Appendix ROD-3

New Information since the Navy 

Final Environmental Impact 

Statement (2009)
Table of Contents

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

New Information .............................................................................................1

Relationship to the 2008 Forest Plan...............................................................2

Amendment to the 2008 Forest Plan ...............................................................3

Changes in Policy/Agency Direction since 2009............................................3

Updates to the Analysis and Information in the Navy Timber Sale FEIS ..........9

Issue 1 - Timber Supply/Sale Economics .................................................13

Issue 2 – Wildlife Habitat Fragmentation .................................................19

Issue 3 – Inventoried Roadless Areas .......................................................22

Other Resources ............................................................................................25

Appendix A Reasons for Scheduling the Environmental Analysis of the Navy 

Timber Sale .......................................................................................................43

Appendix B - Updated Response to Comments................................................44

References: ........................................................................................................54
Navy Timber Sale Record of Decision New Information since the 2009 FEIS – APPENDIX ROD-3  A3-1

Appendix ROD-3

Additional Information since the Navy Final 

Environmental Impact Statement 

Introduction

The 2015 Record of Decision (ROD) replaces the 2009 Record of Decision for 

this project. The 2009 Record of Decision selected a modified Alternative D 

and subsequently was remanded on appeal. The Responsible Official was 

directed to either select an alternative that was analyzed in detail in the Final 

Environmental Impact Statement (FEIS), or supplement the Draft EIS (DEIS)

to provide detailed analysis for the Selected Alternative. The Responsible 

Official intends to select Alternative F, which was analyzed in detail in the 

FEIS, ensuring that the public has had adequate opportunity to review and 

comment on the alternative, in compliance with the direction in the Regional 

Forester’s letter of remand.

Before making his decision in the Navy Timber Sale project, the Forest 

Supervisor, the Responsible Official for this decision, directed an 

interdisciplinary team (IDT) to review and analyze any changes in information 

since the 2009 FEIS. The interdisciplinary team identified and analyzed new or 

updated information and compared the effects to the FEIS. 

This report summarizes the analysis of the new and updated information since 

the release of the Navy Timber Sale FEIS in 2009. It was used to inform the 

Responsible Official in making his decision for the Navy Timber Sale project

on the significance of new information. Further analysis was included to 

address or clarify issues raised in the 2009 appeal points that also pertain to 

activities proposed by the 2015 Decision. The results of this analysis are 

documented in the addendums and updates to the resource reports in the Navy 

project record, and summarized in this appendix by resource. The project 

record also includes all of the 2009 appeal points and responses. 

New Information

The Council of Environmental Quality (CEQ) regulations implementing the 

National Environmental Policy Act (NEPA) require Federal agencies to prepare 

supplements to a draft or final EIS if “[t]he agency makes substantial changes 

in the proposed action that are relevant to environmental concerns” or “[t]here 

are significant new circumstances or information relevant to environmental 

concerns and bearing on the proposed action or its impacts.” 40 CFR § 

1502.9(c)(1). To comply with this requirement, the Forest Service Handbook 

(FSH) 1909.15-2012-3, Chapter 10, 18.1 provides the following direction:
Appendix ROD-3

A3-2  APPENDIX ROD-3 - New Information since the 2009 FEIS Navy Timber Sale Record of Decision

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.

The FSH addresses new information arising after a decision has been made. 

The new and additional information for Navy Timber Sale has undergone 

interdisciplinary review and is available to the Responsible Official prior to the 

2015 Decision, enabling a better-informed decision. 

Appendix ROD-3, “Additional Information since the Navy Final 

Environmental Impact Statement”, summarizes the results of this

interdisciplinary review. This review of new information and direction did not 

disclose any “significant new circumstances or information relevant to 

environmental concerns and bearing on the proposed action or its impacts” that 

would require a supplemental EIS under NEPA (40 CFR § 1502.9(c)). The 

Navy project has not made substantial changes in the proposed action that are 

relevant to environmental concerns. There are no changes, new information, or 

circumstances that may result in significant environmental impacts in a manner 

not previously evaluated or considered. The new information or changed 

circumstances are within the scope and range of effects considered in the 

original analysis.

Relationship to the 2008 Forest Plan

The Navy FEIS and March 2009 Decision incorporated direction from the 

Forest Plan (January 2008). The decision in the Forest Plan contains transition 

language for the Navy Timber Sale project. The direction in the decision for 

the 2008 Forest Plan was “to review these projects, and incorporate the new 

direction in the amended Forest Plan to the extent this can be done without 

causing major disruptions in the implementation of these projects.” This 

project began under the direction of the 1997 Forest Plan in 2006, and the Navy 

DEIS was released November 2, 2007. Direction between the 1997 Forest Plan 

and the 2008 Forest Plan Amendment did not significantly change the 

management direction of the project area for this project. Navy and the other 

projects in Category 2 were also assumed to be implemented in the 

environmental analysis in the 2008 Forest Plan Amendment FEIS. Therefore, 

because the FEIS considered these projects in its effects analysis, their 

implementation is not in conflict with the amended Plan. 

Although there have been non-significant amendments to the Forest Plan since 

it was signed in 2008, none of these amendments would affect the Navy 

project.
Appendix ROD-3

Navy Timber Sale Record of Decision New Information since the 2009 FEIS – APPENDIX ROD-3  A3-3

Amendment to the 2008 Forest Plan

The 2008 Forest Plan is currently undergoing an amendment, including public 

involvement, and release of the DEIS which is expected to be available for 

public comment around mid-2015. Some of the issues being considered in the 

current amendment include the transition to young-growth management, 

renewable energy opportunities, roadless area considerations, and wildlife 

habitat and the conservation strategy. 

As described above, since Navy and the other projects in Category 2 were 

assumed to be implemented in the environmental analysis in the 2008 Forest 

Plan Amendment FEIS, their implementation is not in conflict with either the 

2008 Plan Amendment or the current Forest Plan Amendment direction.

Changes in Policy/Agency Direction since 2009

Project-Level Pre-decisional Administrative Review Process

The Consolidated Appropriations Act of 2012, Section 428, directed the 

Secretary to establish a project-level pre-decisional administrative review 

process (“objection process”) for projects and activities implementing land 

management plans, in place of the post-decisional appeals process used by the 

agency since 1993. The Navy Timber Sale project has gone through the 

objection process (36 CFR 218) which replaced the appeals process (36 CFR 

215) on March 27, 2013. Under the objection process, rather than filing 

appeals after a decision document (Record of Decision, or Decision Notice) is 

signed, individuals and entities may now file objections after the environmental 

analysis and the draft decision are complete, but before the final decision is 

signed. The purpose of the objection process is to encourage collaboration in 

project planning between the Responsible Official and interested publics, with 

the goal of resolving issues and coming to a better-informed decision before a 

final decision is made. 

A 45-day objection filing period begins when a legal notice is published in the 

newspaper of record, and an EA or FEIS is issued, along with a draft decision. 

A letter or email stating that these documents are available (hard copy, DVD, 

and/or on the Forest Service public website) is sent out to individuals and 

organizations who submitted specific written comments. The Navy FEIS was 

distributed to the mailing list in 2009 and will not be redistributed; however, it 

is available online at 

http://www.fs.fed.us/nepa/nepa_project_exp.php?project=14556 or available 

for review at Forest Service District offices. Objections must be filed in 

writing with the Reviewing Officer within the objection filing period, as was 

specified in the draft Record of Decision (ROD). 

To be eligible to object to a project, individuals and entities need to have 

previously submitted timely, specific written comments during the public 

comment periods, unless the objection concerns an issue that arose after 

designated opportunities for comment were over. Comments must be within 
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A3-4  APPENDIX ROD-3 - New Information since the 2009 FEIS Navy Timber Sale Record of Decision

the scope of the project, have a direct relationship to the proposed action, and 

include supporting reasons for the Responsible Official to consider. 

After the 45-day objection filing period ends, a 45-day objection review period 

begins. Prior to a written response by the Reviewing Officer, the Reviewing 

Officer or the objector may request to meet, along with the Responsible 

Official, to discuss the issues raised and any possible resolution. At the end of 

the 45-day objection reviewing period, the Reviewing Officer will issue a 

written response detailing how the objections have been addressed, which may 

also include instructions to the Responsible Official (36 CFR 218.11(b)). The 

final decision document cannot be signed until all concerns and instructions 

identified by the Reviewing Officer in the objection response have been 

addressed by the Responsible Official (36 CFR 218.12(b)). 

Implementation of decisions subject to the objection process may commence 

immediately after a final decision is signed. There is not a requirement to 

publish notification of the decision. See the Navy draft ROD “Administrative 

Review-Opportunity to Object” for more discussion of the objection process 

and eligibility to object.

Inventoried Roadless Areas (2001 Roadless Rule)

When the project decision was signed in March 2009, the Tongass National 

Forest was exempt from the 2001 Roadless Rule. The effects analysis for the 

Navy FEIS was based on the 2008 Forest Plan roadless inventory. All action 

alternatives in the FEIS, except for Alternative F, proposed activities within 

inventoried roadless areas. These proposed activities were consistent with the 

direction in the 2008 decision of the Forest Plan. 

The March 4, 2011 ruling by the Federal District Court for the District of 

Alaska in Organized Village of Kake v. USDA vacated the Tongass exemption 

from the roadless rule. The State of Alaska appealed that decision to the Ninth 

Circuit Court of Appeals which on March 26, 2014 reversed the District Court 

decision concerning the exemption of the Tongass from the roadless rule. The 

three-judge panel of the Ninth Circuit Court determined that the USDA was 

reasonable, in 2003, when it exempted the Tongass from the roadless rule. The 

Ninth Circuit Court also remanded the case to the District Court to decide 

whether a supplemental EIS is required for the Tongass exemption. In August 

2014, however, the Ninth Circuit Court of Appeals granted another hearing, 

held in December 2014 before an eleven-judge panel to rehear the State of 

Alaska’s appeal. The Ninth Circuit Court has issued its en banc decision in 

Organized Village of Kake v. USDA, 11-35517, upholding the Alaska District 

Court’s reinstatement of the roadless rule, which remains in effect and applies 

to the Tongass. Alternative F does not include any harvest units or road 

building within the inventoried roadless areas as described by the 2001 

Roadless Rule; however, the other action alternatives considered in the FEIS 

did include timber harvest and road building within IRAs to maximize timber 

harvest in this area.

Effects to roadless area values were analyzed by alternative in the Navy Timber 
Appendix ROD-3

Navy Timber Sale Record of Decision New Information since the 2009 FEIS – APPENDIX ROD-3  A3-5

Sale FEIS using the Forest Plan’s 2008 roadless inventory. However, the 

analysis update for the 2015 ROD is based on the 2001 Roadless Rule 

inventory, which is slightly different than the Forest Plan’s 2008 roadless 

inventory used in the Navy FEIS. See Figure 2 in this appendix. Alternative F, 

the Selected Alternative, proposes no timber harvest or road building in any 

inventoried roadless area under either the 2001 or 2008 inventory. See also 

“Issue 3 – Inventoried Roadless Areas” in this appendix. The outcome of 

litigation with regard to the Tongass exemption does not alter the effects or 

change the analysis as a result of the project.

USDA Strategic Plan 2010-2015

The USDA Strategic Plan 2010-2015 provides the long-term objectives for the 

agency. 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”. To help achieve this goal, the 

Alaska Region’s development of a Transition Framework program is intended 

to build upon current assets and economic sectors and develop other 

opportunities within the communities within the Tongass National Forest. 

As part of this strategy, there is a gradual shift of Tongass forest management 

from primarily old-growth timber harvest to young-growth forest management. 

On May 26, 2010, Tom Vilsack, the USDA Secretary of Agriculture, put out a 

news release (Release No. 0288.10) highlighting the increasing emphasis the 

Forest Service, in cooperation with USDA Rural Development and Department 

of Commerce’s Economic Development Administration, is putting on this 

management shift. The Secretary issued Memorandum 1044-009 on July 2, 

2013, “Addressing Sustainable Forestry in Southeast Alaska” which reaffirms

the USDA’s high priority for this transition and the goal that in 10-15 years, the 

majority of timber sold by the Tongass will be young growth. 

Although there is currently no young-growth timber of merchantable 

(commercial) value available for harvest in the Navy project area, the Selected 

Alternative contributes to the supply of timber needed to maintain the timber 

industry during the transition to young-growth management, thus helping 

ensure that the infrastructure and job skills will be available when the young 

growth is ready for harvest. 

USDA Investment Strategy for Creating Jobs and Healthy 

Communities in SE Alaska

A primary goal of the administration is a sustainable, stable economy for 

Southeast Alaska’s communities. To this end, Forest Service officials have 

been working with local communities to encourage a diversity of forest-related 

jobs built around timber, renewable energy, forest restoration, tourism, 

subsistence, recreation, fisheries, and mariculture. Timber harvest remains a 

component of Southeast Alaska’s diversified economy and a stable and 

sustainable timber supply is essential for the continuing existence of the timber 

industry. The Navy Timber Sale project contributes to this goal by sustaining 

timber jobs and related opportunities. More information is available at 

http://www.fs.usda.gov/detail/r10/home/?cid=FSBDEV2_038855.
Appendix ROD-3

A3-6  APPENDIX ROD-3 - New Information since the 2009 FEIS Navy Timber Sale Record of Decision

Climate Change Considerations

The Navy FEIS, pages 3-5 and 6, addresses climate change and the rationale 

for not discussing it in detail at the project level. Climate change is a topic that 

continues to be studied throughout the agency, including the Tongass National 

Forest. 

The Forest Service is concerned with effectively integrating climate change 

issues into land management decisions and NEPA analysis. On January 13, 

2009, the USDA Forest Service, Washington Office released a report called 

“Climate Change Considerations in Project Level NEPA Analysis”. The paper 

addresses how climate change can and shall be discussed in project-level 

analysis, evaluating the cause and effect relationship between a proposed action 

and climate change, and whether a quantitative or qualitative analysis is 

warranted. The report states that “It is not necessary to calculate GHG emissions 

for most projects; however, in situations where the responsible official finds the 

information useful for decisionmaking, such data and conclusions developed 

through quantitative analysis would normally only be used for comparing 

alternatives related to direct effects or addressing any applicable regulatory 

requirements related to GHG emissions. Without enough scientific understanding 

to draw conclusions about the significance of the quantitative results, qualitative 

discussions about the potential for greenhouse gases sequestered and emitted are 

more appropriate for disclosing climate change implications. “ 

More recently, CEQ issued revised draft guidance in December of 2014 to 

“provide Federal agencies direction on when and how to consider the effects of 

greenhouse gas (GHG) emissions and climate change” in NEPA reviews (79 

FR 77802; December 24, 2014). The draft guidance “recommends that 

agencies use a reference point to determine when GHG emissions warrant a 

quantitative analysis taking into account available GHG quantification tools 

and data that are appropriate for proposed agency actions.” The guidance also 

states that “in addressing GHG emissions, agencies should be guided by the 

principle that the extent of the analysis should be commensurate with the 

quantity of the projected GHG emissions. When an agency determines that 

evaluating the effect of GHG emissions could not be useful to distinguish 

between the no-action and proposed alternatives and mitigations, the agency 

should document the rationale for that determination.”

In 2011 and again in 2014, the Forest Inventory and Analysis (FIA) program, a 

subunit of the Pacific Northwest Research Station, made numerous carbon 

storage estimates and prepared the first national assessment of the storage and 

flux of carbon in down woody material (DWM) (Anderson 2011) and for live 

trees, snags and logs (Barrett 2014). The 2014 report indicates that the overall 

carbon mass stored in just aboveground trees, snags and logs in the Tongass is 

quite large: about 650 million tons, which is equivalent to 2.4 billion tons of 

CO2. This above-ground carbon storage does not include belowground pools 

such as carbon in non-forested wetlands, alpine, grass and shrublands, roots, 

soil, litter and other organic materials - which is estimated to be as large as the 

aboveground stores (Barrett 2014). “Although there is substantial amount of 
Appendix ROD-3

Navy Timber Sale Record of Decision New Information since the 2009 FEIS – APPENDIX ROD-3  A3-7

recent literature about the effects of forest management on carbon stores, 

different authors have reached widely different conclusions about net 

sequestration because of different assumptions about the timeframe of interest, 

initial volume, post-harvest residuals, decay rates, the amount of energy 

expended in harvest and transport, utilization rates, lifespan of wood products, 

future growth rates of young growth stands, temporal discounting and 

substitution effects” (Barrett 2014). Because of these differing perspectives, 

this information was not deemed essential to make a reasoned decision for this 

project. 

Many proposed projects and programs will emit greenhouse gases (direct 

effect) and, thus, contribute to the global concentration of greenhouse gases 

which affect climate (indirect effect). Because the Navy Timber Sale is 

extremely small in the global atmospheric CO2 context, it is not necessary to 

conduct a quantitative analysis of actual climate change effects.

