APPENDIX 2 

RESPONSE TO COMMENTS 

In addition to discussion at meetings and subsistence hearing testimony, we received ten 

comments on the Environmental Assessment (EA) for the Prince of Wales Outfitter and Guide 

Management Plan. In this appendix, the Forest Service displays and responds to those ten 

comments. 

Introduction 

The Forest Service prepared and mailed the EA for the Prince of Wales Outfitter and Guide 

Management Plan to the public for their comments in March and April 2012. The 30-day 

comment period ended May 9, 2012. Ten comments were received via letters or documented 

conversation from the following individuals or agencies on this EA. A letter designator and 

comment number were assigned for tracking purposes. 

This appendix displays the annotated comment letters followed by the Forest Service’s response 

to those comments. In many of the responses to comments, we provide specific locations or 

page numbers in the EA where a particular topic or analysis is displayed or discussed. 

References for literature cited in this appendix may be found in the EA if a document was 

originally cited in the EA or at the end of this appendix if it is a new citation. 

List of those who commented on the Prince of Wales Outfitter and Guide 

Management Plan EA and comment letter designator 

AKC Stephen Helgeson, Program Director 

Alaska Crossings, Alaska Island Community Services 

CW Charles P Wagner and Charles A. Wagner 

Alaska Coastal Adventures 

DW Dennis Watson 

Craig City Council 

JL Johnnie Laird 

MD Michael Douville 

MG Mark Galla 

Alaska Peak and Seas 

PP Paula Peterson 

Kasaan Tribal Association 

____________________________________________________________________________________

Appendix 2, Response to Comments - Page 1
List of those who commented on the Prince of Wales Outfitter and Guide 

Management Plan EA and comment letter designator 

RL-ST Ron Leighton, Organized Village of Kasaan 

and 

Sam Thomas 

SCL Larry G. McQuarrie 

Sportsman’s Cove Lodge, Southeast Alaska Sportfishing 

Adventures, Inc. 

State Nina Brudie, ANILCA Project Coordinator 

State of Alaska, ANILCA Implementation Program, Office of 

Project Management and Permitting 

____________________________________________________________________________________

Appendix 2, Response to Comments - Page 2

____________________________________________________________ Prince of Wales Outfitter and Guide Management Plan
____________________________________________________________________________________

Appendix 2, Response to Comments - Page 3

____________________________________________________________ Prince of Wales Outfitter and Guide Management Plan
Responses to Alaska Crossings/Stephen Helgeson’s Comments 

(AKC) 

AKC - 1 

There are 210 established sites in the Prince of Wales project area that Crossings may use 

within the next two years, while this assessment and implementation takes place. 

Following this period, Crossings may request that new sites be assessed and possibly 

added to the Outfitter and Guide use areas. The locations in the EA include all outfitter 

and guide use requests through March, 2011. Unfortunately, Alaska Crossing's request 

for new use locations was received after the list of locations was finalized, so those new 

locations were never analyzed and thus could not be included in a decision at this time. 

AKC - 2 

We recognize that there are only six sites between Whale Passage and Pine Point along 

the coast, which makes planning kayak trips difficult. Unfortunately, your request for 

service days came during the middle of the planning process. In order to meet the 

constraints of NEPA, we cannot add sites at this time. Since Crossings used 220 service 

days in 2011, we hope that you can continue using the sites you are already permitted to 

use until we complete this project and monitor effects for two years (EA page 22). 

AKC - 3 

There is a mechanism in place for adding sites through adaptive management (EA page 

22) after two years of monitoring. We understand that this time frame does not work 

with your planned expansion. However, in order to determine if the selected alternative 

meets our purpose and need, we require time to monitor effects. Maintaining forest 

resources and limiting conflicts are high priorities for both districts. 

____________________________________________________________________________________

Appendix 2, Response to Comments - Page 4

____________________________________________________________ Prince of Wales Outfitter and Guide Management Plan
Charles P. Wagner and Charles A. Wagner

Alaska Coastal Adventures 

May 5, 2012, Telephone Comments on the EA 

I was called by Charles P. Wagner and Charles A. Wagner regarding the Prince of Wales Outfitter and 

Guide EA. They have been operating out of Prince of Wales for over 30-years. Charles P. has had 26 

bears that he can harvest out of there for many years. He is a registered guide with 22 years on POW. 

spoke with only one Charles because they discussed each point listed so they had one answer. 

I have been able to keep my livelihood for running hunts for all of those years. We’re also 

transporters. We hunt POW from Exchange Cove all the way to Cape Pole. This area includes 

El Cap, Caulder, Shipley, Red Bay, Salmon Bay, and Buster Bay. 

Over the years, we have seen a depletion of resources from unguided people. The people shoot 

an animal and when they can’t find the wounded animal, they go after another bear – so, 

depleting resources. 

They are leaning toward the listed alternatives for the following sites:

Caulder Bay Alternative 1 Keep it as it is.

California Bay they like Alternative 4.

El Cap Pass Shore Lean toward Alternative 3

Exchange Cover East Shore Alternative 4

Exchange Cove West Alternative 3. A lot of boats float through there, he would 

like a number below 580 something like 250 or 300 at 

most.

Kosciusko Island Road would like to see 200 to 250 service days he thinks 

Alternative 3 is too high. 

Lava Creek Alternative 3 this is a pretty active spot.

No Name Lake Alternative 4

Pine Point Alternative 4

Red Bay Creek/Lake Alternative 4

Red Bay Lake Trail Alternative 4

Salmon Bay Alternative 4

Salmon Bay Creek Alternative 4

Salmon Bay Lake Alternative 4

Shakan Bay Alternative 4

Shipley Bay and Shipley Bay 

Creek/Lake 

Alternative 4

Trout Creek would agree with at least 100 SDs there. There are quite a 

few fly fisherman going there for steelhead and Dolly 

Varden. The area is gorgeous so a lot of people flow in 

and out there. 

CW - 1

CW - 2

CW - 3

____________________________________________________________________________________

Appendix 2, Response to Comments - Page 5

____________________________________________________________ Prince of Wales Outfitter and Guide Management Plan
Charles would like a 60-day limit on the fall hunting days. For example, if you go to the same 

spot twice in a year with clients, you are over the 40 days. 

(5 people x 5 days = 25 SDs x two visits = 50 SDs) 

The revenue that they bring into town is pretty important. This includes Point Baker, small POW 

towns, and Wrangell. 

Phone 951 378-5006 

E-mail charliepwagner@yahoo.com

 

Notes by Sue Jennings 

CW - 4

CW - 5

____________________________________________________________________________________

Appendix 2, Response to Comments - Page 6

____________________________________________________________ Prince of Wales Outfitter and Guide Management Plan
Responses to Charles P. and Charles A. Wagner’s Comments (CW) 

CW-1 

Thank you for your comment, your concerns were considered before a decision was 

made. 

CW-2 

Wounded bears count toward your bag limit for bears in Unit 2, therefore additional 

harvest by nonresidents who have wounded a bear would be unlawful. Unguided hunters 

are beyond the scope of this analysis, though we have provided your comments to the 

Alaska State ANILCA office to share with those State agencies that do have jurisdiction 

over your concerns. 

CW-3 

Thank you for your comment, your concerns were considered before a decision was 

made. 

CW-4 

So far no site has exceeded 40 days for fall hunting, so setting the limit at 60 seems 

unnecessarily high. Forty days is a compromise between allowing growth of guided 

hunting in fall for most sites, while mitigating for conflicts with subsistence users. See 

also response to comment DW-26. 

CW-5 

Thank you for your comment, your concerns were considered before a decision was 

made. 

____________________________________________________________________________________

Appendix 2, Response to Comments - Page 7

____________________________________________________________ Prince of Wales Outfitter and Guide Management Plan
Dennis Watson

Craig City Council

April 23, 2012, Initial Call 

The Craig City Council did meeting last night and discussed this project. He will be in the area 

this week, April 25 and 27. 

They don’t understand why things happened the way they did. 

April 24, 2012, Meeting at Craig Ranger District Office

Concern is a several fold increase in the area around Craig. 

Dennis looked through the Craig City Council comments, which were written before he was on 

the Council. He feels it looked like Craig comments were summarily dismissed. People have 

lived here all their lives and when they are saying something, they are not just blowing air. 

What the Council found missing from the alternatives was a zero alternative, where there are no 

outfitter and guide permitted activities. The zero alternative should be available because he sees 

no place where there is pent up demand. 

The eastern side of the island is a high use area; the other side is what it is. The Craig side has 

much less outfitter and guide use and people like it that way. 

Why would anyone want to go to Cora Point? He has been a commercial fisherman for other 30-

years and he cannot see why anyone would go to Cora Point. 

El Cap – the City Council expect to see more use there. 

Pole Anchorage – this area is totally utilized and over, especially in the summer months. 

Hole in the Wall is totally utilized already – already used up. You don’t see much use in the 

spring and fall but in the summer, it is full of people. 

The Council did actually single out the areas they wanted in their past comments. 

Sumez in particular Arena Cove, don’t know why we would want more people. 

Tlevak Narrows – biggest problem is that this is already the highest use subsistence hunting area 

and there are already conflicts with guides. Don’t want to see an increase here; don’t want to be 

like Kuiu. 

Security Cove – Dall Island can be packed with commercial fishermen and packers in the 

summer. The number of guided clients is not going to bother the fishermen but it may bother the 

clients. 

Tenass Bay – there is a big oyster farm behind El Cap and Tuxekan. People have to understand 

that the State is trying to promote a mariculture area there. There are already problems with 

commercial fishers and other anglers and the oyster farms. 

DW-1

DW-2

DW-3

DW-4

DW-5

DW-6

DW-7

DW-8

DW-9

DW-10

DW-11

____________________________________________________________________________________

Appendix 2, Response to Comments - Page 8

____________________________________________________________ Prince of Wales Outfitter and Guide Management Plan
(Sue Jennings explained the reasoning behind keeping the Central WAAs guide free and how the 

alternatives were developed.)

If we don’t keep guided hunters out of the Craig Circle, then they will take it to the Subsistence 

Board and will get the area taken out that way. They have been keeping Sealaska out for 

subsistence reasons and will keep the Forest Service out. 

The Council concern is mostly hunting. Dennis is also concerned about Klawock River 

steelhead and guided anglers in smaller streams. There used to be bigger and more steelhead in 

the Klawock River and now it seems over fished because the fish are fewer and smaller. The 

same overfishing concerns apply for the Karta River. 

Guided fly fishers are picking on the small streams and ruining the fishing there. These small 

streams cannot bounce back like the Klawock and Karta Rivers. There is a great fear that the 

guides that fish these smaller streams will wipe out the fish populations. 

Guides come to POW and don’t live here. They pressure the delicate system in areas that don’t 

have many people and when the spring steelhead run is done, they take people out salt-water

fishing. 

He is worried that with the economy the way it is that more people will start guiding to 

supplement their income. 

The lodge at Steamboat Bay is putting on more pressure. 

A certain about of guiding is good but it is good at the expense of other people, both their 

lifestyle and monetarily. 

Mr. Watson sees this EA as creating a conflict and not preventing one. 

There is already too much. He would like to see less – any increase will create more conflict. 

South Kanku Harbor lease let to a guiding lodge, now other boats can’t pull in there even in the 

offseason, because they get tangled up in anchors. 

Heceta Lodge on Camp Island now you can’t get close to shore when the weather is bad so the 

area is more dangerous. 

When someone gets an economical gain, it is by taking something from someone else. 

Zero alternative – why don’t we have that. Dennis would only be happy with the status quo or 

less. 

Mike Douville does not like interactions. He would not like more. The island is totally utilized in 

areas and in resources; it doesn’t take much to upset the balance. 

