlay LUD. The TUS LUD management prescription is 

replaced by plan components in Chapter 5 that provide management direction for renewable energy and 

transportation systems corridors and is applied to the 17 LUDs in Chapter 3 of the Forest Plan.

See also response to PLR-1.

COMMENT

SPEC-29: Specific comment for Chapter 4 Standards and Guidelines.

Reinstate standards and guidelines for the overlay Transportation Utility System (TUS) Land Use 

Designations (LUD) as described in the 2008 Forest Plan with corridor goals and management 

prescriptions having precedence over the underlying LUDs.

RESPONSE

See response to TUS-1 and TUS-2. The Transportation and Utilities System (TUS) overlay LUD was 

removed, as well as all associated direction (i.e., “window” and “avoidance area”) in the LUD Standards 

and Guidelines pertaining to application of this overlay LUD. The TUS LUD management prescription is 

replaced by plan components in Chapter 5 that provide management direction for renewable energy and 

transportation systems corridors and are applied to the 17 LUDs.

COMMENT

SPEC-30: Specific comment for Chapter 5 Plan Content Developed Under the 2012 Planning rule.

Revise the Transportation System Corridor (TSC) to apply solely to development and maintenance of 

forest roads located outside of the TUS LUD corridors or under the jurisdiction of the U.S. Forest Service.

RESPONSE

See response to TUS-1 and TUS-3. The management direction for transportation systems corridors in 

Chapter 5 is to facilitate the availability of National Forest System land for the development of existing 

and future transportation systems such as those identified by the State of Alaska in the current version of 

the Southeast Alaska Transportation Plan (SATP) and applicable laws (for example, Section 4407 of P.L. 

109-59, Title XI of the Alaska National Interest Lands Conservation Act, P.L. 96-487). (See DEIS Chapter 

3, Transportation section.)

COMMENT

SPEC-31: Specific comment for Appendices A – K of the Forest Plan.

No appendix on transportation was developed or included. With a proposed major revision, such as the 

elimination of LUD, it would be helpful to review the analysis and decision-making that supports the major 

federal action.

Final EIS I-205 DEIS Comments and Responses
Appendix I

RESPONSE

See response to TUS-1. Removal of the Transportation and Utilities System (TUS) overlay LUD was 

explained in the DEIS in Chapter 3, Transportation section. An analysis of Transportation System 

Corridor direction has been provided in the EIS.

See also response to PLR-1.

COMMENT

SPEC-32: Page-specific comment for Chapter 3 of the Forest Plan.

Page 3-10, Proposed Plan: We support the proposed decision to reference Title XI of the Alaska National 

Interest Lands Conservation Act (ANILCA) in the Wilderness LUD Standards and Guidelines. This 

change will ensure that the full context and process required in ANILCA is considered and followed when 

transportation and utility projects are proposed within conservation system units designated by ANILCA 

on the Tongass National Forest (i.e. designated Wilderness).

RESPONSE

Comment noted.

COMMENT

SPEC-33: Retain “adequate and feasible access for economic and other purposes” as it is the 

correct standard used for inholdings “effectively surrounded” by conservation system units (i.e. 

designated wilderness) in ANILCA section 1110(b). “Reasonable access” is the standard in 

ANILCA section 1323, which applies to general national forest lands; not designated wilderness. 

RESPONSE

No change required. Adequate and feasible access for economic and other purposes in non-wilderness 

national monuments must be consistent with the Alaska National Interest Conservation Act of 1980 

(ANILCA). The language included in the Forest Plan in TRAN (D) on p. 3-26 of the Proposed Forest Plan 

refers the reader to the wilderness LUD description. Management direction for Wilderness is included in 

Chapter 3 for Wilderness and National Monument Wilderness (Proposed Forest Plan, P. 3-19) and for 

Non-wilderness National Monument (Proposed Forest Plan, P. 3-29) where allowed by ANILCA. 

COMMENT

SPEC-34: Plan direction in Chapter 3 should be changed related to rivers found eligible and 

suitable for inclusion in the Wild and Scenic River System in the 1997 Tongass Land Management 

Plan. 

RESPONSE

See response to WSR-1.

COMMENT

SPEC-35: Page-specific comments for Chapter 4 of the Forest Plan.

Page 4-10, Chapter 4, Proposed Plan: Fish Habitat Planning, Fish Habitat and Channel Processes, part 

3: ANILCA section 1326(b) expressly prohibits further studies for the single purpose of considering the 

establishment of a conservation system unit, which includes Wild and Scenic Rivers, unless authorized by 

ANILCA or a further act of Congress. Consideration of new wilderness or wild and scenic rivers in this 

context is inappropriate and we request the following revision:

Consider topics such as erosion processes, watershed hydrology, vegetation, stream channel 

morphology, water quality, wilderness designation, recommendations for inclusion into the Wild 

and Scenic River System, species and habitats, and human uses, during analyses.

DEIS Comments and Responses I-206 Final EIS
Appendix I

RESPONSE

The requested change is outside of the scope of this amendment.

COMMENT

Page 4-31, Proposed Plan: III. Temporary Facilities. ANILCA section 1316 applies to all federal 

public lands where the taking of fish and wildlife is authorized but it does not differentiate 

between subsistence and non-subsistence use. We request the Service consider whether the 

distinction in this section is necessary or appropriate.

RESPONSE

The requested change is outside of the scope of this amendment.

COMMENT

Page 4-44, Proposed Plan: Chapter 4 Recreation Resource Planning: The following guideline 

appears to be relevant to ensuring safe access to communities and popular recreation areas. It is 

unclear why it is being removed. We request the Service re-consider and provide rationale if it is 

not retained in the final plan.

Support a system of anchorages suitable for recreation boats along small boat waterways 

that connect communities or provide access to popular recreation attractions.

RESPONSE

This guideline will be retained in the 2016 Forest Plan in Chapter 4 under Recreation Resource Planning: 

REC2.

COMMENT

SPEC-36: Page-specific Comments for Chapter 3 of the DEIS.

Page 3-382, third paragraph, DEIS: We request the following edit for clarity and consistency with 

ANILCA sections 802 and 804:

It also states, in part, that “customary and traditional” subsistence uses of renewable 

resources “shall be the priority consumptive uses of all such resources on the public lands of 

Alaska when it is necessary to restrict take.”

RESPONSE

The requested change has been made in the Subsistence section.

COMMENT

Page 3-382, fourth paragraph, DEIS: We request the following edit for accuracy:

This ruling took the state out of compliance with ANILCA and the federal government has 

managed harvest of subsistence resource s under federal subsistence regulations on federal 

lands in Alaska since 1990. As a result, federal subsistence harvests of fish and wildlife on the 

Tongass National Forest are presently managed by the Forest Service (Schroeder and Mazza 

2005).

RESPONSE

This requested change was not made, but is very minor.

Final EIS I-207 DEIS Comments and Responses
Appendix I

SPEC-37: Page-specific Comments for Climate and Air section of the DEIS from ADEC (SOA-034) 

COMMENT

Page 3-16, paragraph three, sentence one, should read: “The State of Alaska Department of

Environmental Conservation (ADEC) under the Clean Air Act (CAA), via Title I and Title 5 of the 

EPA approved State Implementation Plan (SIP) regulates air emissions from stationary sources.”

RESPONSE

Comments from Alaska Department of Environmental Conservation provided clarifying language within 

the Climate and Air section of Chapter 3.1 found on pates 3-16, 3-18 and 3-19 of the DEIS. These 

clarifications have been incorporated into the FEIS.

COMMENT

Page 3-18, paragraph three, sentence seven, notes that “ In an effort to better address the air 

quality concerns in the Wilderness, the Forest Service and ADEC enters into a Memorandum of 

Understanding each year to train Forest Service wilderness rangers to visually monitor cruise 

ship emissions with EPA-approved standards.” This sentence should be updated to reflect that 

the MOU is static and does not get entered into each year.

RESPONSE

The sentence has been clarified as follows:

In an effort to better address the visibility concerns in the Wilderness due to cruise ship smoke, the 

Forest Service and ADEC have developed a Memorandum of Understanding to train Forest Service 

wilderness rangers to visually monitor cruise ship emissions with EPA-approved standards.”

COMMENT

Page 3-19 paragraph one, sentence three, should read: “EPA and ADEC have limited regulatory 

responsibility, under the Clean Air Act, for air quality related to these kind of sources.” This 

sentence was discussing indirect sources such as firewood burning and vehicle emissions.

RESPONSE

This sentence has been clarified as recommended.

COMMENT

Page 3-22, paragraph two, sentence five refers to “shrinking alpine habitats.” This may need to be 

re-examined and perhaps changed to read “changing alpine habitats” to reflect the fact that 

glacier melting may expose new alpine habitat at a quicker rate than those of altitudinal forest 

shifts.

RESPONSE

Melting glaciers do not expose new alpine habitat but rather “new non-forested habitat” that quickly 

becomes vegetated. Some lateral edges of glaciers as they shrink may uncover “alpine” habitat as the ice 

may be of higher elevation, but the terminus of many glaciers is not alpine, but sea level. We clarified to 

read “changing non-forested habitats” Altitudinal forest shifts means the marching of shrubs and trees 

up in elevation. We do not have information as to which is faster, retreating glacier re-vegetation, or the 

shifting of the true alpine zonation.

COMMENT

SPEC-38: Page-specific Comments for Water section of the DEIS from ADEC.

Page 3-56, paragraph three, sentence two should read: “Turbidity criteria indicate values will not exceed 

5 nephelometric turbidity unites (NTUs) over natural conditions, when natural values are less than 50 

NTUs.” The original text used the word “nature”.

DEIS Comments and Responses I-208 Final EIS
Appendix I

Page 3-68, paragraph five, sentence two should read: “Landslide debris (e.g., sediment, large wood) that 

enters the stream may block or shift channels, fill pools, and increase the presence of fine sediments

in the channel network.” The original text used the words “increases fines presences” which is 

grammatically cumbersome.

RESPONSE

Edits have been made.

COMMENT

SPEC-39: Page-specific comments on Appendix G of the DEIS from ADEC.

Appendix G, page G-11, M4(c) should be revised to read “Measurements required by M4; a and b are 

from MHW (Mean High Water) to depths of 100 feet MLLW (Mean Lower Low Water).”

RESPONSE

No justification was provided for making this change from 60 feet to 100 feet. The discussion on page G11 under M4 reads, “Sixty feet below MLLW was selected because it is a depth at which repeated dives 

can safely be conducted.” No change was made.

COMMENT

SPEC-40: Typos for Appendixes of the DEIS from ADEC.

COMMENT

Draft EIS, Page A-1: An incorrect date of “June 23, 2016” is given for publishing the corrected 

Notice of Intent.

RESPONSE

Corrections have been made in FEIS.

COMMENT

Draft EIS, Page B-18: “Intermeidate” is misspelled.

RESPONSE

Corrections have been made in FEIS.

COMMENT

SPEC-41: Make Plan consistent with the TAC and the Roadless Rule.

To make the plan consistent with the Tongass Advisory Committee (TAC) recommendations and the 

Roadless Rule, the language regarding these areas should be clarified to ensure that there should be no 

old-growth sales planned in these areas at any point during the transition or after. 

We recommend that the language on page A-4 of the Proposed Plan be changed to better reflect the 

recommendation of the Tongass Advisory Committee to ensure that all of these places are protected: 

"Within Development LUDs, the following old-growth stands (as shown on maps in the planning record) 

are identified as NOT suitable for timber production: (1) Phases 2 and 3 of the 2008 Forest Plan Timber 

Sale Program Adaptive Management Strategy; (2) Trout Unlimited T77 watersheds; and (3) The Nature 

Conservancy/Audubon Priority Conservation Areas.”

RESPONSE

Corrections have been made in the Forest Plan based on the Final Tongass Advisory Committee 

recommendations (see Appendix A and B of the Forest Plan).

Final EIS I-209 DEIS Comments and Responses
Appendix I

COMMENT

SPEC-42: In chapter 5, there is a need for an addition of some specific language in the 

recommendations that should be included in management approaches for young growth.

In chapter 5, there is a need for an addition of some specific language in the recommendations that 

should be included in management approaches for young growth, as well as included in each section in 

chapter 5 where management approaches are outlined.

The language that should be included is the language that deals with doing post-project/after- action 

reviews. There is good language in this section on pre-project collaboration and planning and the TAC 

recognizes the way the Forest Service has integrated our comments on these concepts. However, the 

“after project review” was missed which specifically speaks to our intent that young growth projects 

(especially in the unsuitable lands) will need to go through a period of experimentation and innovation. In 

order for each project to increase the knowledge of how to do these projects better and learn from what 

was successful and unsuccessful, after- action reviews will all stakeholders need to be conducted.

Additions:

The following language from the TAC recommendations should be included:

• Working with project collaboratives, prepare pre- and post-project reports to the public about what 

was planned, what happened with the project or activity. Highlight positive results, such as 

collaborative planning, restoration, workforce development, jobs, and injection of capital into the 

economy and identify areas not meeting expected outcomes in order to address options through 

future efforts

• Design and implement a simple after-action review with project collaborators for the purpose of 

identifying opportunities to make the projects achieve better outcomes in terms of efficiency and 

effectiveness. Document and share.

See response to CONS-4.

RESPONSE

Collaborative approaches to engaging the public and assessing the impacts of federal actions under the 

National Environmental Policy Act (NEPA) can improve the quality of decision-making and increase public 

trust and confidence in agency decisions, and we believe that this plan provides opportunities to do that. 

One of the primary goals of NEPA is to encourage meaningful public input and involvement in the process 

of evaluating the environmental impacts of proposed federal actions. The NEPA process is a public 

process, and the Forest Service is required to “encourage and facilitate public involvement in decisions 

which affect the quality of the human environment” (40 CFR 1500.2(d)).

We appreciate these recommendations, but have not included them in the 2016 Forest Plan. The 

responsible official may identify the need for post-project collaboration as the Forest begins to implement 

the 2016 Forest Plan. If the responsible official believes that this is needed, management approaches 

may be addressed through an administrative change to the plan. 

COMMENT

SPEC-43: Request for chapter 5 changes regarding high value watersheds.

Proposed Plan, Chapter 5, Plan Content Developed Under the 2012 Planning Rule, page 5-7 (High Value 

Watersheds)

Current language: 

“It is expected that at the end of five years following the signing of the Record of Decision (ROD) for this 

proposed plan amendment, the Forest Service would conduct a trend analysis on the annual best 

DEIS Comments and Responses I-210 Final EIS
Appendix I

management practices (BMPs) monitoring of young-growth timber projects that intersect with the 

following watersheds...” 

Replace with the following: 

“It is expected that by the end of the five year period after the signing of the ROD, the Forest Service will 

conduct an internal scientific review together with the Tongass Transition Collaborative and other 

stakeholders to determine likely impact to fish and wildlife habitat from proposed young growth timber 

projects that intersect with the following high-value fish producing watersheds. If harvest is proposed in 

one of these watersheds, the USFS may apply additional standards or guidelines to mitigate risk to fish 

habitat, or may apply a “no net-loss” exchange for other areas for young growth harvest.”

RESPONSE

Edits were made in the Young Growth Management Approaches in Chapter 5 of the Forest Plan that 

capture most of this recommendation. The Forest Service also added the following:

“In addition, it is expected that at the end of five years and ten years following the signing of the 

ROD for this plan amendment, the Forest Service would conduct monitoring with stakeholders to 

determine if the young-growth goals are being achieved, and if not, adjust accordingly.”

The need for additional standards or guidelines (plan components), other than the plan components that 

apply to the LUD where project takes place, would be determined through monitoring. A plan amendment 

is required to add plan components (36 CFR 219.13(a)). Applying a “no net-loss” exchange for other 

areas for young-growth harvest may be a project-specific mitigation measure. 

COMMENT

SPEC-44: Proposed Plan Appendix A – Timber Production Land Suitability, Step 2 – Lands Suited 

and Not Suited for Timber Production Based on Compatibility with Desired Conditions and 

Objectives (FSH 1909.12, Section 61.2), Page A – 4, Item 3. B.

Current language: 

“Within Development LUDs, old-growth stands in Phases 2 and 3 of the 2008 Forest Plan Timber Sale 

Program Adaptive Management Strategy, in the Trout Unlimited TU77 watersheds, and in The Nature 

Conservancy/Audubon Priority Conservation Areas (as shown on maps in the planning record) are 

identified as NOT suitable for timber production, except for small sales after the transition is complete. 

Young-growth stands in all of these areas are identified as suitable for timber production.” 

Replace with the following:

“Within Development LUDs, old-growth stands (as shown on maps in the planning record) in (1) Phases 2 

and 3 of the 2008 Forest Plan Timber Sale Program Adaptive Management Strategy, (2) the Trout 

Unlimited TU77 watersheds, and (3) The Nature Conservancy/Audubon Priority Conservation Areas are 

identified as NOT suitable for timber production. Young-growth stands in all of these areas are identified 

as suitable for timber production.”

RESPONSE

Edits were made in Appendix A of the Forest Plan. 

COMMENT

SPEC-45: The draft TAC recommendations stated, “During the transition period, the annual timber 

volume target should be held constant. Subject to review of the DEIS, the TAC will recommend a 

volume target to hold consistent through the transition period.” The TAC expected to see an 

analysis by the Forest Service of the effects of two different annual volume targets. The DEIS did 

not include an analysis of two volume targets, and the TAC was unable to reach consensus on an 

annual volume target. The range of annual volumes supported by individual TAC members for 

Final EIS I-211 DEIS Comments and Responses
Appendix I

analysis remains at 46MMBF – 70MMBF. We want to be clear that the TAC did not agree to a 

specific annual target.

RESPONSE

The PNW Research Station’s most recent timber demand projections (Daniels et al., 2016) used to inform 

the EIS analysis include a baseline model and three different scenarios displaying alternative futures for 

Southeast Alaska. In the baseline model, 46 MMBF represents the annual average timber demand for 

Tongass timber over the next 15 years – with a range of 41 MMBF to 52 MMBF during the same time 

period. As the forest plan amendment interdisciplinary team began the amendment process and focused 

on timber market demand, 46 MMBF was used to inform timber objectives used during the planning 

process. 

The Daniels et al. (2016) study of long-term timber demand projections is based on economic theory, 

peer-reviewed methodology, and scientific and objective analyses conducted by timber economists and 

forest researchers. Daniels et al. avoids recommending any one scenario as a “most likely” projection 

because of the relatively high degree of uncertainty surrounding developments in Southeast Alaska. The 

baseline model, however, utilizes historical datasets necessary to represent Southeast Alaska timber 

markets and assumes the timber industry in Southeast Alaska will remain at post-2008 recession levels 

for the next 15 years. As such, the baseline annual average of 46 MMBF timber demand from the 

Tongass is considered a conservative and rationale estimate. In addition, the 46 MMBF projection is not 

only represented in the baseline model, but it is also represented in all three scenarios at different points 

in time, and these scenarios represent alternative futures for timber harvest in Southeast Alaska. 

COMMENT 

SPEC-46: In forest-wide objective O-TIM-02 in Chapter 5 of the Forest Plan, clarify the difference 

between “annual market demand” and “projected timber sale quantity (PTSQ)”. Based on the 

definition of PTSQ, the PTSQ timber volume is not a function of demand. Make two separate 

objectives to clarify this distinction. 

RESPONSE

Forest-wide objective O-TIM-01 was written to be a “concise, measurable, and time-specific” statement to 

describe the timber outcomes expected. This forest-wide objective has been revised to avoid confusion. 

DEIS Comments and Responses I-212 Final EIS
Appendix I

Attachment A

Letters from Agencies, Elected Officials, and

Tribal Governments
Date submitted (UTC): 1/31/2016 6:13:23 PM

First name: Rep.

Last name: Josephson

Organization: 

Title: 

Official Representative/Member Indicator: 

Address1: 

Address2: 

City: 

State: 

Province/Region: 

Zip/Postal Code: 

Country: 

Email: Rep.Andy.Josephson@akleg.gov

Phone: 

Comments:

Tongass National Forest Management Plan (due Feb 22, 2016)

Dear Ms. Howle:

I am not a scientist, a fisheries biologist, a timber man or an expert on forest ecology. I am an armchair 

observer of Tongass politics and the forest itself. I am a student of public policy and a citizen concerned with 

our future.

To the extent the following comments can be woven into others and into the USFS?s management plan 

update, I would appreciate it.

My own beliefs are that:

1) What we are doing as a people is not sustainable. The Earth wasn?t designed to hold $7 billion all vying 

for scarce resources. Pressures on those resources are being felt every day. Sometimes the wiser mover is 

the conservative one?conserving a resource. And more than Gifford Pinchot may have foreseen. To the 

extent possible, leave the Tongass Forest in tact, and alone.

2) Do not sell uncut timber, without value added, to overseas or domestic purchasers. 

3) Do not clear cut old growth timber. Lesnoi on Afognak Island has done enough of that, as has 

SeaAlaska.

4) Tourists and cruise ship customers do not want to see denuded landscapes in SE Alaska. They just 

don?t.

5) Do not ever let heavy equipment be driven across a salmon stream.

6) Do not ever let trees be denuded right down to salmon banks.

7) Do not decimate the rest of SE the way that Prince of Wales Island has been. I personally told Secty. 

Vilsack when I met him in the Summer of 2014, that I hoped the USFS lost the litigation related to the Big 

Thorne harvest. He won, and I lost, apparently.

8) It?s ?o.k.? to say ?no?. It?s ?o.k.?
9) Alaska?s industry is already less than 10% of what it was. Don?t bring it back. The economy has 

adjusted. Just leave it alone.

10) Future generations will be unimpressed with the amount of wealth and comfort we?ve amassed since the 

Industrial Revolution. They?ll be more impressed with the natural beauty we protect. 

Thanks for listening,

State Rep. Andy Josephson

Juneau, Alaska
United States Department of the Interior

OFFICE OF THE SECRETARY

Office of Environmental Policy and Compliance 

1689 C Street, Room 119

Anchorage, Alaska 99501-5126

VIA ELECTRONIC MAIL, NO HARD COPY TO FOLLOW

9043.1 

ER 15/0644 February 17, 2016 

PEP/ANC 

Mr. Earl Stewart 

Tongass National Forest 

Attn: Forest Plan Amendment 

648 Mission Street 

Ketchikan, AK 99901 

Subject: Draft Environmental Impact Statement for the Tongass Land and Resources 

Management Plan Amendment, Alaska 

Dear Mr. Stewart: 

The U.S. Fish and Wildlife Service (FWS) has participated as a cooperating agency in 

developing alternatives and providing information for the U.S. Forest Service’s (Forest Service) 

Proposed Land and Resources Management Plan (Forest Plan) amendment for the Tongass 

National Forest (Tongass) and the associated Draft Environmental Impact Statement (EIS) 

currently under review. The Department of the Interior (Department) appreciates the opportunity 

provided to the Department’s FWS to serve as a cooperator. Our comments focus on areas of 

continuing concern and are based on our authorities under the Fish and Wildlife Coordination 

Act and the National Environmental Policy Act. 

General Comments 

The Forest Plan amendment is intended to help accelerate transition away from harvest of oldgrowth forest, in favor of greater reliance on second-growth or “young-growth” forests that have 

regenerated following timber harvest. The Department fully supports this goal, as it has 

excellent potential to reduce impacts of the Forest Service’s timber program on fish and wildlife. 

We understand that a secondary purpose of the Forest Plan amendment is to facilitate 

development of renewable energy on the Tongass. 

Old-growth logging on the Tongass has been controversial, in part due to direct and indirect 

impacts to fish and wildlife caused by clearcut logging and the roads associated with logging. In 

response to these concerns, the Forest Service developed the Tongass Old-Growth Conservation 

Strategy (conservation strategy) in partnership with the FWS, the State of Alaska, and others, as 

part of the 1997 Forest Plan. This conservation strategy features a network of old-growth 
2 

reserves (OGR) and other non-development land use designations to protect important habitat 

and corridors connecting the reserves. The conservation strategy also includes a suite of 

standards and guidelines that direct how timber harvest and other activities must be conducted to 

reduce impacts to vulnerable species. The conservation strategy remains an integral part of the 

current (2008) Forest Plan. The notice of intent (NOI) for the current Draft EIS states, “It is not 

expected that changes made to the Tongass Forest Plan will affect the overall integrity of the 

Plan’s conservation strategy.” We are concerned that some elements of the proposed action, 

(Draft EIS Alternative 2, p. 2-14) or the Forest Service’s preferred alternative (Draft EIS 

Alternative 5, p. 2-31), could significantly weaken the conservation strategy, conflicting directly 

with the expectation stated in the NOI. 

Below, we provide specific recommendations regarding clearcut logging and extensive 

commercial thinning without appropriate slash treatments in riparian management areas, beach 

and estuary fringe, and OGRs. We recommend development and selection of an alternative that 

avoids sensitive areas and important habitats for any renewable energy or transportation projects 

approved under the Forest Plan. We also recommend that specific elements of the conservation 

strategy be updated with the best available scientific data and strengthened by incorporating 

experience from the last 20 years of management, specifically where available information 

suggests the current conservation strategy is not adequate to sustain vulnerable species. 

Specific Comments

Riparian, Beach and Estuary Fringe, and OGR Logging 

Riparian areas have been protected from logging to maintain water quality, streambank stability, 

and habitat for fish and wildlife across the country for many decades. The Tongass Timber 

Reform Act (TTRA, H.R. 987) has mandated protection of riparian buffers along fish-bearing 

streams and many of their tributaries on the Tongass since 1990. The TTRA buffers have been 

expanded for many channel types where scientific information or management experience 

showed that additional protection was warranted to minimize impacts from logging. These 

standards should be relaxed only if reliable scientific evidence clearly demonstrates that the 

protection is not necessary. Such findings are not presented in the Draft EIS. Also, the Draft 

EIS contains little evaluation of the consequences of relaxing the existing standards. We 

recommend the Final EIS include scientific or data-based recommendations supporting proposed

management changes and provide a more robust discussion of impacts of proposed changes. 

Beach fringe is defined in the Forest Plan as, “the area inland from saltwater shorelines that is 

typically forested.” The current Forest Plan forbids clearcut logging within 1,000 feet of 

saltwater shorelines to protect habitat for many species of wildlife, including deer, bears, bald 

eagles, otters, geese, and many others. Both the proposed action and preferred alternative would 

allow clearcutting and commercial thinning in beach fringe. Large forest openings and extensive 

timber thinning without appropriate slash treatments can interfere with animal movements and 

increase vulnerability of some species to predation, harvest by humans, and/or exposure to deep 

snow and severe weather. We recommend that the selected alternative limit young-growth 

treatments to actions that maintain or improve wildlife habitat in beach and estuary fringe forest. 

We also recommend openings be limited to two acres or less in order to maintain hunting habitat 

for goshawks and provide thermal cover for deer. Moreover, we recommend that slash be 
3 

treated to allow unconstrained movement of deer, bears, wolves, and other species. We also 

recommend against creating openings in beach fringe where a corridor of mature or old forest 

less than 660 feet wide would be left, in order to maintain effective thermal cover (Concannon 

1995). 

Similarly, OGRs have been designated specifically to support wildlife dependent on old-growth 

forest. To achieve maximum conservation benefit, treatments in OGRs should be designed 

primarily to accelerate development of old-growth characteristics without compromising 

landscape connectivity and animal movement. For instance, thinning with slash treatment, 

pruning of lower branches to improve light penetration, small patch cuts, and narrow strip cuts 

might all be used to treat second-growth in OGRs to accelerate development of old-growth 

characteristics. We strongly recommend against creating large clearcut openings in OGRs, given 

the importance of this productive old-growth forest for a variety of species. 

Management actions that reduce long-term habitat values (by clearcutting in riparian areas, 

beach fringe, or OGRs) or disrupt movement of animals through logged landscapes (by cutting in 

designated corridors such as beach fringe and riparian zones) could undermine the intent and the 

functioning of the conservation strategy. We recommend against allowing such actions, which 

we believe seriously compromise the integrity of the conservation strategy. 

If inadequate young-growth timber is available to meet demands outside of riparian, beach and 

estuary fringe, and OGRs, we recommend that additional alternatives be developed to offer only 

the volume of young-growth that can be produced without impacting these sensitive areas. If 

necessary, additional old-growth could potentially be offered from areas with lower 

environmental sensitivity, to offset reductions in young-growth availability. We also 

recommend that one or more alternatives be developed to evaluate longer timber harvest 

transition periods, if necessary, to avoid creating large openings in these sensitive habitats. 

Renewable Energy and Transportation Systems Corridors 

All action alternatives identified in the Draft EIS would remove the Transportation and Utility 

Systems Overlay land use designation, which identifies “windows” where road and utility 

corridors are deemed compatible and “avoidance areas” where roads and other human 

infrastructure would conflict with other resource values. Current guidance would be replaced by 

direction in the Transportation Systems Corridors section, which is intended to facilitate the 

availability of Tongass lands for development of transportation systems (Proposed Forest Plan, 

pp. 5-13 to 5-15). The proposed direction removes constraints on development of roads and 

utility corridors, while adjusting management of other resources to allow development of these 

corridors. 

We recommend that sensitive habitats be avoided when renewable energy facilities or 

transportation and utility corridors are proposed, studied, and ultimately developed. We support 

inclusion of plan components that require siting roads and other infrastructure outside of OGRs, 

beach fringe, designated wildlife corridors, and other sensitive areas unless an analysis 

demonstrates that there are no practical alternatives. The action alternatives evaluated in the 

Draft EIS do not appear to require this analysis, which leads to the presumption that construction 

of roads and renewable energy facilities are allowed wherever they may be proposed, 
4 

irrespective of habitat values. This proposed approach could undermine the integrity of the 

conservation strategy, which was designed to protect important habitat in specific locations from 

human impacts. 