For the Navy project, all the action alternatives would result in an initial net 

release of carbon into the atmosphere above that of the No-action Alternative,

although over time, regenerating young growth could result in greater net 

sequestration of carbon than the No-action Alternative. Alternative C proposes 

the most timber harvest (62.0 million board feet (MMBF)) and roadbuilding 

(25.7 miles National Forest System (NFS) and temporary road) and would thus 

have a greater immediate effect on carbon sequestration than Alternative F, 

which proposes the least harvest (13.1 MMBF) and roadbuilding (3.3 miles 

NFS and temporary road). At the Navy project scale, the magnitude of the 

project is so small compared to the factors that contribute to climate change 

that foreseeable effects would be small, if measurable at all, for all alternatives. 

It is estimated that the forests of the Tongass represent approximately only one 

quarter of one percent of the stored carbon in forests worldwide (Forest Plan 3-

19). Within the Navy project area, this percentage is considerably smaller. 

Therefore, it is reasonable to conclude that small, if even measureable, changes 

in carbon sequestration under any of the action alternatives, whether positive or 

negative, would not be a relevant factor for choosing among alternatives. 

Additionally, the task of understanding all the factors that influence climate 

change and how carbon is sequestered continues to be subject to substantial 

uncertainty and for these reasons is not essential to a reasoned choice among 

alternatives. None of the action alternatives are predicted to measurably 

contribute to the cumulative effects on climate change.

The Tongass National Forest currently monitors climate change in several 

ways, one of which is formally assessed in the annual Forest Plan Monitoring 

and Evaluation Report under the following question: “What are the long-term 

changes to the permanent snowpack and how does it affect the physical and 

biological environment?” The 2013 Tongass National Forest Monitoring and 

Evaluation Report identifies a number of activities in its Action Plan for 2014-

2015 which include continued coordination with other agencies supporting 

climate change research, staff and employee training, completion of 

vulnerability assessments, and continued monitoring of snowpacks, glaciers, 
Appendix ROD-3

A3-8  APPENDIX ROD-3 - New Information since the 2009 FEIS Navy Timber Sale Record of Decision

and stream information. In addition, the regeneration of Alaska yellow-cedar is 

being monitored in order to maintain or increase this species in regenerating 

stands on sites judged to be suitable for the species’ long-term persistence. 

The Forest Plan FEIS discusses climate change factors (p. 3-11 to 3-20) and 

discloses the risk of possible effects and the considerable uncertainty 

concerning specific predictions of how the climate may change, and even more 

uncertainty regarding the effects of climate change on the resources of the 

Tongass National Forest. The Tongass National Forest will continue to 

monitor potential effects of climate change through the existing Forest Plan 

monitoring programs, and other studies that are occurring regionally and 

nationally. Any need for a different course of action that might affect this 

decision will be addressed through existing procedures to determine whether 

changes are warranted (Navy FEIS p. 3-5).

Based on the current understanding of climate change in Southeast Alaska and 

action alternatives associated with the Navy Timber Sale project, specific 

adaptation actions are not necessary to meet Forest Plan objectives at this time. 

Forest Service National Core Best Management Practices

In April 2012, the Forest Service issued a memo initiating implementation of 

the National Core Best Management Practices (BMP) program, which 

integrates water resource protection into management activities conducted 

across the landscape. Directives for using these BMPs are currently in 

development. The National BMP Program will enable the agency to readily 

document compliance with the management of nonpoint source pollution at 

local, regional, and national scales and address the new planning rule 

requirement for national BMPs (36 CFR 219.8(a)(4)). The Navy project will 

implement the most up-to-date BMP guidance.

Forest Service National Core Best Management Practices 

Monitoring Program

The Forest Service is developing a National Core BMP Monitoring Program 

that addresses implementation and effectiveness of BMPs. The draft National 

Core BMP Monitoring Technical Guide is currently in review. The Tongass 

National Forest has tested the national protocols for timber harvest and road 

activities and has adopted them as part of Forest Plan Monitoring. Results will 

be reported in the Annual Tongass National Forest Monitoring and Evaluation 

Report.

National Pollutant Discharge Elimination System (NPDES)

On March 20, 2013, in Decker v. NEDC, the Supreme Court reversed the Ninth 

Circuit Court’s decision in NEDC v. Brown and held that the Clean Water Act 

and its implementing regulations do not require the NPDES permits for 

stormwater discharges from logging roads into the navigable waters of the 

United States. However, should it be determined that an NPDES permit is 

required for this project, the Forest Service will comply with any applicable 

permitting requirements prior to project implementation. 
Appendix ROD-3

Navy Timber Sale Record of Decision New Information since the 2009 FEIS – APPENDIX ROD-3  A3-9

Updates to the Analysis and Information in 

the Navy Timber Sale FEIS

Chapter 1 

The issues were reviewed and no additional issues were identified. No public 

involvement has occurred specifically for the Navy project since 2009; 

however, comments on other timber harvest projects were considered at the 

time of the review.

No changes have been made to the proposed action, Alternative B (FEIS p. 1-

2), and there are no changes that are relevant to environmental concerns. 

However, as described below under Issue 1: Timber Supply/Sale Economics, 

updated timber volume estimates based on timber cruise plot data resulted in 

lower net volume estimates than the volume estimates in the FEIS which were 

based on stand exam data. This has resulted in lower net volume estimates in 

the updated analysis for the proposed action, as well as the other action

alternatives. 

Chapter 2

Alternatives Considered but Eliminated from Detailed Analysis

Refer to Chapter 2, pages 2-17 and 2-18 of the FEIS which discusses the action 

alternatives which were considered but eliminated during the planning process. 

During the informal resolution meetings for the appeal on the 2009 Decision, 

three proposals were received from the appellants and are discussed below. 

Four appeals to the 2009 Navy ROD, under the 36 CFR 215 appeal regulations, 

were submitted by several organizations, including The Wilderness Society 

(TWS), SEACC et al., Greenpeace et al., and Juneau Sierra Club. Forest 

Service personnel and appellants met to discuss possible appeal resolutions. 

Three of the appellants presented proposals, all subsets of the 2009 Selected 

Alternative, which only included the units in the roaded area. The Wilderness 

Society (TWS) and SEACC et al. both submitted a proposal that avoided 

inventoried roadless areas, omitted the units in the area between Anita Bay and 

Burnett Inlet and units with an Alaska yellow-cedar component, and stipulated 

removal of culverts rather than installation of waterbars from National Forest 

System (NFS) roads that would be put into storage upon sale completion. The 

Sierra Club submitted a proposal that included all the aspects of the TWS and 

SEACC proposals, plus deleting Units 114-120 along the 51540 road, and Unit 

94. Like the TWS/SEACC proposal, it also stipulated removal of culverts, 

rather than installation of waterbars for NFS roads associated with the timber 

sale.

The Navy IDT considered these proposals and compared potential effects by 

resource to the other alternatives in the FEIS. The IDT found that the issues 

addressed by the appellants’ proposals are already addressed in other 
Appendix ROD-3

A3-10  APPENDIX ROD-3 - New Information since the 2009 FEIS Navy Timber Sale Record of Decision

alternatives considered in detail, primarily Alternatives E and F. Alternative E 

addressed the wildlife habitat concern with harvest in the area between Anita 

Bay and Burnett Inlet by avoiding harvest in that area, and Alternative F 

partially addresses this concern by reducing harvest in the area. Alternative F 

addresses effects to inventoried roadless areas by avoiding all harvest and road

construction in inventoried roadless areas. All alternatives include seed tree 

retention in some units to help maintain or increase the cedar component in 

regenerating stands.

The appellants’ suggestion during the informal resolution meetings to remove 

culverts from roads which will be put into storage was also considered. The 

disposition of the roads after harvest activities are complete is determined by 

the Objective Maintenance Level and the Alaska Forest Resources and 

Practices Act (AFRPA) Class, shown on the road cards, and the site-specific 

needs of the road, consistent with the Wrangell Access and Travel Management 

Plan (ATMP). The decision whether or not to remove culverts from NFS roads 

will be made at the time of road storage. The roads will be evaluated for 

erosion potential, and measures will be implemented to reduce sediment 

delivery and reduce the risk of crossing failure and stream diversion. This may 

include the removal of drainage structures and bridges, or construction of water 

bars, rolling dips or other measures necessary to protect resources. The 

language of “Where feasible, culverts will be left in place with adequate 

protection, typically waterbars” has been removed from the road cards. 

After the March 4, 2011 Federal District Court, District of Alaska ruling in 

Organized Village of Kake, et al. v. US Department of Agriculture (D.C. No. 

1:09-cv-00023 JWS) that the Tongass is no longer exempt from the 2001 

Roadless Rule, the IDT also considered a modification of Alternatives B 

through E that dropped proposed units and roads within 2001 IRAs. 

FASTR was run to assess the effects on financial efficiency of this possible 

modification to Alternatives B through E. Alternatives B, C, and D, originally 

designed to respond to Issue 1: Timber Supply and Economics (including 

varying emphases), have cruised volume ranging from 26.6 MMBF sawlog and 

utility (Alternative D) to 62.0 MMBF (Alternative C) (see Table 2). 

Alternative E’s volume is 24.5 MMBF. When only the units within the roaded 

portion of Alternatives B through E were considered, the range in volumes was 

considerably narrowed, with reduced volumes ranging from 8.4 MMBF 

(Alternative E) to 16.6 MMBF (Alternative C). Alternative F’s volume (13.1 

MMBF) falls within the middle of the range of volumes of the roaded portion 

of the alternatives. 

While all alternatives are currently showing as deficit, Alternative F’s indicated 

bid value is about $28.74/MBF to $61.49/MBF more economical than the other 

FEIS action alternatives (see Table 2). Although considering only roaded units 

improved the indicated bid value per MBF for Alternatives B though E, 

FASTR still indicates that they may appraise deficit. An economic comparison 

showed Alternative F’s indicated bid value/MBF about $5.55 to $8.46 more 

economical than Alternatives B, C, or E if modified, and about $9.46 less 
Appendix ROD-3

Navy Timber Sale Record of Decision New Information since the 2009 FEIS – APPENDIX ROD-3  A3-11

economical than Alternative D if modified. As explained in the FEIS, 

alternatives which show as deficit in current FASTR runs may become more 

economical in future markets or a portion of the units may become economical. 

Timber sales on the Tongass are not advertised until they appraise with positive 

values. 

Alternative E, which included harvest in inventoried roadless areas, was 

designed to respond to Issue 2: Wildlife Habitat Fragmentation by not 

harvesting timber in the area between Anita Bay and the head of Burnett Inlet. 

Modifying Alternatives B through E to exclude harvest activities in inventoried 

roadless areas would result in less effect on interior habitat, coarse canopy, and 

patches of old-growth habitat than these alternatives in the FEIS, due to fewer 

acres of harvest and roadbuilding. However, Alternatives B, C, and D still 

harvest units within the roaded portion of the Anita Bay area. Alternative F still 

has less harvest in the Anita area than would Alternative B, C, or D if modified, 

retaining part of the low-elevation POG corridor due to greater retention (50 

percent) in Unit 67, and deleting a portion of Unit 70. 

The volume and economic results of modifying Alternatives B through D were 

similar to Alternative F, and they would not address any issues not already 

addressed by Alternative F. Modifying Alternative E was most similar to the 

TWS and SEACC proposals, which were considered but eliminated during the 

informal appeals resolution process. Therefore, this modification was not 

analyzed in further detail. 

Alternatives Considered in Detail

Alternatives considered in detail are described in the FEIS, pp. 2-9 to 2-15. 

Four of the five action alternatives considered in detail include timber harvest 

in inventoried roadless areas, while one action alternative (Alternative F) and 

the no-action Alternative A do not. As a result of the July 29, 2015 Ninth 

Circuit Court of Appeals ruling vacating the Tongass exemption from the 

roadless rule, at the present time the roadless rule remains in effect in Alaska.

Although the Tongass at this time can only implement timber harvest and road 

construction activities within the roaded area, the Responsible Official could 

select Alternative F or Alternative A, or choose an action alternative that 

proposes activities in an IRA and then defer any timber harvest units and road 

construction within an IRA. Deferring timber harvest and road construction in 

IRAs in Alternative B, C, D, or E differs from modifying these alternatives, 

since deferred activities could still be implemented in IRAs should the Tongass 

exemption be reinstated. 

Chapter 3

Land Divisions

The FEIS, pp. 3-1 to 3-2, lists the land divisions used in the FEIS as well as in 

the updated resource analyses. However, when the additional analyses were

done on the new information as described in this appendix, additional levels of 

land divisions were sometimes used for analysis areas, and are described in this 
Appendix ROD-3

A3-12  APPENDIX ROD-3 - New Information since the 2009 FEIS Navy Timber Sale Record of Decision

appendix.

Cumulative Effects - Past, Present, and Reasonably Foreseeable 

Projects

The IDT reviewed the status of other projects within the project area since 

2009. These projects were considered in the section “Cumulative Effects” on 

pages 3-2 to 3-4 of the Navy FEIS, and are updated here. 

Fishtrap Salvage Timber Sale authorized the harvest of approximately 208 

MBF of cedar decline and blown down sawtimber and utility volume from 240 

acres adjacent to existing roads. This sale was sold in 2007 and harvested in 

2011. 

North Etolin Salvage Timber Sale authorizes the harvest of approximately 

200 thousand board feet (MBF) of cedar decline, blown down sawtimber and 

utility volume along the existing road system. This sale, which had a decision 

in August 2008, is located to the north on the Honeymoon road system (Road 

6549), outside the project area but is within the wildlife analysis area. This sale 

has not been offered for purchase at this time of the analysis. 

The decision on Wrangell District Roadside Timber Sales (March 2011) 

authorizes salvage harvest of dead, dying, and blown down timber, and green 

sawtimber sales of less than 50 MBF each and green fuelwood sales within 

1,200 feet of the existing road systems of Wrangell, Zarembo, and Etolin 

Islands. There may be multiple small sales whose total combined volume 

would not exceed 500 MBF on an annual basis from the three islands 

combined. No sales have been identified on the Anita Bay road system that 

accesses the Navy project area at this time.

Road reconditioning on Road 6539 was completed and addressed the 

sediment concerns in the Thrucut/Goose Lakes Creek watershed. Periodic 

maintenance including brushing, ditch clearing, and some resurfacing where 

needed has been completed for Road 6543.

The resurfacing of Burnett Inlet Portage Trail at the head of Burnett Inlet 

was completed in the summer of 2013. As stated in the FEIS (page 3-3), this 

project is not expected to contribute to cumulative effects to any resource.

In 2014, the Sealaska land bill land legislation was passed by Congress as a 

rider to the National Defense Authorization Act for FY2015 (PL 113-291, Sec. 

3002). Previous versions of the Sealaska bill had been introduced but not 

passed for the past several years, and the proposed acquisition was not 

considered as a “reasonably foreseeable future action” in the FEIS. This bill 

allowed Sealaska Corporation to acquire 70,075 acres of roaded, managed 

National Forest System (NFS) timberlands, and “futures sites” including bays, 

shorelines, and other areas for economic development on the Tongass, in place 

of their final Alaska Native Claims Settlement Act (ANCSA) entitlements 

which they filed for conveyance in June 2008 with the Bureau of Land 

Management (BLM). There are no acquisition areas in the vicinity of the Navy 

project area that are anticipated to affect or be affected by timber harvest 
Appendix ROD-3

Navy Timber Sale Record of Decision New Information since the 2009 FEIS – APPENDIX ROD-3  A3-13

operations on the Navy Timber Sale.

The deer model reanalysis analyzed effects to wolves by considering deer 

density at the Etolin Island and Vicinity biogeographic province level. Projects 

considered at the biogeographic province level analysis included Baht, 

Backline, and Wrangell Island projects. 

This section updates the Timber Supply and Economics section in Chapter 3 of 

the FEIS (pgs. 3-7 to 3-18). 

Since 2009, there have been changes regarding direction on the Regional

export policy, changes in mill infrastructure affecting the projected costs and 

revenues of the project alternatives, and the development of a new financial 

efficiency model, among other changes, as described below. 

Region 10 Limited Export Policy

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

completed. 

The Navy FEIS financial efficiency analysis included adjustments for the 

limited interstate shipping policy at that time. Since then, the Regional 

Forester approved time-limited shipment of unprocessed hemlock and Sitka 

spruce logs and provided additional options for purchasers. Export increases 

timber sale value due primarily to lower manufacturing costs. On February 28, 

2014, the Regional Forester reaffirmed the 2012 memo approving increased 

export for timber purchasers supplying Alaska yellow-cedar for domestic 

processing. Purchasers who provide Alaska yellow-cedar to small business 

operators who will process the timber locally may be approved, on a case-bycase basis, to increase export of an equivalent amount of hemlock and spruce 

volume from the sale(s) involved, over and above existing policy limits. This 

approval will support businesses by improving access to timber and promoting 

the manufacture of products in the State of Alaska.

Changes to Southeast Alaska’s Mill Infrastructure 

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

Alaska mill infrastructure, as mentioned above. The original Navy financial 

efficiency analysis appraisal point destination was the Silver Bay Mill on 

Wrangell Island. However, Silver Bay Logging dismantled their mill in 2010. 

