United States 

Department of

Agriculture

Forest Service

Tongass National Forest

R10-MB-717a

March 2011

Wrangell Ranger District 

Roadside Timber Sales

Decision Notice, Finding of No 

Significant Impact, and 

Environmental Assessment

Wrangell Ranger District

Wrangell, Alaska
Cover Photo: Road 6267 on Wrangell Island
United States

Department of

Agriculture

Forest

Service

Alaska Region

Tongass National Forest

Wrangell Ranger District

P.O. Box 51

Wrangell, AK 99929-0051

Phone: (907) 874-2323

Fax: (907) 874-7595

 Caring for the Land and Serving People Printed on Recycled Paper 

File Code: 1950-1

Date: March 10, 2011

Dear Planning Participant,

Here is the Decision Notice and Finding of No Significant Impact (FONSI) for the Wrangell Ranger 

District Roadside Timber Sales Environmental Assessment (EA). It has been posted on the internet 

at: http://www.fs.fed.us/r10/tongass/projects/projects.shtml and at the Wrangell Library. Attached 

also is the Environmental Assessment for the Roadside Timber Sales and appendices. Copies of the 

Decision Notice and EA are also available upon request on CD or hardcopy from the Wrangell 

District. 

The Decision Notice documents my decision to select Alternative 2, the proposed action, and the 

factors I considered in reaching the decision. The proposed action was developed based on public 

comments received during the scoping period. This project makes available up to 500 MBF of 

timber per year for offer as small scale commercial firewood sales, salvage sales and green-timber 

sales along the existing road systems on Etolin, Wrangell, and Zarembo Islands. No roads will be 

constructed in this project. 

As District Ranger, I am responsible for this decision. Information concerning implementation of 

this decision and appeal rights is included in the Decision Notice. 

I want to thank those of you who took the time to review and comment on this project. For more 

information, please call Austin O’Brien at 907-874-2323. 

Sincerely,

ROBERT DALRYMPLE

Wrangell District Ranger

Decision Notice,

Finding of No Significant Impact, and

Environmental Assessment

Wrangell Ranger District Roadside Timber Sales

Agency: USDA Forest Service

 Tongass National Forest

Responsible Official: Robert J. Dalrymple, District Ranger

Wrangell Ranger District 

P.O. Box 51

Wrangell, AK 99929

For Further Information: Austin O'Brien

Wrangell Ranger District

P.O. Box 51

Wrangell, Alaska, 99929

(907) 874-2323

Abstract

My decision is to implement Alternative 2 of the Wrangell Ranger District Roadside 

Timber Sales EA. The Selected Alternative will make available up to 500 MBF of timber 

per year along existing roads in salvage sales, small sales, and microsales. I have 

determined that the impacts of the Selected Alternative are not significant and preparation

of an environmental impact statement is not required. The rationale for my decision and 

findings are described in the Decision Notice and Finding of No Significant Impact. 

The Environmental Assessment and appendices are included in this document.

This document is available online at:

http://www.fs.fed.us/r10/tongass/projects/projects.shtml.

DECISION NOTICE

and FINDING OF NO SIGNIFICANT IMPACT

Table of Contents

Decision .............................................................................................................................. 1

Rationale for the Decision .................................................................................................. 5

Purpose and Need ............................................................................................................ 5

Issues................................................................................................................................ 6

Public Comment .............................................................................................................. 6

Changes to the EA ........................................................................................................... 6

Environmental Effects ..................................................................................................... 7

Public and Agency Involvement......................................................................................... 7

Alternatives......................................................................................................................... 8

Finding of No Significant Impact ....................................................................................... 8

Findings Required by Other Laws and Regulations......................................................... 10

Distribution ....................................................................................................................... 14

Implementation Date......................................................................................................... 14

Administrative Review or Appeal Opportunities ............................................................. 15

Decision Notice 

and Finding of No Significant Impact

Wrangell Ranger District Roadside Timber Sales

USDA Forest Service

Wrangell Ranger District, Tongass National Forest

Wrangell, Alaska

This Decision Notice documents my decision for the Wrangell Ranger District Roadside Timber 

Sales project. It contains a brief summary of the environmental analysis completed for this 

project as well as my decision regarding which alternative to implement and the rationale for my 

decision. It also contains certain findings required by various laws, and information concerning 

the right to Administrative Review of this decision. The Environmental Assessment (EA) 

completed for this project documents the environmental analysis and conclusions upon which 

this decision is based. The EA is incorporated by reference in this decision document and is 

attached.

Decision

Based on the EA completed for this project, as well as my consideration of comments received 

during the 30-day public review of the document, it is my decision to implement Alternative 2, 

the Proposed Action, hereafter known as the Selected Alternative. 

The Selected Alternative makes available up to 500 MBF of fuelwood and sawtimber per year as 

commercial salvage harvest of dead, dying, or blown down timber, and minor harvest of green 

fuelwood and green sawtimber. The timber will be offered as multiple salvage, fuelwood, small

sales, and micro-sales, depending on annual demand from the public and local operators. 

The removal of hazard and potential hazard trees will be emphasized. Individual green-timber 

sales will be limited to 50 MBF. Harvest systems will include even-aged management for 

salvage sales, and uneven-aged management (group selection or single-tree selection) for green 

tree sales. Timber harvest will require ground-based, cable, or helicopter yarding systems. 

All harvest will occur within 1,200 feet from either side of existing roads within land use 

designations (LUDs) designated for development in the Forest Plan on Etolin, Wrangell, and 

Zarembo Islands as shown on the Selected Alternative maps DN-1, DN-2, and DN-3. This 

decision does not authorize harvest within non-development LUDs, beach fringe, or 2001 

inventoried roadless areas with existing roads. No new road construction is authorized in this 

decision. 

I am incorporating the design criteria and monitoring requirements described in the EA into my 

decision. This decision will be implemented using the Implementation Plan described in 

Appendix 1 of the EA. Because this decision is programmatic in nature, identification of 

appropriate site-specific practices and any necessary mitigation will be made during the annual 

project review process.
2

Figure DN-1: Project Area on Wrangell Island 
Decision Notice

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Figure DN-2: Project Area on Etolin Island 
4

Figure DN-3: Project Area on Zarembo Island
Decision Notice

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Rationale for the Decision

In making this decision, I considered applicable laws, regulations, policy, and the Forest Plan in 

relation to information disclosed in the EA and planning record. I feel the best available science 

and information was used in the analysis. I considered how each alternative met the purpose of 

and need for action and addressed the issues. I also considered the effects of the project on the 

human and natural environment and weighed the potential resource effects, whether adverse and 

beneficial, as well as the public benefit.

Purpose and Need

I feel that the Selected Alternative best meets the purpose of and need for this project.

The Selected Alternative will support the local economy which is currently struggling 

economically. It would create opportunities for small businesses and individuals and provide 

economic benefit to the local community, small business operators, and the public by providing a 

predictable annual supply of timber and fuelwood. This project will contribute to one of the 

goals of the USDA Strategic Plan FY2010 – 2015 which is to “Assist Rural Communities to 

create Prosperity so they are Self-sustaining, Repopulating and Economically Thriving”. This 

project is also part of the Tongass Transition Framework which seeks to build upon current 

assets and economic sectors and develop other opportunities on the Forest. This project will

supply multiple small sales that would locally provide the raw materials for a variety of wood 

products such as lumber, fuelwood, cedar shakes, and wood for artistic and musical pursuits.

The Selected Alternative will establish a program on the District which can provide a more 

predictable supply of fuelwood for personal firewood users and commercial firewood businesses 

to meet local fuelwood needs. It will allow the District to reduce the competition for fuelwood 

between the general public and commercial firewood businesses. It will increase the supply of 

fuelwood available to commercial operators and will designate specific areas for commercial 

operations. This supply of fuelwood will also contribute to the local economy by producing 

employment opportunities and reducing the community’s reliance on expensive imported nonrenewable fossil fuels for heating.

The Selected Alternative will also allow the Wrangell District to improve public service in

responding to requests for wood products in a more timely and efficient manner. It establishes a 

program that will be more efficient in meeting the local wood fiber needs of the community by 

consolidating multiple timber harvest opportunities into one process. The program will enable 

the District to respond more quickly to timber salvage opportunities and recover the economic 

value of salvage timber before it deteriorates. It provides for a more predictable supply of green 

sawtimber through microsales for commercial operators. 

The Selected Alternative responds to the goals of the Forest Plan to seek to provide a supply of 

timber that meets the annual market demand and to maintain and promote wood production from 

suitable forest lands, providing a continuous supply of wood to meet society’s needs, consistent 

with the standards and guidelines for the specific LUDs in this project. 

The Selected Alternative also provides an economical way to maintain safe roads on the District 

by removing hazard trees that could fall onto the road and cause injury or block traffic. These 

trees can then be made available for sawtimber or fuelwood. 
6

The Selected Alternative will also promote forest health by allowing the removal of diseased or 

windthrown trees, thereby improving stand vigor and promoting more rapid regeneration of 

young trees. 

When compared with the No-action Alternative, the Selected Alternative best meets the project’s 

purpose and need, and best moves the project area toward desired conditions identified for each 

land use designation in the Forest Plan. 

Issues

I chose the Selected Alternative because it best addresses the relevant issues, concerns, and 

opportunities. The key issue developed from scoping comments was the available supply of 

fuelwood and timber for the public and local small timber operators and manufacturers. Two 

alternatives were considered to address the key issue – the Proposed Action and no action. The 

Selected Alternative best meets this issue by providing a dependable supply of fuelwood and 

timber which can be made available to meet the needs of the public and local timber businesses

over time. 

Public Comment

The input received from the public and the State of Alaska weighed heavily in my decision. The 

project was initially developed in response to requests by local timber operators and fuelwood 

cutters for accessible dead, dying and blown-down fuelwood and timber as well as individual 

green trees. In making my decision, I considered comments received from the public during 

scoping and public meetings, and during the 30-day public review of the EA. Overall, the public 

comments generally supported this project, but some commenters expressed concern over the 

potential adverse effects. Appendix 4 of the EA contains the letters received in comment to the 

EA, and the Forest Service response to the concerns raised. 

The design criteria for the Proposed Action incorporated public request for a variety of sale types 

and sizes. The design criteria also address environmental concerns such as potential effects on 

wildlife connectivity, POG, aquatic resources and riparian areas, or soil productivity are 

addressed in the EA and the Implementation Plan (Appendix 1), through Forest Plan Standards 

and Guidelines, best management practices (BMPs), and mitigation and monitoring.

I believe that these concerns are addressed by the incorporation of the design criteria, standards 

and guidelines, BMPs, and the Implementation Plan required in my decision which will 

minimize the potential for adverse environmental effects. I believe that my decision on the 

Selected Alternative best meets the desires expressed by the public.

Changes to the EA 

Some changes, clarifying information presented in the EA, were made as a result of public and 

agency comments (see Appendix 4 of the EA). These changes include:

(EA p. 13) Salvage harvest, while conducted in accordance with Forest Plan Standards and 

Guidelines (VII. Salvage Harvest, p. 73), would not be authorized in non-development LUDs 
Decision Notice

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under this decision. Therefore, parts A, B, D, E, and F of the Forest Plan reference would apply 

to salvage harvest under this decision; part C would not apply under this decision. 

(EA pp. 23 and 38) The terms productive forestland and productive old growth (POG) in the 

silviculture and botany sections were clarified. Productive forestland and POG are not 

synonymous terms although historically (pre-harvest), all productive forestland was considered 

to be POG for this analysis. Productive old growth includes volume classes 4 and higher, and is 

old-growth forest capable of producing at least 20 cubic feet of wood fiber per acre per year, or 

having greater than 8,000 board feet per acre (Forest Plan p. 7-29). Productive forestland

includes young growth in volume class sizes 1-3 as well as classes 4 and higher. It includes 

forested areas containing timber volumes of greater than or equal to 8,000 net board feet/acre or 

having the potential to achieve this volume and capable of maintaining that volume (producing 

20 cu. ft/acre/year of industrial wood or having a site index of 40 or higher).

The productive forestland and productive old growth (POG) acreage figures were updated to 

read approximately 239,397 acres of pre-harvest POG, of which approximately 29,398 acres

have been harvested. 

Several changes were made to clarify language in the Implementation Plan (EA Appendix 1), 

which is included with the EA.

Environmental Effects

In making my decision I considered the resource analysis reports and planning record, and 

weighed the potential resource effects (including the cumulative effects) whether adverse and 

beneficial, as well as the public benefit. I found that neither of the alternatives, including the 

Selected Alternative, provides significant effects to the environment. These effects are 

summarized in Table 2 of the EA. This project is limited in nature and scope. The Selected 

Alternative provides for limited harvest (up to maximum of 500 MBF) of dead and down trees 

along approximately 165 miles of existing roads. It provides for only limited harvest of 

individual green trees. Green tree harvest would is limited to single tree or group harvest 

distributed to minimize openings and distributed along the road system. Individual green tree 

sales are further restricted in size to a limit of 50 MBF. Appropriate yarding systems will be 

used to achieve minimal ground disturbance and green-up requirements will be met. No new 

road construction is authorized in this decision. 

The environmental effects are expected to be minor and are further mitigated by the use of the 

design criteria, standards and guidelines, and BMPs. The Implementation Plan incorporates 

design features and mitigation requirements intended to minimize the impacts to all resources. It 

requires additional resource review of each sale proposal. Each timber sale proposal will also 

require District Ranger review and approval. 

Public and Agency Involvement

This project included extensive public, agency, and tribal involvement. This action has been 

listed on the Tongass National Forest Schedule of Proposed Actions (SOPA) since January 2009 

and updated periodically during the analysis. At a public meeting the Ranger District held in 

April 2008, the public requested increased firewood availability, including commercial green 
8

firewood sales on the existing road system. A scoping letter was sent out in January 2009 to 

agencies, groups, and individuals who have expressed interest in Forest Service projects in this 

area, and notice published in the Wrangell Sentinel. The Forest Service received six comments 

all in favor of the proposal, requesting increased availability of small sales and giving priority 

consideration to firewood for personal users on Wrangell Island. The Forest Service also 

consulted Federal, State, and local agencies, and tribes during the development of the EA: 

National Marine Fisheries Service, Alaska Department of Environmental Conservation, Alaska 

Department of Fish & Game, and Wrangell Cooperative Association.

The EA was made available for public comment in November 2010. A notice of availability was 

published in the Wrangell Sentinel on November 25, 2010. Three comment letters were received 

during the 30-day comment period and are included in Appendix 4 of the EA. 

Alternatives

Two alternatives were developed to address the key issues developed from scoping. These 

alternatives are presented in Chapter 2 of the EA. The decision selects Alternative 2. 

Finding of No Significant Impact

After considering the environmental effects described in the EA, I have determined that these 

actions will not have a significant effect on the quality of the human environment considering the 

context and intensity of impacts (40 CFR 1508.27). Thus, an environmental impact statement 

will not be prepared. I base my finding on the following:

1.

2.

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

Federal agency believes that on balance the effect will be beneficial. Neither adverse nor 

beneficial effects are significant in context or intensity to warrant an EIS for this project. 

My finding of no significant environmental effects is not biased by the beneficial effects 

of the action. 

3.

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

conclusions in the EA, I have determined that no significant impact would occur to the 

public health and safety. The project area is located away from populated areas. While 

harvest operations could cause temporary traffic delays or congestion to recreation users 

of the road system, the Forest Service would communicate with the public regarding 

when and where potential delays could take place. Removal of hazard trees along the 

roads will increase public safety.

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

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

critical areas. The project does not enter any roadless areas. No historic properties, park 

lands or farmlands are located within the area of potential effects for the project. An 

archeologist will review harvest locations for each proposed sale to determine if a field 

survey is needed. No wild and scenic rivers occur in the project area or are affected by 

the project. High-value wetlands and high-vulnerability karst will be excluded from 

harvest. Other wetlands and karst identified during field review of the annual operating 

plan will have site-specific protections in place to minimize potential effects. Therefore, 
Decision Notice

9

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

area.

4.

5.

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

highly controversial. The effects on the quality of the human environment are not likely 

to be highly controversial. This project was proposed in response to requests by the local 

public and public input has been in favor of it. While there is some controversy over 

timber harvest of old-growth timber in Southeast Alaska in general, this project proposes 

primarily dead/down or dead/standing trees for salvage or firewood harvest, with some 

green tree harvest or small sales of 50 MBF or less, alongside existing road corridors. 

This project responds to the goals and objectives of the Forest Plan and helps move the 

project area towards conditions described in that Plan. Therefore, I have determined that 

there are no significant impacts based on the evidence found in the EA that would be 

highly controversial.

6.

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

or involve unique or unknown risks. The Forest Service has considerable experience with 

the types of activities to be implemented. The effects analysis shows the effects are not 

uncertain, and do not involve unique or unknown risk. Small salvage sales, commercial 

firewood harvest, and microsales of the kind proposed and analyzed in this EA have been 

successfully implemented under categorical exclusions and permits on the Wrangell 

Ranger District and elsewhere on the Tongass. The implementation plan specifies the 

site-specific analysis that would take place annually for the year’s proposed sales plan. 

Based on this analysis, I have determined there are no unique or unknown risks involved 

with this project, therefore there is no significant impact due to uncertainty or a possible 

unique or unknown risk.

7.

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

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

action is not likely to establish a precedent for future actions with significant effects, 

because the types of actions proposed – microsales, small salvage sales, and commercial 

firewood cutting permits – have already been occurring on the Wrangell Ranger District 

without significant effects. I have therefore determined the Proposed Action would set 

no precedent for future action with significant impacts, nor would it represent a decision 

in principle about a future consideration.

8.

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

cumulatively significant impacts. I have determined the Proposed Action will have

individually insignificant impacts and cumulatively insignificant impacts as they relate to

past, present, and reasonably foreseeable actions. All previously harvested stands on the 

District have regenerated and many have received various treatments such as thinning, 

pruning, or planting. There is no new road construction. The salvage harvest and limited 

scope and scale of individual green-tree sales contribute very minimally to cumulative 

effects, and no significant cumulative effects were identified for any resource.

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

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

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

The Forest Service has determined that a finding of No Historic Properties Affected is 
10

appropriate for this project. This project meets the provisions stipulated in the 

Programmatic Agreement between the Forest Service, Alaska Region, the Advisory 

Council on Historic Preservation, and the State Historic Preservation Officer. Therefore, 

I have determined no significant impacts would occur that adversely affect districts, sites, 

highways, structures, or objects listed in or eligible for listing in the National Register of 

Historic Places or cause loss or destruction of significant scientific, cultural, or historical 

resources.

9.

10.

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

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

1973. The action will not adversely affect any endangered or threatened species or its 

habitat that has been determined to be critical under the Endangered Species Act of 1973, 

because there are no listed species or critical habitat in the project area or in areas 

adjacent to the project area, and no marine environment is included in the project area. 

Therefore, I have determined no significant impacts would occur that adversely affect an 

endangered or threatened species or its habitat.

Findings Required by Other Laws and Regulations

Whether the action threatens a violation of Federal, State, or local law or requirements

imposed for the protection of the environment. The following findings show that the 

action does not violate Federal, State, or local law requirements imposed for the 

protection of the environment and has been reviewed by Federal and State agencies. The 

action is consistent with the Forest Plan.

National Forest Management Act

The National Forest Management Act (NFMA) requires specific determinations to be made for 

this project: consistency with the Forest Plan and FSM 2410.3, R10 Supp. 2400-2002-1 

(5/7/2002); a determination of even-aged management as the optimal method of harvesting, if 

used; and specific authorizations to create openings over 100 acres in size, if any. Specific unit 

prescriptions will be developed for sales.

2008 Tongass Land and Resource Management Plan (Forest Plan): This decision is 

consistent with the Forest Plan, and both project alternatives complied with the Forest Plan. This 

project incorporates all applicable Forest Plan Standards and Guidelines and management 

prescriptions, and complies with Forest Plan goals and objectives (pages 2-4 through 2-9). The 

Forest Plan complies with all resource integration and management requirements of 36 CFR 219 

(219.14 through 219.27). Application of Forest Plan direction for the Wrangell Roadside project 

ensures compliance at the project level. Therefore, I have found the Wrangell Roadside Timber 

Sales project consistent with the Forest Plan.

Even-aged Management as the Optimal Method of Harvesting: I have determined that evenaged management may be the optimal harvest method when used to remove dead or dying trees 

resulting from windthrow, insect infestations, and disease, in order to promote forest health and 

to hasten natural regeneration as provided for in the Forest Plan. 

Harvest Openings over 100 Acres in Size: There are no harvest openings over 100 acres 

proposed for this project. 
Decision Notice

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With the above considerations, I have found the Wrangell Roadside Timber Sales project is 

consistent with the Forest Plan and FSM 2410.3, R10 Supp. 2400-2002-1 and consequently 

complies with the National Forest Management Act.

Endangered Species Act of 1973

This decision is not anticipated to have a direct, indirect, or cumulative effect on any threatened 

and endangered species in or outside the project area. Consultation with the National Marine 

Fisheries Service was conducted and this agency has concurred that the project is not likely to 

adversely affect any threatened or endangered species. A biological evaluation has been 

completed for this action which determined that no federally listed threatened or endangered 

species will be affected by this activity. Consultation with the U.S. Fish and Wildlife Service 

was not necessary because no threatened and endangered terrestrial species occur in the project 

area. 

Therefore, I find that no significant effects would occur to federally listed threatened and 

endangered species as a result of this decision.

Tongass Timber Reform Act

Application of Forest Plan Riparian Standards and Guidelines ensures that no commercial timber 

harvest is allowed within 100 feet horizontal distance either side of Class I or Class II streams 

flowing directly into a Class I stream.

Therefore, I have determined that no significant effects would occur to riparian areas because 

these buffers will be applied.

National Historic Preservation Act of 1966

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

includes locating, inventorying and evaluating the National Register of Historic Places eligibility 

of historic and archeological sites that may be directly or indirectly affected by scheduled 

activities. Regulations (36 CFR 800) implementing Section 106 of the NHPA require Federal 

agencies to consider the effects of their actions on sites that are determined eligible for inclusion 

in or are listed in the National Register of Historic Places ("historic properties"). 

No documented archeological sites are located within the project area. I have determined that 

the project has little to no potential to affect historic properties because of its nature, size, 

location within the low archeological site sensitivity zone or location within areas that have 

previously been surveyed for cultural resources. However, since potential ground-disturbing 

activities are associated with this project and there are a few areas falling within the high 

archeological site sensitivity zone, proposed harvest locations will be assessed according to the 

Programmatic Agreement with the Advisory Council on Historic Preservation and the Alaska 

State Historic Preservation Officer. 