Keeping guides out of the central WAAs does not address Craig’s concerns. As the stands close 

in within the Central WAAs, then hunting pressure will be more concentrated in other areas 

where people are hunting now. Don’t see how the central WAAs offset impacts as the area 

constricts. 

Mr. Watson is also concerned about the Sealaska Lands Bill. Where are the guides going when 

Sealaska gets their land? The whole EA will need to be rethought when the Bill goes through. 

If we do not have the right decision, at least four cities and four tribes will be filing appeals on it. 

Mr. Watson would rather see a good decision and not have to hassle with appeals. 

DW-12

DW-13

DW-14

DW-15

DW-16

DW-17

DW-18

DW-19

DW-20

DW-21

DW-22

DW-23

DW-24

DW-25

DW-26

DW-27

DW-28

____________________________________________________________________________________

Appendix 2, Response to Comments - Page 9

____________________________________________________________ Prince of Wales Outfitter and Guide Management Plan
It is a great concern that we are on the outside looking in to the process. 

It seems arbitrary means of determining how many people will go into each place each year. 

This is a unique area and not one size fits all. 

Notes by Sue Jennings

DW-29

DW-30

____________________________________________________________________________________

Appendix 2, Response to Comments - Page 10

____________________________________________________________ Prince of Wales Outfitter and Guide Management Plan
Response to Dennis Watson/Craig City Council’s Comments (DW) 

DW-1 

We are sorry that you feel that the Craig City Council comments were summarily 

dismissed. We assure you that comments were considered and used to develop issues 

and alternatives in the EA. Issue 1 specifically addresses the conflict with subsistence 

hunting near communities (EA page 11), which is the major concern stated in the Craig 

City Council comments. Alternatives 3 and 4 include a limit on the number of hunting 

service days allocated to outfitters and guides at no more than 40 service days per area 

during the fall hunting season (EA page 19). This limit was added partially in response 

to the City of Craig comments. Under project monitoring, there is a requirement to 

monitor the number of deer and bear harvested by hunt each year and to re-evaluate hunts 

if conflicts arise (EA page 24). Impacts to subsistence are analyzed in Chapter 3 starting 

on EA page 52. This analysis includes the City of Craig’s request for a "local use area" 

near Craig (EA page 53) and includes the map supplied in the City of Craig comments 

(Figure 3-2). Table 2-1, on the next page, shows how the alternatives address hunting 

near communities for the areas specified in the City of Craig comments. Please note that 

both Alternatives 3 and 4 have a lower number of fall deer hunting service days than the 

Proposed Action (Alternative 2) in response to the City of Craig concerns. See also 

Table 3-1 on page 59 of the EA. The comments from the City of Craig were not 

summarily dismissed but included throughout the analysis and document. 

DW-2 

The interdisciplinary team (IDT) did consider a zero allocation alternative but eliminated 

it from detailed analysis (EA page 15). The zero alternative was eliminated because 

Forest Service regulations and the Forest Plan allow for and encourage outfitter and guide 

permitting as an economic opportunity. A zero alternative also does not meet the 

Purpose and Need. In NEPA, a zero alternative is not required. Section 1502.14(d) 

requires the alternatives analysis to "include the alternative of no action." The Council on 

Environmental Quality states 'There are two distinct interpretations of "no action" that 

must be considered, depending on the nature of the proposal being evaluated. The first 

situation might involve an action such as updating a land management plan where 

ongoing programs initiated under existing legislation and regulations will continue, even 

as new plans are developed. In these cases "no action" is "no change" from current 

management direction or level of management intensity. To construct an alternative that 

is based on no management at all would be a useless academic exercise. Therefore, the 

"no action" alternative may be thought of in terms of continuing with the present course 

of action until that action is changed.' 

In the case of the Prince of Wales Outfitter and Guide EA, the no action alternative is a 

continuation of the current use. Timber sales are an example of the second way to look at 

the no action alternative. The no action alternative is usually no timber harvest - it is a 

yes or no question on whether to harvest timber. This option is used because there is no 

current management of a stand trees. Since outfitters and guides are already authorized 

on Prince of Wales, we looked at the no action as a continuation of the current 

management, which meets our direction. 

____________________________________________________________________________________

Appendix 2, Response to Comments - Page 11

____________________________________________________________ Prince of Wales Outfitter and Guide Management Plan
Table 2-1: Service Days Allocated to Outfitting and Guiding* in Areas of Concern Listed 

in the City of Craig’s Scoping Comments 

Recreation 

Use Area Access 

Highest 

Actual 

Annual 

Use 

Recreation 

Visitor 

Capacity 

Service 

Days (SD)

Alternative 

1 - No 

Action - 

Current 

Permitted 1

Alternative 2 

- Proposed 

Action - 

50% of 

recreation 

visitor 

capacity 

(SD) 

Alternative 3 

- 25% of 

recreation 

visitor 

capacity (SD) 

Alternative 

4 (SD) 

Arena Cove Shore 2 282 141 71 22 

Bobs Place Shore 3 847 424 212 33 

Hole In The 

Wall Shore 17 282 34 141 71 37 

Nossuk Bay Shore 15 2,822 828 1,411 706 911 

One Duck 

Lake Road 2 2,117 1,059 529 22 

One Duck 

Road System Road 1 2,117 1,059 529 11 

Point Dolores Shore 4 2,822 1,411 706 22 

Port Alice Shore 3 847 424 212 33 

Port Refugio Shore 8 2,822 1,411 706 55 

Port Santa 

Cruz Shore 1 2,822 1,411 706 22 

Steamboat 

Bay Shore 2 309 155 77 55 

Suemez 

Island Road 

System 

Shore 12 3,091 1,546 773 13 

Tlevak 

Narrows Shore 12 2,822 1,411 706 143 

Trocadero 

Creek Road 7 635 9 318 159 10 

Total2 24,637 9 12,322 6163 1389 

* Note not all service days are for hunting – service days can be for hunting, fishing, wildlife 

viewing, or any other outfitted or guided activity. 

1

 Alternative 1 – rows have blanks if there is no 2011 permitted use in these areas; however, 

these areas have been used by outfitters and guides in the past and will probably be 

requested for use in the future. 

2

 The number of service days in this “total” row was calculated using decimals, whereas data 

shown in the columns above were rounded to whole numbers. Thus, the columns do not add 

up exactly to match the total due to rounding. 

DW-3 

There are many reasons that people choose to visit an area. The experience that each 

person seeks is unique, and one person's desolate landscape is another's inspiration. 

____________________________________________________________________________________

Appendix 2, Response to Comments - Page 12

____________________________________________________________ Prince of Wales Outfitter and Guide Management Plan
DW-4 

Use has increased at El Capitan Cave in the past 3 years with the increase of the small 

cruise ship visitors. El Cap has a finite capacity because only so many tours can be 

performed during a day. Full capacity has not yet been met at the cave. 

DW-5 

The marine anchorage is out of the scope of this project. The Forest Service does not 

manage the area below mean high tide. Portions of Cape Pole are private land, not 

managed by the Forest Service. On NFS land near Pole Anchorage, there has been a 

small amount of guided bear hunting during the spring season, which ends June 30th. 

DW-6 

Hole in the Wall is restricted from outfitter-guide use during the high use season of July 

and August (EA, page 90). 

DW-7 

You are correct, the Craig City Council pointed out areas of concern in their scoping 

comments. They also provided a map of their areas of concern. This map is Figure 3-2 

on page 55 of the EA. Hunting pressure on the areas near Craig and the other 

communities on Prince of Wales were considered in the EA analysis (EA page 39, 

Subsistence section starting on EA page 51, and Table 3-1). Although the City of Craig 

voiced the concern, we assumed that other communities on Prince of Wales would have 

very similar concerns about hunting near their communities. For this reason, the analysis 

focused on hunting days within 15 miles of any community on Prince of Wales. This 

balanced analysis treats all communities equally, while including analysis of the Craig 

"local use area". 

DW-8 

Arena Cove is difficult to get to unless there is great weather; this limits its use. Based 

on monitoring, there has been no evidence to show overcrowding or competition for use 

of this beach (e.g. little sign of use on the beach, no encounters with other users during 

periodic checks). There has been a small amount of guided big game hunting at Arena 

Cove. By analyzing Arena Cove in this EA, we are prepared with numbers and 

mitigation measures, if an outfitter or guide requests use at Arena Cove. 

DW-9 

Alternative 1 considers an allocation to outfitter and guide use that is not an increase over 

the current allocation for this area. According to our records, displayed on page 57 of the 

EA, Tlevak Narrows received a high use of 7.6 service days in 2008. This equates to 7.6 

days out of 161 total days for subsistence hunting. Hunting conflicts in the area may be 

due to unguided hunters. 

DW-10 

The Forest Service does not manage marine areas. Guides tend to self-manage based on 

the needs and desires of clients. Hence if clients are negatively affected by crowds of 

fishing boats, then the guides may wait for a different time to visit this site or may go to 

another permitted site. 

____________________________________________________________________________________

Appendix 2, Response to Comments - Page 13

____________________________________________________________ Prince of Wales Outfitter and Guide Management Plan
DW-11 

The Forest Service does not manage marine areas. 

DW-12 

Calls for subsistence wildlife proposals are issued in January of odd numbered years. 

Instructions for how to submit proposed changes to subsistence regulations can be found 

on pages 14 and 15 of the Management Regulations for the Harvest of Wildlife on 

Federal Public Lands in Alaska (2011-2012). We have shared also your concerns with 

the Alaska State ANILCA office who forwarded your concerns on to the State agencies 

with jurisdiction over your concerns. If the Federal Subsistence Board closes the Craig 

Circle to guided hunting, we would not permit outfitters and guides in that area (EA page 

9). 

DW-13 

The Klawock River is not on Forest Service land and therefore the Forest Service does 

not permit guided fishing there. Fishing restrictions were recommended by Forest 

Service fisheries specialists seen in Alternatives 2 and 4 in small streams to protect these 

runs. There is no guided fishing permitted on the Karta River. 

DW-14 

The State of Alaska Department of Fish and Game manages harvest and sets sport fishing 

harvest regulations. If there is concern regarding a fish population being "wiped out" due 

to sport fishing, ADF&G is the agency that would take emergency action to close an area 

or stream to sportfishing. Outfitters and guides that are permitted by the Forest Service 

for service days to take clients to fish small streams also must follow ADF&G 

sportfishing regulations. 

DW-15 

Guides can take clients to remote areas that do not have many people. The Forest Service 

fisheries specialists assessed each stream that receives guided use and made 

recommendations on number of guided user days per year, with timing restrictions on 

certain streams. As described in response to comment DW-14, the ADF&G is 

responsible for the sustainability of fish and wildlife on all lands in Alaska and regulates 

freshwater harvest limits for sportfishing. Saltwater sportfishing is not managed by the 

Forest Service. Alternatives 2 and 4 have outfitter-guide fishing restrictions to maintain 

steelhead, summer run coho, and sockeye runs. The restrictions limit the number of 

service days and timing available to outfitter-guides (EA, page 26). 

DW-16 

Prince of Wales guided numbers decreased during the recent economic down-turn, more 

than likely due to the fact that non-local clients have less disposable income to spend on 

travel and guided trips. In the last two years, there have been new requests for service 

days so there is demand for the number of service days to increase. The size of the 

increase will depend on requests and the alternative selected for implementation. 

____________________________________________________________________________________

Appendix 2, Response to Comments - Page 14

____________________________________________________________ Prince of Wales Outfitter and Guide Management Plan
DW-17 

This is a private lodge and they may be providing skiffs from their lodge, which is not on 

National Forest System lands so they are not guiding or outfitting on Forest Service 

lands. We have no control over what the lodge does with clients on their land. 