Another potential destination, the Pacific Log and Lumber Company’s mill in 

Ketchikan, closed in 2011. The financial efficiency analysis was recalculated 

to the Viking Mill in Klawock on Prince of Wales Island. As a result, the 

round-trip tow distance increased, increasing the stump-to-mill cost for all 

alternatives. On average, the barging costs were estimated to be $99/MBF, a 

$19/MBF increase over previous analysis. 

Timber Volume Estimates

The volumes in the following Comparison of Alternatives in Table 1, below, 

have been updated with more-precise estimates based on cruised net timber 

volume, as compared to the volume estimates in Table 3-6 in the FEIS, even 

though the total harvest acres by alternative are unchanged, except as noted

Issue 1 - Timber 

Supply/Sale 

Economics
Appendix ROD-3

A3-14  APPENDIX ROD-3 - New Information since the 2009 FEIS Navy Timber Sale Record of Decision

below under “Harvest Acres Totals”. Timber volume estimates in the FEIS 

were based on stand exam data. Stand exams are measured on a one plot to 10 

acre intensity, with at least three plots per unit being installed. Stand exam 

plots are useful for stand characteristics, including species composition and 

forest health, and estimating volumes for comparison between alternatives at 

the EIS stage. Timber volume for the 2015 ROD uses updated volumes based 

on a more-intensive inventory - a timber cruise - of a subset of the units. In a 

timber cruise, more measurement plots per acre are installed (in this case one 

plot per 7 acres). In addition, individual (32-foot logs) logs are graded and 

defects removed from each, which further refines the volume estimates, 

resulting in a more-accurate portrayal of timber found in each of the units and 

hence a better comparison of the alternatives. The relative ranking by volume 

of the alternatives has changed very slightly – in the FEIS, Alternative E was 

higher than Alternative D by 1.2 MMBF, and in the update Alternative D is 2.1 

MMBF higher than Alternative E. During implementation, minor adjustments 

may be made to the number of acres, and between acres of conventional and 

helicopter yarding. Reduction of the volume estimates in the FEIS to the cruise 

data is not a change relevant to environmental concerns or on-the-ground 

implementation. 

Harvest Acres Totals

Minor adjustments in the acres by harvest system, as well as refinements in the 

geographic information system (GIS) information used, resulted in very slight 

changes in the overall number of harvest acres by alternative when they were 

rerun for the updated analysis. Alternatives B, C, and D were reduced by 9, 13, 

and 8 acres respectively, and Alternatives E and F showed an increase of 2 and 

1 acres, respectively, as compared to the harvest system acres in Table 3-6 of 

the FEIS. See Table 1, below.

Acres by silvicultural system shown in the FEIS Table 3-24 reflect a difference 

of 1 to 13 acres (depending on alternative) as compared to the updated harvest 

system acres, due to mapping precision in GIS as explained above. This does

not affect the effects analysis or conclusions.
Appendix ROD-3

Navy Timber Sale Record of Decision New Information since the 2009 FEIS – APPENDIX ROD-3  A3-15

Table 1 (updates p. 3-17 of Navy FEIS)

Comparison of Alternatives – Harvest System, Harvest Volume and 

Roads

Harvest System Unit of

Measure

Alt A Alt B Alt C Alt D Alt E Alt F 

(Sel. Alt.)

Conventional 1 Acre 0 1,282 2,519 1,255 554 643

Net Saw 

MMBF

0 18.4 36.6 18.2 8.0 8.6

Helicopter Acre 0 1,922 3,575 1,106 2,772 609

Net Saw 

MMBF

0 9.6 18.8 5.6 13.9 3.1

Harvest Volume2

Net Sawlog MMBF 0 28.1 55.4 23.8 21.9 11.7

Utility MMBF 0 3.3 6.6 2.8 2.6 1.4

Total MMBF 0 31.4 62.0 26.6 24.5 13.1

Roads

New System Mile 0 6.6 12.1 4.8 2.2 0.6

New Temporary3 Mile 0 5.8 13.6 5.0 2.7 2.7

Reconstruction4 Mile 0 0.8 2.1 0.4 0.8 0.8

LTF5 Construction # 0 0 1 0 0 0 1 Includes cable and shovel yarding systems

2 Some volume totals may not exactly match their sums due to rounding.

3 In some cases, old temporary roads that have been decommissioned still have a discernable 

road prism. These road beds will be reused to minimize environmental effects. 4 Reconstruction (periodic maintenance) has occurred on some roads since the FEIS, resulting 

in fewer road miles planned for reconstruction. 5 Log transfer facility

Financial Efficiency Analysis

The NEPA Economic Analysis Tool Residual value (NEATR) program was

used for financial analysis in the FEIS. On March 28, 2011, the Financial 

Analysis Spreadsheet Tool – RV (FASTR) was approved by the Regional 

Forester to replace the NEATR as a financial efficiency analysis tool for use in 

timber planning. The model version October 21, 2013 was used to compare 

alternatives for the Navy project. See Table 2, below.

The FASTR model is designed from the R10 RV-FM appraisal program using 

readily available or regional averages for data. FASTR outputs are useful to 

gauge current economic conditions for a timber sale and provide a relative 

comparison between alternatives. These results are not meant to serve as an 

actual appraisal or provide actual costs and values at the time of offering since 

these will fluctuate with timber markets. The FASTR tool should not be 

viewed as a complete answer but as one tool that can be used for information

about timber resources, alternatives and trade-offs between costs and benefits.

Actual salability is determined at Gate 4 (advertisement) using the Official R10 

RV-FM Appraisal and statistically sound cruise data. 

The FASTR model uses the same logging costs and manufacturing costs per 
Appendix ROD-3

A3-16  APPENDIX ROD-3 - New Information since the 2009 FEIS Navy Timber Sale Record of Decision

thousand board feet (MBF) developed for the Alaska Region timber sale 

appraisal program. Costs reflect production studies and data collected from 

timber sale purchasers in Southeast Alaska. 

Table 2 (updates p. 3-11 of Navy FEIS)

Financial Efficiency Analysis –Volumes, Costs, and Values1

Alt A Alt B Alt C Alt D Alt E Alt F 

(Sel. Alt.)

Volume – Sawlog (MBF)

Sitka Spruce 0 6,997 13,885 5,876 5,715 2,916

Hemlock 0 15,393 29,416 13,166 11,557 6,416

Western Red Cedar 0 2,851 6,061 2,394 2,223 1,188

Alaska Yellow Cedar 0 2,810 6,083 2,360 2,390 1,171

Total Sawlog Volume (MBF) 0 28,051 55,445 23,796 21,885 11,691

Utility Volume (MBF) 0 3,324 6,597 2,793 2,588 1,386

Total (Sawlog and Utility) 0 31,375 62,042 26,589 24,473 13,077

Pond Log Value $/MBF $0 $629 $637 $626 $645 $629

Stump to Mill Cost $/MBF $0 $574 $563 $548 $555 $513

Indicated Bid Value2 $0 ($2,122,721) ($3,145,327) ($1,226,945) ($938,925) ($165,567)

Indicated Bid Value $/MBF3 $0.00 ($75.68) ($56.73) ($51.56) ($42.90) ($14.16)

Source: FASTR version October 21, 2013

1 ( ) Indicates negative value 2 Indicated bid value

3 Indicated bid value/MBF

Changes in the overall costs and values by alternative since the FEIS are due to 

various factors such as reductions in the estimated volume for all alternatives, 

changes in selling values by species, updates in the average Forest Service 

costs per MBF for sale preparation, administration, and engineering support, 

and updates in production costs and revenues. The cost of environmental 

analysis and documentation (NEPA) is no longer factored into the total project 

costs used to calculate indicated bid value, since that cost has already occurred. 

In addition, market fluctuations reflect an improvement in the current pond log 

value. Some costs, such as log haul, increased when the log destination was 

reappraised to Viking Mill in Klawock.

As in the FEIS (FEIS p. 3-11), all alternatives are shown to be deficit. The 

indicated bid value of the alternatives in the FEIS ranged from -$88.47/MBF 

(Alternative F) to -$163.65/MBF (Alternative C) (FEIS Table 3-2). The 

updated indicated bid values per MBF show an improvement for all 

alternatives, and now range from -$14.16 (Alternative F) to -$75.68/MBF

(Alternative B). Alternative F is still the most economical alternative. The 

FEIS explains (FEIS p. 3-11) that alternatives which show as deficit may

become more economical in future markets or a portion of the units may 

become economical in current markets, as markets fluctuate. For instance, in a 

recovering U.S. economy, widespread new home construction raises the 

demand (and price) for sawn wood products. In Alaska, the species most 
Appendix ROD-3

Navy Timber Sale Record of Decision New Information since the 2009 FEIS – APPENDIX ROD-3  A3-17

sensitive to booms in housing construction is Western redcedar. When the 

range of alternatives includes differing amounts of Western redcedar, the 

ranking of alternatives can quickly change in 2 years due to the widely 

fluctuating Western redcedar market. A complete timber sale appraisal is 

needed to determine the actual economics of the timber offered for sale. As 

stated in the FEIS (p. 3-11), no timber sale would be offered if it appraises 

deficit. 

Forest Products Employment

Data in the FEIS showed employment figures for years 2002 through 2006 

(Table 3-1 FEIS p. 3-9) in the number of logging, sawmill, and related industry 

jobs across Southeast Alaska. This information has been updated to include 

data from 2007 through 2011 (see Table 3, below). Since 2006, forest products 

employment data show a downward trend until 2010 when it appears to have 

stabilized.

Table 3 (updates Table 3-1, p. 3-9 of Navy FEIS)

Forest Products Industry Employment in Southeast Alaska 2002-2011

Year1 Tongass 

Logging2 Tongass 

Sawmill2

Total Tongassrelated 

Employment

Other 

Sawmill

Other 

Logging

Total Other 

Timber 

Employment

Total Industry 

Employment

2002 63 110 173 40 299 339 512

2003 108 91 199 64 298 362 561

2004 82 95 177 53 220 273 450

2005 88 96 184 52 263 315 499

2006 81 77 158 46 217 263 421

2007 44 70 114 63 225 288 402

2008 52 70 122 24 118 142 265

2009 48 39 87 19 110 129 216

2010 61 46 107 7 133 140 247

2011 62 47 109 3 150 153 262 1

Calendar years

2

Estimated based on the ratio of Tongass timber harvest to total timber harvest in SE Alaska.

Source: Alaska Department of Labor, Kilbourn et al. 2014, Brackley et al. 2006b, Brackley and 

Crone 2009, Alexander and Parrent 2010, Alexander 2011, Alexander 2012, Alexander and 

Parrent 2012, and Parrent 2012. Data on file with: Regional Economist, Ecosystems Planning, 

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

The number of timber-related jobs and income is related to the net harvest 

volume as well as how much timber is processed locally and how much the 

timber purchaser exports, under the terms of the Tongass Export Policy. More 

local sawmilling jobs are supported if a purchaser chooses to process logs 

locally, while more transportation/other services jobs are supported if a 

purchaser exports timber. The number of jobs and related income shown in the 

table below are based on assumptions that all units and volume will be 

harvested across each action alternative. These estimates will likely change as 

actual timber offerings are packaged that would include some or all of the 
Appendix ROD-3

A3-18  APPENDIX ROD-3 - New Information since the 2009 FEIS Navy Timber Sale Record of Decision

units. The jobs per MBF used for this estimate are based on an average from 

operators and may vary depending on who buys the sale and how much volume 

is processed locally and how much is exported.

Table 4 below displays estimated direct logging, sawmilling, and 

transportation/other services-related employment and income for the 

alternatives, generated with FASTR Version October 21, 2013. Due to a lower 

estimated harvest volume, calculated using cruise runs for the project units, the 

number of potential jobs is lower than those estimated in the FEIS. 

The first number in the range of Total Jobs in the table assumes that all Alaska 

yellow-cedar (AYC), plus hemlock-spruce export (50 percent total sale net 

sawlog volume) is exported (all allowable export). The second number in the

range of Total Jobs assumes domestic processing of all the volume. Exporting 

all the timber allowable results in fewer domestic sawmilling jobs, but more 

transportation service jobs such as stevedoring. 

The ranking of alternatives, in terms of potential jobs, has changed slightly 

since the FEIS. In the FEIS, Alternative C supported the greatest number of 

jobs, followed by Alternatives B, E, D, and F (in that order). The updated 

information shows Alternative D supports slightly more jobs than Alternative

E, due to slightly greater volume. Alternative F supports the fewest potential 

jobs, the same ranking as in the FEIS.

Table 4 (updates p. 3-14 of Navy FEIS)

Estimated Project Employment and Income in Alaska

Projected Alaskan 

Employment and Income1 Alt A Alt B Alt C Alt D Alt E Alt F

(Sel. Alt.)

Logging 0 63 125 54 49 26

Sawmilling 0 30-68 57-133 25-57 23-52 12-28

Transportation/Services 0 33-20 65-40 28-17 26-16 14-8

Total Jobs2 0 126-151 248-298 107-128 98-117 52-63

Direct Income ($ Millions)3 $0 $6,676,937 $13,171,248 $5,661,694 $5,200,980 $2,780,997

Direct Income ($ Millions)4 $0 $7,152,369 $14,119,764 $6,068,408 $5,573,655 $2,981,335

Source: FASTR Version October 21, 2013) 1 Memo Employment Coefficients and Indirect Effects, for NEPA planning: 2012 Update. 

(Source: Susan Alexander, Alaska Region Economist) 2 Number of jobs first number lists number of jobs with all allowable export, then number of 

jobs with 100 percent hem/spruce domestic processing. Total jobs, when summing logging and 

sawmill export manufacturing, may not add up exactly due to rounding. 3 With Allowable Export, current export policy 4.With 100% hem/spruce domestic processing

Forest Service Costs

The Forest Service costs estimates are averages from the Alaska Region’s 

budget allocation process. The totals of the average costs (which are based on 

alternative volume) are subtracted from indicated bid values to estimate net 

present value of each alternative. 

The Forest Service cost averages per MBF have changed slightly since the 
Appendix ROD-3

Navy Timber Sale Record of Decision New Information since the 2009 FEIS – APPENDIX ROD-3  A3-19

FEIS. Sale preparation cost has gone from $23/MBF in the FEIS to 

$20.78/MBF; sale administration cost has gone from $9/MBF in the FEIS to 

$12.18/MBF; and engineering support cost has gone from $28/MBF in the 

FEIS to $22.67/MBF. 

In the FEIS, the analysis and documentation costs ($1,634,753) were included 

in the total project costs for each alternative. However, in this updated 

analysis, FASTR assumes that the cost of environmental analysis, at 

$47.97/MBF, has already incurred at Gate 2, and this figure is no longer

factored into the present value of cost for the alternatives. The costs of 

processing the appeals received in 2009 and this supplemental analysis are also 

not factored into the cost of this project. 

Table 5 (updates p. 3-13 of Navy FEIS)

Estimated Forest Service Financial Costs and Revenues

Forest Service Costs1 Alt A Alt B Alt C Alt D Alt E Alt F 

(Sel. Alt.)

Sale Preparation $0 $582,879 $1,152,144 $494,471 $454,767 $242,964

Sale Administration $0 $341,649 $675,318 $289,829 $266,558 $142,411

Engineering Support $0 $635,893 $1,256,935 $539,444 $496,130 $265,062

Total Project Costs $0 $1,560,421 $3,084,397 $1,323,745 $1,217,455 $650,437

Indicated Bid Value2 $0 ($2,122,721) ($3,145,327) ($1,226,945) ($938,925) ($165,567)

Net Present Value3 $0 ($3,683,142) ($6,229,724) ($2,550,690) ($2,156,380) ($816,004)

1 Based on Alaska Region’s average budget allocation for cost centers. 

2 ( ) indicates negative value.

3 Indicated bid value minus total project costs, ( ) indicates negative value.

Source: N Stearns, FASTR version October 21, 2013.

Payments to the State of Alaska

On October 2, 2013, Congress passed a one-year reauthorization of the Secure 

Rural Schools (SRS) and Community Self Determination Act, as part of Public 

Law 113-40. The one-year reauthorization provided for payments to states,

which are distributed to counties in which national forests are situated. SRS 

expired at the end of FY2013. More information is available at 

http://www.fs.usda.gov/pts/. As of April 16, 2015, a two-year reauthorization 

was passed by Congress and if signed into law, would provide about $12 

million to communities in Southeast Alaska over 2015 and 2016.

There is no new information for the Wildlife Habitat Fragmentation section in 

Chapter 3 of the FEIS (pp. 3-19 to 3-33). The FEIS included analysis on 

fragmentation, corridors and the area between Anita Bay and Burnett Inlet

(FEIS pp. 2-3 and 3-20 thru 3-33). The FEIS analysis for patch sizes and 

fragmentation was reviewed and no new information was found that would 

further affect the fragmentation in the areas or the analysis of patch size or 

fragmentation. 

Figure 3-5 on page 3-29 of the FEIS displays existing POG corridors with the 

locations of the units for all alternatives. The existing POG corridor map 

(Figure 1, following page) was rerun to display the location of only the 

Issue 2 –

Wildlife Habitat 

Fragmentation
Appendix ROD-3

A3-20  APPENDIX ROD-3 - New Information since the 2009 FEIS Navy Timber Sale Record of Decision

Selected Alternative, Alternative F, units. The bold red letters A through E on 

the map refer to the discussion of corridors on page 3-28 in the FEIS.