Updating Plan Components for Wildlife 

Alexander Archipelago Wolf 

Concerns over documented, unsustainable mortality of wolves on Prince of Wales Island have 

triggered several reviews, recently resulting in a petition to list the endemic Alexander 

Archipelago wolf as threatened or endangered under the Endangered Species Act. The latest 

FWS status assessment (FWS 2015) reviewed the status of the wolf across its range and for 

several discrete populations. The greatest concern continues to be for wolves on Prince of Wales 

and surrounding islands. The wolf population there appears to have declined from about 350 

wolves in the 1990s and early 2000s to approximately 89 wolves in 2014 (FWS 2015). This 

decline is believed to be due to the combined effects of both legal and unreported (illegal) 

harvest of wolves, facilitated by an extensive network of logging roads and declining deer 

numbers, which in turn are associated with the loss of winter habitat and regeneration of younggrowth forests in intensively logged areas. Despite concerns that the wolf population on Prince 

of Wales has declined and will likely continue to decline, the FWS did not list the wolf as 

threatened or endangered because loss of the Prince of Wales population is not expected to affect 

survival or vulnerability of the subspecies across the rest of its range (Federal Register 81(3), pp. 

435-458). 

Under the Forest Service’s 1982 planning rule (47 FR 43037, Sept. 30, 1982), which continues to 

apply to most of the wildlife standards and guidelines in the proposed Forest Plan, the Tongass 

must be managed to provide for viable, well-distributed populations of native wildlife. We 

believe that this includes maintaining the wolf population on Prince of Wales Island. 

Implementation of existing standards and guidelines intended to protect wolves from 

unsustainable harvest and habitat loss appears to be inadequate for the wolves on Prince of 

Wales, given the population’s documented decline. For example:

 Management of road densities to limit hunter and trapper access is recommended, but not 

required by the current standards and guidelines, and most areas on Prince of Wales 

exceed the recommended 0.7 to 1.0 miles of road per square mile; 

 Maintenance of deer habitat capability (as calculated by the interagency deer habitat 

model) to sustain wolf populations and human hunters appears to be required by the 

current Forest Plan, but many areas fall short of the specified 18 deer per square mile. 

Recent timber sales have reduced deer habitat capability further; and 

 A wolf habitat management program is to be developed where wolf mortality concerns 

have been expressed, but no such program has been developed despite repeated 

expressions of concern by the FWS, the Department, and others, as well as the 

completion of various interagency studies of wolf mortality. 

The Forest Plan amendment process offers an opportunity to strengthen the wolf standards and 

guidelines to help the Forest Service maintain or increase the amount of secure and high-value 

habitat required to maintain a viable wolf population on Prince of Wales. We recommend that a 
5 

wolf habitat management program be developed, as recommended by the Forest Plan. The FWS 

can provide assistance in development of this management program. 

Additionally, we recommend that road density guidelines be strengthened to require reduction of 

road densities where wolf harvest mortality exceeds sustainable levels in areas where roads 

provide access for wolf trapping. We also recommend that no future timber sales be allowed that 

reduce deer habitat capability in areas where it is already below levels believed to be necessary 

to support human hunters and wolves. 

Queen Charlotte Goshawk 

Standards for management of northern goshawk nesting habitat should also be updated to reflect 

the best available science. Much of the current science on management of goshawk nesting 

habitat in the coastal rainforests of the North Pacific coast is reviewed in McClaren et al. (2015). 

We recommend modification of two elements of the Forest Plan to better protect goshawks, 

which are vulnerable to habitat loss and disturbance from forest management practices. 

Goshawks are known to forego nesting in years with low prey abundance and/or inclement 

spring weather. Nest sites are routinely inactive for a few years, then become active again when 

conditions are favorable. The current Forest Plan allows nest protections to be dropped after two 

consecutive years of inactivity. We strongly recommend that this standard be modified to 

protect documented goshawk nesting stands indefinitely, unless an active nest is detected 

elsewhere in the same goshawk territory. The FWS has worked with the Forest Service directly 

to develop suggested language for an updated plan component to accomplish this goal. We 

recommend that the modified standard be included in the selected alternative. 

Fledgling goshawks typically learn to fly and hunt in an area of about 500 acres adjacent to their 

nest stand. Forest management to maintain suitable hunting habitat in the area around the nest is 

thought to be important for maintaining productivity of goshawk nesting territories. We 

therefore recommend that post-fledging areas around known or suspected nest sites be managed 

to prevent creation of large forest openings, which are avoided by goshawks. 

Legacy Forest Structure

The current Forest Plan requires retention of legacy forest structure in old-growth harvest units 

greater than 20 acres, in areas where logging has been most intensive. The intent of this standard 

is to ensure that sufficient residual trees, snags, and clumps of trees remain in timber harvest 

units in watersheds that have had concentrated past timber harvest activity and are at risk for not 

providing the full range of matrix functions (Proposed Forest Plan, track changes version, p. 4-

90). Areas of extensive young-growth, which will support increasingly greater proportions of 

the Tongass’s timber harvest into the future, often lack adequate residual structure. 

We strongly recommend that the selected alternative include updated Forest Plan components 

that restore habitat-related functions provided by older forest structure, where past logging has 

left large areas of young-growth. Retention of residual old-growth, supplemented by secondgrowth where inadequate old-growth remains, will help move harvested stands toward a 
6 

condition that will support a broader variety of wildlife in the future as retained young-growth 

stands mature. 

Alternatives 3 and 4 in the Draft EIS would apply the existing legacy forest structure standards 

(designed for old-growth logging) to young-growth harvest (Draft EIS, Appendix F, pp 3-4). 

The existing standard requires retention of 30 percent of each harvested stand, in watersheds 

where the standard applies. We believe that a legacy forest structure standard designed 

specifically for young-growth harvest may not necessarily match existing standards and 

guidelines designed for old-growth logging. Instead, we recommend that new Forest Plan 

components consider the amount and distribution of residual old-growth and require retention of 

additional young-growth as necessary to meet the intent of the standard. This could reduce 

impacts on young-growth timber volume availability, while providing adequate structure to 

improve habitat values into the future. We encourage development of guidance on treatments 

that would accelerate succession of retained young-growth toward old-growth conditions. If 

retention of structure in young-growth stands would delay the transition to primarily younggrowth harvest, we recommend additional alternatives that use a longer transition period be 

developed and fully evaluated. 

Thank you for the opportunity to collaborate as a partner in your effort to amend the Forest Plan. 

If you have any questions on our comments, please feel free to contact Steve Brockmann, 

Southeast Alaska Coordinator for the FWS, at 907-780-1181 or at steve_brockmann@fws.gov. 

 Sincerely, 

 Philip Johnson, PhD 

 Regional Environmental Officer 

cc: Jackie Timothy, Alaska Department of Fish and Game 

Literature Cited 

Concannon, J.A. 1995. Characterizing structure, microclimate and decomposition of peatland, 

 beachfront, and newly logged forest edges in southeastern Alaska. PhD Dissertation, Univ of 

 Washington. 325 pp. 

McClaren, E.L., T. Mahon, F.I. Doyle, and W.L. Harrower. 2015. Science-based guidelines for 

 managing northern goshawk breeding areas in coastal British Columbia. Journal of 

 Ecosystems and Management 15(2):1-91. 

U.S. Fish and Wildlife Service. 2015. Species status assessment for the Alexander Archipelago 

 wolf (Canis lupus ligoni). December 2015. Alaska Region, Anchorage, Alaska. 162 pp.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION 10 

1200 Sixth Avenue, Suite 900 

Seattle, WA 98101-3140 

February 22, 2016 

M. Earle Stewart, Supervisor, Tongass National Forest 

Attn: Forest Plan Amendment 

648 Mission Street 

Ketchikan, Alaska 99901 

Dear Mr. Stewart: 

OFFICE OF 

ECOSYSTEMS, TRIBAL 

AND PUBLIC AFFAIRS 

Thank you for the opportunity to review the Draft Environmental Impact Statement for the Tongass 

Land and Resource Management Plan Amendment, Tongass National Forest, in southeast Alaska (EPA 

Project #14-0026-AFS). We have reviewed the Draft EIS in accordance with our responsibilities under 

the National Environmental Policy Act and Section 309 of the Clean Air Act. Specifically Section 309 

directs EPA to review and comment in writing on the environmental impacts of major federal agency 

actions. Our review considered the evaluation of the anticipated environmental impacts, as well as the 

adequacy of the EIS in meeting procedural and public disclosure requirements of NEPA. 

Based on our review, we have assigned the Draft EIS a rating ofEC-2 (Environmental ConcernsInsufficient Information). We believe that the most recent, southeast Alaska-specific data and 

information should be incorporated into the climate and greenhouse gas analyses and discussion in the 

final EIS. An explanation of our rating system is enclosed (Enclosure 1 ). In general, we support the 

selection of the Forest Service and Technical Advisory Committee's preferred alternative, Alternative 5. 

We believe Alternative 5 meets the direction of Secretarial Memorandum 1044-009 by accelerating the 

transition to young-growth, while also providing greater flexibility for alternative energy projects, and 

appropriate review of inventoried roadless areas. 

We appreciate the inclusion of a "track changes" version of the 2008 Forest Plan and the scoping and 

comment summary report (Appendix A) in the Draft EIS. These resources greatly facilitated our 

review. An Executive Summary would also have been helpful, especially to stakeholders who might not 

be able to review the full document. We recommend that an Executive Summary be included in the 

Final EIS. 

As we stated in our scoping comments, we support appropriate updates to standards and guidelines that 

reflect the most recent management science regarding ecological services, climate change and resiliency. 

We also recognized the need for adequate socioeconomic analysis to promote the sustainability of 

Southeast Alaska communities, particularly tribal, low income and minority communities, dependent on 

timber harvesting and other activities on the Tongass. We believe the Tongass Amendment EIS 

adequately accomplishes this through the thorough analyses and evaluation of management alternatives, 

resources and projected outcomes and goals. We also appreciate that 1.1,broad l'ange of potential activity 

types, such as communication sites, renewable power projects, and mining, as weli as timber harVest 

were considered in this programmatic document. We believe doing so allows for greater disclosure to 

and participation of stakeholders, potential permittees and forest users. 
Finally, we have recornniendations for your consideration in the area of climate change and greenhouse 

gas emissions in the Final EIS. We appreciate the thorough discussion in the Draft EIS of the various 

factors that affect and drive climate in southeast Alaska. We also recognize that, in addition to the 

USDA Secretarial Memorandum 1044-009, another primary driver for undertaking this Forest Plan 

amendment is to consider changes in forest management and health as a consequence of a changing 

climate. 

We belfove the Affected Environment section contains adequate discussion of climate inputs and 

possible anthropogenic effects on climate. We recommend, however, that the most recent sources of 

data for Alaska be used wherever possible. For example, our own Climate Impacts in Alaska website 

(http://www3.epa.gov/climatechange/impacts/alaska.html) references the 2014 National Climate 

Assessment (http://nca2014.globalchange.gov/report/regions/alaska#intro-section), which states Alaska 

temperatures have increased approximately 3 degrees F in the last 60 years. Also, current data from The 

Alaska Climate Research Center indicates that while total mean seasonal and annual temperatures in 

Alaska from 1959 to 2014 reflect an increase in temperature, temperatures from 1979 to 2014 generally 

show a decline in mean seasonal and annual temperatures 

(http://akclimate.org/ClimTrends/Change/TempChange.html) in most of Alaska, including southeast 

Alaska. This trend, along with increased ice extent in the Bering Sea, differs from trends identified in the 

Arctic, such as increased temperatures and decreased overall Arctic ice extent. We believe assessment 

of climate change for the Tongass should be as specific to southeast Alaska as practicable. 

The Final EIS might also consider the following additional factors for incorporation into the relevant air 

quality and climate change sections of the main document, or as an appendix. These include 

quantification of GHG emissions from the proposed action and appropriate quantitative or qualitative 

analytical methods to ensure useful information is available to inform the public and the decisionmaking process in distinguishing between alternatives and mitigations. 

Thank you again for the opportunity to review the Draft Environmental Impact Statement for the 

Tongass Land and Resource Management Plan Amendment. Please contact Jennifer Curtis of my staff 

in Anchorage at 907-271-6324 or curtis.jennifer@epa.gov with any questions you may have. 

Christine B. Littleton, Manager 

Environmental Review and Sediments Management Unit 

Enclosure: 

1. U.S. Environmental Protection Agency Rating System For Draft Environmental Impact Statements 

2 
Date submitted (UTC): 2/22/2016 12:00:00 AM

First name: Christine B.

Last name: Littleton

Organization: United States Environmental Protection Agency, Region 10

Title: Office of Ecysystems, Tribal and Public Affairs

Official Representative/Member Indicator: 

Address1: 1200 Sixth Avenue, Suite 900

Address2: 

City: Seattle

State: WA

Province/Region: 

Zip/Postal Code: 98101-3140

Country: United States

Email: curtis.jennifer@epa.gov

Phone: 907-271-6324

Comments:

February 22, 2016

M. Earle Stewart, Supervisor, Tongass National Forest

Attn: Forest Plan Amendment

648 Mission Street

Ketchikan, Alaska 99901

Dear Mr. Stewart:

Thank you for the opportunity to review the Draft Environmental Impact Statement for the Tongass Land and 

Resource Management Plan Amendment, Tongass National Forest, in southeast Alaska (EPA Project #14-

0026-AFS). We have reviewed the Draft EIS in accordance with our responsibilities under

the National Environmental Policy Act and Section 309 of the Clean Air Act. Specifically Section 309 directs 

EPA to review and comment in writing on the environmental impacts of major federal agency actions. Our 

review considered the evaluation of the anticipated environmental impacts, as well as the adequacy of the EIS 

in meeting procedural and public disclosure requirements of NEPA.

Based on our review, we have assigned the Draft EIS a rating of EC-2 Environmental Concerns Insufficient 

Information). We believe that the most recent, southeast Alaska-specific data and information should be 

incorporated into the climate and greenhouse gas analyses and discussion in the final EIS. An explanation of 

our rating system is enclosed (Enclosure 1). In general, we support the selection of the Forest Service and 

Technical Advisory Committee's preferred alternative, Alternative 5. We believe Alternative 5 meets the 

direction of Secretarial Memorandum 1044-009 by accelerating the transition to young-growth, while also 

providing greater flexibility for alternative energy projects, and appropriate review of inventoried roadless areas.

We appreciate the inclusion of a "track changes" version of the 2008 Forest Plan and the scoping and 

comment summary report (Appendix A) in the Draft EIS. These resources greatly facilitated our review. An 

Executive Summary would also have been helpful, especially to stakeholders who might not be able to review 

the full document. We recommend that an Executive Summary be included in the

Final EIS.

As we stated in our scoping comments, we support appropriate updates to standards and guidelines that reflect 

the most recent management science regarding ecological services, climate change and resiliency. We also 

recognized the need for adequate socioeconomic analysis to promote the sustainability of Southeast Alaska 

communities, particularly tribal, low income and minority communities, dependent on timber harvesting and 

other activities on the Tongass. We believe the Tongass Amendment EIS adequately accomplishes this 

through the thorough analyses and evaluation of management alternatives,

resources and projected outcomes and goals. We also appreciate that a broad range of potential activity types, 

such as communication sites, renewable power projects, and mining, as well as timber harvest were 

considered in this programmatic document. We believe doing so allows for greater disclosure to

and participation of stakeholders, potential permittees and forest users.

Finally, we have recommendations for your consideration in the area of climate change and greenhouse gas 
emissions in the Final EIS. We appreciate the thorough discussion in the Draft EIS of the various factors that 

affect and drive climate in southeast Alaska. We also recognize that, in addition to the

USDA Secretarial Memorandum 1044-009, another primary driver for undertaking this Forest Plan amendment 

is to consider changes in forest management and health as a consequence of a changing climate.

We believe the Affected Environment section contains adequate discussion of climate inputs and possible 

anthropogenic effects on climate. We recommend, however, that the most recent sources of data for Alaska be 

used wherever possible. For example, our own Climate Impacts in Alaska website 

(http://www3.epa.gov/climatechange/impacts/alaska.html) references the 2014 National Climate Assessment 

(http://nca2014.globalchange.gov/report/regions/alaska#intro-section), which states Alaska temperatures have 

increased approximately 3 degrees F in the last 60 years. Also, current data from The Alaska Climate 

Research Center indicates that while total mean seasonal and annual temperatures in Alaska from 1959 to 

2014 reflect an increase in temperature, temperatures from 1979 to 2014 generally show a decline in mean 

seasonal and annual temperatures

(http://akclimate.org/ClimTrends/Change/TempChange.html) in most of Alaska, including southeast Alaska. 

This trend, along with increased ice extent in the Bering Sea, differs from trends identified in the Arctic, such as 

increased temperatures and decreased overall Arctic ice extent. We believe assessment

of climate change for the Tongass should be as specific to southeast Alaska as practicable.

The Final EIS might also consider the following additional factors for incorporation into the relevant air quality 

and climate change sections of the main document, or as an appendix. These include quantification of GHG 

emissions from the proposed action and appropriate quantitative or qualitative analytical methods to ensure 

useful information is available to inform the public and the decision-making process in distinguishing between 

alternatives and mitigations.

Thank you again for the opportunity to review the Draft Environmental Impact Statement for the Tongass Land 

and Resource Management Plan Amendment. Please contact Jennifer Curtis of my staff in Anchorage at 907-

271-6324 or curtis.jennifer@epa.gov with any questions you may have.

Christine B. Littleton, Manager

Environmental Review and Sediments Management Unit

Enclosure:

1. U.S. Environmental Protection Agency Rating System For Draft Environmental Impact Statements
LO - Lack of Objections 

U.S. Environmental Protection Agency Rating System for 

Draft Environmental Impact Statements 

Definitions and Follow-Up Action* 

Environmental Impact of the Action 

The U.S. Environmental Protection Agency (EPA) review has not identified any potential environmental 

impacts requiring substantive changes to the proposal. The review may have disclosed opportunities for application 

of mitigation measures that could be accomplished with no more than minor changes to the proposal. · 

EC - Environmental Concerns 

EPA review has identified environmental impacts that should be avoided in order to fully protect the 

environment. Corrective measures may require changes to the preferred alternative or application of mitigation 

measures that can reduce these impacts. 

EO - Environmental Objections 

EPA review has identified significant environmental impacts that should be avoided in order to provide 

adequate protection for the environment. Corrective measures may require substantial changes to the preferred 

alternative or consideration of some other project alternative (including the no-action alternative or a new 

alternative). EPA intends to work with the lead agency to reduce these impacts. ' 

EU - Environmentally Unsatisfactory 

EPA review has identified adverse environmental impacts that are of sufficient magnitude that they are 

unsatisfactory from the standpoint of public health or welfare or environmental quality. EPA intends to work with 

the lead agency to reduce these impacts. If the potential unsatisfactory impacts are not corrected at the final EIS 

stage, this proposal will be recommended for referral to the Council on Environmental Quality (CEQ). 

Adequacy of the Impact Statement. 

Category 1 -Adequate 

EPA believes the draft EIS adequately sets forth the environmental impact( s) of the preferred alternative and 

those of the alternatives reasonably available to the project or action. No further analysis of data collection is 

necessary, but the reviewer may suggest the addition of clarifying language or information. 

Category 2 - Insufficient Information 

The draft EIS does not contain sufficient information for EPA to fully assess environmental impacts that should 

be avoided in order to fully protect the environment, or the EPA reviewer has identified new reasonably available 

alternatives that are within the spectrum of alternatives analyzed in the draft EIS, which could reduce the 

environmental impacts of the action. The identified additional information, data, analyses or discussion should be 

included in the final EIS. 

Category 3 - Inadequate 

EPA does not believe that the draft EIS adequately assesses potentially significant environmental impacts of the 

action, or the EPA rev~ewer has identified new, reasonably available alternatives that are outside of the spectrum of 

alternatives analyzed in the draft EIS, which should be analyzed in order to reduce the potentially significant 

environmental impacts. EPA believes that the identified additional information, data, analyses, or discussions are of 

such a magnitude that they should have full public review at a draft stage. EPA does not believe that the draft EIS is 

adequate for the purposes of the National Environmental Policy Act and or Section 309 review, and thus should.be 

formally revised and made available for public comment in a supplemental or revised draft EIS. On the basis of the 

potential significant impacts involved, this proposal could be a candidate for referral to the CEQ. 

* From EPA Manual 1640 Policy and Procedures for the Review of Federal Actions Impacting the Environment. 

February, 1987. 
Alaska State Legislature

State Capitol

Juneau, Alaska

99801-1182

Juneau Delegation

Senator Dennis Egan 

Representative Cathy Muñoz

Representative Sam Kito III

22 February 2016

M. Earl Stewart

Forest Supervisor, Tongass NF 

Attn: Forest Plan Amendment

648 Mission Street

Ketchikan, AK 99901

Dear Mr. Stewart: 

We are writing in response to the release of the Proposed Amended Land and Resource 

Management Plan (Proposed Forest Plan) and Draft Environmental Impact Statement (DEIS) 

for the Tongass National Forest. As you note in your release, the Proposed Forest Plan and 

associated DEIS are the first developed under the 2012 Planning Rule. We applaud your efforts 

and recognize the significance of charting a sound course for management activities in 

Southeast for the next 10 to 15 years.

As a delegation, we support a plan that manages for sustainability and encourages a viable and 

long-term timber industry that will provide jobs and opportunities for generations to come. In 

particular, we look forward to a plan that encourages renewable energy resource development 

and value-added timber processing so that, in keeping with Article VIII of the Alaska 

Constitution, these resources are used for the maximum benefit of Alaskans. We support local 

processing—turning timber into musical instruments, furniture, flooring, and other wood 

products—so that more Alaskans are employed for each acre harvested.

Providing clear and strategic guidance for the Tongass National Forest is an important priority 

for Southeast residents and businesses alike. We thank you for your attention to the public 

comments made on this issue and appreciate your diligence in incorporating this feedback into 

your final plan.

Sincerely,

 

 

Senator Dennis Egan Rep. Cathy Muñoz Rep. Sam Kito III

Senate District Q House District 34 House District 33
February 22, 2015 

Forest Supervisor 

Tongass national Forest 

Attn: Forest Plan Amendment 

648 Mission Street 

Ketchikan, AK 99901 

Re: Comments on Proposed Tongass Nation Forest Land and Resource Management Plan 

 And the draft EIS 

Thank you for allowing us this opportunity to comment on the Proposed Tongass National 

Forest Land and Resource Management Plan and the draft EIS. 

Our understanding is that the primary changes in this plan is focusing on the transition from 

harvesting old growth to young growth. But as a community who has experienced the downside 

of the lack of a supply of old growth timber, we are concerned in the ability of the USFS to 

provide an economically viable supply of young growth timber, and to do it within the 15 year 

time frame as charged by the Secretary of Agriculture. We are concerned that the inventory 

data is generalized, and therefore we support and encourage development of an accurate 

inventory of young growth availability. 

This inventory is critical for a complete and accurate economic analysis of the transition on 

communities and industry. Loss of harvesting volume is not a result in decline in demand, it is a 

result from the loss of economic sales available to industry and the slow process the USFS 

undertakes to develop sales due to an ongoing fear of lawsuits. No business can operate 

economically in such an environment and thus the loss in industry opportunity. 

 The plan fails to consider social and economic metrics to measure outcomes of the 

transition from old growth to young growth. Metrics showing the impacts to industry and 

also to communities. 

 Appendix C Watershed Analysis: There has been so much discussion of late regarding 

“watershed” analysis and impacts within the T77 watersheds. Based on our own 

personal experience with the Wrangell Island Sale, an actual stream “watershed” for a 

harvest unit or harvest area, may be smaller than the T77 defined watershed. Yet the 

USFS is trying to utilize the T77 watershed analysis. The Plan needs to clarify its 

definition and use of watershed analysis vs. the T77 watersheds. 

 We support the relaxation of Standards and Guides for the harvest of Young Growth 

during the transition in land use designations that may normally minimize or prohibit 

some commercial harvesting if it will provide economic sales of young growth timber. 

 

CITY AND BOROUGH OF WRANGELL

INCORPORATED MAY 30, 2008

P.O. BOX 531 (907)-874-2381

Wrangell, AK 99929 FAX (907)-874-3952

 www.wrangell.com
2 

 Appendix F Visual Priority Routes and Scenic Integrity. According to our Wrangell 

District, for some reason it appears that all of Wrangell’s Forest Roads are designated a 

Visual Priority Route. While we agree that the main roads do have a visual preference, 

not all of the roads need to be classified a visual priority route to limit timber or other use. 

( Originally, some of these designations were going to be dealt with in the upcoming 

Wrangell Island Sale, but now we understand that will not happen and we have to 

address it here. Only the road management plan – what stays open, what will be closed 

and level of use will now be addressed in the Wrangell Island Sale. ) For example, the 

back side of the Nemo-Skip Loop Road (6267) (From Turn Island where the road turns 

northeast back to intersection of #6265 to Earl West) is heavily timbered and more out of 

site out of mind and a good area in which to continue to permit timber harvest. Yes it is 

on a loop so makes for a fun day trip, but there is nothing wrong with timber harvesting. 

Questions can be answered with educational materials about timber harvesting practices 

and economic values to communities. 

Every road on Wrangell Island will meet one of the primary criteria for a visual priority 

route – for example the water routes of small and midsize boats. We are on an island. 

Timber roads climb mountains that provide views, over looks are created for turn outs for 

logging trucks and once trees are harvested, you can see the water. It does not mean 

that each road should be a visual priority route. All roads should be analyzed as a 

whole, and key stretches of roads identified. Off shoots of some of the priority roads 

that receive minimal traffic could be reclassified as non visual priority. 

 Tourism is the big growth industry since supply of timber to harvest and political affects 

have reduced the opportunity for the timber industry. The plan also fails in considering 

the social and economic metrics to measure outcomes of tourism growth for 

communities and businesses and the impacts to recreational sites 

We understand that the USFS has selected as its preferred alternative, Alternative 5 that was 

proposed by the Tongass Advisory Committee. While the Borough is not agreeing or 

disagreeing with that alternative specifically, we do understand that their proposed amendment 

included additional recommendations that were not necessarily “plan” amendments. Yet their 

recommendation was to be presented as a package. If Alternative 5 is implemented, we believe 

the other components of their recommendation, including the monitoring, bringing stakeholder 

participation in earlier in planning processes, USFS internal culture change, inventory 

assessments and social economic impact analysis are critical components of any plan 

implementation strategy. 

Sincerely, 

Jeff Jabusch 

Borough Manager 

CC: Mayor David Jack 

 Borough Assembly 

 Carol Rushmore, Economic Director/Planner 







Ketchikan Indian Community 

Cultural Resources Department 

429 Deermount Street. 

Ketchikan, AK 99901 

(907) 228-9445 

February 22, 2016 

Forest Supervisor, Tongass National Forest 

Attn: Forest Plan Amendment 

648 Mission Street, Ketchikan, AK 99901 

Re: Tongass Land and Resources Management Plan (Forest Plan) Amendment 

Ketchikan Indian Community (KIC) has benefited by having USFS staff attend Tribal Council 

meetings reporting on activities and projects of concern to the tribe. Continuing to support this 

level of communication will inevitably lead to increased cooperation and collaboration between 

USFS and KIC in the coming months and years. 

KIC is appreciative in general of the USFS’s attempt on behalf of the general public to protect 

and preserve our National Forests for suitable and sustainable multiple use goals and objectives. 

Some of those Uses found listed in Chapter 2 for the Forest Plan (i.e. Biodiversity, Fish, 

Wildlife, Plants, Soil and Water, Wetlands Heritage Resources, Sacred Sites and Subsistence) to 

name a few of the twenty (20) Uses specified are very key to tribal members. It is important for 

USFS to remember that though “Timber” Use predominates the planning effort and staff 

resources “Timber” still only 1 out of 20 Multiple Uses specified to be managed for in the 

Tongass Forest Plan. 

Timber harvest should not negatively impact the other identified goals and objectives of the 

Forest Plan disproportionate to its value, especially when it is not supporting a significant 

number of private sector jobs. It is my understanding that approximately half the trees logged on 

the Tongass are exported as unprocessed logs. On the surface this business model requires little 

long-term investment in Alaska and employs comparatively few Alaskans and potentially 

squanders a valuable resource. 

Southeast Alaska’s culture and economy is based on a well-functioning ecosystem. Ecosystem 

Services and the secondary benefits provided by a healthy forest include both the subsistence 

resources: fish, deer and berries, that fill freezers of many KIC members; and to employment 

opportunities and dollars brought in by tourism and fishing. To this end it would be desirable to 

focus forest management resources at restoring watersheds impacted by logging and support job 

creation in fishing, hunting, general outdoor recreation, renewable energy, mariculture and 

tourism. 

In regards to the Forest Plan Preferred Alternative 5: There is concern over impacts to Riparian 

Management Areas (RMAs), especially Beach and Estuary fringe areas where the likelihood of 

damaging subsistence and cultural heritage resources is greater than upland areas. Nevertheless, 

Beach and Estuary fringe areas become less protected with this new Forest Plan. Additional 
oversight by USFS staff would be essential to minimize impacts and mitigate damages of any 

land disturbing activity in Beach and Estuary fringe areas permitted under this new Forest Plan. 

Another concern is what will be required to be monitored before during and after timber harvest, 

in other words the quality and quantity of monitoring. It is our understanding that a separate 

Monitoring Plan tied to this Forest Plan will be developed in the near future. In a recent meeting 

of TAC it was stated and not disputed that due to limited USFS staff some logging sites have in 

the past received only a windshield surveys, rather than boots on the ground for through and 

frequent inspections. We strongly encourage a robust monitoring plan and enough staff to be 

present at logging sites before during and after harvest. Supported by a budget that is adequate to 

accomplish this task, funded if necessary by increased fees paid by companies harvesting timber 

to allow for this monitoring and subsequent restoration. And that this Monitoring Plan be 

developed sooner rather than later and applied retroactively to timber sales approved and 

ongoing before such a Monitoring Plan is complete and approved. 