I conclude no significant effects would occur to historic resources as a result of this decision.

Federal Cave Resource Protection Act

While there are some areas of high-, medium-, and low-vulnerability karst along existing roads 

on Etolin Island, Forest Plan Karst and Caves Standards and Guidelines would be applied to any 

karst resources. No harvest will occur on high-vulnerability karst lands; and on moderatevulnerability karst lands, individual karst features will be buffered to maintain existing 

environmental condition around the features. Identification of appropriate practices and 

necessary mitigation during the annual project review process will prevent significant 
12

impairment of karst lands during project implementation. Therefore, I have determined that no 

significant effects would occur to karst or caves from this decision.

ANILCA Section 810, Subsistence Evaluation and Finding

The effects of this project have been evaluated to determine potential effects on subsistence 

opportunities and resources. There is no documented or reported subsistence use that will be 

restricted as a result of this decision. For this reason, neither of the alternatives would result in a 

significant possibility of a significant restriction of subsistence use of wildlife, fish, or other 

foods. Therefore, I have found the Wrangell Roadside Timber Sales Selected Alternative

consistent with ANILCA. 

Clean Water Act

I have determined that this project fully complies with the Clean Water Act. Project activities 

meet all applicable State of Alaska Water Quality Standards. 

My decision incorporates soil and water conservation practices (BMPs) to control nonpoint 

source pollution on the project area. 

This project will be implemented using soil and water best management practices (BMPs) that 

are consistent with the Alaska Forest Resources and Practices Regulations (AFRPA) to achieve 

Alaska Water Quality Standards. 

Therefore, I have determined that no significant impact to water quality is expected to occur 

from this decision.

Clean Air Act

Emissions anticipated from the implementation of the Selected Alternative will be minor and of 

short duration and are not expected to exceed State of Alaska ambient air quality standards (18 

AAC 50). Therefore, I have determined that no significant impact to air quality would be 

expected to occur from this decision.

Coastal Zone Management Act of 1972, as Amended

Under the Coastal Zone Management Act (CZMA), Forest Service activities and development 

projects that affect the coastal zone must be consistent to the maximum extent practicable with 

the enforceable policies of the Alaska Coastal Management Program (ACMP). The State of 

Alaska has concurred with the Forest Service’s General Consistency Determination (GCD) for 

Tongass National Forest Timber Sales. Under this GCD, all timber harvest and associated 

activities conducted on the Tongass National Forest – except those that require State or Federal 

permits – have been determined to be consistent with the enforceable policies of the ACMP. The 

Wrangell Roadside Timber Sales project does not include any activities that require a State or 

Federal permit. Therefore, the project falls within the scope of the GCD and no individual 

consistency determination is required. 

Magnuson-Stevens Fishery Conservation and Management Act

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

consultation with the National Oceanic and Atmospheric Administration’s National Marine 

Fisheries Service (NMFS) for actions or proposed actions that may adversely affect essential fish 

habitat (EFH). The potential effects of EFH are discussed in the EA in Appendix 2, Essential 

Fish Habitat. Formal consultation with NMFS was initiated with the EA and EFH assessment. 

The EFH assessment found that this project “may adversely affect Essential Fish Habitat”

because the project harvests timber in watersheds that contain anadromous species, log hauling 
Decision Notice

13

would occur on existing roads that cross anadromous fish streams, and the project would 

authorize the use of marine transfer facilities. However, the effects of harvest on freshwater 

aquatic resources and the effects of using MAFs on marine resources are expected to be 

undetectable. Therefore, it is my determination that mitigation via no-harvest buffers and best 

management practices makes it unlikely that any significant adverse effects would occur to 

Essential Fish Habitat by implementing this project.

Executive Order 11988 (Floodplains)

Executive Order 11988 directs Federal agencies to take action to avoid, to the extent possible, 

the long- and short-term adverse impacts associated with the occupancy and modification of 

floodplains.

The project complies with the Forest Plan which excludes timber harvest from sensitive riparian 

areas. No harvest will be authorized in floodplains (considered one component of riparian 

management areas) where commercial harvest is not allowed by the Forest Plan Standards and 

Guidelines. No occupancy or modification to floodplains will occur due to timber harvest.

Therefore, I have concluded that no significant impacts to wetlands or floodplains will occur due 

to timber harvest from this decision.

Executive Order 11990 (Wetlands)

Executive Order 11990 requires Federal agencies to avoid, to the extent possible, the long- and 

short-term adverse impacts associated with the destruction or modification of wetlands.

No new roads will be constructed, and high-value wetlands will be excluded from harvest. 

Dispersed individual tree and group selection harvest is expected to result in minimal change to 

the canopy and associated hydrologic processes. Any on-site processing facilities will be located 

to prevent or minimize impacting wetlands. No measurable effects on fish habitat are expected 

in either alternative; therefore, no significant impacts to fish habitat or wetlands would occur due 

to timber harvest from this decision.

Executive Order 12898 (Environmental Justice)

Executive Order 12898 directs Federal agencies to identify and address the issue of 

environmental justice, i.e., adverse human health and environmental effects of agency programs 

that disproportionately impact minority and low-income populations.

Implementation of the Selected Alternative is not anticipated to cause any adverse human health 

or environmental effects; therefore, I have concluded that implementation of the Selected 

Alternative is not anticipated to cause disproportionate adverse human health or environmental 

effects to minority or low-income populations.

Executive Order 12962 (Aquatic Systems and Recreational Fisheries)

Executive Order 12962 directs Federal agencies to conserve, restore, and enhance aquatic

systems to provide for increased recreational fishing opportunities nationwide.

It is my determination that with the application of Forest Plan Standards and Guidelines, 

including those for riparian areas, no significant adverse effects to freshwater or marine 

resources will occur. Best management practices would be implemented to provide assurance of 

water quality and aquatic habitat protection for all freshwater streams affected by the project.

Any adverse effects to recreational fishing opportunities will be insignificant.
14

Executive Order 13007 (Indian Sacred Sites)

Executive Order 13007 directs Federal agencies to (1) accommodate access to and ceremonial 

use of Indian sacred sites by Indian religious practitioners and (2) avoid adversely affecting the 

physical integrity of such sacred sites. Based on consultations with the appropriate Indian tribes, 

I have determined this project will not affect the integrity of any sacred sites or limit access to 

any sacred sites.

Distribution

The Wrangell Ranger District Roadside Timber Sales Decision Notice, FONSI, and EA are 

available on the internet at http://www.fs.fed.us/r10/tongass/projects/projects.shtml. Notification 

of the availability of the Decision Notice was sent to the project mailing list including State and 

Federal agencies, anyone commenting on the project, and anyone requesting a copy of this 

decision. The project mailing list is available in the project record. The Decision Notice is also 

available in hard copy or on CD, upon request.

A legal notice of the availability of this decision will be published in the Wrangell Sentinel. 

Implementation Date

Implementation of my decision which is subject to appeal pursuant to 36 CFR part 215, may 

occur on, but not before, 5 business days from the close of the appeal filing period. The appeal 

filing period closes 45 days after publication of legal notice of this decision in the Wrangell 

Sentinel, published in Wrangell, Alaska. 
Decision Notice

15

Administrative Review or Appeal Opportunities

This decision is subject to administrative review (appeal) pursuant to 36 CFR Part 215. 

Individuals or non-federal organizations who submit written comments or otherwise express 

interest in this particular action during the comment period specified at 215.6 have standing to 

appeal this decision. The notice of appeal must be in writing, meet the appeal content 

requirements at 215.14 and be filed with the Appeal Deciding Officer:

Forest Supervisor, Forrest Cole

Tongass Supervisors Office, Ketchikan

648 Mission St.

Ketchikan, Alaska 99901

Fax: 907-228-6292 

Email: appeals-alaska-tongass@fs.fed.us

The Notice of Appeal, including attachments, must be filed (regular mail, fax, e-mail, express 

delivery or messenger service) with the Appeal Deciding Officer at the correct location within 45 

calendar days of publication of notice of this decision in the Wrangell Sentinel, the newspaper of 

record for this project. The publication date in the newspaper of record is the exclusive means 

for calculating the time to file an appeal. 

Appeals submitted electronically, including attachments, must be in an electronic format 

compatible with Microsoft Word.

Hand-delivered appeals will be accepted at the Ketchikan Supervisors Office during normal 

business hours (8:00 am through 4:30 pm) Monday through Friday, excluding holidays.

Contact

For additional information concerning this decision or the Forest Service appeal process, contact 

Austin O’Brien, TMA, Wrangell Ranger District, P.O. Box 51, Wrangell, AK, 99929, phone 

number 907-874-2323. 

__________________________________________ ____________

ROBERT DALRYMPLE Date

District Ranger

Wrangell Ranger District
16

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i 

ENVIRONMENTAL ASSESSMENT 

Table of Contents 

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

What Is Being Proposed With This Project? .................................................................. 1

Why Is This Project Being Proposed? ............................................................................ 9

What Factors Will Be Used To Make A Decision On This Project?............................ 11

Who Was Consulted For This Project? ......................................................................... 11

Public Involvement ............................................................................................... 11

How Can We Meet the Purpose and Need? .................................................................. 12

Design Criteria for the Proposed Action ................................................................... 12

What Other Actions Could Meet The Same Need? ...................................................... 15

What Would It Mean Not To Meet The Need? ............................................................ 15

Comparison of Alternatives .......................................................................................... 15

Environment and Effects................................................................................................19

What are the Effects of the No Action and the Proposed Action? ................................ 19

Timber Harvest Management ....................................................................................... 19

Supply and Demand .............................................................................................. 19

Timber Economics .................................................................................................... 20

On-site Log Processing ............................................................................................. 21

Direct and Indirect Effects .................................................................................... 22

Cumulative Effects................................................................................................ 22

Silviculture .................................................................................................................... 23

Direct and Indirect Effects .................................................................................... 23

Cumulative Effects................................................................................................ 24

Transportation ............................................................................................................... 25

Direct and Indirect Effects .................................................................................... 25

Cumulative Effects................................................................................................ 26

Wildlife Species and Old-growth.................................................................................. 27

Direct and Indirect Effects .................................................................................... 27

Cumulative Effects................................................................................................ 29

Subsistence .................................................................................................................... 30

Direct and Indirect Effects .................................................................................... 30

Cumulative Effects................................................................................................ 30

Aquatics ........................................................................................................................ 31

Freshwater Resources ............................................................................................... 31

Direct and Indirect Effects .................................................................................... 32

Marine Resources...................................................................................................... 33

Cumulative Effects................................................................................................ 34

Botany ........................................................................................................................... 35

Direct and Indirect Effects .................................................................................... 35
Table of Contents 

ii

Cumulative Effects................................................................................................ 38

Determination ....................................................................................................... 38

Invasive Plant Species................................................................................................... 38

Direct and Indirect Effects .................................................................................... 40

Cumulative Effects................................................................................................ 40

Inventoried Roadless Areas .......................................................................................... 41

Cumulative Effects................................................................................................ 41

Heritage ......................................................................................................................... 41

Archaeological Analysis and Survey .................................................................... 41

Direct, Indirect, and Cumulative Effects .............................................................. 42

Recreation ..................................................................................................................... 42

Direct and Indirect Effects for All Islands ............................................................ 42

Wrangell Island Recreation....................................................................................... 43

Direct and Indirect Effects to Wrangell Island Inventoried Recreation Places .... 43

Etolin Island Recreation ............................................................................................ 44

Direct and Indirect Effects to Etolin Island Inventoried Recreation Places ......... 45

Zarembo Island Recreation ....................................................................................... 45

Direct and Indirect Effects to Zarembo Island Inventoried Recreation Places ..... 46

Cumulative Effects................................................................................................ 47

Scenery .......................................................................................................................... 48

Direct and Indirect Effects .................................................................................... 48

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

Soils............................................................................................................................... 49

Direct and Indirect Effects .................................................................................... 49

Cumulative Effects................................................................................................ 50

Karst .............................................................................................................................. 50

Direct and Indirect Effects .................................................................................... 51

Cumulative Effects................................................................................................ 51

Wetlands ....................................................................................................................... 51

Direct and Indirect Effects .................................................................................... 52

Cumulative Effects................................................................................................ 52

What Mitigation and Monitoring Is Necessary For This Project? ................................ 52

Appendix 1: Wrangell Roadside Timber Sales EA Implementation Plan ............A1-1

Annual Sale Plan ............................................................................................... A1-1

Environmental Review...................................................................................... A1-2

Process for Consideration of New Information ................................................ A1-6

Appendix 2: Essential Fish Habitat .......................................................................A2-1

Appendix 3: Past, Present, and Reasonably Foreseeable Projects ....................A3-1

Appendix 4: Response to Comments ...................................................................A4-1
1 

ENVIRONMENTAL ASSESSMENT 

Introduction 

The Forest Service has prepared the Wrangell Ranger District Roadside Timber Sales 

Environmental Assessment (WRD Roadside EA) in compliance with the National Environmental 

Policy Act (NEPA) and other relevant Federal and State laws and regulations. The WRD 

Roadside EA discloses the environmental effects of two alternatives: the Proposed Action and 

No Action. A preliminary Finding of No Significant Impact (FONSI) was included in the EA 

when it was distributed for comment in November 2010. 

Additional documentation, including detailed analyses of project area resources, is located in the 

project planning record located at the Wrangell Ranger District Office in Wrangell, Alaska. 

What Is Being Proposed With This Project? 

This project proposes to authorize commercial salvage harvest of dead, dying or blown down 

fuelwood and sawtimber resulting from natural disturbance, and the minor harvest of green 

fuelwood and green sawtimber. This Proposed Action would authorize harvest of up to 500,000

board feet (MBF) of fuelwood and sawtimber per year, depending on demand from the public 

and local operators. Individual green-timber sales size depends on request but would be limited 

to 50 MBF each. The amount of harvest is limited in size, since the purpose of the annual plan is 

to meet the needs of local operators. Harvest activities are proposed to begin in 2011.

The project area for the WRD Roadside EA is the area on either side of existing National Forest 

System (NFS) roads on Wrangell, Etolin, and Zarembo Islands on the Wrangell Ranger District 

as shown on Figures 2 – 5, and within the development land use designations (LUDs) as 

identified in the Tongass Land and Resource Management Plan (Forest Plan). The project area 

does not include non-development LUDs, beach fringe, or 2001 inventoried roadless areas with 

existing roads. All commercial harvest will occur on suitable forest land within the development 

LUDs as specified in the Forest Plan. According to information contained in the GIS database, 

only about 13,378 acres (approximately 30 percent) of the project area is suitable and available 

commercial forest land. 

No new road construction would be authorized in this decision. Figure 1 (below) is a vicinity 

map for the project area. Figures 2, 3, and 4, for each island, show the project area in greater 

detail, including road numbers and LTFs. Figure 5 shows the Forest Plan LUDs for the project 

area islands and surrounding areas. 
2 

Figure 1 - Wrangell Roadside EA Vicinity Map 
Environmental Assessment 

3 

Figure 2 - Project Area on Wrangell Island 
4 

Figure 3 - Project Area on Etolin Island 
Environmental Assessment 

5 

Figure 4 - Project Area on Zarembo Island 
6 

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Environmental Assessment 

7 

Figure 5 - Land Use Designation Map 
8 

Back of 11” x 17” LUD Map
Environmental Assessment 

9 

Why Is This Project Being Proposed? 

The purpose and need for this project is to respond to the following: 

1) Support the local economy. 

Small businesses with limited capital investment resources are typical of the Southeast Alaska 

timber industry. In the past several years, most of the larger mills in Southeast Alaska have 

closed and Wrangell has struggled with economic recession. Recently, the mill in Wrangell 

which was originally built to meet the terms of one of the long-term contracts has been 

dismantled. 

Small timber operators in the Wrangell area are mostly self-employed. They typically hire one 

to five employees on an as-needed basis. Implementation of this project would create many 

opportunities suitable for these remaining businesses and provide economic relief for local 

communities, small business operators, and individuals on Wrangell Island by providing a 

steadier annual supply of timber. 

One of the goals of the USDA Strategic Plan FY2010 – 2015 is to “Assist Rural Communities to 

create Prosperity so they are Self-sustaining, Repopulating and Economically Thriving”. As part 

of this, the Alaska Region began in May 2010 to develop a Transition Framework program to 

build upon current assets and economic sectors and develop other opportunities. This project 

would be part of that by supplying multiple small sales that would provide the raw materials for 

a variety of wood products such as lumber, fuelwood, cedar shakes, and wood for artistic and 

musical pursuits. 

2) Maintain a safe travel route while providing opportunities for small sales. 

Part of road maintenance is to ensure that there are no „hazard‟ trees along roads that could fall 

on the roadbed and either seriously injure or block traffic flow. These trees are routinely 

removed as necessary due to decay or blowdown. Part of the purpose of this EA is to 

aggressively assess any trees within this category and provide them as opportunities either for 

sawtimber or fuelwood. Another benefit for safety is the road maintenance required of the 

operator during a sale, which includes collection for surface rock replacement. 

3) Promote forest health. 

Forests in Southeast Alaska are a host to various insects and diseases. Many of these are part of 

the ecosystem, but others can reach proportions where they can cause damage and not allow the 

development of young healthy trees. By removing some of the diseased trees, or trees that have 

blown down, other trees remain healthy and young trees can become established. 

4) Provide a supply of fuelwood to support both local small operators and personal 

firewood users’ needs. 

The recent substantial increases in home heating fuel costs have resulted in a noticeable increase 

in demand for locally cut firewood. Firewood users have reported it is increasingly difficult to 

get enough firewood to meet the needs of the community. Based on comments from the public, 

the demand currently exceeds the supply being offered, and competition for this resource is 

expected to increase. 
10

Currently, both personal-use and commercial firewood cutters can only remove dead trees (either 

standing or downed). Commercial operators that have permits can obtain dead and downed 

firewood along any open road system on Wrangell Island except the first 100 feet along the Pat‟s 

Creek and Nemo Loop road systems (green firewood is not available). Personal-use cutters can 

go anywhere on the open road system. This project would increase the amount of fuelwood 

available by expanding commercial fuelwood harvest to include dying and low-grade green 

trees. Offering commercial green fuelwood sales would reduce the competition that currently 

exists between commercial and personal-use firewood cutters by offering the commercial sales in 

specific areas.

5) Provide a supply and capture the economic value of salvage timber in an efficient and 

timely manner. 

The WRD Roadside EA project consolidates multiple small-sale harvest activities under one 

analysis and uses the implementation plan, so resource managers could respond to requests in a 

more time efficient and cost-effective manner while managing the resource (Forest Service 

Handbook [FSH] 2409.18). It also allows for scheduled program of small sales and firewood 

sales. Due to the conditions in Southeast Alaska, some species deteriorate quickly and cannot be 

used for valuable products and their value for fuel wood diminishes. Due to reduced budgets and 

personnel, there is not always the opportunity to complete the required analyses before this 

happens. 

6) Provide green sawtimber for small sales. 

By consolidating multiple small-sale harvest activities under one analysis, the Forest Service can 

conduct a more-efficient environmental analysis, thereby meeting public demand from local 

operators for a small number of green trees in a timelier manner. These small sales would 

provide revenue to those purchasing the wood, since unlike the Alaska resident free-use program 

which does not allow the operator to sell products from the trees, the products can be sold. 

Identifying these sales in advance would reduce conflicts with that program. 

7) Respond to the goals and objectives of the Tongass National Forest Land and Resource 

Management Plan (Forest Plan) and help move the project area towards conditions 

described in that Plan. 

All development (Timber Production, Modified Landscape, and Scenic Viewshed) LUDs in the 

project area include the goal to “seek to provide a supply of timber that meets the annual market 

demand, consistent with the standards and guidelines for the LUD”. The Timber Production and 

Modified Landscape LUDs also include the goal “to maintain and promote wood production 

from suitable forest lands, providing a continuous supply of wood to meet society‟s needs” 

(USDA 2008). This project would respond to those Forest Plan goals and objectives. 
Environmental Assessment 

11

What Factors Will Be Used To Make A Decision On 

This Project? 

Based on the environmental analysis in this EA, and following the goals, objectives and desired 

conditions outlined in the Forest Plan, the Responsible Official will decide whether and, if so, 

how to make timber available from the WRD Roadside EA project area. 

This decision will include: 

Whether to authorize the harvest of salvage dead/dying and down trees that occur from 

natural causes; 

Whether to authorize the harvest of green and dead/dying fuelwood; 

Whether to authorize the harvest of sawtimber; 

What, if any, specific mitigation measures are needed; and 

What, if any, monitoring requirements are needed beyond the Forest Plan monitoring 

plan to ensure that established design criteria are implemented. 

Who Was Consulted For This Project?

Public Involvement 

In response to public interest concerning firewood availability, the Wrangell Ranger District held 

a meeting in April 2008 to gather input on increasing the availability of both commercial and 

personal-use firewood, and opportunities to minimize conflicts between each group. The 

meeting was attended by over 25 individuals interested in Forest Service efforts to increase 

firewood availability. One of the recommended actions from the meeting was to begin offering 

commercial green fuelwood sales on the existing road systems. The Wrangell Roadside project 

is being proposed as a direct result of the concerns and recommendations brought forth during 

this public meeting. 

The Wrangell Roadside project has been listed in the Schedule of Proposed Actions since 

January 2009. The proposal was provided to the public and other agencies for comment during 

scoping in January 2009. The Forest Service received six comments on this project, all in favor 

of the proposal, requesting increased availability of small sales and giving priority consideration 

to firewood for personal users on Wrangell Island. 

In addition to the public, the Forest Service consulted the following Federal, State, and local 

agencies, and tribes during the development of this EA:

Federal, State, and Local Agencies 

National Marine Fisheries Service 

Alaska Department of Environmental Conservation 

Alaska Department of Fish & Game 

Federally Recognized Tribes 

Wrangell Cooperative Association 
12

How Can We Meet the Purpose and Need? 

Based on the comments from the public, other agencies, and a local tribal organization, the 

Deciding Official determined that the key issue was how to offer an accessible, more-readily 

available supply of fuelwood and timber for personal users, local small operators, and wood 

product industries. Therefore, only two alternatives are being considered: the No-action 

Alternative and the Proposed Action. 