DW-18 

The carrying capacity formula and this environmental assessment were designed to take 

into account different user groups and their resource needs. We feel it is possible to 

permit use in a way that minimizes conflicts with traditional uses and unguided 

recreationists. Permits allow the Forest Service to limit use in areas while moving use to 

under used areas, thus, reducing conflicts. 

DW-19 

We agree with Mr. Watson that there may be areas where conflict occurs between guided 

groups and other guided or unguided individuals. People like to recreate, hunt, and fish 

in the same areas, whether guided or unguided. The EA addresses ways to deal with the 

conflicts through the Elements and Assumptions Common to All Alternatives (EA page 

15 - 17) and Adaptive Management (EA page 20-22). The elements common to all 

alternatives include no guided big game hunting in WAAs 1318, 1319, 1421, and 1422 

(Central WAAs Closure); no big game outfitter and guiding within one mile of 

communities, recreation cabins, campgrounds, or picnic areas or within one mile of the 

Karta River, Karta Lake, or Salmon Lake; and limited outfitter and guide use in most 

Wilderness areas. Through Adaptive Management, guided use can be reduced or 

eliminated based on resource concerns and the number and content of complaints. The 

EA also makes assumptions about group size, limiting groups to a maximum size of 12 

people with a group size of six for hunting and fishing groups (EA page B-17). 

Permitting allows the Forest Service to limit or restrict use in areas to protect resources 

and reduce conflicts, while encouraging outfitters and guides to use under used areas. 

Unguided users will have no restrictions, except in areas where there are resource 

concerns. 

DW-20 

Alternative 1 considers an allocation to outfitter and guide use that is not an increase over 

the current allocation for this area. 

DW-21 

The Forest Service does not manage areas below mean high tide. The State of Alaska 

manages areas below mean high tide. We provided your comments to the State. 

DW-22 

The Forest Service does not manage areas below mean high tide. The State of Alaska 

manages areas below mean high tide. We provided your comments to the State. 

____________________________________________________________________________________

Appendix 2, Response to Comments - Page 15

____________________________________________________________ Prince of Wales Outfitter and Guide Management Plan
DW-23 

The EA states that people can continue to enjoy POW recreation and subsistence 

opportunities in the same way they do now; a decision on this project will not regulate 

unguided use (EA page 3). It also states that, "Title 8 of ANILCA assures that a 

subsistence priority will be met for federally qualified subsistence users. Residents of all 

Prince of Wales communities have a positive Customary and Traditional Use 

determination for all waters above the mean high tide line" (EA page 57). Most of the 

outfitter and guide activities do result in an economic benefit for the company that is not 

at the expense of someone else. Based on use from 2004-2008, 52.9% of the guided use 

on POW was from passive touring (nature viewing, sightseeing, wildlife viewing) [EA 

page 11]. Passive touring does not take anything from the island other than pictures and 

memories. There were a total of 6,917 passive touring service days from 2004-2008, 

averaging about 1,384 service days per year (EA page B-21). Camping and active 

touring (biking, hiking, kayaking) combined for a total of 1,318 service days from 2004-

2008, which averages out to about 264 service days per year (EA page B-21). 

Based on your other comments, your concern is related to hunting and fishing, which 

make up 12.2% and 24.3% respectively, of the guided use (EA page B-11). From 2004-

2008, there were a total of 1,756 hunting service days for an average of about 351 per 

year. There were a total of 3,240 fishing service days in the five years for an average of 

648 fishing service days per year (EA page B-21). This level of use was analyzed in the 

subsistence section of the EA stating on page 51, the wildlife section starting on page 65, 

and the Fisheries and Hydrology section starting on page 107. The EA found that guided 

recreationists have not had any meaningful effect on deer abundance or distribution. It 

goes on to state that competition for deer may occur between guided sport hunters and 

subsistence users, and recreationists using hunting areas during hunting season may 

occasionally limit access to subsistence users. However, the EA also states that guided 

recreationists are not expected to contribute significantly to restrictions in access or 

competition in the foreseeable future (EA page 64). For fisheries, none of the alternatives 

in this project are expected to result in a significant possibility of a significant restriction 

for subsistence resources through changes in abundance and distribution, access, or 

competition, because fishing restrictions in Alternatives 1, 2, and 4, and regulatory 

controls under all alternatives, protect fisheries resources. Outfitters and guides are not 

authorized to collect or harvest other subsistence resources (EA page 51). 

DW-24 

The interdisciplinary team (IDT) did consider a zero allocation alternative but eliminated 

from detailed analysis (EA page 15). The zero alternative was eliminated because Forest 

Service regulations and the Forest Plan allow for and encourage outfitter and guide 

permitting as an economic opportunity. A zero alternative also does not meet the 

Purpose and Need. In NEPA, a zero alternative is not required. Please see response to 

DW-2. The current level of permitting is considered the no action alternative. 

DW-25 

We agree that there needs to be a balance of uses on the island and that the balance can 

be upset without careful consideration of all the resources and people's concerns. The 

analysis in the EA shows that most areas have not reached the limit on the amount of 

____________________________________________________________________________________

Appendix 2, Response to Comments - Page 16

____________________________________________________________ Prince of Wales Outfitter and Guide Management Plan
recreation that can occur, based on the recreation visitor capacity formula. Some of these 

areas have reached the number of outfitter and guide service days available for use based 

on Forest Plan standards and guidelines; however, some areas do have room for 

expansion of outfitter and guide activity (EA Table 2-1). Appendix B of the EA 

discusses how the visitor capacity was analyzed, which includes a discussion on group 

size (page B-17) and encounters (page B-18). As provided for in the Forest Plan, the 

discussion on encounters shows that the number of people or groups you may encounter 

depends on where you are located. In primitive areas, like Wilderness, we expect that 

you will not encounter more than three people or groups in a day. In roaded areas, we 

expect that you will encounter up to 10 groups or people in a day. So, in areas along the 

road systems near communities, you should expect to encounter more people than when 

in Coronation Island Wilderness. We recognize that for some this number of encounters 

may be higher than they want. For others, this number of encounters may seem low 

compared to other National Forests. 

DW-26 

Retention of the Central WAAs closure was not intended to address Craig's subsistence 

concern alone. All communities on POW Island have subsistence priority, and the 

combination of the Central WAAs Closure and the cap on hunting service days across all 

sites described in Alternatives 3 and 4 are intended to address subsistence concerns fairly 

for all communities on POW Island. As described in the EA and Wildlife Resource 

Report, the Central WAAs are centrally located relative to all communities on POW 

Island. Of the 14 communities on POW, 11 are within 15 miles of at least one of these 

Central WAAs. This area is important for local subsistence hunters because it contains 

most of the current and future huntable young growth. Approximately 48% of all young 

growth currently <10 years old occurs within the Central WAAs. As you suggest, much 

of the currently huntable young growth on POW Island is approaching the stem exclusion 

stage, at which it will become less attractive for deer and deer hunters. However, roughly 

82% of the stands likely to be harvested soon, (those that are already NEPA cleared or 

under contract) occur within the Central WAAs closure area as well. This means that 

most of the future huntable young growth on POW Island will occur within the Central 

WAAs Closure where there will be no competition with guides as long as the closure is 

retained. Most subsistence hunters prefer to hunt in young clearcuts or alpine, and the 

Central WAAs closure prevents guided hunters from blocking access to preferred hunting 

habitats where those habitats are most concentrated in the Zone. 

The 40 service day cap on fall hunting service days by site was intended to reduce 

competition between subsistence and guided hunters all across the POW Zone. The 

number of days was limited to 40 because that would allow some growth for guides in 

most areas, but would not allow guided hunters to use any given site for either fall bear or 

deer hunting for more than 25% of the hunting season, which is currently 161 days long. 

DW-27 

We agree that the outfitter and guide use areas will need to be reviewed when a Sealaska 

Lands Bill is passed. The Forest Service cannot stop managing the National Forests 

because Congress is considering legislation. When legislation becomes law, we take a 

look at our projects to ensure they meet the law. This is part of the standard operating 

____________________________________________________________________________________

Appendix 2, Response to Comments - Page 17

____________________________________________________________ Prince of Wales Outfitter and Guide Management Plan
procedure for the Forest Service. We address reductions in the Adaptive Management 

section of the EA, "Permit administrators would follow direction in Forest Service 

Handbook 2709.11 Chapter 40, Section 41.53 and Forest Service Handbook 2709.14 

Chapter 50, Section 53 to make the reductions. In cases where reductions were needed, 

the permit administrator would work with the outfitter or guide to determine if the 

permitted activities could be accommodated at a different area with similar attributes and 

available service days" (EA pgs. 22 and 23). 

DW-28 

We would all like to see a good decision and not have to “hassle with appeals”. The 

Decision Framework in Chapter 1 of the EA explains how the District Rangers will make 

their decision on which alternative to select and implement. Specifically, the Framework 

states that the Rangers will allocate "...a portion of the total recreation use for outfitter 

and guide use while taking into account the needs of unguided users and forest resources" 

(EA page 8). Your comments and the all of the other comments and concerns will be 

considered as part of the decision. The Rangers will also look at impacts to forest 

resources, laws, and regulations to determine which alternative to select. Hopefully, you 

will find that the decision is the "right decision"; however, if you still have concerns, then 

an appeal would be appropriate. 

DW-29 

We are sorry that you feel that you are "outside looking in to the process". We started 

requesting public involvement and concerns in April of 2007. This request included 

tribes, tribal corporations, outfitters and guides, and many other groups and individuals. 

Posters and notices were posted in Thorne Bay and Craig (EA page 9). In March 2010, 

through government to government consultation, the Rangers let the tribes know that we 

planned to start NEPA in the fall of 2010. Scoping on the proposed action was sent in 

February 2011; we received 18 comments. Open houses were held in March 2011 in 

both Craig and Thorne Bay. These comments are in response to the release of the EA in 

April 2012. No decision will be made on which alternative to select and implement until 

after all the comments and government to government consultations are considered. We 

have tried to include everyone interested in the process. 

DW-30 

We agree, all of the sites in the project area have unique characteristics and one size does 

not fit all. Through the Recreation Visitor Capacity Analysis (Appendix B), we tried to 

take some of those unique characteristics into account when determining the number of 

people that could recreate at each site. The Visitor Capacity Analysis looks at how many 

recreationists a site could accommodate each year, not how many will go into each place 

each year. Basically, we tried to determine if a site was more like an elevator or a 

conference room. The elevator can fit up to 10 people at a time, while a conference room 

could fit 50 or 60. Some recreation use sites can only accommodate a few people, like 

Aats Bay, while other sites can accommodate many, like Dog Salmon Fishpass Viewing 

site. The formula was not arbitrary, it looked at actual use at each site, types of use, ease 

of access to the site, group size, season of use, and the Forest Plan suggested number of 

encounters. To eliminate the need to set specific dates and times of use at each location, 

the formula also includes a temporal displacement factor (EA page B-20). This factor 

____________________________________________________________________________________

Appendix 2, Response to Comments - Page 18

____________________________________________________________ Prince of Wales Outfitter and Guide Management Plan
reduces the number of days available at each site depending on how much management 

oversight occurs. To eliminate any arbitrary decisions on capacity, this formula was used 

for every recreation use area. 

 

____________________________________________________________________________________

Appendix 2, Response to Comments - Page 19

____________________________________________________________ Prince of Wales Outfitter and Guide Management Plan
From: johnnie laird [mailto:muskegex@yahoo.com] 

Sent: Wednesday, May 09, 2012 5:18 PM

To: Slayton, Melanie -FS

Cc: Leslie, Scott J -FS

Subject: EA comments

Mel ... 

 

I submitted my comments through the auto response on the EA's web site. 

 

I am sending along a copy to you just to make sure that it is received. 

 

Thanks ........... Johnnie 

 

 

I have been directly involved in the Unit #2 hunting issues for many years. I have had USFS Use 

permits since 1983 (hunting Guiding permits since 1994). 