Tribal Members especially those actively engaged in carving and weaving are extremely 

concerned over status of Yellow Cedar. Tlingit, Haida and Tsimshian people use the rot-resistant 

wood for canoe paddles and totem poles. They can take a lengthwise strip of bark from a living 

tree for weaving baskets and hats, and as backing in blankets. The tree can compartmentalize the 

injury and continue growing. However, the yellow cedar’s shallow roots make the tree 

vulnerable to changes brought on by climate warming. It is our understanding that the USFS has 

been studying yellow cedar decline in Southeast Alaska for many years. A 2014 USFS finding 

document states “substantial information indicating that listing this species may be warranted”. 

If this is the case, and tribal members feel that it is, the Forest Plan should limit timber harvest of

healthy Yellow Cedar until this issue of decline can be addressed. With the goal of maintaining 

healthy stands of Yellow Cedar wherever possible for as long as possible. 

KIC does not outright oppose the Timber Industry but desires harvesting to be done in a 

sustainable way rather than driven by short-term economic gain for a relative few companies and 

individuals. We strongly encourage USFS to only implement forest management actions that 

protect and maintain, subsistence and cultural values. Southeast Native Alaskans, and other 

people groups derive significant value from a healthy Tongass National Forest and surrounding 

ecosystem. Keeping it that way is essential for what KIC Leadership considers “Our Way of 

Life”.

I am appreciative of the opportunity for review documentation and to provide input. 

Sincerely, 

Tony R Gallegos, Cultural Resources Director 

Work: (907) 228-9445

Email: tgallegos@kictribe.org


Earl Stewart, Forest Supervisor 

Tongass National Forest 

648 Mission St. 

Ketchikan, AK 99901 

Re: Tongass Land and Resource Management Plan 

comments-alaska-tongass@fs.fed.us

 February 22, 2016

Dear Mr. Stewart, 

The City of Kupreanof respectfully submits the following comments in response to the 

Draft Environmental Impact Statement (DEIS) of the Proposed Tongass Land and 

Resource Management Plan (LRMP). Due to the past half century of politically-driven 

decisions of your predecessors to sign-off on unsustainable, large-scale industrial 

clearcutting of the Tongass National Forest, our island ecosystems have been tragically 

compromised on an island-wide, landscape level of impairment. Elsewhere whole 

watersheds have been rendered incapable of maintaining stable and productive 

populations of Sitka blacktail deer and are no longer capable of meeting basic local 

subsistence needs. 

The entirety of nearby Mitkof Island has suffered the most restrictive season and bag 

limits in all of Southeast for the last 45 years. These restrictions to local hunters remain in 

place to this day even after a total hunting closure which lasted over 17 years. Previous to 

large-scale clearcutting which targeted low elevation, high volume old growth on Mitkof 

island, the area provided among the most abundant deer populations in all of Southeast 

Alaska. 
In 1961, the Alaska Department of Fish and Game (ADFG) published a statistical 

summary of the season’s deer hunter harvest in all Southeast communities. In terms of 

hunter success, Petersburg ranked the highest of all communities of Southeast with a 

hunter success rate of 97%. 

 

 In 1961 Petersburg ranked the highest of all communities of Southeast in terms of 

highest average number of deer per hunter, (3.5 deer per hunter), with a season total of 

over 1922 deer by 549 hunters.) However, in 2012, 147 hunters on Mitkof Island required 

565 deer hunter days to harvest just 22 deer.1

To make matters worse, in 2013, even as the remaining high value old growth timber was 

being clearcut (Tonka Timber Sale) on nearby Lindenberg Peninsula, the same hunting 

restrictions were imposed by emergency order and remain in place for the foreseeable 

future. 

Other old growth dependent species such as the Alexander Archipelago wolf (Canis lupus 

ligoni) of Prince of Wales Island (Unit 2), face such precipitous declines in the face of 

large scale timber extraction in the on-going Big Thorne Timber Sale, that according to 

ADFG wolf researcher, Dr. David Person, 

“the Big Thorne timber sale, if implemented, represents the final straw that will 

break the back of a sustainable wolf-deer predator-prey ecological community on 

Prince of Wales Island...”

Still other old growth dependent species such as marten, Queen Charlotte goshawk, and 

several other species demonstrate population declines consistent with biological research 

demonstrating the debilitating effects of habitat fragmentation resulting from even age 

(clearcutting) management and the associated logging road system. 

Despite these documented failures of an agency whose byline is, “Caring for the Land, 

and Serving People”, the United States Forest Service (USFS) remains committed to 

singling out the Tongass as the only public forest in the entire National Forest System in 

which large scale industrial old growth timber extraction continues apace, while being 

fully aware of long-standing negative, economic, environmental, and social 

consequences. 

1 ADF&G, 2014. Deer hunter survey summary statistics. Alaska Dept. of Fish and Game. 

Division of Wildlife Conservation. Juneau. WINFONET database.
The problem of even age management was identified in the early 1960's and summarized 

in a technical report produced by ADFG back in 1985, titled, "The impacts of Clearcut 

Logging on the Wildlife Resources of Southeast Alaska."

The very first paragraph to the introduction of this report states, 

"Logging, as currently practiced and planned in southeast Alaska, has the 

potential to significantly and permanently alter large amounts of wildlife 

habitat.Wildlife species which are adapted to use existing habitat may decline and 

associated recreational and subsistence uses may be substantially reduced." 

So it cannot be said, the large scale mismanagement which has occurred on the Tongass 

was not well known, nor its actions constituted unintended consequences. Rather, the 

agency has consistently operated and remains, in a state of regulatory capture . 2

“Addressing sustainable forestry in Southeast Alaska” 

An industry-wide shift out of old growth logging to second growth was first pitched by 

the agency in 2010 at the Tongass Futures Roundtable (TFR.) Within 3 years, the TFR 

was disbanded, but barely two months later, Secretary Vilsack’s Memorandum of 20133

was issued. In that memorandum, radical revisions of the timber industry were outlined, 

with the execution of the Big Thorne Timber Sale (the largest timber sale in well over a 

decade) pitched as the first step in “addressing sustainable forestry.” 

The Memorandum included an entreaty to Congress to legislatively eliminate the 

silvicultural standard known as CMAI, or Cumulative Mean Annual Increment, which 

represented the methodology for maximizing timber yield by ensuring that timber would 

not be cut prior to achieving its greatest rate of regrowth. The consequences of this 

revision means that all second growth (rebranded as “young growth”) would no longer be 

managed to achieve the crucial structure, function, or compositional characteristics which 

old growth dependent wildlife of our coastal temperate rainforest have adapted to and 

require in order maintain, “viable, well distributed populations” as promulgated in the 

National Forest Management Act of 1976 (NFMA.) 

The consequence of this Secretarial edict constitutes nothing less than a permanent 

conversion of the (formerly) highest value, most biological productive old growth habitat 

2 https://en.wikipedia.org/wiki/Regulatory_capture

Secretary’s Memorandum 1044-009 “Addressing Sustainable Forestry in Southeast Alaska” 3
of the Tongass National Forest into corporate tree plantations which are incapable of 

functioning under the mandate of Multiple Use, and incapable of maintaining the 

sustainable yield of old growth dependent plants and animals central to subsistence needs 

of rural residents. 

 Ultimately, the “Transition” was re-pitched at the Tongass Advisory Committee (TAC), 

a full 6 years after its announcement at the TFR and is now found in the DEIS Proposed 

Amendment to the LRMP. The public has been reassured in this document with terms 

such as “Transition,” “Stewardship,” and “Restoration.” 

The terms seem to indicate an (albeit after-the-fact) agency acknowledgement that the 

decades of overwhelming public outcry over unsustainable old growth timber extraction 

has been heard, and an agency paradigm shift is afoot. Those familiar with corporate 

marketing tactics such as ‘bait and switch,’ ‘rebranding,’ and ‘spin,’ however, understand 

instead, that something else is underfoot. 

The TAC implementation, process, representation, and premises used to lend the patina of 

legitimacy and unbiased deliberation to the LRMP is a transparent demonstration of 

manufactured consensus for rubber stamping the predetermined outcome defined in 

Secretary Vilsack Memorandum. 

These abuses of the Federal Advisory Committee Act (FACA) abetted by the agency’s 

handpicked membership of the TAC demonstrate the agency intended from the outset to 

run roughshod over the intent of FACA. The LRMP DEIS itself, is fatally flawed in its 

Purpose and Need statement in that it excludes a full range of alternatives and with that, 

major disclosures of environmental impacts and the requisite “hard look” delineated in 

the National Environmental Policy Act. The National Forest Management Act, and other 

benchmark environmental and procedural laws in the pursuit of business as usual and it 

does not reflect well on the agency, nor the continued imposition of its failed business 

model on the regional economy, the environment, and the social wellbeing of Southeast 

Alaskans. 

Economic Overview 

A cursory overview of the LRMP, coupled with the documented historical record, 

demonstrates the Proposed Alternative reveals the actual shift away from industrial 

clearcutting of old growth will not occur for 15 years or more. This period of time will 

render moot what little remains of the existing old growth habitat, as it will be liquidated. 
The agency allowance of up to 50% or more of raw log exports to China, Japan, South 

Korea and elsewhere continues. The net effect of these policies preclude the most viable 

options and opportunities for providing local small mill owners access to local old growth 

timber. The small mills cannot add sufficient value to young growth nor can they compete 

on the scales of volume necessary to remain competitive. The DEIS fails to provide the 

analysis necessary to examine these inevitable outcomes. 

While the lion’s share of the agency budget continues to increase the size of a burgeoning 

corporate tree plantation occurring within the most biologically critical, highest volume, 

easiest to access, low elevation watersheds, the industrial scale, even age management 

regime condemns present and future opportunities of local small mill owners from access 

to viable livelihoods.

Further, the DEIS fails to examine alternative economic scenarios in which forest 

dependent industries such as ecotourism, commercial fishing, recreation, sport hunting 

and fishing sectors are allowed to operate in an economic scenario free from the 

deleterious impacts of corporate tree plantations within the same landscapes. 

Any objective analysis of the last fifty years of the timber industry in Southeast Alaska 

must conclude the wholesale felling and foreign export of the region’s old growth 

rainforests allowed temporary profit taking for a few — while exerting a profoundly 

negative constellation of cultural, ecological, social, and economic consequences — for 

the many. On federal lands alone, a limited calculation of explicit economic 

consequences to U.S. taxpayers totaled over a billion dollars within a 30 year period of 4

federal timber sales. The implicit ecological and social subsidies remain unaccounted and 

largely ignored. The explicit economic subsidies to the timber industry are more aptly 

described as a corporate welfare system than an “industry” competing in the “free 

market.” 

For these reasons, the City of Kupreanof respectfully requests the USFS revisit its 

obligation to fulfilling the full intent of NEPA, NFMA, FACA, and the Administrative 

Procedures Act by abandoning the current DEIS and conducting a revised DEIS. 

Sincerely, 

David Beebe 

Vice Mayor 

City of Kupreanof 

4

 1980-2010 Alaska Wilderness League akbriefing.wikispaces.com








Date submitted (UTC): 1/31/2016 6:13:23 PM

First name: Rep.

Last name: Josephson

Organization: 

Title: 

Official Representative/Member Indicator: 

Address1: 

Address2: 

City: 

State: 

Province/Region: 

Zip/Postal Code: 

Country: 

Email: Rep.Andy.Josephson@akleg.gov

Phone: 

Comments:

Tongass National Forest Management Plan (due Feb 22, 2016)

Dear Ms. Howle:

I am not a scientist, a fisheries biologist, a timber man or an expert on forest ecology. I am an armchair 

observer of Tongass politics and the forest itself. I am a student of public policy and a citizen concerned with 

our future.

To the extent the following comments can be woven into others and into the USFS?s management plan 

update, I would appreciate it.

My own beliefs are that:

1) What we are doing as a people is not sustainable. The Earth wasn?t designed to hold $7 billion all vying 

for scarce resources. Pressures on those resources are being felt every day. Sometimes the wiser mover is 

the conservative one?conserving a resource. And more than Gifford Pinchot may have foreseen. To the 

extent possible, leave the Tongass Forest in tact, and alone.

2) Do not sell uncut timber, without value added, to overseas or domestic purchasers. 

3) Do not clear cut old growth timber. Lesnoi on Afognak Island has done enough of that, as has 

SeaAlaska.

4) Tourists and cruise ship customers do not want to see denuded landscapes in SE Alaska. They just 

don?t.

5) Do not ever let heavy equipment be driven across a salmon stream.

6) Do not ever let trees be denuded right down to salmon banks.

7) Do not decimate the rest of SE the way that Prince of Wales Island has been. I personally told Secty. 

Vilsack when I met him in the Summer of 2014, that I hoped the USFS lost the litigation related to the Big 

Thorne harvest. He won, and I lost, apparently.

8) It?s ?o.k.? to say ?no?. It?s ?o.k.?
9) Alaska?s industry is already less than 10% of what it was. Don?t bring it back. The economy has 

adjusted. Just leave it alone.

10) Future generations will be unimpressed with the amount of wealth and comfort we?ve amassed since the 

Industrial Revolution. They?ll be more impressed with the natural beauty we protect. 

Thanks for listening,

State Rep. Andy Josephson

Juneau, Alaska















LISA MURKOWSKI 

ALASKA 

COMMITTEES: 

ENERGY AND NATURAL RESOURCES 

CHAIRMAN tinitrd ~tatrs ~rnatc APPROPRIATIONS 

SUBCOMMJTTE E ON INTERIOR, 

ENVIRONMENT, ANO Rf LATED AGENC1E S 

CHAIRMAN 

HEALTH, EDUCATION, LABOR, 

AND PENSIONS 

INDIAN AFFAIRS 

By Electronic Mail and U.S. Mail 

Mr. Earl Stewart, Forest Supervisor 

Tongass National Forest, 

Attn: Forest Plan Amendment 

648 Mission St. 

WASHINGTON, DC 20510-0203 

(202) 224 6665 

1202) 224-5301 FAX 

February 19, 2016 

Ketchikan, Alaska 99901 

Comments-alaska-tongass@fs.fed.us 

510 L STREET, SUITE 600 

ANlHORAGf' AK 99501 1956 

(907) 271 3735 

101 12TH AVENUE, ROOM 329 

FAIRBANKS, AK 99701-6278 

(907) 456 0233 

800 GLACIER AvE NL•f, Sum 101 

JUNf AU, AK 99801 

(907) 586 7277 

805 FRONTAGE ROAD, SUITf 105 

K .NAI, AK 99611-9104 

(907) 283 -5808 

1900 FIRST AVENUE, SUITE 225 

KETCHIKAN, AK 99901 6059 

(907) 225-6880 

851 EAST WESTPOINT 0RIVF, SulTf 307 

WASILLA, AK 99654-7142 

(907) 376 7665 

RE: Comments on Proposed Land Resource Management Plan for the Tongass National Forest, 

November 2015, RlO-MB-769 a-c. 

Dear Mr. Stewart: 

Attached for inclusion in the referenced docket are my Comments on the Proposed Land 

Resource Management Plan for the Tongass National Forest, November 2015. 

Sincerely, 

United 

Murkowski, States Senator 

Cc: Robert Bonnie, U.S. Department of Agriculture 

Beth Pendleton, Tongass Regional Forester 

HOME PAGE AND WEB MAI],, 

MURKOWSKl.SENATE.GOV 
Formal Comments of 

Senator Lisa Murkowski on the 

Tongass National Forest: 

Proposed Land and Resource Management Plan (2015) 

RIO-MB-769 a-c 

Submitted February 19, 2016 

Submitted to: 

Mr. Earl Stewart, Forest Supervisor 

Tongass National Forest 

Attn: Forest Plan Amendment 

648 Mission Street 

Ketchikan, AK 99901 

Submitted by: 

Senator Lisa Murkowski 

709 Hart Senate Building 

Washington, D.C. 20510 

202-224-6665 
INTRODUCTION: 

I write to express my views on the Tongass National Forest: Proposed Land and Resource 

Management Plan (2015) (Proposed TLMP, Plan or Plan Amendment) and the U.S. Forest 

Service's (Forest Service) Proposed Preferred Alternative changing the 2008 Tongass National 

Forest: Land and Resource Management Plan (Final TLMP, or 2008 Plan) 1 released for 

comment on November 15, 2015.2 The three-volume Plan prompts a host of conflicting 

reactions. The updated scientific research and data collected by Forest Supervisor Earl Stewart, 

Project Team Leader Susan Howle, and their 20 assistant "preparers" and 46 "contributors" is 

impressive. Unfortunately however, as detailed in these comments, the substance of the Plan is 

deeply concerning. The Forest Service should wait to make a final decision on whether and what 

kind of TLMP plan update is required until there is firm data to support the Administration's 

policy decision to accelerate a transition to a young-growth forest management program in the 

reg10n. 

As an Alaskan born in Southeast Alaska, some of the research was fascinating. For example, it is 

notable that El Capitan Cave on Prince of Wales Island is between 107 ,000 and 115 ,000 years 

old.3 It is useful to know that there are 152,800 acres of Productive Old-Growth timber (POG, 

the largest of old-growth trees) on top of karst formations remaining in the Tongass;4 that since 

Statehood Alaskans have harvested only 8 percent of the original POG in the Tongass Forest; 

and that, regardless of which proposed alternative is selected to govern future forest activities, 91 

percent of all POG will remain after a century. 5 

The detailed accounting of land ownership is very useful especially because it documents 

conclusively that only 190,000 acres of the 17 ,906,000 acres of total land within the outer 

boundaries of the Tongass National Forest are privately owned. It is important to keep at the 

forefront the fact that the Forest Service controls 93.4 percent of the forest or 16,720,000 acres 

after passage of the Southeast Alaska Native Land Entitlement Finalization Act (Sealaska Lands 

Bill) in December 2014. 6 Only one-half of one percent of the forested lands in Southeast Alaska 

contain 2 miles of road per square mile, while 46 percent of the nearly 18 million acres have no 

roads at all, another fact contained in the Plan that bears emphasis. 

Unfortunately, despite its positive attributes, overall the Plan is unjustified - a extremely 

premature attempt to implement a legally questionable, economically unsupported, 

environmentally unneeded, and extremely short-sighted change in the management of the 

nation's largest federally owned forest. · 

1 U.S. Department of Agriculture Forest Service, Tongass National Forest: Land and Resource Management Plan 

(2008), available at https://fs.usda.gov/Internet/FSE DOCUMENTS/stelprdb5367422.pdf. 

2 U.S. Department of Agriculture Forest Service, Tongass National Forest: Proposed Land and Resource 

Management Plan (2015), available at http://www.fs.usda.gov/lnternet/FSE DOCUMENTS/fseprd480655.pdf. 3 U.S. Department of Agriculture Forest Service, Tongass Land and Resource Management Plan: Draft 

Environmental Impact Statement- Plan Amendment, 3-27 (November 2015), available at 

http://www. fs. usda.gov/Internet/FSE DOCUMENTS/fseprd480660. pdf. 

4 Id. at 3-28. 

5 Id. at 2-40. 

6 Id. at 3-263. 
THE DRIVER BEHIND A PLAN UPDATE - The Proposed Plan is not driven by actual 

data, but assumptions to support an agenda to end old-growth harvesting or to satisfy the 

desire of some to end most all timber production from the Tongass. This Plan Amendment 

is a rush to judgment that is ill considered and is likely to result in harm to the residents of 

Southeast Alaska. 

The Obama Administration and Secretary Vilsack, soon after taking office in 2009, made it 

abundantly clear that they intended to dramatically alter the economic underpinnings of the 

timber industry in Southeast Alaska- an industry that the Forest Service was largely responsible 

for establishing in the 1950s and that the federal government has been partially responsible for 

seeing decline in recent decades. In the Secretary's July 1, 2013 memorandum Addressing 

Sustainable Forestry in Southeast Alaska (the Memorandum) he simply decreed that 

management of the forest would change notwithstanding Congressional direction in 1980, and 

clarifying direction in 1990 and again in 2014 that requires the Forest Service "to seek to meet" 

the existing demand for timber (once defined by average timber market conditions, not by Forest 

Service policy)7. 8 He did so seemingly because he believed an industry that utilized a tiny 

percentage of the old-growth trees in the forest somehow violated the Multiple-Use Sustained 

Yield Act of 1960 (the 1960 Act). As I see it, he also decided that it simply wasn't worth the cost 

and time for his agency to address litigation from environmental groups opposed to most any 

form and any significant quantity of Tongass timber harvesting. 

The 1960 Act, even as revised in 1996, requires the Secretary to manage "all the various 

renewable surface resources of the national forests so that they are utilized in the combination 

that will best meet the needs of the American people; making the most judicious use of the land 

for some or all of these resources or related services over areas large enough to provide sufficient 

latitude for periodic adjustments in use to conform to changing needs and conditions .... "

9 

Clearly under the Act, national forests are to be managed to support recreation, wildlife, 

economic activities, and timber harvesting- a specific designated use in national forests. 10 

The Memorandum, however, equated the desires of some for "changing needs" to timber 

preservation and a reduction of timber harvesting. Meanwhile, it ignores that "changing needs" 

in the minds of many Alaskans may well mean the need for greater economic benefits from 

Alaska's renewable national forest lands as income to offset declines from wealth devised from 

the production of oil and gas in other parts of the State. The Memorandum seemingly defines 

timber harvesting in Alaska as, after a transition period, largely equating only to the harvesting 

of small diameter, young-growth timber (Y-G). This was clearly never intended by Congress in 

passage of the 1960 Act, the 1980 Alaska National Interest Lands Conservation Act, or the 1990 

Tongass Timber Reform Act. 

7 Tongass Timber Reforms Act, Pub. L. No. 101-626 §101(amending·§705(a) ofthe Alaska National Interest 

Lands Conservation Act of 1980 (Pub. L. No. 96-487)). 

8 U.S. Department of Agriculture, Secretary's Memorandum 1044-009, 1(July2015), available at 

http://www.fs.usda.gov/Internet/FSE DOCUMENTS/stelprdb5445760.pdf. 

9 Multiple-Use Sustained Yield Act of 1960, Pub. L. No. 86-517 § 4(a). 

JO Id. § I. 

2 
The Memorandum calls for a transition to young-growth harvesting over a "10 to 15 year" 

period, with the possibility of a "small sale frogram" to harvest a small amount of old-growth 

timber for "niche markets" after transition. 1 A fatal flaw in this approach is that it sets in motion 

a transition to young-growth harvesting without any real evidence, but only speculation that such 

an industry could be economically viable in Southeast Alaska. There is little, if any, firm 

knowledge of the amount of young-growth that will be environmentally acceptable to harvest 

from the Tongass. Nevertheless, this information is a primary condition before any enterprise, let 

alone an industry, could attract the private financing necessary to fund the transition to Y-G. The 

Administration pressed the transition to Y-G without any clear indication of what end uses would 

constitute the economic market for Y-G-what products can be made and profitably shipped and 

sold from the wood in this forest. This transition mandate came before there was any evidence on 

the economic impacts on the region of the policy shift, an apparent violation of the National 

Forest Management Act of 1976. 12 That Act requires planning before policy changes were 

crafted, not afterwards to justify the actions already directed by the memorandum and the views 

of political appointees. 

The Department and the Forest Service clearly placed the cart before the horse in 2013. It created 

a Tongass (Citizens) Advisory Committee (TAC) in fall 2013 to make recommendations on how 

the transition could be implemented, leaving out of its charter a discussion on whether such a 

shift should take place. 13 The Administration since then has proposed the Plan Amendment to 

accelerate the transition to a young-growth industry. The Proposed TLMP picks and chooses 

which of the advisory committee recommendations to implement, apparently supporting only the 

recommendations that will allow it to "lock in" a transition plan prior to January 20, 2017. 

This Plan Amendment is a rush to judgment that is ill considered, and is likely to result in harm 

to the residents of Southeast Alaska. 

Let me acknowledge that for more than five decades it has been the common wisdom in the 

region - an area the size of West Virginia-that eventually the timber industry in the Tongass 

National Forest will transition from dependence on old-growth timber to largely young-growth 

timber. That was the justification for the expenditure of federal funds to help pay for forest road 

building in Southeast Alaska. The roads were an investment that would be repaid with stumpage 

fees and tax revenues from future second- and third- rotation sales and the economic activity 

they would promote. It makes perfectly good environmental sense to protect a majority of the 

old-growth timber stands in the Tongass National Forest, to protect fishery habitat and to protect 

wildlife, both for their own sake and the sake of subsistence, recreational, and commercial 

hunting in the region. 14 It is wise to encourage an industry to transition and to develop new 

markets for young-growth timber - markets where Alaskan timber might have economic 

advantages in sales in the future because of geographical location, product characteristics, or 

innovations. By contrast, it is arbitrary to set an end date, or effectively arbitrarily limit the 

amount of old-growth by volume or acreage that may be harvested in the Tongass, without any 

11 USDA, Secretary's Memorandum 1044-009, 2. 

12 Pub. L. No. 94-588. 

13 If the latter had been under discussion there likely would have been no recommendations issued by the TAC given 

the requirements for issuance of a report under the Federal Advisory Committee Act. 

14 80% of which will be protected even without a young-growth transition plan. 

3 
firm evidence that a transition to a young-growth timber supply is economically viable over an 

articulated time period - whether the transition is viable starting within a few years and fully 

completed within 16 years, compared to one starting in 25 years and fully underway three 

decades from now when the existing old-growth will have increased by 50 percent and the 

acreage to support a future industry 60 to 90 years later will have increased. 15 

It would be counterproductive effectively to place an arbitrary limit on old-growth timber sales 

of approximately 5 million board feet a year after a "transition," with no evidence that that is a 

sufficient harvest to meet high-value wood demand for musical instruments or other high-value 

uses. Such a limit appears to be based on environmental goals rather than a serious consideration 

of economic facts. It is also wrong to limit arbitrarily the amount of old-growth timber that can 

be harvested to about 2 percent of a 16. 7-million-acre forest, when a harvest that would still 

leave about 96 percent of such trees standing can occur while enabling a viable, integrated timber 

industry in the region. 16 

The Memorandum paid lip-service to maintaining a viable timber industry in the Tongass: 

"(The) Department of Agriculture is committed to maintaining Southeast Alaska's 

exceptional natural resources in perpetuity. USDA is equally committed to doing 

its part to ensure that the communities within and adjacent to the Tongass 

National Forest are economically vibrant. These two goals must go hand in hand . 

. . . We must speed the transition away from old-growth timber (but) we must do 

this in a way that preserves a viable timber industry that provides jobs and 

opportunities for residents of Southeast Alaska .... To accomplish the transition to 

a timber program based primarily on young growth, it is important to retain the 

experience and infrastructure of the existing industry so businesses can quickly 

retool. These businesses are fundamental to both the young growth and restoration 

components of the future timber program, and to the economic vitality of the 

region. Such an approach requires a reliable supply of economically viable 

timber, with the old-growth component decreasing over time while the young 

growth component increases .... Additional research will be necessary to develop 

effective ways to meet" the challenges of establishing an "economically viable 

young-growth program due to the relatively young age of the available stands, 

market conditions, and other factors." 17 

The Forest Service should actually fund and undertake that research to make sure that a 

transition is economically feasible and somewhat likely to succeed before amending the 2008 

Plan and "locking in" reduced old-growth timber harvest offerings. 

As noted above, there is a case to be made for a transition when the amount of second-growth 

and its volume of fiber make economic sense to support a viable timber industry. In 2014, I 

accepted a provision to allow a limited waiver of federal law to permit a limited amount of 

15 Alaska Forest Association, Comments on U.S. Forest Service Tongass National Forest Timber Demand, 

Projections for 2015 to 2030, 7 (January 7, 2016). 16 USDA, Tongass National Forest: Land and Resource Management Plan. 

17 citation 

4 
timber to be harvested before it reaches optimal size to allow a transition to begin more 

quickly. 18 In 2015, I supported the Forest Service's budget to help it gain funding to conduct 

needed research to prove that there will be sufficient second-growth wood to fuel a younggrowth timber industry. I am willing to support additional funding if proposed by the 

Administration for objective economic studies to determine what products can be made from 

young-growth and at what costs, to prove the economic viability of a transition given Tongass 

wood volumes, and to allow private investment to help fund a transition to a young-growth 

industry. I will support the TAC recommendations for new management policies to allow a 

transition to young-growth. But the TAC carefully proposed in its recommendations that younggrowth replace old-growth on a "one-to-one volumetric basis," 19 with old-growth not being 

reduced until there is a market for young-growth to profitably replace it, i.e., until it is proven in 

an intellectually honest fashion that such a transition can actually take place without further harm 

to the economic underpinnings of Southeast Alaska's economy and not until there are markets 

for young-growth to replace the economic benefits of old-growth timber. If objective studies 

prove that a transition can occur more quickly and be financeable by the private sector it could 

well be worthy of support. 

Until then, I must adamantly oppose unnatural transition, and worse an amendment to the 2008 

Plan, that encourages Forest Service management policies that will result in a reduced timber 

harvest. The Proposed TLMP is not driven by actual data, but assumptions to support an agenda 

to end old-growth harvesting or to satisfy the desire of some to end most all timber production 

from the Tongass. This history of timber harvesting in Southeast Alaska provides an important 

foundation to understand my concerns. 

TIMBER HARVESTING HISTORY: Timber sale levels have declined dramatically for 

more than a decade resulting in the loss of more than 5,000 timber and timber-related jobs. 

The blueprint for a timber industry in Southeast Alaska has changed dramatically since the 1950s 

when the Forest Service offered timber sales to attract a pulp industry in the region. The Forest 

Service believed that the Tongass could supply up to 1.8 billion board feet of timber yearly in a 

biologically sustainable fashion. That timber was just a part of the then-estimated 95 billion 

board feet to lie in the 9.5 million acres of commercial forest lands in the Tongass.20 The Alaska 

National Interest Lands Conservation Act of 1980 (ANILCA) reduced that harvest target from 

federal lands to 450 million board feet (mmbf) a year, providing mandatory spending of $40 

million a year for pre-commercial thinning and other work to allow that harvest level to be met 

while removing 5. 7 million acres from the forest land base - land placed in conservation system 

units, protected habitat, and wilderness. ANILCA: 

18 Southeast Alaska Native Land Entitlement Finalization Act (Sealaska Lands Bill), Pub. L. No. 113-291 § 3002. 

19 Tongass Advisory Committee (TAC), Final Recommendations, 2 (December 2015), available at 

http://www.merid.org/~/med ia/Files/Projects/tongass/December%202015%20 Meeting/Tongass%20Ad visory%20C 

ommittee%20Final%20Recommendations Dec%202015.pdf. 