The FEIS, p. 3-33 discloses that Alternative F proposes the least harvest of the 

action alternatives of interior habitat and coarse canopy, and has the least effect 

on large patches of old-growth habitat. It has less harvest in the Anita area than 

Alternatives B, C, and D, with 50 percent retention in Unit 67 to retain part of 

the low-elevation POG corridor which would be completely severed in

Alternatives B, C, or D, and deleting a portion of Unit 70.
Appendix ROD-3

Navy Timber Sale Record of Decision New Information since the 2009 FEIS – APPENDIX ROD-3  A3-21

Figure 1. Existing Landscape-level POG Corridors on Etolin Island
Appendix ROD-3

A3-22  APPENDIX ROD-3 - New Information since the 2009 FEIS Navy Timber Sale Record of Decision

This section updates the Inventoried Roadless Area (IRA) section in Chapter 3 

of the FEIS (pgs. 3-34 to 3-44). On March 4, 2011, the Federal District Court, 

District of Alaska ruled in Organized Village of Kake, et al. v. US Department 

of Agriculture (D.C. No. 1:09-cv-00023 JWS), that the Tongass is no longer 

exempt from the 2001 Roadless Rule. On appeal, the Ninth Circuit Court of 

Appeals reversed that decision on March 26, 2014, finding that the USDA was 

reasonable, in 2003, when it exempted the Tongass from the roadless rule. In 

August 2014, the Ninth Circuit Court of Appeals granted another hearing, held 

in December 2014, before an eleven-judge panel to rehear the appeal. On July 

29, 2015, the Ninth Circuit Court issued its en banc decision in Organized 

Village of Kake v. U.S. Dept. of Agriculture, 11-35517, upholding the Alaska 

District Court’s reinstatement of the roadless rule, which remains in effect and 

applies to the Tongass. 

The current analysis considers effects to 2001 Roadless Rule inventory areas, 

rather than the 2008 Forest Plan inventory which was used in the 2009 FEIS 

analysis. The size and characteristics of the 2001 Roadless Rule roadless 

inventory (120,367 acres) and the 2008 Forest Plan roadless inventory on 

Etolin Island (127,176 acres) are similar (see Figure 2). A main difference is

that the 2008 Forest Plan roadless inventory included many of the shoreline 

units harvested during the beach logging era (pre-1960s) since they had 

regained their roadless characteristics. Alternative F does not propose any 

timber harvest or road construction within either the 2008 Forest Plan roadless 

inventory areas or the 2001 Roadless Rule inventoried roadless areas. 

The FEIS only considered the cable- and shovel-yarded units, but did not apply 

a buffer to helicopter units, consistent with the inventory done for the Forest 

Plan SEIS. This updated analysis includes the helicopter-yarded units as well,

reflecting a more-conservative analysis that includes indirect effects such as 

noise or visual disturbance from helicopters. In addition to proposed roads and 

units themselves, an area within 1,200 feet of existing and proposed roads and 

600 feet of proposed units was considered to assess indirect effects such as

temporary disturbance from the sights and sounds of harvest-related activities, 

and the loss of interior habitat. Although there is no change to the activities 

proposed or to the effects from any alternative, including the helicopter units in 

the updated analysis increased the number of acres affected due to indirect 

effects for all action alternatives. 

Alternative F indirectly affects about 1 percent of the zone inside of the IRA 

boundary, as a result of proposed units and roads adjacent to or nearby (but not 

within) the IRA boundary, even though there are no direct effects from harvest 

activities. The 566 “Total Acres Affected” for Alternative F (Table 6) reflects 

only indirect effects and reside solely in the zone of influence. The “Total 

Acres Affected” for the other action alternatives includes both direct effects 

(from units and roads themselves) and indirect effects (from the zone 

surrounding the units and roads). No unique features of the roadless areas 

would be affected under any alternative, and the areas would remain eligible 

for potential wilderness consideration. 

Issue 3 –

Inventoried 

Roadless Areas
Appendix ROD-3

Navy Timber Sale Record of Decision New Information since the 2009 FEIS – APPENDIX ROD-3  A3-23

Table 6 updates the information in Table 3-8 on page 3-39 of the Navy FEIS. 

The number of actual harvest acres in the FEIS’s 2008 Forest Plan roadless 

inventory, used in the FEIS Table 3-8, appears larger than the 2001 Roadless 

Rule inventory acres below. This is because some units fall in areas that are 

designated as roadless under the 2008 Forest Plan roadless inventory, but not 

designated as roadless under the 2001 Roadless Rule inventory. Conversely, 

the number of affected acres appears larger under the 2001 Roadless Rule 

inventory than the 2008 Forest Plan roadless inventory, because the updated 

analysis included the 600-foot zone around helicopter units as “affected” while 

the FEIS analysis did not include the zone around helicopter units. 

When the March 2011 court ruling vacated the Tongass exemption from the 

roadless rule, the portions of Alternatives B through E that proposed activities 

in inventoried roadless areas were no longer viable to implement. The roadless 

rule currently remains in effect in Alaska. If the Responsible Official were to 

select Alternative B, C, D, or E, he could choose to defer all activities in 

inventoried roadless areas.

Table 6

Effects to the 2001 Roadless Rule Inventory Acres by Alternative

Roadless

Acres

2001 Roadless Rule 

inventory

Percent of Roadless 

Acres in the Project 

Area Affected:

2001 Roadless Rule 

inventory

Total Roadless Acres

1 120,367

Roadless Acres within project area 53,848

Acres Affected by Alternative Total Acres Affected2

Alt A 0 0

Alt B 5,963 11

Alt C 12,117 22

Alt D 3,120 6

Alt E 6,272 12

Alt F 566 1

Proposed Timber Harvest 

within 2001 Roadless Areas

Proposed Total Miles in 

2001 Roadless Areas3

Alt A 0 0

Alt B 2,200 6.3

Alt C 4,463 16.8

Alt D 1,094 4.3

Alt E 2,219 1.7

Alt F 0 0 1

Mosman Roadless Area, North Etolin Roadless Area, and South Etolin Roadless Area. 2 Acres affected by alternative includes the zone of influence defined as 1,200 feet from 

existing and proposed roads, and 600 feet from all harvest units including the helicopter units.

3 Miles of new road proposed includes NFS roads and temporary roads.
Appendix ROD-3

A3-24  APPENDIX ROD-3 - New Information since the 2009 FEIS Navy Timber Sale Record of Decision

Figure 2. 2001 and 2008 Roadless Areas with Alternative F
Appendix ROD-3

Navy Timber Sale Record of Decision New Information since the 2009 FEIS – APPENDIX ROD-3  A3-25

Other Resources

An updated biological evaluation (BE) for plants was prepared to more clearly 

disclose the effects by alternative for plants on the 2009 sensitive species list. 

There are no new effects disclosed.

The determination, for some sensitive plants, remains “May adversely impact 

individuals, but not likely to result in a loss of viability in the planning area, nor 

cause a trend toward federal listing” has not changed. Other plants will not be 

affected at all. 

A resource report was prepared that focused on rare plants, and whether the 

project actions could result in the loss of viability for rare plants known to 

occur in the project area. Two plants which were analyzed as sensitive plants 

in the 2008 report are analyzed as rare in the 2013 updated report. There has 

been no new information to analyze and no other changes since the 2009 FEIS. 

The updated BE and resource report are in the project record.

No federally-listed threatened, endangered or proposed plants are known to

occur in the project area.

There have been no changes to the heritage resource since the 2009 FEIS. In 

2004, 2005 and 2006 Forest Service archaeologists conducted a cultural 

resource survey of the project area and determined a finding of No Historic 

Properties Affected. The State Historic Preservation Officer concurred with 

our recommendation.

There has been no new information to the recreation resource since the 2009 

FEIS that would warrant reconsideration of the conclusions in that analysis. 

While current outfitter guide use information and reported use changes 

annually since the recreation resource report was written, this does not change 

any of the conclusions in the analysis. The Burnett Inlet Portage Trail at the 

head of Burnett Inlet (inventoried recreation place 62.01) had surfacing work 

completed in the summer of 2013. 

Additional activities completed since 2009 include the Fishtrap Salvage Sale 

and road closures; neither adds significantly to the cumulative visual effects of 

Navy. The salvage sale is either not seen from any visual priority routes, or 

only seen at an angle in the background distance zone. 

A map showing the project area’s scenic integrity objectives (SIO) adopted by 

the decision on the 2008 Forest Plan has been added to the project record to 

illustrate the previous report’s discussion of SIOs within the project area. This 

map presents no additional information that would change the conclusions in 

the FEIS regarding scenery. 

A review determined that the conclusions drawn for the 2009 Navy Timber 

Sale FEIS (see pages 3-90 to 3-97) are accurate and remain relevant to current 

issues. Additional analysis was done for Unit 70, which can be seen from

Anita Bay and lies within the Modified Landscape LUD. Unit 70, which is 49 

acres, meets the 40-60 acre opening Scenery Standard and Guideline for High 

Botany 

Heritage

Recreation

Scenery
Appendix ROD-3

A3-26  APPENDIX ROD-3 - New Information since the 2009 FEIS Navy Timber Sale Record of Decision

Visual Absorption Capacity (Forest Plan p. 4-58), particularly as it is divided 

into two smaller settings and will have 15 percent of the stand retained. While 

the Forest Plan allows for harvest to dominate the characteristic landscape, it 

also states that units will be designed to borrow from naturally existing form 

and line. To achieve Forest Plan direction, the reserve trees will be grouped 

and located to reduce the straight borders of the settings. This will give the unit 

a more natural appearance. 

The 1,157-foot Burnett Inlet Portage Trail runs from the head of Burnett Inlet 

to Road 51401. This portage route is not identified in the Forest Plan as a 

Visual Priority Route, and the Forest Plans Standards and Guidelines do not 

apply. While management activities proposed in the Selected Alternative could 

increase the degree of visual disturbance along this route, this increase is 

considered minimal because portage users are accustomed to seeing the effects 

of harvest activities and road-based motorized recreation use.

Other foreseeable future activities do not have viewpoints or viewsheds in 

common with Navy, have been considered in previous analysis, or will not 

increase the visual impact. 

There is no new information which would affect the silviculture analysis for the 

2009 FEIS. The silviculture resource report was reviewed and included the 

following clarifications: 

• The King George and Honey George sales, listed as previous timber 

sale acres harvested, are north of and outside the Navy project area so 

reference to these projects has been removed. 

• The Etolin Porcupine precommercial thinning project in 2010 and 2011 

resulted in 573 acres of thinned stands on the island, 

• A thinning project done in the 1980s has been identified and 

information added to the report. 

• A previous planting of Alaska yellow-cedar has been identified in the 

project area. 

Also, more information on Alaska yellow-cedar harvest, regeneration, and 

post-thinning composition has been added to the resource report. Alaska 

yellow-cedar conservation and promotion strategies include retaining seed 

trees, single-tree selection, favoring cedar during thinning, and inter-planting of 

cedar. Natural regeneration is prolific on the Tongass as average stocking 

conditions show all species regenerate 2,000 total trees per acre (TTPA) in the 

Central Zone (Draft Report Exploring the Sustainable Yield Capacity of the 

Young Growth Lands on the Tongass National Forest while Evaluating the 

Impact of Acreage Reductions and Rotation Age, prepared for USDA Forest 

Service and Juneau Economic Development Council, 2011). The Navy project 

area is located in the Central Zone, where regeneration survey data show 

Alaska yellow-cedar comprises 7 percent of the total TTPA. It is fully 

expected that all species, including Alaska yellow-cedar, will naturally 

regenerate following timber harvest in the Navy project area.

Silviculture
Appendix ROD-3

Navy Timber Sale Record of Decision New Information since the 2009 FEIS – APPENDIX ROD-3  A3-27

There are no changes to the soil, karst and wetland analysis for the 2009 FEIS. 

There have been minor changes in on-the-ground conditions, with the addition 

of three new landslides. However, all of these occurred in natural setting areas 

not associated with management activities and do not change the results of the 

landslide analysis, nor do they affect the proposed roads or units in the Selected 

Alternative. 

The cumulative impact to wetlands in the project area will be very slightly 

higher due to the recent surfacing of the Burnett Inlet Trail, near the head of 

Burnett Inlet, completed in summer 2013. Trail improvements included fill on 

approximately 0.5 acre of wetlands.

A subsistence evaluation was conducted for the six alternatives in accordance 

with Alaska National Interest Lands Conservation Act (ANLICA) Section 810. 

An ANILCA 810 subsistence hearing was conducted in Wrangell, Alaska in 

June 2008. Based on that evaluation, in the FEIS it was determined that in 

combination with other past, present, and reasonably foreseeable future actions, 

all of the action alternatives could result in a slight increase in the possibility of 

a significant restriction on subsistence use of deer. This is consistent with the 

Forest Plan’s determination based on the cumulative effects of full 

implementation of the Forest Plan (FEIS, p. 3-122).

The wildlife and subsistence addendum (2012) updated deer model capability 

information and incorporated more-recent hunter harvest data (2005-2010) 

from Alaska Department of Fish and Game (ADFG) (Table 21, Wildlife and 

Subsistence ROD Addendum). Deer model results for all alternatives are 

shown in Tables 7 and 8 in the Wildlife: Sitka Blacktailed Deer section, below. 

For Alternative F, in wildlife analysis area (WAA) 1901, neither the direct 4

percent decline in deer habitat capability (DHC) from current condition at 

stem-exclusion phase, nor the 14 percent cumulative change in DHC from 

historic condition at stem-exclusion phase would constitute “a substantial 

reduction” or “large reductions in abundance or major redistribution”. 

Current deer density of just under 16.0 would be reduced to 15.4 at stemexclusion phase.

Hunter demand at 0-25 years post-harvest (stand initiation phase) which was 

estimated to be 2.4 percent of DHC for WAA 1901 (FEIS, Table 3-29) has 

been updated to an estimated 7.0 percent of DHC for Alternative F. At stemexclusion phase (after 25 years post-harvest), it is estimated at 7.2 percent of 

DHC. These figures are based on the updated assumption of 144 deer 

harvested per year (the FEIS assumption was 78 deer per year). Although the 

2008 Forest Plan did not include a 36 percent reduction factor for predation at 

the request of the State of Alaska, these figures include this reduction factor, 

since it was used in the Navy DEIS and FEIS and produces a moreconservative result. Even with the 36 percent reduction for predation, hunter 

demand is below the 10 percent of winter carrying capacity that is considered 

sustainable and provides a reasonably high level of hunter success.

Based on the information in the FEIS and the new information analysis, at a 

Soils, Karst, 

and Wetlands

Subsistence
Appendix ROD-3

A3-28  APPENDIX ROD-3 - New Information since the 2009 FEIS Navy Timber Sale Record of Decision

project level, direct effects within the foreseeable future from the Navy Timber 

Sale project alone would not result in a significant possibility of a significant 

restriction on any subsistence resources, including deer. 

However, since additional timber harvest may occur at some future time in the 

development LUDs in WAA 1901, cumulatively there may be a significant 

possibility of a significant restriction on subsistence use of deer in WAA 1901 

in the future due to additional reductions in habitat capability. This is 

consistent with the Forest Plan finding that full implementation of the Plan 

could lead to a significant possibility of a significant restriction on subsistence 

use of deer. The potential foreseeable effects, directly and cumulatively, from

the project alternatives will not have a significant possibility of a significant 

restriction on subsistence uses for other resources including bears, furbearers, 

marine mammals, waterfowl, salmon, other finfish, shellfish, and other foods 

such as berries and roots.

There is no new information regarding transportation policy since the FEIS was 

published; however, there are some minor updates and changes documented in 

the addendum to the transportation report in the project record. 

Implementation of the 2008 Etolin Island Road Closure contract work included 

closing 1.5 miles (roads 6560 and 51011) and decommissioning 0.4 mile (road 

51000) of road. Roads 6539 and 6543, identified for reconstruction in the 

FEIS, have since had this work completed, which consisted of 

reconditioning/periodic maintenance including resurfacing, compaction, and 

seeding.

In April 2012, the Forest Service issued National Core BMPs. Directives for 

using these BMPs are currently in development. The Navy Timber Sale will 

implement the most current BMP guidance at the time of implementation. 

Currently, this project cites the Alaska Region BMPs, which are fully described 

in FSH 2509.22. A crosswalk between the current Alaska Region BMPs and 

these National BMPs has been placed in the project record for reference.

The addendum for the watershed resource report identified several items of 

updated or clarified information including:

• Road reconditioning on Road 6539 that addressed some sediment 

concerns in the Thrucut/Goose Lakes Creek watershed was completed 

in 2011. The condition of this road was identified in the resource report 

as a contributor to sediment risk in the Thrucut/ Goose Lakes Creek 

Watershed. Removal of landslide material, ditch-cleaning, and 

installation of a new culvert resolved these concerns.

• Updates identifying road storage, closure, and stormproofing work 

completed through implementation of the Wrangell Ranger District 

ATMP. 