I am very glad that we are getting this new EA as the current EA we have been working under is 

very out dated. 

 

*********************** 

Important issues to me that are noted in the EA are:

 

Outfitters and guides need opportunities for business growth on Prince of Wales Island to 

maintain their businesses and increase the local economy. 

 

Permit administrators will annually monitor number of use days by sites for guided deer hunting. 

Outfitters and guides will be required to report the number of deer or bear harvested by hunt each 

year. If conflicts arise at particular sites, biologists and permit administrators will re-evaluate the 

permit allocations for these sites.

 

In compliance with the Alaska National Interest Lands Conservation Act of 1980 

(ANILCA), this document analyzes the potential effects of proposed land use activities on 

subsistence uses and needs, and includes a distinct finding on whether the proposed action may 

significantly restrict subsistence uses.

 

Use higher than the visitor recreation capacity would not be allowed in any alternative. If higher 

use (unguided plus guided use) is identified through monitoring in any recreation use location, 

administrative action may be taken to limit outfitter and guide use. 

 

Unguided visitors would not be limited, unless resource damage is occurring. If resource damage 

is occurring (for example, trail erosion), visitors may be detoured away from the affected area 

until the concern can be resolved. 

 

The action alternatives are designed to minimize environmental effects and meet Forest Plan 

standards and guidelines. Some measures are required in all areas. Some measures are specific to 

JL - 1

____________________________________________________________________________________

Appendix 2, Response to Comments - Page 20

____________________________________________________________ Prince of Wales Outfitter and Guide Management Plan
location. These design elements and mitigation measures will be implemented through outfitter 

and guide permit conditions and administration of the permits. 

 

******************* 

 

These along with other measures will assure that all problems including those within the 

Subsistence arena can and will be addressed. 

 

Alternative #2 is the best choice. 

 

Thank you ....... Johnnie Laird 

JL – 1,

Cont.

____________________________________________________________________________________

Appendix 2, Response to Comments - Page 21

____________________________________________________________ Prince of Wales Outfitter and Guide Management Plan
Responses to Johnnie Laird’s Comments (JL) 

JL-1 

Thank you for your comment, your preference for Alternative 2 was considered before a 

decision was made. 

____________________________________________________________________________________

Appendix 2, Response to Comments - Page 22

____________________________________________________________ Prince of Wales Outfitter and Guide Management Plan
____________________________________________________________________________________

Appendix 2, Response to Comments - Page 23

____________________________________________________________ Prince of Wales Outfitter and Guide Management Plan
Responses to Michael Douville’s Comments (MD) 

MD-1 

Road closures do not equate to hunting closures, but restrict access to means other than 

motorized vehicles. Many hunters prefer to hunt along closed roads because competition 

with those that hunt from a vehicle is reduced along closed roads. The designated hunter 

program provides a means for subsistence users to meet their subsistence needs if they 

are physically unable to hunt. Cumulative effects of large scale timber harvest were 

recognized in the Forest Plan FEIS (2008) as contributing to a significant possibility of a 

significant restriction for subsistence deer over the course of rotation assuming full 

implementation. However, the POW Zone applies silvicultural treatments to 

approximately 2,000 acres of young growth annually; these treatments usually improve 

deer habitat and lengthen the stand initiation stage that provides forage for deer. A large 

percentage of currently huntable and future young growth occurs in the Central WAAs 

closure which would be retained under this project as a place free from competition from 

guided hunters. This project does not affect unguided hunters. See also response to DW26. 

MD-2 

Data provided by ADFG indicate that total hunter numbers and total days hunted in 

WAAs 901, 902, 1003, and 1323 (which make up the bulk of the proposed Craig Circle) 

increased from 2005-2008, but have decreased since then. Guided hunter days across all 

guide use sites in the proposed Craig Circle also increased from 10 location days in 2005 

to 29 location days in 2009. However, 29 guided location days comprise less than 6% of 

total hunter days in the Craig Circle (see graph below). 

 

____________________________________________________________________________________

Appendix 2, Response to Comments - Page 24

____________________________________________________________ Prince of Wales Outfitter and Guide Management Plan
MD-3 

Alternatives 2 and 4 have more restrictions for guided fishing than the current 

management plan that the Forest Service operates under (see Alternative 1, EA page 

119). Forest Service fisheries specialists recommended fish restrictions on number of 

service days allowed and timing on streams with species of concern, including small 

streams, which have limited run size, to address this concern (seen in Alternatives 2 and 4 

EA page 120). The only alternative with higher number of service days allocated for 

guided fishing than what is currently allocated is Alternative 3. 

 

____________________________________________________________________________________

Appendix 2, Response to Comments - Page 25

____________________________________________________________ Prince of Wales Outfitter and Guide Management Plan
Hi Sue,

I would just like to inform you of the following areas that I have conducted hunting activities in for the 

past many years for both black bear and deer and also explain a bit of how it is conducted. 

Since we only report time spent on USFS land our reporting does not portray an accurate calculation of 

the amount of users in a given area or display or demonstrate how much use is actually being done. 

During the spring black bear hunts you are only getting a fraction of the time that we actually spend in 

these areas due to the fact that we are off shore hunting from boats but still are utilizing these areas.

All of my hunting trips are 7 to 10 days in duration and generally 3 to 4 hunters.

Of course I have reported use through all of these years when we have actually went ashore to pursue 

game but what has been reported is only a fraction of the time we spend hunting these areas. Since my 

operation is boat based we spend most of our time hunting the shorelines from boats in the spring and 

only go ashore once we have spotted an animal that we intend to harvest. 

Generally I will have 3 or 4 hunters on these trips but often we may only record being on shore once per 

hunter when they actually harvest an animal. This being said all clients (hunters) hunt these areas every 

day until they harvest their animals even though they may not actually spend time on the forest lands. 

When these activities are being conducted we may be in two or three skiffs or boats hunting the shore 

lines and covering several miles. 

As for hunting in the fall we spend all of our time on the USFS lands since fall is a different scenario in 

regards to how we hunt and I conduct my operations. Bears are in the streams eating fish inland from 

the beaches and of course deer are inland as well so we do utilize National Forest during this time.

Following is a list of some of the specific areas that we hunt nearly every trip. In addition to these 

specific areas we also hunt all areas in-between while cruising to our next destination hunting the 

shorelines along the way. 

I conduct hunting operations beginning at Kasaan Peninsula and run north around the northern end of 

POW and then south to Salt Lake Bay. This area is GOA's 02-03 & 02-04. The following areas are where I 

tend to conduct most of my hunting activities.

POW LOCATIONS -- Exchange Cove, Lava Creek, Salmon Bay, California Bay, Red Bay, Buster Bay, 

Merrifield Bay, Humpy Creek, Labouchere Bay, Hole In The Wall, Shakan Bay, Calder Bay, Dry Pass, El 

Capitan Passage, Nossuk Bay, Salt Lake Bay.

Kosciusko Is. Locations -- Shakan Bay, Dry Pass, El Capitan Passage, Devilfish Bay, Tokeen Bay, Shipley 

Bay, Cape Pole, Halibut Harbor, Survey Cove, Trout Creek, Fishermans Harbor, Pole Anchorage, Holbrook 

Arm, Seaotter Sound, Davidson Inlet.

Hamilton Island, Divide Island, Middle Island, Marble Island, Tokeen Island, Tuxekan Is, Heceta Island.

All of the above locations I have hunted every year for the past nearly 20 years and are vital to the 

viability of my business and livelihood. Simply put, without the ability to continue to operate my hunting 

activities in these areas as I have in the past I would not be able to maintain my business and means of 

livelihood. Thank you for your considerations

Sincerely,

Mark Galla

MG - 1

MG - 2

____________________________________________________________________________________

Appendix 2, Response to Comments - Page 26

____________________________________________________________ Prince of Wales Outfitter and Guide Management Plan
DBA -- Alaska Peak & Sea's

Po box 362

Wrangell, Ak 99929

Home/Business phone # 907-874-2454

Cell phone # 907-470-3200

Web site - www.wedoalaska.com

Email - mark@wedoalaska.com

Registered guide license # 763

Sent from my iPad. Mark Galla

____________________________________________________________________________________

Appendix 2, Response to Comments - Page 27

____________________________________________________________ Prince of Wales Outfitter and Guide Management Plan
Response to Mark Galla’s Comments (MG) 

MG - 1 

Thank you for your hunting explanation. As described, guided hunters are using areas 

along the shoreline but outside of Forest Service jurisdiction. We have no means to 

quantify how much time is used outside of Forest Service jurisdiction, but this activity, 

like other boating activities, may contribute to competition with unguided hunters in the 

spring. 

MG-2 

Thank you for the list of areas where you would like to continue to conduct your hunting 

operations. We appreciate site-specific information. Your concerns about maintaining 

your business will be considered before a decision on which alternative to implement is 

made. 

____________________________________________________________________________________

Appendix 2, Response to Comments - Page 28

____________________________________________________________ Prince of Wales Outfitter and Guide Management Plan
Paula Peterson

Kasaan Tribal Association

April 11, 2012, Initial Call 

I spoke with Paula Peterson about the Prince of Wales Outfitter and Guide Management Plan 

EA. These are her comments. 

The Kasaan Tribal Association will have elections on April 19, 2012. She would like to have 

formal government-to-government consultation meetings with the new members after the 

election. 

The Tribal Council does not want any outfitters or guides in their traditional area as shown in 

the Haa Aani – Our Lands Book. The traditional areas are on the map – this is a really good 

book. 

Everybody comes in to hunt deer – so much waste of deer meat, which is left sitting along the 

road to rot. 

Fishermen come in the bay and local people can’t get fish for their personal need. 

Lodges take people out from the lodges – these should be considered commercial users. Paula 

does not think that this use is regulated enough. 

Paula would only allow guided tours in the area if they are not harmful to the environment and 

do not include hunting or fishing.

Notes by Sue Jennings

PP-1

PP-2

PP-3

PP-4

PP-5

____________________________________________________________________________________

Appendix 2, Response to Comments - Page 29

____________________________________________________________ Prince of Wales Outfitter and Guide Management Plan
Response to Paula Peterson’s Comments (PP) 

PP-1 

We have consulted with and had ongoing consultations with the Organized Village of 

Kasaan, the Hydaburg Cooperative Association and the Klawock Cooperative 

Association. We also tried to schedule meetings with the Craig Tribal association. 

PP-2 

We actively consulted with the tribes about their traditional areas as defined on Haa Aani 

and worked with them to see what Outfitter and Guide activities they would accept. 

PP-3 

According to Alaska Hunting Regulations, all meat of the neck, brisket, ribs, front and 

hind quarters, and along the backbone of a harvested deer must be salvaged. Wanton 

waste of big game meat is punishable by a fine of up to $10,000 and one year in jail. If 

you see anyone wasting meat or violating any hunting or fishing regulation, please report 

them to the State or Forest Service office. 

PP-4 

The Forest Service does not manage fishing in marine waters. Restrictions on service 

day allocations for outfitted and guided use recommended by Forest Service fisheries 

biologists accounted for streams and fish runs important for subsistence use. 

PP-5 

When lodges take paying guests onto Forest Service System lands, it is considered a 

commercial use and requires a special use permit. Forest Service staff performs periodic 

checks of popular commercial use locations and communication with lodges to minimize 

unregulated commercial uses. There are existing laws and regulations to deal with illegal 

guiding. 

PP-6 

Thank you for your comment, your concerns were considered before a decision was 

made. 

____________________________________________________________________________________

Appendix 2, Response to Comments - Page 30

____________________________________________________________ Prince of Wales Outfitter and Guide Management Plan
Ron Leighton, Organized Village of Kasaan 

And Sam Thomas, former member of the Craig Tribal 

Association Council

April 26, 2012, Craig Ranger District 

I met with Ron Leighton and Sam Thomas at the Craig Ranger District Office at Sam’s request. Also 

present were Tim Marshall and for the last half of the meeting, Mel Slayton. These are the notes I took. 