20 Sen. Frank Murkowski, The Tongass, Fact versus Fantasy, 4 (Chart on Timber Harvesting in Tongass Compared 

to Biological Capacity, U.S. Forest Service Data) (August 1996). 

5 
"Represented a proper balance between the reservation of national conservation 

system units and those public lands necessary and appropriate for more intensive 

use and disposition and thus Congress believes that the need for future legislation 

designatinF new conservation system units (CSUs) ... has been obviated 

thereby."2 

It took Congress just ten years to repeal the 1980 silviculture subsidy, to reduce the allowable 

timber harvest target to between 220 to 267 mmbf, and to add another 722,000 acres into 

protected status/CSUs. By the Forest Service's own estimates at the time, in 1990 the Tongass 

produced 6,113 direct jobs, contributing $516 million to the state's economy from the harvest of 

4 71 mmbf of timber from federal lands. 

The TLMP finally approved in 1999 to implement the Tongass Timber Reform Act (TTRA),22 

passed nine years earlier, anticipated a harvest or Allowable Sale Quantity (ASQ) of between 

153 and 187 mmbf. 23 The Forest Service was required to "seek to meet" the demand for then 

existing timber markets. The mills supplying those markets all were equipped to process larger 

diameter, old-growth timber. Mills whose customer base was (and largely continues to be) 

tailored toward processing of that type of wood assumed its availability. In 1999, the harvest still 

reached 146 mmbf. 

For a host of factors, some market driven, but others driven by environmental group litigation 

and the inability of the Forest Service to provide a consistent quantity of timber to satisfy 

markets and prevent customer switching, sale levels declined dramatically for more than a 

decade. In 2005 harvests fell to 50 mmbf, and over the next I 0 years they have averaged just 

33.3 mmbf, generally far less than the "market demand" for the timber. During that period, while 

the Forest Service offered (or attempted to offer) 57.8 mmbf a year, the Service only successfully 

sold 35.4 mmbf a year - litigation and Forest Service sale policies significantly reduced the 

amount of timber being utilized in the forest. 24 

As a result, a host of mills in Southeast Alaska have closed. This has resulted in the loss of more 

than 5,000 timber and timber-related jobs. Ketchikan lost a 500-employee pulp mill, two 100-

employee sawmills and later an I 00-employee veneer plant, Sitka lost a 500-employee pulp mill, 

Prince of Wales Island, lost a 25-employee sort yard and 700 logging and road building jobs, 

Wrangell lost a 100-employee sawmill, and Metlakatka lost an I 00-employee hemlock mill and 

100 jobs in road building and logging. Other parts of the region faced and are facing steep 

indirect job losses. The industry, which once accounted for nearly 80 percent of all 

manufacturing jobs in Alaska and produced a payroll of more than $300 million a year in 1991, 

today has been reduced to an industry that accounts for only about 600 total jobs and a total 

21 Alaska National Interest Lands Conservation Act of 1980, PL. 96-487 § 101 (d). 

22 Tongass Timber Reform Act, Pub. L. No. 101-626. 

23 I do understand that the Forest Service since 2012 no longer uses the term Allowable Sale Quantity to characterize 

timber sale offerings having moved to Projected Timber Sale Quantity (PTSQ). ASQ is used here simply because it 

was in usage at the time of ANILCA and TTRA's passage and reflects the expected timber offerings by Alaskans, 

dependent, of course, on the level of congressional funding provided to the Forest Service for planning/execution of 

timber sales. 

24 U.S. Forest Service, Alaska Region Timber Volume History (January 2015). 

6 
payroll in the region of approximately $27 million. 25 Despite these losses, the timber industry is 

important locally in the "Panhandle" of Southeast Alaska. For example, from 1990 to 2000, 

following passage of the Tongass Timber Reform Act and the eventual closure of the Alaska 

Pulp Co. mill in Sitka and the Ketchikan Pulp Co. mill in Ketchikan and sawmill in Wrangell, 

Southeast's total population declined by 7 percent. 

The decline continued from 2000 to 2010 because of the marked slowdown in timber harvesting. 

From 2000 to 2010 total population in the region declined to 69 ,849 from 73, 082, a further 

decline of 5 percent; 24 of the region's 34 communities are facing declines: from 2 percent in 

Hydaburg, now a shipping port for log exports, to 57 percent in Point Baker on northern Prince 

of Wales Island. 26 Almost exclusively linked to the downturn in timber employment, state 

elementary schools in six communities closed following a region-wide enrollment decline of 15 

percent- the schools in Edna Bay, Elfin Cove, Meyers Creek (Chuck), and Whale Pass remain 

closed. Ketchikan (both City and Ketchikan Gateway Borough), for example, saw its population 

peak in 1995 at 14,800. While it bottomed out in 2004 at 13,200, it still is only at about 13,900 -

900 fewer residents in the area than at logging's peak. Ketchikan's average wage in 2013, the 

most recent year for data, was $42,767, considerably below its pre logging era collapse and well 

below the statewide average of $51,033. 27 

On Prince of Wales Island, the downturn in the timber industry caused far worse economic 

impacts. The Island's population, according to the U.S. Census Bureau, fell 20 percent from 

1996 to 2007. The Island, once fueled by timber, is now dominated by government agency 

spending. Some 52 percent ($38 million) of the total census area wages in 2011 were funded by 

government agencies and natural resources provided just 6 percent ofwages.28 

According to Southeast Conference, the umbrella organization for all communities in Southeast, 

timber jobs and payrolls fell by 24 percent from 2006 to 2011. Timber, which accounted for 

4,500 direct jobs in the region in the late 1990s, by 2011 accounted for just 422 jobs and wages 

were down to $16.8 million.29 

Even though the seafood industry increased 4 percent from 2006 to 2011, generating $391 

million in ex-vessel value for Southeast residents, and even though tourism fell 6 percent from 

2006 to 2011, generating 6,000 part-time and some year-round employment with a payroll of 

25 Caroline Schultz, Alaska's Timber Industry Fallen on Hard Times, ALASKA ECONOMIC TRENDS, Alaska 

Department of Labor and Workforce Development, 14 (October 2010), available at 

http://laborstats.alaska.gov/trends/oct 1 Oart2 .pdf. 

26 Alaska Department of Commerce, Division of Economic Development, Report to the Alaska Timber Jobs Task 

Force, 3 (March 2012). 

27 Conor Bell, Ketchikan 's Fluid Economy: Alaska's Gateway City, From Mining and Timber to Fishing and 

Tourism, Stories in the News/Sit News (August 16, 2014), available at 

http://www.sitnews.us/0814News/08 l 614/081614 ketchikan economy.html (citing the Alaska Department of Labor 

and Workforce Development, Research and Analysis Section). 

28 Prince of Wales Area Redefines its Economy after the Timber Decline, Stories in the News/Sit News, 2-3 (August 

1, 2012), available at http://www.sitnews.us/0812News/080112/080112 POW.html. 

29 Southeast Conference, Southeast Alaska by the Numbers, 8 (2012), available at 

http://www.seconference.org/sites/default/files/Southeast%20Alaska%20by%20the%20numbers%20small%20for% 

20emailing%20and%20web.pdf (citing the McDowell Group and the U.S. Forest Service). 

7 
$164 million, and even though mineral development has grown in Southeast, to 650 jobs and a 

$60 million payroll by 2011 (largely as a result of the opening of the Kensington gold mine in 

Juneau and the reopening of the Greens Creek silver mine outside of Juneau), timber could still 

play a vital role in a balanced economy in Southeast Alaska. That would be the case if timber 

production was allowed to return just to the allowable sale quantity levels permitted by the 2008 

TLMP. 30 

This history provides the foundation for the following comments on the Plan. 

CRITERIA FOR PLAN ALTERNATIVES-The Plan Amendment process was 

fundamentally flawed because the Plan, rather than looking objectively at the outcome of 

all reasonable forest alternatives, appears to have been predetermined in order to support 

a prior decision to exclude consideration of a more robust timber harvest scenario. 

The Plan Amendment process was fundamentally flawed because the Plan, rather than looking 

objectively at the outcome of all reasonable forest alternatives, was gerrymandered as a result of 

the 2013 Memorandum and the decision to exclude consideration of a more robust timber harvest 

scenario. The Forest Service admits that early in the Plan: 

In the past Forest Plan revisions and amendments, varying demand scenarios were 

used to develop alternatives, including scenarios that allowed for growth and 

expansion of the current industry. In this amendment, the purpose and need 

demands the transition to a predominately young-growth-based industry and the 

reduction of old-growth harvest. Therefore, examination of alternatives at levels 

above projected demand is not warranted because these would require expansion 

of old-growth harvest levels, at least during the next 1 Oto 20 years."31 

Worse, the forest "demand level" used as the base for sale forecasts in the document is not a real 

assessment of the market "demand" for timber, as required by Sec. 101 of the Tongass Timber 

Reforms Act of 1990.32 The five alternatives in the Proposed TLMP are assessed against the 

baseline "demand estimate" used by the Forest Service in crafting the Plan Amendment. The 

Tongass National Forest Timber Demand, Projections for 2015 to 2030 (the Demand Estimate), 

crafted by economists from the Pacific Northwest Research Station,33 estimates that only 40.9 

mmbf was sought by markets in 2015 and that only 41.6 mmbfwill be sought in 2016 - a 

demand level that rises to a range of between 51.9 and 76.4 mmbfby 2030 as young-growth 

production increases. 34 Nowhere in the Plan does it justify why the demand level that effectively 

controls the consideration of the five alternatives is more than 100 mmbfless than the Forest 

Service's published demand levels for 2014, of between 110 and 151 mmbf in a "Limited 

30 Id. at 6-1 0. 

31 USDA Forest Service, Tongass Land and Resource Management Plan: Draft Environmental Impact Statement -

Plan Amendment, 2-9. 

32 Tongass Timber Reforms Act of 1990, Pub. L. No. 101-626 § 101 (amendment to Pub. L. No. 96-487 § 705(a). 

33 Jean M. Daniels, Michael D. Paruszkiewicz, and Susan J. Alexander, Tongass National Forest Timber Demand, 

Projections for 2015 to 2030 (December 2, 2015). 

34 USDA Forest Service, Tongass Land and Resource Management Plan: Draft Environmental Impact StatementPlan Amendment, at 2-8 (Table 2-1). 

8 
Lumber" scenario and between 110 and 163 mmbf in an "Expanded Lumber" market scenario.35 

The 2015 demand estimates varied from between 58 to 113.2 to 204 mmbf on a slightly revised 

demand report. 36 

A review of the Demand Estimate, however, does shed light on the marked differences. '.'Efforts 

to end harvesting of old-growth timber on the Tongass National Forest have spurred multiple 

initiatives focused on transitioning to a young-growth timber base. The young-growth transition 

is expected to affect timber supply for the remaining Southeast Alaska forest products industry," 

write the authors. 37 While noting that timber sale demand from Alaska may be impacted in the 

future by changes in domestic and export forest product markets, by foreign currency 

fluctuations, and by changes in the federal timber base because of lands legislation or 

congressional action, the report noted that this Demand Estimate was influenced by the 

Secretary's Memorandum. "Efforts were set into motion by evolving USDA policy limiting oldgrowth harvesting and encouraging the harvest of younger second-growth forest stands."38 

"Although this is an analysis of timber demand, it is important to remember that the interaction 

between demand and supply is what ultimately determines trends in markets," continues the 

demand report. 39 Thus the Demand Estimate, which is the basis for the Forest Service not 

seeking to offer more old-growth timber to meet "market demand" and for seeking an 

amendment to the 2008 TLMP, is being driven in significant ways not by markets, but by the 

limitation of timber supply available to markets - a process, in turn, that is solely being driven by 

the Secretary's policy directive mandating a rapid transition to a young-growth industry. 

Alaska mill operators, even with the downturn in American timber export markets in 2015 

spurred by the strengthening of the U.S. dollar, have repeatedly indicated that market demand for 

timber would have allowed them to harvest and process far more timber, if a larger multi-year, 

dependable supply of federal timber had been made available. The Viking Lumber Mill at 

Klawock, for example, has "repeatedly told the Forest Service that they would like to purchase 

more timber sales because their customers have additional capacity and Viking wants to more 

fully utilize (their) mill," according to comments by the Alaska Forest Association.40 More 

timber availability would have improved the mill's efficiency, which the Forest Service's 

Demand Estimate seemingly places at about 18.75 percent in 2013.41 

The Forest Service is arguing that it does not need to offer more timber because "demand" for 

timber was down because of lower sale levels. But without more economically appraised timber 

being put up for sale, the industry has nothing with which to attract market buyers. Except for 

2014's Big Thorne timber sale, the Forest Service was only planning to offer sales of another 60 

mmbf of old-growth saw and utility logs at Mitkof and Three Sisters Island and a 4.2 mmbf 

35 U.S. Department of Agriculture, U.S. Forest Service Alaska Region Briefing Paper, 1 ("Predicting Likely Timber 

Purchases and Offer Levels on the Tongass National Forest. Fiscal Year 2014") (February 2014), available at 

http:/ /www.fs.usda.gov/Intemet/FSE DOCUMENTS/stelprdb544 7816.pdf. 

36 Id. at 9 (Table 5 "Projected Tongass National Forest Timber Harvest (Model Item K)"). 

37 Daniels, Tongass National Forest Timber Demand, at 5. 

38 Id. at 3. 

39 Id. at 4. 

40 Alaska Forest Association, Comments on US. Forest Service Tongass National Forest Timber Demand, at 6. 

41 Daniels, Tongass National Forest Timber Demand, at 8. 

9 
young-growth sale at Dargon Point in 2015 - none completed. Proposed sales in 2016, according 

to preliminary Forest Service sale documents, at Saddle Lakes, Kuiu Island, and from Koscuisko 

and Wrangell Islands, as of this writing, are just 51 mmbf, which is not enough to support higher 

timber production, artificially limiting the timber demand levels. 

This makes the Plan Amendment process based on an obviously circular argument: the only 

alternative that can be accepted is one that does not exceed market demand estimates, while 

those estimates are clearly being limited so that they don't exceed the reduction in old-growth 

harvest levels being driven by the Secretary's policy decision to accelerate a transition to younggrowth harvesting. 

The Forest Service should be adopting a more rational "no-action" amendment, at least as it 

relates to the timber program. That would allow harvests at the levels anticipated by the 2008 

TLMP of up to 167 mmbf a year, depending upon congressional appropriation, while not 

preventing the Forest Service from offering more young-growth sales to help begin a transition 

to a Y-G industry. 

ENVIRONMENT AL IMP ACTS - Concerns about the effects of a larger harvest on the 

environment, commercial fishing, and tourism are unsupported by the record. 

The Forest Service leadership obviously is opposed to such a large harvest. Consider, however, 

what a larger harvest would mean to the forest, the environment, and its resources. Based on the 

2008 TLMP, admittedly crafted on the 1982 planning rules and not the revised 2012 rules, 

logging would limit impacts in the land under Forest Service control to just another 655,000 

acres of the remaining 5.6 million acres of commercially productive forest. That would mean that 

no more than 12 percent of the commercially productive forest will ever be affected and less than 

4 percent of the total forest. 

Already, 4.9 million acres of the productive forest - 88 percent - are in protected status and 

unavailable for logging or construction activity. Of the total Tongass, besides the 6.5 million 

acres in wilderness, parks, monuments and LUD II land status, another 9.5 million acres are 

currently classified by the Forest Service as Inventoried Roadless Areas (IRAs) - which prevents 

road construction and any activities that will dramatically reduce biological protections for 

wildlife. Even if the Forest Service's Alternative One from its Plan document would be selected, 

an alternative modified by the 2012 planning rules, just 40, 140 acres of old-growth would be 

harvested over the next 25 years (generating up to 118.7 mmbf of harvest annually), and only 

62,413 acres of old-growth would be harvested after 100 years. That means after 100 years only 

1.2 percent of the productive old growth would be harvested in the Tongass, i.e., 90 percent of 

the original amount of productive old growth will remain, and just 1 percent less than under the 

other four alternatives being considered by the Plan Amendment. 42 

That also means 82 percent of all high volume, POG trees will remain in the Tongass untouched 

after 100 years, just one percent less than the other four alternatives. Some 80 percent of POG 

will remain in 100 years compared to the 82 percent that now exists in the forest, just one percent 

42 USDA Forest Service, Tongass Land and Resource Management Plan: Draft Environmental Impact StatementPlan Amendment, at 2-43 (Table 2-18). 

10 
less than in the other four alternatives. According to the data developed in the Forest Service's 

Tongass Land and Resource Management Plan: Draft Environmental Impact Statement - Plan 

Amendment (the DEIS), deer habitat will be 87 percent of the levels of 1954 (before commercial 

timber harvesting began), just 1 percent less than under the other four alternatives, and just 2 

percent less than today's leveI.43 

The leading concern with timber harvesting is traditionally the effect of logging on commercial 

fishing, specifically salmon production. But the record of fisheries and timber is quite clear - it is 

fully possible to permit logging by means of modern-era logging practices without negative 

environmental impacts on fisheries. Exempting minor spruce harvesting during World War II, 

modern commercial logging began in the Tongass in 1954. In 1954 Alaska statewide produced 

44.29 million salmon. While harvests declined to 25.12 million salmon at the time of Statehood 

in 1959, because the federal government allowed the use of fish traps, commercial salmon 

harvests rebounded to set a then record of 189 .51 million in 1991 - the peak year for timber 

production from Southeast Alaska - proving that the fish harvests were not harmed in spite of 

timber harvesting. Despite the timber harvests, pink salmon production (Southeast being the 

leading source for pink salmon in the state) hit a then record of 128.33 million pink salmon in 

1991. While pink returns biologically usually are higher in alternating years, pink returns to the 

state surpassed the 90 million mark 14 times from 1989 to 2011 - when logging on federal, state 

and Native corporations lands were at their peak- while pink production had only passed the 90 

million mark once from 1878 to 1989. Clearly, that record of increasing salmon production is 

partially the result of state management, partially the result of the state's regional aquaculture 

program that began in the mid-1970s, and partially the result of moderating weather and stream 

conditions improving fry survival. But it also undercuts the argument that timber production in 

Southeast Alaska harms salmon production.44 Timber harvest practices have improved in Alaska, 

especially since the late 1980s, further reducing the impacts of timber operations on fisheries. 

It is equally unpersuasive to argue that timber production has harmed tourism in Southeast 

Alaska. In 1985, 497,300 visitors came to Alaska. By 1999, when timber harvesting was at 146 

mmbf (one of the last years above 140 mmbf) tourism in Alaska reached 1.199 million visitors. 45 

The impacts of the logging of 435,000 acres of the region certainly have not prevented tourists 

from visiting. According to the most recent extensive study of tourism, 1,064,000 visitors came 

to Southeast in 2011-12 out of a total visitor volume to the state that year of 1.82 million. 

Visitors spent $1.003 billion in Southeast in 2011-12. This is hardly an indication that timber 

development has destroyed Alaska's environment and reduced its attractiveness to tourists.46 

43 Id. at 2-44, (Table 2-18 continued). 

44 Alaska Department of Fish and Game, Alaska Salmon Catches 187 8 to 2011 (2012). 

45 McDowell Group Inc., Economic Impact of Alaska's Visitor's Industry 2011-2012, 3 (February 2013), available at 

https://www.commerce.alaska.gov/web/p01ials/6/pub/Visitor Industry Impacts 2 13.pdf. 

46 Id. 

11 
ECONOMIC IMPACTS - An immediate transition to a young-growth forest management 

program is unreasonable and economically unjustified. 

There is no basis for the Forest Service to limit old-growth logging to the levels that would be 

enshrined in the TLMP by approval of the proposed Plan Amendment, especially when it is not 

clear that an industry can afford to transition to Y-G timber. 

Except for Federal Forest Service timber lands, there are few other lands available for timber 

production in the region. The total state forest lands in Southeast covers about 50,000 acres.

47 

That equates to an allowable sale quantity of only about 11 mmbf a year over the next 100-year 

rotation. Information provided by the Alaska Division of Forestry shows that while it can 

consider about 70 mmbf in sales from Prince of Wales Island and perhaps 50 mmbftotal in other 

sales (the Vallenar Bay sale at12 mmbf and the Edna Bay sale on Koscuisko Island at 24.5 mmbf 

are among the largest) after that state additions to the timber base will be relatively small. 

Looking at Native owned tracts, all provided as a result of the Alaska Native Claims Settlement 

Act of 1971, Sealaska Native Regional Corporation has about 292,000 acres of timber lands out 

of its 365,000 total acres that it has and will receive under the act. While village corporations 

may have more second-growth acres, there is a real question whether many of those acres will be 

of sufficient size to make Y-G harvesting economic in future decades. One of the key problems 

with the DEIS is that it assumes, based on the Demand Estimate, that about 61 mmbf a year are 

currently available to support a Y-G transition - a figure that will rise to about 80 mmbf over the 

15 year transition. 48 However, the fact that Sealaska is estimating that its sustainable harvest over 

the next 25 years is only about 45 mmbf annually casts doubt on the accuracy of that entire part 

of the supply forecast - the part upon which the DEIS transition policy is based. 49 

In the Lower 48 the average Y-G mill costs about $100 million to build and equip - more than 

the total capitalization of Alaska's existing timber industry. The Forest Service's own Demand 

Estimate questions whether a young-growth transition is feasible. "Whether Alaskan products 

will remain competitive during the young-growth transition will depend on a variety of factors," 

the market Demand Estimate concludes. It suggests that for a transition to be successful, given 

the limited volumes of young-growth available based on current land uses, a biomass and a wood 

pellet industry will need to be developed to better utilize wood waste from young-growth product 

production. It notes for that to happen wood pellets will need to replace 30 percent of the heating 

oil currently used in Southeast Alaska for home heating. "Producers, however, may find it 

difficult to compete with pellet producers in British Columbia in international markets. In 

addition, transportation challenges make it difficult for Southeast Alaska producers to ship 

material to other regions within Alaska itself. There is tremendous interest in developing markets 

for value-added niche products. Whether demand for these products would be sufficient to 

sustain a timber industry in southeast Alaska will likely be the subject of debate for many years 

to come," concludes the Demand Estimate. 50 

47 State of Alask:a Division of Economic, Development Report to the Alaska Timber Jobs Task Force, 2 (March 

2012). 

48 Daniels, Tongass National Forest Timber Demand, at Table 22. 49 See comments by Sealaska and by the Alaska Forest Association for additional details. 

50 Daniels, Tongass National Forest Timber Demand, at 32. 

12 
That is hardly a firm foundation upon which to base a transition to a young-growth industry, or 

on which to base adoption of the Proposed TLMP to start implementation of that transition. 

If the Forest Service is intent upon proceeding with one of the published alternatives, then 

Alternative 5, the preferred alternative, is best to ensure continuation of some timber industry in 

Southeast Alaska. It allows more old-growth to be harvested than any of the three reducedharvest alternatives, and allows the transition to stretch over a longer period of time. It also 

comes closer to meeting the recommendations of the TAC than the other three reduced timber 

alternatives (Alternatives 2-3-4). But the alternative is still defective because it does not include 

any of the suggestions the State of Alaska offered in the state's harvest alternative, does not 

consider the impacts of the Alaska Mental Health Trust land exchange that is currently being 

considered by the Forest Service in the region, and does not follow the more reasonable 1982 

planning rule procedures. 

ROADLESS RULE REVISION - Harvesting should be permitted from existing roads that 

have already been built in the Tongass. 

There are good reasons to include one part of Alternative 2 in a final new TLMP. Alternative 2 

proposes to allow timber harvesting in areas where roads were built prior to the adoption of the 

federal Inventoried Roadless Area (IRA) Rule in 2001. There are nearly 33,000 acres of timber 

in the Tongass that are currently off limits to timber harvesting, but accessible by established 

roads. This is largely because the final IRA regulations were not updated to reflect as-built roads 

in the Tongass between when roadless designations were first proposed as part of the RARE II 

process in 1978 and when the IRA regulations were issued in 2001. The 2008 TLMP certainly 

does not consider the additional roads built in the forest between 2003 and 2009, when the rule 

was not in effect in the Tongass because of a court accepted consent decree, but then was 

reinstated early in the Obama Administration - a decision still being litigated. Harvesting should 

be permitted from existing roads that have already been built in the Tongass. It should not be 

prohibited simply because of planning inertia that was in effect prior to adoption of the IRA rule 

by the Clinton Administration. 

TIMING ISSUES OF PLAN AMENDMENT - The Forest Service should ensure that a 

transition is economically feasible and likely to succeed before amending the 2008 Plan and 

"locking in" reduced old-growth timber harvest offerings. 

As noted above, it seems clear that the final new TLMP will be crafted and reviewed before there 

is data that confirms the volume of young-growth timber currently available for harvest in the 

Tongass, and long before an economic study is finished that confirms that it will be financially 

viable for a Y-G industry to develop (and find profitable markets for its products) based on that 

level of wood volume. 

In its final recommendations, the TAC acknowledged that there are still considerable 

uncertainties in the amount, volume, and timing of the availability of Y-G to support a transition. 

Among the panel's overarching principles is the statement that "due to uncertainties in young 

growth inventory data and often significant differences in on the ground operational outcomes, 

13 
independent monitoring is essential to achieve the dual objective of reducing old-growth sooner 

and providing for a viable timber industry."51 

During its review of forest policy, the TAC noted that of the 16.7 million acres of the Tongass 

under Forest Service control, 13.3 million acres already are under wilderness (5.9 million acres) 

and Natural Setting classifications (7.4 million acres). That leaves just 3.4 million acres for any 

development. 52 The panel found that of the 435,000 acres of the Tongass that have already been 

harvested, most harvested since 1954, only 273,000 acres are areas currently considered as 

"suitable" for harvest - outside of beach fringe and stream buffers - and only 186,000 acres 

currently are in Forest Service areas open for Y-G harvesting. More than 120,000 acres of Y-G is 

currently classified as non-suitable for second-growth harvest. 53 

The Forest Service, acting on the TAC recommendations, proposed in July 2015 to fund up to $4 

million of studies to update the inventory of young-growth by location and to develop better data 

on the growth rates of young-growth trees. While a privately funded study was in process in late 

summer and early fall of2015, the separate Forest Service funded study of inventory, led by the 

Pacific Northwest Research Station with assistance from the State of Alaska's Division of 

Forestry personnel, was delayed from the start. Work presumably continues to progress on the 

methodology to guarantee that it will provide credible data from more age-classes of Y-G timber 

in more locations forest-wide and on all slopes, not just on southern facing slopes (southern slope 

trees due to ground warming in northern climates usually produce the biggest and fastest 

growing trees). Consequently, that study is unlikely to be started until spring 2016 and unlikely 

to be completed prior to the finalization of the final new TLMP planned for December 2016. 

Even if the study will be completed in time, the study, as currently envisioned, will not produce 

the quality of data needed to accurately forecast future Y-G timber availability forest-wide. 

Again, the inventory study should sample young-growth from all land areas and all age Classes. 

Harvests in the Tongass before 1976 tended to be at low elevations, below 500 feet, where 

harvesting costs were the lowest, but also where trees grow the fastest from warmer soil 

temperatures. Harvesting- and thus future tree growth after 1976 where about two-thirds of the 

future Y-G trees will come from -will produce markedly different growth rates and thus 

different harvest volumes. Appendix B-2 of the DEIS seems to imply that while new site 

class/site index data was estimated and fed into the computer models used to estimate wood 

availability, there were not any actual field surveys at the time of the DEIS to prove the accuracy 

of the site index information upon which the new land Plan Amendment is based. Until the site 

index data is confirmed as accurate across all age classes and all terrains and elevations in 

Alaska, not just the Pacific Northwest, it would appear to be impossible for either the Forest 

Service or private mill operators to have much faith in the accuracy of the DEIS. All of the 

assumptions on the economic feasibility of a transition flow from this basic data. How can, for 

example, logging costs for Y-G timber be accurately forecast without true faith in the volume 

estimates? How can the computer models be upgraded to depict Alaska Y-G timber output if the 

volumes and grades for that timber are in so much doubt, affecting saw and utility log forecasts? 

51 TAC, Final Recommendations, 4. 52 Id. at 1 (a slightly different number than the Forest Service projections). 

53 Id. at 8-10. 

14 
The Alaska Forest Association and individual timber operators in the region will likely express 

similar concerns with greater precision in their comments. 

Equally important, the TAC urged that funding take place for studies into the economics of 

product formation from Y-G timber. "There is limited information available on growing, 

managing, harvesting, processing, manufacturing, and marketing of young-growth timber within 

Southeast Alaska. Additional research re~arding young-growth silviculture and operability is 

necessary to support a viable transition." 4 The committee noted that for a Y-G industry to 

succeed businesses will have "to adapt their business models and develop new products and 

markets." It recommended that the Forest Service "provide assistance to communities and 

businesses, conduct market analysis and products demand analysis" to aid a transition. 55 An 

economic analysis should proceed and be funded and finished before a plan amendment to the 

2008 Plan is proposed, much less adopted. 

U.S. Department of Agriculture (USDA) officials have voiced support for providing additional 

funding to cover an economic study of products that may be produced in Alaska from Y-G 

timber, to estimate costs of production, transportation and sale. The environmental community 

has expressed suppo1i for such studies. Such studies need to be conducted. My concern is that the 

Secretary did not propose any money for such studies in the Administration's FY 17 budget 

released February 9, 2016, nor did the budget propose any additional funding for the inventory 

studies cited above. Without the Secretary and Forest Service committing significant funds to 

advance their transition, the transition will falter. 