The Proposed Action would authorize salvage harvest of dead, dying or down fuelwood and 

sawtimber resulting from natural disturbance. It would also authorize the harvest of minor 

quantities of green fuelwood and green sawtimber. The combined volume would not exceed 

500,000 board feet (MBF) per year. The volume would be offered as multiple salvage sales, 

fuelwood, small sales, and microsales within development LUDs along the existing road systems 

of Wrangell, Zarembo and Etolin Islands on the Wrangell Ranger District. By analyzing these 

similar types of sales in this EA, with additional site-specific analysis following the guidelines of 

the implementation plan, the Forest Service would be able to respond to requests and authorize 

small sales more efficiently. 

Design Criteria for the Proposed Action 

The specific locations of actual harvest areas would be identified by Forest Service personnel or 

based on proposals made by prospective purchasers. These proposed timber sales would then be 

included on an annual proposed sale plan (Appendix 1). All proposals will follow the guidelines 

established in this EA, the Forest Plan, and all applicable direction. The annual proposed sale 

plan will include a brief narrative of each sale and a summary sheet of all sale proposals with 

acres, volume, type of sale and whether requested by a purchaser and other comments. The 

approved annual sale plan will be posted on the public website and be available at the Wrangell 

Ranger District Office. 

All commercial harvest activities authorized under this project will meet the following design 

criteria. See also Table 1, below.

Applicable to any harvest: 

Harvest would only occur in areas where Forest Plan land use designations (LUDs) allow 

timber harvest (Forest Plan, pages 3-101 to 3-121), namely Timber Production, Modified 

Landscape, and Scenic Viewshed; 

Harvest would only occur in areas suitable for timber harvest; 

Harvest would be within 1,200 feet on either side of existing road; 

No harvest would be authorized in the beach or estuary fringe, riparian management 

areas, unstable slopes or other areas where commercial harvest is not allowed by the 

Forest Plan Standards and Guidelines, or in 2001 inventoried roadless areas; 

No road construction would be needed for timber harvest; 

On-site processing may be allowed for some sales; and 

Projects would be implemented using the WRD Roadside EA Implementation Plan 

contained in Appendix 1. 
Environmental Assessment 

13

Applicable to salvage of dead, dying or down trees: 

Salvage harvest would be authorized to remove down or dead timber in accordance with 

page 4-73 of the Forest Plan (VII. Salvage Harvest, parts A, B, D, E, and F); and

Incidental green trees may be removed. 

Applicable to green tree harvest: 

Single-tree selection or group selection sawlog sales would be limited to a maximum of 

50,000 board feet (50 MBF) per sale. 

Green fuelwood sales would include non-merchantable, low quality, or dying trees; sales 

would be limited to a maximum of 50,000 board feet (50 MBF) per sale. 

Harvest in any individual stand would be limited to 33 percent of the average trees per 

acre with 67 percent retained for stand structure and wildlife habitat. 
14

Table 1 - Proposed Sale Types 

Sale type --------> Commercial

dead/down firewood

Salvage sawtimber Commerical green 

fuelwood1

Microsale Green sawtimber

Rx Single-tree selection Salvage Partial cut Single-tree selection Single-tree selection

or group selection

Retention N/A N/A Average 67% of trees 

per acre

N/A N/A

Type of tree Individual standing 

dead or down, can 

include landing slash 

left from previous 

harvest

Dead or blowdown 

salvage2

Green or dying trees

not meeting sawlog 

quality standards

Requested tree(s), 

generally 1-2 dead or 

down trees

Green trees or groups

meeting sawlog 

quality standards

Sale size limit3

50 MBF 50 MBF450 MBF 50 MBF 50 MBF

Example

products5, (not 

limited to this list.) 

Fuelwood (includes 

firewood, wood 

pellets, wood bricks)

Lumber and fuelwood Fuelwood (includes 

firewood, wood 

pellets, wood bricks)

Lumber, cedar bolts, 

canoes, totem, cedar 

shakes, music wood

Lumber

1

 Incidental removal of green trees only for operational access, safety, or to remove trees facing imminent mortality in next 5 years from natural causes. 

2

 Fuelwood includes firewood, wood pellets, and wood bricks. 

3

 The combination of all harvest along the roadside would not exceed 500 MBF per year. 

4

 Size is dependent on type of salvage opportunity but would not exceed 500 MBF per year. 

5

 In most cases, some processing will be done in the woods. The amount of in the woods processing will depend on the type of product produced and site 

conditions. 
Environmental Assessment 

15

What Other Actions Could Meet The Same Need? 

As an alternative means of meeting the demand for additional accessible timber and fuelwood 

through this project, the Forest Service would have to increase the small sales program and issue 

more firewood permits, conducting a separate NEPA analyses on each sale. This would cause an 

increased workload and longer delays, and thus may not adequately meet the need since the 

workforce on the Tongass has been decreased in response to lower budgets for the timber 

program. This option is the No-action Alternative, which is described below. Another means of 

meeting the demand for timber and fuelwood could be through larger-scale harvest programs 

such as roadside units from EISes. This could also result in delays due to the additional time it 

takes to complete an EIS and move through the process of appeals and possible litigation for 

these larger projects. 

Table 1 displays the types of harvest that could occur each year, dependent on the need and 

request of prospective purchasers. Not all harvest types would necessarily occur each year. 

What Would It Mean Not To Meet The Need? 

Not meeting the need is defined by the No-action Alternative. Under the No-action Alternative, 

current management plans would continue to guide management of the project area. Current and 

ongoing management activities conducted as part of past environmental document decisions 

would continue to occur (i.e. precommercial thinning, road maintenance and timber harvest). In 

addition: 

Resource managers would be limited in their ability to provide a predictable and steady 

supply of salvage timber and fuelwood and green sawtimber to support local small 

operators and wood product industries. 

Resource managers would lose the opportunity to respond quickly to salvage timber 

opportunities and capture the economic value of the timber. 

There may continue to be conflicts between commercial and personal fuelwood gatherers 

due to increasing competition for a limited supply. 

There would not be the opportunity to support the local economy. 

The costs incurred in the individual NEPA analysis for small sales would be higher, since 

multiple analyses would be conducted. 

Comparison of Alternatives 

The direct, indirect, and cumulative effects of implementing either alternative would in most 

cases be similar, as described in the respective resource sections. There are little or no direct and 

indirect effects for the No-action Alternative. There are also little or no direct effects for the 

Proposed Action, due to the limited annual volume (not exceeding 500 MBF) of partial harvest 

and salvage harvest, spread across three islands. Indirect effects of the Proposed Action are 

expected to be minor and/or temporary. 
16

Cumulative effects are also similar between the No-action Alternative and the Proposed Action. 

While other projects are planned in and near the WRD Roadside EA project area, this project 

contributes very little to any cumulative effects. Direct, indirect, and cumulative effects are 

compared for the No-action Alternative and the Proposed Action under the effects section of the 

resource analyses in this EA. 

Table 2 - Comparison Table – Direct and Indirect Effects 

Resource No Action Alternative Proposed Action

Aquatic No effect Little to no effect

Heritage No effect No effect

Invasive plant species Existing activities involving road 

use could continue to spread 

invasive species to some degree in 

the project area, whether or not 

this project is implemented.

Slight increased risk of introducing 

and spreading invasive plant species 

in the project area; however, this 

project is not expected to have a 

significant effect on invasive species 

populations or the habitats affected by 

them, individually or cumulatively.

Botany: sensitive and rare plants No effect May adversely impact individuals, but 

is not likely to result in a loss of 

viability in the planning area, nor 

cause a trend toward Federal listing

Wildlife: migratory birds Individuals would not be affected, 

or would be affected by natural 

circumstances. No measurable 

consequences to the individuals or 

populations are expected. 

Harvest of nest trees used by 

migratory birds during the breeding 

season may result in lowered 

reproductive success for individuals; 

however, these effects are not 

expected to contribute to a loss of 

population viability on Tongass NF 

for any species.

Wildlife, MIS species: Alexander 

Archipelago wolf, American 

marten, black bear, brown bear, 

red squirrel, Sitka black-tailed 

deer, pink salmon, coho salmon, 

Dolly Varden char, cutthroat 

trout, endemic small mammals

Individuals would not be affected, 

or would be affected by natural 

circumstances. No measurable 

consequences to the individuals or 

populations are expected. 

Animals such as deer or bears may be 

displaced during the duration of the 

activities. One or more individuals 

would be affected but the change 

would be small. Effects would not be 

expected to have any long-term 

effects on species or their habitats, or 

the natural processes sustaining them.

Wildlife, MIS species: bald 

eagle, mountain goat, river otter, 

Vancouver Canada goose

Individuals would not be affected, 

or would be affected by natural 

circumstances. No measurable 

consequences to the individuals or 

populations are expected. 

Individuals would not be affected, or 

the action would affect an individual 

but the change would be so small that 

it would not be of any measurable or 

perceptible consequence to the 

individuals or populations. 
Environmental Assessment 

17

Resource No Action Alternative Proposed Action

Wildlife: POG, coarse canopy 

and habitat connectivity

Change would be so small that it 

would not be of any measurable or 

perceptible consequence to 

individuals or populations. 

One or more individuals would be 

affected but the change would be 

small. Effects would not be expected 

to have any long-term effects on 

species or their habitats, or the natural 

processes sustaining them.

Wildlife, sensitive species: 

Aleutian tern, dusky Canada 

goose, Island king salmon, Fish 

Creek chum salmon, northern 

pike, black oystercatcher, 

Kittlitz‟s murrelet

No effect (species are not present) No effect (species are not present)

Wildlife, sensitive species: 

Queen Charlotte goshawk

Individuals would not be affected, 

or would be affected by natural 

circumstances. No measurable 

consequences to the individuals or 

populations are expected. 

May impact individuals but not likely 

to cause a trend to Federal listing or a 

loss of viability 

Subsistence: deer and fuelwood Deer: No change in abundance 

and distribution of, access to and 

competition for deer. 

Firewood: Abundance of, access 

to, and competition for are likely 

to increase.

Deer: No change in abundance and 

distribution of, access to and 

competition for deer. 

Firewood: An improvement in 

availability of commercial firewood, 

and less competition for firewood. 

Subsistence: other resources No change in abundance and 

distribution of, access to and 

competition.

No change in abundance and 

distribution of, access to and 

competition. 

Threatened or Endangered 

Species: Steller sea lion, 

humpback whale

Individuals would not be affected, 

or would be affected by natural 

circumstances. No measurable 

consequences to the individuals or 

populations are expected. 

Not likely to adversely affect. 

Potential indirect effects could include 

disturbance due to increased boat or 

barge traffic. However, routes

between islands where harvest may 

occur do not intersect any areas where 

these species are known to 

congregate. 

Recreation No effect Potential temporary traffic delays or 

increased traffic, temporary noise 

associated with harvest activities in 

vicinity of active sale.

Karst No effect Little to no effect

Soils No effect Little to no effect: Some soil 

disturbance is expected from logging 

activities; the amount will not exceed 

the Regional soil quality standard. 
18

Resource No Action Alternative Proposed Action

Wetlands No effect Little to no effect: Some ground 

disturbance is expected from logging 

activities which could alter hydrologic 

conditions. Timber harvest on 

wetlands is expected to result in 

minimal change to the canopy and 

associated hydrologic processes.
Environmental Assessment 

19

ENVIRONMENT AND EFFECTS 

What are the Effects of the No Action and the 

Proposed Action? 

This section displays the physical, biological, social and economic environments of the affected 

project area and the potential changes that may occur from implementing this project. 

Much of the project area has been analyzed in other NEPA documents or will be included in 

future projects (Appendix 3). Where applicable, information from previous NEPA documents is 

incorporated into this analysis. The projects and activities listed were considered in the 

cumulative effects analysis for each resource. 

The resource reports included the area within 1,320 feet from all project area roads. However, 

the Secretary has reserved the authority for decisions within 2001 roadless areas until a longterm roadless policy can be determined. Therefore, this project will only include the area 1,200 

feet from the existing road, to be consistent with the roadless inventory. The effects as discussed 

in this EA would be the same or somewhat less than those disclosed in the resource reports. 

Timber Harvest Management 

Supply and Demand 

Information from local small sale purchasers, and data collected from public meetings, the 

Wrangell Island Analysis, and Wrangell Ranger District small sale records generally support the 

desire and need for smaller roadside-based sales. 

Small local timber operators in the Wrangell area are mostly independent and self-employed. 

These operators generally do not have year-round employees; rather, they hire one to five 

employees on an as-needed basis. 

Through the small sales program on the Wrangell Ranger District since 1997, the district has 

offered and sold approximately 3 MMBF in 19 small salvage and green-tree sale offerings 

ranging in size from 5 to 662 MBF, indicating consistent demand. Small operators generally do 

not have a need for the quantity of wood offered in a larger timber sale, nor do they have the 

equipment or financial backing necessary to purchase one. 

The Forest-wide demand for timber from the Tongass has been addressed in the 2008 Forest 

Plan, Appendix G. The annual market demand is calculated yearly and was 211 MMBF in FY 

2010. A complete “Appendix A” has been included in the project record. 

Firewood is also an important resource for Wrangell residents. Dead yellow-cedar is the most 

preferred type of firewood. There has been increasing public concern that commercial firewood 

cutters are competing with local residents for firewood. Despite the fact that local commercial 

firewood cutters sell firewood exclusively to Alaska residents, because it is a commercial 

enterprise, it is still not considered personal use. 
20

Timber Economics 

The main factors that influence the economic value of timber sales are logging systems, length of 

haul to the nearest manufacturing centers, road construction, and proposed timber management 

including quantity and quality of timber. 

Yarding is the process of moving logs from the stump to a centralized landing area. The systems 

proposed to be used to bring logs to the landing area are ground-based, cable and helicopter. 

Selection of the systems used to harvest timber depends on many factors such as topography, 

access, slope and resource protection requirements. 

Logging Systems 

On-site ground reconnaissance following the guidelines in the Implementation Plan will 

determine that proposed logging systems provide the required resource protection measures to 

meet management objectives and desired conditions of each LUD. To insure that all 

management objectives are met, this project has developed a monitoring plan that will review 

some of the implemented harvest proposals for compliance with specified management 

objectives. Effects resulting from logging systems are also discussed in the Soil and the 

Wetlands resource sections. 

Since all harvest activities in the project area are along existing road, conventional cable and 

ground-based yarding systems would primarily be the most economical and efficient logging 

methods used for harvesting timber in the project area. Depending on resource protection needs, 

requirements for partial- or full-log suspension could be required. 

Helicopters may be used for yarding some harvest areas where conventional yarding systems 

may not be the most efficient system, or where factors such as topography, slope or other 

resource concerns dictate the use of helicopter systems. However, this system would require that 

the proposed harvest contain a species mix and composition with high commercial values and 

relatively high volume per acre. The majority of anticipated helicopter use would be to support 

on-site processing activities. 

Compared to even-aged management, uneven-aged management prescriptions generally incur 

higher costs for harvesting timber due to the overall reduction in volume per acre and increased 

costs of yarding around residual trees. Generally, the higher amount of residual trees left in a 

stand, the higher the cost for harvesting of designated trees. However, removing higher-quality, 

more-valuable timber can offset the increased cost of harvesting designated trees. 

Financial Efficiency Analysis 

No financial efficiency analysis is required by Forest Service Handbook 2409.18. The projected 

value of this project is not anticipated to exceed $100,000 because of the size of the sale 

offerings. Therefore, each sale will be appraised according to Forest Service Handbook 

direction. 

Competition for Resources 

Past, present, and future timber harvest projects in this area may have reduced opportunities for 

firewood gathering to some degree. However, much firewood gathering occurs in scrub timber 

and muskeg areas. Furthermore, roads built in association with past, present, and future timber 

sales have increased access to firewood-gathering locations. Recent and foreseeable future road 

closures associated with the Wrangell Ranger District Access and Travel Management Plan 
Environmental Assessment 

21

(ATMP) will reduce this access over time. While concerns have been raised about competition 

between subsistence users and commercial firewood cutters, the intent of this project is to 

alleviate competition by providing alternate locations and sources for commercial operators. 

The implementation of this project could affect abundance, distribution, and competition for 

fuelwood. Most local users do not travel to other islands to gather fuelwood. By focusing 

commercial firewood sales away from dead trees and/or away from Wrangell Island, the reduced

competition could provide more plentiful fuelwood gathering opportunities for personal users. 

At this time, however, restricting availability or access is not proposed in this project. Instead, 

allowing commercial permit holders to cut dying/green fuelwood trees, as proposed in this 

project, could increase the overall availability of fuelwood for both commercial and personal 

users. 

Because there are no road changes authorized as part of this project, it will not affect access 

through opening or closing of roads. 

On-site Log Processing 

The Proposed Action includes on-site log processing in some areas. The type of sale, the 

products produced, individual purchaser preference, and environmental considerations will 

influence if and how much on-site processing will be permitted. 

Fuelwood 

Fuelwood processing involves felling (if trees are standing), yarding the designated trees to the 

road, cutting, and splitting the rounds into saleable-sized firewood. The effects from this type of 

processing are mostly sawdust and wood debris generated from the yarding, cutting, and splitting 

activities. Standard timber sale contract provisions require the purchaser to remove wood debris 

from ditches and the road surface. 

Lumber 

Sawlogs (green and salvage) are sawn into lumber either in the woods or at a designated 

location, such as a nearby rock pit. Processing in the woods is accomplished with portable type 

sawmills that are carried, skidded, or flown in by helicopter. Once the sawlogs are milled in the 

woods, the lumber products are carried, skidded, or flown out by helicopter to the road. The 

effects of on-site processing operations are mostly noise from the saws, sawdust accumulation, 

and log slab residue. Milling residues are scattered on-site for decomposition, burned in rock 

pits, or hauled away to an approved disposal area. 

Music Wood and Shake Bolts 

The on-site processing methods for both music billets and blocks and shake bolts are similar in 

nature. Typically, the tree will be felled and bucked to length using a chainsaw. The bucked 

sections are then split into billets, blocks, or bolts using hand tools such as mauls, wedges and 

froes. The split material is then hand carried, zip-lined, or flown out to the road using helicopter 

cargo nets. The effects from this type of processing would be sawdust accumulation and nonmerchantable wood residue produced during the breakdown splitting. 
22

Direct and Indirect Effects 

Both alternatives have short- and long-term effects on timber supply and demand. Volume made 

available through implementation of the Proposed Action would contribute to meeting the local 

demand for timber in the short term. 

No Action 

This alternative represents no management actions at this time. Forest lands located elsewhere 

would need to be harvested to meet local market demand for timber and fuel/firewood. The 

economic value would not be captured through the removal of dead or dying trees. Sales to 

smaller operators may be delayed through the NEPA process. 

Implementation of this alternative would not contribute to meeting the local demand for 

sawtimber and fuelwood, negatively affecting small operators and the public who may purchase 

fuelwood or cut their own firewood for home heating. Less readily available fuelwood could 

result in greater competition or more difficulty obtaining it. 

Proposed Action 

The Proposed Action would make timber available for harvest, would positively affect small 

operators, and would contribute to meeting the local demand for sawtimber and fuelwood. The 

timber offered would generally be sold as Special Salvage Timber Sales and Small Business 

Administration sales. This volume, up to 500 MBF per year, would help meet a portion of the 

small operators‟ estimated annual demand for timber. It would also increase the availability of 

firewood for personal use by allowing commercial harvest of green fuelwood, reducing 

competition between personal and commercial users for available dead and down wood. 

Cumulative Effects 

The long-term supply of timber would be minimally affected by the amount of suitable acres 

harvested during this entry into the project area. Implementation of the Proposed Action would 

result in a slight increase in suitable acres harvested over time in the project area. Due to the 

type of salvage and partial-cutting activities prescribed, and the variable levels and effects of 

natural disturbance events and damaging agents in the project area, some stands could potentially 

receive multiple intermediate treatments over the course of the rotation. Stands that receive 

intermediate treatments and retain higher percentages of the original stand structure would still 

function as productive old-growth forest and will remain as part of the suitable acres land base. 

Conclusion 

Implementation of the Proposed Action would benefit the public by making sawtimber and 

fuelwood available from the project area. Timber harvest would result in revenue for the 

Treasury and the support of local jobs. Allowing harvest along the existing road system in the 

project area would minimize logging costs by facilitating the use of less-expensive shovel and 

short-span yarding systems. 
Environmental Assessment 

23

Silviculture 

Vegetation within the project area is a mosaic of coniferous forest intermixed with alpine, 

muskeg, riparian, and shrubland plant communities. Hemlock and Sitka spruce forests occur on 

well-drained sites in this subsection. Mixed conifer forest types occupy areas where drainage is 

restricted. Open shrubby bogs and ferns occur on the wettest portions of the project area. The 

majority of the stands proposed for harvest under this EA are located along the lower-elevation 

transition zones between well-drained Western Hemlock/Sitka Spruce sites and restricteddrainage Mixed Conifer sites. 

Direct and Indirect Effects 

No Action 

Disturbance processes would continue, including gap-phase, small-scale disturbance as well as 

stand-replacing wind-generated stand re-initiation. Some high wind-hazard stands are likely to 

experience large-scale stand-replacing events in the future, resulting in more structure in the 

early, even-aged stage of development. Other stands will likely experience moderate disturbance 

resulting in more two-aged structure. Forest growth and yield would not be maximized or 

improved. Forest health would not improve; insect damage, disease, and cedar decline are likely 

to continue and spread at their present levels and rates. 

Proposed Action 

The Wrangell Roadside project would result in annual harvest on approximately 0.004 to 0.08 

percent of the original productive forestland on the three islands, depending on the regeneration 

method and harvest retention. (Productive forestland includes young stand size classes 1-3, as 

well as the old saw timber trees stand size class 4 and greater which constitute productive old 

growth (POG). Historically, all productive forestland was considered to be POG.) 

The combination of even-aged and uneven-aged regeneration harvests in this alternative includes 

both the salvage of dead and dying trees, and green-tree harvest. Estimated harvest acreages 

were developed based on the number of acres required to achieve the 500 MBF harvest using 

even-aged and uneven-aged harvest. 

Uneven-aged management is limited to the removal of up to 33 percent of the trees per acre in 

fuelwood sales which can improve forest health by harvesting diseased and insect damaged trees. 

Green sawtimber sales will use group selection or single-tree selection as uneven-aged harvest 

methods. Forest health concerns, including the removal of trees with disease, damage, or that 

face imminent mortality, can be used as factors in determining which trees to harvest. 