• Clarification of effects of road reconditioning in Fishtrap Creek 

watershed: Alternative F would recondition 0.35 mile of existing 

system road on Road 51543, including re-installation of one bridge at a 

Transportation

Watershed
Appendix ROD-3

Navy Timber Sale Record of Decision New Information since the 2009 FEIS – APPENDIX ROD-3  A3-29

Class II stream in the upper Fishtrap Creek watershed. Reconditioning 

would also occur on 0.42 mile of existing Road 51540. Road 

reconditioning would result in short-term increases in sediment. The 

temporary increase would not degrade water quality or fish habitat. 

Implementation of BMPs described in the road cards is expected to 

maintain water quality and minimize impacts to fish habitat. This 

correction would not change the relative ranking of alternatives.

• Clarification, FEIS page 3-153, Environmental Effects: Two of the 

eleven red pipes in the project area are located on Maintenance Level 1 

roads that are used to access Alternative F units: Road 6544 MP 2.569 

and Road 51544 MP 0.226. When these roads are stored, the removal of 

these red pipes would restore an estimated 4000 feet of mostly 

anadromous fish habitat access in Pump Creek and 4400 feet of resident 

fish habitat in Upper Big Bend watershed. The removal of these two 

pipes would substantially reduce the habitat affected by red pipes in the 

project area. An additional gray pipe at MP 0.586 (potentially affecting 

over 3,000 feet of anadromous fish habitat) could also be removed 

during storage of Road 6544. These roads would be high priority for 

storage and red pipe removal during implementation of the Access and 

Travel Management Plan (ATMP).

• Fish passage at road/stream crossings and removal or replacement of 

red pipes: In the Navy project area, eleven (not ten as stated in the 

FEIS) culverts did not meet current fish passage standards in 2009. One 

of the eleven culverts is mainly affected by beaver debris and may only 

be temporarily red (personal communication Dennis Reed, Wrangell 

RD Fish Biologist). Since 2009, an additional culvert was determined 

to be red and was replaced by a bridge in 2011. In addition, review of 

FEIS Table 40 determined that the column “Feet of Fish Habitat 

Affected” was displaying units in meters, not feet. New information 

from recently completed stream edits has also been added to update 

FEIS Table 3-40, shown here:

Watershed Name # of Red Culverts Feet of Fish Habitat 

Affected

Kindergarten Lake 2 Class II - 2,650

Pump 5 Class I - 6,195

Class II – 6,565

South Anita Bay Frontal 1 Class II - 650

Duckbill Creek 1 Class II – 2,385

Upper Big Bend Frontal 1 Class II – 4,410

West Burnett Frontal 1 Class II - 590

Total 11 Class I – 6,195

Class II – 17,255
Appendix ROD-3

A3-30  APPENDIX ROD-3 - New Information since the 2009 FEIS Navy Timber Sale Record of Decision

The wildlife and subsistence resource report has been reviewed and updated. 

The Navy biological assessment/biological evaluation (BA/BE) was also 

updated. Updated analysis is based on the Selected Alternative (Alternative F) 

unless otherwise noted.

No information that would affect the decision was revealed in these analyses. 

The FEIS states that the Alternative F would have the least effect on wildlife 

habitat of any action alternative, due to having the least acres of harvest and 

miles of roadbuilding. A summary of the updated analyses is included below.

Sitka Black-tailed Deer

The deer model was designed for use at the Forest Plan level and has 

undergone changes in the settings used as more information is known. These 

changes are described in the paper “Tongass Interagency Deer Winter Habitat 

Suitability Index Model” located in the project record.

Direction as to how the deer model is to be used for analysis was updated in 

2011. This direction was used to reanalyze the effects for Navy FEIS, and the 

reanalysis is detailed in the Wildlife and Subsistence Addendum 2012 in the 

project record.

Deer habitat capability: Deer habitat capability was reanalyzed for all 

alternatives using the October 2011 direction for the deer model which was 

developed jointly by the interagency wildlife biologists. The differences 

between FEIS model run and the 2011-direction model run deer habitat 

capability (DHC) results are largely due to how partial harvest was treated in 

the analysis. In the FEIS, if volume removal was less than or equal to 30 

percent, the stand was considered to have some remaining volume and an 

adjustment was made to the results of the deer model. The reanalysis models 

all harvest, including partial cuts, as clearcut, to provide a more-conservative 

scenario. Also, in the FEIS, non-federal ownerships were included in the 

analyses for both direct and cumulative effects; the 2011 model runs used NFSonly lands in WAA 1901 for direct effects, and all lands on Etolin Island for 

cumulative effects analysis.

Table 7, below, updates Table 3-48 in the FEIS (p. 3-170) for deer habitat 

capability, including some minor formatting changes. In Table 3-48, the 26-

150 year figures show the decline from 1900 (cumulative), but in updated 

Table 7, the figures for all years (0-25 and 26-150) show the decline from 

existing condition. 

The reanalysis shows a greater percentage of decline than the FEIS. As in the 

FEIS, Alternative F has the least effect of the action alternatives, and 

Alternative C the greatest effect. Alternative F shows a 2 percent decline in 

deer habitat capability from existing condition at 0-25 years post harvest (the 

FEIS showed a 1 percent decline), and 4 percent decline from existing 

condition at 26-150 years. 

Wildlife
Appendix ROD-3

Navy Timber Sale Record of Decision New Information since the 2009 FEIS – APPENDIX ROD-3  A3-31

Table 7

2012 Direct Effects on Sitka Black-tailed Deer Habitat Capability (DHC) 

by Alternative for WAA 19011 (updates Table 3-48 in the FEIS)

Time frame Deer Habitat Capability2 (and percent change) by Alternative

Existing Alt. A Alt. B Alt. C Alt. D Alt. E Alt. F

0-25 years

(% change )3

3,271

(N/A)

3,253

(-<1%)

3,105

(-5%)

2,991

(-9%)

3,146

(-4%)

3,087

(-6%)

3,199

(-2%)

26-150 years

(% change)

4

3,271

(N/A)

3,200

(-2%)

3,052

(-7%)

2,937

(-10%)

3,093

(-5%)

3,034

(-7%)

3,145

(-4%) 1 National Forest System (NFS) lands only in WAA 1901 with partial harvest modeled as 

clearcut. Includes existing managed stands. 2 Deer habitat capability expressed as number of deer

3 0 – 25 years represents the immediate effect of project implementation. 4 26 – 150 years represents the effects of the project once harvested areas are regenerated and 

the canopy closes, reducing the amount of understory forage for deer.

The cumulative effects were also reanalyzed to show the reduction in DHC 

from historic (1954) conditions on all lands (Table 8, below). 

Table 8 

2012 Cumulative Effect on Sitka Black-tailed Deer Habitat Capability 

(DHC) by Alternative for WAA 1901 and Etolin Island1

Scale /

Time Frame

Deer Habitat Capability2 (DHC) by Alternative

Historic

(1954)

Existing Alt. A Alt. B Alt. C Alt. D Alt. E Alt. F

WAA 1901

0-25 years

(% change)

3 3,675

3,271

(-11%)

3,253

(-11%)

3,105

(-16%)

2,991

(-19%)

3,146

(-14%)

3,087

(-16%)

3,199

(-13%)

WAA 1901

26-150 years

(% change)

4 3,675

3,271

(-11%)

3,200

(-13%)

3,052

(-17%)

2,937

(-20%)

3,093

(-16%)

3,034

(-17%)

3,145

(-14%)

Etolin Island

0-25 years

(% change)

3 6,557

6,024

(-8%)

6,006

(-8%)

5,859

(-11%)

5,744

(-12%)

5,899

(-10%)

5,840

(-11%)

5,952

(-9%)

Etolin Island

26-150 years

(% change)

4 6,557

6,024

(-8%)

5,953

(-9%)

5,805

(-11%)

5,690

(-13%)

5,846

(-11%)

5,787

(-12%)

5,899

(-10%) 1 Includes both NFS and non-NFS lands with non-NFS land assigned zero habitat capability 

and partial harvest modeled as clearcut (most conservative scenario). Includes existing 

managed stands, present, and reasonably foreseeable actions.

2 Deer habitat capability expressed as number of deer

3 0 – 25 years represents the immediate effect of project implementation 4 26 – 150 years represents the effect of the project once harvested areas areas are regenerated 

and the canopy closes, reducing the amount of understory forage for deer. 

Similar to direct effects, the results for cumulative effects show a greater 

percentage of decline than does the FEIS; however, the relative ranking of the 

alternatives is almost the same as in the FEIS. Alternative F has the least effect 

of the action alternatives. At the WAA level, Alternative F shows a 13 percent 
Appendix ROD-3

A3-32  APPENDIX ROD-3 - New Information since the 2009 FEIS Navy Timber Sale Record of Decision

decline in deer habitat capability from historic (1954) condition at 0-25 years 

post harvest, and 14 percent decline at 26-150 years (the FEIS showed a 8.7 

percent decline from historic (1900) condition) at 26-150 years. 

Deep snow habitat: Although winter habitat was considered by the project 

biologist during the analysis for the FEIS, the deer model was not designed to 

model deep snow winters (severe winters). Therefore, additional analysis was 

done for the Alternative F at both the WAA 1901 and also the all-Etolin Island 

scale to predict the results of the potential effects on deer for deep snow habitat. 

Deep snow habitat is classified as productive old-growth (high-POG) less than 

800 feet in elevation on south aspects for this analysis. There would be a direct 

effect of 2 percent reduction of deep snow habitat in WAA 1901 from the 

current levels for Alternative F, which is proportional to the overall habitat

capability reduction, and a cumulative effect of 24 percent reduction from 

historic conditions. At the Etolin Island scale, the current condition shows a 14 

percent reduction from historic levels, with no measurable change resulting 

from Alternative F.

Wolves

Deer density and road density were analyzed in the FEIS, with wolves 

considered in relation to road density. To more-thoroughly assess project 

effects on wolves, three analyses were recalculated, for: 1) Deer density to 

estimate the effects on the wolves’ primary food source, including analysis at 

the biogeographic province scale for Alternative F, 2) Road density to evaluate 

the effect of increased roads on the potential hunting/trapping pressure, 

including recent road closures and removing non-NFS lands from direct effects, 

and 3) Consideration of wolf harvest data for a more-detailed analysis of 

potential effects to wolves. 

Theoretical deer density (deer/mi2) was recalculated based on the deer habitat

capability derived from the model using the 2011 direction for all alternatives

(see discussion under Sitka black-tailed deer). This is an indicator to assess the 

ability of an area to support theoretical deer populations capable of maintaining 

sustainable wolf populations and meeting human harvest demands. 

All deer densities for WAA 1901 are less than 18 deer/mi2 (see Tables 9 and 

10, below). Historically, neither WAA 1901 nor Etolin Island supported a very 

high deer density, approximately 18 deer/mi2

, according to this analysis. As a 

result, the area may be at higher risk of not supporting deer populations capable 

of maintaining both wolf populations and meeting human harvest demands, 

where deer are the primary prey of wolves. Elk on Etolin Island may be 

fulfilling part of the role as prey for wolves. WAA 1910 on the south end of 

Etolin Island is dominated by the South Etolin Wilderness, which will maintain 

habitat into the future.

Results of the deer density by alternative reanalysis were somewhat lower (0.4 

to 0.9 deer/mi2 for direct effects at WAA 1901) than those shown in the FEIS; 

however, the ranking was the same, with Alternative F having the least effect 

of the action alternatives. 
Appendix ROD-3

Navy Timber Sale Record of Decision New Information since the 2009 FEIS – APPENDIX ROD-3  A3-33

Table 9

2012 Direct Effect on Sitka Black-tailed Deer Density (deer/square mile) 

WAA 19011 (updates portions of Table 3-51 in the FEIS)

Existing Alt. A Alt. B Alt. C Alt. D Alt. E Alt. F

0-25 years 

(% change)

2

16.0

(N/A)

16.0

(0%)

15.2

(-5%)

14.6

(-9%)

15.4

(-4%)

15.1

(-6%)

15.6

(-2%)

26-150 years

(% change)

3

16.0

(N/A)

16.0

(0%)

14.9

(-7%)

14.3

(-10%)

15.1

(-5%)

14.8

(-7%)

15.4

(-4%) 1 Deer density based upon DHC / NFS land acres at all elevations; does not include 

freshwater. They do not reflect actual, known densities of deer. 

2 0 – 25 years represents the immediate effect of project implementation 3 26 – 150 years represents the effect of the project once harvested areas go into stem exclusion.

Table 10

2012 Cumulative Effect on Sitka Black-tailed Deer Density (deer/square 

mile) WAA 1901 and Etolin Island1 (updates Tables 3-51 and 3-54 on p. 

3-177 and 3-179 of Navy FEIS)

Scale /

Time frame

Deer Density by Alternative

Historic 

(1954)

Existing Alt. A Alt. B Alt. C Alt. D Alt. E Alt. F

WAA 1901

0-25 years

(% change)

2

17.9

(N/A)

15.9

(-11%)

15.8

(-11%)

15.1

(-16%)

14.6

(-19%)

15.3

(-15%)

15.0

(-16%)

15.6

(-13%)

WAA 1901

26-150 years

(% change)

3

17.9

(N/A)

15.9

(-11%)

15.6

(-13%)

14.8

(-17%)

14.3

(-20%)

15.0

(-16%)

14.8

(-17%)

15.3

(-15%)

Etolin Island

0-25 years

(% change)

2

18.1

(N/A)

16.6

(-8%)

16.6

(-8%)

16.2

(-11%)

15.8

(-12%)

16.3

(-10%)

16.1

(-11%)

16.4

(-9%)

Etolin Island

26-150 years

(% change)

3

18.1

(N/A)

16.6

(-8%)

16.4

(-9%)

16.0

(-11%)

15.7

(-13%)

16.1

(-11%)

16.0

(-12%)

16.3

(-10%) 1 Deer density based upon DHC / total NFS and State land acres at all elevations; does not 

include freshwater. They do not reflect actual, known numbers of deer. 

2 0 – 25 years represents the immediate effect of project implementation 3 26 – 150 years represents the effect of the project once harvested areas go into stem exclusion.

Further analysis, based on Alternative F, was used to examine the effects on the 

availability of deer for both wolf and human harvest by considering deer 

density at the Etolin Island and Vicinity biogeographic province level in 

accordance with the Forest Plan guideline. In 1954, there were four WAAs

(1904, 1905, 1906, and 1910) in this biogeographic province where deer 

density was 18 deer/mi2 or greater, with WAA 1901 just slightly below, at 17.9 

deer/mi2

. Currently there is one WAA (1906) with at least 18 deer/mi2; it 

would remain so into the foreseeable future. These results are similar to those 

predicted in the Forest Plan. While subsistence hunting could be affected 
Appendix ROD-3

A3-34  APPENDIX ROD-3 - New Information since the 2009 FEIS Navy Timber Sale Record of Decision

sometime in the future, all WAAs in the Etolin biogeographic province are 

projected to remain above five deer/mi2, the level thought needed to sustain a 

viable wolf population. Therefore, deer densities on Etolin are expected to 

contribute to maintaining viable wolf populations on the Tongass (Suring et al. 

1993 VPOP Strategy). Shown below are the deer densities for cumulative 

effects, based on Alternative F, on the WAAs in the Etolin Island and Vicinity 

biogeographic province. The Navy project is within WAA 1901; Etolin Island 

includes WAAs 1901 and 1910.

Table 11

Cumulative Effects of Alternative F Timber Harvest on Deer Habitat1

WAA Historic Existing

Implementation 

0-25 years

Stem Exclusion

26-150 years

1901 17.9 15.9 15.6 15.3

1903 12.0 10.3 9.5 9.4

1904 25.6 16.7 16.7 16.5

1905 18.5 14.4 14.1 13.9

1906 41.1 26.3 26.1 24.5

1910 18.4 17.5 17.5 17.5 1. Includes other projects within the biogeographic province. 

Source: DMRerunBioprovince13ResultsUpdate20120530.xlsx

Roads and Wolf Harvest

To determine the effects of roads for the potential of increased hunting/trapping 

pressure on wolves, road densities were recalculated, based on Alternative F,

to remove State and other non-NFS lands from direct effects and to reflect 

recent road closures. Results changed slightly from those shown in the FEIS,

Table 3-52. Cumulative effects were analyzed for all ownerships on Etolin 

Island.

Except for the life of the sale, open road density below 1,200 feet elevation for 

WAA 1901 for Alternative F would remain the same as existing condition, at 

0.39 mi/mi2

. Total road density would increase, from 0.64 to 0.67 mi/mi2 

below 1,200 feet elevation for WAA 1901 with the implementation of 

Alternative F. Therefore, even during the life of the sale, road densities would 

continue to be below the Forest Plan wolf road density standard and guideline 

of 0.7 to 1.0 mi/mi2

, recommended for “areas where road access and associated 

human-caused mortality has been determined...to be a significant contributing 

factor to locally unsustainable wolf mortality” (Forest Plan p. 4-95).