I suspect that even more funding will be required for economic and marketing studies before 

private financing will be available to support a Y-G transition. The financial analysis on Page 3-

481 of the DEIS, for example, indicates that all of the plan alternatives, including the preferred 

Alternative 5, have a positive net present value. And Table 3 .22-16 indicates that Alternative 5 

will result in a $112.9 million net present value. But without any information on the cost of Y-G 

harvest, much less better estimates of the reduction in the value of POG when sale areas decrease 

and production costs rise, how can estimates that predict Forest Service costs will be about $105 

per thousand board feet and the typical purchaser profit will be about $80 per thousand board 

feet possibly be accepted as potentially accurate? Until data on the volume of Y-G and data on 

the potential products that will be manufactured from Y-G, as well as their costs and profits, are 

generated, it is impossible to believe that forecast models, based on the Lower 48' s experience, 

can possibly govern either Forest Service policy or private sector investment decisions. It is one 

thing to base policy on "informed estimates" when those estimates have a reasonable, proven 

basis in fact, but it is a totally different case to base public policy on forecasts that have such a 

tenuous relationship to proven facts in Alaska - given its different marketing costs, labor costs, 

transportation costs, operating costs, and likely volumes of future wood availability. 

While it is fully appropriate for the Forest Service to continue to study and develop actual data 

that may prove that a transition to greater Y-G usage can happen sooner than the industry's 

expectation of 30 years, it is inappropriate for the Plan Amendment to be proposed, much less 

54 Id. at 24 (Research Investments). 

55 Id. at 25. 

15 
finalized, until that work is undertaken - something that is unlikely to happen prior to 2017 on a 

forest-wide basis at the current level of funding seemingly being proposed by the Forest Service. 

TONGASS ADVISORY COMMITTEE RECOMMENDATIONS -The Forest Service 

should take closer account of the TAC's detailed recommendations. 

While I will leave it to the TAC to file their own comments on the Proposed TLMP, it is 

noteworthy that the Forest Service has declined to follow a number of the TAC 

recommendations. 

To encourage a transition to Y-G sooner than market conditions might allow, the TAC proposed 

a system of "co-intent" where Y-G acreage in "unsuitable" areas could be harvested within the 

first 15 years of a transition to provide greater volumes quickly to permit an economic transition 

to begin. But the Forest Service's Alternative 5 includes restrictions of harvesting in such areas 

that may make it far harder for such Y-G harvesting to take place economically. 

More important, the TAC recommended that if any suitable young-growth acres are removed 

from the timber base as a result of future review processes, an equal number of acres should be 

added to the Y-G base. This effectively prevents the continual chipping away of a commercial 

timber base as has been the case under recent Forest Service TLMP revisions. There is nothing in 

Alternative 5 that seems to carry out that requirement - a key basis for the panel reaching 

consensus on its recommendations. There is also little in the Plan Amendment alternatives that 

will implement the TAC's detailed recommendations on additional federal aid, new policies for 

planning and overseeing sales, guarantees that timber sales will be conducted to provide a 

reliable supply of timber for mill amortization, or on its requests for new oversight panels 

governing and reviewing forest plan implementation and enforcement. 

RENEW ABLE ENERGY OVERLAY - The plan revisions should give greater assurance 

of speedy approval for roads or transmission facilities through roadless areas to developers 

of proposed renewable energy projects. 

As part of its plan update, the Forest Service agreed to consider changes in regulations governing 

the construction of roads and electrical transmission lines to' facilitate the economics of 

construction of renewable energy projects in or through the 9 .5-million acres of Inventoried 

Roadless Areas (IRAs) in the Tongass. In my comments of June 26, 2014 on the harvest plan, I 

encouraged the Forest Service to modify the 2008 Plan to make it clearer and easier for r.oads 

and utility systems to be built to facilitate less expensive construction of renewable energy 

projects, and also to aid economic development of mineral deposits in the forest. 

I welcome the decision of the Forest Service to include language in the plan update to make its 

intent known that it wants to facilitate construction of roads and electrical transmission lines for 

renewable energy developments. Unfortunately, it's far from clear that the actual plan revision 

will give any greater assurance of speedy approval for roads or transmission facilities through 

roadless areas to developers of proposed renewable energy projects. 

16 
Because the Forest Service prepared the post-World War II study that noted nearly 200 sites in 

Southeast Alaska that could potentially be tapped for hydroelectric power generation, there are 

innumerable sites that could permit lower-cost hydroelectric generation. Such cost savings are 

considerable in light of the roughly 60-cents per kilowatt hour cost of diesel-fueled generation in 

the region (a cost that admittedly has fallen recently due to falling world oil prices). 

Theoretically, transportation and utility access was guaranteed through most of the Tongass 

National Forest by Title 11 of ANILCA, which set up a process guaranteeing access through 

conservation system units after the agency ruled that IRAs are covered under that definition. A 

consent decree several years ago did permit about a dozen projects to proceed in roadless areas. 

But that ruling leaves out many dozens more. While the existing 2008 Plan does not preclude 

construction of roads and utilities in roadless areas, it does contain regulations that complicate 

approvals for roads and transmission facilities in some Land Unit Designation (LUD) areas. 

Although the existing alternatives propose to provide more "flexibility" on a "case-by-case" 

basis for roads and utilities, the language does not provide sufficient certainty of approval to 

encourage developers to advance costly reconnaissance studies of potential projects that could be 

impacted by roadless rule regulations. I strongly encourage the Forest Service to look again at 

how it is proposing to handle future requests for renewable energy developments in and impacted 

by roadless areas to prevent needless costs and development uncertainties. 

MINERAL DEVELOPMENT ACCESS - The Forest Service should allow roads through 

roadless areas to guarantee more affordable access to mineral developments. 

Concerning mineral development, the draft alternatives do nothing to allow development of 

roads or power transmission lines through IRAs to aid mineral developments in the region. The 

2001 Roadless Rule allows for "reasonable access" to locatable minerals covered by the Mineral 

Leasing Act of 1920. 56 But agencies have defined "reasonable" access to not be determined by 

the economics of access. 

Thus, if a mine site can be accessed by water, the Forest Service is unlikely to approve roads that 

likely would make access less expensive for both the mineral developers and for workers 

heading to the project, even though the January 2001 regulations permit roads to be built across 

inventoried roadless areas if needed "in conjunction with the continuation, extension or renewal 

of a mineral lease on lands that are under lease by the Secretary of the Interior."57 The Forest 

Service, for example, in 2013 opposed legislative efforts to speed a permit for a road through an 

IRA to reach either the Niblack or Bokan Mountain mineral and rare earth element deposits on 

southeastern Prince of Wales Island. While access to the mines can come by water, workers 

living on the island will effectively have to reach Ketchikan in order to be transported back to the 

mines for work - a more dangerous and time consuming process than if they could simply drive 

to work by the road network on the Island. It would make great sense for the USDA, which two 

years ago classified Southeast Alaska as a high unemployment area, authorizing it to receive aid 

from its Operation Strikeforce initiative, to allow roads through roadless areas to provide more 

reasonably priced access for workers to mineral developments. Any plan update should be 

modified to guarantee more affordable access to mineral developments. 

56 36 C.F.R. Part 228. 

57 36 C.F.R Ch. II § 294.12(b)(7). 

17 
GENERAL ADDITIONAL POINTS: 

The Proposed TLMP and the Demand Estimate have a variety of other issues. There are serious 

weaknesses in both the Demand Estimate and in the DEIS. For example, in no particular order: 

• The demand analysis does not make any estimates as to the cost of accessing, 

transporting, and harvesting of Y-G timber, undercutting the credibility of its cost 

estimates. 

• The demand analysis contains no Alaska-specific estimates of the cost of producing 

products from Y-G timber, which undercuts the credibility of its estimates for the demand 

for Y-G in the first 10 years, and in years through 2030. 

• The DEIS on Page 3-223 argues that an Alexander Archipelago wolf threatened or 

endangered listing decision under the Endangered Species Act would impact timber 

harvesting and seemingly require greater use of Y-G. Since the listing did not take place 

on January 6, 2016 and the USF&WS ruled that the Alexander Archipelago is not a 

unique subspecies of gray wolf, that assumption affecting the Plan is invalid. 

• The demand report argued that biomass from Y-G timber could be economic because of 

the high price of diesel fuel for home heating. Given current world prices for crude oil of 

around $28 a barrel, the price for diesel fuel is falling rapidly which undercuts the 

methodology of the demand study. As of January 20, 2016, diesel prices nationwide on 

average were $2.13 a gallon, compared to $2.89 one year earlier - a fall of 35%. 58 

CONCLUSION: 

Since the start of commercial logging in an area slightly larger than West Virginia, only about 

435,000 acres of the nearly 10 million acres of total forested lands have been disturbed by 

humans, or just eight percent of the total productive forest. By allowing an alternative that might 

involve harvesting of just 17 ,000 more acres of old-growth timber over the next quarter century 

than the other four plan alternatives, the Forest Service could well restore hundreds of direct and 

indirect jobs in the region, without noticeable harm to the region's commercial fisheries, wildlife 

habitat, Native subsistence activities or the environment. By simply following the existing 2008 

Plan, it could add even more jobs and payroll in an economically distressed region, without harm 

to the environment or wildlife or fisheries. The agency should wait to decide whether and what 

kind of TLMP plan update is required until there is firm data to support the Administration's 

policy decision to accelerate a transition to a young-growth forest management program in the 

region. A delay in this plan revision is the only action available to the Forest Service that is 

justified by the record. 

Sincerely, 

United 

Murkowski States Senator 

58 AAA Daily Fuel Gauge Report (January 20, 2016), available at http://www.fuelgaugereport.com/. 

18 
STATE CAPITOL 

P.O. Box I IOOO I 

Juneau. AK 9981 1-000 I 

907-465-3500 

fax: 907-465-3532 

February 22, 2016 

Mr. Earl Stewart 

Forest Supervisor 

Tongass National Forest 

Attn: Forest Plan Amendment 

648 Mission Street 

Ketchikan, AK 99901 

Governor Bill Walker 

STATE OF ALASKA 

Re: Tongass Land & Resource Management Plan Amendment and DEIS 

Dear Mr. Stewart: 

550 West Seventh Avenue. Suite 1700 

Anchorage. AK 9950 I 

907-269-7450 

fax 907-269-7461 

www.Gov.Alaska.Gov 

Governor@Alaska.Gov 

The State of Alaska (State) has reviewed the Draft Environmental Impact Statement (DEIS) for the 

U.S. Forest Service's (USFS) proposed Land and Resource Management Plan (Proposed Plan) for 

the Tongass National Forest and is pleased to provide its comments. 

I appreciate the primary intent of the plan amendment to accelerate the transition from an oldgrowth to a predominantly young-growth forest management program in the National Forest, and 

to do so in a way that preserves and sustains a viable timber industry that provides jobs and 

opportunities for residents and communities in southeast Alaska. Through the Division of Forestry, 

the State actively participated in the Tongass Advisory Committee (TAC) that achieved consensus 

on a suite of recommendations to the USFS on its young-growth transition strategy. A key objective 

for the State is the triple bottom line, where social, economic, and environmental interests are 

balanced to produce an outcome with broad support. We must continue to work together to ensure 

that the Tongass National Forest provides maximum benefits to the communities of Southeast 

Alaska and all users of the forest. 

I would also like to acknowledge the great work that has been done by the TAC. Rarely have I ever 

seen an effort like this, where stakeholders with such varied interests have come together to reach a 

consensus on a very complex resource management issue. I greatly appreciate the work of the TAC, 

and I hope that this committee, or one similar to it, will continue to help guide the USFS and the 

State as we continue to work toward a strong, vibrant economy for the residents of Southeast 

Alaska. 

I am pleased that many key recommendations from the TAC were incorporated into Alternative 5 of 

the DEIS. 

However, I am generally concerned about the underlying science and analysis that 1) supports the 

feasibility of young-growth forest management, and 2) demonstrates the effectiveness of such a 

strategy. The Forest Plan needs to include scientific information and sound analysis regarding both 

the silvicultural treatments necessary for timber production and a sustainable industry, and a 

concurrent analysis of how these treatments affect key wildlife species and their habitat. The plan 

must demonstrate, with accompanying science-based appendices, that young-growth management 
Mr. Earl Stewart 

State of Alaska Comments on Tongass Land and Resource Plan Amendments 

February 22, 2016 

Page 2 

can sustain timber outputs and useable and sustainable wildlife populations. This is particularly 

important in highly-modified landscapes. 

While this is an amendment and not a full forest plan revision, the transition to predominantly 

young-growth harvest and management will be a ground-breaking event on the Tongass. Science is 

key to determining what is, or is not, feasible. For such a significant resource management policy 

change, the science and analysis must be rigorous. State resource managers believe more work is 

required in this area. 

I would also like to highlight a significant concern that none of the alternatives will meet the 

requirement of the Tongass Timber Reform Act. The State encourages USFS to assess the legal 

consistency of the Forest Plan with the Act. The Act's clear directive to maintain a viable forest 

products industry supported by Tongass timber must not be lost in the evolution of Tongass 

National Forest policy. To do so only continues the crippling legacy of litigation and controversy 

that unfortunately is a historic legacy of Tongass forest management. 

The State departments of Natural Resources, Fish and Game, Transportation and Public Facilities, 

and Environmental Conservation have carefully reviewed the Proposed Plan and DEIS. Their 

attached consolidated comments include more technical detail regarding the concerns listed above, 

as well as comments and suggested revisions on topics including timber demand calculations, 

transportation corridors, subsistence, fish and wildlife habitat, water quality, and consideration of 

wilderness and wild and scenic rivers. It must also be emphasized that mineral development and 

alternative energy values are of significant consideration. 

Thank you for the opportunity to comment on the DEIS and draft Proposed Plan. Please contact 

the State of Alaska agency staff identified in the attached consolidated comment letter if you have 

any questions or you would like to discuss our comments in greater detail. 

Sincerely, 

'll~P~ 

Bill Walker 

Governor 

Enclosure 

cc: The Honorable Lisa Murkowski, United State Senate 

The Honorable Dan Sullivan, United States Senate 

The Honorable Don Young, United States House of Representatives 

The Honorable Sam Cotten, Commissioner, Alaska Department of Fish and Game 

The Honorable Larry Hartig, Commissioner, Alaska Department of Environmental 

Conservation 

The Honorable Marc Luiken, Commissioner, Alaska Department of Transportation and 

Public Facilities 

The Honorable Mark Myers, Commissioner, Alaska Department of Natural Resources 
1 

Tongass Land and Resource Management Plan Amendment 

Draft Environmental Impact Statement (DEIS)

State of Alaska – Agency Comments

February 22, 2016 

The State of Alaska (State) appreciates the opportunity to provide its comments on the Proposed 

Amended Land and Resource Management Plan (Proposed Plan) and Draft Environmental 

Impact Statement (DEIS) for the Tongass National Forest.

The State has participated in the development of the Proposed Plan since the U.S. Forest Service 

(USFS) issued a Notice of Intent (NOI) to prepare an environmental impact statement (Federal 

Register, Vol. 79, No. 101, May 27, 2014). The State submitted comments during the 30-day 

public scoping period and now requests your consideration of the following comments on the 

Proposed Plan and DEIS. These comments were prepared by the departments of Natural 

Resources (ADNR), Fish and Game (ADF&G), Transportation & Public Facilities (ADOT&PF), 

and Environmental Conservation (ADEC). They are presented in order of general priority. 

FORESTRY1

The State, through ADNR’s Division of Forestry, was an active participant in the Tongass 

Advisory Committee (TAC). The TAC was a formally recognized Federal Advisory Committee 

Act (FACA) process that achieved consensus on a suite of recommendations to the USFS on the 

Young Growth transition strategy. Many of the key recommendations from the TAC are 

incorporated into Alternative 5 of the DEIS, however there were many important 

recommendations concerning the transition that were not appropriate to include in the DEIS and 

Proposed Plan. These recommendations were focused on the forest plan implementation process 

and cultural change within the USFS that will be necessary to successfully navigate the agency, 

forest industry, communities and residents of the region through the transition. 

The TAC charter was narrow and focused its effort primarily on the Young Growth transition 

and the timber management aspects of this challenge. There are other important economic 

sectors and interests at play in the Tongass National Forest and these interrelated interests should 

be addressed as the transition unfolds. Balancing these interests is no easy task but the TAC has 

taken the first steps in laying the foundation for this effort. The next steps of implementation and 

adaptation will be critical to the outcome of the transition. While the State fully supports the 

TAC process and recommendations, we have serious concerns with the Proposed Plan and DEIS. 

 

1 The State of Alaska point of contact for forestry-related comments on the Proposed Plan and DEIS is Jim 

Schwarber with DNR’s Division of Forestry. He can be reached at james.schwarber@alaska.gov or 907-451-2704.
2 

By providing the following comments, the State retains its right to file an objection after the 

public comment period closes on February 22 or consider other action. 

Any national forest plan developed must meet all applicable laws including Section 101 of the 

Tongass Timber Reform Act (TTRA) of 1990 (Public Law 101-626) that states in part, “the 

Secretary shall to the extent consistent with providing for the multiple use and sustained yield of 

all renewable forest resources, seek to provide a supply of timber from the Tongass National 

Forest which (1) meets the annual market demand for timber from such forest and (2) meets the 

market demand from such forest for each planning cycle.” 

Currently the “existing industry” is an old-growth-dependent industry and the majority of the 

industry believes that old-growth harvest must continue until there is a sufficient quantity of 

young growth to supply the industry (greater than 100 MMBF); in addition for mills the young 

growth must reach sufficient size to produce clear cuttings for niche markets (150+ years of age) 

(See the attached Working Forest Group (TWFG) report, Strategies to Maintain a Viable Timber 

Industry in Southeast Alaska, 2015).

The annual market demand (seek to meet) in the past has been calculated by the Morse 

Methodology. The last information on the Region 10 website is for FY2014; for that year, the 

estimated volume the USFS should offer to meet the FY2014 sell objectives was 142 MMBF 

(line Q under the expanded lumber scenario). The annual projected timber sale quantity (PTSQ) 

under the amended Forest Plan should equal the annual market demand number. No alternative 

in the DEIS provides sufficient volume to meet this annual demand number. The proposed PTSQ 

in the DEIS, 46 MMBF, does not meet the requirements of TTRA sec. 101 to seek to meet the 

annual timber demand from the forest. 

The Proposed Plan also does not meet the statutory requirements of TTRA because no alternative 

provides sufficient quantities of old growth during the planning cycle (life of the Plan, 15 years) 

to meet the demands of the existing industry which is old-growth dependent. Thus, regardless of 

which alternative is selected, the Proposed Plan will violate both prongs of the requirement of 

TTRA sec. 101 to “seek to meet” timber demand. This will be a fatal legal flaw in the amended 

plan. The language requiring the USFS to “seek to meet” timber demand is more than a mere 

suggestion from Congress that the Forest Service consider the timber industry in its planning 

process. 

The TTRA includes caveats that recognize the USFS may not always actually meet the market 

demand for timber due to circumstances beyond its control, such as litigation that prevents a 

planned sale from actually being offered and sold. However, the intentional creation of a Forest 

Plan that on its face actually prevents the USFS from offering sufficient timber to meet demand 

cannot possibly be construed by the public or the federal courts as “seeking to meet market 
3 

demand.” Based on the above, none of the action alternatives meet the Purpose and Need to 

preserve a “viable timber industry.” 

We find it problematic that the DEIS utilizes, as a foundational source, an unpublished draft 

report (Daniels, et al; in press) that is referenced 52 times. A final Timber Demand Study would 

be more appropriate considering its importance to informing the DEIS. 

• Since the Tongass Timber Reform Act, sec. 101 requires the Forest Service to “seek to 

meet” timber demand, the use of an unpublished draft of timber demand projections is 

unacceptable in the DEIS. In addition, the Proposed Plan itself makes no direct mention 

of the Daniels et al. study.

• Daniel’s draft Demand Study is flawed in part because of its incorrect assumptions of 

volume available from State and private lands, and by assuming this volume will be 

offered on an annual basis. Timber resources managed by the University of Alaska Lands 

Office and the Alaska Mental Health Trust will not contribute as much timber harvest in 

the near future as they have in the recent past. These two entities follow a different 

harvest strategy than the Alaska Division of Forestry does on the state lands it manages in 

Southeast Alaska.

• An unrealistic assessment of market demand may be considered a fatal flaw in a national 

forest plan EIS. The USFS’ inflated assessment of market demand was successfully 

challenged in Natural Resource Defense Council v. USFS, 421 F.3d 797, 811-12 (9th Cir. 

2005) We think the same flaw exists in this plan, wherein the market demand is deflated 

to the point that it is misleading. The PTSQ is what the USFS wants to offer over the long 

term, not what the industry needs to survive or maintain itself at the existing level.

• The DEIS refers to Daniels (2015) inconsistently throughout the document. Initially the 

“Daniels (2015)” format is used 22 times between pages 2-8 to 3-347, implying this is a 

final report. A variation that appears once is “(Daniels et al 2015)” on page 3-313. One 

must review the References on page 6-14 to see this actually refers to an “Unpublished 

Draft Methodology.” Appendix G of the DEIS then refers 27 times to a “Daniels et al. (in 

press)” and includes a different title in the Citations on page G-9 of the DEIS. Are these 

actually two different references, or do they refer to the same unpublished manuscript? 

• Please explain why the DEIS uses 25- and 100-year timeframes for comparison purposes. 

The use of those timeframes is misleading to the public. The lifespan of a Forest Plan is 

15 years. A forest plan must show volumes for PWSQ (Projected Wood Sale Quantity) 

and PTSQ (Projected Timber Sale Quantity) for two decades per USFS Handbook 

direction. Based on this requirement, analysis and comparison of alternatives should be 
4 

based on a 20-year period. Projecting that a Forest Plan and PTSQ will not change over 

25- and 100-year periods is misleading especially for the Tongass. Page 1-2 and 1-3 of 

the DEIS provide a planning history for the Tongass. The first forest plan for the Tongass 

was completed in 1979; since then there has been at least six different forest plans for the 

Tongass and the annual sales quantity has gone from over 400 MMBF to 46 MMBF 

under the current DEIS. Over a 36-year period, the forest plan has been changed every 

six years. To project and compare alternatives and suggest to the public that 

implementation of forest management activities will not change over 25- and 100-year 

periods misleads the public and prevents the public from being able to provide informed 

comments on the Proposed Plan. Please revise with appropriate timeframes for 

comparison. 

• Analysis for the DEIS should be based on a 20-year period that coincides with the PWSQ 

and PTSQ calculations. Analysis over longer timeframes should provide the public 

information on the continued effects of actions taken during the life of the Forest Plan (15 

years) or the PTSQ projects for the first two decades.

• Another issue is the timeframe used in Daniel’s draft Demand Study, which only projects 

timber demand for a 15-year period (2015-2030). Any demand study associated with a 

forest plan should be for the first two decades so that the projected wood sale quantity 

(PWSQ) and PTSQ can be developed. Note that the proposed PTSQ under the DEIS is 

less than the derived Demand for the three scenarios that Daniels develops (Table G-1 

page G-6 DEIS Vol II). The PTSQ should at least be equal to the largest derived demand 

volume for the first two decades of the plan. 

• The PTSQ developed for the Proposed Plan should have taken into consideration the 

following statement from the Timber Demand section of the DEIS: 

o “In choosing the timber sale offer level, it is important to anticipate the 

consequences of decisions. In terms of short-term economic consequences, oversupplying the market is less damaging than under-supplying it. If more timber is 

offered than purchased in a given year, the unsold volume is still available for 

purchasing off-the-shelf or re-offered at a minimal investment. However, a 

significant shortfall in timber supply available for harvest can be financially 

devastating to the industry.” (Pg. G-8, DEIS Vol. II) 

• The DEIS on page 1-5 under Need states, “that the transition should be implemented in a 

manner that preserves a viable timber industry that provides jobs and opportunities for 

Southeast Alaska residents.” The DEIS needs to define “viable timber industry” and 

“existing industry.” These terms need to be defined for the Forest Service to be able to 
5 

develop a Forest Plan that “preserves” or “retains” the timber industry in southeast, and 

to be able assess positive or negative changes in the timber industry resulting from 

implementing the transition. 

Analytical Needs

The analysis within the DEIS needs strengthening. For example:

• Table 3.9-10 Existing Young Growth in Reserves and in Matrix Lands by Alternative is 

misleading in that the percentage in each column is the percent of the total amount of 

young growth (YG) on the forest, not its percentage based on the subsection it is in 

(Reserve or Matrix).

• In Alternative 2 in Table 3.9-10, the reserves contain 110,339 acres of YG. This

alternative will harvest 47,136 acres or 42.7% of the YG acres within the reserves; the 

table shows that amount of harvest as only 10% of the total acres of YG. What are the 

effects to the reserve system if 42.7% of the YG within the reserves is harvested? YG 

stands within beach buffers and less than 800 foot in elevation have greater value for 

wildlife that YG stands above 800 feet in elevation, and they may have more value than 

old-growth stands depending upon the location of the old growth (OG). 

Nowhere in the Economic and Social Environment section on wood products is there any 

discussion on the cost to harvest and produce a manufactured product, either lumber or biomass 

(see lumber price graph). Please provide this missing information. 

• Note graphs on pages 3-482 and 3-483 (Net Revenue) Figure 3.22-17 is net revenue for 

OG and Figure 3.22-18 is net revenue for YG. When you add the values together for a 

five year period in most cases the total net revenue is negative in value. As an example, 

Alternative 5 (preferred alt.) in Years 16-20 (a period when the transition has been 

completed and YG makes up the majority of the volume being offered) the total net 

revenue sum is a negative $10 million. How can the USFS have a timber sale program 

that is negative value when Public Law 112-74, House Report 2055-257, Section 414 

allows it only to offer positive value timber sales?

• Note the information under Financial Analysis on pg. 3-481. The DEIS uses pond log 

value (PLV) to determine net revenue. 

o Pond log values are the price a buyer would pay for a log at the mill site (selling 

value minus manufacturing costs). Logging and transportation costs and an 

amount for normal profit and risk are also factored into this value. These pond log 
6 

values represent the value to the purchaser and are net of Forest Service costs that 

would be incurred for National Environmental Policy Act (NEPA) preparation, 

sale preparation and administration, and engineering support. (DEIS pg. 3-481) 

• Table 2.22-16 shows discounted net revenue by alternative. How can the USFS show 

positive net revenue based on the statement above when the USFS has been subsidizing 

its timber sale program for years? The USFS cost for sale preparation and support is 

approximately $104/mbf (2014 Saddle Lakes DEIS pg. 3-67). 

• Real life example – (2014 Saddle Lakes DEIS chapter 3 Issue 1 – Timber Economics 

section pg. 3-62) In Table 5,they have taken the end sales value minus the total cost to 

create the end product and the result is a negative value in all but one alternative under 

the export policy scenario. What is labeled the indicated advertised rate is the stumpage 

return to the USFS and is before the USFS subtracts their administrative cost of 

$104/mbf. 

• Another real life example – (Big Thorne Project, ROD 2013) Table ROD-9 on page 36 

shows an indicated bid value for the selected alternative as $23.77 positive; again this is 

before the FS admin fee of $104/mbf is subtracted. Big Thorne includes both OG and YG 

volume. 

• Using the discounted net revenue number for Alternative 5 from Table 3.22-16, the USFS 

is saying it will average a positive return of ~$98/MBF ($112.9 million divided by 

(46MM(annual volume) *25years)) over a 25-year period after subtracting its

administrative cost.

According to 40 CFR 1502.23, when economics are relevant and important to a decision, 

economic information must be included in an EIS. 

• The DEIS documents do not detail the PLV used by the USFS. What is the PLV number 

for YG? What is the PLV for OG? Nothing in the documents tells the reviewer how the 

USFS determined the PLV and cost of future harvest 25 and 100 years out. Did the USFS

use a set percentage increase over time? Please provide this missing information.

• In Appendix B (pg. B-13) when they performed the modeling exercise they used only the 

five southern districts on the Tongass for the first 15 years. By not considering/using the 

entire Tongass they misrepresent the actual cost of harvesting timber from the forest. See 

TWFG paper, Analysis of Old Growth Inventory and Land Base Available for Operations 

within the Tongass National Forest, 2014. In that document the cost of transportation 
7 

from the northern part of the Tongass to the Viking mill in Klawock drives most volume 

available for harvest into negative value territory.

• Based on the Woodstock model (see attached TWFG sheet) for Alternative 5 and the 

statement on pg. 2-32 of the DEIS, by year 16 the volume of OG harvest will be reduced 

to 5MMBF per year or a total of 25MMBF for the period years 16-20. The Woodstock 

model shows the 25MMBF of OG producing a net return of $360.99/mbf. Refer to the 

net returns for Saddle Lakes and Big Thorne; the USFS has not produced an OG timber 

sale that generates a net return after administrative cost of $360.99. 

Corrections or Revisions Needed 

Page 3-450, DEIS: Table 3.22-5 shows the average timber harvest for State lands is 25.7 MMBF 

for the last 13 years; the average for the last seven years is a much lower 12.3 MMBF. The last 

seven years is a better indication of future volume based on the fact that Alaska Mental Health 

Trust and the University are not bound to manage on a sustained-yield basis. 

Page C-4, DEIS: Table C-1 breaks down past road construction and states that 3,379 miles out of 

3,660 miles of roads constructed on non-national forest land remain open. Based upon the 

Division of Forestry’s best estimate, instead of 92% remaining open, the total still open is more 

likely in the range of 1500-2000 miles, or about 50%. 

Additions 

Since this amendment process is driven by Memorandum 1044-009 – July 2, 2013, consider 

including the memorandum in the Appendix of the DEIS, or at least the two quotes below: 

• “To accomplish the transition to a timber program based primarily on young growth, it 

is important to retain the expertise and infrastructure of the existing industry so 

businesses can quickly re-tool. These businesses are fundamental to both the young 

growth and restoration components of the future timber program, and to the economic 

vitality of the region. Such an approach requires a reliable supply of economically viable 

timber, with the old growth component decreasing over time while the young growth 

component increases.” 

• “To ensure a smooth transition, the Forest Service will continue to offer a supply of old 

growth timber while increasing the supply of young growth to provide industry in Alaska 

the opportunity to develop new markets, learn new skills, and acquire new equipment. 