Removal of trees in groups would result in small openings of 2 acres or less that would 

regenerate to healthy young-growth trees. Removal of trees dispersed throughout the stand 

would result in old trees interspersed with regeneration of younger trees. If all harvest in a year 

was uneven-aged, this would treat up to an estimated 239 acres annually, depending on how 

much volume is harvested. Uneven-aged harvested stands will retain stand structure and species 

composition at levels high enough to maintain function as productive old-growth and remain as 

part of the suitable land base. 

Even-aged management will be used for salvage operations to remove dead standing or down, 

or dying trees, created by insect infestations, disease outbreaks, or windthrow. Incidental green 
24

trees may also be removed for access, safety, operational feasibility, or to remove dying trees or 

trees facing imminent mortality due to natural disturbance processes. The primary reasons for 

prescribing even-aged harvest in this project are to minimize the occurrence of potentially 

adverse effects from windthrow, and to rehabilitate lands adversely affected by windthrow. This 

is estimated to treat up to 24 acres annually, if all harvest in a year was even-aged. 

Additional blowdown would be minimized, to the extent practicable, by locating the boundary 

along the edges of natural openings, areas containing naturally windfirm trees, or in moreprotected areas, such as small draws. 

Species Composition Structure and Health 

Given the amount of harvest applied over the project area, the overall post-harvest tree species 

composition on the islands would remain relatively the same as the pre-harvest overstory tree 

species composition. 

Forest health and productivity would be improved by the removal of dead trees created by 

windthrown trees and insect damage, creating younger, healthier, faster-growing forests. The 

harvest openings will provide space for shade intolerant yellow-cedar to naturally regenerate and 

maintain the presence of healthy yellow-cedar in the project area. Forest growth, yield, and 

long-term soil productivity would be enhanced. The Proposed Action is consistent with the 

Forest Plan, management direction, and the National Forest Management Act (NFMA). 

Cumulative Effects 

The analysis area for cumulative effects consists of Wrangell, Etolin, and Zarembo Islands. 

Timber harvest first began in 1913 along the beach fringe and large-scale even-aged harvests 

along roads began in the 1960s. Currently, about 29,398 acres (or 12.3 percent) of the 

approximately 239,397 acres of productive forestland originally on the islands have been 

harvested and successfully regenerated with young-growth timber, including 1,796 acres in nonfederal land ownerships. 

Reasonably foreseeable future projects were determined by assessing those projects that are 

currently being implemented, such as a timber volume under contract, those projects that have 

NEPA decisions, and those projects with on-going NEPA analysis. This is includes 11 NEPA 

projects involving timber harvest on the three islands. A State timber sale called the Zarembo 

Island Sale, near St. John‟s Harbor and consisting of approximately 420 acres of harvest, was 

sold and is planned to be logged on Zarembo Island in 2011. Other forest harvest activities 

include personal-use firewood cutting (dead trees only), permit-based commercial firewood 

cutting (dead trees only), and free-use green sawtimber program available to Alaska residents. 

All of the past harvested stands on Wrangell, Etolin, and Zarembo Islands have been successfully 

regenerated. According to the Forest Service Activity Tracking System, by 2009 about 11,812

acres of young-growth precommercial thinning had occurred on the islands (including thinning 

for wildlife habitat improvement, research, or timber production), plus there have been 317 acres 

of young-growth pruning and 4,509 acres of tree planting on the three islands. Approximately 

2,500 acres of precommercial thinning is planned for the next 5 years. The cumulative effects of 

past, present, and reasonably foreseeable future actions would have little effect on forest longterm yield and productivity, regeneration, or species composition. 
Environmental Assessment 

25

Transportation 

The existing Wrangell Ranger District forest road system is managed under the 2007 Wrangell 

Ranger District Access and Management Plan (ATMP). No additional roads will be constructed 

under the WRD Roadside Timber Sales EA. 

Use on some roads may be authorized by a permit for management associated with this project, 

as directed in the Code of Federal Regulation [CFR] Title 36 Section 212. 

Zarembo Island: The Zarembo Island road system is accessed by two log transfer facilities 

(LTFs) - one in St. John Harbor and the other in Deep Bay. Both LTFs serve the island‟s road 

system. Some roads are not included in the current Proposed Action since they are within the 

2001 Roadless Rule inventory. 

Etolin Island: The LTFs in Anita Bay would be used to access the Anita Bay road system. The 

proposed road construction for the Navy Timber Sale project area is not part of this project since 

these roads are only proposed and not constructed. The road system from the Honeymoon LTF 

on the north end of the island is not included since it is within the 2001 Roadless Rule inventory. 

Wrangell Island: The Wrangell Island road system is connected to the community of Wrangell, 

including local sawmill operations. There are two LTFs located on Wrangell Island - Pats Creek 

and Earl West. 

Maintenance 

Maintenance and reconditioning of existing National Forest System (NFS) roads is an ongoing 

process that occurs on a periodic basis. Usually this road work is determined to fit the category 

of routine repair and maintenance of roads that do not individually or cumulatively have a 

significant effect on the quality of the human environment and may be categorically excluded, as 

directed in FSH 1909.15, Section 31.1b. The maintenance and reconditioning of NFS roads on 

the project area may occur before, during and after the project analysis and implementation. The 

timing of this work may coincide with this project's analysis but is not part of the Proposed 

Action. This work is done by the Forest Service or through separate service or public works 

contracts to reduce the backlog of deferred maintenance. Road maintenance is performed to 

comply with best management practices, maintain the existing infrastructure for the proposed 

timber sales or future harvest entries, and other National Forest management activities. 

As timber is sold as part of this project, cost collections for maintenance and surface rock 

replacement (where applicable) will take place. The collections offset the cost of road 

maintenance due to timber hauled over the roads. 

Direct and Indirect Effects 

The Proposed Action does not consider changing the maintenance levels (ML) for any road. Nor 

does this project propose new road construction. Maintenance will continue to be performed, as 

needed, according to the district road maintenance plan. 

Since the Forest Service is able to collect a reimbursement for maintenance, this project will not 

have an effect on the Forest Service‟s ability to maintain the roads within the analysis area. 

On-site processing may occur as part of a timber sale. This may involve processing wood along 

the roadside, within the unit, or in a rock pit. Permit stipulations will govern the activities and 
26

provide guidelines for a complete clean-up. This type of small-scale processing will not affect 

the transportation network or Forest Service maintenance costs. 

Log Transfer Facilities 

There are two basic methods of transferring logs to a mill site: hauling logs overland by trucks 

or hauling logs by water via an LTF. It is anticipated that logs harvested on Wrangell Island 

would be hauled overland. However, existing LTFs may be used to transport logs to mill sites in 

other areas. Logs on Etolin or Zarembo Islands may be transferred to a barge or water at an LTF 

and subsequently taken to a mill site or the LTF may be used to move already processed products 

if on-site processing occurs. 

At the Anita Bay North LTF on Etolin Island, there is a proposal to widen the lower barge ramp 

and widen the roadway between the current parking lot (old campsite) and the Anita Bay North 

LTF. This will enable small operators to use the lower barge ramp for loading logs. The steep 

slope between the parking lot and LTF will be reduced to a more moderate slope, which will 

reduce the chances of cut-slope erosion. The design for this project is complete, but it is waiting 

for funding. This project will most likely be completed in the next few years but due to the 

present funding situation, it is impossible to predict exactly when the construction will occur. 

These changes may potentially have a positive effect on purchasers who are moving wood to 

their vessels. 

The effects of using LTFs under this EA would be minimized due to existing permit regulations 

and monitoring requirements. Which, if any, LTFs are used would depend on the purchaser of 

the timber sale and where the timber would be processed and sold. 

Cumulative Effects 

The area considered for cumulative effects on the transportation system was the project area. 

The project area encompasses the road systems described in the existing condition. The 

transportation system for this project is multimodal; both roads and waterways would be used 

extensively for transportation. 

A road-resurfacing project for the 6265 Road on Wrangell Island is expected to be completed by 

mid-summer 2011. The contractor for this project must allow traffic to pass through the 

construction zone. Although short delays may occur, this project will not affect potential timber 

management activities associated with the WRD Roadside EA. 

A reconstruction project for a 4-mile section of the 6267 Road on Wrangell Island is expected to 

be completed by mid-summer 2011. The project would replace the failing wood-waste base with 

shot rock since the existing wood base is too weak in this road segment to support log haul in its 

current condition. Minor realignments may occur to reduce the amount of rock needed to 

reconstruct the road. This project will have a positive effect on potential management activities 

in this area by allowing future log haul after the reconstruction. 

Other timber sales are occurring or will occur at the same time as potential sales resulting from 

the decision on this project. These sales will utilize existing roads and provide maintenance in 

accordance with use. These projects may be conducted at the same time as management 

activities associated with the WRD Roadside EA. Coordination may be necessary along the road 

system and at the LTFs if timber sales have concurrent operations. Any potential conflicts will 

be reconciled when the operators submit their operation plans. 
Environmental Assessment 

27

The logging operations associated with this project will increase the road use, but not to the 

extent that they will have a significant effect on the existing road system. Timber sale contracts 

contain provisions that require the operator to maintain haul roads and post signage to alert other 

road users of their activity. No effect is anticipated on the transportation system due to these 

projects. 

If LTFs are used, annual monitoring is required to maintain permits at all active LTF sites. As 

part of this monitoring, an underwater survey is conducted by divers to measure the amount of 

bark accumulation at the site. LTF permit monitoring results are filed with the Alaska 

Department of Environmental Conservation. Any discharge of bark into the water at an LTF site 

requires a National Pollution Discharge Elimination System (NPDES) permit. Dive surveys 

have been conducted and show that the permit requirements are being met at all sites. Since the 

potential quantity of wood moving over the LTFs as part of this project is much less than past 

timber sales, very minimal bark accumulation is expected. 

Wildlife Species and Old Growth 

The following section summarizes the effects of the proposed activities on threatened, 

endangered, candidate and proposed species (TES), Alaska Region sensitive species, 

management indicator species (MIS), and other species of concern that may occur in the analysis 

area. More information is available in the Wildlife resource report in the project record, 

including a summary of species and direct and indirect effects. 

The effects to wildlife for this project are primarily based on timber harvest of productive old 

growth (POG)1. 

Direct and Indirect Effects 

Threatened, Endangered, and Proposed Species (TES) 

Both humpback whales - an endangered species, and Steller sea lions - a threatened species, 

occur in marine waters surrounding Etolin, Wrangell, and Zarembo Islands. No critical habitat 

has been designated for either of these species on Wrangell Ranger District. There are no 

terrestrial TES found in the project area. There will be no direct effects to threatened or 

endangered species as a result of this project since both of these species are marine mammals. 

Proposed activities would not markedly increase marine disturbance or alter habitat that could 

affect the marine environment. Permittees and timber sale operators will be required to comply 

with the Marine Mammal Protection Act and Marine Mammal Viewing Guidelines 

(http://www.fakr.noaa.gov/protectedresources/mmv/guide.htm). 

Potential indirect effects would include disturbance due to increased boat or barge traffic 

between points of harvest and locations where wood products are processed or sold. However, 

marine transits between islands where harvest may occur do not intersect any areas where these 

species are known to congregate such as sea lion haulouts. 

A biological assessment and biological evaluation (BA/BE) was submitted to and reviewed by 

the National Oceanic and Atmospheric Administration (NOAA). On October 14, 2009, the 

 

1

 Productive old growth (POG): Old-growth forest capable of producing at least 20 cubic feet of wood fiber per acre 

per year, or having greater than 8,000 board feet per acre. 
28

NOAA concurred with the Forest Service determination that the Proposed Action “may affect, 

but is not likely to adversely affect” ESA-listed species or designated critical habitat. No 

determination was required by the USFWS since there are no terrestrial species over which they 

have jurisdiction present in the project area. 

Sensitive Species, Management Indicator Species (MIS), and Other Species of 

Concern 

Species that may be affected by the Proposed Action include those that are associated with oldgrowth habitat that may be altered or reduced as a result of this project. The only sensitive 

species likely to occur in the project area is northern goshawks; MIS likely to occur in the project 

area includes species such as deer, wolves, martens, bald eagles, black and brown bears, brown 

creepers, hairy woodpeckers, red-breasted sapsuckers, red squirrels, river otters, and Vancouver 

Canada geese. Other species of concern include other migratory birds, and endemic small 

mammals. Affected environment and habitat requirements are described in the Wildlife resource 

report. 

Potential effects will consist mostly of short-term disturbances associated with harvest and 

processing and changes in habitat structure. As the specific locations of these impacts have yet 

to be identified, and because harvest is likely to be spread among 21 wildlife analysis areas 

(WAAs), it is very difficult to quantify the anticipated impacts. Animals such as deer or bears 

may be displaced during the duration of the activities. In some cases, harvest of nest trees used 

by migratory birds during the breeding season may result in lowered reproductive success for 

individuals. The upper limit of harvest will be 500 thousand board feet per year. If all harvest in 

a year was uneven-aged, this would treat up to an estimated 239 acres annually, depending on the 

percent volume removed. Changes in habitat structure will result in a loss of volume in 

productive old-growth stands and decrease in snow interception of the canopy where harvest 

occurs. There will be a reduction in snags adjacent to the existing open roads available to cavitynesting birds or other wildlife dependent on decadent trees in the project area. However, 

adequate trees exist outside the project area to provide nesting and denning sites. These effects 

are not expected to contribute to a loss of population viability on Tongass NF for any species. 

Productive Old Growth, Coarse Canopy, and Habitat Connectivity 

POG within the beach fringe, riparian buffers and those areas determined to be unsuitable for 

commercial timber harvest, such as unstable slopes, form the matrix lands of the Conservation 

Strategy. Commercial timber harvest in these areas is not allowed or limited by the Forest Plan. 

Therefore, the Conservation Strategy will provide sufficient habitat for old-growth associated 

species to maintain population viability on the Tongass National Forest. The Forest Plan Legacy 

Standards and Guidelines will be applied as necessary in value comparison units (VCUs) 455 

and 457 on Zarembo Island. 

Direct and indirect effects include a potential increase in habitat fragmentation and changes in 

forest structure including a reduction in volume. However, considering that harvest will be 

limited to 500 MBF annually and that no individual green-tree sale would exceed 50 MBF, 

additional habitat fragmentation as a result of this project should be immeasurably small. In 

cases of salvage events, when a single sale may exceed 50 MBF, the actual habitat changes that 

result in fragmentation will have already occurred. 
Environmental Assessment 

29

Harvest may contribute to further reductions in connectivity, particularly in areas where stands 

are subject to high winds and stands are unraveling. Important wildlife habitat connectivity areas 

have been identified in Appendix 1. 

Coarse-canopy habitats are likely important for wildlife species dependent on large trees, such as 

brown creepers, hairy woodpeckers, and Keen‟s myotis. About 980 acres of the project area 

have coarse canopy (SD67). Harvest of coarse-canopy stands (defined as size/density class 

SD67) has been disproportionally high in the Etolin Island biogeographic province. Effects to 

coarse-canopy habitats will be considered on a case-by-case basis. 

Cumulative Effects 

This project will not contribute to cumulative effects for humpback whales (endangered species) 

and Steller sea lions (threatened species) because the permitted activities will occur in terrestrial 

habitats and will have minimal affects the marine environment. These effects are limited to 

barge and boat traffic. Cumulative effects for this resource would be the same as direct and 

indirect effects. Other projects that may affect these species have or will have consultation with 

NMFS prior to their implementation. 

Some species may experience decreases in population in these areas if all of the projects listed in 

the cumulative effects section (Appendix 3) are implemented. Neither of the alternatives under 

consideration is likely to cause a trend toward federal listing or a loss of viability for any species 

under consideration. 

Activities proposed in this project would not occur within non-development LUDs or change 

non-development LUD boundaries. The old-growth reserve system, as well as other nondevelopment LUDs, the beach buffer, riparian buffers, and other retention mandated by Forest 

Plan Standards and Guidelines is assumed to maintain biodiversity across the Forest. Negligible 

cumulative effects could occur from natural causes such as blowdown. 

Roughly 40 percent of the POG originally available in the project area has already been 

harvested. Further decreases in old-growth habitat and habitat quality are anticipated in 

association with other projects under development or already NEPA-cleared that occur on these 

islands. However, this project contributes very little to the cumulative effects expected to occur 

among all of the projects under consideration. Anticipated maximum annual acres affected 

would be approximately 0.5 percent of the project area annually. Upcoming projects will 

consider this project in their cumulative effects during their NEPA analyses, using more-specific 

information as it becomes available. 
30

Subsistence 

The subsistence resource identified for analysis in this project is deer. No other resources, 

including fisheries, shellfish, berries, or any other subsistence resource are anticipated to be 

affected by this project. 

Direct and Indirect Effects 

Deer are the most important subsistence wildlife resource potentially affected by this project. 

Minor reductions in volume associated with green tree harvests may reduce snow interception or 

change understory structure, but is not expected to result in changes in abundance or distribution. 

No roads will be constructed for this project nor are any existing roads proposed to be closed 

with this project, therefore there will be no changes in access to deer, or changes in competition 

to deer. 

Cumulative Effects 

While direct and indirect effects of this project alone are not expected to affect abundance and 

distribution, access to, or competition for deer as a subsistence resource, cumulative effects of 

this project when considered with past, present, and future timber harvest in this area may result 

in a restriction in subsistence opportunities. NEPA documentation for the Doughnut, Shady, 

Skipping Cow, Navy, and Backline Timber Sales all concluded that there would be a significant 

possibility of a significant restriction to subsistence use of deer as a result of cumulative effects 

according to the Forest Plan. The Forest Plan ROD (page 61) states, “based on [the subsistence 

analysis for the Forest Plan], implementation of the Forest Plan may result in a significant 

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

distribution of these resources and on competition for these resources”. In addition, the Wrangell 

District Access and Travel Management Plan (ATMP) authorizes the closure of many roads on 

WRD, and its NEPA analysis concluded a significant possibility of a significant restriction to 

subsistence use of terrestrial resources, including deer, as a result of a decrease in access. 

ANILCA 810 Finding 

Direct and indirect effects of this project alone are not expected to affect abundance and 

distribution, access to, or competition for deer as a subsistence resource, as stated above. Due to 

cumulative effects combined with other past, present, and reasonably foreseeable future actions, 

the alternatives (including the no action) under this project may result in a significant possibility 

of a significant restriction to subsistence use of deer due to the potential effects of projects on the 

abundance and distribution of deer and on competition for deer. This is consistent with the 

finding in the Forest Plan Record of Decision and the findings on Navy EIS and Baht EIS. 

No other subsistence resources or uses are expected to be restricted as a result of this project or 

past, present, or foreseeable future projects. Significance determination for the ANILCA finding 

is not the same as NEPA significance. 
Environmental Assessment 

31

Aquatics 

This section describes project area aquatic resources and analyzes the effects of this timber sale 

project on these resources. For the purposes of this assessment, “aquatic resources” refers to 

overall watershed health, water quality, riparian and in-water habitats, and fisheries. This section 

will also cover marine habitats and animals near Forest Service facilities. 

Freshwater Resources 

This project would occur adjacent to the road systems on Etolin, Wrangell, and Zarembo Islands 

on the Wrangell Ranger District. Physical, biological, and management-related descriptions of 

these island environments can be found in their respective landscape assessments (Etolin 1998, 

Wrangell 2005, and Zarembo 2006) and will not be elaborated here. 

There are currently 236 miles of open (i.e., legally accessible) and drivable roads on the three 

island systems. The project area includes 165 of these road miles. The Wrangell District is 

currently implementing its ATMP and, when fully implemented, will have fewer open miles than 

those previously stated in the landscape assessment. There are 12 watersheds on Etolin Island, 

10 watersheds on Wrangell Island, and 15 watersheds on Zarembo Island affected by this project. 

Etolin Island 

Only the watersheds on the central portion of Etolin Island would be affected by this project. 

The southern one-third of the island lies within protected wilderness where timber sales are 

prohibited. The Etolin Island Landscape Assessment was completed in 2006 and provides a 

recent and adequate assessment of the island‟s watersheds and aquatic resources. In addition, the 

2009 Navy Timber Sales analysis provide a more thorough watershed and aquatic resource 

condition and risk assessment for a smaller set of island watersheds. Overall, these 

assessments/analyses do not point out any specific watersheds that may be of special concern 

with relation to additional timber sale development. In fact, all Etolin Island watersheds and 

aquatic resources appear to be functioning normally. 

Wrangell Island 

This project would mostly affect the watersheds on the southern two-thirds of Wrangell Island. 

Though the Wrangell Island Analysis (1998) is somewhat dated, between the information 

presented in that document and the analyses conducted for the Shady (2004) and Backline (2006) 

timber sales, most Wrangell Island watersheds and aquatic resources affected by the Roadside 

project have had recent condition assessments. McCormack Creek watershed was the only 

system identified in two of these documents as being potentially sensitive to additional 

development. The McCormack Creek Watershed Restoration Plan (2006) identified several 

items that would improve overall watershed condition and make the system less sensitive to 

further timber development. Several of these improvements (i.e., road closures) were made in 

2008. Otherwise, the remaining Wrangell Island watersheds affected by this project appear to be 

functioning normally. 

Zarembo Island 

This project has the potential to affect most Zarembo Island watersheds because of the island‟s 

extensive road system. The Zarembo Island Landscape Assessment (2005) and the Zarembo 

Island Watershed Restoration Plan (2007) comprehensively evaluate the status and needs of all 
32

Zarembo watersheds and aquatic resources. In addition, the Skipping Cow (2000) and Baht 

(2007) timber sales provide additional analyses relevant to timber development in a large subset 

of island watersheds. Overall, these assessments/analyses do not point out any specific 

watersheds that may be of special concern with relation to additional timber sale development. 

In fact, most Zarembo Island watersheds and aquatic resources appear to be functioning 

normally. 

Direct and Indirect Effects 

The most notable results of logging activities affecting Southeast Alaska aquatic resources 

include short-term increases in turbidity from point- and non-point erosion sources, riparian and 

in-water habitat loss/degradation from riparian timber harvest and road construction; timber 

harvest- and road construction-induced landslides or mass wasting events; and impaired fish 

passage at poorly planned or constructed road crossings. Increased sedimentation and 

temperature are additional logging effects that can negatively affect aquatic resources but are 

generally far less pronounced in this region, because: 

Southeast Alaska is geologically young in comparison to other North American regions, 

which implies there is less mineral soil available that can lead to severe sedimentation 

problems, 

streams in this region are generally fast-flowing and have high annual discharges that 

effectively and regularly flush fine sediments out of the system, and, 

the high annual precipitation rates (snow and rain), dense vegetative cover, and temperate 

climate buffer area waters from the effects of solar radiation that lead to increased 

temperatures. 