The open and total road densities were also recalculated for Etolin Island. The 

open road density would be 0.22 mi/mi2 during the life of the sale and 0.21 

mi/mi2 after the roads are closed, same as the existing condition. The total road 

density for Etolin Island would be 0.41 mi/mi

2 with the implementation of 

Alternative F.

Harvest Rate of Wolves

The methodology developed jointly by the Forest Service and ADFG was used 

to analyze mortality for individual wolf packs (Person and Logan 2012). This 
Appendix ROD-3

Navy Timber Sale Record of Decision New Information since the 2009 FEIS – APPENDIX ROD-3  A3-35

analysis estimated the following harvest rate of wolves:

Table 12

Estimated average harvest rate of wolves for years 1986 through 2013

Harvest rate of individual wolf packs

WAA 1901 2.2 individuals

WAA 1910 2.0 individuals

Etolin Island 2.1 individuals

Harvest (hunting and trapping) of ≥7 wolves in a pack in 1 year is considered 

“pack depletion” and “high risk of depletion” if this persists for 2 or more 

years. Harvest of ≥3 wolves per year (estimated to be about a third of the 

population) within an average pack home range (about 116 mi2) is considered 

unsustainable and “chronic unsustainable harvest” if this persists for 5 or more 

years. For the years between 1986 and 2013, WAA 1910, on the south end of

Etolin Island, dominated by the South Etolin Wilderness and outside the project 

area, had unsustainable annual harvests of wolves 31 percent of the time during 

this time period (8 out of 26 years). WAA 1910 also had annual harvest rates 

of ≥7 wolves (pack depletion) three times or 12 percent of the time during the 

reporting period, probably since much trapping (over 75 percent) occurs on the 

shoreline from boats. 

WAA 1901 has had an unsustainable annual harvest of wolves at least 27 

percent of the time during this period (7 out of 26 years). WAA 1901 also had 

annual harvest rates of ≥7 wolves (pack depletion), only once, in 2010. This

supports the concept that the Anita Bay road system is not used as much for 

trapping, since it is not connected to a community and is not snow-plowed. 

Neither WAA 1901 nor Etolin Island as a whole has met or exceeded the

parameters for chronic unsustainable harvest or pack depletion. 

Average wolf harvest has remained within sustainable levels (ADFG Navy 

DEIS comment letter 2008). This is attributed to the relatively low 

accessibility of this area by nearby communities; however, there may be a 

concern for potential overharvest during the active portion of the timber sale.

Marten

In the FEIS, marten were analyzed as an MIS species at the WAA scale (WAA 

1901). Additional habitat analysis, based on Alternative F, has been conducted 

at the value comparison unit (VCU) scale since marten have smaller home 

ranges in this area, generally a third-order watershed or a 10,000-acre 

landscape approximately the size of an average VCU. For this additional 

analysis, all timber harvest was considered as clearcut, even though partially 

cut stands may provide habitat during some years since the stands would retain 

about 70 percent of the stand structure. 

Two measures were used to analyze the effects to marten: high-value habitat at 

the VCU level, and road density using NFS-only lands less than 1,500 feet in 
Appendix ROD-3

A3-36  APPENDIX ROD-3 - New Information since the 2009 FEIS Navy Timber Sale Record of Decision

elevation.

High-value marten habitat includes low-elevation (below 1,500 feet) highvolume old-growth stands. Direct impacts to high-value marten habitat for 

Alternative F would result in a decrease of 0 to 9 percent for all VCUs in the 

project area, and WAA 1901 would experience a 2 percent decrease. 

Cumulative effects with past harvest are more substantial, with a decrease of 4 

percent to 36 percent within the project area VCUs, with VCUs 4640 and 4670 

showing a 35 and 36 percent decrease, respectively, and VCU 4650 showing a 

25 percent decrease. VCUs where timber harvest has reduced high-value 

habitat by 25 percent or more are less capable of supporting marten during 

deep-snow winters and could lead to larger home ranges and higher rates of 

predation. Cumulative decrease is 19 percent for WAA 1901 (calculated as 17 

percent in the FEIS) and 14 percent for Etolin Island. 

Cumulative reduction in POG would range from 1 percent to 22 percent for 

project area VCUs under Alternative F. Total POG would continue to decline 

from historic habitat, but none of the individual VCUs or WAA 1901 would 

exceed the 25-30 percent of reduction in POG which research has determined 

to be a threshold in other areas of the country. Therefore, there may be affected 

individuals, but overall populations appear, and should remain, stable. 

Road density effects were considered, since roads provide access to marten 

trapping. Road density for marten has been updated using NFS-only lands less 

than 1,500 feet in elevation. As stated in the FEIS, p. 3-180, marten densities 

begin to decline in areas where road density exceeds 0.2 mile of road per 

square mile (mi/mi2

) of land and may be reduced as much as 90 percent when 

road density approaches 0.6 mile/mi2 (Suring, et al 1992). Two of the five 

VCUs in the project area (4640 and 4670) exceed 0.6 mi/mi2 for open road 

density, and three VCUs (4640, 4650, and 4670) exceed 0.6 mi/mi2 for total 

road density, both for existing condition and under Alternative F. For WAA 

1901, open road density under Alternative F would be 0.4 mi/mi2 during the 

life of the sale, then revert back to 0.3 mi/mi2 (existing condition). Both 

existing and Alternative F total road density is 0.6 mi/mi2 (estimated at 0.4 

mi/mi2 in the FEIS, p. 3-183). However, roads on Etolin Island are not 

connected to a community and are not generally plowed during the winter 

trapping season. This may partially reduce the effects of road density on the 

Etolin Island marten population. Full implementation of the Wrangell ATM 

Plan will lower the open road density in WAA 1901 by roughly 50 percent; it 

would not change the total road density. 

Cumulative impacts for road density are roughly the same for project area 

VCUs and for WAA 1901 as the direct effects, but lower for Etolin Island at 

0.2 mi/mi2

. While there may be localized effects, overall populations are less 

susceptible to overharvest from road density. Unroaded State parcels and 

National Forest System lands, plus the South Etolin wilderness augment marten 

chance of survival on Etolin Island. 

Seasons and bag limits (unlimited) have remained unchanged in the past years 
Appendix ROD-3

Navy Timber Sale Record of Decision New Information since the 2009 FEIS – APPENDIX ROD-3  A3-37

and no closures of the marten trapping season have occurred within the last 90 

years in GMU 3, except for Kuiu Island where marten trapping was closed in 

2008. ADFG has expressed concern that increasing road access on several 

islands in GMU 3 may necessitate future restrictions. No specific islands were 

mentioned and concerns most likely apply to areas accessible from 

communities.

Bald Eagle

Bald eagle protection requirements (50 CFR Part 22.26) have changed from 

what was in the former Bald Eagle MOU and analyzed in the FEIS. Variances 

no longer exist; “take” permits in accordance with the Bald and Golden Eagle 

Protection Act would be required if disturbance to nesting bald eagles would 

occur. Listed below are the required distances to avoid disturbance to nesting 

eagles. All nests are considered active March 1 through May 31; protections 

extend until August 31 unless nests are proven to be inactive. 

• Avoid clear-cutting or removal of overstory trees within 330 feet (100 

meters) of both active and alternate nests at any time (same as MOU).

• Avoid timber harvesting operations, including road construction and 

chain saw and yarding operations, during the nesting season within 660 

feet (200 meters) of the nest.

• Avoid construction of log transfer facilities and in-water log storage 

areas within 330 feet (100 meters) of active and alternate nests.

• Avoid operating helicopters or fixed-wing aircraft within 1,000 feet 

(305 meters) of the nest during the breeding season, except where 

eagles have demonstrated tolerance for such activity.

• Avoid blasting and other activities that produce extremely loud noises 

within 1/2 mile of active nests (or within 1 mile in open areas).

Bald eagle protection requirements have been updated in the unit cards.

Additional MIS

As explained in the FEIS p. 3-165, other MIS (black and brown bears, brown 

creepers, red squirrels, hairy woodpeckers, red-breasted sapsuckers, river 

otters, Vancouver Canada goose, and mountain goats) were not analyzed in 

detail in the 2008 wildlife report or FEIS, mainly because much of their 

habitats are protected by Forest Plan Standards and Guidelines. However, 

some of the preferred habitat outside old-growth reserves and areas protected 

by Forest Plan Standards and Guidelines would be affected by the action

alternatives. At an appellant’s request, analysis was expanded to include the 

MIS listed above, with the exception of mountain goats, which do not occur in 

the project area. All results are based on Alternative F, unless otherwise 

specified.

Black and brown bears: Black bears occur in the project area, and brown 

bears typically occur on the south end of Etolin outside the project area. Both

bears use a variety of habitats from sea level to alpine. Estuaries, riparian 
Appendix ROD-3

A3-38  APPENDIX ROD-3 - New Information since the 2009 FEIS Navy Timber Sale Record of Decision

areas, and forested coastal areas have the highest value; young clearcuts, 

muskegs, small openings, and subalpine meadows provide high levels of 

forage. Riparian areas and salmon-bearing streams are important during the 

spring and late summer. 

Direct effects (reduction of existing habitat) were calculated for WAA 1901

(NFS lands only), with POG representing black bear denning habitat, and all 

habitats except older young growth in stem exclusion as foraging habitat.

Cumulative effects (reductions to historic 1954 condition) were calculated for 

both WAA 1901 and Etolin Island (NFS and non-NFS land). See table below. 

This level of change is not expected to limit overall bear populations.

Table 13

Black and brown bear habitat direct (existing) and cumulative (historic) 

effects

Analysis Area Habitat type Percent reduction from 

existing/historic acres

Existing Historic

WAA 1901 POG (denning) 2% 11%

WAA 1901 All habitat (forage) 1% 4%

Etolin Island POG (denning) - 7%

Etolin Island All habitat (forage) - 3%

Brown creepers: Brown creepers nest and forage in old growth. They are 

negatively affected by edge resulting from fragmentation from logging, and 

densities are consistently lower in edge habitat. Effects to brown creepers were 

analyzed using changes in interior POG habitat and patch size to represent 

changes in brown creeper habitat.

Alternative F would reduce current interior habitat by 2 percent. The 2 percent 

reduction in habitat could have localized impacts on nesting and dispersal, but 

is not likely to limit brown creepers at the WAA scale. The Navy DEIS 

(Chapter 3, pp. 16, 25-26) contained additional information on fragmentation 

effects. 

Red squirrels: Red squirrels rely on mature conifer forests with large coneproducing trees and cavities for nest sites. Spruce trees in mature to old-growth 

forest provide the highest value, but red squirrels can survive fairly well in 

older cone-producing young growth. They are considered a “species of least 

concern” and there is no trapping or shooting harvest limit or closed season for 

squirrels in GMU3.

Direct effects (reduction of existing habitat) to red squirrels were calculated

using changes to POG and older young-growth habitat both by VCU and 

overall to WAA 1901. Cumulative effects were calculated using changes to 

POG and older young-growth habitat by VCU, for WAA 1901, and for Etolin 

Island, from historic (1954) condition. See table below. While there may be 
Appendix ROD-3

Navy Timber Sale Record of Decision New Information since the 2009 FEIS – APPENDIX ROD-3  A3-39

localized changes in squirrel home ranges and /or density, minimal effects have 

occurred at the island scale, and habitat for red squirrels will improve as 

younger stands reach cone-producing age.

Table 14

Red squirrel habitat direct (existing) and cumulative (historic) effects

Analysis Area Habitat type Percent reduction from 

existing/historic acres

Existing Historic

VCUs (WAA 1901) POG/older young growth 0 - 7% 0 - 21%

WAA 1901 POG/older young growth 2% 10%

Etolin Island POG/older young growth - 6%

Hairy woodpeckers: Hairy woodpeckers are uncommon on the Tongass, 

preferring high-volume POG stands with patches greater than 500 acres

considered optimal habitat. Both hairy woodpeckers and red-breasted 

sapsuckers are cavity nesters preferring large trees for nesting. Effects to both 

species are similar except for the type of POG affected.

Direct effects (reduction of existing habitat) were analyzed for the percent 

reduction in high-POG by VCUs in the project area and also for WAA 1901. 

Cumulative effects (reductions to historic 1954 condition) were also analyzed 

for the percent reduction in high-POG by project area VCUs and for WAA 

1901. See table below. Cumulative effects on preferred hairy woodpecker 

habitat may represent localized gaps in distribution.

Table 15

Hairy woodpecker habitat direct (existing) and cumulative (historic) 

effects

Analysis Area Habitat type Percent reduction from 

existing/historic acres

Existing Historic

VCUs (WAA 1901) High-volume POG 0 - 8% 0 - 35%

WAA 1901 High-volume POG 2% 18%

Red-breasted sapsuckers: Red-breasted sapsuckers are common on the 

Tongass. This cavity excavator uses snags and partly dead trees in coniferous, 

deciduous, or mixed forests for nesting and forage. It prefers low-and-medium 

volume POG and can be found along clearcut edges as well.

Direct effects (reduction of existing habitat) were analyzed using the percent 

reduction for low and medium-POG by VCUs in the project area and overall 

for WAA 1901. Cumulative effects (reductions to historic 1954 condition) 

were also analyzed for low and medium-POG by project area VCUs and 
Appendix ROD-3

A3-40  APPENDIX ROD-3 - New Information since the 2009 FEIS Navy Timber Sale Record of Decision

overall for WAA 1901. See table below. Impacts to red-breasted sapsucker 

habitat are less than those to hairy woodpecker habitat, due to limited past 

logging in lower volume classes.

Table 16

Red breasted sapsucker habitat direct (existing) and cumulative 

(historic) effects

Analysis Area Habitat type Percent reduction from 

existing/historic acres

Existing Historic

VCUs (WAA 1901) Low/med-volume POG 0 – 7% 0 – 11%

WAA 1901 Low/med-volume POG 2% 4%

River otters: In Southeast Alaska, river otters are associated with coastal and 

fresh water aquatic environments and the old-growth forest immediately 

adjacent (within 100-500 feet). Their primary habitat is protected by Forest 

Plan Standards and Guidelines, including Beach and Estuary Standards and 

Guidelines, and Riparian Standards and Guidelines. No harvest is scheduled in 

these habitats. All habitat within a minimum of 100 feet of Class I and II

streams is protected by standards and guidelines and Tongass Timber Reform 

Act (TTRA). 

For this analysis, effects to security and denning habitat were calculated based 

on the effects to POG within 100 to 500 feet of fish-bearing streams (Class I 

and II) for all ownerships and elevations. Since protected coastal areas provide 

the highest-quality habitat, direct project effects (reduction of existing habitat) 

are expected to be minimal. 

Cumulative effects (reduction to historic 1954 condition) to otters are more 

substantial than direct effects. See table below. Freshwater riparian denning 

and foraging security cover has been previously reduced from historic 

condition. Past harvest has also occurred in beach habitat, and these older 

clearcuts may receive some use by otters, but are not considered optimal 

habitat. No formal population surveys have been conducted, but according to 

Lowell 2010, river otter trends appear stable. 
Appendix ROD-3

Navy Timber Sale Record of Decision New Information since the 2009 FEIS – APPENDIX ROD-3  A3-41

Table 17

River otter habitat direct (existing) and cumulative (historic) effects

Analysis Area Habitat type Percent reduction 

from existing/

historic acres

Existing Historic

VCUs (WAA 1901) POG 100’-500’ from fish streams 0 - 6% 2 - 23%

WAA 1901 POG 100’-500’ from fish streams 2% 14%

Etolin Island POG 100’-500’ from fish streams - 10%

Vancouver Canada goose: Vancouver Canada goose habitat on the Tongass 

includes low-productivity forest and wetlands in estuary, river, and upland 

areas (FEIS p. 3-165). They also use overstory canopy for cover. No harvest is 

scheduled in the majority of these habitats (FEIS p. 3-165) which are protected 

by Forest Plan Standards and Guidelines. 

However, for this analysis, effects were calculated based on the reduction to 

forested muskeg, non-POG, SD5H, and SD4H lands. Direct effects (reduction 

of existing habitat) to these lands were calculated by VCU and overall for 

WAA 1901. Cumulative effects (reductions to historic 1954 condition) were 

calculated by VCU, overall for WAA 1901, and at the Etolin Island scale. See 

table below.

Table 18

Vancouver Canada goose habitat direct (existing) and cumulative 

(historic) effects

Analysis Area Habitat type Percent reduction from 

existing/historic acres

Existing Historic

VCUs (WAA 1901) Forested muskeg, nonPOG, SD5H and SD4H0 - 2% 1 - 4%

WAA 1901 Forested muskeg, nonPOG, SD5H and SD4H1% 2%

Etolin Island Forested muskeg, nonPOG, SD5H and SD4H- 1%

A Biological Assessment (BA) was completed in 2009 and concurrence was 

obtained. The list for Threatened, Candidate and Endangered species was 

reexamined on the NMFS and USFWS Alaska websites on December 28, 2011, 

and includes both species managed by USFWS and those managed by NMFS. 

Species not occurring within Southeast Alaska inside waters and/or the 

southern portion of the Tongass National Forest were dropped from further 

analysis. Species occurring within the action area were analyzed further. 