The continuation of limited sales of old growth timber is essential to maintain the existing 

industry until young growth can efficiently be processed.” 
8 

WILDLIFE2

The Alaska Department of Fish and Game (ADF&G) reviewed USFS alternatives 

accommodating the transition from old-growth to young-growth timber harvest and looks 

forward to participating in future interagency review of the young-growth monitoring plan. 

ADF&G recognizes the value to wildlife in transitioning to young-growth forest management 

while maintaining sufficient old-growth forest to support sustainable and harvestable populations 

of old-growth associated birds and mammals. 

Wolves 

ADF&G supports additional research and analyses concerning the effect of the Proposed Plan on 

Alexander Archipelago wolves. The State has primary trust authority for managing wolves and 

the USFS has land management authorities to provide habitat and access management for wolves 

in cooperation with the state. Conservation of wolves in this area warrants additional 

consideration in the Forest Plan.

Sealaska Land Exchange and the Old Growth Reserve System

The Old Growth Reserve (OGR) system was first established in the 1997 Forest Plan as the 

primary component of the wildlife conservation strategy with the intent of providing habitat 

sufficient to maintain sustainable, well-distributed populations of old-growth associated species. 

The OGR system is particularly important for maintaining populations of old-growth associated 

species in areas where much of the old-growth forest has been harvested. The Southeast Alaska 

Native Land Entitlement Finalization and Jobs Protection Act transferred land out of the Tongass 

National Forest to Sealaska Corporation including lands within existing OGRs. The USFS 

worked with ADF&G and others to create new or modified OGRs for affected areas of the 

Tongass National Forest from remaining productive old growth (POG). A report on that effort is 

included in Appendix D of the DEIS. 

Although Appendix D of the DEIS states that a review of the scientific basis for the current 

conservation strategy is outside the scope of this amendment, ADF&G recommends the USFS 

use its science review process to assess the new and modified OGRs before issuing the Final 

Environmental Impact Statement (FEIS). If the review of the modified OGRs indicates they are 

unlikely to meet the OGR system intent, especially in heavily-logged areas, and more old-growth 

logging occurs on nearby USFS land, the opportunity to create a more effective system in those 

areas may be lost. 

 

2 The State of Alaska point of contact for fish, wildlife and subsistence-related comments on the Proposed Plan and 

DEIS is Greg Albrecht with ADF&G’s Division of Habitat. He can be reached at greg.albrecht@alaska.gov or 907-

465-6384.
9 

Young-Growth Management 

Page 3-215 through 3-217, DEIS: Please provide more information on benefits to wildlife from 

precommercial thinning. Explain the assumption that reestablishing old-growth characteristics 

will benefit wildlife by discussing benefits and losses to species groups, and describe how 

recurring thinning treatments will affect those groups prior to reaching old-growth characteristics 

or harvest. Please clarify the terms maintain and improve with regard to wildlife habitat by 

providing or referencing a standard of what it means to maintain or improve. 

We recommend the USFS articulate how young-growth management will benefit wildlife. 

Depending on the species and phases of their natural history, some species may benefit from the 

young-growth management, while others may not. The Forest Plan should address the state of 

knowledge regarding the proposed management scheme for at least the management indicator 

species (MIS), provide a quantitative assessment of the most likely effects of second growth 

management for individual wildlife species, and provide a qualitative assessment of effects 

where no quantitative assessments are possible.

Page 3-215 through 3-217 and 3-245, DEIS: Please include outputs (e.g. deer/mi2) from the 

habitat suitability index model at the wildlife analysis area level so that finer scale analyses can 

be made in areas where extensive old-growth harvest was conducted. We caution using the 

FRESH model, with which ADF&G is not familiar, prior to field verification. Please include 

more information in Chapter 3 about the FRESH model and its assumptions. Also, clarify how 

habitat quality is expected to improve after 25 years following thinning prescriptions (DEIS 

Table 3.10.11). 

Specific Comments on the Proposed Plan and DEIS 

Page 2-7, Wildlife, DEIS: Please consider managing habitat to provide for sustainable wildlife 

populations rather than viable populations.

Page 2-8, Wildlife, Proposed Plan: Replace the term sport with hunting. 

Page 2-14 through 2-20, Alternative 2, DEIS: Please provide a clearer description of how harvest 

in the beach buffer occurs. Include discussion of the anticipated effects on MIS when the 1,000 ft 

beach buffer is removed for harvest and road construction. Please expand the discussion of how 

leaving an adjacent inland stand of POG or young growth serves the purpose of the beach buffer. 

It would be helpful to focus this discussion on biogeographic provinces 13 and 14. See our 

similar comments for Appendix D on page 4. 

Page 3-10, Desired Condition, paragraph 1, Proposed Plan: Define appropriate research, how the 

determination is made, and what role the state plays in the process. 
10

Page 3-45, Proposed Plan: Consider adding a land use designation (LUD) standard and guideline 

under the wildlife habitat improvement heading that addresses non-native wildlife management 

following a natural disturbance or disease. 

Page 3-67, Desired Condition, Proposed Plan: Clarify how a population of a species is defined 

as a subspecies. Consider revising the definition on page 7-92 and consult the ADF&G draft 

Wildlife Action Plan for more information on subspecies (2015). 

Page 3-138, Wildlife, Proposed Plan: Please clarify the author and standing of the Tongass 

Young Growth Management Strategy referenced here. The document could be strengthened by 

adding more information regarding the effects of the strategy to wildlife. The version available 

through the references (Page 6-49, DEIS) does not contain Exhibit 3. 

Page 3-223, DEIS: Please update this section to reflect the Fish and Wildlife Service decision 

announced on January 5, 2016 that the Alexander Archipelago wolf does not warrant protection 

as an endangered or threatened species under the Endangered Species Act.

Page 4-96, Proposed Plan: We recommend adding standards and guidelines for protection of the 

Pacific marten Martes caurina, which is endemic to Admiralty and Kuiu Islands. Macdonald and 

Cook (2007) and Dawson (2008) are good resources. 

Page 4-100, DEIS: We recommend eliminating the distinction between peregrine falcon 

subspecies given recent studies about the subspecies status along parts of coastal Alaska. 

Page 4-99, Proposed Plan: Please replace goshawk nest stand with nest site. The monitoring 

protocol could be strengthened by ensuring the assumptions of nest identification and the 

probability of detection is valid. ADF&G biologists are interested in helping USFS biologists 

develop the monitoring program. We are concerned about the efficacy and statistical validity of 

the current goshawk monitoring program. 

Page 5-8, Management Approaches, Proposed Plan: This section would benefit from clear goals 

and objectives related to monitoring the effects of young-growth harvest on MIS. See our similar 

comments for Appendix D on page 4. 

Appendix D of the DEIS 

Page D-3: This section summarizes the scope of analysis and acknowledges new science. As in 

the DEIS, the analysis does not adequately describe how young-growth harvest affects wildlife 

species. Similarly, the DEIS and the section on the contribution of matrix lands lacks adequate 

analysis and should be strengthened with references from land management focused research 

conducted on the Tongass. 
11

Page D-4, paragraph 2, DEIS: Stating young growth serves as dispersal corridors between oldgrowth stands is a generalization, as young-growth stands can be barriers rather than corridors 

for some old-growth associated species. Please revise. 

Page D-5, paragraph 3: The USFS states that on a forest-wide basis, over 90% of the existing 

POG will be protected from harvest. Given the context, this statement implies that forest 

management will have little effect on old-growth associated species because 90% of their habitat 

will remain intact. However, populations of many old-growth associated species are confined to 

islands or biogeographic regions where a much higher proportion of POG has been or will be 

harvested. We recommend that relative to wildlife, such habitat summaries be presented at a 

scale that is meaningful to the species or populations being discussed. 

Page D-5, paragraph 4: To help the reader get a better sense of the scale of changes resulting 

from GIS mapping updates, please add text and a table describing how the changes affected the 

wildlife habitat analysis. For example, provide the number of polygons/acres in a given 

bioregion found to be >150 years old and corrected to size class 4, resulting in increased POG 

acreage in a bioregion.

Page D-12: Please provide a clearer description of how harvest in the beach buffer occurs under 

Alternative 2. Include discussion of the anticipated effects on MIS when the 1,000 ft beach 

buffer is removed for harvest and road construction. Please expand the discussion of how leaving 

an adjacent inland stand of POG or young growth serves the purpose of the beach buffer. It 

would be helpful to focus this discussion on biogeographic provinces 13 and 14, which have the 

highest level of this type of harvest under Alternative 2. See our similar comments for the DEIS 

on page 3. 

Page D-17, paragraph 4: Please clarify the statement that individual islands function as 

metapopulations for some species. 

Page D-18, paragraph 7: This section would benefit from clear goals and objectives related to 

monitoring the effects of young-growth harvest on MIS. See our similar comments for the DEIS 

on page 3. ADF&G is available to help develop the monitoring questions. 

FISH

Ongoing USFS monitoring results show existing standards and guidelines protecting riparian 

areas and fish habitat are largely effective. ADF&G recognizes the need to provide bridge timber 

for the transition to young growth which may require short-term relaxations of conservation 

strategy elements. We encourage simple, measurable, replicable methods to ensure monitoring is 
12

completed and results are useful. ADF&G biologists look forward to being involved with these 

monitoring efforts.

Page 3-31, DEIS: Include discussion and citation of literature regarding how increased harvest in 

the riparian management area (RMA) in moderate vulnerability karst landscapes could impact 

diffuse recharge and stream water quality.

Page 3-103, DEIS: Include discussion and citation of literature regarding potential changes to 

windfirmness due to thinning in the RMA. 

Page 3-103, DEIS: Include discussion and citation of literature regarding how a reduction of the 

RMA width could affect wood recruitment where average tree heights exceed 100 ft. 

Page 3-118, paragraph 5, DEIS: Consider strengthening the discussion by citing recent research 

on rainbow trout and steelhead Onchorhynchus mykiss (Kendall et al. 2015, Pearse et al. 2009, 

Sloat and Reeves 2014a, Sloat and Reeves 2014b). 

Page 3-123, DEIS: Please clarify the circumstances where substantially more RMA group 

selection could occur, and how many acres would be acceptable under this alternative given the 

standards and management approaches in the riparian section of Chapter 5. 

Page 3-126, paragraph 2, DEIS: Consider removing the statement: 

Some negative effects, or more appropriately, increased risk, to the natural range of variation in 

stream processes and fish habitat would likely occur by management activities over the long 

term for all alternatives. The extent of harvest activity and associated road development are 

likely to result in decreases of some fish populations in managed watersheds. 

This is speculative and contradictory to the statement in the first two sentences of the third 

paragraph page 3-126. The presence of risk should not be confused or used interchangeably with 

negative effects, in the absence of supportive research. We recommend removing the association 

between risk and negative effects to fish habitat from the DEIS. The concept that risk is both 

normal and being fully mitigated in the Tongass should be added to the DEIS with discussion of 

Dr. Doug Martin’s body of research, cited elsewhere in the DEIS.

Page 5-8, S-YG-BEACH-03, Proposed Plan: In some locations, such as estuaries, the forest edge 

could be greater than 200 feet from mean high tide and it is not clear whether or not this buffer 

includes non-forest acreage. If the standard is intended to include non-forested acreage, please 

include in the FEIS an evaluation of compatibility with the proposed desired conditions of the 

beach and estuary fringe in Chapter 5 and the forest side standards and guidelines in Chapter 4. If 

the standard is intended to include forested acreage only, we suggest modifying the first sentence 
13

of the standard to Commercial harvest in the beach fringe is not allowed within a minimum 200-

foot buffer beginning at the forested edge above the mean high tide line.

Page 5-9, Proposed Plan: A 10-acre opening in the RMA outside of the Tongass Timber Reform 

Act buffer appears contradictory with desired condition DC-YG-RIP-01, the fish and riparian 

standards and guidelines of Chapter 4, and Appendix D. Given the desired condition in DC-YGRIP-01 is to improve functions for soil, water, fish, wildlife, and other resources, while also 

providing a commercial byproduct, please explain where a 10-acre opening would improve 

conditions and be approved at the project level, especially if there is no requirement to thin the 

RMA following harvest. If the assumption in Alternative 5 is that timber can be harvested in 

such a matter from the RMA, the FEIS should describe instances when a 10-acre opening in the 

RMA could be implemented so that decision makers understand whether or not this wood source 

is a reliable element of the alternative.

Page 5-9, Proposed Plan: Alternatives 2 and 5 allow removing up to 35% basal area of a stand in 

the RMA. Consider adding a standard in the Chapter 5 riparian section to clarify how the 35% 

removal can be distributed across the stand and if harvest can be focused in the RMA. 

Page D-19, Table 8 DEIS: Consider adding a row in the table showing projected young-growth 

acreage suitable for harvest in development LUDs following proposed changes to the scenic 

integrity standards and guidelines and the application of the rules surrounding harvest prior to the 

culmination of mean annual increment. This would provide perspective when evaluating the 

necessity to conduct harvest in environmentally sensitive areas by showing the relative gains in 

available timber from all components of each alternative.

Page 4-10, Section III, Proposed Plan: Add a reference for the 2015 Fish Stream Identification 

and Stream Classification on the Tongass National Forest document and its associated field 

guide, which include results of recent working groups and field verification studies. 

Page 5-7, paragraph 5, Proposed Plan: Consider including prioritization of stewardship fund use 

on the district where they were generated, a process made easier by Public Law 108-148-DEC.

Page D-12, paragraph 3, DEIS: Improve clarity by beginning the first sentence with Of the action 

alternatives. 

Page D-12, paragraph 3, DEIS: Consider revising the statement in the last sentence about effects 

being short-term and localized, which contradicts the statement on page D-11, paragraph 4. 

Page 3-98, Table 3.6-2, DEIS: Suggest changing the title to Commonly targeted sport, 

subsistence, and commercial fish. The existing title is misleading since sport fishing for 

steelhead in the region is primarily catch-and-release.
14

Page 3-104, paragraph 1, DEIS: Specify the harvest type discussed in the second sentence. 

Page 3-108, paragraph 2, DEIS: Angler days (Table 1), recorded in ADF&G’s statewide harvest 

survey data, better represent fishing effort trends than license sales. The data is available at: 

http://www.adfg.alaska.gov/sf/sportfishingsurvey/index.cfm?ADFG=region.home. 

Table 1.–Angler days by water type 

among Southeast Alaska communities, 

1996–2014 

Year Freshwater Saltwater Total

1996 72,459 297,960 370,419

1997 93,478 346,320 439,798

1998 75,445 295,302 370,747

1999 99,054 435,610 534,664

2000 106,355 435,052 541,407

2001 98,093 409,148 507,241

2002 101,563 367,739 469,302

2003 107,755 369,437 477,192

2004 104,166 443,083 547,249

2005 102,200 465,584 567,784

2006 104,834 412,001 516,835

2007 104,431 435,859 540,290

2008 100,094 409,503 509,597

2009 96,343 403,738 500,081

2010 87,279 356,572 443,851

2011 95,332 352,276 447,608

2012 91,009 387,998 479,007

2013 83,871 462,179 546,050

2014 95,068 469,242 564,310
15

Page 3-328, Table 3.15-7, footnote 6, DEIS: Please include the data source for the ADF&G 

ratings.

Page 3-343, Fishing, DEIS: Please provide a citation for the statement 13 percent of inventoried 

recreation places acres are currently important for fishing. 

SUBSISTENCE

Pages 3-97 through 3-101, DEIS: This section includes a general characterization of the 

magnitude of sport and commercial fish harvests from Conrad and Gray (2014). The FEIS 

should include similar information for subsistence harvest presented in Conrad and Gray (2014). 

Page 3-390, first paragraph under abundance and distribution, DEIS: The ADF&G (2014) 

citation is inaccurate. Please cite the 1987 Tongass resource use cooperative survey (TRUCS), 

which provides the only survey data for Tenakee Springs and Skagway. 

Pages 3-533 through 3-635, DEIS: In the subsistence sections of the Elfin Cove, Gustavus, 

Meyer’s Chuck, Metlakatla, Pelican, Port Alexander, Skagway, and Tenakee Springs individual 

community assessments, the 1987 ADF&G harvest data are referenced as distinct from the 

TRUCS data presented in Kruse and Frazier (1988), but the information in both references is 

from the same study. Citations in these sections presenting the data from both publications 

should be reconciled. 

Page 3-508, third paragraph, DEIS: Prince of Wales communities are listed as using a 

combination of hydroelectric and diesel-generated power while the individual community 

summaries indicate power is generated by diesel only. Please clarify.

Pages 3-513 through 3-654, DEIS: Please include a citation for the source of information 

presented in the community use area maps for all communities. If maps are based on the 1987 

TRUCS harvest data, please include an analysis of how uses may have changed in the last 30 

years. 

Pages 3-542 through 3-43 and 3-560 through 3-561, DEIS: The Haines and Hyder individual 

community assessments focus on potential impacts to local resident deer harvests, however, 

moose are more important for these residents, unlike most other southeast communities. Please 

modify the assessments to include the importance of moose in these communities. 

Pages 3-568, 3-599, and 3-653, DEIS: The Kake, Pelican, and Yakutat individual community 

assessments specify several subsistence use areas as most important or very important. Please 

provide a definition for these subjective terms, or eliminate them.
16

Page 3-550, DEIS: Update this section to include recent completion of the Gartina Falls 

Hydroelectric facility in Hoonah.

Page 3-604, DEIS: In the Petersburg Subsistence section, replace land mammals (mostly deer) 

with deer, to be consistent with information for other communities regarding the TRUCS data. 

Page 3-612, first paragraph: Replace Pelican with Port Alexander. 

TRANSPORTATION3

Elimination of the TUS LUD violates USFS planning regulations and NEPA. 

The most significant proposed amendment to the 2008 Tongass Land and Resource Management 

Plan is the elimination of the Transportation and Utility Systems Land Use Designation (TUS 

LUD). Under the current plan, the TUS LUD depicts specific geographic corridors connecting 

the communities located within the boundaries of the Tongass National Forest. These corridors 

are intended to be developed and operated as transportation and utility systems in accordance 

with the State of Alaska’s Southeast Alaska Transportation Plan (SATP). The State of Alaska 

holds transportation and utility easements to develop and operate the public infrastructure 

connecting these communities by way of a reciprocal exchange of easements with the United 

States, which was enacted by Congress in the Section 4407 of SAFETEA-LU (P.L. 109-59), the 

2006 federal transportation bill. In December 2015, Congress passed the latest federal 

transportation bill (FAST Act, P.L. 114-94), which clarified a “perceived defect” in Section 4407 

and expressly granted to the State the transportation and utility easements linking the 

communities of Southeast Alaska. Senate Report 114-80 (July 15, 2015) at pages 23-24. The 

elimination of the TUS LUD, as proposed in the amendments, would remove specific geographic 

management areas from the Forest Plan, which would violate USFS planning regulations and 

would violate the requirements of the National Environmental Policy Act (NEPA). 

Elimination of the TUS LUD requires a plan revision, rather than a plan amendment. 

Under USFS planning regulations, a plan may be amended “to add, modify, or remove one or 

more plan components, or to change how or where one or more plan components apply to all or 

part of the plan area.” 36 CFR § 219.13. The plan components are guides for future project 

activities which include: (i) desired conditions; (ii) objectives; (iii) standards; (iv) guidelines; and 

(v) suitability of lands. 36 CFR § 219.7. Each plan component may apply “to the entire plan 

area, or to specific management or geographic areas.” Id. Thus, a plan amendment may change 

 

3 The State of Alaska primary contact for Proposed Plan and DEIS comments related to transportation is Roger 

Healy of the Alaska Department of Transportation & Public Facilities. Roger can be reached at 

roger.healy@alaska.gov or 907-465-6958.
17

how a geographic area (i.e., a LUD) is managed in the National Forest, but it may not add or 

eliminate a management area or geographic area from the plan.

The designation or elimination of a management area or geographic area from an existing plan 

must be done through a plan revision. 36 CFR § 219.7(c) and (d). The administrative and public 

processes for a plan revision are separate and different from the processes required for a plan 

amendment. 36 CFR §§ 219.7(c) and 219.13(b). The USFS’ attempt to eliminate the TUS LUD 

through a fast-track plan amendment violates the regulatory processes that are designed to ensure 

a reasoned and deliberative consideration of proposed modifications to planning areas or 

geographic areas in forest plans. 36 CFR §§ 219.7(c). As the USFS has not commenced or 

undertaken the required administrative and public processes for the elimination of the TUS LUD, 

the elimination of the LUD would violate the National Forest Management Act and the 

implementing regulations.

Elimination of the TUS LUD requires public notice and compliance with NEPA.

The stated purpose and need for the Proposed Plan amendments is to enable the transition to 

young-growth timber harvest management as directed by the Secretary’s 1044-009 

Memorandum. Elimination of the TUS LUD does not fulfill or further the stated purpose of the 

proposed plan amendments, and the proposed action was not disclosed as a secondary purpose 

for the plan amendment. During the scoping process, the USFS identified four significant issues 

that were to be analyzed in depth as there were “disagreements about the best way to use a 

resource.” DEIS, page 1-9. Those significant issues are: 

 

1. Young Growth Transition; 

2. Renewable Energy;

3. Protection of Roadless Areas; and 

4. Protection of Wildlife Habitat and the Old Growth forest. 

Quite notably, neither the published notice of intent nor the DEIS purpose and need statement 

disclose the intent to eliminate the TUS LUD. The elimination of the existing management 

prescriptions for Southeast Alaska’s transportation and utility corridors is unnecessary and 

counterproductive. If the USFS intends to consider and debate ‘the best way to use’ these 

transportation and utility corridors, the National Environmental Policy Act (NEPA) requires the 

significant federal action be disclosed and fully analyzed prior to implementation.

The Proposed Plan and DEIS grossly underestimate development in the TUS LUD. 

The USFS draws an unsupported conclusion that “[t]here is considerable uncertainty concerning 

the future development of Southeast Alaska’s road system.” DEIS, p. 3-278. This statement is 
18

particularly confusing, as an array of present and reasonably foreseeable transportation projects 

are identified in the cumulative effects analysis. DEIS Appendix C. Just in the category of 

highway development projects: construction of 32.3 miles of highway in the TUS LUD were 

recently completed; 140.6 miles of highway are funded for design and construction; and 15.7 

miles of highway are funded for environmental permitting and design. These multiple highway 

projects are indicative of the State of Alaska’s robust delivery of improved transportation 

infrastructure to Southeast Alaska—there is no uncertainty in these actions.

Development and delivery of transportation projects in the established transportation and utility 

corridors is accomplished, in part, by the stability and predictability of the geographically 

designated TUS LUD. The USFS’ proposed objective to “Cooperate with other agencies in 

developing 35 miles of transportation corridors on NFS lands during the 15 years after plan 

approval [Proposed Plan, 5-14]” appears extremely limited and quite contradictory to the many 

upcoming and reasonably foreseeable highway projects. With nearly 200 miles of state highway 

construction recently completed and planned for the near future—and congressionally granted 

easements underlying hundreds of miles of the TUS LUD—the USFS’s proposed objective does 

not reflect the planned development in the TUS LUD. 

The Proposed Plan could benefit by adding new components in addition to TUS LUD. 

The DEIS expresses a need to support development of renewable energy and perhaps to include 

power transmission corridors in the new Renewable Energy Direction (RE) component. It is 

easy to imagine that renewable energy projects, including support roads and power transmission 

lines, will need to branch from and be located outside the TUS LUD corridors. To ease the 

development of those discrete projects, the RE component and the Transportation Systems 

Corridor Direction (TSC) component may prove workable for the USFS. However, for the 

multiple-agency and multiple-year planning required to connect the communities of Southeast 

Alaska, the State requires that the forest plan recognize the Section 4407 easements and the 

SATP corridors in the existing TUS LUD. The Forest Plan must make the distinction that the 

new RE and TSC components are designed for, and apply to developments outside the TUS 

LUD.

The DEIS and proposed plan amendments explain that the geographically specific TUS LUD is 

being eliminated and replaced with area wide plan components for the new TSC. The purpose of 

the plan direction for TSC is to facilitate the availability of NFS land for the development of 

existing and future transportation systems. However, the rationale for this change is not clear 

nor was it developed as an issue that required addressing. It is unclear how eliminating the TUS 

LUD will better facilitate the availability of NFS land for the development of existing and future 

transportation systems, since the State currently holds easements over the vast majority of the 

TUS LUD. The depiction of the corridors on the TUS LUD maps in the 2008 plan was 
19

informative and consistent with the management direction in the plan concerning the priority of 

TUS development in those corridors. The removal of the TUS LUD corridors from the Proposed 

Plan’s maps is a significant change that does not seem either necessary or productive. Removal 

appears to be counterproductive particularly given that the corridors were incorporated into the 

2008 Forest Plan, but now the same corridors identified in the SATP appear to be only 

referenced as examples of corridors that might be constructed in the national forest. The 

elimination of TUS LUDs eliminates any attempt to recognize and reserve corridors for this 

potential future land use. It removes any current effort to identify the need of specific corridor 

reservations and to inform other current and potential land use of corridor reservations. Removal 

of the TUS LUD will likely have the effect of making NSF land less available, create future use 

conflicts, and deter development of existing and future transportation systems. 

The proposed revision to the plan is confusing in that it repeatedly states that transportation and 

utility systems are not precluded anywhere in the Tongass Nation Forest under the provisions of 

Public Law 109-59 and ANILCA Title XI. That statement masks a great deal of information. 

Section 4407 of Public Law 109-59 granted transportation and utility easements within specific 

corridors that are recognized by the TUS LUD; ANILCA Title XI provides a process wherein a 

transportation and utility easement may or may not be granted. Since the State currently holds 

property rights in the corridors identified in the TUS LUD, the LUD must be preserved. The 

State could pursue infrastructure development outside the TUS LUD, under ANILCA or other 

authorities, but that would be a somewhat unusual or rare occurrence. The new RE and TSC 

components may prove useful in that unusual circumstance; however, for development of 

infrastructure connecting the communities in the Tongass, the State, regulatory agencies, and the 

public require the disclosure and predictable management of the transportation and utility 

corridors in the TUS LUD. 

There is no management advantage by replacing TUS LUD with a new TSC component. 

Under the current plan, the TUS LUD guarantees precedence of transportation and utility 

development goals over the goals and management prescriptions of an underlying LUD crossed 

by the TUS LUD by stating “The Transportation Utility System (TUS) LUD takes precedence 

over any underlying LUD (subject to applicable laws) regardless of whether the underlying LUD 

is a TUS Avoidance LUD or not. As such, it represents “a ‘window’ through the underlying 

LUD through which roads and/or utilities can be built.” This is an ideal LUD to manage a 

property interest and development interest that may not spring to life for years or decades to 

come. The express purpose of the TUS LUD was to minimize potential conflicts with 

underlying LUD goals and associated management prescriptions should transportation 

development occur. The LUD flags in advance specific areas of land use goals conflicting with 

those of future potential transportation and utility development, though the goals objectives and 

management standards and guidelines of the TUS LUD do not spring into existence until 
20

commencement of construction of the transportation or utility facility. The TUS LUD provides 

predictability and transparency. 

The proposed plan amendment is designed to eliminate the TUS LUD and the specific 

geographic corridors where the management prescriptions of the TUS LUD apply. The Proposed 

Plan and the DEIS explain that the TSC components will take precedence over LUD-specific 

standards and guidelines throughout the Tongass National Forest, but those statements give little 

comfort when the specific property and development rights granted by Congress and recognized 

in the TUS LUD are removed from the plan. While the State recognizes that the TSC component 

and the RE component may provide clarity for potential development outside the TUS LUD, all 

but the smallest fraction of infrastructure development in Southeast Alaska will occur within the 

TUS LUD. To provide the predictability and transparency necessary for the continued 

development of the infrastructure connecting the communities of Southeast Alaska, the TUS 

LUD must be preserved. 

General Plan comments by section:

Chapter 1 Introduction

Proposed Plan page 1-5 second to last paragraph states: “The communities of Southeast Alaska 

depend on the Tongass National Forest in various ways, including employment in wood 

products, commercial fishing and fish processing, recreation, tourism, and mining, and mineral 

development.” The paragraph also goes on to explain the importance of subsistence resources; 

however, overlooked is the importance of public access to the forest by all modes including 

maintenance of forest roads. We recommend including in the introduction a sentence describing 

the importance and role of public access and transportation infrastructure. 

Chapter 2 Goals and Objectives 

No mention is made under Forest Desired Conditions of transportation utility system goals and 

objectives. 

Recommend the inclusion statements of desired conditions for development and maintenance of 

regional and area transportation - utility systems:

• Provision and maintenance of air and marine access points and associated infrastructure 

by the Forest Service, including a system of forest trails and road to facilitate access to 

forest areas managed for timber harvest and various multi-uses including recreation, 

subsistence and administration of the forest. 
21

• A State of Alaska maintained multi-modal regional transportation system of airports, 

marine docks and floats, and road system supporting access to and through the National 

Forest providing efficient and essential transportation between communities within the 

forest and between the forest and the rest of the world in support of the area economy. 

Under Forest-wide Multiple-use Goals and Objectives recommend the addition of the above as 

goals under a category referred to as “Access.” Similar access objectives should be listed under 

and in support of the following categories:

• Local and Regional Economies 

• Minerals and Geology 

• Recreation and Tourism 

• Renewable Energy 

• Subsistence and 

• Timber

Recommend redefining “Transportation” as a category supporting the following Goal: 

• Development and operation of transportation and utility infrastructure within the 

“Transportation Utility System” corridors linking the communities of Southeast Alaska as 

provided by Section 4407 of P.L. 109-59, as amended by P.L. 114-94, and as allowable 

under ANILCA Title XI.

Chapter 3 Management Prescriptions

Do not replace the overlay Transportation Utility System (TUS) overlay Land Use Designations 

(LUD) as described in the 2008 Forest Plan. Retention of the TUS LUD is needed to physically 

locate TUS corridors established by law, replete with goals and management prescriptions 

having precedence over the underlying LUDs. 