On a watershed scale, the effects to aquatic resources of removing a relatively small number of 

individual trees or salvaging timber from small blowdown or disease events adjacent to the road 

system would be virtually immeasurable. Furthermore, there would be little to no expected 

negative effects to aquatic resources on any of the islands for the following reasons: 

previous assessments and project analyses do not indicate areas or resources of special 

concern, 

there has been only minimal riparian logging in systems on these islands, 

there would be no new road construction, 

the Wrangell District has been proactive about maintaining its road systems, reducing the 

road inventory through storage projects, and improving fish passage at problematic 

crossings, 

the project’s specifications greatly limit the scope and scale of effect to resources, and 

the annual proposed sale plan is subject to specialist review and recommendations prior 

to implementation. This plan will fully adhere to all Forest Plan Standards and 

Guidelines, and project-specific best management practices. 

Effects to Fish Movement at Stream Crossings 

There would be no effect to fish passage at stream crossings as a result of the Proposed Action, 

because no new road construction would be authorized. The existing road systems do contain 
Environmental Assessment 

33

documented fish passage concerns that are called “red pipes”2. They are cataloged in the 

Tongass National Forest Road Condition Survey database, and identified in Table 1 of the 

Aquatic resource report. 

Recent work has been done to correct these problems. Many of the remaining structures are 

blocking only a short amount of upstream habitat or very small streams that would not support 

large fish populations. Though these structures are a priority issue for the Forest and District, 

they are not addressed as a part of this project. These structures are usually corrected or removed 

as part of a road maintenance and closure program, in conjunction with larger timber sales or 

when other funding is available. 

Marine Resources 

This project would authorize the use of LTFs to facilitate the movement of equipment to the 

islands‟ road systems and remove wood material. Wood material could either be floated or 

loaded directly to a barge or boat for transport. These facilities are located at Starfish Cove 

(Anita Bay North and South) on Etolin Island; Earl West Cove (Venus Cove) and Pats Creek on 

Wrangell Island; and St. John Harbor and Deep Bay on Zarembo Island. An operator may 

choose to load/offload equipment and/or wood material at docks and ramps located at the marine 

access facility (MAF) at Roosevelt Harbor on Zarembo Island. Additional site-specific 

information on LTFs/MAFs can be found in the Backline (2006), Baht (2007), and Navy (2009) 

timber sales environmental analysis documents. 

The LTFs are periodically monitored in conjunction with authorizing permit requirements and 

projected use usually associated with large-scale timber sales. State and Federal permits require 

dive surveys to measure bark deposition in the area around LTFs. Bark deposition must be less 

than 1 acre of continuous coverage 10 cm thick. This is the threshold assumed to have minimal 

detrimental effects to aquatic organisms. While several transect points measured had bark depths 

greater than 10 cm, no areas of continuous coverage exceeding 1 acre were found. The available 

information for these facilities suggests that bark deposition is below the threshold of concern 

(Table 3). 

 

2

A “red pipe” is a structure that cannot pass fish at all life stages and flows specified in the Aquatic Habitat 

Management agreement between the USFS and the State of Alaska. 
34

Table 3 - Bark Deposition Levels at WRD MAFs 

MAF Bark Deposition Surveryor/year

Starfish Cove North - Etolin 0.51 acre continuous coverage, <10 

cm deep (additional 0.47 acre of 

discontinuous coverage)

Alaska Commercial Divers, 

2000

Starfish Cove South - Etolin 0.78 acre continuous coverage, 0-70 

cm deep (additional 0.13 acre of 

discontinuous coverage

Alaska Commercial Divers, 

2000

Earl West Cove - Wrangell 0.20 acre continuous coverage, 0-35 

cm deep (site has less than 1 acre of 

measurable bottom surface due to 

deep irregular rock formations)

Craig’s Dive Center, 2001

Pats Creek - Wrangell 0.33 acre continuous coverage, 1-50 

cm deep

Alaska Commercial Divers, 

2000

Deep Bay - Zarembo Trace amounts, discontinuous 

coverage, <5 cm deep

Alaska Commercial Divers, 

2000

St. John Harbor - Zarembo 0.40 acre continuous coverage, 0-25 

cm deep (additional 1.3 acres of 

discontinuous coverage)

Craig’s Dive Center, 2001

There would be very little to no effect to marine habitats as a result of implementing this project 

because: 

The available information indicates that bark deposition at MAF sites is not above 

thresholds of concern for marine habitats and/organisms. 

Operators would be required to follow contract stipulations and Log Transfer Facility 

Guidelines (Forest Plan Appendix G) that regulate MAFs to protect resources (e.g., fuel 

transfer, debris containment, etc). 

It is anticipated that most wood material would be loaded directly to a barge or boat for 

transport, which would greatly reduce the potential for wood debris to enter the water and 

foul habitats. If logs are placed in the water, the amount would be very limited for any 

given sale, due to the scope of this project. 

Cumulative Effects 

This project would likely overlap with other Forest Service timber sale projects and private 

personal use and firewood collection along the three island road systems. However, no 

significant negative cumulative effects to area aquatic resources are expected to occur as a result 

of implementing the project action alternative because: 

The project’s small scale and effects would be distributed across a wide area over time. 

(Note: Though the total estimated affected area maximum for uneven-aged harvest is

239 acres, this harvest would consist of single-tree selection and would retain at least 67 

percent of the stand area. It would be virtually impossible for all of this harvest to occur 

in a single watershed for this project.) 

There would be no new road construction. 
Environmental Assessment 

35

Stream buffers would be established based on stream class and channel type, as directed 

by the Forest Plan Standards and Guidelines, to protect and maintain water quality, 

riparian and aquatic habitat, and fish populations. 

Any planned deviations from Forest Plan Riparian Buffer Standards and Guidelines 

would necessitate a watershed analysis in which the scope of the analysis would be 

dependent upon the intensity of the action (see the Forest Plan, Appendix C for further 

explanation). 

The review of the annual proposed sale plan would provide an opportunity to examine the 

effects of actions proposed under this project in relation to other past, present, and 

reasonably foreseeable future activities and/or variations in environmental conditions 

(i.e., cumulative watershed effects). 

This project would contribute very little to potential wood debris in marine habitats. 

Botany 

No plant surveys have been specifically conducted in support of this project; however, surveys 

conducted in the past for other projects have coincided with the project area. 

Rare Species 

The Alaska Natural Heritage Program (ANHP) maintains a database of rare plant species in 

Alaska. Rare plants on the Tongass National Forest are defined by the Forest Plan as plants with 

potential conservation concerns on the Tongass. They may be common elsewhere; however, the 

edge of their range is known or suspected to be on the Tongass, or disjunct3populations of the 

plant species occur on the Tongass. 

Sensitive Species 

Seventeen vascular plant species or subspecies and one lichen are designated as sensitive in the 

Alaska Region. A species is listed as sensitive when it has been determined that concerns exist 

for the species‟ continued viability in the region due to a combination of rarity and specific 

threats to population viability. Table 5 lists the Alaska Region sensitive plants (2009) that are 

known or suspected to occur in the Alaska Region. 

Direct and Indirect Effects 

The project proposes timber harvest, which could potentially contribute to a small increase in 

disturbed rare and sensitive plant habitat on Wrangell, Zarembo, and Etolin Islands. 

Plants or their habitats can be negatively affected by timber harvest, or related activities. These 

effects can include: 

Crushed or buried plants or habitat, covering plants or soil with slash, 

Alterations of water flows in the soil and on the surface (hydrologic processes) leading to 

desiccation or drowning of plants, 

Changes in evapotranspiration leading to changes in available soil moisture levels, 

Intensified light penetration as overstory canopy is removed, 

 

3

 Disjunct - discontinuous or separated in time or space 
36

Decreased light penetration after canopy closure, or 

Decreased reproductive potential in some species by eliminating associated mycorrhizal 

fungi. 

Since the exact location of harvest activities under the Proposed Action is unknown at this time, 

no prediction can be made of the magnitude of the direct or indirect effects on particular 

populations of rare or sensitive plants. 

While the long-term effects of timber harvest on the rare and sensitive plants in our region have 

not been studied and remain uncertain, road building causes irreversible impacts on directly 

affected populations. This project will not have these effects since there is no new road 

construction. 

Table 4 - Known Rare Plant Populations in the Project Area 

Scientific Name1 Common Name # of 

Populations

Carex gynocrates Wormsk ex Drejer northern bog sedge 1

Cypripedium montanum Douglas ex.Lindl mountain lady's slipper 1

Galium kamtschaticum Steller ex.Schult & 

Schult f.

northern bedstraw 2

Glyceria leptostachya Buckley Davy mannagrass 1

Hymenophyllym wrightii Bosch Wright's filmy fern 18

Listera convallarioides (Sw.) Nutt. ex Elliot Broadlipped twayblade 6

Malaxus paludosa (L.) Sw. bog adder's-mouth orchid 1

Platanthera orbiculata (Pursh) Lindl. lesser roundleaved orchid 1

1 Plant species that are considered Sensitive are shown in bold type 

Table 5 - Effects to Alaska Region Sensitive Plants 

Scientific name Common Name

Summary 

of BA/BE 

Finding: No 

Action

Summary 

of BA/BE 

Finding: 

Proposed 

Action

Known/

Suspected 

in Project 

Area

Aphragmus eschscholtzianus

Andrz. ex DC

Eschscholtz‟s 

little nightmare

No impact No impact No

Botrychium spathulatum 

W.H Wagner

Spathulate 

moonwort

No impact No impact Suspected

Botrychium tunux Stensvold

& Farrar

Moosewort fern No impact No impact No

Botrychium yaaxudakeit 

Stensvold & Farrar

Moonwort fern, 

no common 

name

No impact No impact No
Environmental Assessment 

37

Scientific name Common Name

Summary 

of BA/BE 

Finding: No 

Action

Summary 

of BA/BE 

Finding: 

Proposed 

Action

Known/

Suspected 

in Project 

Area

Cirsium edule Nutt Edible thistle No impact No impact Suspected

Cochleara sessilifolia

Rollins

Sessileleaf 

scurvygrass

No impact No impact No

Cypripedium guttatum Sw. Spotted lady‟s 

slipper

No impact No impact No

Cypripedium montanum 

Douglas ex Lindl.

Mountain lady‟s 

slipper

No impact No impact Known

Cypripedium parviflorum 

Salisb. var. pubescens 

(Willd.) Knight

Yellow lady‟s 

slipper

No impact No impact Suspected

Ligusticum calderi Mathias 

and Constance

Calder‟s lovage No impact May affect1Suspected

Lobaria amplissima

(authority not known)

Lichen, no 

common name

No impact No impact No

Papaver alboroseum Hultén Pale poppy No impact No impact No

Piperia unalascensis 

(Spreng.) Rydb.

Slender spire 

orchid

No impact May affect1Suspected

Platanthera orbiculata 

(Pursh) Lindl.

Lesser 

roundleaved rein 

orchid

No impact No impact Known

Polystichum kruckebergii

W.H. Wagner

Kruckebergs 

hollyfern 

No impact No impact No

Romanzoffia unalaschcensis 

Cham.

Alaska 

mistmaiden

No impact No impact No

Sidalcea hendersonii S. 

Watson

Henderson‟s 

checkermallow 

No impact No impact No

Tanacetum bipinnatum L. 

Sch. Bip subsp. huronense 

(Nutt.) Breitung

Lake Huron 

tansy 

No impact No impact No

1

 Full text of determination is “may adversely impact individuals, but not likely to result in a loss of viability on the 

Tongass National Forest, nor cause a trend toward federal listing.”
38

Cumulative Effects 

For this analysis, the cumulative effects area is the three islands - Wrangell, Zarembo, and Etolin 

- where harvest activities are planned. This area was chosen because an island is a natural, 

geographical boundary for the rare plants and their habitats known or suspected to occur on the 

island. An island environment limits influences on plant dispersal and pollination from other 

islands and the mainland. The cumulative effect to rare and sensitive plants is calculated in 

terms of the potential reduction in total productive old growth (POG) habitat on Wrangell, 

Etolin, and Zarembo Islands. 

Before timber harvest on these islands, there were about 239,397 acres of POG on the three 

islands. Past harvest from 1913 to present removed trees from about 29,398 acres (about 12.3 

percent) of the initial POG. Other potential timber projects (Appendix 3) would harvest 

additional POG. 

Based on a range of 24-239 acres of annual harvest in this project, the maximum affected area of 

potential rare and sensitive plant habitat within POG would be up to 1/10 of 1 percent of the 

initial POG per year. 

Other past effects in the cumulative effects analysis area, which would have adversely affected 

rare and sensitive plants include the presence of the city of Wrangell on Wrangell Island, roads, 

gravel pits, marine access facilities, hatchery support facilities and remote cabins and home sites. 

Determination 

There would be no effects to sensitive and rare plants for the No-action Alternative. There may 

be effects to six sensitive species in the Proposed Action because they could occur in the forested 

habitat. For those six species, the proposed activities may adversely impact individuals but are 

not likely to result in a loss of viability on the Tongass National Forest, nor cause a trend toward 

Federal listing. 

Measures are listed in the implementation plan (Appendix 1) to mitigate or avoid effects to rare 

or sensitive plant populations, if found. 

Invasive Plant Species 

An invasive species is one whose introduction does or is likely to cause economic or 

environmental harm or harm to human health (Executive Order 13112). The Alaska Natural 

Heritage Program‟s 2007 Weed Ranking Project results were used to determine which plants 

qualify as invasive. The ranking process takes into account documentation of each plant species, 

including climatic comparison of Alaska's climates to climates where the plant is known to 

thrive, biological characteristics and dispersal ability of the plant, the plant's distribution, and 

feasibility of control. If a plant has not been ranked, the extent of invasiveness is based on 

general observations of plant behavior. The Tongass National Forest High Priority Invasive 

Plant Species List of priority species will be the focus for prevention activities. However, on a 

site-specific basis, other species may be of concern and warrant prevention practices. 

Vectors are factors that aid the spread of invasive species. Roadside areas are at a highest risk of 

establishment of invasive species. Vectors include erosion control plantings on disturbed areas 

adjacent to roads and contaminated vehicles and heavy equipment. Road construction, which is 
Environmental Assessment 

39

a primary vector in the spread of invasive plant species, is not proposed for this project. Road 

maintenance may be required for some of the proposed sales from this project. Road 

maintenance poses a risk of spreading invasive plants into uninfected areas if the equipment used 

goes from a weeded area to a weed-free area. Mobilization of motor vehicles, logging 

equipment or processing equipment from infested areas increases the risk of importing additional 

invasive plants. Increased traffic along the road has the potential to spread the existing weeds, as 

well as create new introductions of invasive plant species. 

Invasive Plant Species in the Project Area 

Non-native plant inventories of the area were conducted in 2006. An invasive plant risk 

assessment was completed for this project. Most surveys focused on the existing road systems 

on Zarembo, Etolin, and Wrangell Islands. The following is a brief description of the locations 

of the high-priority plants and plants of concern in the project. 

Reed canary grass (Phalaris arundinacea L.): Reed canary grass is widespread along roads on 

Zarembo Island and Wrangell Island roads, and scarce on Etolin except for two road systems 

(51540 and 51720) where it was seeded for erosion control. 

Hawkweeds (Hieracium): There is one known population of yellow hawkweed on Etolin Island, 

on Road 6544. 

The roadsides around the City of Wrangell support a dense infestation of yellow hawkweed. 

There are five populations of yellow hawkweed (Hieracium lachenalii, and Hieracium 

caespitosum) on Wrangell Island along National Forest System Roads 6265 (two populations), 

6270, 6299, and 50022. 

Zarembo Island has a growing population of yellow hawkweed (Hieracium lachenalii) found in 

the summer of 2005, and a small population of orange hawkweed (Hieracium aurantiacum), on 

Road 6592.

Bull thistle (Cirsium vulgare): One small population is known on Wrangell Island, on Road 

6277. 

Oxeye daisy (Leucanthemum vulgare): Oxeye daisy (Leucanthemum vulgare) is found near the 

Anita Bay North LTF on Etolin Island and near the Roosevelt field camp on Zarembo Island. 

Common dandelion (Taraxacum officinale): In recent years, common dandelion has become 

more widespread on the roads in the project area. Zarembo has the highest concentration, 

followed by Wrangell Island and Etolin Island. 

Hairy cat’s ear (Hypochaeris radicata): Hairy cat‟s ear is widespread (all three islands), 

persistent, and a difficult plant to eradicate. Its preferred habitat is reported as dry grassland, 

though it is found in the ditches along logging roads. 

Marsh cudweed (Gnaphalium uliginosum): The only place marsh cudweed is known to occur 

is on the floor of two rock pits on Etolin Island, on Roads 6548 and 6545. 

Wall lettuce (Mycelis muralis): Wall lettuce is found on Etolin Island in an old camp site near 

Anita Bay South LTF, and Zarembo Island along Road 6592. 

Additional species are known in the vicinity, though they have not been found along roads 

considered for timber harvest. They include tansy ragwort (Senecio jacobaea), thistle (Cirsium
40

spp.), sowthistles (Sonchus spp.), Japanese knotweeds (Polygonum spp.), sweet clover (Melilotus 

officinale) and others. 

Direct and Indirect Effects 

No Action 

The rate and possibility of spread of any invasive plants within the project area will not be 

altered from the current condition. Invasive plants may spread or increase their rate of spread 

regardless of whether this project is implemented. 

Proposed Action 

Implementation of the Proposed Action may result in a slight increased risk of introducing and 

spreading invasive plant species in the project area compared to the No-action Alternative. 

Because this project is programmatic in nature, it is not possible to determine the exact effects or 

site-specific mitigation. Appropriate mitigation will be determined and implemented with 

individual sales. Implementation of this project is not expected to have a significant effect on 

invasive species populations or the habitats affected by them, either individually or cumulatively. 

Areas of timber harvest may experience some soil disturbance, facilitating the establishment of 

invasive plant species. Harvest in a closed-canopy forest will allow more light into the stand 

altering the vegetation composition, and generally make the stand more susceptible to invasion 

of invasive plants. Habitat is already altered where salvage harvest is proposed. Single-tree or 

group selection harvest for this project will maintain 67 percent of the stand structure. The only 

invasive plant species found in existing clearcuts are European mountain ash and reed canary 

grass. 

On-site processing is expected to take place in areas with altered habitat. No alteration of native 

habitat is anticipated with on-site processing. 

Based on examination of areas of recently harvested areas and young-growth forests in many 

parts of the Tongass National Forest, harvested areas are at a low risk for establishment of 

invasive plants due to the shading caused by rapid regrowth of understory vegetation and the 

development of a dense forest stand. 

Cumulative Effects 

The cumulative analysis area is the three islands on which harvest activities are proposed. 

Cumulative effects associated with this project include past, current, and reasonably foreseeable 

projects. Past projects have resulted in the introduction of non-native and invasive plants in the 

project area. Past, present, and future public recreation use, outfitter/guide and other commercial 

use, administrative use and road maintenance can also influence the risk of spread. In some 

areas, invasive species introduced along roads are spreading to other habitats. For example, reed 

canary grass seeded along roads on Zarembo has spread down into riparian areas along Meter 

Bight Creek. Current and future projects are less likely to contribute to the introduction and 

spread of invasive plants due to practices that will prevent spread and introduction. Because this 

project poses only a slight risk of introduction and spread of invasive plants, due to no road 

construction, it is not expected to contribute to invasive plant populations. 
Environmental Assessment 

41

Inventoried Roadless Areas 

Inventoried roadless areas that are adjacent to the project area are: 

West Zarembo (#235), East Zarembo (#236) and South Zarembo (#237); 

North Etolin (#232), South Etolin (#234) and Mosman (#233); and 

North Wrangell (#227), East Wrangell (#247), Central Wrangell (#289), South Wrangell 

(#229) and Southeast Wrangell (#290). 

The project area considered during public scoping was within 1,320 feet of the existing roads on 

Wrangell, Zarembo and Etolin Islands within the Timber Production, Modified Landscape or 

Scenic Viewshed LUDs. This project area was used to analyze the potential effects in the 

resource reports. Some existing roads, or portions of roads, were not included if there are Forest 

Plan constraints such as beach fringe or if within a non-development LUD. With heightened 

concerns about the effects to roadless areas, the project area was modified to be within 1,200 feet 

of the road to be consistent with the roadless inventory. Also, roads that have been constructed 

since the 2001 Roadless Rule inventory are not being considered at this time. Currently, 

commercial timber harvest within the roadless rule inventory displayed in the Forest Service 

Roadless Area Conservation FEIS, Volume 2, (November 2000) would require approval by the 

Secretary of Agriculture, as outlined in Memorandum 1042-154 (May 2009) and Memorandum 

1042-155 (May 2010). Memorandum 1042-155 shall remain in full force and effect for 1 year.

Because no new roads are being constructed for this project and no harvest will occur within 

these inventoried roadless areas, there will only be indirect effects of possible sights and sounds 

of any timber sales adjacent to the roadless areas. These effects would be minor and in addition 

to the current use by the public and for commercial use of the road system. 

Cumulative Effects 

The effects of timber harvest activities to the inventoried roadless areas were previously 

analyzed in the Baht EIS (2007), Skipping Cow EIS (2000), Navy EIS (2009), Backline EA 

(2005), Shady EA (2004), and Doughnut EA (2000). This project will not contribute to the 

cumulative direct effects. 

Heritage 

The Wrangell Roadside Timber project area, located in the central portion of the Tongass 

National Forest, lies within the traditional territory of the Wrangell or Stikine Tlingit as 

evidenced by a variety of sites including villages, seasonal campsites, fish traps and weirs, rock 

art, sacred and religious areas, and subsistence or resource gathering places. The Stikine Tlingit 

continue to recreate, hunt and gather on these lands today. 

Archaeological Analysis and Survey 

Since 1974, approximately 265 archaeological surveys of varying size and intensity have been 

conducted on Etolin, Wrangell, and Zarembo Islands with surveyed areas totaling over 5,800 
42

acres and resulting in the documentation of approximately 170 sites. None of the documented 

archaeology sites is located within the project area boundaries. 

The activities potentially authorized under the EA are addressed in our Programmatic Agreement 

with the Advisory Council on Historic Preservation and the Alaska State Historic Preservation 

Officer (USDA-FS 2002). The agreement recognizes that many of the undertakings this EA 

addresses have little to no potential to affect historic properties because of their nature, size, 

location within the low archaeological site sensitivity zone or location within areas that have 

previously been surveyed for cultural resources. 