In most cases, I did not differentiate between comments made by Ron or Sam because it was a 

conversation and both spoke on most topics. 

Both Ron and Sam requested formal government-to-government consultation more than once in the 

conversation. I did not include each instance in the notes; it is just included here. 

We don’t want this type of program in our area for several reasons. There is not much federal 

land and we are dolling it out to guides for 10 years. We can’t do subsistence on our land or on 

State land. 

These people putting in viewing in Polk Inlet for guided deal in that area is a Shaman’s grave; 

we don’t want this. 

(Tim – They are not allowed to go to those sites.)

I had a bear guide almost shoot me (Ron). 

(The guide or one of his clients shot toward the water and almost hit Ron when he was on the water in his 

boat. Ron was in Little Goose Bay in his skiff, he had to slow down for rocks. When he came out in one 

area, he saw a bear on the beach. A guy shoots at the bear right across his boat. The shot went across 

the bow – if he had been going faster, he would have been shot. This was in April 2011. Ron did not 

report the incident to the FS and feels reporting it now will just cause Ron trouble.) 

We are seeing a lot of orphaned bears due to sow killing. Now the orphans are a problem. 

What makes the guides more important than the locals? 

What have you set aside for us? 

This decision will have an impact for ANILCA. We are concerned about areas around viewing 

sites. On west coast, there is a problem with people viewing sea otters. What kind of effect will 

this viewing have on the sea otter plan? 

You don’t realize what you are doing when you start shoving this stuff in our face. 

Kasaan will be doing an inventory in the traditional areas. While they are doing the inventory, 

bear hunters are shooting from boats and could shoot some of our people. 

Guided deer hunts we are totally against that. How can you bring in out of state people to 

deplete our resource? 

How are you going to police these people? You will have to hire more law enforcement officers 

(LEOs) to monitor the guides and the people from Ketchikan. 

RL-ST - 1

RL-ST - 2

RL-ST - 3

RL-ST - 4

RL-ST - 5

RL-ST - 6

RL-ST - 7

RL-ST - 8

RL-ST - 9

RL-ST - 10

RL-ST - 11

____________________________________________________________________________________

Appendix 2, Response to Comments - Page 31

____________________________________________________________ Prince of Wales Outfitter and Guide Management Plan
One person in Kasaan took eight does and hunted two more for elders. You don’t have a 

designated doe tag. As long as an officer did not stop him, he didn’t put a deer tag on the deer. 

Once he was stopped, he tagged the deer. You never think about the impacts. 

I think it is time to have a real strong consultation on traditional foods and the impacts (Ron). 

There is not a lot of federal land around Kasaan Bay. 

Our specialist may have the answers but they won’t have the right answers. The FS is putting 

this in for a small group of people that will impact the great number of people. Once you start 

permitting people, they have a financial gain and they come into a different light. The feds 

would honor them and not the people. 

It will take time for consultation so will have to take time to do it. We will look at all the 

traditional areas and we may be able to say where they can go year to year. 

Kasaan wants to go into an ecotourism lodge themselves. By doing this you are giving away our 

opportunity for the lodge. 

Polk Inlet people are flying in with planes so we can’t hunt within a few miles of the viewing 

area. I am proposing a deal with elder hunts to hunt in mid-June (Ron). This hunt would be for 

elders and people with disabilities. If there are deer near the viewing area and it is hunting 

season, I will shoot the deer. I have a subsistence priority. You can see how nightmarish this 

deal is. These guys have a right because they have a permit and I have a subsistence right. 

People dump boats from Polk Inlet for people from Ketchikan. They come over and run the 

boats to hunt. There are more and more orphan bears – these are fragile, skinny, small bears by 

themselves. Hunters are not supposed to shoot sows with cubs. Now when people come around 

they push the cubs into hiding. This makes the bears dangerous. 

If you give them a permit, a ten-year permit, they will have paying customers and will displace 

residents. I can’t hunt in the same area. If I am subsistence hunting, they can claim that they 

feel threatened and endangered when I am in the same area. If it goes to court, I would lose 

because the guide has exclusive right and would claim they were threatened. 

(Mel – no commercial permit grants exclusive rights – guides know they must share the areas where they 

are permitted.)

Around Kasaan, there is not much federal land to do early hunt. These are locations where they 

don’t want these activities. They are starting the inventory at the beach and going inland 1⁄2 mile; 

they will log any findings of ancestry and traditional foods. They will propose that certain 

locations are not used. Don’t want anything that will impact subsistence resources. 

There are going to be impacts where there are large groups of people. Guides on luxury liners 

with 50 or 60 people can break into groups of 12 so they spread out in this area being impacted. 

So, there is less area for subsistence. 

Sam is concern about permitting commercial use of fauna. There is a way to permit commercial 

gathering of forest products. 

The State doesn’t recognize the FS system. The state has been telling people in Ketchikan that 

when they go to POW they are considered subsistence gatherers. However, if there is no 

seaweed on Grendel and I can scoot across to Camino to get seaweed; State regulations say I 

need to get a fishing license. I am getting fed up with regulations. We will issue them our own 

licenses so can gather subsistence anywhere. 

RL-ST - 12

RL-ST - 13

RL-ST - 14

RL-ST - 15

RL-ST - 16

RL-ST - 18

RL-ST - 17

RL-ST - 19

RL-ST - 20

RL-ST - 21

RL-ST - 22

RL-ST - 23

____________________________________________________________________________________

Appendix 2, Response to Comments - Page 32

____________________________________________________________ Prince of Wales Outfitter and Guide Management Plan
Subsistence is less than 1% of the consumption and most regulated activity. You have to have a 

pocketful of permits. I’ve been getting harassed out there. I was pulled over by the same person 

on the same day. They have protection acts for everything. They should have a Cultural 

Protection Act, so can gather resources. It would be much like consultation with the Forest. 

Notes by Sue Jennings 

RL-ST - 24

____________________________________________________________________________________

Appendix 2, Response to Comments - Page 33

____________________________________________________________ Prince of Wales Outfitter and Guide Management Plan
Response to Ron Leighton and Sam Thomas’s Comments (RL-ST) 

RL - ST - 1 

Activities that would be permitted under this EA are not mutually exclusive to 

subsistence use. Guided harvest is currently estimated to account for <1% of deer harvest 

on POW Island. The Central WAAs Closure and service day cap for fall hunters found in 

Alternatives 3 and 4, as well as the Rangers' ability to make adjustments as necessary 

should alleviate subsistence concerns. Guided hunters are also not permitted within one 

mile of communities (EA page 16). 

RL - ST - 2 

Forest Service Heritage personnel actively monitor areas used by the outfitters and guides 

to ensure they are not impacting existing cultural sites. Outfitter and guide visits to 

known archaeological sites, like the mentioned shaman’s grave, are not permitted by 

Forest Service in any way. We will continue to work with the island's tribes to ensure 

that sites important to the tribes are protected from impacts by outfitters and guides. 

RL - ST - 3 

This is a serious offense and should be reported to the State Troopers. It is illegal to 

shoot from a boat and the offender should be prosecuted. There are ample laws and 

regulations to deal with this offense. We do not know about and cannot deal with 

incidents like this if they are not reported. 

RL - ST - 4 

Harvest regulations prohibit taking of sows accompanied by cubs in Unit 2 (ADFG 

2011). Sealers are required to look for signs of lactation, and should they be found, 

citations may be issued. 

RL - ST - 5 

The EA specifically states that unguided visitors can continue to enjoy POW recreation 

and subsistence the way they do now (EA page 3). The EA also states that the 

subsistence priority will be met for federally qualified subsistence users as outlined in 

Title 8 of ANILCA (EA page 57). Nowhere in the EA does it state that outfitters and 

guides are more important than any other users. 

RL - ST - 6 

The central WAAs were closed to outfitter-guides for hunting due to subsistence 

concerns; the Karta River corridor was closed to outfitter-guides due to high local use; 

Hole-in-the-Wall is restricted during July and August. 

RL - ST - 7 

Sea otter viewing takes place on the ocean, which is outside the scope of this project. Sea 

otters are protected under the Marine Mammal Protection Act (MMPA). 

____________________________________________________________________________________

Appendix 2, Response to Comments - Page 34

____________________________________________________________ Prince of Wales Outfitter and Guide Management Plan
RL - ST - 8 

We are sorry that you feel that we are "shoving this stuff" in your face. It has always 

been our intention to keep everyone informed and more importantly, involved in this 

project so that we address all sides and all concerns. The first scoping letter went out on 

this project in April 2007, when we were starting to develop the Visitor Capacity 

Analysis (EA page 9). This initial scoping included tribes, tribal corporations, outfitters 

and guides and others that were interested. In March 2010, the district rangers informed 

the tribes that we were planning to start the NEPA process in the fall of 2010, thus, 

starting the formal government to government consultation. At that time, the District 

Rangers tried to determine concerns. During the consultations, the rangers were asked if 

this project would affect subsistence uses and the tribal governments were assured that 

subsistence would not be restricted with any decision for this project. This has been 

confirmed through the analysis in the EA. We sent the Proposed Action out for comment 

on February 14, 2011 and received 18 comments. During the scoping period, we had 

open houses in both Craig and Thorne Bay. The EA was signed in March of 2012 and 

sent to the tribal corporations and governments for an early review. The document was 

mailed to the public at the beginning of April and the 30-day comment period started on 

April 9, 2012. A subsistence hearing was held in Craig on April 26, 2012 and testimony 

was taken. After the 30-day comment period, government to government consultation 

continued through formal meetings. Through all of these public involvement efforts, we 

have asked for feedback, suggestions, and specific areas that should have limited outfitter 

and guide activity. 

RL - ST - 9 

It is illegal to shoot from a boat. There are ample laws and regulations to deal with 

offenders. Shooting without knowing the target, is poor hunting practice by any hunter. 

Precautions are necessary in the field. Guides are required to follow all regulations and 

must be licensed by the State of Alaska. If you see anyone shooting from a boat, please 

inform the State Troopers. 

RL - ST - 10 

Nonresident hunters currently make up 8% of deer hunters on POW Island, and are 

generally less successful than are resident hunters (42% successful). Nonresident hunters 

have increased on POW between 1998 and 2009, but not all nonresident hunters are 

guided. Residents of Unit 1B (Ketchikan) make up 45% of deer hunters on POW Island 

and take an average of 751 deer annually (28% of deer harvested on POW annually). 

Local residents (those that live in Unit 2) make up 47% of the hunters on POW Island 

and have the highest success rate (75%). Most harvest of deer from nonlocal hunters is 

from resident Ketchikan hunters. 

RL - ST - 11 

Outfitter-guide fees are used for monitoring, enforcement and enhancement. An increase 

in outfitter-guide use warrants an increase in law enforcement. The Forest Service LEOs 

do not monitor the people from Ketchikan; that is the responsibility of the State of 

Alaska. In addition to LEOs, Forest Service permit administrators monitor the outfitters 

and guides. Other Forest Service employees note where and when they see outfitters and 

____________________________________________________________________________________

Appendix 2, Response to Comments - Page 35

____________________________________________________________ Prince of Wales Outfitter and Guide Management Plan
guides, what activities they are doing, and how many clients. This information is used to 

check actual use at the end of each year. 

RL - ST - 12 

Harvest tickets are required for deer and must be carried in the field. Tickets must be 

validated by cutting the month and day immediately upon killing a deer and must be used 

in sequential order. Subsistence hunters are required to report harvests using a joint 

State-Federal harvest report. If members of the public witness poaching, they should 

report the offense to enforcement officers immediately so that an investigation can be 

conducted. 