LUD Management Prescriptions:

ADD TUS LUD overlay LEVEL ONE precedence to other LUDs in the following 

categories:

SPECIAL INTEREST AREA LUD under TRANSPORTATION, Transportation Operations, 

TRAN, add: 
22

B. Coordinate interpretation of the unique values of the Special Interest Area with management 

of transportation infrastructure in TUS LUD corridors and the rights-of-way of other publiclyowned roadways.

REMOTE RECREATION LUD under TRANSPORTATION, Transportation Operations, 

TRAN, add: 

A. (revise) New roads are not permitted, except within a TUS LUD and to access authorized 

mineral operations (or as excepted under Lands). 

MUNICIPAL WATERSHED LUD under TRANSPORTATION, Transportation Operations, 

TRAN, add: 

A. (revise last sentence) New road construction is generally inconsistent with Old-growth 

Habitat LUD objectives, but new roads may be constructed if within a TUS LUD. Forest roads 

may occur in this area with due consideration for protection of the watershed. 

OLD-GROWTH HABITAT LUD under TRANSPORTATION, Transportation Operations, 

TRAN, add: 

A. (revise) New road construction is generally inconsistent with Old-growth Habitat LUD 

objectives, but new roads may be constructed if within a TUS LUD, or if a forest road 

with no feasible alternative. 

B. Add: 4. Roads under the jurisdiction of the Alaska Department of Transportation and 

Public Facilities shall be managed in accordance with the State of Alaska’s best 

management practices. 

SEMI-REMOTE RECREATION LUD under TRANSPORTATION, Transportation 

Operations, TRAN, add: 

A. (revise) Where Semi-Primitive Motorized recreation opportunities are emphasized, 

existing low standard roads are generally managed for use by high clearance or OHVs, 

snowmobiles, or motorcycles subject to an approved Access and Travel Management Plan. 

Generally, new roads are not constructed in this area, except within a TUS LUD and to link 

existing roads or provide access to adjacent LUDs. 

Add : 4. Roads under the jurisdiction of the Alaska Department of Transportation and Public 

Facilities shall be managed in accordance with the State of Alaska’s best management practices. 

LUD II Page 3-68 under Objectives add bullet: Roads and utility lines are allowed within a TUS 

LUD. 
23

Page 3-72 under Transportation Operations: TRAN: add 3. Roads and utility lines allowed within 

a TUS LUD. Roads under the jurisdiction of the Alaska Department of Transportation and 

Public Facilities shall be managed in accordance with the State of Alaska’s best management 

practices.

WILD RIVER LUD page 3-74 add under Objectives: Permit road and utility lines allowed 

within a TUS LUD. 

Under TRANSPORTATION, Transportation Operations, TRAN, add: 

Page 3-80 (add) D. Roads and utility lines allowed within a TUS LUD. Roads under the 

jurisdiction of the Alaska Department of Transportation and Public Facilities shall be managed 

in accordance with the State of Alaska’s best management practices.

SCENIC RIVER LUD page 3-87 TRANSPORTATION, Transportation Operations: TRAN 

Add: 5. Roads and utility lines allowed within a TUS LUD. Roads under the jurisdiction of the 

Alaska Department of Transportation and Public Facilities shall be managed in accordance with 

the State of Alaska’s best management practices.

RECREATIONAL RIVER LUD page 3-87 TRANSPORTATION, Transportation Operations: 

TRAN 

Page 3-94 add: 3. Roads and utility lines allowed under a TUS LUD. Roads under the 

jurisdiction of the Alaska Department of Transportation and Public Facilities shall be managed 

in accordance with the State of Alaska’s best management practices. 

EXPERIMENTAL FOREST LUD page 3-100 TRANSPORTATION, Transportation 

Operations: TRAN 

Add: C. Roads and utility lines allowed within a TUS LUD. Roads under the jurisdiction of the 

Alaska Department of Transportation and Public Facilities shall be managed in accordance with 

the State of Alaska’s best management practices. 

SCENIC VIEWSHED LUD 

Add under Objectives page 3-101: Roads and utility lines are allowed under a TUS LUD. 

TRANSPORTATION, Transportation operations: TRAN, page 3-108 
24

Add: 6. Roads and utility lines allowed within a TUS LUD. Roads under the jurisdiction of the 

Alaska Department of Transportation and Public Facilities shall be managed in accordance with 

the State of Alaska’s best management practices. 

MODIFIED LANDSCAPE LUD page 3-109 add under Objectives: Roads and utility lines 

allowed within a TUS LUD. 

Under TRANSPORTATION, Transportation Operations, TRAN, add: 

Page 3-115 (add) 6. Roads and utility lines allowed within a TUS LUD. Roads under the 

jurisdiction of the Alaska Department of Transportation and Public Facilities shall be managed 

in accordance with the State of Alaska’s best management practices.

TIMBER PRODUCTION LUD page 3-116 add under Objectives: Roads and utility lines 

allowed within a TUS LUD. 

Under TRANSPORTATION, Transportation Operations, TRAN, add: 

Page 3-122 (add) 5. Roads and utility lines allowed within a TUS LUD. Roads under the 

jurisdiction of the Alaska Department of Transportation and Public Facilities shall be managed 

in accordance with the State of Alaska’s best management practices. 

MINERALS LUD page 3-123 add under Objectives: Roads and utility lines allowed within a 

TUS LUD.

Under TRANSPORTATION, Transportation Operations, TRAN, add: 

Page 3-128 (add) E. Roads and utility lines allowed within a TUS LUD. Roads under the 

jurisdiction of the Alaska Department of Transportation and Public Facilities shall be managed 

in accordance with the State of Alaska’s best management practices.

Chapter 4 Standards and Guidelines

Reinstate standards and guidelines for the overlay Transportation Utility System (TUS) Land 

Use Designations (LUD) as described in the 2008 Forest Plan with corridor goals and 

management prescriptions having precedence over the underlying LUDs. 

Chapter 5 Plan Content Developed Under the 2012 Planning rule
25

Revise the Transportation System Corridor (TSC) to apply solely to development and 

maintenance of forest roads located outside of the TUS LUD corridors or under the jurisdiction 

of the U.S. Forest Service.

Chapter 6 Implementation 

No comments. 

Appendices A – K 

No appendix on transportation was developed or included. With a proposed major revision, such 

as the elimination of LUD, it would be helpful to review the analysis and decision-making that 

supports the major federal action. 

ALASKA NATIONAL INTEREST LANDS CONSERVATION ACT4

Wild and Scenic River Management

ANILCA amended the Wild and Scenic Rivers Act and designated 26 Wild and Scenic Rivers 

and an additional 12 rivers designated for study. There are currently no designated rivers on the 

Tongass National Forest, and pursuant to ANILCA Section 1326(b)5

, Congress has since 

provided no further direction to the Forest Service to conduct additional Wild and Scenic River 

studies in Alaska.

We appreciate the proposed plan does not include new wilderness and wild and scenic river 

reviews or recommendations. However, we remain concerned that, despite explicit direction in 

ANILCA Section 1326(b) to not conduct such studies, the USFS continues to manage the 32 

rivers recommended in the 1997 Forest Plan Record of Decision to maintain their eligibility for 

designation at some distant future date as wild and scenic rivers. 

The plan indicates such management will continue until Congress takes action; however, the plan 

does not disclose any details on how or when the recommendations were submitted to Congress 

and what occurred subsequent to the submittal. We do not support protective management for 

recommended rivers that resulted from a study conducted in violation of ANILCA, nor do we 

 

4 The State of Alaska point of contact for ANILCA comments on the Proposed Plan and DEIS is Sue Magee with 

DNR’s Office of Project Coordination and Permitting. She can be reached at susan.magee@alaska.gov or 907-269-

7529.

5 ANILCA Section 1326(b) No further studies of Federal lands in the State of Alaska for the single purpose of 

considering the establishment of a conservation system unit, national recreation area, national conservation area, or 

for related or similar purposes shall be conducted unless authorized by this Act or further Act of Congress. 

(Emphasis added)
26

support applying management prescriptions on that basis indefinitely. We therefore request the 

corresponding Wild, Scenic and Recreational LUDs either be removed from the plan or only 

applied after a river is designated by Congress. Further, we request the plan include specific 

information about the recommendations’ submittal to Congress and any subsequent actions taken 

by Congress in response. 

ANILCA Section 810 Analysis 

The DEIS states that an 810 evaluation and determination is not required because this is a 

programmatic amendment. However, the DEIS not only evaluates the impacts to subsistence, 

citing a “significant possibility of a significant restriction, resulting from a change in 

competition” (p. 3-394), the Service is also holding subsistence hearings. For clarity and 

compliance with ANILCA, we recommend the Service include a full 810 evaluation in the plan. 

We note the information is largely already contained in the DEIS.

Page-specific Comments

Page 3-10, Proposed Plan: We support the proposed decision to reference Title XI of the Alaska 

National Interest Lands Conservation Act (ANILCA) in the Wilderness LUD Standards and 

Guidelines. This change will ensure that the full context and process required in ANILCA is 

considered and followed when transportation and utility projects are proposed within 

conservation system units designated by ANILCA on the Tongass National Forest (i.e. 

designated Wilderness).

Page 3-26, Chapter 3, Proposed Plan, Transportation, Transportation Operations: TRAN (D). We 

request the plan retain “adequate and feasible access for economic and other purposes” as it is 

the correct standard used for inholdings “effectively surrounded” by conservation system units 

(i.e. designated wilderness) in ANILCA section 1110(b). “Reasonable access” is the standard in 

ANILCA section 1323, which applies to general national forest lands, not designated wilderness. 

Page 3-107, Proposed Plan: We do not support this management prescription, which would 

recommend FERC not authorize hydroelectric facilities on rivers found eligible and suitable for 

inclusion in the Wild and Scenic River System in the 1997 Tongass Land Management Plan. 

This comment also applies to other management prescriptions found elsewhere in the plan that 

rely on the 1997 wild and scenic river recommendations as their basis. See above general 

comment on wild and scenic rivers. 

Page 4-10, Chapter 4, Proposed Plan: Fish Habitat Planning, Fish Habitat and Channel 

Processes, part 3: ANILCA section 1326(b) expressly prohibits further studies for the single 

purpose of considering the establishment of a conservation system unit, which includes Wild and 
27

Scenic Rivers, unless authorized by ANILCA or a further act of Congress. Consideration of new 

wilderness or wild and scenic rivers in this context is inappropriate and we request the following 

revision:

Consider topics such as erosion processes, watershed hydrology, vegetation, stream 

channel morphology, water quality, wilderness designation, recommendations for 

inclusion into the Wild and Scenic River System, species and habitats, and human uses, 

during analyses. 

Page 4-31, Proposed Plan: III. Temporary Facilities. ANILCA section 1316 applies to all federal 

public lands where the taking of fish and wildlife is authorized but it does not differentiate 

between subsistence and non-subsistence use. We request the Service consider whether the 

distinction in this section is necessary or appropriate.

Page 4-44, Proposed Plan: Chapter 4 Recreation Resource Planning: The following guideline 

appears to be relevant to ensuring safe access to communities and popular recreation areas. It is 

unclear why it is being removed. We request the Service re-consider and provide rationale if it is 

not retained in the final plan. 

Support a system of anchorages suitable for recreation boats along small boat waterways 

that connect communities or provide access to popular recreation attractions. 

Page 3-382, third paragraph, DEIS: We request the following edit for clarity and consistency 

with ANILCA sections 802 and 804: 

It also states, in part, that “customary and traditional” subsistence uses of renewable 

resources “shall be the priority consumptive uses of all such resources on the public 

lands of Alaska when it is necessary to restrict take.” 

Page 3-382, fourth paragraph, DEIS: We request the following edit for accuracy: 

This ruling took the state out of compliance with ANILCA and the federal government has 

managed harvest of subsistence resource s under federal subsistence regulations on 

federal lands in Alaska since 1990. As a result, federal subsistence harvests of fish and 

wildlife on the Tongass National Forest are presently managed by the Forest Service 

(Schroeder and Mazza 2005).
28

ENVIRONMENTAL CONSERVATION6

The Alaska Department of Environmental Conservation (ADEC) provided the following 

comments on the DEIS. 

Page 3-16, paragraph three, sentence one, should read: “The State of Alaska Department of 

Environmental Conservation (ADEC) under the Clean Air Act (CAA), via Title I and Title 5 of 

the EPA approved State Implementation Plan (SIP) regulates air emissions from stationary 

sources.” 

Page 3-18, paragraph three, sentence seven, notes that “ In an effort to better address the air 

quality concerns in the Wilderness, the Forest Service and ADEC enters into a Memorandum of 

Understanding each year to train Forest Service wilderness rangers to visually monitor cruise 

ship emissions with EPA-approved standards.” This sentence should be updated to reflect that 

the MOU is static and does not get entered into each year.

Page 3-19 paragraph one, sentence three, should read: “EPA and ADEC have limited regulatory 

responsibility, under the Clean Air Act, for air quality related to these kind of sources.” This 

sentence was discussing indirect sources such as firewood burning and vehicle emissions. 

Page 3-22, paragraph two, sentence five refers to “shrinking alpine habitats”. This may need to 

be reexamined and perhaps changed to read “changing alpine habitats” to reflect the fact that 

glacier melting may expose new alpine habitat at a quicker rate than those of altitudinal forest 

shifts.

Page 3-56, paragraph three, sentence two should read: “Turbidity criteria indicate values will not 

exceed 5 nephelometric turbidity unites (NTUs) over natural conditions, when natural values are 

less than 50 NTUs.” The original text used the word “nature”. 

Page 3-68, paragraph five, sentence two should read: “Landslide debris (e.g., sediment, large 

wood) that enters the stream may block or shift channels, fill pools, and increase the presence of 

fine sediments in the channel network.” The original text used the words “increases fines 

presences” which is grammatically cumbersome.

Appendix G, page G-11, M4(c) should be revised to read “Measurements required by M4; a and 

b are from MHW (Mean High Water) to depths of 100 feet MLLW (Mean Lower Low Water).” 

 

6 The State of Alaska’s primary contact for DEIS comments related to environmental conservation is Gary Mendivil 

of the Alaska Department of Environmental Conservation. He can be reached at gary.mendivil@alaska.gov or 907-

465-5061.
29

MISCELLANEOUS EDITS

Typos 

• Draft EIS, Page A-1: An incorrect date of “June 23, 2016” is given for publishing the 

corrected Notice of Intent.

• Draft EIS, Page B-18: “Intermeidate” is misspelled.

ATTACHMENT

The Working Forest Group (TWFG) report, Strategies to Maintain a Viable Timber Industry in 

Southeast Alaska, 2015.

REFERENCES

Alaska Department of Fish and Game. 2015. Alaska’s wildlife action plan, draft for public and 

agency review, 8-1-2015. Division of Wildlife Conservation, Juneau. 

Conrad, S., and D. Gray. 2014. Overview of the 2013 southeast Alaska and Yakutat commercial, 

personal use, and subsistence salmon fisheries. Alaska Department of Fish and Game, 

Fishery Management Report No. 14-28, Juneau. 

Dawson, N. D. 2008. Vista Norteña: Tracking historical diversification and contemporary 

structure in high latitude mesocarnivores. Doctoral dissertation, University of New 

Mexico, Albuquerque. 

Kendall, N. W., J. R. McMillan, M. R. Sloat, T. W. Buehrens, T. P. Quinn, G. R. Pess, K. V. 

Kuzishchin, M. M. McClure, and R. W. Zabel. 2015. Anadromy and residency in 

steelhead and rainbow trout Oncorhynchus mykiss: a review of the processes and 

patterns. Canadian Journal of Fisheries and Aquatic Sciences 72: 319-342. 

MacDonald, S. O. and J. A. Cook. 2008. The mammals and amphibians of Southeast Alaska. 

Museum of Southwestern Biology, Special Publication 8:1-191. 

Pearse D. E., S. A. Hayes, M. H. Bond, C. V. Hanson, E. C. Anderson, R. B. MacFarlane, J. C. 

Garza. 2009. Over the falls? Rapid evolution of ecotypic differentiation in 

steelhead/rainbow trout (Oncorhynchus mykiss). Journal of Heredity 100: 515-525. 

Sloat, M. R., and G. H. Reeves. 2014a. Demographic and phenotypic responses of juvenile 

steelhead trout to variation in the spatial predictability of food resources. Ecology 95: 

2423-2433. 
30

Sloat, M. R., and G. H. Reeves. 2014b. Individual condition, standard metabolic rate, and rearing 

temperature influence steelhead and rainbow trout (Oncorhynchus mykiss) life histories.

Canadian Journal of Fisheries and Aquatic Sciences 71: 491–501. 
Strategies to Maintain a Viable Timber Industry

 in Southeast Alaska

January 2015

Prepared for: 

USDA, Forest Service, Alaska Region

Under Challenge Cost-Share Agreement (14-CS-11100500-020) 
TABLE OF CONTENTS 

EXECUTIVE SUMMARY................................................................................................................................... 4

INTRODUCTION............................................................................................................................................. 5

Background....................................................................................................................................................................... 5

Report Objective .............................................................................................................................................................. 5

REPORT DATA COLLECTION / WORK SESSION / INTERVIEWS........................................................................ 5

Objective........................................................................................................................................................................... 5

Survey Planning and Methodology ................................................................................................................................. 6

Survey Implementation Issues and Revised Project Scope............................................................................................ 7

Revised Project Implementation..................................................................................................................................... 7

Results............................................................................................................................................................................... 7

Survey Responses............................................................................................................................................................................. 8

SOUTHEAST ALASKA’S FUTURE TIMBER INDUSTRY .....................................................................................12

Future Industry Concept #1........................................................................................................................................... 13

Basis for Concept #1 ...................................................................................................................................................................... 13

Recommendations ......................................................................................................................................................................... 13

Future Industry Concept #2........................................................................................................................................... 16

Basis for Concept #2 ...................................................................................................................................................................... 16

Recommendations ......................................................................................................................................................................... 16

 Short-Term (Present Day to Five Years)............................................................................................................................... 16

 Mid-Term (Six Years to Fifteen Years).................................................................................................................................. 19

 Long-Term (Beyond Fifteen Years)....................................................................................................................................... 21

APPENDICES ................................................................................................................................................22

APPENDIX A: SECRETARY’S TRANSITION MEMORANDUM JULY 2, 2013 ................................................................... 23

APPENDIX B: SAMPLE SURVEY...................................................................................................................................... 27

APPENDIX C: INTIAL BUSINESS CONTACTS – JULY 2014 ............................................................................................. 30

APPENDIX D: U.S. FOREST SERVICE SOUTHEAST ALASKA SPECIES SUMMARY REPORTS .......................................... 31

APPENDIX E: TONGASS TIMBER REFORM ACT (TTRA), SECTION 101......................................................................... 75

APPENDIX F: ANILCA SECTION 705(a) ........................................................................................................................... 76

APPENDIX G: INFRASTRUCTURE NEEDS MAPS ............................................................................................................. 77

Map 1. Revillagigedo Island .......................................................................................................................................................... 77

Map 2. Prince of Wales Island - Trocadero Bay........................................................................................................................... 78

Map 3. Prince of Wales of Island – Cabin Creek.......................................................................................................................... 79

Map 4. Prince of Wales of Island – Sandy Point.......................................................................................................................... 80

Map 5. Prince of Wales of Island – Dolomi Bay........................................................................................................................... 81

Map 6. Prince of Wales of Island – West Arm of Cholmondeley Sound..................................................................................... 82

Strategies to Maintain a Viable Timber Industry in Southeast Alaska (14-CS-11100500-020) 2 of 97| Page
Map 7. Wrangell Island ................................................................................................................................................................ 83

Map 8. Mitkof Island..................................................................................................................................................................... 84

Map 9. Kupreanof Island .............................................................................................................................................................. 85

Map 10. Kuiu Island ...................................................................................................................................................................... 86

Map 11. Chichagof Island............................................................................................................................................................. 87

Map 12. Baranof Island ................................................................................................................................................................ 88

APPENDIX H: ALASKA TIMBER JOBS TASK FORCE (SHORT REPORT) – JULY 2012...................................................... 89

WORKS CITED..............................................................................................................................................97

In accordance with Federal law and U.S. Department of Agriculture policy, this institution is prohibited from discriminating on 

the basis of race, color, national origin, sex, age, or disability. (Not all prohibited bases apply to all programs.)

Strategies to Maintain a Viable Timber Industry in Southeast Alaska (14-CS-11100500-020) 3 of 97| Page
EXECUTIVE SUMMARY 

The purpose of this Challenge Cost-Share Agreement was for The Working Forest Group (TWFG) to 

facilitate an analysis that defined where and what types of investments should be made in retooling the 

existing old growth timber industry into one that is dependent on young growth timber supply from 

Southeast Alaska considering all lands as sources. 

Originally, the project scope called for facilitation of a 2-day work session to collect the information from

15 knowledgeable individuals from various Southeast Alaska timber industry segments 

(manufacturing/processing, harvesting, land owner/operator, logistics, road building, consulting, and 

other). After several attempts to reach a cross-section of the industry by telephone and email, several 

respondents emphasized a frustration with the process. The current industry has been involved in 

discussions for several years and have not seen their primary concern for timber supply being 

addressed. This non-participation led to a request that the project scope be adjusted from a two-day 

work session to on-site discussions with industry at their various mill sites. The U.S. Forest Service 

agreed to amend the scope and on-site interviews were conducted in November 2014.

The common message TWFG heard from those interviewed was that the timber industry in Southeast 

Alaska will cease to exist unless there is old growth timber made available while the young growth 

matures and/or a market for Alaska’s young growth is developed.

Therefore, based on the information provided on the surveys and during the interview process along 

with The Working Forest Group’s knowledge of the timber industry, TWFG would like to propose two 

potential future industry concepts: 

• Future Industry Concept #1: The creation of a viable timber Industry in Southeast Alaska that is 

dependent on young growth fiber, can only be achieved by extending the rotation length until 

young growth trees develop old growth characteristics. Old growth harvest on the Tongass 

National Forest must continue for the foreseeable future.

• Future Industry Concept #2: The creation of a viable timber Industry in Southeast Alaska that is 

dependent on young growth fiber, which maintains the existing industry while ceasing the 

harvest of old growth timber stands on the Tongass National Forest within five (5) years.

 With the cornerstones for future forest management in Southeast Alaska being based on:

• Active Forest Management by use of the abundant forest resources of the region, 

• Making Southeast Alaska investment friendly to future timber industry investors, 

• Developing an all Landowners (public and private) Management Strategy based on the Working 

Circle concept; and

• Using Timber Management to develop methods to resolve the regional issues of: 

 Transportation

 Renewable Energy

 Solid Waste

 Employment – development and retention of tomorrow’s workforce

Strategies to Maintain a Viable Timber Industry in Southeast Alaska (14-CS-11100500-020) 4 of 97| Page
INTRODUCTION 

Background

At the request of the U.S. Department of Agriculture, Forest Service, Alaska Region (USFS), The Working 

Forest Group (TWFG) was granted funds under a Challenge Cost-Share Agreement (14-CS-11100500-

020) to complete an analysis that defines where and what types of investments should be made in 

retooling the exiting old growth timber industry into one that is dependent on young growth supply 

from Southeast Alaska considering all lands as sources. 

The United States Department of Agriculture, Office of the Secretary issued Secretary’s Memorandum 

1044-009 – Addressing Sustainable Forestry in Southeast Alaska on July 2, 2013 (Appendix A) stating that 

the USDA Forest Service must speed the transition away from old growth timber harvesting, towards a 

forest industry that utilizes young growth and calling for additional research to develop effective ways to 

meet the challenges of the transition over the next 10-15 years. Hence, the support for this report.

This analysis was to be conducted by facilitating a 2-day work session with 15 individuals, who were 

chosen from surveys created and distributed by The Working Forest Group (TWFG), based on the 

respondent’s interest in attending the work session and their knowledge of the Southeast Alaska timber 

industry. However, the original project scope was modified from facilitating a 2-day work session to 

one-on-one meetings to better fit the industry’s work season.

Report Objective

The objective of this report is to deliver the following timeframe information for a transition from old 

growth to young growth: 

 

 Short-Term (Present Day to Five Years)

 Mid-Term (Six Year to Fifteen Years)

 Long-Term (Beyond Fifteen Years)

REPORT DATA COLLECTION / WORK SESSION / INTERVIEWS 

Objective

In order to gain insight into where and what types of investments should made in retooling the existing 

old growth timber industry into one that is dependent on young-growth, the original project scope was 

to select and recruit 15 representatives from the forest industry and forest land owners within 

Southeast Alaska to attend a two-day work session in Ketchikan.

Strategies to Maintain a Viable Timber Industry in Southeast Alaska (14-CS-11100500-020) 5 of 97| Page
Survey Planning and Methodology

The process was to:

1. Build a list of potential participants

2. Construct a short survey (Appendix B) to compile preparatory information to schedule a two-day 

work session and assess participation level interest 

3. Distribute survey and response through The Working Forest Group via web, email, and mail

4. Retrieve, compile, and summarize data

5. Select and invite participants to a two-day work session

6. Conduct work session

7. Compile information from all data received and build a report

8. Deliver the draft and review with client

9. Deliver final report and recommendations

The data collection of the project started in April 2014 with the development of The Working Forest 

Group website (www.akworkingforest.org) in order to distribute, collect and compile the survey 

information. Concurrently, a list of 100 potential participants was built with the help of the State of 

Alaska Department of Commerce and Economic Development, the Division of Forestry, other forest 

industry contacts, and by searching the State of Alaska business license database. 

A short, but concise survey was developed (Appendix B) asking questions such as: contact information,

the respondents industry, number of years involved in the business, number of employees, and their 

business plan for the next ten years. Additional questions asked their views on: 1) what would make a 

viable forest products industry in Southeast Alaska; 2) did they think the government (federal, state, 

local) should make investments to advance the transition to young growth and if so, what area (multiple 

choice); 3) volume of economically viable young growth manufacturing/processing opportunities they 

saw (multiple choice); 4) activities/components they considered essential for an integrated young 

growth forest products industry (multiple choice); 5) could their business operate exclusively from a 

young growth resource today (yes/no), and if not, what changes would need to be made to their 

business (multiple choice); and 6) landowners were asked if they were committed to keeping their 

entire managed forest land base in production for the next rotation or harvest (yes/no) and if not, why. 

The survey concluded with questions related to the proposed 2-day work session - if they were 

interested in participating, and if so what dates and would they need financial assistance to attend. 

Initial contact was made with 47 businesses and individuals (Appendix C) with ties to the Southeast 

Alaska forest products industry via email on July 10, 2014. The email included an introduction to the 

project, the proposed 2-day work session, and The Working Forest Group (TWFG). The ten question 

survey was attached as a fillable PDF form, but a direct link was given to where the survey could be 

taken online and submitted as well as instructions on how to fill the survey out offline and then be able 

to mail, fax, or email. The email was then followed-up by phone calls the week of July 14, 2014 with the 

addition of another seven to ten contacts who did not have email addresses.

Strategies to Maintain a Viable Timber Industry in Southeast Alaska (14-CS-11100500-020) 6 of 97| Page
From this initial outreach only eight accepted the invitation to complete the survey. The method above 

was repeated on July 31, 2014 with three additional surveys completed. Survey responses can be found 

in the Results section below. 

Survey Implementation Issues and Revised Project Scope

Out of the eleven responses received, only five showed interested in attending a 2-day work session. 

Feedback received outside the survey responses were: 1) it was the wrong time of year to try and hold a 

2-day work session due to the industry’s work season and 2) the current industry has been involved in 

discussions for several years and have not seen their primary concern for timber supply being addressed

and did not see the value in participating in another work session. 

In early September 2014 TWFG pulled together a list of 15 potential work session attendees based on 

their forest industry affiliation and industry knowledge, including those who showed interest from the 

survey. An invitation was sent to the work session invitees on September 17, 2014 with only one 

individual accepting the invitation. 

Revised Project Implementation

Therefore, TWFG decided that the 2-day work session was not the most productive way to collect the 

information and revised the project scope by trying to schedule and meet people individually during the 

Alaska Forest Association’s 57th Annual Convention in Anchorage (October 22-24, 2014), at the Forest 

Products Task Force meeting in Klawock (November 17, 2014), and by on-site visits (Prince of Wales 

Island and Ketchikan, November 16-19, 2014) instead of facilitating a formal 2-day meeting. 

From October 22-November 19, 2014 TWFG spoke personally to 18 individuals tied to the Southeast 

Alaska timber industry (land owner-2; timber consulting-2; manufacturing/processing-9; harvesting-3; 

other-2.)

Results

The purpose of the one-on-one meetings was to collect each person’s thoughts on how and what they 

saw was needed in order to transition from an old growth industry to a young growth industry. The 

common message that TWFG heard from respondents (17 out of 18) was: 

• the current young growth timber is too young to be economically harvested and there is no 

current product/market for the timber; and

• if there is not some volume of old growth made available while the young growth matures, they 

will no longer be in business.

Only one manufacturer saw a potential for young growth and that potential was in a pellet/chip

manufacturing facility. 

Strategies to Maintain a Viable Timber Industry in Southeast Alaska (14-CS-11100500-020) 7 of 97| Page
Survey Responses

Survey Responses – Page 1 of 3

Continued

Strategies to Maintain a Viable Timber Industry in Southeast Alaska (14-CS-11100500-020) 8 of 97| Page
Survey Responses – Page 2 of 3

Continued

Strategies to Maintain a Viable Timber Industry in Southeast Alaska (14-CS-11100500-020) 9 of 97| Page
Survey Responses – Page 3 of 3

Strategies to Maintain a Viable Timber Industry in Southeast Alaska (14-CS-11100500-020) 10 of 97| Page
Other comments heard from in-person interviews were:

• The current young growth needs 180+ years of growth to be viable. 

• Still need 75-120 MMBF of old growth in order to stay in business while current young growth 

matures. 

• Old growth products is Alaska’s only viable timber market at this time because there is no other 

old growth supplier. 

• Alaska’s young growth cannot compete in the market because of high shipping costs to Seattle. 