Direct, Indirect, and Cumulative Effects 

Because potential ground disturbing activities are associated with this project and there are a few 

areas in the high archaeological site sensitivity zone, there is a small potential to affect 

previously undiscovered historic properties. A qualified archaeologist will review proposed 

harvest locations and follow the procedures for assessing information needs as stipulated in our 

Programmatic Agreement. 

Recreation 

This section discusses current recreation uses on Wrangell, Etolin, and Zarembo Islands, special 

use permits on these islands, and Wild and Scenic Rivers that may be affected by the 

implementation of this project. 

Recreation Opportunity Spectrum (ROS) 

The recreation opportunity spectrum (ROS) was developed by the Forest Service to help identify, 

quantify, and describe the variety of recreation settings available on National Forest System 

lands (Forest Plan, Appendix I, pages I-1 to I-8). 

The entire project area is within the Roaded Modified ROS setting, where alterations to the 

natural environment dominate the landscape. No effects to ROS settings would be anticipated to 

occur with this project. 

Direct and Indirect Effects for All Islands 

A marine access facility (MAF) provides access from saltwater to the land, and can include such 

features as boat and/or floatplane docks, and ramps suitable for human access. A log transfer 

facility (LTF), however, is designed for log transfer to saltwater only. The direct effects could 

include issues with congestion at a LTF or MAF, and traffic along the roads. Additionally, 

roadside harvest may result in temporary delays in traffic, which could negatively affect 

recreation users on Zarembo Island roads. The Forest Service will communicate with the public 

about the planned activities and when and where to expect them to occur to mitigate these 

effects. 

There may be a potential to indirectly affect those recreation sites found adjacent to, or within 

hearing distance the road system, and within the project area. Indirect effects might include 

noise associated with nearby roadside timber operations, and traffic flow issues getting to and 

from the recreation site. Those inventoried recreation places listed as potentially indirectly 
Environmental Assessment 

43

affected will be examined if they are within a reasonable distance from a proposed roadside 

timber sale to identify mitigation that may reduce the effects. 

If on-site processing of material is proposed in the individual sale requests, mitigation may 

include identifying processing areas that are not likely to be heard from recreation sites known to 

receive high use. 

Effects should be minimal and of short duration due to the small amounts of timber expected to 

be removed from any one location. The Forest Service will communicate with the public about 

the planned activities and when and where to expect them to occur to mitigate these effects. 

Additionally, some of the roadside campsites could benefit from the removal of both dead/dying 

and/or green trees to improve safety and enhance views as seen from these recreation places. 

Opportunities to improve views or remove potential hazard trees in conjunction with roadside 

sales will be considered in the timber sale proposals, if practicable. 

Wrangell Island Recreation 

Wrangell Island provides the highest concentration of recreation use on the Wrangell Ranger 

District. The road system maintained on the island provides access for a variety of recreational 

pursuits, from driving to backcountry hiking. Direct road access to many of the recreation sites 

on the island provides year-round recreation opportunities for the community of Wrangell and 

visitors. Commercial recreation uses include outfitting/transporting on the road system, hiking 

tours, road-based nature tours, freshwater fishing, picnicking and other remote recreation uses. 

Non-commercial recreation use includes many of the same activities by local residents, along 

with other activities such as cross-country skiing, snow machining, hunting, horseback riding, 

trapping, berry picking, and ATV use. 

All roads within the project area are included within an inventoried recreation place. Wrangell 

Island roads receive a high amount of use due to their direct connection with Wrangell, providing 

access to recreation areas, and for pleasure driving. 

Direct and Indirect Effects to Wrangell Island Inventoried Recreation 

Places 

The Wrangell Roadside Timber Sales have the direct potential to affect all the roads within the 

project area, and the recreation use they receive. Direct effects could include delays of public 

traffic while individual sales are in progress. Communication to the public of when and where to 

expect traffic delays when sale operations are active will help mitigate these effects. 

Table 6 displays the inventoried recreation places on Wrangell Island that may have direct 

effects with the implementation of the Proposed Action. The areas that may have indirect 

effects, such as an increase in noise or traffic, are also shown. 
44

Table 6 - Wrangell Island Inventoried Recreation Places with Potential Effects 

Rec #1Inventoried Recreation Place Direct 

Effects

Indirect

Effects

22094.06 Earl West Marsh X

22094.08 Forest Roads 6299 (Thoms Creek) and 6270 (Fools Inlet) X

22094.02 Highbush Lake X

22094.03 Highbush Road (includes Road 50040, parking, trailhead and short 

trail to lake, and boat storage area)

X

22100.00 Long Lake Road 6271, including Long Lake Trailhead Recreation 

Site, and the 0.6 mile Long Lake Trail

X X

22094.07 Lower Salamander Campsites X

22092.08 Mainline Road 6265 and spurs- Main Forest Roads between State 

Lands at McCormack Creek and Earl West Creek; including 6265 

(Mainline), 6263 (Basin), 50024, 50050 (Salamander), and 50022 

(Garnet)

X

22092.04 Middle Ridge Cabin Site X

22092.03 Nemo Point Road – Rec Place includes campsites listed below: X

 Nemo Information Site X

 Yunshookuh Loop Campsite X

 Three Sisters Viewpoint Campsite X

 Anita Bay Overlook Campsite X

 Highline Campsite X

22092.04 Pats Valley Road System X

22094.10 Salamander Ridge Trail X

22092.07 Thoms Lake Road – Road 6267 between 6265 junction and Turn 

Island Trailhead

X

22107.00 Turn Island Saltwater Access Trail and Campsite X

22094.01 Upper Salamander Campsite X

1The Recreation number corresponds to the GIS layer. 

Etolin Island Recreation 

There are two main road systems on Etolin Island: the Anita Bay road system that includes all 

roads accessed from the Starfish Cove marine access facility (MAF) and which would be used in 

this project, and the King George road system that includes all roads accessed from the 

Honeymoon MAF but would not be used for this project. Recreation use of the roads and docks 

is low compared to the Wrangell Island road system, as access requires transporting vehicles to 

the island by boat. Although some recreation use can be expected year-round, recreation use of 

the roads and docks generally centers on hunting activities in the fall. 

On Etolin Island, there are three inventoried recreation areas identified near or partially within 

the project area: the shoreline areas near the head of Anita Bay, shoreline areas near the head of 

Burnett Inlet, and shoreline areas near the head of Mosman Inlet. Use of these areas are 
Environmental Assessment 

45

dispersed, with Anita Bay receiving most use from people accessing the road system, while the 

areas near the heads of Mosman and Burnett Inlets are most often used for dispersed beach 

related recreation activities such as camping, beachcombing, and exploring. 

Direct and Indirect Effects to Etolin Island Inventoried Recreation 

Places 

This project has the potential to affect all the roads within the project area and the MAF at 

Starfish Cove directly. The direct effects could include issues with congestion at the LTF, and 

traffic along the roads. Additionally, roadside harvest may result in temporary delays in traffic, 

which could negatively affect recreation users on Etolin Island roads. These effects can be 

mitigated with public communication from the district to alert the public to activities that may 

affect their use of roads during certain times. 

Table 7 displays the inventoried recreation places on Etolin Island that may have direct effects 

with the implementation of the Proposed Action. The areas that may have indirect effects, such 

as an increase in noise or traffic, are also shown. 

Table 7 - Etolin Island Inventoried Recreation Places with Potential Effects 

Rec # Inventoried Recreation Place Direct 

Effects

Indirect

Effects

22088.00 Anita Bay road system – entire Forest Service road system originating from 

Starfish LTF

X

22060.00 Head of Anita Bay X

22062.00 Head of Burnett Inlet – shoreline east and west X

22062.01 Head of Burnett Inlet roads – shoreline north and west X

22066.00 Mosman Inlet – shoreline at north end, locally known as Pump Creek X

22061.00 Starfish Cove – including LTF X

Zarembo Island Recreation 

Zarembo Island, west of Wrangell, provides for roaded recreation opportunities on the Wrangell 

Ranger District. Two marine access points, Roosevelt and St. John, provide docks and road 

access for the public. Zarembo Islands supports a Sitka black-tailed deer population, which 

provides guided and non-guided hunting opportunities to residents and out-of-state hunters. 

Recreation uses on Zarembo Island are dispersed, and currently there are no developed recreation 

facilities maintained for public use by the Wrangell Ranger District. 

Table 8 displays the inventoried recreation places on Zarembo Island that may have direct effects 

with the implementation of the Proposed Action. The areas that may have indirect effects, such 

as an increase in noise or traffic, are also shown. 
46

Table 8 - Potential for Effects to Zarembo Island Inventoried Recreation Places 

Rec # Inventoried Recreation Place Direct 

Effects

Indirect

Effects

22043.02 Beach Road – shoreline and roads on north side of Zarembo Island 

from State lands at St. John Harbor to Deep Bay

X

22043.04 Interior Roads – maintained FS roads, interior to the island X

22043.08 Meter Bight – shoreline X

22043.05 Roosevelt/Deep Bay – includes marine access point, uplands and 

roads around Deep Bay and Roosevelt, and FS administrative site

X

22043.00 St. John – includes LTF, uplands, road around St. John Harbor, and 

FS administrative site

X

22043.03 St. John State Land Right of Way – new in 2008, includes Forest 

Service mainline roads within State lands

X

The main road system on Zarembo Island is accessible by MAFs, the Roosevelt Harbor dock and 

the St. John Harbor dock. During the deer-hunting season, the island is a popular destination for 

Wrangell and Petersburg residents to pursue Sitka blacktail deer, and in some cases elk (by 

permit drawing). Both access points can become congested at times due to boats rafted together 

at the docks. At Roosevelt, personal vehicles can be stored for use during the hunting season, 

allowing residents to drive the roads to access higher-elevation hunting grounds easily. 

Recreation use of the roads and docks is low compared to the Wrangell Island road system, as 

access requires transporting vehicles to the island by boat. Although some recreation use can be 

expected year-round, recreation use of the roads and docks generally centers on hunting activities 

in the fall. 

Direct and Indirect Effects to Zarembo Island Inventoried Recreation 

Places 

The WRD Roadside Timber Sales, as proposed, have the potential to directly affect all the roads 

on Zarembo Island that are within the project area and the MAFs at St. John Harbor and 

Roosevelt Harbor. Additionally, roadside harvest may result in temporary delays in traffic, 

which could negatively affect recreation users. These effects can be mitigated with public 

communication from the district to alert the public to activities that may affect their use of roads 

during certain times. 

Outfitter and Guide Use 

On the Tongass National Forest, most outfitter and guide special use permits allow for dispersed 

use on vast areas of the National Forest, and many Tongass guides have authorization to use 

areas on Wrangell, Etolin, and Zarembo. 

On Wrangell Island, 12 outfitter and guide companies reported use from 2004-2008. During that 

5-year period, 6,622 clients were reported, an average of 1,324 clients/year. 

On Etolin Island, nine outfitter and guide companies reported use on Etolin Island from 2004-

2008. During that 5-year period, 3,507 clients were reported, an average of 701 clients/year. 

On Zarembo Island, five outfitter and guide companies reported use on Zarembo road system 
Environmental Assessment 

47

from 2004-2008. During that 5-year period, 99 clients were reported, an average of 20 

clients/year. 

Most of the destinations used by outfitter and guide clients are remote, and not usually associated 

with the road system, except for travel. Effects to outfitter and guides and their clients would 

depend on the types of activities they are seeking, and would be similar to those discussed above 

in the recreation places section. 

Non-Recreation Land Use Permits 

The Tongass National Forest authorizes a variety of non-recreation land use through special use 

permits. On Etolin Island, there are authorizations for a mariculture oyster farm, two 

communication sites, and the Burnett Hatchery. On Zarembo Island, there is an active mining 

claim just off the road system near St. John Harbor. The activities proposed for this project will 

not affect these special use authorizations because the permits are not within the project area. 

On Wrangell Island, there is an authorization for the Tyee power line crossing Wrangell Island. 

The Tyee power line is the only special use permit with authorization of land use inside the 

project area. The Southeast Alaska Power Agency (SEAPA), formerly known as the Four Dam 

Pool Power Agency, holds a special use permit for the Tyee power line, which includes 

approximately 23 miles of power line on Wrangell Island. The power line crosses the project 

area through three road sections: three crossings of the Old Hermit Road system (Roads 50051 

and 50052), four crossings of the Salamander Ridge Road (Road 50050), and one crossing near 

Highbush Lake (Road 50041). Aside from requiring the normal safety precautions necessary 

when working around active power lines, none of the activities proposed in the WRD Roadside 

Timber Sales would negatively affect this special use authorization. 

Wild and Scenic Rivers 

Rivers on the Tongass National Forest were evaluated during 1997 Forest Plan revision for their 

eligibility and suitability for inclusion in the Wild and Scenic River System. This process 

resulted in the recommendation of river segments to be designated as wild and scenic rivers. 

There were four river segments on Wrangell and Etolin Islands that were considered for 

inclusion, but none were recommended. There were no rivers on Zarembo that were considered 

for inclusion in the Wild and Scenic River System. None of the activities proposed in the 

Roadside Timber Sales will affect these rivers‟ eligibility for inclusion in the Wild and Scenic 

River System, should they be considered for inclusion in the future. 

Cumulative Effects 

Cumulative effects for recreation are mostly related to increased harvest activity along road 

systems on all three islands. Several large timber harvest sales are in different stages of 

planning. This could result in increased traffic on roads and at some marine access facilities on 

Etolin and Zarembo Islands, developments that are also used for recreation by the public. 

Activities authorized under this project will affect roads, but the magnitude of this effect will 

depend on other active harvest operations using the same road systems and marine access 

facilities. The removal of trees expected with the project area will not result in cumulative 

effects to recreation resources, as the volume of removal will be small in size, unlikely to be 

noticed by the casual observer, and unlikely to negatively affect recreation users after harvest 

activities are complete. 
48

Scenery 

The Forest Plan provides standards and guidelines that include the designation of visual priority 

areas, such as travel routes and use areas. These areas were defined considering public input. 

These areas were identified as locations where scenic quality is an integral part of the landscape 

experience. They include land areas viewed while traveling on roads, trails, or marine routes 

(visual priority travel routes) and areas viewed from campgrounds, visitor centers, or permanent 

communities (use areas). The majority of the Wrangell Roadside project area is screened by 

foreground vegetation when viewed from most visual priority travel routes and use areas (VPRs). 

A complete index of VPRs is listed in the Forest Plan, Appendix F. The Forest Plan includes the 

adoption of scenic integrity objectives (SIOs), which provide further direction and guidance for 

managing long-term desired future visual conditions of forest resources especially from those 

areas receiving the highest human use. 

With the exception of areas around the town of Wrangell, other small settlements, and in areas of 

timber management, the majority of the landscape on Zarembo, Etolin, and Wrangell Islands 

shows very little human influence. Timber harvest has occurred on private lands and in many 

portions of National Forest System lands, beginning in the 1950s (or earlier) and continuing 

through the present. Road systems to support timber management have also been developed and 

are visible in many areas of the islands. Around the City of Wrangell, roads, buildings, and other 

structures are visible. 

Direct and Indirect Effects 

The proposed development activities will be seen intermittently from some VPRs. The proposed 

SIOs for much the project area are Moderate and Very Low4

. The implementation of the 

Proposed Action will meet the Forest Plan Standards and Guidelines for scenery for the Timber 

Management, Modified Landscape and Scenic Viewshed LUDs. 

The Proposed Action would contribute a small increase to scenery disturbance throughout the 

project area on Wrangell, Zarembo and Etolin Islands. The Proposed Action would have some 

adverse effects to scenery, but is unlikely to exceed standard and guidelines for scenery at any 

time. 

Cumulative Effects 

Cumulative effects consider the overall effects to scenery expected to result from past, present, 

and foreseeable future projects within and adjacent to the project area. These projects include 

land management activities such as timber harvest, road building and associated construction 

activities, and effects from projects on adjacent non-National Forest System lands. 

At this time, the Proposed Action should slightly increase the cumulative effect of visual change 

as seen from VPRs. However, due to the minimal additional disturbance, the actions associated 

 

4

 Moderate SIO (M): Management and design activities will be subordinate to the landscape character of the area. 

Changes in the landscape may be evident to the casual observer but appear as natural occurrences when contrasted 

with the appearance of the surrounding landscape. 

Very Low SIO (VL): Land management activities may dominate the characteristic landscape. Yet when viewed as 

background, should appear to be a natural occurrence. 
Environmental Assessment 

49

with this proposal will be within Forest Plan Scenery Standards and Guidelines, and will meet all 

SIOs as described in the Forest Plan. 

Soils 

Soils provide the foundation for forest growth and ecosystem health; they can also cause 

detrimental effects to aquatic resources when transported into streams and rivers. Timber harvest 

and road building can affect the ability of soils to support the forest. Geomorphic processes in 

the forest include a variety of landslide types (mass wasting) and erosion of exposed soil (surface 

erosion). These processes occur naturally; however, timber harvest and logging roads can 

increase the frequency and magnitude of mass wasting and surface erosion. 

Direct and Indirect Effects 

Timber harvest may result in soil displacement, exposure, or puddling, which can reduce soil 

productivity. The degree of soil disturbance is related to the type of yarding that occurs within 

the harvest unit. The Proposed Action could include full- or partial-suspension harvest, or 

ground-based systems (shovel), depending on the site conditions. It is assumed that more 

displacement will occur in areas where partial-suspension yarding is used compared to areas 

where full-suspension yarding is used. Ground-based systems are expected to result in the 

highest amount of ground disturbance. Woody debris that is currently on the ground can reduce 

the effect of harvest activities on soils by providing a debris layer between the soil and harvested 

material. This mat of woody debris is commonly used to help support ground-based equipment, 

minimizing soil disturbance. 

Some soil disturbance is an unavoidable consequence of timber harvest. Mitigation measures are 

applied to reduce disturbance, however, it is not possible to eliminate disturbance completely. 

The intent of Regional Soil Quality standards is to maintain soil productivity within acceptable 

parameters. A guideline of 15 percent reduction in inherent soil productivity is established as a 

threshold value for measurable or observable soil properties or conditions. The Proposed Action 

is not expected to reduce inherent soil productivity within the harvest unit beyond this threshold, 

because these guidelines can be met with use of appropriate yarding systems and unit layout. 

Soil effects resulting from the Proposed Action would be reduced by adhering to the Soil 

Management Handbook Standards and Guidelines (1991), best management practices (BMPs) of 

the Soil and Water Conservation Handbook (2006), applicable soils direction included in the 

Forest Plan (Chapter 4 and Appendix C), and the application of erosion control provisions of the 

timber sale contract. These standards and guidelines, along with contractual provisions, include 

site-specific logging requirements such as full or partial suspension of logs, split yarding, and 

controlled felling. By following these requirements, the Proposed Action is expected to result in 

little to no effect to soil productivity. 

On-site processing poses a risk for contamination of surface and subsurface soil and water 

resources from the spill of petroleum products. The risk and potential for effects is 

commensurate with the amount and scale of processing. Fuel spills would most likely happen 

with equipment malfunction, during the servicing or refueling of equipment, or during fuel 

transport. Effects would be minimized by locating the processing, service, and refueling sites 

well away from wetlands and stream channels, on a hardened surface such as road or rock pit, 
50

transporting in approved containers and using properly maintained equipment. Soil and Water 

BMP 12.8 addresses fuel spill prevention; specific issues to address in the annual operating plans 

required by timber sale contracts include the following: 

Locate fuel storage areas in a manner to minimize the potential for contamination of 

surface and subsurface soil and water resources. 

Require a secondary means of containment for the entire contents of the largest single 

tank plus sufficient freeboard to allow for precipitation, per 40 CFR 112. 

Contracts or permits will also require equipment operators to carry absorbent pads and require 

appropriate disposal methods for waste products. 

On-site processing has the potential to generate accumulations of wood. Processing waste and 

bark waste will not be deposited in riparian areas or wetlands. In productive forests with welldrained soils, residual debris will be disbursed to prevent unnatural accumulations, as 

recommended by the soil scientist to maintain soil productivity according to the site conditions. 

Disposal on roads or in rock pits will be approved during the annual proposed sale plan. 

Stockpiling large volumes of wood and bark waste would be done in accordance with a disposal 

and monitoring plan developed after a thorough analysis of effects based on site conditions. 

Cumulative Effects 

At the stand level, no cumulative effects from timber or fuelwood harvest activities are 

anticipated. 

At a project level, cumulative effects are viewed as the summation of the disturbance or potential 

soil disturbances in the project area. Activities resulting in cumulative effects on soil resources 

in the project area include past and future timber harvest, roads, and natural disturbances such as 

windthrow and landslides. Future timber harvest that follows Forest Plan Standards and 

Guidelines and implements BMPs is not expected to cause a cumulative negative effect to the 

soil resource. Road maintenance, as well as use, can lead to increased soil erosion; the amount is 

not quantified but is expected to be relatively low. Landslides and windthrow may negatively 

affect soil quality by accelerating soil erosion. The amount is not quantifiable but is expected to 

be relatively low. On-site log milling is not anticipated to affect soil resources. 

Karst 

Karst vulnerability categories are used to identify appropriate standards and guidelines. 

Vulnerability categories are based on the idea that some parts of a karst landscape are more 

sensitive than others to planned land uses. The differences in vulnerability or sensitivity of a 

particular system are typically a function of the extent of karst development, the openness of the 

karst system, and the sensitivity of other resources that benefit from the karst ground water 

systems. 

The only area within the project area known to have karst is on Etolin Island. The karst is 

located along Roads 6542, 6545, 6538, 51009 and 6540 near Kindergarten Bay and north toward 

Quiet Inlet, and includes high-, moderate- and low-vulnerabilty karst lands along these existing 

roads. There is one known cave. 
Environmental Assessment 

51

Direct and Indirect Effects 

Under the current Forest Plan Standards and Guidelines, as clarified in Appendix H, no harvest 

will occur on high-vulnerability karst lands; thus, there will be no effects on those lands. Based 

on Forest Service inventories of karst lands in Southeast Alaska, of any karst lands found 

adjacent to existing road, 20-30 percent of the karst will likely be high vulnerability. These lands 

will be removed from consideration for timber harvest during the annual review process. In 

moderate-vulnerability karst lands, individual karst features will be buffered to maintain existing 

environmental condition around the features. Identification of appropriate practices and 

necessary mitigation during the annual project review process will prevent significant 

impairment of karst lands during implementation of projects. 