RL - ST - 13 

This is a topic that applies to more than the Outfitter Guide EA and it is a part of ongoing 

government to government consultation on this EA and on other fronts. 

RL - ST - 14 

Current management allows any outfitter or guide to come in and request service days for 

any area. Permit administrators do an analysis just around that site to determine if 

outfitter and guide activity is okay. Because the analysis is small-scale, most of the time 

permits are issued. As you can see from Alternative 1, there are already outfitters and 

guides permitted on POW. The intent of the EA is to determine the number of service 

days to issue to outfitters and guides in each recreation use area, based on a landscape 

and site-specific recreation analysis. We started with the Visitor Capacity Analysis and 

determined how much recreation can occur at each recreation use area without causing 

resource damage. Based on the capacity, we developed a proposed action, which meets 

Forest Plan standards and guidelines. We sent out the proposed action for comment. 

From the 18 comments we received, we developed three alternatives, each with fewer 

service days then the proposed action. Our goal is to balance guided use with unguided 

use so that everyone is treated fairly. The environmental analysis will limit permitted 

activity more than the current management strategy, due to the visitor capacity and 

selected alternative. The point isn't to put everything in for a small group but to balance 

uses to meet the needs of everyone. 

RL - ST - 15 

The Forest Service actively worked with each of the tribes to further define their 

traditional areas and how the Forest Service can protect those in manner that preserves 

their importance and use by the tribes, but also allows for a certain amount of permitted 

use. 

RL - ST - 16 

Kasaan can get a special use permit to operate on federal land, just like any other outfitter 

or guide, if capacity is available. If competition occurs and more service days are 

requested than available, then the Forest Service may do a prospectus to determine the 

number of service days given to each operator. Outfitter-guide permits do not authorize 

exclusive use. 

____________________________________________________________________________________

Appendix 2, Response to Comments - Page 36

____________________________________________________________ Prince of Wales Outfitter and Guide Management Plan
RL - ST - 17 

Over flights of aircraft do not preclude subsistence hunting. Calls for subsistence wildlife 

proposals are issued in January of odd numbered years. Instructions for how to submit 

proposed changes to subsistence regulations can be found on pages 14 and 15 of the 

Management Regulations for the Harvest of Wildlife on Federal Public Lands in Alaska 

(2011-2012). If elder hunts are approved by the Board of Game, the Forest Service would 

follow the stipulations in the approval. Due to safety concerns, the FS is seeking a 1/4 

mile hunting restriction in the vicinity of Dog Salmon Fishpass to prevent viewer/hunter 

conflicts. 

RL - ST - 18 

If someone is paid to stage a boat for a hunter, that person is outfitting and must have the 

proper permits. Otherwise, they are subject to state and federal citations. Harvest 

regulations prohibit taking of sows accompanied by cubs in Unit 2 (ADFG 2011). 

Sealers are required to look for signs of lactation, and should they be found, citations may 

be issued. 

RL - ST - 19 

Safe hunting regulations and ethics apply to guided and unguided users. Outfitter-guide 

permits do not authorize exclusive use in an area and this EA does not limit unguided 

users. If you feel there is a conflict, please contact the permit administrators at the Forest 

Service office. 

RL - ST - 20 

Calls for subsistence wildlife proposals are issued in January of odd numbered years. 

Instructions for how to submit proposed changes to subsistence regulations can be found 

on pages 14 and 15 of the Management Regulations for the Harvest of Wildlife on 

Federal Public Lands in Alaska (2011-2012). Forest Service outfitter and guide permits 

stipulate that all regulations must be followed, including those made by the Alaska Board 

of Game, Alaska Board of Fisheries, and the Federal Subsistence Board (EA page 9). 

RL - ST - 21 

Luxury liner season ends in September before the fall hunting season. The EA 

specifically states that other than hunting and fishing, there will be no gathering so there 

is no competition for food stuffs (EA page 7). Passengers aboard luxury liners do not 

enter the woods much and when they do it is usually on a well-defined trail. 

RL - ST - 22 

The EA specifically states that the analysis does not include any type of collecting (EA 

page 7). Collecting would not be allowed as part of outfitting or guiding. 

RL - ST - 23 

Residents of Ketchikan do not have subsistence priority. This project pertains to 

allocations and permitting of Outfitter and Guides and does not establish additional 

regulation for anyone else. These issues are beyond the scope of this analysis. 

____________________________________________________________________________________

Appendix 2, Response to Comments - Page 37

____________________________________________________________ Prince of Wales Outfitter and Guide Management Plan
RL - ST - 24 

These comments are beyond the scope of this analysis and this project. This project only 

relates to outfitters and guides and does not relate to permitting for subsistence users. 

____________________________________________________________________________________

Appendix 2, Response to Comments - Page 38

____________________________________________________________ Prince of Wales Outfitter and Guide Management Plan
May 14, 2012

Mr. Francisco B. Sanchez

District Ranger 

Craig Ranger District

P.O. Box 500

Craig, AK 99921-9998

Subject: Comments to POW Outfitter-Guide Management Plan EA

Dear Mr. Sanchez:

Thank you for the opportunity to comment on the POW Outfitter-Guide Management Plan 

Environmental Assessment, although I wish the FS could time these things so they did not 

occur during a time when we are extremely busy preparing for our seasons.

In reviewing the EA I was struck by several troublesome issues that would affect my business, 

and my position as a long-standing Outfitter/Guide in my local area. My concerns can be 

summarized in the words of the EA starting on Page 78: 

“All of the alternatives would allocate more service days to most sites than have been used in the 

past. Between 2004 and 2009, the highest number of service days reported for any year was in 

2006 at 2,848 service days for all sites combined. This amounts to approximately 14% of the 

days allocated in Alternative 1, 2% of the days allocated in Alternative 2, 3% of the days 

allocated in Alternative 3, and 11% of the days allocated in Alternative 4. Exceptions to this 

pattern are sites where past use has been high. This would include sites such as Dog Salmon 

Fishpass and Klakas Inlet. 

Should outfitter-guide use rise to the levels allowed under any of these alternatives, it would 

result in a dramatic increase in all of the potential impacts described for wildlife as outlined 

above. For example, if outfitter-guide use increased enough to fully utilize the allocation in 

Alternative 1, it would amount to a seven-fold increase in service days used across the Zone, 

whereas the increase associated with Alternative 2 would amount to a fifty-fold increase. Some 

species, particularly those sensitive to disturbance from human activities, may experience

negative consequences such as disruption of feeding, reproduction, or other factors affecting 

short-term population levels. Though this analysis has assumed full implementation of 

allocations under each alternative, impacts to human recreation and social factors would likely 

cause a re-evaluation of these allocations long before major effects would occur to wildlife. This 

assumption is based on the nature of scoping comments received and POW residents’ low 

tolerance for sharing recreation and subsistence sites compared to people from other parts of the 

country. 

 

Adaptive management may be implemented to change allocations or other outfitter and guide 

management based on monitoring, observations, or feedback we receive during implementation 

of this project. In most cases, if adaptive management is implemented, it will result in a 

____________________________________________________________________________________

Appendix 2, Response to Comments - Page 39

____________________________________________________________ Prince of Wales Outfitter and Guide Management Plan
reduction of permit allocations or other management technique designed to reduce effects on 

affected resource/s; these management adjustments would likely either have no effect on or 

reduce effects on wildlife. In cases where adaptive management results in an increase in permit 

allocations, the allocations and their effects will not exceed the greatest allocations and effects 

described in this analysis. 

Generally speaking, the estimated disturbance to wildlife is greatest for Alternative 2, followed 

by Alternatives 3, 4 and 1, respectively. This is based solely on the number of days allocated 

under each alternative. This pattern holds true for all but 32 of the 209 Outfitter-Guide Use sites. 

Most sites that do not hold to this pattern are sites where current permitted service days already 

exceed 25% or even 50% of estimated recreation visitor capacity.”

I will try to address my concerns and preferences for each Alternative in sequence:

Alternative 1, the No Action Alternative (and my Preferred Alternative): Apart from the fact 

that it doesn’t meet “current Forest Service Handbook direction for outfitter and guide 

management (FSH 2709.14, Chapter 50, Section 53)” and would need tweaking to address 

some already high use areas (which presumably could be dealt with using Adaptive 

Management measures), this alternative would still provide sufficient Service Days (“a sevenfold increase across the Zone”) for the foreseeable future and would appear to be the least 

disruptive to current established O/Gs and the Forest, while still providing controlled growth 

opportunities. This conservative approach has considerable merit in my view. I’m not sure how 

we get around the FSH problem, but if the Handbook doesn’t meet the needs of the users or 

the Forest, perhaps it needs to be revised so that it does!

Alternative 2, the Preferred Alternative: This begs the question: Preferred by whom? It 

proposes increases in Service Days that are quite frankly, stunning, and throughout the EA 

appears to carry the most negative of consequences not in keeping with good stewardship of 

the Forest. A selection of quotes from the EA:

Page 79:

“Generally speaking, the estimated disturbance to wildlife is greatest for Alternative 2, followed 

by Alternatives 3, 4 and 1, respectively. This is based solely on the number of days allocated 

under each alternative. This pattern holds true for all but 32 of the 209 Outfitter-Guide Use sites. 

Most sites that do not hold to this pattern are sites where current permitted service days already 

exceed 25% or even 50% of estimated recreation visitor capacity. Effects to individual species 

are described below.” 

“As described above, overall, Alternative 2 has the greatest likelihood of disturbance to deer of 

any alternative, followed by Alternatives 3, 4, and 1, respectively.” 

Page 80

“While the estimated impact to deer populations is higher for alternatives that allocate higher 

service days (Alternative 2 in particular), the actual use is more important. We have no good 

means to anticipate future changes in use.” 

SCL - 1

SCL - 2

____________________________________________________________________________________

Appendix 2, Response to Comments - Page 40

____________________________________________________________ Prince of Wales Outfitter and Guide Management Plan
Page 82

“Alternative 2 poses the greatest impact to Threatened, Endangered, and Candidate species 

because it allocates the most days and therefore offers the greatest opportunity for outfitter and 

guide access to shoreline sites via marine habitats important to these species. Following 

Alternative 2, Alternatives 3 and 4 pose the next greatest impact, respectively, and Alternative 1 

poses the least impact because it allocates the fewest service days for marine access sites.” 

Alternative 2 has one redeeming characteristic, according to the EA, that overrides all other 

considerations:

“Chapter 3, Affected Environment and Environmental Consequences – Page 104 

This alternative has the highest number of proposed service days, which would offer 

operators the greatest opportunity for growth and stability2. 

 

2 

If an action alternative is selected for implementation, outfitters and guides may get 10-year priority use 

permits, which would allow businesses the opportunity for long term planning and investment. This could lead 

to stability in the outfitter and guide industry.”

I could not disagree more. Virtually unlimited, open access to finite natural resources, 

whether they be fish, game, wilderness, or the limited O/G sites of the Forest, is an invitation to 

chaos, and instability, particularly for long-standing operators who have developed their 

operations over many hard years and during recent economic downturns. Open access often

invites operators who consider only their own financial gain and have little regard for the

natural resources they are using. They incur additional enforcement and monitoring costs and 

more than occasionally do not live within the parameters of their permits. We have learned this 

lesson the hard way many times in resource management. 

Furthermore, the operative word in the quote above (“guides may get 10-year priority use 

Permits”) is the word “may.” That does not suggest or instill any sense of stability. 

Why is the Forest Service advocating this path? Where is this perceived demand going to 

come from? Who wants this increase in Service Days? Certainly not the small, established 

businesses that have forged out an operation over the years, only to see it jeopardized by 

largely unnecessary and unwarranted open access to the FS lands on POW. 