• Pulp mills could/would be the biggest consumer of Alaska’s current young growth, however no 

more pulp mills in Alaska.

• There is potential for a whole log, young growth export to Asia, but not dimensional lumber. 

This does not help current small operators since most focus on dimensional lumber and old 

growth specialty products – this does not allow the industry to grow.

• Currently, there isn’t enough infrastructure by the way of trucks to haul logs or cheap power to 

transition to a large enough young growth industry to be sustainable.

• Alaska’s young growth cannot compete with Washington. 

• A 10% profit will not bring investors to Alaska. 

• Alaska has the best old growth hemlock, vertical grain wood in the world that is used for doors, 

windows, and molding. Young growth does not act the same, it’s too crooked.

• Initially Alaska’s old growth cedar did not fit in the market, but now it’s in demand for high end 

garage doors, entry doors, decks, and stairs and goes for a premium price. Young growth cedar 

is for lower end commodities such as fencing because it’s crooked and splits easily.

• The only other comparable cedar on the market as compared to Alaska’s old growth cedar is 

British Columbia cedar.

• Alaska’s old growth spruce is a wanted commodity in Japan, Indonesia, and China (70%) and the 

other 30% goes to Tacoma for Steinway pianos in New York and Germany.

• In order to keep a timber industry in Alaska there needs to be a mix of old growth timber 

(spruce, hemlock and cedar) made available as the young growth matures and/or a market for 

young growth is developed.

The straightforward message TWFG heard from those interviewed was that there will be no timber 

industry in Southeast Alaska unless the majority of the timber offered is old growth, while the young 

growth matures and/or a market for Alaska’s young growth is developed.

Based on the information provided during the interview process and with The Working Forest Group’s 

working knowledge of the timber industry TWFG would like to propose two potential future industry 

concepts, both with recommendations and the Future Industry Concept #2 broken into three (3) 

timeframe analyses: 1) Short-term defined as present day to five (5) years out; 2) Mid-term defined as 

year six (6) to fifteen (15) years out; and 3) Long-term as defined beyond fifteen (15) years out.

Strategies to Maintain a Viable Timber Industry in Southeast Alaska (14-CS-11100500-020) 11 of 97| Page
SOUTHEAST ALASKA’S FUTURE TIMBER INDUSTRY 

The cornerstones for future forest management in Southeast Alaska will need to be based on:

• Active Forest Management by use of the abundant forest resources of the region, 

• Making Southeast Alaska investment friendly to future timber industry investors, 

• Developing an all Landowners (public and private) Management Strategy based on the Working 

Circle Concept; and

• Using Timber Management to develop methods to resolve the regional issues of: 

 Transportation

 Renewable Energy

 Solid Waste

 Employment – development and retention of tomorrow’s workforce

Infrastructure Needs maps have been created for 12 regions as seen below in the index of maps. Each 

map can be found in Appendix G and will be referenced in the Future Industry Concept #1 and #2

sections. 

Map Developed by Alaska Mental Health Trust Land Office

Strategies to Maintain a Viable Timber Industry in Southeast Alaska (14-CS-11100500-020) 12 of 97| Page
Future Industry Concept #1

Creation of a viable timber Industry in Southeast Alaska, dependent on young growth fiber, can only be 

achieved by extending the rotation length until young growth trees develop old growth characteristics. 

Old growth harvest on the Tongass National Forest must continue for the foreseeable future.

Basis for Concept #1

The existing timber industry in Southeast Alaska, both exporters and manufacturers, believe that the 

harvest of old growth timber must occur in order to maintain a viable industry into the future. The only 

Southeast Alaska landowner currently able to provide sufficient quantities of old growth to maintain a 

viable industry is the U.S. Forest Service.

Exporters and manufacturers differ regarding the management of young growth stands. Round log

exporters maintain that young growth can and should be included in the current Tongass Timber 

Program and are considered that young growth trees may reach a diameter size that makes them 

undesirable on the international market.

Manufacturers believe that all young growth stands should be allowed to grow over an extended 

rotation period, usually estimated to be between 200-250 years until the trees develop sufficient fiber 

containing old growth characteristics that such fiber meets niche market requirements. For a current 

young growth stand to have enough time to grow shop grade or better wood requires the continued 

cutting of old growth for at least another 150 years.

There is limited demand for Sitka spruce as a species to be manufactured into dimensional lumber.

Current dimensional lumber producers/marketers include small percentages of Sitka spruce into lumber 

orders as “other species” or incidental and limited to no more than 5% of the volume. Hemlock, pine 

and fir are the most common species used on the West Coast for dimensional lumber. Existing 

manufacturers are not optimistic about being able to integrate large volumes of Sitka spruce into 

current markets. Based on the Species Summary Report provided by the USFS (Appendix D) older stands 

(45-65 years of age) of young growth on the Tongass National Forest are predominately hemlock by the 

number of stems per acre, but volume per acre is dominated by Sitka spruce. It is not uncommon to 

have spruce make up two thirds of the volume in a stand. 

Recommendations

1. To maintain an old growth industry for a minimum of 150 years from today, the U.S. Forest 

Service needs to develop a timber sale program that will provide on an annual basis, a minimum 

sufficient volume to meet the statutory requirements of Tongass Timber Reform Act (TTRA) Sec. 

101 (Appendix E) and ANILCA Section 705(a) (Appendix F); that “the Secretary shall” provide a 

supply of timber from the Tongass National Forest which meets the annual market demand and 

the market demand for each planning cycle. 

Strategies to Maintain a Viable Timber Industry in Southeast Alaska (14-CS-11100500-020) 13 of 97| Page
2. Current and future forest plans development land use designations must provide sufficient acres 

of forested lands to meet the supply demand of ANILCA and TTRA (Recommendation 1) while, 

“providing for the multiple use and sustained yield of all renewable resources” (TTRA Sec. 101).

3. The Tongass Exemption to the Roadless Rule must be re-instated.

4. Develop long term “Agreements” between Federal, State and Private Landowners addressing:

a) Access and Road Use – This agreement should provide all landowners the ability to use 

each other’s infrastructure at no cost to the non-landowner. Such an agreement should 

include a project specific use agreement that can be implemented quickly under the 

umbrella agreement. 

b) Infrastructure – Develop collaboratively with an emphasis on consolidating existing 

infrastructure and minimizing future development. 

c) Maintenance – Ensure that maintenance and upgrades of infrastructure is performed by 

or paid for by the “user” and includes activities needed to “maintain” permits as well.

5. Develop and implement an Infrastructure Improvement Plan for roads, sort yards, log transfer 

facilities, rafting grounds, long/short term storage areas and barge/ship loading facilities on all 

ownerships. Consolidate existing road systems to maximize volume at centralized sort yards, log 

transfer facilities and ship loading points. Road systems for resource management should be 

connected to existing community road systems when possible to reduce management costs and 

expand local workforce job opportunities. 

a) Consider at the minimum the following development needs: 

• Revillagigedo Island: Connect all isolated road systems; develop a centralized 

wood processing facility (Leask Cove) including a sort yard, log transfer facility and 

barge/ship loading facility. Consider development of an industrial park that 

includes a sawmill, and a wood-energy / municipal solid waste fueled electrical 

plant. (Map can be found in Appendix G – Map 1.)

• Prince of Wales Island – Trocadero Bay: Connect the private road systems in 

Trocadero Bay to the Hydaburg Highway (Map can be found in Appendix G – Map 

2.) 

 

• Prince of Wales Island – Cabin Creek: Provide access to the Prince of Wales road 

system by connecting the private road systems at Kina Cove, Cabin Creek, Paul's 

Bight and Smith Lagoon with the USFS roads at Polk Inlet and Little Coal Bay (Map 

can be found in Appendix G – Map 3.)

Strategies to Maintain a Viable Timber Industry in Southeast Alaska (14-CS-11100500-020) 14 of 97| Page
• Prince of Wales Island – Sandy Point: Connect the private roads at Sandy Point 

road to the Hollis Highway (Map can be found in Appendix G – Map 4.)

• Prince of Wales Island – Dolomi Bay: Connect the Dolomite, Lancaster Cove, Reid

Cove and Dora Bay road systems together. Look at feasibility of a connection with 

the West Arm of Cholmondeley Sound road system (Map can be found in Appendix 

G – Map 5.)

• Prince of Wales Island - West Arm of Cholmondeley Sound: Connect the West 

Arm of Cholmondeley Sound with Sulzer Portage (Map can be found in Appendix G

– Map 6.)

• Wrangell Island: Extend the existing Wrangell Island road system to Fool's Inlet. At 

Fool's Inlet construct a sort yard, log transfer facility and a barge/ship loading 

facility (Map can be found in Appendix G – Map 7.)

• Mitkof Island: Blind Slough development to include improvements to existing log 

transfer facility, construction of a sort yard and barge/ship loading facility (Map can 

be found in Appendix G – Map 8.)

• Kupreanof Island: Improve or construct sort yards, log transfer facilities, and 

barge/ship loading facilities at both Kake and Totem Bay. Connect the Portage Bay 

road system with Kake road system. Extend Kake road system south to Totem Bay

(Map can be found in Appendix G – Map 9.)

 

• Kuiu Island: Connect the existing road system to No Name Bay, with development 

in No Name Bay to include a sort yard, log transfer facility, and a barge/ship loading 

facility. Saginaw Bay development to include a sort yard and log transfer facility.

(Map can be found in Appendix G – Map 10.)

 

• Chichagof Island: Connect the road systems of False Island to Corner Bay, Hoonah 

to Salt Lake Bay, Hoonah to Freshwater Bay, Salt Lake Bay to Eight Fathom Bight (if 

possible), and Port Fredrick to Sealaska land (if possible). Hoonah development to 

include a sort yard, log transfer facility, and a barge/ship loading facility. (Map can 

be found in Appendix G – Map 11.)

 

• Baranof Island: Connect the road systems at Rodman Bay, Fish Bay and Katlian Bay 

to the community of Sitka. Develop a sort yard, log transfer facility and barge/ship 

loading facility at Sitka. Consider connecting, if possible, the Northern Baranof 

Island road systems at Appleton Cove, Saook Cove and Hanus Bay with the Rodman 

Bay Road system. (Map can be found in Appendix G – Map 12.)

 

Strategies to Maintain a Viable Timber Industry in Southeast Alaska (14-CS-11100500-020) 15 of 97| Page
Future Industry Concept #2

Creation of a viable timber Industry in Southeast Alaska, dependent on young growth fiber, which 

maintains the existing industry while ceasing the harvest of old growth timber stands on the Tongass 

National Forest within five (5) years.

Basis for Concept #2

The Working Forest Group proposes that the Tongass National Forest implement the following 

recommendations to meet the mandates listed below from the Secretary’s Memorandum 1044-009, 

dated July 2, 2013 (Appendix A): 

to speed the transition away from old growth timber harvesting and towards a forest industry 

that utilizes second growth – or young growth – forests. 

to effectuate this transition over the next 10 to 15 years, so that at the end of this period the vast 

majority of timber sold by the Tongass will be young growth.

to retain the expertise and infrastructure of the existing industry so businesses can quickly retool.

Recommendations

 Short-Term (Present Day to Five Years) 

1. USFS provide the existing industry old growth volume based on the Tongass Integrated Plan 

(TIP) (http://www.fs.usda.gov/detail/tongass/landmanagement/?cid=stelprd3812864 – USDA 

Forest Service) for the next five (5) years. The majority of the volume sold would be old growth, 

with only incidental volumes of young growth sold as a by-product of wildlife habitat 

development in non-development lands.

2. Develop long term “Agreements” between Federal, State and Private Landowners addressing:

a) Access and Road Use – this agreement should provide all landowners the ability to use 

each other’s infrastructure at no cost to the non-landowner. Such an agreement should 

include a project specific use agreement that can be implemented quickly under the 

umbrella agreement. 

b) Infrastructure – Develop collaboratively with an emphasis on consolidating existing 

infrastructure and minimizing future development. 

c) Maintenance – Ensure that maintenance and upgrades of infrastructure is performed by 

or pay for by the “user”. Include activities needed to “maintain” permits as well.

Strategies to Maintain a Viable Timber Industry in Southeast Alaska (14-CS-11100500-020) 16 of 97| Page
3. Conduct Stand Surveys of all young growth stands on all land-ownerships and gather at a 

minimum the following data:

• Acreage – available over multiple rotations for timber production

• Stand Age at the time of the survey

• Species Composition

• Site Index including information on aspect, slope and elevation for each stand

• Management intent of the owner – will the stand be intensely managed over a 

short rotation or will rotation be extended to accomplish landowners’ 

management goals.

4. Develop an Infrastructure Improvement Plan for roads, sort yards, log transfer facilities, rafting 

grounds, long/short term storage areas and barge/ship loading facilities on all ownerships. 

Consolidate existing road systems to maximize volume at centralized sort yard, log transfer 

facilities and ship loading points. Road systems for resource management should be connected 

to existing community road systems when possible to reduce management cost and expand 

local workforce job opportunities. 

b) Consider at the minimum the following development needs: 

• Revillagigedo Island: Connect all isolated road systems; develop a centralized 

wood processing facility (Leask Cove) including a sort yard, log transfer facility and 

barge/ship loading facility. Consider development of an industrial park that 

includes a sawmill, and a wood-energy / municipal solid waste fueled electrical 

plant. (Map can be found in Appendix G – Map 1.)

• Prince of Wales Island – Trocadero Bay: Connect the private road systems in 

Trocadero Bay to the Hydaburg Highway (Map can be found in Appendix G – Map 

2.)

 

• Prince of Wales Island – Cabin Creek: Provide access to the Prince of Wales road 

system by connecting the private road systems at Kina Cove, Cabin Creek, Paul's 

Bight and Smith Lagoon with the USFS roads at Polk Inlet and Little Coal Bay (Map 

can be found in Appendix G – Map 3.)

• Prince of Wales Island – Sandy Point: Connect the private roads at Sandy Point 

road to the Hollis Highway (Map can be found in Appendix G – Map 4.)

• Prince of Wales Island – Dolomi Bay: Connect the Dolomite, Lancaster Cove, Reid 

Cove and Dora Bay road systems together. Look at feasibility of a connection with 

the West Arm of Cholmondeley Sound road system (Map can be found in Appendix 

G – Map 5.)

Strategies to Maintain a Viable Timber Industry in Southeast Alaska (14-CS-11100500-020) 17 of 97| Page
• Prince of Wales Island - West Arm of Cholmondeley Sound: Connect the West 

Arm of Cholmondeley Sound with Sulzer Portage (Map can be found in Appendix G

– Map 6.)

• Wrangell Island: Extend the existing Wrangell Island road system to Fool's Inlet. At 

Fool's Inlet construct a sort yard, log transfer facility and a barge/ship loading 

facility (Map can be found in Appendix G – Map 7.)

• Mitkof Island: Blind Slough development to include improvements to existing log 

transfer facility, construction of a sort yard and barge/ship loading facility (Map can 

be found in Appendix G – Map 8.)

• Kupreanof Island: Improve or construct sort yards, log transfer facilities, and 

barge/ship loading facilities at both Kake and Totem Bay. Connect the Portage Bay 

road system with Kake road system. Extend Kake road system south to Totem Bay

(Map can be found in Appendix G – Map 9.)

 

• Kuiu Island: Connect the existing road system to No Name Bay, with development 

in No Name Bay to include a sort yard, log transfer facility, and a barge/ship loading 

facility. Saginaw Bay development to include a sort yard and log transfer facility.

(Map can be found in Appendix G – Map 10.)

 

• Chichagof Island: Connect the road systems of False Island to Corner Bay, Hoonah 

to Salt Lake Bay, Hoonah to Freshwater Bay, Salt Lake Bay to Eight Fathom Bight (if 

possible), and Port Fredrick to Sealaska land (if possible). Hoonah development to 

include a sort yard, log transfer facility, and a barge/ship loading facility. (Map can 

be found in Appendix G – Map 11.)

 

• Baranof Island: Connect the road systems at Rodman Bay, Fish Bay and Katlian Bay 

to the community of Sitka. Develop a sort yard, log transfer facility and barge/ship 

loading facility at Sitka. Consider connecting, if possible, the Northern Baranof 

Island road systems at Appleton Cove, Saook Cove and Hanus Bay with the Rodman 

Bay Road system. (Map can be found in Appendix G – Map 12.)

5. Land Exchange between the U.S. Forest Service and the State of Alaska - the National Forests 

within the State of Alaska are in the process of writing a new forest plan (Chugach) or amending 

an existing plan (Tongass). Both forests have State lands within or adjacent to their external 

boundaries. The Alaska Timber Jobs Task Force report of June 2012 (Appendix H) contains the 

recommendation to exchange 250,000 acres (recommendation #4 of Section 2, Task 5). This 

recommendation was driven in part by the Chugach National Forest’s interest in obtaining state 

owned lands within or near the Chugach for recreational purposes. 

Strategies to Maintain a Viable Timber Industry in Southeast Alaska (14-CS-11100500-020) 18 of 97| Page
Consideration should be given to a land exchange between the State and the U.S. Forest Service. 

Such an exchange would maintain the existing amount of land by ownership (no net loss of 

national forest lands or state lands) and would help align ownership with land use objectives. 

State land within or near the Chugach National Forest could be exchanged for lands within the 

Tongass National Forest. Federal lands transferred to the State should be included in the 

Southeast State Forest. 

At the conclusion of the land exchange (5 years from now) the Tongass timber sale program 

would cease selling old growth timber except for volumes affected by large insect or disease 

outbreaks, catastrophic windthrow events, the salvage of dead or down material and incidental 

volumes sold through a micro-sale program (sales under 50 MBF). Lands transferred from the 

State to the USFS could be developed for non-timber purposes (recreation facilities), but would 

be excluded from availability for timber harvest.

 Mid-Term (Six Years to Fifteen Years) 

1. Implement Land Exchange between USFS and State of at least 250,000 acres or per the 

recommendation of the Alaska Timber Jobs Task Force report.

2. Implement Infrastructure Plan

3. Continue collecting young growth stand data on all lands

4. USFS Timber Sale Program will only include of the harvest of old growth timber volumes 

affected by large scale insect and/or disease outbreaks, catastrophic windthrow events, the 

salvage of dead or down material and incidental volumes sold through a micro-sale program 

(sales under 50 MBF). Stewardship contracting should be used as the contracting method on all 

sales.

Young growth volumes sold during this timeframe would be minimal and be a by-product of 

treating young growth acreage in non-development land use designations for purposes of 

wildlife habitat development. 

5. Develop a young growth management/marketing strategy in association with the State and 

private landowners by coordinating the harvest between land ownerships based on young 

growth stand data gathered in the short and mid-term and future land management plans by 

land ownership should be consider when developing harvest plans. 

Also, consider the Working Circle concept that proposes the establishment of five (5), 50-mile 

radius Working Circles centered in the Southeast Alaska communities of Hoonah, Kake, Wrangell, 

Klawock, and Ketchikan. The total operating area of these Working Circle centers encompasses 

more than 95 percent of the production forest land use designations (LUDs) contained within 

Strategies to Maintain a Viable Timber Industry in Southeast Alaska (14-CS-11100500-020) 19 of 97| Page
the Tongass National Forest (TWFG. pg. 15). The primary goal of the Working Circle concept, 

within the TWFG paper cited, was the creation of an appraisal point at each of the five (5) 

Working Circle centers to generate positive value USFS timber sales. When included as part of 

this report’s Infrastructure Development Plan, the Working Circle concept maximizes future 

volume across all landownerships at centralized locations that will provide an economy of scale 

and manufacturing opportunities.

Research and/or consider potential young growth product development such as:

a) Pacific Rim needs and cutting methods/dimensions – Southeast Alaska has a 

competitive advantage over the Pacific Northwest in shipping cost to Pacific Rim 

countries; can that advantage be used by mills to provide manufactured 

products to Pacific Rim countries? What are those products? 

b) Bio-diesel for marine use – Navy, Coast Guard, Cruise ships, commercial fishing

fleet – can waste material and/or non-traditional commercial wood fiber 

associated with timber harvest be used to produce bio-diesel? Is there a 

competitive advantage to produce that fuel in Southeast Alaska in connection 

with the supposed “boom” that will occur in the Arctic? Can such a product be 

integrated into the marine support industry currently being envisioned for 

Southeast Alaska? 

c) Stock for remanufacturing – veneer, timbers, and shop material – can primary 

manufacturing work to supply stock to the Pacific Rim or other international 

markets vs. domestic markets? Is supplying domestic markets economically 

feasible?

d) Wood energy – producing fuel products for export outside the region and/or 

producing heat and power within the region. Is it better to produce power at a 

small scale locally or at a larger “regional size” and transport via a region grid? 

Can waste material and/or non-traditional commercial wood fiber associated 

with timber harvest be combined with municipal solid waste to produce power 

and resolve communities’ issues with handling solid waste?

6. Develop a mill infrastructure/transition plan in association w/ State and private landowners 

based on the developed young growth management and marketing strategy as proposed above. 

What is the infrastructure need based on the strategies developed? What is the infrastructure 

needs based on the annual available volume from the “all lands” management strategy? Is it one 

or two large capacity mills that consume the volume generated on an annual basis region wide? 

Or multiple high efficiency mills strategically located across the region (Working Circle concept)?

What infrastructure is needed to produce primary manufactured products vs. finished products? 

Strategies to Maintain a Viable Timber Industry in Southeast Alaska (14-CS-11100500-020) 20 of 97| Page
Are there different infrastructure needs when considering the production of domestic vs. 

international products?

 Long-Term (Beyond Fifteen Years) 

1. Seek investors and entrepreneurs to implement plans and strategies developed during the midterm.

2. USFS starts offering young growth volumes from National Forest lands when available volumes 

combined with volume from all other landowners are sufficient on an annual basis to provide for 

the future industry as envisioned and planned for during the mid-term. 

Strategies to Maintain a Viable Timber Industry in Southeast Alaska (14-CS-11100500-020) 21 of 97| Page
APPENDICES 

APPENDIX A: SECRETARY’S TRANSITION MEMORANDUM JULY 2, 2013 

APPENDIX B: SAMPLE SURVEY 

APPENDIX C: INITIAL BUSINESS CONTACTS – JULY 2014

APPENDIX D: U.S. FOREST SERVICE SOUTHEAST ALASKA SPECIES SUMMARY REPORTS 

APPENDIX E: TONGASS TIMBER REFORM ACT (TTRA), SECTION 101 

APPENDIX F: ANILCA SECTION 705(a) 

APPENDIX G: 

Map 1. Revillagigedo Island

Map 2. Prince of Wales Island – Trocadero Bay

Map 3. Prince of Wales Island – Cabin Creek

Map 4. Prince of Wales Island – Sandy Point

Map 5. Prince of Wales Island – Dolomi Bay

Map 6. Prince of Wales Island – West Arm of Cholmondeley Sound 

Map 7. Wrangell Island

Map 8. Mitkof Island 

Map 9. Kupreanof Island

Map 10. Kuiu Island

Map 11. Chicagof Island 

Map 12. Baranof Island 

APPENDIX H: ALASKA TIMBER JOBS TASK FORCE (SHORT REPORT) – JULY 2012 

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APPENDIX A: SECRETARY’S TRANSITION MEMORANDUM JULY 2, 2013 

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APPENDIX B: SAMPLE SURVEY 

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APPENDIX C: INTIAL BUSINESS CONTACTS – JULY 2014 

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APPENDIX D: U.S. FOREST SERVICE SOUTHEAST ALASKA SPECIES 

SUMMARY REPORTS 

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APPENDIX E: TONGASS TIMBER REFORM ACT (TTRA), SECTION 101 

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APPENDIX F: ANILCA SECTION 705(a) 

 

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APPENDIX G: INFRASTRUCTURE NEEDS MAPS 

Map 1. Revillagigedo Island

Map Developed by Alaska Mental Health Trust Land Office

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Map 2. Prince of Wales Island - Trocadero Bay

Map Developed by Alaska Mental Health Trust Land Office

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Map 3. Prince of Wales of Island – Cabin Creek 

Map Developed by Alaska Mental Health Trust Land Office

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Map 4. Prince of Wales of Island – Sandy Point 

Map Developed by Alaska Mental Health Trust Land Office

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Map 5. Prince of Wales of Island – Dolomi Bay 

Map Developed by Alaska Mental Health Trust Land Office

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Map 6. Prince of Wales of Island – West Arm of Cholmondeley 

Sound 

Map Developed by Alaska Mental Health Trust Land Office

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Map 7. Wrangell Island

Map Developed by Alaska Mental Health Trust Land Office

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Map 8. Mitkof Island 

Map Developed by Alaska Mental Health Trust Land Office

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Map 9. Kupreanof Island 

Map Developed by Alaska Mental Health Trust Land Office

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Map 10. Kuiu Island

Map Developed by Alaska Mental Health Trust Land Office

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Map 11. Chichagof Island 

Map Developed by Alaska Mental Health Trust Land Office

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Map 12. Baranof Island

Map Developed by Alaska Mental Health Trust Land Office

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APPENDIX H: ALASKA TIMBER JOBS TASK FORCE (SHORT REPORT) – JULY 

2012 

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WORKS CITED 

The Working Forest Group (TWFG). Analysis of Old Growth Inventory and Land Base Available for 

Operations within the Tongass National Forest. June 2014. Print.

U.S. Department of Agriculture. Tongass Integrated Plan. USDA Forest Service. Web. 26 December 

2014. http://www.fs.usda.gov/detail/tongass/landmanagement/?cid=stelprd3812864 

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February 22, 2015 

Forest Supervisor 

Tongass national Forest 

Attn: Forest Plan Amendment 

648 Mission Street 

Ketchikan, AK 99901 

Re: Comments on Proposed Tongass Nation Forest Land and Resource Management Plan 

 And the draft EIS 

Thank you for allowing us this opportunity to comment on the Proposed Tongass National 

Forest Land and Resource Management Plan and the draft EIS. 

Our understanding is that the primary changes in this plan is focusing on the transition from 

harvesting old growth to young growth. But as a community who has experienced the downside 

of the lack of a supply of old growth timber, we are concerned in the ability of the USFS to 

provide an economically viable supply of young growth timber, and to do it within the 15 year 

time frame as charged by the Secretary of Agriculture. We are concerned that the inventory 

data is generalized, and therefore we support and encourage development of an accurate 

inventory of young growth availability. 

This inventory is critical for a complete and accurate economic analysis of the transition on 

communities and industry. Loss of harvesting volume is not a result in decline in demand, it is a 

result from the loss of economic sales available to industry and the slow process the USFS 

undertakes to develop sales due to an ongoing fear of lawsuits. No business can operate 

economically in such an environment and thus the loss in industry opportunity. 

 The plan fails to consider social and economic metrics to measure outcomes of the 

transition from old growth to young growth. Metrics showing the impacts to industry and 

also to communities. 

 Appendix C Watershed Analysis: There has been so much discussion of late regarding 

“watershed” analysis and impacts within the T77 watersheds. Based on our own 

personal experience with the Wrangell Island Sale, an actual stream “watershed” for a 

harvest unit or harvest area, may be smaller than the T77 defined watershed. Yet the 

USFS is trying to utilize the T77 watershed analysis. The Plan needs to clarify its 

definition and use of watershed analysis vs. the T77 watersheds. 

 We support the relaxation of Standards and Guides for the harvest of Young Growth 

during the transition in land use designations that may normally minimize or prohibit 

some commercial harvesting if it will provide economic sales of young growth timber. 

 

CITY AND BOROUGH OF WRANGELL

INCORPORATED MAY 30, 2008

P.O. BOX 531 (907)-874-2381

Wrangell, AK 99929 FAX (907)-874-3952

 www.wrangell.com
2 

 Appendix F Visual Priority Routes and Scenic Integrity. According to our Wrangell 

District, for some reason it appears that all of Wrangell’s Forest Roads are designated a 

Visual Priority Route. While we agree that the main roads do have a visual preference, 

not all of the roads need to be classified a visual priority route to limit timber or other use. 

( Originally, some of these designations were going to be dealt with in the upcoming 

Wrangell Island Sale, but now we understand that will not happen and we have to 

address it here. Only the road management plan – what stays open, what will be closed 

and level of use will now be addressed in the Wrangell Island Sale. ) For example, the 

back side of the Nemo-Skip Loop Road (6267) (From Turn Island where the road turns 

northeast back to intersection of #6265 to Earl West) is heavily timbered and more out of 

site out of mind and a good area in which to continue to permit timber harvest. Yes it is 

on a loop so makes for a fun day trip, but there is nothing wrong with timber harvesting. 

Questions can be answered with educational materials about timber harvesting practices 

and economic values to communities. 

Every road on Wrangell Island will meet one of the primary criteria for a visual priority 

route – for example the water routes of small and midsize boats. We are on an island. 

Timber roads climb mountains that provide views, over looks are created for turn outs for 

logging trucks and once trees are harvested, you can see the water. It does not mean 

that each road should be a visual priority route. All roads should be analyzed as a 

whole, and key stretches of roads identified. Off shoots of some of the priority roads 

that receive minimal traffic could be reclassified as non visual priority. 

 Tourism is the big growth industry since supply of timber to harvest and political affects 

have reduced the opportunity for the timber industry. The plan also fails in considering 

the social and economic metrics to measure outcomes of tourism growth for 

communities and businesses and the impacts to recreational sites 

We understand that the USFS has selected as its preferred alternative, Alternative 5 that was 

proposed by the Tongass Advisory Committee. While the Borough is not agreeing or 

disagreeing with that alternative specifically, we do understand that their proposed amendment 

included additional recommendations that were not necessarily “plan” amendments. Yet their 

recommendation was to be presented as a package. If Alternative 5 is implemented, we believe 

the other components of their recommendation, including the monitoring, bringing stakeholder 

participation in earlier in planning processes, USFS internal culture change, inventory 

assessments and social economic impact analysis are critical components of any plan 

implementation strategy. 

Sincerely, 

Jeff Jabusch 

Borough Manager 

CC: Mayor David Jack 

 Borough Assembly 

 Carol Rushmore, Economic Director/Planner