Potential effects from on-site processing include leachate5from large volumes of stockpiled 

wood waste and contamination from fuel associated with processing. On-site processing 

facilities could be located to prevent or minimize effects to karst lands. 

Cumulative Effects 

The cumulative effects area is all karst lands on Etolin, Wrangell, and Zarembo Islands as 

defined by the Forest Plan. Road construction, rock pit development and timber harvest have 

occurred on karst lands in the project area in the past. These activities may have affected karst 

systems by contributing sediment or interrupting hydrologic systems. Implementation of current 

standards and guidelines is expected to minimize the potential to affect karst lands. 

Wetlands 

Wetlands are defined as “those areas that are inundated or saturated by surface or groundwater 

with a frequency and duration sufficient to support, and that under normal circumstances do 

support, a prevalence of vegetation typically adapted for life in saturated soil condition”, per 

CFR Title 40 Section 230.41. They are plentiful in Southeast Alaska, especially in areas with 

gentle terrain, where roads are constructed. The high precipitation in the areas contributes to 

their abundance. 

A variety of wetland types are found in the project area. The most common wetlands are open 

muskegs, scrub forest/muskeg complex, and forested wetlands. Less common but more 

important biologically are lacustrine wetlands associated with ponds and lakes, riverine wetlands 

associated with streams, and estuarine systems along the coast. Wetlands are valued for their 

intrinsic properties as well as the goods produced by them. Aesthetics, recreational use, timber 

harvest, and plant and wildlife habitat are examples of some of the values associated with 

wetlands. Wetlands functions include flood moderation, ground water exchange, and reduction 

of runoff and sedimentation. 

For this project, it is anticipated that commercial timber harvest will only occur on forested 

wetlands that meet suitable criteria as described in Appendix A of the Forest Plan. The 

predominant effect of timber harvest activities on wetlands is from road building; however, no 

road building is proposed in this project. Equipment operation also affects wetlands, since 

 

5

 Leachate is a solution formed by downward percolating ground water dissolving soluble materials from the byproducts of on-site processing. 
52

wetlands have low bearing strength, making them highly susceptible to permanent alteration due 

to both off-road recreation vehicles and logging equipment. Harvesting timber on forested 

wetlands temporarily changes the hydrology of the site. A temporary increase in soil moisture is 

expected until transpiration and interception is reestablished. In wetlands, tree growth is 

impeded due to wetness, and the increased wetness associated with timber harvest further 

impedes growth. 

On-site processing, which is included in the Proposed Action, has the potential to affect 

wetlands. Detrimental activities associated with processing can include the deposit of byproduct in wetlands, and filling wetlands to create a processing site. Leaving limbs and tops 

from trees cut in forested wetlands would not be detrimental. However, deposition of limbs and 

tops from trees cut elsewhere, and stockpiled in a wetland would likely be considered an adverse 

effect on the wetland. 

Direct and Indirect Effects 

Yarding disturbance is expected to be the primary and longest-lasting effect to wetlands in this 

project, since no road building is proposed. Heavy equipment operating in wetlands with low 

bearing strength can cause long-term alteration of the wetland. Typically, waste wood or slash is 

placed as a mat to increase bearing strength, preventing the equipment from creating excessive 

rutting or craters when equipment is sunk. 

Timber harvest on wetlands is expected to be a partial harvest in most areas, which is expected to 

result in minimal change to the canopy, and associated hydrologic processes. 

Potential effects from onsite processing can include leachate from large volumes of stockpiled 

wood waste and contamination from fuel associated with processing. Onsite processing facilities 

will be located to prevent or minimize affecting wetlands. 

Cumulative Effects 

This project will overlap with other Forest Service timber sale/road construction projects and 

private firewood collection along the three island road systems. No significant negative 

cumulative effects to wetland resources are expected to occur as a result of implementing the 

project action alternative because: 

There will be no road construction. 

The projects’ specifications greatly limit the scope and scale of effect. 

On-site log milling is not anticipated to occur in wetlands. 

What Mitigation and Monitoring Is Necessary For This 

Project? 

Many of the effects to various resources are reduced or avoided through Forest Plan Standards 

and Guidelines including the best management practices which meet the requirements of the 

Clean Water Act. Any additional mitigation measures would be identified during the 

development of timber sale proposals for the annual sale plan. 
Environmental Assessment 

53

Monitoring will be conducted using the Forest Plan Monitoring and Evaluation Plan (Forest 

Plan, Chapter 6). Where applicable, timber sales from this project will be included as the part of 

the sampled units for monitoring. In addition, the following project-level monitoring is included: 

Heritage - Following harvest activities, a Forest Service archaeologist will visit a sample of 

harvest areas to assess the nature of ground disturbance and verify the presence or absence of 

cultural resources. 

Vegetation - All of the areas proposed for timber harvest are expected to meet the requirements 

of the National Forest Management Act regulations (certified as restocked within 5 years of 

harvest). Regeneration (stocking) surveys will be conducted on all harvest units after the fourth

full growing season following the completion of logging. All harvested areas are expected to be 

naturally stocked and certified by this time. Monitoring of previous harvesting on the Wrangell 

Ranger District shows a 100 percent regeneration success rate. 

Wildlife - Following harvest activities, a Forest Service biologist will visit a sample of harvest 

areas to assess the nature of effects on wildlife species. 
54

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APPENDIX 1 

WRANGELL ROADSIDE TIMBER SALES EA 

IMPLEMENTATION PLAN 

A1-1 

Appendix 1 

Wrangell Roadside Timber Sales EA Implementation 

Plan 

This implementation plan provides direction for the site-specific resource review of each 

potential timber sale proposed under the decision for the Wrangell Roadside District Roadside 

EA. 

If any resource concern for a proposed sale cannot be successfully mitigated or does not conform 

to the Forest Plan Standards and Guidelines, the proposed timber sale would not be implemented 

under this EA, and a separate NEPA analysis would be required. 

The effects to various resources are reduced or avoided through the use of Forest Plan Standards 

and Guidelines including the best management practices which meet the requirements of the 

Clean Water Act. Additional mitigation measures may be identified during the development of 

timber sale proposals for the annual sale plan. 

Monitoring will be conducted using the Forest Plan Monitoring and Evaluation Plan (Forest 

Plan, Chapter 6). Where applicable, timber sales from this project will be included as the part of 

the sampled units for monitoring. 

Annual Sale Plan 

The annual proposed sale plan will generated from the individual timber harvest proposals 

received from the public and timber operators. The specific location, sale type, volume in MBF, 

logging systems and silviculture prescription for each timber sale will be established for each 

proposal. Each proposal will go through an interdisciplinary environmental review. A Timber 

Sale Proposal for each sale will be prepared (Exhibit 1) with a map and a unit card narrative. 

Resource concerns and applicable Forest Plan Standards and Guidelines, best management 

practices (BMPs), and specific mitigation measures will be identified on the unit card narrative. 

The individual sale proposals will be incorporated into an annual proposed sale plan with a brief 

narrative for each sale and a summary sheet of all sale proposals with acres, volume, type of sale 

and whether requested by a purchaser and other comments. These proposals will be reviewed 

and approved by the Wrangell District Ranger, who will determine which sales will be offered 

that year. The District Ranger will also determine the level of additional environmental review 

necessary. 

Throughout the year, local operators may locate desired timber for purchase and approach the 

Forest Service with a proposal. Any timber sale proposals or requests that fall within the 

guidelines of this plan that occur after the annual sale plan has been completed for that fiscal 

year will be either incorporated into the plan for the next fiscal year, or if time and personnel 

allow, follow the same procedures as the current year‟s proposal. 
A1-2 

Environmental Review 

The environmental review will be interdisciplinary and may include the following if applicable. 

Timber/Silviculture 

A silvicultural prescription will be added to the sale folder. Harvest must be documented and 

updated in appropriate TIM, FACTS and GIS databases, including vegetation databases with 

corrections for volume remaining. The appropriate harvest method will be assesses to minimize 

ground and vegetation disturbance. Proposals will be assessed to ensure green-up and 

regeneration requirements are met. 

All of the areas proposed for timber harvest are expected to meet the requirements of the 

National Forest Management Act regulations (certified as restocked within 5 years of harvest). 

Regeneration (stocking) surveys will be conducted on all harvest units after the fourth full 

growing season following the completion of logging. All harvested areas are expected to be 

naturally stocked and certified by this time. Monitoring of previous harvesting on the Wrangell 

Ranger District shows a 100 percent regeneration success rate. 

Transportation 

Roads not open to the public through the District Travel Management Plan may be authorized by 

a permit for management associated with an individual timber sale (CFR Title 36 Section 212). 

Harvest activities will be designed to avoid impacting the public and to limit impacts to the road 

surface and drainage structures. 

Wildlife Species 

The most current information on raptor nests and wolf dens and associated buffers will be 

assessed. Also, any survey information within development LUDs for threatened/endangered, 

sensitive/proposed species, and sensitive, MIS, and other species identified for protection in the 

Forest Plan will be assessed. 

The most current versions of the Alaska Region sensitive species list and Tongass National 

Forest MIS list will be used in the assessment. 

Any occurrence of raptors, wolves, or great blue herons, or any previously undiscovered 

individuals of endangered, threatened, or sensitive species, their sign, or key habitats for any 

MIS or other species prior to or during the implementation of this project will be evaluated to 

assess the need for additional avoidance or mitigation measures. 

Any proposals within 1⁄2 mile of trumpeter swan wintering habitats, located at Pats Lake and 

Thoms Lake on Wrangell Island will require additional analysis. 

Following harvest activities, a Forest Service biologist will visit a sample of harvest areas to 

assess the nature of effects on wildlife species. 

Old-growth Wildlife Habitat and Connectivity 

Cumulative impacts will be assessed if the timber sale is within a coarse canopy stand (SDM 67 

as determined by the GIS size density layer) or if proposals occur within the following locations 

where concerns for wildlife habitat connectivity have been identified. 

On Etolin Island, important wildlife habitat connectivity areas include: 
 Appendix 1 – Implementation Plan 

A1-3 

Road 6540 from milepost (MP) 0.00 to 3.69, from 6.18 to 6.37 (right side only), from 

6.18 to 6.76, from 6.76 to 6.93 (right side only - this section also has some slivers of 

harvestable area on the right side of the road, and slivers of deferred harvest on the left 

side that were ignored), and from 8.90 to 9.63 (right side only) 

Road 6547 from MP 0.00 to 0.89 (entire length of the road) 

Road 6548 from MP 0.00 to 0.67 (entire length of the road) 

Road 51720 from MP 0.00 to 1.47 

On Wrangell Island, wildlife habitat connectivity areas include: 

Road 6270 from MP 0.13 to 1.18 

Road 50016 from MP 0.00 to 0.15 

Road 50022 from MP 0.44 to 2.05 

On Zarembo Island, wildlife habitat connectivity areas include: 

Road 6590 from MP 37.43 to 37.82

Road 6592 from MP 3.72 to 4.01 

The Forest Plan includes a requirement for legacy trees for VCUs 4550 and 4570 on Zarembo 

Island. Salvage logging of legacy trees that were left in the harvest of the original logging 

systems/transportation unit is generally prohibited unless the rationale is clearly documented and 

the effects are clearly neutral or an improvement (Forest Plan page 4-90). 

Subsistence 

Areas that are heavily used for subsistence hunting of deer should be identified to ensure that 

hunter and operator safety is considered during timber harvest. 

Aquatics 

All streams will be identified by stream class and channel type during on-site inspections or 

using GIS data. If additional streams are found that are not on GIS, these streams will be added 

based on 2008 Forest Plan, Channel Type – Appendix D. Riparian management areas consisting 

of no-harvest and RAW buffers will follow Forest Plan Standards and Guidelines pp. 4-50 to 4-

53. See also FSH 2090.21 (2001) Chapter 10, Section 12. 

Botany and Invasive Plants 

The most current information on rare, sensitive, and invasive plants will be used to assess the 

proposals to evaluate the need for additional avoidance or mitigation measures. The most 

current versions of the Alaska Region Sensitive species list and Tongass National Forest rare 

plant list will be used. The Tongass National Forest High Priority Invasive Plant Species List of 

priority species will be used to assess invasive plants. 

Any occurrence of previously undiscovered rare or sensitive plants at any time before or during 

implementation of this project will be evaluated to assess the need for additional avoidance or 

mitigation measures. 

Timber sale proposals will include site-specific practices that need to be implemented to prevent 

the introduction and spread of invasive plants. This will include road maintenance activities 

associated with individual sales. Management considerations and mitigation will be noted on the 
A1-4 

unit card narrative. However, on a site-specific basis, other species may be of concern and 

warrant prevention practices. 

The 2008 Tongass Forest Plan Invasive Species Standards and Guidelines (page 4-22) and 2007 

Tongass NF Invasive Plant Management Supplement provide policy for minimizing spread of 

invasive species. The Tongass National Forest has a standard seed mix and fertilizer application 

rate that is compatible with invasive plant policy. 

Possible mitigation measures include: 

The use of hay or straw bales for erosion control shall be avoided. Weed-free jute 

matting, synthetic sediment fence or other weed-free materials will be used where 

necessary. 

To prevent the spread of existing species, it may be necessary to eradicate them prior to 

operating in the area. Known species in the project area include reed canary grass, 

hawkweeds, bull thistle, oxeye daisy, common dandelion, hairy cats‟ ear, and wall 

lettuce. If any known species exist that may become involved in the harvesting or 

transport for an individual sale proposal this will be noted on the unit card narrative. 

Heritage 

Locations of the timber sale proposals will be reviewed each year for the determination of any 

known heritage sites. Since potential ground-disturbing activities are associated with this project 

and there are a few areas in the high archeological site sensitivity zone, a qualified archeologist 

will review proposed harvest locations, including an existing data search for known historic 

properties and previous surveys. Additional field survey needs may be identified. If no survey is 

needed, the project may proceed and the rationale for the determination will be documented and 

tracked in the corporate database. If a survey is needed, standards and guidelines for the conduct 

of field surveys as defined in the Programmatic Agreement with the Advisory Council on 

Historic Preservation and the Alaska State Historic Preservation Officer will be followed. 

Following harvest activities, a sample of harvest areas will be assessed to verify the presence or 

absence of cultural resources. 

Recreation 

If a timber sale proposal is located adjacent to a recreation site or on a route to a recreation site, 

this should be noted on the unit card narrative along with any actions needed to minimize 

impacts to the users. Possible recommendations to minimize the effects to users and to increase 

safe operations may be additional signing, prohibition of operational work on weekends or 

during certain times of the year and notification through the Recreation and Roads report on 

KSTK (local radio station), along with public notices in the Wrangell Sentinel (local newspaper). 

The possibility of temporary wood processing on site will be determined and noted on the unit 

card narrative. If proposed work has the potential to disrupt users at a recreation use area 

through dust and/or noise, alternate sites will be identified and will become part of the sale 

proposal. 

In identifying proposals, especially on Wrangell Island, there may be instances when removal of 

trees can improve a recreation site or travel route by improving the safety of the site, improving 

sight distance along a road or opening up views from those locations. These opportunities 

should be coordinated with the recreation management staff. 
 Appendix 1 – Implementation Plan 

A1-5 

Scenery 

The Visual Priority Travel Routes and Use Areas are designated in the 2008 Forest Plan and will 

be noted on the unit card narrative. 

Soils 

During field review, if any slopes are over 72 percent or if wetlands are present, it will be noted 

on the unit card narrative. A soil scientist will need to conduct an on-site evaluation of any 

proposed harvest area over 72 percent to determine if the slopes are stable for the proposed 

harvest. (Forest Plan page 4-65.) 

Appropriate mitigation and design measures will be applied to avoid significant adverse effects 

to the soil resources. Seeding may be used to ensure that ground cover is established in a timely 

manner to reduce soil erosion. If seeding cannot be completed prior to September 15, or appears 

unsuccessful by that time, other erosion control measures must be applied to disturbed areas near 

surface waters before heavy fall rains and frost. Ensure that the current Tongass National Forest 

erosion control seed mix is used. 

Appropriate logging systems will be required to ensure that harvest will result in minimal ground 

disturbance. 

Wetlands 

Using field review, GIS soils information, and the National Wetland Inventory data, possible 

wetlands requiring protection will be identified on the unit card. Appropriate protection 

measures to avoid adverse effects will be included on the unit card, in accordance with the Forest 

Plan Wetlands Standards and Guidelines, page 4-88. Contract provisions that may be included 

are: 

Trees felled into muskegs or other non-forested (non-commercial) wetlands shall be 

removed by suspension cable or other low-impact yarding systems. 

In forested wetlands, shovel or other logging/yarding equipment will be supported by 

slash to minimize disturbance. Material used to construct mats for equipment operation 

will be dispersed after use. 

Prior to discharging material into wetlands, the site will be approved to ensure that 

wetland functions are protected. 

Timber sale proposals will be reviewed to assess impacts on high-value wetlands. This includes 

fens near karst, dome bogs, and other wetlands that are providing a special habitat such as the 

Earl West marsh, and Salamander marsh along the 50500 Road. 

Karst 

The only area within the project area known to have karst is on Etolin Island. The karst is 

located along Roads 6542, 6545, 6538, 51009 and 6540 near Kindergarten Bay and north toward 

Quiet Inlet, and includes high-, moderate- and low-vulnerabilty karst lands along these existing 

roads. There is one known cave. (See Navy Final EIS 2009.) 

The latest karst information will be obtained and any possibility of karst will be noted on the unit 

card narrative. The unit card narrative will include a description of any specific needs to 

mitigate concerns to karst lands. These may include: 

A windfirm, no-harvest buffer for loosing streams. 
A1-6 

Resurgent streams will be protected to protect and maintain the environment surrounding 

the springs and the quality of the waters flowing from them. 

Measures will be taken to reduce erosion and sediment transport from the road surface 

and cut-slopes in karst lands. 

Suspension requirements will protect surface soil and vegetation and disturbance would 

be minimal. 

Water will not be diverted to or from karst features. 

By-products from on-site processing will not be scattered on land underlain by karst. 

By-products from on-site processing will be placed where leachate will not run off onto 

karst lands. 

Process for Consideration of New Information 

In the event that there is new information or changed direction for any resource occurs during the 

implementation of the decision on Wrangell Ranger District Roadside EA, the following Forest 

Service direction from Forest Service Handbook (FSH) 1909.15, section 18.1 will be used to 

evaluate the previous analysis: 

If new information or changed circumstances relating to the environmental impacts of a 

proposed action come to the attention of the responsible official after a decision has been 

made and prior to completion of the approved program or project, the responsible official 

should review the information carefully to determine its importance. Consideration 

should be given to whether or not the new information or changed circumstances are 

within the scope and range of effects considered in the original analysis. 

Based on further direction in FSH 1909.15 section 18, after interdisciplinary review and 

consideration of the changed circumstances or the new information, the responsible 

official may determine whether or not a correction, supplement, or revision to the EA is 

necessary. If a supplemented or revised EA and FONSI is completed, a new decision 

notice would be issued, or, documentation that the original decision is to remain in effect 

and unchanged, following direction in FSH 1909, chapter 40. 

If a sale is already under contract and new information arises, the direction to evaluate 

whether changes need to be made to the contract, in Forest Service Handbook (FSH) 

1909.15, Tongass National Forest Supplement, TNF 1909.15-2009-1. 
 

A1-7 

Instructions: Below is an example of a Unit Card narrative with some of the information that may be 

necessary. More information may be needed depending on the proposal. 

Exhibit 1 

TIMBER SALE PROJECT PROPOSAL

Wrangell Ranger District 

FY 20XX 

<Name of Timber Sale>

<Location – which island>

Preparer: Date: Approved: Date:

Plan to be Offered: Sold: Y / N Purchaser:

LUD: Type of Sale: 

Commercial Fuelwood (Green / Dead), 

Microsale, or Salvage Sawtimber

Total Unit Acres: Net Harvest Volume 

MBF:

VCU:

TM Compartment:

Logging Systems: Harvest Acres: Species:

Stand Number(s): Photo Number:

SILVICULTURE:

Existing Stand Condition: Describe stand species composition of overstory trees and advanced regeneration, quantity of 

advanced regeneration, residual tree windfirmness, and physical health and condition of residual trees (any insect and 

diseases, blowdown, etc).

Silvicultural Prescription: Complete RX needs to be prepared by a certified silviculturist and placed in the sale folder.

Reference: Forest Plan Standards and Guidelines p. 4-15

LOGGING: 

Describe any specifics needed – partial /full suspension.

Reference: Forest Plan Standards and Guidelines p. 4-70

TRANSPORTATION/ACCESS: 

What roads will be used for access? Note LTF, if needed. What is status of road according to the Wrangell RD Access 

Travel Management Plan? Is permit required in accordance with CFR Title 36 Section 212? 

Reference: Forest Plan Standards and Guidelines p. 4-80

FISH/WATERSHED: Describe any streams and protection needed as shown on the map. (GIS layer)

Reference: Forest Plan Standards and Guidelines p. 4-9 (fish)

WILDLIFE: Were any raptor nests known or observed? Any raptors seen in the area? 

GIS data, or information gathered from persons familiar with the harvest area.

Reference: Forest Plan Standards and Guidelines p. 4-89 (wildlife) and p. 4-68 (subsistence)

SOILS/WETLANDS: Presence of slopes >72%. Presence of wetland soils. (GIS wetland layer, Site visit)

Reference: Forest Plan Standards and Guidelines p. 4-64 (soils) and p. 4-88 (wetlands)

RECREATION: Is sale located near on the route to an inventoried recreation site? (Recreation Sites GIS layer, Wrangell 

Island Map)

Reference: Forest Plan Standards and Guidelines p. 4-43

SCENERY: Is sale located along a Visual Travel Priority Route? (Forest Plan, Appendix F)

Reference: Forest Plan Standards and Guidelines p. 4-56

HERITAGE RESOURCES: Contact archaeologist.

Reference: Forest Plan Standards and Guidelines p. 4-16

LANDS: Is the sale adjacent to other owner ship? Any SUPs nearby? Powerline?

Reference: Forest Plan Standards and Guidelines p. 4-27

GEOLOGY/KARST: Any karst known in the area?