Three candidate species not previously analyzed in 2009 were considered in the 

2012 Biological Assessment/Biological Evaluation. These species are Pacific

Federally-listed

Threatened,

Endangered 

and Candidate 

species (TES) 

and Alaska 

Sensitive 

Species
Appendix ROD-3

A3-42  APPENDIX ROD-3 - New Information since the 2009 FEIS Navy Timber Sale Record of Decision

herring, yellow-billed loon, and Kittletz’s murrelet.

• Pacific herring (Clupea pallasii) within the Southeast Alaska DPS were 

designated a candidate species in April 2008 (Federal Register 2008a). 

A determination of “not likely to jeopardize candidate species, or 

adversely modify proposed critical habitat” was made for Pacific 

herring. Disturbance at Anita Bay LTFs and offshore barge locations 

would be unmeasurable compared to the range of the population. The 

project may adversely affect individuals but is not likely to result in a 

loss of viability in the planning area nor cause a trend toward federal 

listing. Since that time, the National Oceanic and Atmospheric 

Administration (NOAA) Fisheries concluded on April 2, 2014 that 

listing of the Pacific herring is not warranted at this time. 

• Yellow-billed loon (Gavia adamsii) was added as a candidate species

(March 2009). A determination of “no effect” was made for yellowbilled loons due to incidental occurrence and lack of its habitat 

disturbance. Since that time, on October 1, 2014, the USFWS issued a 

12-month finding on the petition to list the yellow-billed loon, and 

determined that listing as a threatened or endangered species is not 

warranted (79 FR 59195-59204).

• Kittlitz’s murrelet (Brachyramphus brevirostris), was proposed as a 

candidate species in May 2004. Found in glacial habitats, it has only 

incidental occurrence south of LeConte Bay, about 50 miles north of the 

project area. A determination of “no effect” was made for Kittlitz’s 

murrelet. Since that time, on October 3, 2013 the USFWS issued a 12-

month finding on the petition to list the Kittlitz’s murrelet and 

determined that listing as a threatened or endangered species is not 

warranted (78 FR 61764-61801). 

The updated BA was submitted to NMFS for review on August 29, 2012. The 

Forest Service is not required to consult with USFWS on the no effect 

determination for the candidate species, yellow-billed loon and Kittlitz’s 

murrelet. Concurrence was received on September 7, 2012. The 2009 

determination that the Navy Timber Sale “may affect, but not likely to 

adversely affect” federally listed species (humpback whale and Steller sea lion) 

remains unchanged per that concurrence letter. Since that time, the eastern 

distinct population segment Steller sea lion was delisted per a Final Rule 

published in the Federal Register November 4, 2013 and effective December 4, 

2013 (78 FR 66139), but will continue to be protected under provisions of the 

Marine Mammal Protection Act. 

The Endangered, Threatened, and Candidate Species under NMFS authority in 

Alaska list was updated in March 2013, and includes two fish species not 

previously on the list: the Lower Columbia River coho salmon (Oncorhynchus 

kisutch) and the green sturgeon (Acipenser medirostris). The Navy BA 

addresses the coho among the “Fourteen stocks of salmon [that] have been 

identified as potentially migrating into the marine waters of the Tongass (Forest 
Appendix ROD-3

Navy Timber Sale Record of Decision New Information since the 2009 FEIS – APPENDIX ROD-3  A3-43

Plan FEIS Appendix F)”, with a “low probability that some may occasionally 

be present in inside waters”. The BA concludes there will be “no effect to 

listed salmon and trout species.” Critical habitat for the green sturgeon does 

not occur in Alaska and the species’ northernmost known range is British 

Columbia, although incidental marine presence could occur in the project area. 

A determination of “no effect” has been made for the green sturgeon, as well as 

the Lower Columbia River coho salmon. NMFS concurred on March 15, 2014 

that due to the no-effect determination, no consultation was required. 

The Sensitive Species list for the Alaska Region was revised in February 2009

and the updated list was incorporated in the Navy FEIS. No updates have 

occurred since then. 

On March 31, 2014 the USFWS published a Notice of Petition Finding and 

Initiation of Status Review in the Federal Register (79 CFR 17993) for the 

Alexander Archipelago wolf. Pursuant to a 2011 petition by Greenpeace to list 

the Alexander Archipelago wolf (Canis lupus ligoni) as a threatened or 

endangered species and to designate critical habitat under the Endangered 

Species Act of 1973, as amended (Act), the USFWS 90-day review found that 

the petition presents substantial scientific or commercial information indicating 

that listing the wolf may be warranted. As a result of a positive 90-day finding,

the USFWS initiates a 12-month status review. Pursuant to an Agreement in 

Center for Biological Diversity et al. v Jewell et al. filed September 22, 2014, 

the USFWS will issue a decision by the end of 2015 on whether listing the wolf 

is warranted.

On April 10, 2015 the USFWS published a Notice of Petition Finding and 

Initiation of Status Review in the Federal Register (80 CFR 19263) for the 

Alaska yellow-cedar (Callitropsis nootkatensis). Pursuant to a 2014 petition by 

Center for Biological Diversity, The Boat Company, GSACC, and Greenpeace 

to list the Callitropsis nootkatensis as a threatened or endangered species under 

the Endangered Species Act of 1973, as amended (Act), the USFWS 90-day 

review found that the petition presents substantial scientific or commercial 

information indicating that listing the yellow-cedar may be warranted. As a 

result of a positive 90-day finding, the USFWS initiates a status review. At the 

conclusion of the status review, the USFWS will issue a 12-month finding as to 

whether the Service believes that listing is warranted. 

Appendix A

Reasons for Scheduling the Environmental 

Analysis of the Navy Timber Sale

Portions of Appendix A have been deleted, updated, or added since 2009 to 

include current agency direction and information. Figures and tables have been 

updated with the most current Forest-wide timber program information. A

complete, updated Appendix A is in the project record and online on the project 

website at http://www.fs.fed.us/nepa/nepa_project_exp.php?project=14556. 
Navy Timber Sale Record of Decision New Information since the 2009 FEIS – APPENDIX ROD-3  A3-44

Appendix B

Updated Response to Comments

Introduction

Appendix B of the FEIS includes responses to comments received for the Navy Timber 

Sale Draft Environmental Impact Statement (DEIS). As part of the interdisciplinary team 

review for the 2015 Decision for the Navy project, these responses were reviewed and 

updated as necessary. Only the portions of the comments which were updated are included 

in this appendix. The original response is included in Appendix B of the FEIS.

Comment letters are included in Appendix B of the FEIS and are annotated with an 

associated commenter acronym and a number. Responses to these comments are identified 

with a corresponding acronym and number in the Forest Service Response following each 

letter. Annotations (ie, “ACMP-7”) precede each response and correspond to the 

annotations on the original letters of comment to the Draft EIS in Appendix B of the Navy 

FEIS. 

Appendix B of the FEIS includes the annotated original letters and response to those 

comments.

Forest Service Response to Alaska State Department of Natural Resources 

Division of Coastal and Ocean Management (ACMP) Comments:

ACMP-7 

Updated Response: The response states “At this time, the Forest Service plans to replace 

one red culvert in the Pump Creek watershed during implementation of the Navy Timber 

Sale.” This statement is an error. No red culverts will be replaced as part of the Navy 

Timber Sale. A ‘red’ culvert is a road crossing structure for a stream that does not allow 

juvenile fish passage during the full range of water flows. These culverts would be 

replaced through other funding mechanisms. 

ACMP-30 

Updated Response: Since 2009, roads 51011 and 51000 within the project area have been 

stored and road 6560 within the project area has been stormproofed. These roads are not 

planned for use in the Navy project. 

Forest Service Response to AK State Dept. of Fish and Game (ADFG) 

Comments:

ADFG-11 

Updated Response: Limitations of the model were disclosed in the FEIS (pp. 3-168-169);

discussions with ADFG on the deer model resulted in updated direction in 2011.

ADFG-12 

Updated Response: Based upon 2011 direction, the deer model was re-run for the ROD 

with all units modeled as clearcut to model the most-conservative scenario. You are 

correct - since there are no agreed-upon coefficients for the other silvicultural prescriptions

used from the Navy project. The 2011 direction was updated to be more in line with the 

how the deer model was run for the 2008 Forest Plan Amendment analysis and was done 
Appendix ROD-3

Navy Timber Sale Record of Decision New Information since the 2009 FEIS – APPENDIX ROD-3  A3-45

with input from USFWS and ADFG. The 2012 addendum to the wildlife and subsistence 

report for this ROD explains how the model was used for the updated analysis. 

ADFG-13 

Updated Response: Discussions with ADFG on the model resulted in updated direction in 

2011. A separate analysis of deep snow winter habitat during severe winters was added in 

the 2012 addendum to the wildlife and subsistence report for this ROD.

ADFG-14 

Updated Response: The wolf section was updated in the 2012 addendum to the wildlife 

and subsistence report for this ROD. The Forest Service acknowledges that current deer 

density of 16 deer/square mile is below the Forest Plan guideline of 18 deer/mi2

recommended to sustain both wolves and meet estimated human deer harvest demands 

(where deer are the primary prey of wolves) and may be theoretically reduced by another 2

percent under the Selected Alternative. It is not known to what extent elk are being killed 

by wolves, but predation of elk by wolves is documented in the ADFG elk management 

report for GMU 3.

ADFG-17 

Updated Response: Theoretical deer density was updated in the 2012 addendum to the 

wildlife and subsistence report for this ROD using the information of the updated deer 

model information.

ADFG-18 

Updated Response: The 2012 addendum to the wildlife and subsistence report for this

ROD includes additional risk analysis of wolf mortality based upon methodology in Person 

and Logan 2012.

ADFG-27 

Updated Response: The Selected Alternative does not harvest timber in roadless areas;

therefore no directly affected acres would be within an inventoried roadless area. 

Additional marten analysis was included in the 2012 addendum to the wildlife and 

subsistence report for this ROD, and includes analysis by VCU, WAA, and Etolin Island as 

a whole. 

Forest Service Response to Environmental Protection Agency (EPA) 

Comments:

EPA-2 

Updated Response: The new NPDES permit was received, with an authorization effective 

date of April 15, 2009. 

Forest Service Response to Glen Ith (GI) Comments:

GI-4 

Updated Response: The quartile method is no longer used to display the results of the 

deer model. Additional discussion is under ADFG 12 and 13.

GI-4c 

Updated Response: The deer model was run again using the 2011 direction, and the 

results are in the 2012 addendum to the wildlife and subsistence report in the project 

record. Also discussed in response to comments ADFG-12 and 13.
Appendix ROD-3

A3-46  APPENDIX ROD- 3 - New Information since the 2009 FEIS Navy Timber Sale Record of Decision

GI-4f 

Updated Response: Also discussed in response to comments ADFG-12 and 13.

GI-5 

Updated Response: Although effects to individual patch size were not displayed in detail 

in the FEIS, the 2008 Old Growth resource report included changes to the number of 

blocks and average block size by category from historic to resulting condition (Table OG6).

Forest Service Response to SE Alaska Conservation Council (SEACC) 

Comments:

SEACC-1 

Updated Response: Updated market demand is calculated annually, with the estimate 

used as a guideline in setting annual timber sale goals. Predicting likely timber purchases 

and offer levels on the Tongass for Fiscal Year 2014 can be referenced at 

http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5447816.pdf (Feb 3, 2014). 

SEACC-3 

Updated Response: The 5-year timber sale plan has information on when and how much 

estimated volume is planned from the Navy project; however, the preliminary timber cruise 

volume data for the Navy alternatives show a lower available volume. The information in 

Appendix A has been updated from FY 2009 to FY 2014 based on the estimated amount of 

market demand for FY 2014. See response to comments SEACC-1, and SEACC- 9 to 

SEACC-13. The market demand is updated annually. 

SEACC-11 

Updated Response: Brackley et al. was estimating timber demand and not the timber to 

be offered since the availability of timber to be offered is dependent on various factors. The 

FY 2013 timber demand was estimated at 143 MMBF. The volume that was offered was 

115 MMBF.

SEACC-12 

Updated Response: Although in 2009, Silver Bay Logging, Inc. had been in negotiations 

to sell the Wrangell mill; prospective purchasers had voiced reluctance due to lack of a 

steady timber supply, which is one of the reasons that this is a significant issue for this 

project. In 2010, Silver Bay Logging dismantled their mill. The indicated bid value was 

recalculated to the Viking Mill in Klawock on Prince of Wales Island in the updated 

FASTR analysis.

SEACC-13 

Updated Response: Appendix A of the Navy FEIS has been updated with current

information.

Forest Service Response to Sealaska Corporation (SC) Comments:

SC-2

Updated Response: The NEPA Economic Analysis Tool-Residual Value, or NEATR 

program, used for modeling financial analysis in the FEIS, has been superseded by the 

Financial Analysis Spreadsheet Tool – RV, (FASTR). Like NEATR, FASTR provides a 

relative comparison of anticipated project costs and revenues for a range of project 

alternatives. The FASTR model uses the same logging costs and manufacturing costs 
Appendix ROD-3

Navy Timber Sale Record of Decision New Information since the 2009 FEIS – APPENDIX ROD-3  A3-47

developed for the Alaska Region timber sale appraisal program. FASTR was used during 

the updated FEIS analysis to analyze and compare the alternatives. At this time, the action 

alternatives still show deficit returns. Inputs into the FASTR program are rough estimates 

and the output is not intended to be used as a timber sale appraisal. 

SC-3 

Updated Response: With the decision of the Organized Village of Kake, et al. vs. US 

Department of Agriculture (1:09-cv-00023 JWS), the Tongass exemption for the roadless 

rule was vacated and the roadless rule’s application to the Tongass was reinstated on March 

4, 2011. A subsequent ruling on March 26, 2014 by the Ninth Circuit Court of Appeals 

reversed that District Court decision concerning the exemption of the Tongass from the 

roadless rule. The Ninth Circuit Court also remanded the case to the District Court to 

decide whether a supplemental EIS is required for the Tongass exemption. In August 2014, 

however, the Ninth Circuit Court of Appeals granted another hearing, held in December 

2014, before an eleven-judge panel to rehear the appeal of the March 2011 decision. The 

Ninth Circuit Court has issued its en banc decision in Organized Village of Kake v. U.S. 

Dept. of Agriculture, 11-35517, upholding the Alaska District Court’s reinstatement of the 

roadless rule, which remains in effect and applies to the Tongass. 

Forest Service Response to Sitka Conservation Society et al (SCS) 

Comments:

SCS-2 

Updated Response: See updated response to SC-3.

SCS-3 

Updated Response: The Navy project presents a range of alternatives, including a noaction alternative, that responds to the issues identified. The range of volume among the 

action alternatives has been recalculated to be estimated at 13.1 MMBF (Alternative F) to 

62.0 MMBF (Alternative C), with the other action alternatives falling in this range.

SCS-8 

Updated Response: The referenced link has been updated to 

http://www.fs.fed.us/pnw/pubs/brackley/index.shtml.

SCS-9 

Updated Response: Appendix A has been updated for FY 2014. The updated market 

demand estimate calculations for FY 2014 can be referenced at 

http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5447816.pdf.

SCS-16 

Updated Response: On March 28, 2011, Financial Analysis Spreadsheet Tool – RV 

(FASTR) was approved by the Regional Forester to replace the NEPA Economic Analysis 

Tool Residual Value (NEAT_R) version 2.16 as the Forest Service, Alaska Region, 

financial efficiency and economic analysis tool for use in modeling timber volume during 

planning. The Financial Efficiency Table (FEIS Table 3-5 TM-5) has been updated using 

the FASTR analysis modeling tool and is documented in the addendum to the timber 

economics report. 

Forest Services cost averages per MBF have been updated as discussed under Issue 1, 

Timber Supply and Economics (see subsections Financial Efficiency Analysis and Forest 
Appendix ROD-3

A3-48  APPENDIX ROD- 3 - New Information since the 2009 FEIS Navy Timber Sale Record of Decision

Service Costs) in this appendix. 

SCS-18 

Updated Response: In November 2009, the Regional Forester approved time-limited 

shipment of unprocessed hemlock and Sitka spruce logs and provided additional options 

for purchasers. The export policy is reviewed annually by the Regional Forester. An 

updated (February 2014) letter regarding the current export policy is in the project record.

SCS-19 

Updated Response: See also the updated response to comment SCS-18 regarding limited 

interstate shipment policy.

SCS-20 

Updated Response: FASTR, used in the updated analysis, reflects Alaska yellow-cedar 

export rates. Species selling values are incorporated from the most recent quarterly 

appraisal bulletin used for the residual value appraisal method. The Navy FEIS used the 

Residual Value 3rd Qtr., 2007 appraisal bulletin and the updated analysis used the FASTR 

version October 21, 2013 using the Residual Value 4th Qtr, 2012 to compare alternatives.

SCS-21 

Updated Response: Table 3-2 has been updated in the timber report addendum (Table 1), 

using data generated by FASTR and updated employment coefficients for logging and 

sawmilling. 

Timber cruise data collected since the 2009 FEIS showed less volume than the stand exam 

volume estimates in the FEIS, with employment figure estimates decreased accordingly 

(Table 3 in the timber report addendum, in the project record). 