Alternative 3, The Dog Salmon Creek Fish Pass Alternative: Although the Beaver Falls 

Trail is also part of the exception that this alternative provides, Dog Salmon Creek is part of my 

O/G permit area and is of particular concern to me.

In the chart on Page 28 of the EA, access to all of the Dog Salmon Creek areas, including the 

popular Fish Pass, is described as being by road. While that is technically correct; there is a 

road leading to a trail that accesses the Fish Pass, in practice the greatest amount of access is 

via the Forest Service dock in Polk Inlet near the mouth of Dog Salmon Creek. 

SCL – 2

Cont.

SCL – 3

____________________________________________________________________________________

Appendix 2, Response to Comments - Page 41

____________________________________________________________ Prince of Wales Outfitter and Guide Management Plan
The dock is small. It will accommodate one floatplane on its face, and a small boat on each 

side of the dock if the boats do not interfere with the wings of a floatplane on the face. 

In both Alternative 2 and 3, the greatly expanded access contemplated for the Dog Salmon 

Fish Pass will simply not work until and unless additional development of the Forest Service 

dock in Polk Inlet is provided. Without those improvements there will be considerable conflicts 

between the existing O/Gs authorized to use the area, and in fact, in my opinion, the air taxi 

operator currently using the facility will itself have difficulty in utilizing any increased allocation 

of Service Days above what is already authorized for the operation.

Another aspect of the EA which is not addressed, and which comes into play at the Polk Inlet 

Forest Service dock, is the question of priority use among competing O/Gs in an area. My O/G 

permit has been in use for a decade and a half, yet my access to the Polk Inlet dock has on 

occasion been preempted in recent years by a less “senior” O/G with a large allocation of 

Service Days. Somehow that does not seem equitable. I do not begrudge the larger operator 

his increased access to the Fish Pass at all. There is certainly economic benefit from that 

access to the Forest that is proper and justified. But when my operation is denied access, or 

my right to be at the Polk Inlet dock is questioned by a newcomer O/G, then we have a 

problem. 

The original concept of an Outfitter/Guide envisioned one person, with perhaps an assistant 

guide or two, being responsible for an individual, or a small group of hunters, fisherpersons or 

other outdoor adventurers. That concept is changing. It appears that larger operations are 

becoming more prevalent and are demanding more access to the designated O/G sites. I 

suspect that is the impetus for this proposal. 

Given the new paradigm, it would seem reasonable to insist that Outfitter Guides (including 

their employees) who share access to common sites, be made aware of other O/Gs who have 

Service Days allocated at the site. Perhaps this could be accomplished as part of the 

permitting process. Further, it would be useful to establish access priority based on seniority as 

an O/G at each site(s) instead of access being determined by default according to the number 

of Service Days an operator is allocated. Long-standing operators would have some measure 

of protection by such a policy. 

Incidentally, on Page 78, the chart does not include a ranking for the Dog Salmon Fish Pass. 

Why is that very high use area not included?

Alternative 4, the 10% Alternative: This alternative would appear to work well with Adaptive 

Management to adjust the problem areas. The EA cites “administrative burdens” associated 

with the alternative but does not specify what they are. This alternative would be my second 

choice after Alternative 1, because it is the next most conservative alternative.

SCL – 3

Cont.

SCL – 4

SCL – 5

SCL – 6

SCL – 7

SCL – 8

____________________________________________________________________________________

Appendix 2, Response to Comments - Page 42

____________________________________________________________ Prince of Wales Outfitter and Guide Management Plan
In Summary: I fail to see the need to rush into the stunning increases in Service Days 

recommended by the Preferred Alternative, and even Alternative 3, when the current SD

allocations for the most part are not being used. Obviously there are a very few high use areas 

that need attention, however they should be addressed in a more surgical manner rather than 

the wholesale, scattergun approach being suggested to increase SD allocation. 

While the FS may have technical and administrative reasons to update policies in order to

comply with the FSH/FSM and the Forest Plan, etc., it is difficult to understand the justification 

for the remainder of the Purpose and Need when, with but a few exceptions, there is largely no 

demand for the SD allocation already provided. 

The questions cannot be ignored: Who wants this increase in SDs? Is there a political agenda 

here? Are we opening up POW for industrialized guided operations? Who will be served by the 

huge access increases being proposed in the Preferred Alternative? And why are across-theboard increases being recommended (up to “fifty-fold”) when currently there is a demand for 

only 14% of the days used across the Zone at the highest rate established in 2006?

Certainly not the established Outfitter Guides and the residents of Prince of Wales Island.

Respectfully,

L. G. McQuarrie 

Larry “Mac” McQuarrie, Owner

Southeast Alaska Sportfishing Adventures, Inc. 

dba Sportsman’s Cove Lodge

Office: 907-247-7252

Fax: 907-247-7255

Cell: 907-617-2790

E-mail: captainmac@alaskasbestlodge.com

SCL – 9

SCL – 10

SCL – 11

____________________________________________________________________________________

Appendix 2, Response to Comments - Page 43

____________________________________________________________ Prince of Wales Outfitter and Guide Management Plan
Response to Sportsman’s Cove Lodge/Larry McQuarrie’s 

Comments (SCL) 

SCL - 1 

Alternative 1 considers an allocation to outfitter and guide use that is not an increase over 

the current allocation for this area. According to our records, displayed on page 57 of the 

EA, Tlevak Narrows received a high of 7.6 service days in 2008. Alternative 1 does not 

meet the Forest Service Handbook because it does not allow for a growth in permitted 

outfitter and guide service days, this is not the addition of new outfitters and guides but 

allows currently permitted outfitters and guides to increase their number of service days. 

Alternative 4 was designed to allow a 10% growth opportunity for the outfitter-guides, 

which meets Forest Service Handbook direction. 

SCL -2 

Alternative 2 is the proposed action, not the preferred alternative. A preferred alternative 

was not identified for this project. The Proposed Action (Alternative 2) was developed 

based on the Forest Plan direction that states, generally 50% of an area's use capacity 

may be allocated to outfitter and guide use. The Proposed Action does not allow for 

unlimited access to resources. If Alternative 2 were selected, permit holders would have 

to follow stipulations on the permit that limit access to specific permitted areas (EA page 

7 - 8). Carrying capacity figures were determined based on a formula that incorporated 

several different variables such as Land Use Designation, Recreation Opportunity 

Spectrum, and travel mode (see carrying capacity analysis, Appendix B, for details). 

Other alternatives are being considered that have far less days allocated to outfitter and 

guide use. With Alternative 2, fishing would be limited based on the 1998 EA and no big 

game hunting would be allowed in the Central WAAs. There are also limits on some fish 

streams to protect sockeye, steelhead, and coho salmon stocks. Included in all of the 

alternatives are restrictions on use within Wilderness areas (EA page 4). Permits would 

be issued in ways to limit conflict (EA page 21). The advantage of permitting is that new 

use can be limited to areas where there will not be conflicts. Current outfitter and guide 

use will be considered before new permits are issued. 

Your quote from the EA is correct; guides "may" be issued 10-year permits. We used the 

word may because all current and future guides may not meet the criteria for a 10-year 

use permit. For example, if a permit holder has no previous record of supplying outfitter 

or guide services, then a 2-year priority use permit could be issued. If an outfitter or guide 

meets all of the criteria for priority use permits, they could be issued 8 more years on a 

priority use permit. The 10-year permit would instill a sense of stability since the 

permittees would know how many service days they have available for the next 10 years. 

The way outfitter and guide permits are issued now, there is open access to the FS lands 

on POW. Currently, there are no limits established in any of the recreation use areas. 

This analysis established a carrying capacity for all the recreation use areas used by 

outfitters or guides, thus, setting a limit on use for the first time. Any decision will 

establish a limit on the number of service days available to outfitters and guides. Rather 

than open access, this document limits access based on resource and social concerns. This 

____________________________________________________________________________________

Appendix 2, Response to Comments - Page 44

____________________________________________________________ Prince of Wales Outfitter and Guide Management Plan
is accomplished by taking a landscape level and site-specific view of outfitter and guide 

activity on both ranger districts. 

SCL -3 

The increases considered for the developed recreation sites: Dog Salmon Fish Pass and 

Beaver Falls were established because these sites are developed recreation sites, with 

hardened facilities that can better handle increased visitor use while protecting resources. 

The potential to increase use at these sites is an option that the Forest Service wanted to 

make sure was analyzed during this assessment, but it does not have to be selected as part 

of any of the alternatives. The dock as a limiting factor for use of this site was not 

considered for this assessment. Due to competition at the dock, it is likely that increased 

use at the dock would lead to a prospectus. Also, the dock could be expanded in the 

future, possibly through fee enhancement money, which is money that returns to the 

district for the purpose of enhancing outfitter and guide use areas. 

SCL -4 

Permitted outfitter and guides who have days at the Polk site should not be excluded from 

use of this site; however, we acknowledge that this competition exists. The capacity of 

the Polk dock was not considered during this assessment. Competition at the dock may 

be addressed through a prospectus, arranged timing, or expansion of the dock. 

SCL -5 

The impetus for this proposal is a national initiative to manage recreation use and 

resources in a more proactive rather than reactive manner. Although Prince of Wales 

Island has not experienced high use rates that would lead to a lawsuit, such use has 

occurred in other parts of the Tongass National Forest. This assessment is an attempt to 

manage outfitter and guide use and resources before problems occur. 

SCL -6 

When a decision is made on which alternative to implement, all outfitters and guides may 

be issued a 10 year permit, so their standing would be the same. Through lawsuits, the 

Courts have decided how much information the Forest Service can give out about guide 

activity because business information is proprietary. We will consider suggestions for 

implementation. Adaptive Management, as discussed on page 20 of the EA, is the 

process that would allow the FS to make adjustments to the allocation and/or 

management of locations. If adaptive management fails to resolve conflicts, a prospectus 

may be used to regulate allocations. 

SCL -7 

Ranking for Dog Salmon Fish Pass is discussed on page 77, ranks for alternatives were 

Alternative 3, 2, 4, and 1, respectively, from highest impact to lowest. 

SCL -8 

The description of the administrative burden, along with an example, can be found on 

page 99. In short, Alternative 4 would create an administrative burden because it 

incorporates the fishing restrictions and would require an immediate redistribution of use 

for fishing at 26 locations, but the ability to redistribute is limited by the low availability 

____________________________________________________________________________________

Appendix 2, Response to Comments - Page 45

____________________________________________________________ Prince of Wales Outfitter and Guide Management Plan
of additional days in other locations. If Alternative 4 is selected, it is likely that a 

prospectus for freshwater fishing will be required. 

SCL -9 

We do not have a preferred alternative. The proposed action is based on the Forest Plan 

standards and guidelines and is our starting point for this analysis. It is precisely our 

intent to manage individual locations in a surgical manner. With an outfitter-guide 

management plan, we have the ability to manage outfitter-guide services cumulatively, 

over a longer period of time. This saves both time and money, and through adaptive 

management, to add or remove locations, and adjust allocations, as indicated by 

monitoring. Although the process appears to be a "scattergun approach", it is, in fact, a 

"surgical" tool. Through monitoring, we can identify locations that are high use, and then 

make adjustments. Having additional use available at other locations allows us to move 

outfitter-guides to those locations. This prevents conflicts and resource degradation, but 

doesn't require additional analysis, which would cost more money and time. The 

landscape level approach allows us to see the whole picture and not just focus on the high 

use areas. 