Reference: Forest Plan Standards and Guidelines p. 4-23

BOTANY: Any sensitive, rare or invasive plants known in the area? (GIS botany layers)

Reference: Forest Plan Standards and Guidelines p. 4-41 (plants) and p. 4-22 (invasive species)
Appendix 1 – Implementation Plan 

A1-8 

Sale Area Map 

Map needs to have: 

unit boundary

roads and road numbers

streams by stream class

north arrow

legend

scale

date
 

A1-9 

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APPENDIX 2 

ESSENTIAL FISH HABITAT

A2-1 

Appendix 2 

Essential Fish Habitat 

Essential Fish Habitat (EFH) is the water and substrate necessary for fish spawning, breeding, 

feeding, or growth to maturity. The marine EFH in Alaska includes estuarine and marine areas 

from tidally submerged habitat to the 200-mile exclusive economic zone (EEZ). The freshwater 

EFH includes streams, rivers, lakes, ponds, wetlands and other bodies of water currently and 

historically accessible to salmon. EFH for Pacific salmon recognizes six critical life history 

stages: (1) spawning and incubation of eggs, (2) juvenile rearing, (3) winter and summer rearing 

during freshwater residency, (4) juvenile migration between freshwater and estuarine rearing 

habitats, (5) marine residency of immature and maturing adults, and (6) adult spawning 

migration. Habitat requirements within these periods can differ significantly, and any 

modification of the habitat within these periods can adversely affect EFH. 

Assessment 

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

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

or proposed actions that may adversely affect Essential Fish Habitat. The Act promotes the 

protection of EFH through review, assessment, and mitigation of activities that may adversely 

affect these habitats. On August 25, 2000 the Forest Service, Alaska Region, and NMFS came to 

an agreement on how consultation will be accomplished in Alaska. 

This Wrangell Roadside Timber Sales Environmental Assessment (WRD Roadside EA) satisfies 

the consultation requirements by providing a description and assessment of EFH in the project 

area, a description of the proposed project and its potential effects on these habitats, and a 

description of the mitigation measures that would be implemented to protect these habitats. The 

formal consultation starts when NMFS receives a copy of the Environmental Assessment with 

the EFH Assessment. NMFS may then respond in writing as to whether it concurs with the 

findings of the assessment or make conservation recommendations. The Forest Service must 

respond to any recommendations made by NMFS within 30 days. For specific information on 

the location and the actions under consideration, please refer to the EA. 

The project area includes areas adjacent to the open road systems on Etolin, Wrangell, and 

Zarembo Islands of the Wrangell Ranger District, which is part of the Tongass National Forest. 

The streams and lakes within the project area support a variety of anadromous and resident fish 

species. Anadromous species that spawn in freshwater streams or lakes in the project area 

include pink salmon (Oncorhynchus gorbuscha), chum salmon (O. keta), coho salmon (O. 

kisutch), coastal cutthroat trout (O. clarkii), steelhead (rainbow) trout (O. mykiss), and Dolly 

Varden char (Salvelinus malma). The project area also supports resident populations coastal 

cutthroat trout (O. clarki), Dolly Varden char (Salvelinus malma), and non-game fish species 

including sculpin (Cottus spp.) and three-spined stickleback (Gasterosteus aculeatus).

The analysis area supports a large amount of EFH and includes all of the freshwaters that 

intersect or lie adjacent to the open road systems. These waters are cataloged in Tongass 

National Forest GIS library. 
A2-2 

This project would authorize the use of marine access facilities (MAFs) to facilitate the 

movement of equipment to the island road systems and remove wood material. Wood material 

could either be floated or loaded directly to a barge or boat for transport. These facilities are 

located at Starfish Cove on Etolin Island, Earl West Cove and Pats Creek on Wrangell Island, 

and St. John Harbor and Roosevelt Harbor on Zarembo Island. The available information for 

these facilities suggests that effects to marine environments due to past or current usage are 

within acceptable limits of bark accumulation, the principle affecting agent, set forth by State 

and Federal regulations. It is uncertain exactly what plant and animal species are present at these 

locations, but certainly eelgrass, various kelps, invertebrates, fish, birds, and marine mammals 

that are locally common to Southeast Alaska marine waters could be present either annually or 

seasonally. 

Potential effects on freshwater EFH from harvesting timber as part of this project may include 

increased peak flows and increased sediment delivery, which may reduce downstream habitat 

quality for salmon. Potential changes in physical habitat may include reduced pool volume due 

to filling from sedimentation and changes in substrate composition. Pool water volume is 

important to the rearing and over-wintering of juvenile fish. Increases in fine sediment in the 

substrate can reduce survival of salmon eggs and change the assemblages of aquatic insects used 

by fish for food. Potential effects to marine EFH may include deposition of wood debris that can 

smother aquatic organisms or the accidental spill of fuel during equipment transfer that can kill 

marine life. 

The effects of harvesting in individual watersheds on freshwater aquatic resources under this EA 

are expected to be undetectable. This is due to the wide distribution and infrequency of natural 

disturbance events that generate salvage opportunities, the application of Riparian Area 

Standards and Guidelines, and the project‟s proposal to remove primarily dead and down timber 

and a limited amount of single-tree selection green timber. Furthermore, review of the annual 

proposed sale plan would provide the opportunity to modify any project activities to protect 

freshwater resources. The current integrity of riparian areas and streams would be maintained in 

the project area. Implementation of this project is not expected to increase significantly the 

cumulative effects on watersheds, water quality, and/or associated fish species and habitat. 

The effects of using MAFs on marine resources under this EA are expected to be undetectable 

because movement of wood material at these facilities would be limited and there is a low 

likelihood that logs would be floated with any project activities. Furthermore, review of the 

annual proposed sale plan would provide the opportunity to modify any project activities to 

protect marine resources. The current integrity of marine habitats would be maintained in the 

project area. Implementation of this project would not be expected to increase significantly the 

cumulative effects on marine habitats or organisms. 

Determination 

The Forest Service determines that the Wrangell Roadside Timber Sales project “may adversely 

affect Essential Fish Habitat” because the project entails ground-disturbing actions (i.e., timber 

harvest) in watersheds that contain anadromous species, and log hauling would occur on existing 

roads that cross anadromous fish streams. In addition, the project would authorize the use of 

marine transfer facilities. 

The Tongass Land and Resource Management Plan (Forest Plan) provides specific guidance in 

the form of standards and guidelines. Riparian Standards and Guidelines were specifically 
Appendix 2 – Essential Fish Habitat 

A2-3 

developed through a collaborative effort involving lead watershed and fisheries scientists from 

Federal and State (Alaska Department of Fish and Game) agencies. Forest-wide standards, 

guidelines, and best management practices – developed to meet water quality standards, and to 

protect and enhance watershed processes and fish habitat – are believed to be sufficient to protect 

EFH. 

The Forest Service will ensure that adverse effects to freshwater EFH would be minimized for 

the following reasons: 

management activities would occur outside of EFH; 

no-harvest aquatic habitat buffers would be delineated prior to any harvest activities 

according to Forest Plan Standards and Guidelines to protect these habitats; 

in areas where windthrow occurred or may occur, buffer widths on Class I, II and III 

streams would be increased, and additional trees would be left standing to insure 

resistance to windthrow; and 

best management practices would be implemented to protect water quality and aquatic 

habitat for all freshwaters affected by the project. 

There would be very little or no adverse effects to marine EFH as a result of implementing this 

project because: 

operators would be required to follow contract stipulations and Log Transfer Facilities 

Guidelines (Forest Plan, Appendix G) that regulate MAFs to protect resources (e.g., fuel 

transfer, debris containment, etc); 

the scope and scale of this project suggests that very little wood material, if any, would be 

floated for any given sale; and, 

it is anticipated that most wood material would be loaded directly to a barge or boat for 

transport, which would greatly reduce the potential for wood debris to enter the water and 

foul habitats. 

Additional effects to EFH are likely to occur only from unforeseen events. A copy of this EFH 

assessment and WRD Roadside EA were given to NMFS per agreement, and the Forest Service 

will continue the consultation process. 
A2-4 

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APPENDIX 3 

PAST, PRESENT, AND REASONABLY FORESEEABLE 

PROJECTS 

A3-1 

Appendix 3 

Past, Present, and Reasonably Foreseeable Projects 

Past, Present, and Reasonably Foreseeable Projects Included in Cumulative Effects 

Analysis 

Island Project/Activity Name

(Decision Year)

VCU(s) Planned 

Harvest 

Acres1

NEPA 

Volume 

(MBF) 1

NFS 

Road

Miles1

Temp 

Road

Miles1

Zarembo Skipping Cow EIS (2000) 0458, 0459 906 19,000 10.7 3.9

Baht EIS ROD (2007 & 

2008)

0456, 0457, 0458, 0459 1,255 43,500 5.9 8.8

Zarembo EIS (2013) 0456, 0457, 0458, 0460 unknown 40,000 unknown unknown

Mining Exploration unknown N/A N/A N/A N/A

Meter Bight Fishway 

Repair CE (2009)

0459 N/A N/A N/A N/A

St. John Creek Fishway 

Retrofit CE (2008)

0457 N/A N/A N/A N/A

Wrangell Doughnut EA (2000) 0475, 0476, 0477 350 4,900 1.4 0

Backline EA (2005) 0476, 0477, 0478, 0479 471 11,800 0 1

Shady EA (2004) 0478, 0480, 0504, 0505 240 4,630 0 0.6

Wrangell Island Project

EIS (2012)

0475, 0476, 0478, 0479,

0480, 0504, 0505

7,489 91,000 21 10

Middle Ridge cabin const. 

and use (2009)

0477 N/A N/A N/A N/A

Etolin Navy EIS (2009)20464, 0465, 0466, 0467, 

0468

5,434 73,000 8.1 8.8

Porcupine Salvage CE 

(2004)

0465, 0467 26 700 0 0

Fishtrap Salvage CE 

(2005)

0464 240 200 0 0

North Etolin Roadside 

Salvage CE (2008)

0462 250 250 0 0

Districtwide 

(Wrangell, 

Etolin, and 

Zarembo 

Islands)

Wrangell Outfitter/ Guide 

EA 2010

varies N/A N/A N/A N/A

Private and commercial 

firewood

varies N/A N/A N/A N/A

Free use varies N/A N/A N/A N/A

NFS road maintenance varies N/A N/A N/A N/A

1

 Figures are estimates 

2

 Decision reversed, a new ROD is projected for 2011 
A3-2 

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APPENDIX 4 

RESPONSE TO COMMENTS 

Appendix 4 – Response to Comments 

A4-1 

Appendix 4 

Response to Comments 

Appendix 4 includes the comment letters we received on the Wrangell Roadside Timber 

Sales EA, and the Forest Service responses. 

The Forest Service received three letters commenting on the EA: from the public, from 

an organization, and from the State of Alaska. We have considered the issues raised in 

each letter and offer responses, below. Most of the comments have been addressed in the 

EA, as noted in the Forest Service's responses. Other comments requested clarification of 

procedures presented in the EA, also presented in the responses, below. 

Individual comments within each letter have been numbered. Comments are also 

summarized in the numbered Forest Service responses below each letter to help the 

reader correlate the response with the original letter. 
A4-2 
Appendix 4 – Response to Comments 

A4-3 

Forest Service Response to Jim Colier Comments: 

C-1 

Offer smaller sales, like 20-25 MBF, and/or selective logging like Free Use. 

Response: (EA p. 12-13; 14) This project will offer a variety of salvage sale, fuelwood, 

small sales and microsales opportunities; size will depend on purchaser request, up to 50 

MBF per sale. Potential purchasers may propose alder, as well as other species, for a 

sale. 

C-2 

Do not allow fuelwood material to sit and deteriorate on side of road, rendering it 

worthless as firewood. 

Response: Contract provisions will specify utilization and removal of wood, including 

timeframes for removal. 

C-3 

Have the same requirements for commercial fuelwood cutters as commercial loggers – 

logging protocol, cleanup, and signage. 

Response: (EA p. 21; 27) Standard timber sale contract provisions require cleanup, 

maintaining haul roads, and posting appropriate signage. 

C-4 

Be sure public is aware of opportunity and protocol to propose dead standing and other 

sales. 

Response: (EA p. 12; A1-1) Prospective purchasers/local operators may locate desired 

timber within the project area for purchase and make proposals for sales to the FS. The 

public can contact the Wrangell Ranger District for information on upcoming sales. The 

individual timber sales will be advertised using a competitive bidding process. 

C-5 

Small sales should not have to be cable logged; some operators cannot afford a yarder. 

Response: (EA p. 20; 49) Logging systems would include shovel, cable, or helicopter 

yarding, depending on site conditions. All harvest areas are along existing road. 

Prospective purchasers can select desired timber within the project area and work with 

Forest Service personnel to propose a sale based on their operating capabilities. 
A4-4 
Appendix 4 – Response to Comments 

A4-5 
A4-6 
Appendix 4 – Response to Comments 

A4-7 
A4-8 
Appendix 4 – Response to Comments 

A4-9 

Forest Service Response to Alaska State Department of Natural Resources OPMP 

Comments: 

AK-1 

Include all existing roads in development LUDs (including those in roadless areas) as per 

the 2008 Forest Plan in the available project area. 

Response: (EA p. 19, 41) The Secretary of Agriculture has reserved authority for 

decisions in 2001 roadless until long-term policy can be determined. To make the project 

compatible with the roadless policy, the project area was revised to include the area 1,200 

feet (rather than 1,320 feet) from existing roads, and to not enter other inventoried 

roadless areas. 

AK-2 

Directionally fell timber and yard timber away from Class IV and other streams not 

covered by Process Group Standards and Guidelines. Do not allow shovels or other 

equipment to cross Class IV and other streams, to protect banks and beds. 

Response: (EA p. 49) Contractual provisions including full or partial suspension 

requirements, split yarding, and controlled felling will be applied on a site-specific basis. 

Use of shovel yarding will depend on site conditions. 

(EA p. 49; 59-60; A2-2) Following soil standards and guidelines and BMPs assures 

water quality and aquatic habitat protection; integrity of riparian areas will be maintained. 

AK-3 

Ensure that cumulative effects due to adjacent harvest units do not result in significant 

effects to fish and wildlife over time. How will harvest units be sited to avoid significant 

effects to fish and wildlife? 

Response: (EA p. 28) For salvage sales (i.e. blowdown), the actual habitat changes that 

result in fragmentation will have already occurred. No individual green-tree sale would 

exceed 50 MBF, and additional habitat fragmentation as a result of this project should be 

immeasurably small. 

Green tree sales using either individual tree marking or group selection will only harvest 

a small percentage of a given stand for each sale. If group selection harvest is used, the 

individual openings will not exceed 2 acres in size and will be distributed in the stand to 

minimize fragmentation. 

AK-4 

Apply RAW buffers to even-aged units adjacent to riparian management areas. 

Response: (EA p. 23-24) Even-aged harvest in this project is intended to minimize the 

occurrence of potentially adverse effects from windthrow, and to rehabilitate lands 

adversely affected by windthrow. Additional blowdown would be minimized, to the 

extent practicable, by locating the boundary along the edges of natural openings, areas 

containing naturally windfirm trees, or in more-protected areas, such as small draws. 

(EA p. A1-3) Riparian management areas consisting of no-harvest and RAW buffers will 

follow Forest Plan Standards and Guidelines pp. 4-50 to 4-53. 

AK-5 

Avoid green sawtimber sales using group selection in McCormack Creek watershed. 

Response: (EA p. 31) McCormack Creek watershed is already identified as potentially 

sensitive to additional development, and restoration measures such as road closures and 
A4-10

culvert removals have taken place. Any harvest prescription within this watershed would 

take into account previous harvest and potential additional effects. 

AK-6 

Do not authorize green sawtimber or green fuelwood sales in the Anita Bay “pinch point” 

area to preserve connectivity in this area. 

Response: (EA p. A1-2 and 3) This area has already been identified as important for 

connectivity (Etolin Island roads 6540, 6547, 6548). Any green tree harvest in 

connectivity areas will be done in a manner that considers the importance of these areas 

as wildlife corridors. 

AK-7 

Do not authorize green sawtimber or green fuelwood sales in other wildlife habitat 

connectivity areas identified in segments of nine roads in the EA, to preserve connectivity 

in these areas. 

Response: (EA p. A1-2 and 3) As stated regarding the Anita Bay "pinch point", these 

areas have also been identified as important for wildlife connectivity. We are planning to 

manage these areas over time and with harvest prescriptions that will maintain the overall 

connectivity. 

AK-8 

The maximum affected area of coarse canopy habitat (within the project area) would be 

up to 24 percent annually. Recommends that harvest in coarse canopy habitat not be 

authorized. 

Response: (EA p. 28-29; 34; A1-2) The EA recognizes the importance of POG and 

coarse canopy. The 239 maximum annual acres of harvest scenario is an estimate of how 

many overall acres would be required to reach the annual maximum volume of 500 MBF 

if all harvest was single-tree selection, which retains the structure of the stand (EA p. 23). 

Even-aged management, on the other hand, would be prescribed for salvage (dead/down) 

harvest areas; an all-even-aged scenario would affect about 24 acres annually. The 

“maximum affected area of coarse canopy” assumes an unrealistic scenario of all 500 

MBF being green timber harvested from only coarse canopy areas, which (at 980 acres, 

EA p. 29) comprise only about 2 percent of the project area. By contrast, this project is 

designed to provide primarily salvage opportunities of dead/down timber for commercial 

firewood operators as well as some single-tree green sawlog selection for microsales and 

small sales. The green tree harvest in Alternative 2 would be distributed throughout the 

analysis area and specific harvest prescriptions will address impacts to wildlife habitat 

condition. 

AK-9 

Provide maps that show POG and coarse canopy stands in project area. 

Response: (Project records #0122, 0123, 0124) Maps showing POG, and POG corridors 

island-wide (including the project area) for Wrangell, Etolin, and Zarembo Islands are in 

the project record (wildlife folder). Coarse canopy is included in the POG areas. 

AK-10

Provide an estimate of the anticipated maximum annual percent change to remaining 

POG within the project area from implementing the proposed action. 

Response: (EA p. 23; 29) The EA (p. 29) and the wildlife resource report state, 

"Anticipated maximum annual acres affected would be approximately 0.5 percent of the 
Appendix 4 – Response to Comments 

A4-11

[overall] project area annually." The wildlife resource report also states: "Quantitative 

analyses of reductions in timber volume and effects to productive old growth (POG) 

habitats would not be meaningful for this project since the exact location and harvest 

prescriptions that will be used for this project are not known at this time." 

Uneven-aged harvested stands will retain stand structure and species composition at 

levels high enough to maintain function as productive old-growth and remain as part of 

the suitable land base. 

AK-11

State the size, in acres, of the project area. 

Response: (Project record #0151) 44,425 project area acres. 
A4-12
Appendix 4 – Response to Comments 

A4-13
A4-14

Forest Service Response to SEACC Comments: 

S-1 

Prioritize sales and thinning projects on the roads planned for closure under the ATMP. 

Response: (EA p. A1-2) Use of roads that are closed may be authorized by permit for 

management of a timber sale. Future sales that are part of this decision will be prioritized 

along road systems that are being considered for road closure as identified in the ATMP. 

S-2 

Explain whether salvage will be allowed in non-development LUDs per salvage 

standards and guidelines. Please limit salvage S&Gs to parts A, B, and E of the FP. EA 

is unclear at pp. 12-13. 

Response: (EA p. 12-13) While the Forest Plan Salvage Standards and Guidelines (p. 4-

73) allow salvage in non-development LUDs, harvest (including salvage sales) that 

would be authorized under this EA only includes development LUDs. Therefore, part C 

of the Salvage Harvest Standards and Guidelines, regarding salvage in non-development 

LUDs, will not apply. This has been clarified in the EA. Any salvage harvest plans in 

non-development LUDS will be considered and analyzed in a separate NEPA document. 

S-3 

Does “dead AYC for fuelwood” refer only to unmerchantable portions of dead AYC, or 

could it include potential sawlog material? Explain. 

Response: (EA p. 19) Dead yellow cedar has traditionally been the most sought-after 

fuelwood for both personal and commercial firewood cutters. This is primarily because 

of its lower moisture content and ability to cure more rapidly than western hemlock. 

Much of the dead yellow cedar that is cut for firewood is not considered to be 

merchantable sawlog due to sap rot and sun checking that often extends several inches 

into the tree bole. 

S-4 

Explain the discrepancy in the “productive forestland” figures shown in the silviculture 

section, and the “POG” figures shown in the botany section. 

Response: (EA p. 24. 38) Productive forestland and productive old growth (POG) are 

not synonymous terms, although historically (pre-harvest), all productive forestland was 

considered to be POG for this analysis. Productive forestland includes young growth of 

stand size classes 1-3, as well as older saw timber stand size classes 4 and greater. The 

stand size classes 1-3 may be the result of timber management, or natural occurrence 

such as a stand-replacing wind event. It includes forested areas containing timber 

volumes of greater than or equal to 8,000 net board feet/acre or having the potential to 

achieve this volume and capable of maintaining that volume (producing 20 cu. 

ft/acre/year of industrial wood or having a site index of 40 or higher). 

Productive old growth (POG) includes only stand size classes 4 and greater and is oldgrowth forest capable of producing at least 20 cubic feet of wood fiber per acre per year, 

or having greater than 8,000 board feet per acre (Forest Plan p. 7-29). 

The acres of historic productive forestland and historic POG were rerun using the Forest 

Activity Tracking system database (FACTS). The productive forestland and productive 

old growth (POG) acreage figures were updated to read approximately 239,397 acres of 

pre-harvest POG, of which approximately 29,398 acres have been harvested. 
Appendix 4 – Response to Comments 

A4-15

S-5 

a) What monitoring will the FS conduct to evaluate impact of logging in "important 

wildlife connectivity areas"? 

Response: (EA p. 53) Forest Plan Monitoring and Evaluation Plan (FP Ch. 6). In 

addition to FP monitoring, Forest Service sale administration personnel monitor each 

sale. Each sale could potentially be selected at random for the FP annual monitoring 

program. In addition, following harvest activities, a Forest Service biologist will visit a 

sample of harvest areas to assess the nature of effects on wildlife species. 

b) How much connectivity reduction in “high-value stands” is possible before wildlife, 

and human use thereof, is significantly affected? 

Response: EA p. 28 states “Added fragmentation should be immeasurably small, thus 

this project does not cause significant impacts.” The EA Appendix 1, Implementation 

Plan, recognizes and identifies several areas on all three islands important to wildlife 

habitat connectivity, and states that cumulative impacts will be assessed if any timber sale 

proposals are located in these areas. 

c) What standard will wildlife biologist use to assess potential effects on a case-by-case 

basis? 

Response: (EA p. A1-3; A1-8) Forest Plan Wildlife Standards and Guidelines pp. 4-89 

to 91 outlines standards for connectivity. 
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