SCS-34 

Updated Response: See updated response to SC-3.

SCS-35c 

Updated Response: Regarding the roadless component of the Navy project area, almost 

54,000 acres are roadless (2001 Roadless Rule inventory) - about 80 percent of the total 

project area. Alternative C would directly affect the most vegetation by harvesting timber

in cable-harvest units and clearing roads within the roadless acres, about 1,572 acres and 17 

miles of new NFS and temporary roads within the inventoried roadless areas. To reflect a 

more conservative, complete analysis of direct and indirect effects to inventoried roadless 

areas, helicopter units were included in the updated analysis. Alternative C would harvest 

about 2,891 acres with helicopter yarding; however, these units leave 70 percent of the 

timber stand intact and do not require any roadbuilding. 

Alternative B would remove timber from over 583 acres with cable yarding and 7 miles of 

roads, and 1,617 acres by helicopters. Alternative D has a similar amount of cable yarding 

units, about 487 acres and 5 miles of road, but less than 607 acres of helicopter harvest. 

Alternative E has 0 acres of cable unit harvest with just under 2 miles of road, but 2,219 

acres of helicopter harvest within the Navy project area (2012 roadless area analysis 

addendum). Alternative F, the Selected Alternative, does not harvest any timber or build 

any roads in IRAs.

With the decision of the Organized Village of Kake, et al. vs. US Department of 
Appendix ROD-3

Navy Timber Sale Record of Decision New Information since the 2009 FEIS – APPENDIX ROD-3  A3-49

Agriculture (1:09-cv-00023 JWS), the Tongass exemption for the roadless rule was vacated 

and the Roadless Rule’s application to the Tongass was reinstated on March 4, 2011. A 

subsequent ruling on March 26, 2014 by the Ninth Circuit Court of Appeals reversed that 

District Court decision concerning the exemption of the Tongass from the roadless rule. 

The Ninth Circuit Court also remanded the case to the District Court to decide whether a 

supplemental EIS is required for the Tongass exemption. In August 2014, however, the 

Ninth Circuit Court of Appeals granted another hearing, held in December 2014, before an 

eleven-judge panel to rehear the appeal of the March 2011 decision. The Ninth Circuit 

Court has issued its en banc decision in Organized Village of Kake v. U.S. Dept. of 

Agriculture, 11-35517, upholding the Alaska District Court’s reinstatement of the roadless 

rule, which remains in effect and applies to the Tongass.

SCS-37 

Updated Response: Appendix A to the FEIS annually updates the timber demand figure. 

Due to the export policy and good overseas markets, in addition to recovering domestic 

markets, in 2014 this is based on the “Expanded Lumber, Scenario 2”, with the goal for 

volume of timber to be offered at 142 MMBF.

SCS-41 

Updated Response: The Navy project is fully compliant with the requirements of NFMA. 

The silvicultural prescriptions are designed to:

• The even-aged management prescriptions will regenerate cedar, and precommercial thinning will give preference to cedar young growth to maintain or 

increase the cedar composition. 

• For the uneven-aged prescriptions, where 70 percent of the original basal area will 

be left, no more than 50 percent of the cedar and spruce basal area will be 

harvested. Species diversity and the cedar component will be maintained. Alaska 

yellow-cedar and western redcedar regeneration is considerable in many of the 

stands previously harvested. A summary of pre- and projected post-harvest 

conditions shows quantitative effects of single-tree selection for trees over 9” DBH 

for helicopter units in the Navy project area, found in the silviculture resource 

report, Table 6. Monitoring after harvest will be done via stocking surveys on all 

harvest units to verify the effectiveness of recruiting and retaining desired species in 

the managed stand.

• Several of the even-aged stands will have western redcedar and Alaska yellowcedar retained as seed trees to provide a seed source for the future stand. This will 

minimize the effects of porcupine damage on the regenerated stands, as porcupines 

do not prefer these species as a source of food. This also will help establish and 

maintain a cedar component in the newly regenerated stand.

• The planting of Alaska yellow-cedar is an option that is in the silvicultural 

prescriptions and can be implemented if Alaska yellow-cedar is not regenerating in 

the stand. This is costly and usually not necessary with the prolific natural 

regeneration that occurs in Southeast Alaska. It is fully expected that all species, 

including Alaska yellow-cedar, will naturally regenerate following timber harvest in 

the Navy project area. 
Appendix ROD-3

A3-50  APPENDIX ROD- 3 - New Information since the 2009 FEIS Navy Timber Sale Record of Decision

• At the time of precommercial thinning for even-aged stands, Alaska yellow-cedar 

and western redcedar are the first-priority species to be favored and selected as 

leave trees. This is both an effective and economical way to increase the percent of 

cedar within a managed stand.

The Navy project is not proposing any vegetation type conversion requiring justification by 

an analysis showing biological, economic, social, and environmental design consequences, 

and the relation of such conversions to the process of natural change.

SCS-42 

Updated Response: Alaska yellow-cedar (AYC) decline is recognized and discussed in 

the silviculture section of the FEIS on pages 3-99 to 104 and in the 2012 updated 

silviculture resource report. The silviculture report identifies the units where yellow-cedar 

decline was found to occur. As described in SCS-41, above, several measures can be taken 

to ensure that species mix, including Alaska yellow-cedar and western redcedar, is 

maintained, and these are specified on the unit cards where prescribed. 

Paul Hennon et al.’s Dynamic Conservation Strategy discusses the complex causes of AYC 

decline and reduces it to two factors for landscape modeling: snow cover and drainage. 

AYC had reached its greatest competitive advantage in poorly and moderately drained soils 

but is now only healthy at these sites where snow-cover levels are adequate to offer 

protection. Within zones in which the snow cover is sufficient, AYC’s niche has been 

limited to better-drained soils where its roots can penetrate deeper. Hennon et al identified 

dynamic maladapted, persistent, and migration zones for AYC. There is guidance and 

options for conservation and management in the paper, Shifting Climate, Altered Niche, 

and a Dynamic Conservation Strategy for Yellow-Cedar in the North Pacific Coastal 

Rainforest (Hennon et al 2012).

Ongoing efforts to develop a comprehensive conservation and management strategy for 

AYC in Southeast Alaska are nearly complete. This strategy provides:

• a thorough review of the knowledge on the extensive mortality to AYC, including 

the role of climate,

• options for the conservation and active management of AYC on lands that are 

considered either suitable or unsuitable for AYC,

• the use of risk models and yellow-cedar distribution to evaluate, quantify, and map 

areas of habitat suitability for AYC, both now and in the future century. 

Risk of decline to AYC by the year 2080 varies considerably by geography in coastal 

Alaska. Some areas are already heavily impacted by decline and risk is not expected to 

increase appreciably; other areas are currently unimpacted, but are expected to develop 

decline; still other areas are expected to remain healthy. 

The coastal rainforest environment around the range of AYC in Alaska is divided into 33 

geographic zones to produce a more fine-scale view of AYC’s current and expected future 

health status and associated prospects for conservation and management. Within the Etolin 

Island Management Zone, where the Navy project is located, the percentage of AYC

forests expected to be at high risk doubles from 11 to 23 percent between 2020 and 2080. 

High-risk areas are initially concentrated on southern, western, and eastern portions of this 
Appendix ROD-3

Navy Timber Sale Record of Decision New Information since the 2009 FEIS – APPENDIX ROD-3  A3-51

management area and then encroach to higher elevations and more-northerly latitudes. 

Several areas known to have AYC decline now do not show high risk until 2080 (e.g., the 

valley between Alice Peak and Helen Peak). AYC forests rated at low risk decrease from 

67 percent in 2020 to 34 percent in 2080. Low-risk forests in 2080 are well distributed, but 

are mainly found at high elevations and interior areas of Etolin Island. 

Conservation goals for AYC can be met in the large South Etolin wilderness area in the 

southern portion of the island. There, extensive AYC decline occurs now and is expected 

to progress upslope, but extensive areas of low to medium risk persist at higher elevations 

through 2080. Some areas that are currently impacted by decline are not projected to be at 

high risk to decline until 2080; therefore, relative risk may be underestimated somewhat for 

other parts of this management zone. Succession to other species, including western 

redcedar, is expected in these impacted forests. Within the Navy project area, there are 

good opportunities for active management, given road systems and land-use status. 

Additional AYC could be planted on well-drained soils, as was done in 1986 at Anita Bay

(Hennon Et.al [n.d]). This is included as an option in the silvicultural prescriptions for the 

Navy project.

SCS-58 

Updated Response: Open and total road density calculations were updated in the 2012 

addendum to the wildlife and subsistence report for this ROD.

SCS-60 

Updated Response: Since 2009, road maintenance work has been accomplished within 

the project area. In 2008, a road maintenance contract closed 1.5 miles of Roads 6560 and 

51011 and decommissioned 0.4 mile of Road 51000. Sections of the 6539 and 6543 roads

which were identified for reconditioning in the FEIS have had periodic maintenance work 

completed. 

SCS-62 

Updated Response: See updated response to SCS-60.

SCS-85 

Updated Response: Although not required, additional MIS analysis was included in the 

2012 addendum to the wildlife and subsistence report for this ROD. Information on TES 

species was updated in BA/BE for this ROD.

SCS-89

Updated Response: The single-tree selection prescriptions will not eliminate spruce from 

the stand. No more than 50 percent of the basal area of the spruce in the stand will be 

removed. Deal, et al (2001) found that partial cutting maintained stand structures similar to 

uncut old-growth stands, and the cutting had no significant effect on tree species 

composition (FEIS p. 4-27). 

Deer modeling assumptions used for the FEIS are found in the Wildlife section in Chapter 

3. The 2012 addendum to the wildlife and subsistence report outlines the assumptions used 

for the deer model as rerun using 2011 direction. See also updated response to ADFG-12 

and 13.
Appendix ROD-3

A3-52  APPENDIX ROD- 3 - New Information since the 2009 FEIS Navy Timber Sale Record of Decision

SCS-113 

Updated Response: See updated response ADFG 11-13.

The deer model was rerun using 2011 direction, as described in the 2012 addendum to the 

wildlife and subsistence report in the Navy project record.

SCS-115a and 115b

Updated Response: See updated response to ADFG-12 and 13.

SCS-116 

Updated Response: See updated response to ADFG-12 and 13.

SCS-118 

Updated Response: See updated response to ADFG& 12 and 13.

SCS-120 

Updated Response: See updated response to ADFG-12.

SCS-121 

Updated Response: See also updated response to ADFG-12.

SCS-122 

Updated Response: See updated response to ADFG-12.

Uneven-aged stands are created through uneven-aged systems or small-scale natural 

periodic disturbances that allow for recruitment/release of understory trees resulting in a 

multi-storied stand structure.

SCS-123 

Updated Response: See updated response to ADFG-12.

SCS-124

Updated Response: The silviculture resource report defines an uneven-aged stand and the 

objectives of uneven-aged management, the silviculture system implemented with the 

single-tree selection partial harvest prescription. See also updated response to ADFG-12.

SCS-126 

Updated Response: See also updated response to ADFG 11 and the Forest Plan (pp. 3-

231 to 232 and 3-265 through 3-268). 

SCS-127 

Updated Response: See updated response to ADFG 11-13 and SCS 126.

SCS-128 

Updated Response: See updated response to ADFG 11-13 and SCS 126.

SCS-129 

Updated Response: See updated response to ADFG-13.

SCS-130 

Updated Response: See updated response to ADFG 11-13 and SCS 126.
Appendix ROD-3

Navy Timber Sale Record of Decision New Information since the 2009 FEIS – APPENDIX ROD-3  A3-53

SCS-131 

Updated Response: Since the 2009 FEIS, the quartile method is no longer in use. See 

additional discussion under ADFG-12 and 13.

SCS-132 

Updated Response: See updated response to ADFG-14 and 18.

SCS-134 

Updated Response: See also updated response to ADFG-14 and 18.

SCS-135 

Updated Response: Total and open road densities were updated in the 2012 wildlife and 

subsistence report for the ROD.

Forest Service Response to The Wilderness Society (TWS) Comments:

TWS-1 

Updated Response:

See updated response to SC-3.

TWS-4 

Updated Response: In November 2009, the Regional Forester approved time-limited 

shipment of unprocessed hemlock and Sitka spruce logs and provided additional options 

for purchasers. The February 2014 letter from the Regional Forester for the annual review 

of the export policy is in the project record. Timber markets are subject to the global 

marketplace and are very dynamic. 

TWS-6 

Updated Response: 

See updated response to SC-3.

Forest Service Response to George Woodbury (GW) Comments:

GW-1 

Updated Response: While market fluctuations show an improvement in the economics of 

all alternatives, as compared to the FEIS, the modeled indicated bid value for all 

alternatives including the Selected Alternative is currently deficit, based on the historic 

market conditions and current cost collection numbers. However, these values may not 

reflect the future market conditions at the time of the contract offering. An alternative may 

or may not become more economical in future markets, or a portion of the units may be

economical in current markets. If the contract appraises deficit at the future time of 

offering, it will not be advertised until market conditions improve. 
Appendix ROD-3

A3-54  APPENDIX ROD- 3 - New Information since the 2009 FEIS Navy Timber Sale Record of Decision

References

2011 Draft Report. Exploring the Sustainable Yield Capacity of the Young Growth Lands 

on the Tongass National Forest while Evaluating the Impact of Acreage Reductions and 

Rotation Age. Prepared for USDA Forest Service and Juneau Economic Development 

Council, 2011. 

Anderson, H.E. 2011. Biomass and carbon. In: Barrett, T.M.; Christensen, G.A., tech eds., 

Forests of southeast and south central Alaska, 2004-2008. Gen Tech. Rep. PNW-GTR-835. 

Portland, OR: US Department of Agriculture, Forest Service, Pacific Northwest Research 

Station: 13-22.

Barrett, T.M. 2014. Storage and flux of carbon in live trees, snags, and logs in the Chugach 

and Tongass National Forests. Gen Tech. Rep. PNW-GTR-889. Portland, OR: US 

Department of Agriculture, Forest Service, Pacific Northwest Research Station: 44 p.

Deal, Robert L. 2001. The effects of partial cutting on forest plant communities of western 

hemlock-Sitka spruce stands in southeast Alaska. Canadian Journal of Forestry Resources. 

31:2067-2079

Federal District Court, District of Alaska ruling in Organized Village of Kake, et al. v. US 

Department of Agriculture (D.C. No. 1:09-cv-00023 JWS) March 4, 2011.

Hennon, Paul, E. et al 2012. Shifting Climate, Altered Niche, and a Dynamic Conservation 

Strategy for Yellow-Cedar in the North Pacific Coastal Rainforest. In: BioScience 62: 147–

158.

Hennon, P., McKenzie, C., D’Amore, D., Wittwer, D., Mulvey R., Lamb, M., Biles, F., 

Cronn, R., [n.d.] A climate Adaptation Strategy for Conservation and Management of 

Yellow-cedar in Alaska. Manuscript in review. On file with P. Hennon, Pacific Northwest 

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Lowell, R. E.. 2010b. Unit 3. Pages 59-75 in P. Harper, editor. Furbearer management 

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Person, D. K. and B. D. Logan. 2012. A spatial analysis of wolf harvest and harvest risk on 

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Alaska Department of Fish and Game, Juneau, AK. USA.

Suring, L.H., R.W. Flynn, and E.J. DeGayner. 1992. Habitat capability model for marten in 

Southeast Alaska: winter habitat, in L.H. Suring, 1993, Habitat capability models for 

wildlife in Southeast Alaska. USDA Forest Service, Juneau, AK.

Suring, L. H., D. C. Crocker-Bedford, R. W. Flynn, C. S. Hale, G. C. Iverson, M. D, 

Kerchoff, T. E. Schenck, L.C. Shea, and K. Titus. 1993. A Proposed Strategy for 

Maintaining Well-Distributed, Viable Populations of Wildlife Associated With OldGrowth Forests in Southeast Alaska. Report to an Interagency Committee. Juneau, Alaska: 

USDA, Forest Service, Alaska Region. 

USDA Office of the Secretary of Agriculture. 2010. News Release No. 0288.10. May 26, 
Appendix ROD-3

Navy Timber Sale Record of Decision New Information since the 2009 FEIS – APPENDIX ROD-3  A3-55

2010.

USDA Office of the Secretary of Agriculture. 2013. Memorandum 1044-009 “Addressing 

Sustainable Forestry in Southeast Alaska” July 2, 2013

USDA Forest Service. 2008. Tongass National Forest Land and Resource Management 

Plan, Final Environmental Impact Statement, and Record of Decision. R10-MB-603a-d 

(all volumes). USDA Forest Service, Alaska Region.

USDA Forest Service. 2007. Navy Timber Sale Draft Environmental Impact Statement. 

R10-MB-572a and b. Wrangell Ranger District, Wrangell, AK.

USDA Forest Service. 2007. Navy Timber Sale Final Environmental Impact Statement. 

R10-MB-632. Wrangell Ranger District, Wrangell, AK.
Appendix ROD-3

A3-56  APPENDIX ROD- 3 - New Information since the 2009 FEIS Navy Timber Sale Record of Decision

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