SCL -10 

The ranger districts on Prince of Wales Island do get requests for outfitter and guide 

permits on a regular basis. In the last two years, while we have been working on this 

environmental document, several requests have been made for additional sites. Permits 

have not been issued because our priority was to complete this document and monitor the 

use for two years (EA page 22). As you can see from the comments on the EA, some 

people feel there are currently conflicts between guided and unguided users, others feel 

that there is room to grow and wish to expand the number of permitted service days, and 

others do not see the need to increase the number of outfitter and guide permits. This 

environmental analysis lets us ask the questions about use and allows us to analyze on a 

landscape level the effects of outfitter and guide activities. There is a demand for new 

outfitter and guide permits, in 2011 there were nine new requests and in 2012, there were 

three new requests. In 2011, there were 5,818 service days service days requested, 

which included 2 requests for 20 (total) bear hunts that were denied. InnerSea 

Discoveries, a small cruise ship, was permitted 4,620 service days. In 2012, 650 service 

days were requested. In the last two years, the requested activities were bear hunting 

(denied), fishing, hiking, camping, and cave tours. 

SCL -11 

As stated in the response to SCL-2, the current policy is open access and unlimited 

outfitter and guide growth. This analysis sets limits on outfitter and guide growth, while 

allowing for expansion in some areas. There is no political agenda, we are responding to 

regulations that require an overall (landscape) look at outfitter and guide activities. This 

required look allows us to look at cumulative effects of outfitter and guide use across 

both districts. Since this plan is for more than 10 years, we need to look at long range 

use. The EA looks at a range of alternatives, as required by law. We started with the 

Forest Plan standards and guidelines, which would have a fifty-fold increase. This is our 

proposed action. Based on comments, concerns, and issues, we developed two more 

alternatives, each successive alternative had a lower allocation than the proposed action. 

____________________________________________________________________________________

Appendix 2, Response to Comments - Page 46

____________________________________________________________ Prince of Wales Outfitter and Guide Management Plan
This is how environmental analysis works; we develop a proposed action based on our 

purpose and need, regulations, and the Forest Plan and send that out to the public for 

review and comment (scoping). Based on these comments we develop alternatives to the 

proposed action. We send out our analysis of the alternatives for review and comment. 

Based on the analysis, public comment, laws and regulations, the District Rangers decide 

on which alternative to implement. Your input will be considered before any decisions is 

made. We assume that there will be more requests for service days in the future. 

____________________________________________________________________________________

Appendix 2, Response to Comments - Page 47

____________________________________________________________ Prince of Wales Outfitter and Guide Management Plan
May 7, 2012 

Kent Nicholson, Acting District Ranger 

Tongass National Forest, Thorne Bay Ranger District

P.O. Box 19001 

Thorne Bay, AK 99919-0001 

Francisco Sanchez, District Ranger

Tongass National Forest, Craig Ranger District

P.O. Box 500 

Craig, AK 99921 

Dear Mr. Nicholson and Mr. Sanchez: 

The State of Alaska reviewed the March 2012 Prince of Wales Island Outfitter and Guide 

Management Plan Environmental Assessment (EA). The following comments represent the 

consolidated views of the State’s resource agencies.

We appreciate the Plan’s clear acknowledgement that the public and the commercial transporters 

they depend upon will not be affected by this plan, and recommendations for increased allocation 

of service days to outfitters and guides, with the exception of a few highly utilized areas. 

Outfitters and guides provide unique opportunities to the visiting public and local residents who 

may not have the means or skills to access public lands on their own, particularly for hunting or 

fishing. 

Although the Wilderness Needs Assessments are now available for public review, as we noted in 

our scoping comments, the plan still lacks clearly identified user conflicts in the low use 

designated wilderness areas to justify closing specific areas to certain types of outfitting and 

guiding. We recommend leaving these low use areas available for all types of outfitter and guide 

activities. A monitoring process and adaptive management would likely address any future 

issues that develop, i.e., a specific conflict can be adaptively addressed by the appropriate 

administrative entity (federal or state) using the appropriate tool. In certain instances, state 

management tools may be more effective than federal tools, so we recommend looking at all 

available options. 

The EA indicates that service days will be restricted where there are fish “species of concern” in 

the proposed action (Page 40). We understand that the Service considers steelhead, sockeye, and 

coho species of concern due to their importance to subsistence users, relatively low abundance, 

 

 ANILCA IMPLEMENTATION PROGRAM

 Office of Project Management and Permitting

SEAN PARNELL, Governor

550 W. 7TH AVENUE, SUITE 1430

ANCHORAGE, ALASKA 99501

PH: (907) 334-2563 / FAX: (907) 269-5673

nina.brudie@alaska.gov

____________________________________________________________________________________

Appendix 2, Response to Comments - Page 48

____________________________________________________________ Prince of Wales Outfitter and Guide Management Plan
and run timing. The Alaska Department of Fish & Game (ADF&G), which is responsible for the 

sustainability of fish and wildlife on all lands in Alaska, identifies fish stocks of concern using 

three categories: yield, management, and conservation. If fish stocks of concern require 

regulatory action, we request the Service utilize the appropriate regulatory entity, i.e., the Alaska 

Board of Fisheries or the Federal Subsistence Board. Any unilateral efforts by the District to 

minimize user conflicts, based solely on allocation concerns, would circumvent these existing 

regulatory processes. ADF&G is available to assist the Service during preparation of Board 

proposals, if necessary. 

Lastly, the Affected Environment Wilderness discussion (Page 87), which focuses on “generally 

prohibited” activities in designated wilderness is incomplete and inaccurate. While the Alaska 

National Interest Lands Conservation Act (ANILCA) is referenced, there is no recognition of 

several relevant provisions, including Sections 1315 regarding cabins, and 1316 regarding 

temporary facilities and equipment related to the taking of fish and wildlife, which provide 

exceptions for wilderness areas in Alaska. In addition, Section 1110(a) states, “the Secretary 

shall permit, on conservation system units...nonmotorized surface transportation...subject to 

reasonable regulation” which includes mechanized modes of transportation, such as bicycles. 

Section 811 provides for subsistence access, “The Secretary shall permit on public lands... 

surface transportation traditionally employed...subject to reasonable regualation.” Any 

restrictions to ANILCA protected access in designated wilderness, including group size limits, 

must be implemented by formal regulation. While the Forest Plan may “generally prohibit” 

groups greater than 12 individuals, to our knowledge no such limit has been implemented by 

regulation. We request the final plan provide a broader discussion of ANILCA exceptions and 

recognize that the encounter rates and group size limits addressed in the Forest Plan are 

guidelines and, unless implemented by regulation, are not prohibitions. 

Thank you for the opportunity to comment. Please contact me at (907)334-2563 if you have any 

questions or concerns.

 Sincerely,

 

 Nina Brudie 

 ANILCA Project Coordinator 

cc: Susan Magee, ANILCA Program Coordinator 

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Appendix 2, Response to Comments - Page 49

____________________________________________________________ Prince of Wales Outfitter and Guide Management Plan
Responses to State of Alaska, ANILCA Implementation Program’s 

Comments (State) 

State - 1 

The Wilderness Act prohibits all commercial services within wilderness areas 

(Wilderness Act, Section 4 (c)). Forest Service Handbook direction notes that, “when 

conducting a needs assessment for outfitting and guiding activities in a wilderness area, 

to assess whether these activities are necessary for realizing the recreational or other 

wilderness purposes of the area and the extent to which the activities may be authorized 

consistent with maintaining the wilderness character of the area” (FSH 

2709.14.53.1f(1)(a)). The EA has identified an adaptive management approach where 

additional or new uses might be considered when a guide can demonstrate that their use 

would model appropriate wilderness practices and incorporate awareness for wilderness 

values in their interaction with clients and others (Element 7 WSC). The types, extent, 

and amount of use by outfitters and guides identified by the wilderness needs assessment 

are consistent with the management requirements for the protection of the wilderness 

character and wilderness resources as required by law. The Forest Service is required to 

protect the wilderness character and resources first (Blackwell vs. High Sierra Hikers). 

State - 2 

The Forest Service will utilize the appropriate regulatory entity to address fish stocks of 

concern that require regulatory action. 

State - 3 

There are several specific sections of ANILCA that are identified in the letter. Some of 

the sections of ANILCA identified by the State do not relate to the proposed use in this 

analysis. Since they do not relate to management of outfitting and guiding, they are not 

included in the EA. The sections of ANILCA that generally relate to outfitter and guide 

management are addressed in the document. 

State - 4 

The EA addressed the sections of ANILCA that were relevant to the activities to be 

approved through a decision on this project. On page 7, the EA specifically says that; 

“this analysis will not address or authorize development of new recreation structures, 

ground disturbing activities...” 

For example, ANILCA Section 1315(c), (d) addresses existing public use cabins and the 

installation of new public facilities where necessary for the protection of public 

safety. The use of public cabins by guides is discussed on pages 86 and 87 of the 

EA. The installation or development of new recreation structures is outside the scope of 

this analysis. 

ANILCA Section 1316 addresses all public lands where the taking of fish and wildlife is 

permitted. This section notes that the existing and future establishment and use of 

facilities and equipment are subject to reasonable regulation where they are directly and 

necessary related to such activities. Similar to the above example, a new facility would 

involve ground disturbing activities which will not be addressed in this analysis. 

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____________________________________________________________ Prince of Wales Outfitter and Guide Management Plan
The management of ANILCA provisions regarding activities in congressionally 

designated wilderness is provided in Region 10 Supplement 2320-2008-2. When 

addressing the public use of motorized transportation and mechanized equipment for the 

taking of fish and wildlife this direction states that; 

“Equipment use authorized by Section of 1316 of ANILCA shall include all 

equipment directly and necessarily related as practical necessity to the taking of fish 

and wildlife but shall not include motorized forms of transportation other than 

snowmachines, motorboats, or airplanes. Use of such equipment is subject to 

reasonable regulations. The use of motorized equipment such as chainsaws of such 

activities shall be by permit.” (R10 Supplement, FSM 2326.1) 

State - 5 

You are correct in that ANILCA 1110(a) and Section 811 do allow for non-motorized 

transportation methods for traditional activities and for travel to and from villages and 

home sites. However, a bicycle is not specifically identified in ANILCA as an approved 

use. The determination of the use of motorized equipment/mechanical transport to 

implement the provisions of ANILCA is a determination specifically reserved to the 

Regional Forester and is outside the scope of this analysis (R10 Supplement, FSM 

2326.04b) 

State - 6 

Groups size limits in wilderness areas follow the direction provided in the Forest 

Plan. The Forest Plan embodies the provisions of the National Forest Management Act, 

implementing regulations, and other guiding documents. The multiple-use goals and 

objectives, and the land use prescriptions and standards and guidelines, constitute a 

statement of the Forest Plans’ management direction. Group size guidelines for 

wilderness were developed and incorporated into the Forest Plan. The EA notes that a 

group of more than 12 is generally prohibited. While a District Ranger may consider 

adjusting group sizes for a specific request, a request of this nature is currently outside 

the scope of this analysis since the analysis must address uses that are expected in the 

reasonably foreseeable future. Our records show that the average group size in 

wilderness has been four people; the largest group recorded anywhere on POW is 12 

people. Also, group size within the wilderness was addressed in the Forest Plan, and a 

reexamination of this issue is outside of the scope of this analysis. 

State - 7 

The limited number of activities identified on page 87 of the environmental analysis, 

address issues related to guided uses. Questions raised in this comment letter regarding 

other sections of ANILCA were addressed in the EA if they were related to the proposed 

use in this analysis or left out if they were outside of the scope of the analysis. 

 

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Appendix 2, Response to Comments - Page 51

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References Cited 

USFWS. 2010. Subsistence management regulations for the harvest of wildlife on Federal 

public lands in Alaska. Effective July 1, 2010 – June 30, 2012. Office of Subsistence 

Management. 137 pp. http://alaska.fws.gov/asm/index.cfml

Alaska Department of Fish and Game. 2011. 2011-2012 Alaska hunting regulations governing 

general, subsistence, and commercial uses of Alaska’s wildlife. 128 pp. 

http://hunt.alaska.gov

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